Environmental Protection
Agency
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Office of Water (MC 4608T)
EPA817-R-08-001
October 2008
www.epa.gov/safewater
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Water Security Initiative: Consequence Management Plan Guidance
Foreword
The Water Security initiative is a U.S. Environmental Protection Agency (EPA) program that addresses
the risk of intentional contamination of drinking water distribution systems. Initiated in response to
Homeland Security Presidential Directive 9, the overall goal is to establish recommendations for the
design and deployment of contamination warning systems for voluntary adoption by drinking water
utilities. EPA is implementing the Water Security initiative in three phases: (1) development of a
conceptual design that achieves timely detection and appropriate response to drinking water
contamination incidents; (2) demonstration and evaluation of the conceptual design in full-scale pilots at
drinking water utilities; and (3) issuance of guidance and conduct outreach to promote voluntary national
adoption of effective and sustainable drinking water contamination warning systems. Figure F-l
summarizes this process.
Phase
Approach
Scope
Design
Specificity
Funding
DESIGN
System Architecture
DEMONSTRATE
Initial Pilot
Additional Pilots
EXPAND
Voluntary National Adoption
<^'T/ Applied by^T/
Apply to single Evaluate multiple Evaluate
Conceotual , N pilot utility I l> utilities I > Convert to
Conceptual ^^ i/ i/ guidance for
gn f> n A> j/ -^^^
AC N/ i \\ N/y
V 7 Refine < \ / Refine L ^
^ and ^ and
enhance enhance
Not
applicable
Low
ll
High-
Applies to pilot utility only
&.,,&
li^ A
High-
Appliesto each pilot
EPA Funds
fHf
Medium -
Applies to range of utilities
Utility Funds
Figure F-1. Overview of EPA's Water Security Initiative
A contamination warning system should be a proactive approach to managing threat warnings that uses
advanced monitoring technologies/strategies and enhanced surveillance activities to collect, integrate,
analyze, and communicate information. However, it should not be merely a collection of monitors and
equipment placed throughout a water distribution system to alert of intrusion or contamination, but rather
an exercise in information acquisition and management. Different information streams should be
captured, managed, analyzed, and interpreted to recognize potential contamination incidents in time to
respond effectively. While the contamination warning system should be designed by the drinking water
utility, some data sources may be outside of the utility, and in this case, cooperation with partners would
likely be important to the success of a contamination warning system. Figure F-2 illustrates the
recommended components of a contamination warning system, as briefly described below:
Online water quality monitoring involves monitoring for typical water quality parameters
throughout the distribution system, and comparison with an established base-state to detect
possible contamination incidents.
Sampling and analysis involves the collection of distribution system samples that are analyzed
for various contaminants and contaminant classes for the purpose of establishing a baseline of
contaminant occurrence (contaminants detected, levels detected, and frequency of detections) and
method performance, as well as for the purpose of investigating suspected contamination
incidents triggered by other monitoring and surveillance components.
October 2008
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Online Water
Quality
Monitoring
Water Security Initiative: Consequence Management Plan Guidance
Enhanced security monitoring includes the
equipment and procedures that detect and respond
to security breaches at distribution system
facilities.
Consumer complaint surveillance enhances and
automates the collection and analysis of consumer
calls reporting unusual water quality concerns and
compares trends against an established base-state
to detect possible contamination incidents.
Public health surveillance involves the analysis
of health-related data sources to identify illness in
the community that may stem from drinking water
contamination.
Figure F-2. Multi-Component Approach
to a Contamination Warning System
Developing a contamination warning system should also include extensive consequence management
planning to develop procedures for investigating and responding to possible contamination incidents
detected through the recommended routine monitoring and surveillance components. Once a possible
contamination incident has been identified, the consequence management plan should define a process for
establishing the credibility of the suspected incident, the response actions that may be taken to minimize
public health and economic consequences, and a strategy to ultimately restore the system to normal
operations.
In the context of the Water Security initiative, the deployment of a contamination warning system should
include the six phases illustrated in Figure F-3. EPA is developing a suite of guidance to assist utilities
through this process, all of which will be available at EPA's Water Security initiative website
(http://cfpub.epa.gov/safewater/watersecurity/initiative.cfm) upon publication.
APPLICATION OF
Implementation
Preliminary
Testing
Operation and
Maintenance
Evaluation and
Refinement
THIS GUIDANCE
Figure F-3. Recommended Stages of Contamination Warning System Deployment
The document that follows, Interim Guidance on Developing Consequence Management Plans for
Drinking Water Utilities, was written to assist utilities with the development of plans to guide the utility
and partner agencies through the processes of validating, responding to, and recovering from a
contamination incident in the distribution system. This interim guidance manual will be revised as
needed based on findings of the demonstration pilots and public comment prior to being issued in final
form. A companion document, Interim Guidance on Developing an Operational Strategy for
Contamination Warning Systems, was written to assist utilities with the development of recommended
standard operating procedures for day-to-day operations of the monitoring and surveillance components
of a contamination warning system. Together, the operational strategy and the consequence management
plan should comprehensively document procedures that guide operation of the contamination warning
system.
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
Disclaimer
Note to Readers: The U.S. Environmental Protection Agency (EPA) prepared this guidance to help you
enhance the security of your water system. This document does not impose legally binding requirements
on EPA, states, tribes, or the regulated community, and it may or may not apply to a particular situation,
depending on the circumstances. EPA, state decision-makers, and drinking water utilities retain the
discretion to adopt approaches that may differ from this guidance. Any decisions regarding a particular
community water system should be made based on applicable statutes and regulations. Therefore,
interested parties are free to raise questions and objections about the appropriateness of the application of
this guidance to a particular situation, and EPA will consider whether the recommendations or
interpretations in the guidance are appropriate in that situation based on the law and regulations. EPA
may change this guidance in the future. To determine whether EPA has revised this guide or to obtain
additional copies, contact the Safe Drinking Water Hotline at 1-800-426-4791 or visit the EPA's Water
Security website at www.epa.gov/watersecurity.
Any mention of trade names, companies, products, or services in this guidance does not constitute an
endorsement by the Environmental Protection Agency of any non-federal entity, its products, or its
services.
Questions concerning this document should be addressed to:
Jeffrey Pencil
U.S. EPA Water Security Division
1200 Pennsylvania Avenue, NW
Mail Code 4601M
Washington, DC 20460
(202)564-0818
Fencil.Jeffrey@epa.gov
or
Brian Pickard
U.S. EPA Water Security Division
1200 Pennsylvania Avenue, NW
Mail Code 4601M
Washington, DC 20460
(202) 564-0827
Pickard.Brian@epa.gov
Request for Comments
EPA is soliciting suggestions and recommendations to make this interim guidance manual more complete
and user-friendly. Commenters are encouraged to be as specific as possible and to provide references
where appropriate. Submit suggestions by e-mail to: watersecurity@epa.gov and indicate that the
message relates to the "Interim Guidance on Developing an Operational Strategy for Contamination
Warning Systems."
October 2008 iii
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Water Security Initiative: Consequence Management Plan Guidance
Acknowledgements
EPA's Office of Ground Water and Drinking Water would like to recognize the following individuals and
organizations for their assistance and contributions in development of this document:
City of Cincinnati - Greater Cincinnati Water Works
Steve Allen Bill Fromme
Patty Burke David Hartman
Faye Cossins Jim Holly
Yeongho Lee
Mark Menkhaus
Jeff Swertfeger
U.S. Environmental Protection Agency - Office of General Counsel
Cindy Anderson
Leslie Darman
Carrie Wehling
U.S. Environmental Protection Agency -Regions
David Apanian (Region 4)
Greg Grover (Region 6)
Maureen McClelland (Region 1)
Kevin Reilly (Region 1)
Patti Kay Wisniewski (Region 3)
U.S. Environmental Protection Agency - Office of Ground Water and Drinking Water/Water
Steve Allgeier
Lisa Christ
Jeffrey Pencil
David Harvey
Elizabeth Hedrick
Mike Henrie
Security Division
Tanya Mottley
Anand Mudambi
Nancy Muzzy
Brian Pickard
Jessica Pulz
Dan Schmelling
David Travers
Katie Umberg
Richard Weisman
John Whitler
U.S. Environmental Protection Agency - National Homeland Security Research Center
Kathy Clayton Robert Janke Regan Murray
Hiba Ernst Matthew Magnuson Cynthia Yund
John Hall Scott Minamyer
Victoria
Blackschleger
John Chandler
Kevin Connell
Bill Desing
Contractor Support
Darcy Gibbons
Rob Greenwood
Adrian Hanley
Shalini Jayasundera
Reese Johnson
Kim Morgan
Raymond Riordan
Jerry Scott
Scott Weinfeld
Utility Reviewers
Sumedh Bahl, Ann Arbor Water
Reggie Baker, Indiana Department of Environmental Management
Cliff Bowen, California Department of Health Services
Don Broussard, Lafayette Utilities
Zia Bukhari, American Water
Kim Dyches, Utah Department of Environmental Quality
Homer Emery, San Antonio Water
October 2008
IV
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Water Security Initiative: Consequence Management Plan Guidance
Bill Gedney, Southern California Water Company
Bruce Johnson, Tucson Water
Ron Hunsinger, East Bay Municipal Utility District
David Lipsky, New York City Department of Environmental Protection
Steve Rhode, Massachusetts Water Resources Authority
Sandy Smith, Gwinette County Water
David Thurber, Lincoln Water
Greg Welter, O'Brien and Gere
Charles Zitomer, Philadelphia Water
Association of Metropolitan Water Agencies
Vance Taylor
Association of State Drinking Water Administrators
Bridget O'Grady
American Water Works Association
J. Alan Roberson
Kevin Morley
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
Table of Contents
SECTION 1.0: INTRODUCTION 1
SECTION 2.0: CONSEQUENCE MANAGEMENT PLAN OVERVIEW 5
2.1 OVERVIEW OF THE CONSEQUENCE MANAGEMENT PLAN 5
2.2 APPLICATION OF NATIONAL INCIDENT MANAGEMENT SYSTEM AND INCIDENT COMMAND SYSTEM
WITHIN THE CONSEQUENCE MANAGEMENT PLAN 7
2.3 ROLES AND RESPONSIBILITIES 8
2.4 RELATIONSHIP TO OTHER GUIDANCE DOCUMENTS AND PROGRAMS 9
SECTION 3.0: CONSTRUCTING THE CONSEQUENCE MANAGEMENT PLAN 11
3.1 STEP 1: ASSESSMENT AND INTEGRATION OF EXISTING PLANS AND OPERATIONS 11
3.2 STEP 2: DEVELOPMENT OF THE CMP FRAMEWORK 13
3.3 STEPS: IDENTIFICATION OF KEY RESPONSE PARTNERS AND STAKEHOLDERS 26
3.4 STEP 4: ENGAGEMENT OF RESPONSE PARTNERS AND STAKEHOLDERS 26
SECTION 4.0: COMMUNICATIONS 30
4.1 GENERAL COMMUNICATIONS 30
4.2 RISK COMMUNICATIONS 32
4.3 INFORMATION MANAGEMENT 34
SECTION 5.0: TRAINING AND EXERCISES 35
5.1 How TO IMPLEMENT THE CMP THROUGH TRAINING 35
5.2 TRAINING COURSES AND MATERIALS 36
5.3 REVISION OF THE CMP BASED ON EXERCISES OR ACTUAL INCIDENTS 37
SECTION 6.0: IMPLEMENTATION, MAINTENANCE, AND UPDATES 39
6.1 PLAN IMPLEMENTATION 39
6.2 PLAN MAINTENANCE AND UPDATES 40
APPENDIX A: GLOSSARY 42
APPENDIX B: CMP DECISION TREE TEMPLATES 44
B.I CREDIBLE DETERMINATION DECISION TREE TEMPLATE 45
B .2 OPERATIONAL RESPONSE DECISION TREE TEMPLATE FOR CREDIBLE DETERMINATION 49
B.3 SITE CHARACTERIZATION DECISION TREE TEMPLATE 52
B.4 CONFIRMED DETERMINATION DECISION TREE TEMPLATE 58
B. 5 OPERATIONAL RESPONSE DECISION TREE TEMPLATE FOR CONFIRMED DETERMINATION 62
B.6 PUBLIC NOTIFICATION DECISION TREE TEMPLATE 66
B.7 REMEDIATION AND RECOVERY DECISION TREE TEMPLATE 70
APPENDIX C: PUBLIC INFORMATION ACTION PLAN 79
APPENDIX D: ROLES AND RESPONSIBILITIES 82
APPENDIX E: REFERENCES AND TOOLS 88
October 2008 vi
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Water Security Initiative: Consequence Management Plan Guidance
List of Tables
TABLE 1-1. SUMMARY OF CONSEQUENCE MANAGEMENT PLAN GUIDANCE SECTION TOPICS 4
TABLE 1 -2. SUMMARY OF CONSEQUENCE MANAGEMENT PLAN GUIDANCE DOCUMENT APPENDICES 4
TABLE 2-1. SUMMARY OF POTENTIAL UTILITY AND PRIMARY EXTERNAL RESPONSE PARTNER ROLES 8
TABLE 3-1. EXAMPLE MATRIX DOCUMENTING UTILITY PLANS, EQUIPMENT, AND TRAINING 12
TABLE 3-2. SUMMARY OF SITE CHARACTERIZATION ACTIVITIES 16
TABLE 3-3. SUMMARY OF THE REMEDIATION AND RECOVERY PROCESS 25
TABLE 4-1. CRISIS COMMUNICATION ROLES 33
TABLE 5-1. CONSEQUENCE MANAGEMENT PLAN TRAINING EXERCISES 36
TABLE D-l. CMP ROLES AND RESPONSIBILITIES FOR LOCAL PARTNERS 85
TABLE D-2. CMP ROLES AND RESPONSIBILITIES FOR STATE PARTNER ORGANIZATIONS 86
TABLE D-3. CMP ROLES AND RESPONSIBILITIES FOR REGIONAL PARTNER ORGANIZATIONS 87
TABLE D-4. CMP ROLES AND RESPONSIBILITIES FOR FEDERAL PARTNER ORGANIZATIONS 87
List of Figures
FIGURE F-l. OVERVIEW OF EPA's WATER SECURITY INITIATIVE i
FIGURE F-2. MULTI-COMPONENT APPROACH TO A CONTAMINATION WARNING SYSTEM n
FIGURE F-3. RECOMMENDED STAGES OF CONTAMINATION WARNING SYSTEM DEPLOYMENT n
FIGURE 1-1. CONTAMINATION WARNING SYSTEM ARCHITECTURE 2
FIGURE 1-2. RELATIONSHIP OF EMERGENCY RESPONSE PLAN AND CMP 3
FIGURE 2-1. OVERVIEW OF A CONTAMINATION WARNING SYSTEM DECISION TREE STRUCTURE 6
FIGURE 3-1. CREDIBLE DETERMINATION PROCESS OVERVIEW 14
FIGURE 3-2. CONFIRMED DETERMINATION PROCESS OVERVIEW 19
FIGURE 3-3. REMEDIATION AND RECOVERY PROCESS OVERVIEW 24
FIGURE 3-4. POTENTIAL CONTAMINATION WARNING SYSTEM PARTNERS 26
FIGURE 3-5. RECOMMENDED STRATEGY FOR ENGAGING CONSEQUENCE MANAGEMENT PLAN PARTNERS 27
FIGURE D-l. OVERVIEW OF ICS ORGANIZATION STRUCTURE 82
FIGURE D-2. UNIFIED COMMAND FOR MULTI-AGENCY/MULTI-JURISDICTION INCIDENT 84
October 2008 vii
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Water Security Initiative: Consequence Management Plan Guidance
List of Acronyms
The list below includes acronyms approved for use in this guidance document. Acronyms are defined at
first use in the document.
ASTDR Agency for Toxic Substances and Disease Registry
AWWA American Water Works Association
CDC Centers for Disease Control and Prevention
CFR Code of Federal Regulations
CID Criminal Investigation Division (U.S. EPA)
CMP Consequence Management Plan
EMA Emergency Management Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ERT Environmental Response Team (U.S. EPA)
EOC Emergency Operations Center
FEMA Federal Emergency Management Agency
FBI Federal Bureau of Investigation
HASP Health and Safety Plan
HazMat Hazardous Material
HSEEP Homeland Security Exercise Evaluation Program
1C Incident Commander
ICS Incident Command System
JIC Joint Information Center
JOC Joint Operations Center
LEPC Local Emergency Planning Committee
LRN Laboratory Response Network
NOT National Decontamination Team (U.S. EPA)
NIMS National Incident Management System
NRC National Response Center
NRF National Response Framework
NRT National Response Team
OSC On-Scene Coordinator (U.S. EPA)
OSHA Occupational Safety and Health Administration
PIO Public Information Officer
PN Public Notification
PPE Personal Protective Equipment
RLRP Regional Laboratory Response Protocol
RPTB Response Protocol Toolbox
RRT Regional Response Team
SCADA Supervisory Control and Data Acquisition
SERC State Emergency Response Commission
SOP Standard Operating Procedure
UC Unified Command
U.S. DHS United States Department of Homeland Security
U.S. EPA United States Environmental Protection Agency
WaterlSAC Water Information Sharing and Analysis Center
WARN Water/Wastewater Agency Response Network
WCIT Water Contaminant Information Tool (U.S. EPA)
WLA Water Laboratory Alliance
WS Water Security initiative
WUERM Water Utility Emergency Response Manager
October 2008
Vlll
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Water Security Initiative: Consequence Management Plan Guidance
Section 1.0: Introduction
This document is part of a series of guidance documents developed to support EPA's Water Security
(WS) initiative (formerly known as WaterSentinel). Initiated in response to Homeland Security
Presidential Directive 9, the overall goal of the Water Security initiative is to establish recommendations
for the design, deployment, and evaluation of contamination warning systems for drinking water utilities.
Additional information on the objectives of the Water Security initiative and contamination warning
systems can be found in Water Sentinel System Architecture (USEPA, 2005). Additional information is
also available on the Water Security initiative website at:
http://cfpub.epa.gov/safewater/watersecurity/initiative.cfm.
What is the purpose of this document?
The purpose of this document is to assist drinking water utilities with planning, designing, implementing,
and maintaining an effective Consequence Management Plan (CMP) as part of a contamination warning
system. This is based on the model developed under EPA's WS initiative.
Consequence management is a key aspect of a contamination warning system and consists of actions
taken to plan for and respond to potential drinking water contamination incidents in the distribution
system. These actions are meant to minimize response and recovery timelines through a pre-planned,
coordinated effort. Investigative and response actions initiated upon determination of a possible
contamination threat are used to establish credibility, minimize public health and economic impacts, and
ultimately return the utility to normal operations.
The CMP serves as a guide for the utility that describes the actions that should be taken upon discovery of
a possible contamination threat, as detected by one of the contamination warning system monitoring and
surveillance components. In the event of a confirmed contamination incident, the plan provides
information on remediation and recovery steps to return the utility to normal operation. The CMP relies
on extensive pre-planning efforts to both establish clear roles and responsibilities with local, State, and
Federal response organizations and define strategies for communicating with the public.
What is the Role of Consequence Management in a Contamination Warning System?
A contamination warning system should provide drinking water utilities with a proactive approach to
managing threat warnings in the distribution system. It should use advanced monitoring and surveillance
strategies to collect, integrate, analyze, and communicate information to provide timely warning of
potential water contamination threats, while also outlining response actions to minimize public health and
economic impacts. As illustrated in Figure 1-1, there are two major operational phases associated with
an effective contamination warning system: Routine Operation and Consequence Management.
Routine operation generally refers to the normal, day-to-day activities that occur at the component level.
These activities include, from left to right in Figure 1-1, monitoring and surveillance strategies (first box),
along with event detection and initial trigger validation to determine possible contamination (second box).
Routine operation should be governed by defined standard operating procedures for each of the
monitoring and surveillance strategies, and is detailed in the Interim Guidance on Developing an
Operational Strategy for Contamination Warning Systems (USEPA, 2008).
Consequence management (the third, fourth, and fifth boxes in Figure 1-1) provides a decision-making
framework used to establish credibility, implement response actions, minimize public health and
economic impacts, and ultimately return the system to normal operations, and is the focus of this guidance
document.
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
Monitoring and Surveillance
Event Detection
Possible Determination
Credible Determination
Remediation and Recovery
Confirmed Determination
Response actions
Operational response
Public health response
Site characterization
Laboratory confirmation
Risk communication
Response actions
Operational response
Public health response
Expanded samplin
Laboratory confirmation
Risk communication
Drinking water utility
event detection and
initial trigger
validation
System
characterization
Remedy selection
Remedial action
Post-remediation
activity
Public health event
detection and trigge
validation
Figure 1-1. Contamination Warning System Architecture
Why should a drinking water utility develop a CMP?
A CMP is a critical component of a contamination warning system. While monitoring and surveillance
strategies can provide timely warning of potential water contamination threats, they do not support the
initiation of response actions to minimize public health and economic impacts. Therefore, without a well-
defined CMP, monitoring and surveillance activities are of limited value.
In order to protect public health, drinking water utilities should have adequate plans in place to respond to
possible contamination threats in the distribution system. Unintentional incidents, such as cross-
connections with non-potable water, permeation of contaminated water through leaking pipes in areas of
low distribution system pressure, and chemical reactions or microbial growth within the distribution
system pipes, can result in degradation of distributed water quality and may occur with some regularity.
Additionally, intentional contamination incidents, or even the threat of contamination, can have
significant, widespread impacts. The CMP specifically outlines the response actions the utility should
consider taking in the event of a possible drinking water contamination incident. .
Development of a CMP can also provide concurrent, or dual-use, benefits to a utility. For example, many
of the response partner agencies typically involved in developing a CMP for a contamination warning
system are the same partners who would be engaged in other emergencies, such as natural disasters.
Thus, CMP development affords the opportunity to improve coordination, communications, and move
towards an integrated all-hazards response. Regardless of the presence or level of maturity of related
plans (e.g., emergency response plans, communication plans, incident-specific response plans), the broad
and comprehensive nature of a CMP makes it very valuable to utility operations.
How does the CMP relate to the Response Protocol Toolbox?
EPA previously provided guidance on response to drinking water contamination in a suite of six modules
that composed the Response Protocol Toolbox (USEPA, 2004). Many of the concepts presented in the
Response Protocol Toolbox (RPTB) are applicable to development of a CMP for contamination warning
systems and are referenced throughout this document. In particular, this guidance document adopts the
"Possible," "Credible" and "Confirmed" progressive stages of a contamination incident, and applies them
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
to development of specific guidelines for responding to contamination threats or incidents as detected by
a contamination warning system.
How does the CMP relate to the Emergency Response Plan?
The CMP should serve as a component of a utility's overall emergency response plan specifically
focusing on an incident-specific action plan for response and recovery to a drinking water contamination
incident in the distribution system. Figure 1-2 outlines the generic relationship between the emergency
response plan and the CMP.
Water Utility
Emergency Response PI
***? Communication _ lnc,!dff ;.
.SL P"- *"&£*"
i
Distribution System Contamination Natural
Consequence Management Plan disasters
an
I
Rotes a fflhf
Responsibilities ^
i
Water Main
Breaks
Policies (e.g.,
mate water,
pling, safety)
Fire
Figure 1-2. Relationship of Emergency Response Plan and CMP
Although Figure 1-2 portrays the CMP as a separate incident-specific action plan, it can also play an
integral part in the response and recovery of other incidents as well. For example, if a natural disaster,
water main break, or a fire causes contamination within the distribution system, the CMP response and
recovery protocols can be applied.
Who should use this document?
The CMP guidance document has been developed for utilities involved in or planning for contamination
warning system deployment. While the primary focus of this document and the WS initiative at this time
is on large utilities, there are many applications and considerations that may be applicable to medium and
small utilities as well. The CMP guidance document should also serve as a useful tool for other
organizations, such as wastewater utilities and emergency responders, to understand water contamination
preparedness. In addition, this document provides a framework for integration of a CMP with existing
plans, training scenarios, and outreach efforts to local, State, regional, and Federal response partner
agencies.
How do I use this document?
As described in Table 1-1, this document is divided into five sections that provide guidance for
developing, implementing and maintaining a CMP for a drinking water utility contamination warning
system. It provides recommendations, details, and background on the content of the plan; a framework or
approach for developing, implementing, and testing the plan; and discusses how to align a contamination
warning system CMP with existing emergency response plans. Tips and success stories are also
highlighted throughout the document to draw attention to useful processes.
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Water Security Initiative: Consequence Management Plan Guidance
Table 1-1. Summary of Consequence Management Plan Guidance Section Topics
Section Title
CMP Overview
Constructing the
CMP
Communications
Training and
Exercises
Implementation,
Maintenance, and
Updates
Section
Number
2.0
3.0
4.0
5.0
6.0
Topics
Provides an overview of the CMP, describes roles and responsibilities, and
outlines the relationship to other external emergency response plans.
Describes the four steps involved with constructing a CMP: 1 ) Self assessment of
existing plans and how to integrate them into the CMP; 2) development of the
internal CMP framework; 3) identification of key response partner agencies; and
4) engagement of response partner agencies and stakeholders. Discussion in
this section is supported by example decision tree templates in Appendix B to aid
in plan development.
Provides guidance for developing general and risk communication plans and an
information management strategy, which are essential components of a
contamination warning system and CMP. This includes developing plans,
defining roles, and identifying resources and equipment. Additional templates for
developing communication plans along with supplemental information can be
found in Appendices C and E.
Describes methods to implement the CMP through training and exercises.
Provides references to established training courses and guidance materials that
can be used when planning training program for employees and response partner
agencies. It also provides general high-level exercise materials and includes
references to other guidance material specifically for exercise design and
implementation.
Describes the process of implementing and maintaining the CMP.
Implementation will address the integration and sustainability of the plan within
the utility and surrounding community. Maintenance of the water contamination
CMP will address the need to schedule regular reviews and updates.
In addition to the sections described above, this document includes appendices described in Table 1-2.
Table 1-2. Summary of Consequence Management Plan Guidance Document Appendices
Appendix
A
B
C
D
E
Title
Glossary
CMP Decision Tree
Templates
Public Information
Action Plan
Roles and
Responsibilities
Tools and Resources
Description
Terms and definitions.
Provides templates to be used as a guide and starting point for developing
the "utility-specific" CMP framework (as described in Section 3.0).
Provides a template to be used when outlining the public information
actions for each response phase of a contamination warning system.
Describes utility roles under the Incident Command System structure and
describes roles and responsibilities of response partner agencies.
Provides references to additional guidance materials and tools.
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Water Security Initiative: Consequence Management Plan Guidance
Section 2.0: Consequence Management Plan Overview
This section provides the background information for developing and constructing a utility-specific CMP.
It provides an overview of a CMP and its components, describes potential roles and responsibilities for
the utility and response partner agencies, and outlines the relationship to other external emergency
response plans and guidance documents.
2.1 Overview of the Consequence Management Plan
Figure 2-1 provides a general overview of an effective CMP and how it can relate to the monitoring and
surveillance components of a contamination warning system. A utility-specific CMP should include
sections to address all phases of consequence management, including credible determination, confirmed
determination, and remediation and recovery. Information should also be included to address utility and
risk communication issues.
Figure 2-1 also provides an approximate timeline for an effective consequence management process.
This timeline represents an estimate only, since the consequence management process and response
efforts are dependent on the specific circumstances surrounding a contamination incident.
Each of the consequence management phases is described below:
Credible Determination Planning and Actions
This initial stage of consequence management should involve gathering additional information about the
possible water contamination threat through further review of all contamination warning system
components, site characterization activities and other external resources when available and relevant.
Some preliminary response actions may also be initiated during the credible determination process to
limit or minimize impacts of suspected contamination. Based on additional information gathered,
contamination is either ruled out and the system returns to routine monitoring and surveillance activities,
or contamination is deemed credible, and additional confirmatory and response actions should be
initiated.
Confirmed Determination Planning and Actions
In this stage of consequence management, additional information should be gathered and assessed to
confirm drinking water contamination. Response actions initiated during credible determination should
be expanded, and additional response activities may be implemented. Confirmed determination also
includes the utility consulting with its drinking water primacy agency to determine if public notification
(e.g., boil water, do not drink, do not use) is required.
Remediation and Recovery Planning and Actions
Remediation and recovery should occur once contamination is confirmed and the immediate threat to the
public and property has been mitigated. This involves actions that should be taken to quickly restore the
drinking water utility to service. These actions generally include characterization of the contaminated
area and the processes for remediation and return to service. It may also include activating mutual aid
and assistance agreements [e.g., local and State agreements, Water/Wastewater Agency Response
Networks (WARNs)] to assist in providing an alternate water supply, issuing long-term water use
guidance to customers, and decontaminating the water system.
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Water Security Initiative: Consequence Management Plan Guidance
Approximate
Timeline
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Additional Information
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->,
Assess
Responses
Implement Additional
i ^ Operational
Responses
Public
Notification
Implement Additional
Responses
Public
Notification
Operational Strategy Consequence
Document Management Plan
A
Figure 2-1. Overview of a Contamination Warning System Decision Tree Structure
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Water Security Initiative: Consequence Management Plan Guidance
Risk Communication Plan
As part of the CMP, the utility should also develop a comprehensive risk communication plan and
consider additional resources that may be needed to supplement the plan. The purpose of a risk
communication plan is to guide the utility and its partners on when and
how to make notifications, how to work with the media, how to
define what the message will be and establishment of delivery ' SUCCESS STORY
systems for the message (e.g., media, radio, television, auto-dialer
telephone systems).
Development of the risk communication plan should be lead by the
utility Public Information Officer (PIO) and confirmed through
counterparts at external partner agencies. The utility and other
agencies may already have much of this information covered in
existing risk communication or public notification plans, but roles
and responsibilities may still need to be coordinated and confirmed
amongst the groups. The goal is to coordinate communication
across agencies to promote messages that are clear, consistent and
concise (i.e., messages do not give out superfluous or
contradictory information).
The WS initiative pilot utility developed a
crisis communication plan to supplement
their CMP. This plan detailed the
responsibilities of the PIO during all
phases of a contamination incident and
with
press, and the public. The plan included
an overview of basic crisis communication
principles, CMP decision trees adapted for
use by the PIO, and a section with tools
and resources that included templates,
sample notification documents, and
contact information.
2.2 Application of National Incident Management System and Incident Command
System within the Consequence Management Plan
The National Incident Management System (NIMS) provides a systematic, proactive approach guiding
government agencies at all levels, the private sector, and nongovernmental organizations to work
seamlessly to prepare for, prevent, respond to, recover from, and mitigate the effects of incidents,
regardless of cause, size, location, or complexity, in order to reduce the loss of life and property. The
NIMS contains five major components: Preparedness, Communications and Information Management,
Resource Management, Command and Management, and Ongoing Management and Maintenance. The
components of NIMS are adaptable to any situation, from routine, local incidents to those requiring
coordinated federal response. This flexibility is essential for NIMS to be applicable across the full
spectrum of potential incidents, including those that involve multi-agency, multi-jurisdictional, and/or
multidisciplinary coordination. NIMS concepts are used and applied throughout the CMP Guidance
(where possible) to ensure that plans developed based on this guidance are consistent with NIMS.
The Command and Management component, which describes the Incident Command System (ICS), is a
key aspect of NIMS that should be integrated into the CMP. The ICS is a widely applicable management
system designed to enable effective and efficient incident management by integrating a combination of
facilities, equipment, personnel, procedures, and communications operating within a common
organizational structure. ICS is used to organize field-level operations for a broad spectrum of
emergencies from small to complex incidents, both natural and manmade. As a system, the ICS is
extremely useful; not only does it provide an organizational structure for incident management, but it also
guides the process for planning, building, and adapting that structure. Using ICS for every incident or
scheduled event helps hone and maintain skills needed for the large-scale incidents.
The CMP should contain provisions for the utility to implement an ICS to help manage a response to a
contamination incident that goes outside of its normal operations. One of the first steps should be to
ensure that response staff has basic NIMS and ICS training. The training and implementation of NIMS
should be consistent with the guidance developed by the Federal Emergency Management Agency's
(FEMA's) NIMS Integration Center (http://www.fema.gov/emergency/nims/nims_compliance.shtm).
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Water Security Initiative: Consequence Management Plan Guidance
Additional information and clarification on NIMS compliance and NIMS and ICS training can be
obtained through the State Emergency Management Agency (EMA) or Office of Homeland Security.
Additional information pertaining to both NIMS and ICS is provided in Section 5.0 and Appendices D
and E.
2.3 Roles and Responsibilities
Effective operation of a CMP involves the participation of a variety of utility personnel and response
partner agencies, each having well-defined roles and responsibilities. The utility CMP should identify the
roles, duties and responsibilities in a manner that works well for the individual utility while matching the
roles and responsibilities of the ICS and response partner agencies. The roles and responsibilities outlined
in the CMP should provide the utility with a description of what they should be prepared to do and what
is expected from local, State and Federal supporting agencies to respond to a contamination incident.
Roles and responsibilities of supporting agencies should be worked out prior to completion of the CMP.
This section provides a general description of the roles and responsibilities of the personnel (utility and
support agencies) involved with implementing a CMP. Table 2-1 provides a general overview of the
roles and responsibilities that response partners may play in implementing the CMP. Note that Table 2-1
is an approximation only, since response partner roles may vary among localities. Refer to Appendix D
for more detailed information concerning roles and responsibilities.
Table 2-1. Summary of Potential Utility and Primary External Response Partner Roles
Potential Response Partners
Drinking water utility
Drinking water and wastewater primacy agencies
Local health department
Local law enforcement
Local civil government
Local emergency planning committees and
emergency management agencies
Local fire, EMS, and HazMat
Local wastewater utility
Neighboring utilities (water and/or wastewater)
Mutual aid and assistance partners
Media
State government
State environmental and/or public health
laboratories
State health department
State emergency responders
State emergency management and homeland
security agencies
State law enforcement
Department of Homeland Security (DHS)
EPA regional offices and/or laboratories
CMP Activities
Operational
Response
Public Health
Response
Site
Characterization
Criminal
Investigation
Expanded
Sampling
Laboratory
Analysis
Risk
Communication
Remediation and
Recovery
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Water Security Initiative: Consequence Management Plan Guidance
Potential Response Partners
EPA Criminal Investigation Division (CID)
EPA On-Scene Coordinators (OSC)
Federal Bureau of Investigation (FBI)
Centers for Disease Control and Prevention (CDC)
National Response Center (NRC)
CMP Activities
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Drinking Water Utility Roles
As indicated in Table 2-1, the drinking water utility should be involved in all aspects of consequence
management in response to a contamination incident. Thus, it is important to assign CMP roles and
responsibilities to the appropriate utility personnel. Although roles and responsibilities will likely vary
based on the circumstances of each utility, roles should be clarified similar to the way they are listed in
the ICS. This includes assigning utility personnel to the ICS roles identified in Figure D-l in Appendix
D. These job functions are generic, allowing drinking water utilities to map specific CMP roles and
responsibilities to their unique organizational functions.
For the purposes of this guidance document, we use the term "appropriate utility personnel" when
addressing specific utility roles in relation to the ICS. It is ultimately up to the utility to decide the
appropriate personnel responsible for these roles and modify them based on their own organizational
structure. For example, in the U.S. EPA RPTB, it is recommended that utilities designate a water utility
emergency response manager (WUERM) as the Incident Commander (1C) when a threat is reported. In
some utilities, the WUERM is an individual (or several individuals) with designated responsibility for
managing the utility's response to a contamination threat or incident. Although it is important to
recognize and appoint an individual responsible for being the 1C, the use of the term WUERM for the 1C
is optional and dependent on utility preference.
Response Partners
As indicated in Table 2-1, local, State, and Federal support agencies will typically have various response
roles during a drinking water contamination incident. For example, the local fire department may be
called on to provide hazardous material (HazMat) support and State/local laboratories to assist in
analyzing potentially contaminated drinking water samples. Other support agencies may include local
health departments, law enforcement agencies, local governments and local/State/Federal regulatory
agencies. Utilities should identify key partners and stakeholders when developing their CMP in order to
define the roles, responsibilities and assistance capabilities.
Refer to Section 3.0 for information on identifying and engaging response partners and Appendix D for
further information concerning response partner roles.
2.4 Relationship to Other Guidance Documents and Programs
As previously stated, EPA provided guidance on response to drinking water contamination in a suite of
six modules that composed the Response Protocol Toolbox (USEPA, 2004). Many of the concepts
presented in the RPTB are applicable to development of a CMP for contamination warning systems. This
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Water Security Initiative: Consequence Management Plan Guidance
guidance document adopts the RPTB progressive stages of a contamination incident, which include
"Possible," "Credible," and "Confirmed."
The CMP also integrates concepts and information presented by local, State and Federal guidance
documents. These additional guidance documents and tools are referenced in Appendix E.
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Water Security Initiative: Consequence Management Plan Guidance
Section 3.0: Constructing the Consequence Management
Plan
This section is intended to serve as a roadmap for the user in developing and constructing a utility-
specific CMP. The construction of a comprehensive CMP should include the following four sequential
steps:
1. Assessment and integration of existing plans and operations
2. Development of the CMP framework
3. Identification of key response partners and stakeholders
4. Engagement of response partners and stakeholders
3.1 Stepl: Assessment and Integration of Existing Plans and Operations
The first step in developing a CMP should be to conduct
a self assessment of the utility's existing emergency
response plans and overall preparedness. The purpose
of the self assessment is to identify existing procedures
regarding planning and preparedness that may serve as a
starting point for constructing a CMP. This will allow
the utility to expand existing material, strengthen
existing plans, and integrate current operations into the
CMP.
IMPORTANT DEFINITION
According to NIMS, preparedness is defined
as "a continuous process that involves the
integration of planning, training, exercising,
personnel qualification and certification
standards, and equipment certification
standards in an effort to build, sustain, and
improve operational capabilities."
The utility should review existing plans and operations to determine potential elements of a CMP. A
CMP developed in support of a contamination warning system should be a sub-set of the utility's existing
emergency response plan, focusing specifically on the contamination threat to the distribution system.
For example, utilities may have developed action plans and/or specific protocols and procedures within
their emergency response plans for responding to the following:
Water contamination, such as Cryptosporidium and Giardia, cross connections, chemical spills,
intentional contamination, and "white powder" plans
Increased consumer complaint calls
Facility alarms, suspicious persons, or threats made to the system
Depressurization, power outage, adjusting water treatment parameters, or other operational
problems
Severe weather
Civil disorder
Mutual aid and assistance with other utilities
Need for water-use restrictions
Public notification/Risk communication
As plans are reviewed, a list or matrix should be constructed that captures the title of the plan, the
situation it addresses, and what utility divisions and outside agencies are involved. This will help to
identify gaps that need to be addressed during consequence management planning activities.
In addition to an assessment of existing operational plans, the utility should conduct an assessment of
response resources and capabilities. This should involve identifying assets (e.g., staff, equipment) as well
as training needs that are required to carry out the existing plans and operations. Throughout the
development of the CMP, the utility should maintain a list of items or resources that need to be acquired,
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Water Security Initiative: Consequence Management Plan Guidance
enhanced, or improved. Later, during the final drafts of the plan and implementation, the list can be
addressed and shortfalls in training, equipment and other resources can be resolved.
Table 3-1 illustrates a matrix that was used during an actual assessment of utility plans. It identifies the
type of plans and response resources available, areas where gaps may be located, and possible interaction
points. The notes and comments in the list are for illustration purposes.
Table 3-1. Example Matrix Documenting
Type of Plan and
Comments
Emergency
Response Plan
Security Standard
Operating
Procedure (SOP)
Cryptosporidium
Response Plan
Alternate Water
Supply Plan
Existing
Equipment
2-way Radios
Training
Incident Command
(all 4 courses- IS
200, 400, 700, 800)
Site
Characterization
Exercise(s)
Does the plan
contain
protocols for
response to a
water
contamination?
^
^
Quantity
18
Type
FEMA
Utility
Local
Does the
plan
contain a
list of
external
partners?
^
^
Needed
for CMP?
Yes
Needed
for CMP?
Yes
Yes
Yes
Utility Plans, Equipment, and Training
Is the
plan up
to
date?
^
^
Does the plan
have steps
that can be
included in
the CMP?
^
^
Notes
This plan covers water
contamination and has a good list
of potential response partners,
including a contact list.
This plan contains detailed
information on working with local
law enforcement that could be
included in the CMP, although
contact numbers need to be
updated.
This plan contains specific
protocols for responding to water
contaminated by Cryptosporidium.
The process portion will link to
CMP and it has excellent response
information.
This plan is currently being
developed. When completed, it
should be linked to the CMP.
Comments
Not enough radios and all radios are for field use.
Communication is only through dispatch. The radios are old
and may need to be replaced. Radio communication does not
work east of town.
Comments
Two people have taken all the specific recommended courses.
Seven people have taken the intro course. Talk to Training
about expanding this.
Head of Operations has taken the course but no field operators
have taken it. Needs to be expanded.
Participated in small exercise 2 years ago. Once the CMP is
completed, will have to set up exercise(s) to test its
implementation. Talk to City Manager about city exercises.
As each existing plan is reviewed, consider how they are connected to each other and how they are likely
connected to the CMP. When drafting the CMP, use a matrix similar to Table 3-1 to establish links from
the corresponding plans to the relevant CMP sections. Then use the material from the existing response
plans as a starting point for developing that CMP section.
For example, the utility emergency response plan may contain a comprehensive list of response partners
(e.g., under the communication plan section) that may be integrated into the CMP. The emergency
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Water Security Initiative: Consequence Management Plan Guidance
response plan may contain detailed information on alternate water supply planning that can be integrated
as well. In this way, all the utility emergency response plans will be connected and reflect one another.
3.2 Step 2: Development of the CMP Framework
After assessing the utility's existing plans and overall preparedness, the next step is to develop an initial
draft of the CMP. Developing an initial draft will allow the utility's consequence management design
team (i.e., designated utility personnel assigned to develop the CMP) to begin conceptualizing the later
stages of a response and determine when response partners should be engaged. This will also guide the
utility in identifying key staff and/or utility divisions that should be involved in the development process
(refer to Section 2.3, Roles and Responsibilities). Development of the initial draft should occur before
defining external agency involvement as outlined in Steps 3 and 4.
The initial draft should be based on the utility's self-assessment of existing plans and procedures outlined
in Step 1. This includes identification of where the initial draft will most likely be connected to
previously existing plans. The design team should then identify any gaps and areas of the draft CMP that
need to be expanded or developed. For example, the utility may incorporate their existing
Cryptosporidium response plan into their CMP or may realize that their risk communication plan should
be enhanced and updated.
The initial draft of the CMP should include the development
of decision trees for response actions during an incident, as
well as remediation and recovery following an incident. This
should include specific decision trees for determining
whether a contamination incident is credible and/or
confirmed, and for remediation and recovery efforts. The
decision trees should run through the time period up to and
past the point where response partner agencies are contacted
for assistance. The initial draft should identify the major
steps, actions, decision points, communications points, and
expected contributions by partners that occur. Decision trees
or other visuals will be helpful in representing this
information.
IMPORTANT TIP
Appendix B contains examples of
CMP decision trees that should be
used as a guide when developing a
utility-specific plan. Decision trees are
invaluable in the design phase of
consequence management planning,
as well as during response.
After reviewing the information under
Step 2, proceed to Appendix B to
develop the appropriate decision trees
for the utility-specific plan.
The following sections provide guidance for the development of the credible, confirmed, and remediation
and recovery portions of a utility-specific CMP. Example decision tree templates are provided in
Appendix B to further assist in the development of each CMP section.
Credible Determination Planning and Actions
Credible determination is the process for validating a possible threat warning. A possible water
contamination threat warning should be characterized as credible if additional information collected
during the utility's investigation corroborates the threat warning received from a monitoring and
surveillance component(s), and the collective information indicates that contamination is likely. For
example, if the threat warning comes in the form of a security alarm and additional signs of contamination
are observed during the alarm investigation (e.g., broken lock or hatch), the threat would likely be
considered credible. While many threat warnings may result in possible contamination threats, a small
percentage of possible threats are expected to become credible.
Credible determination should begin when the utility person identified as the point of contact within the
response team is notified of a validated monitoring or surveillance alarm, or possible contamination
threat. Depending on the organizational structure, this point of contact could be the division chief,
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Water Security Initiative: Consequence Management Plan Guidance
manager, or director. Under ICS, this person is the 1C. The credible investigation should involve several
activities including notification of internal and external parties, assessment and implementation of
immediate operational responses (e.g., limited system isolation), site characterization, coordination with
internal/external laboratories and laboratory sample analysis, and review of other contamination warning
triggers. The credible investigation should also include a close-out mechanism for situations determined
to be non-incidents (i.e., investigations shows that no contamination occurred).
Figure 3-1 provides a generic overview of the credible determination process. Credible determination
activities may not occur in sequential order and may start at different times, run concurrently, be revisited
when addition investigation information is received, or occur after credible determination. For example,
if field results from site characterization (e.g., site hazard assessment, field safety screening, and rapid
field tests) indicate the presence of a contaminant, the incident may be deemed credible and implementing
the sampling strategy may actually occur during the confirmed determination investigation.
t
1
\ssess operational
responses
V
Internal and exter
notifications
1 r
Conduct site
characterizatioi
Discuss field screening results
and additional information with
appropriate utility and response
partner personnel
nal
u
Investigate for o
Contamination We
System trigge
u
Coordinate/implement
aboratory sample analysis
ther
irning
rs
Figure 3-1. Credible Determination Process Overview
Each utility should develop its own process or plan for determining whether an incident is credible based
on the activities presented in Figure 3-1. The credible determination plan and material should be written
to represent and reflect the specific utility organizational structure and capabilities. A credible
determination decision tree is a clear and efficient way to connect investigation steps from phase to phase.
Appendix B.I contains an example decision tree that can be modified when developing the utility-specific
process for credible determination. Example decision trees for operational response and site
characterization are found in Appendices B.2 and B.3, respectively.
The following sub-sections provide general information to consider when developing the specific sections
of the credible determination plan as outlined in Appendix B.I.
Internal and External Notifications
During the credible investigation, it is critical to work with both internal utility personnel and external
response partner agencies to investigate, control, and respond to a contamination threat. The utility
should first notify key utility personnel (e.g., ICS personnel) who will be responsible for assisting in the
credible determination process.
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Water Security Initiative: Consequence Management Plan Guidance
External response partner agencies may also want to be
notified at this stage of an incident. There are several reasons
for contacting and involving external agencies including
access to information, tools, and resources.
When developing the credible determination plan, it is
important to make assumptions about when to contact
external agencies. If events warrant response actions,
external parties may wish to be notified that a potential
problem is being investigated. At this point, it may be
necessary to notify law enforcement (e.g., local law
enforcement, EPA Criminal Investigation Division, local
Joint Terrorism Task Force) to determine whether the
incident was intentional, due to negligence, or resulting from
another cause.
IMPORTANT TIP
During development of the credible
determination portion of the CMP, it is
critical that all response agencies be
identified (e.g., those who might need
to be notified at this stage of a
contamination incident). Even if an
agency is not going to be immediately
involved, they may wish to be notified
early on during the incident so they
can prepare their resources for a
response. They may also have
access to information of which the
utility is unaware. Refer to Step 3 in
this section for information on
identifying response agencies.
Refer to Steps 3 and 4 for information on identifying and
engaging response partner agencies. Also, refer to Section 4.1 for information on developing the external
communication plan, and consider the example action items provided in Appendix B.I (Credible
Determination Decision Tree Template) to serve as a starting point.
Investigate for Other Contamination Warning System Triggers
Upon receipt of a possible contamination threat, the utility should investigate whether other
contamination warning triggers are activated from the monitoring and surveillance components. Other
contamination warning triggers activated during an investigation may increase the likelihood that a threat
is credible. Identifying multiple triggers may speed response actions that mitigate public health exposures
and economic/environmental impacts.
Assess Operational Responses
At this stage of the credible determination investigation, the utility should consider operational response
actions that may be used to mitigate potential public health and economic impacts. Operational response
actions considered should specifically include whether the contaminant can be isolated within the
distribution system, flushing options, and the relative impact such response actions may have on
customers and utility operators (e.g., minimal number of customers affected, pressure reduction compared
to minimum pressure requirements, potential period of impact). Although sufficient information may not
be available at this time (e.g., source, type, and spread of contaminant) to support these specific
operational response actions, it is important to at least consider all options in case the threat or incident
escalates to credible or confirmed.
Under certain circumstances, an immediate isolation response may be appropriate during the credible
determination phase. This includes specifically determining whether the contamination incident occurred
at a fixed location, such as a storage tank or pump station. If so, and it is determined that the impacts of
isolation are negligible, the utility may be able to quickly and easily isolate the storage tank or pump
station by closing accessible valves, filling tanks, or otherwise altering the distribution hydraulic grade. If
contamination did not occur at these locations, then the utility should continue to consider potential
operational response actions until further information is obtained. Outlining the impacts of isolating
certain areas of the system prior to an incident can be invaluable during an actual incident, and should be
considered as part of the CMP pre-planning efforts.
Appendix B.2 contains more detailed information concerning operational response activities, along with
an example decision tree template. This decision tree can be modified based on each utility's unique
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Water Security Initiative: Consequence Management Plan Guidance
process for performing operational responses during the credible and confirmed stages of a contamination
incident.1
Conduct Site Characterization
Site characterization is a critical step in the credible
determination process and involves collecting information
from an investigation site to support the evaluation of a
drinking water contamination threat. This helps to characterize
the incident once a threat, accidental or criminal, is suspected.
Site characterization involves careful planning and execution,
oftentimes with external agencies and response partners.
The site characterization plan should describe the activities of
the parties involved and highlight their roles and
responsibilities. The plan should cover activities starting with
performing a site hazard assessment when approaching a
suspected contamination site(s) to collecting water samples and
exiting the site. Recommended site characterization activities are
summarized in Table 3-2.
IMPORTANT TIP
Proper safety practices are essential
for minimizing risk to the site
characterization team and should be
established prior to an incident in
order to be effective. Field personnel
should have appropriate safety
training and basic good safety
practices should be incorporated into a
set of concise guidelines or formalized
into a health and safety plan (HASP).
Further information on HASPs is
available in Appendix E.
Table 3-2. Summary of Recommended Site Characterization Activities
Activity
Purpose
Actions
Result
Site Hazard
Assessment
Minimize the risk to the site
characterization team.
Determine hazards using
information from the initial
threat evaluation.
If site hazard is Low, the utility (i.e.,
Incident Commander) may dispatch
the site characterization team to the
site for field safety screening. If the
site hazard is High, the utility may
refer the situation to a HazMat team.
Field Safety
Screening
Determine if additional safety
precautions are necessary at
the site as site characterization
activities proceed.
Perform a radiation screen
and/or air quality tests.
Appropriate utility personnel (e.g.,
1C) decide on whether or not to
instruct the team to proceed with
sample screening.
Sample
Screening
(1) Provide additional
information to assess the
credibility of the threat; (2)
Tentatively identify
contaminants that need to be
confirmed by laboratory
testing; (3) Determine whether
hazards identified in Step 2
require special precautions
during sampling.
Screen water samples
using water testing
equipment methods
designed for rapid results.
Appropriate utility personnel (e.g.,
1C) decide on whether or not to
instruct the team to proceed with
sample collection.
Sample
Collection
Provide water samples to the
laboratory for confirmatory
analyses.
Collect water samples
using approved methods
and document
procedures. SOPs should
be updated to reflect
additional procedures.
Ability to proceed with confirmatory
laboratory analyses.
Refer to the U.S. EPA Response Protocol Toolbox, Module 2, Contamination Threat Management Guide (EPA-817-D-03-002)
for further information on operational response actions.
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Water Security Initiative: Consequence Management Plan Guidance
Appendix B.3 contains more detailed information concerning site characterization activities, along with
an example decision tree template. This decision tree can be modified based on each utility's unique
process for performing site characterization during a possible contamination incident.2
Discuss Field Screening Results
Field screening results from site characterization, including site hazard assessment, field safety screening,
and sample screening/rapid field tests, will aid in determining whether an incident is credible. They
should be reviewed and discussed by the appropriate utility personnel (e.g., 1C and ICS Planning Section)
and response partners. This should not, at this time, include results of laboratory analyses conducted on
samples collected at the end of the site characterization process. However, the sample screening results
may provide information as to which analytical methods to use on the water samples.
Coordinate/Implement Laboratory Sample Analysis
After site characterization has been completed and samples have been collected, the utility should
coordinate the laboratory analyses of the water samples. This includes deciding on the analytical methods
to be used, as well as coordinating with predetermined laboratories that will perform the procedures.
Factors such as sample preservation, filtering techniques, holding times and chain of custody forms
should be accounted for.
Laboratories used for sample analysis should be established well in advance of an incident and notified at
the beginning of the credible determination phase to ensure that roles and responsibilities are established.
This effort should be coordinated in the same manner as with other utility response partners to ensure
responsive, efficient and accurate handling of water samples collected from the suspected contamination
site. The utility sampling strategy should be well-integrated with the plans and operations of the
laboratories in their network (e.g., local/private, State, public health laboratories).
Nationally, laboratories are implementing processes under the Water Laboratory Alliance (WLA). The
WLA is expected to provide the water sector with an integrated nationwide network of laboratories with
the analytical capabilities and capacity to support monitoring and surveillance, response, and remediation
in the event of intentional and unintentional drinking water supply contamination involving chemical,
biological, and radiological contaminants. The WLA is expected to build upon on existing networks such
as the Centers for Disease Control and Prevention Laboratory Response Network (LRN). It is expected to
leverage existing laboratory network capability, capacity, and infrastructure to fill gaps in national
laboratory preparedness for drinking water analyses. Laboratory infrastructure likely to be leveraged
from other networks includes analytical methods, membership criteria, and critical materials, such as
laboratory reagents.
The foundation of the WLA has been developed by creating laboratory response plans in each of the EPA
Regions and Hawaii. The Regional Laboratory Response Plans (RLRPs) provide a framework for a
coordinated laboratory response to drinking water incidents, and have been customized and tested using
table top exercises in each Region (2006-2007). These plans are being further refined in 2008 by
conducting functional exercises in each Region involving actual sample shipments to laboratories,
analyses, data transfer and communication among laboratories.
The RLRPs are expected to be consolidated into a national response plan for drinking water incidents.
This national plan would constitute the framework of operations for the WLA.
Refer to the U.S. EPA Response Protocol Toolbox, Module 3: Site Characterization and Sampling Guide (EPA-817-D-03-003)
for further information on site characterization.
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Water Security Initiative: Consequence Management Plan Guidance
Confirmed Determination Planning and Actions
Once it has been determined that a contamination threat is credible (e.g., additional information obtained
during credible investigation corrobortaes the contamination threat), steps should be taken to confirm and
respond accordingly. Confirmation transitions from a threat to an actual incident and relies on definitive
or nearly definitive information demonstrating that the water has been contaminated.
The most reliable means of confirming a contamination threat are water sample analytical results showing
the presence of a contaminant. However, under some circumstances, it may be appropriate to confirm a
contamination threat in the absence of definitive analytical data. This is particularly true in cases where
analytical confirmation may be impractical because of challenges in collecting a representative sample
(e.g., uncertainty about the point of contaminant introduction or the time that elapsed between the
introduction of the contaminant and receipt of the threat warning). If analytical confirmation is deemed
impractical, it may be necessary to rely on a preponderance of evidence to confirm an incident.
Preponderance of evidence to confirm a contamination incident may include:
Field sample results collected during site characterization;
Results and observations of site characterization;
Information from public health officials, area hospitals, or 911 call centers; and/or
Targeted information from external sources (such as law enforcement intelligence) based on the
collective knowledge of the threat.
If the threat evaluation yields no conclusive evidence of contamination, then the 1C may decide that the
threat is no longer credible and return the system to normal operation. Each situation will be unique, so
the judgment and experience of the 1C and supporting staff is necessary to decide whether a credible
threat should be elevated to a confirmed incident, dismissed as not credible, or investigated for additional
information.
Confirmed determination typically begins by evaluating field screening results (e.g., rapid field test
results, laboratory analysis of water samples collected during site characterization) with incident
command and other response partner agencies, as appropriate. As information is reviewed, response
teams may implement or revise operational responses in order to isolate the contaminated area or mitigate
the consequences of contamination. The utility must also consult with its drinking water primacy agency
regarding the development or implementation of the public notification strategy (e.g., boil water, do not
drink, do not use). Confirmed determination activities also include additional field investigations, as well
as development and/or execution of expanded sampling plans, health and safety plans, risk
communication plans, alternate water supply plans, and any other tools that are required for the particular
incident.
Figure 3-2 provides a generic overview of the confirmed determination process. Although presented in
sequential order, confirmed determination activities may start at different times or run concurrently.
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Water Security Initiative: Consequence Management Plan Guidance
External response
partners
Evaluate field and
sample analytical
results and additional/
updated information
with appropriate
Develop/implement
expanded sampling
strategy
Develop/implement
alternate water
supply strategy
Develop/implement
public notification
strategy
Implement additional
operational responses
Figure 3-2. Confirmed Determination Process Overview
Each utility should develop its own process or plan for determining whether an incident is credible based
on Figure 3-2 activities. The confirmed determination plan and material should be written to represent
and reflect the specific utility organizational structure and capabilities. A confirmed determination
decision tree is a clear and efficient way to connect investigation steps from phase to phase. Appendix
B.4 contains an example decision tree that can be modified when developing the utility-specific process
for confirmed determination. Example decision trees for operational responses and public notification
can also be found in Appendices B.5 and B.6, respectively.
The following sub-sections provide general information to consider when developing the specific sections
of the confirmed determination plan, as outlined in Appendix B.4.
Internal and External Notifications
Response actions during a confirmed determination
investigation require extensive coordination with internal
and external groups. Consequently, the CMP should resolve
any issues pertaining to who will be contacted, at what point
they will be notified, and what their roles and actions will be
so that notification and coordination procedures are well
defined prior to an incident.
If multiple organizations are authorized to respond to a water
contamination incident, the utility and all outside partners
should operate under a single command structure. This is
referred to as Unified Command (UC), where local, State,
and Federal agencies work together with the utility to
manage an incident under one ICS structure. If a UC is
established, consider providing communication and update
reports for various response partners as part of the process,
and be sure to incorporate laboratories. The laboratories'
ability to provide support relies heavily on coordination
efforts and information from the field.
IMPORTANT TIP
Effective communications, information
management, and intelligence sharing
are critical aspects of incident
management. NIMS describes four
types of reports that can be used to
provide incident information to utility
personnel and response partners
during an incident. This includes
incident notification and situation
reports, status reports, analytical data,
and geospatial information. For further
information go to pages 56-57 of the
NIMS document:
http://vwwv.fema.qov/pdf/emerqencv/ni
ms/nims doc full.pdf
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Water Security Initiative: Consequence Management Plan Guidance
If many organizations are involved, the local Emergency Operations Center (EOC) will likely activate
and facilitate agency coordination, most directly with resource requests. EOCs may be organized by
major functional disciplines (e.g., fire, law enforcement, and medical services), by jurisdiction (e.g., State,
regional, county, city, tribal, Federal), or some combination thereof.
Joint Information Centers (JICs) and Joint Operations Centers (JOCs) may also be established at this
stage of a contamination incident. The JIC provides a structure for developing and delivering coordinated
messages; it develops, recommends, and executes public information plans and strategies; advises on
public affairs issues that could affect a response effort; and responds to rumors and inaccurate information
that could undermine public confidence in the emergency response effort. When in place, the JIC
coordinates all incident-related public information activities. It is the central point of contact for all news
media at the scene of an incident. PIOs from all participating agencies/organizations should co-locate at
the JIC.
A JOC is essentially a federal equivalent to the local EOC. Established by the FBI, a JOC would be
activated during a bioterrorist or weapons of mass destruction event. The incident command post will
still retain on-scene control over the incident, but FBI agents would join the ICS at the local level in order
to feed information back to the JOC.
Refer to Section 4.1 for more information on developing the external communication plan and consider
the example action items provided in Appendix B.4 (Confirmed Determination Decision Tree Template)
and D.I to serve as a starting point.
Evaluate Field and Sample Analytical Results
The first step in the confirmed determination process should be to evaluate the field results obtained
during site characterization. This may include results from field safety screening and rapid field tests.
All results should be discussed and evaluated with incident command, the drinking water primacy agency,
EPA region, public health departments and any other partners and external agencies that request to be
notified. The utility 1C or designee should prepare a brief summary of the field results, as well as other
pertinent information about the incident, to aid in determining whether to confirm the incident.
At this stage, laboratory coordination and operations may have also been initiated during credible
determination. The timeline for sample processing may vary depending on when site characterization is
completed and the type of analysis being conducted (e.g., chemical, biological, radiological). In many
cases, chemical contaminants can be identified and confirmed within a short period of time, while
biological contaminants require several days of laboratory testing to provide conclusive results.
All analytical results should be discussed and evaluated with incident command, the drinking water
primacy agency, EPA region, public health departments and any other partners and external agencies that
request to be notified. Laboratory partner involvement may also be valuable in examining quality
assurance/quality control data for the analyses. Positive laboratory analysis results should be considered
when confirming the contamination threat.
Develop/Implement Expanded Sampling Strategy
After evaluating the field screening results, an expanded sampling strategy should be considered.
Expanded sampling is used to determine the extent of the contamination for response and remediation
efforts.
In some cases, hydraulic modeling tools can be used to determine where to sample after the initial
sampling events. System characterization maps and hydraulic models can identify areas of the system
that have a higher probability of being impacted depending on the entry point during the incident.
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Water Security Initiative: Consequence Management Plan Guidance
Although not all incidents and situations can be planned for in advance, the utility may want to pre-
identify logical sampling points across the system, such as those downstream of tanks and reservoirs.
Implement Additional Operational Responses
If the contamination threat is still considered credible after
further evaluation of field screening results, additional
operational responses should be considered and planned.
Operational response at this stage should continue to involve
the decision process for contaminant isolation based on how
much is known about the contamination incident. This
includes the critical decision of whether enough information
is present to isolate portions of the distribution system, as
well as consideration of other operational procedures, such
as flushing.
IMPORTANT TIP
If available, distribution system
hydraulic models can be used to
develop confirmatory water distribution
system sampling maps which show
the potential spread of contamination
at various time intervals. This pre-
existing information can greatly speed
development of expanded sampling
plans and complement institutional
knowledge in trying to determine
contaminant transport through the
distribution system. It can also inform
decisions regarding areas in which to
issue use restriction notices, if
needed.
If the contamination source is known, appropriate utility
personnel (e.g., utility ICS Planning or Operations Section)
should first estimate the spread of the contamination using
distribution system models or knowledge of the system.
Once the spread of the contamination has been estimated, the
utility should consider the feasibility of isolating the contaminated area. If feasible, the utility should take
the appropriate isolation measures (e.g., closing valves, tanks) and notify impacted customers and
appropriate external agencies (in accordance with regulatory practices and guidelines). Outlining the
impacts of isolating certain areas of the system prior to an incident can be invaluable during an actual
incident, and should be considered as part of the CMP pre-planning efforts.
Listed below are four general types of isolation response actions that can be taken, depending on whether
the contamination source is known and whether the distribution system configuration is conducive to
isolation (e.g., valve placement, grid structure). In all cases, it is
critical that the utility have an accurate inventory of
distribution system valves, and that the valves are exercised
at regular intervals, to ensure effective and timely response.
Isolation from the contamination source (e.g., a
contaminated storage tank);
Isolation of one area of the system from another
(e.g., where a system uses two different sources of
treated water where one has contamination);
Isolation by "varying off specific customers (e.g., a
"dead end" neighborhood with water delivery
controlled by one or a limited number of valves);
and
Generalized isolation of the entire system with a
community-wide "do not use" order.
Once implemented, a successful isolation response will leave
potentially contaminated water in the distribution system that is
still accessible by customers. Therefore, thorough and effective customer notification following an
isolation response is critical to minimize the existing contamination contact risk.
IMPORTANT TIP
Pre-planning efforts, supported by
hydraulic and pressure modeling and
monitoring, should be used to
characterize isolation options and
determine whether the basic system
configuration is conducive to isolation.
Pre-planning efforts should also verify
staff availability (e.g., appropriate
adjustments to labor contracts),
establish isolation protocols, describe
a pre-determined incident decision
structure (including internal and
external ICS-related communication
and decision-making protocols), and
describe notification needs.
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Water Security Initiative: Consequence Management Plan Guidance
If the contamination cannot be isolated, then the utility should consider other operational procedures such
as flushing. Although flushing is typically a routine operation that utilities are familiar with, flushing
during a credible contamination incident should be implemented with care as the type and concentration
of the potential contaminant may be unknown at this time. Thus, worker safety/protection measures
should be taken and possible impacts to the environment due to discharged water should be considered.
The drinking water primacy agency should be consulted for any planned discharges to a wastewater
collection system or surface waters. Utilities should consider coordinating with their State regulators
concerning flushing activities during a credible contamination incident as a pre-planning step during CMP
development.
Conditions under which a utility could consider undertaking a flush operational response include:
The utility has obtained the needed regulatory clearances (e.g., State regulators have been
consulted and concur with flushing);
Isolation is infeasible (e.g., contaminant source/spread unknown or contamination has dispersed
to system areas lacking the technical capacity or configuration to support isolation);
Customer notification is anticipated to have limited effectiveness (e.g., contamination spread
involves the notification of many, widespread users); and
The weight of evidence suggests contamination is compatible with a flush response (e.g., the
contaminant type and concentration are sufficiently well known and deemed low risk in a release
context or, in the absence of this specificity, there are strong indications that a release from the
system will have no tolerable environmental, general public health, and sewer system impacts).
Another potential operational response action that may be considered by utility personnel involves
increasing the disinfectant dose at a water treatment plant or boosting the disinfectant dose in the field,
particularly for suspected biological contaminants. However, unless the contaminant type and location
are confirmed, this undirected response could be ineffective (if the contaminant is non-responsive) or
exacerbate the incident, as chlorine reactions with some contaminants may form by-products that are just
as, if not more, toxic than the original contaminant.
Increased disinfectant concentrations at the water treatment plant will also have a low probability of
contacting a contaminant slug that is already in the distribution system. Targeted chlorine boosting in the
system may be effective, but would require availability and transport of portable disinfectant booster
equipment and chemicals (not available to many utilities), unless contamination coincidently occurs in
close proximity to an existing booster station. Other concerns with disinfection as an operational
response include:
Since effective disinfection requires a dynamic hydraulic process (flow through the system), its
use would bar any isolation response;
Higher than normal disinfectant levels may cause a spike in consumer complaints, raise injection
concerns, and could mask the problem (assuming a drop in free and total residual is a key
indicator of potential problems in the system); and
Disinfection may introduce future de-chlorinization needs, all of which may complicate the
credibility determination process.
Thus, the primary role for disinfection should come in the remediation and recovery phase of
consequence management.
Appendix B.5 contains more detailed information concerning operational response activities, along with
an example decision tree template. This decision tree should be used as a guide when developing the
operational response steps of a utility-specific plan.
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Water Security Initiative: Consequence Management Plan Guidance
Develop/Implement Public Notification Strategy
As part of the confirmed determination process, the utility must consult with its drinking water primacy
agency to determine whether public notification (PN) is required. A PN strategy may include issuing
messages such as "boil water," "do not drink," or "do not use," in order to minimize the potential for
exposure of the public to the suspect water.3 The utility 1C and PIO, in coordination with the drinking
water primacy agency and local public health officials, should be responsible for developing this strategy
once it has been determined necessary.
PN in response to a water contamination threat or incident may be required under the PN Rule (40 CFR
141, Subpart Q). Specifically, the rule requires PN for "situations with significant potential to have
serious adverse effects on human health as a result of short-term exposure as determined by the primacy
agency either in its regulations or on a case-by-case basis." See Section 4.2 for more details on PN
Requirements.
Appendix B.6 also contains more detailed information concerning PN activities along with an example
decision tree template. This decision tree should be used as a guide when developing the PN steps of a
utility-specific plan.
Develop/Implement Alternate Water Supply Strategy
It is critical to have an alternate water supply strategy in place and ready to implement in the event that
water contamination seriously undermines the utility's ability to deliver services. Alternate water
supplies will be needed to support public demands, fight fires, and meet the demands of medically-
sensitive populations. While this plan is important for water contamination incidents, alternate water
supply plans can also apply to many other hazards and situations (e.g., natural disaster, drought).
Remediation and Recovery
Remediation and recovery actions should be performed if a contamination incident is confirmed. The
goal of remediation and recovery is to return the drinking water utility to service as quickly as possible
while protecting public health and minimizing disruption to normal life. During the remediation and
recovery stage, the immediate urgency of the situation has passed, and the magnitude of the remedial
action requires careful planning and implementation. While rapid recovery of the system is crucial, it is
equally important to follow a systematic process that establishes remedial goals acceptable to all
stakeholders, implements the remedial process in an effective and responsible manner, and demonstrates
that the remedial action was successful. Figure 3-3 provides a generic overview of the remediation and
recovery process.
Refer to the U.S. EPA Response Protocol Toolbox, Module 5, Public Health Response Guide (EPA-817-D-03-005) for example
notifications.
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Water Security Initiative: Consequence Management Plan Guidance
Risk assessment
Development of
feasibility studies
Analysis and
selection of
preferred remedial
activities
Figure 3-3. Remediation and Recovery Process Overview
The remediation and recovery process is designed to address contamination at concentrations that pose
immediate and/or long-term risks to human health and the environment. The process is described as a
sequence of steps that includes system characterization, risk assessment, remediation, and return to
service. Whether these actions are carried out with response partners or another agency assumes
management of the process, the utility should still be involved in each of the steps described in the plan,
which are outlined in Table 3-3.
The remediation and recovery activities may not necessarily
occur in sequential order, and may start at different times,
run concurrently, reoccur, or start before the remediation and
recovery phase (shown in Figure 3-3). For example, risk
assessment may begin during initial response and run
through remediation and recovery. Also, initial site
characterization sampling results may be used to begin
developing information on contaminant type, concentration,
viability, and may continue in more detail under system
characterization.
The extent to which the remediation and recovery process
follows the steps depends on the nature and extent of
contamination. For example, if the contamination is
contained through immediate operational response and is
confined to a well-defined area, then extensive system characterization may not be necessary; the initial
site characterization may provide sufficient information to guide remediation and recovery efforts.
Similarly, if treatment options for the contaminant of concern are known and well-defined, then the
feasibility study and detailed analysis of available alternatives could be combined.
IMPORTANT TIP
Because of the myriad of potential
contamination incident scenarios,
developing a remediation and
recovery plan for a specific event in
advance is unrealistic. Instead,
personnel from the utility, state
drinking water primacy agency, public
health agencies, EPA regional office,
and state and county EMAs and
homeland security offices should meet
as a group to identify and address
regulatory issues, provisions for long-
term alternative water supplies,
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Water Security Initiative: Consequence Management Plan Guidance
Table 3-3. Summary of the Typical Remediation and Recovery Process
Action
Description
System
characterization
and assessment
System characterization should be used to identify the nature, extent, and fate of particular
contaminants in the water system and components to support the selection of appropriate
remediation actions. The scope of system characterization is broader and more detailed than
the initial site characterization which gathered information to determine whether the threat was
credible.
Risk assessment
for remediation and
recovery
Risk assessment is the qualitative and quantitative evaluation of the risk posed to human
health and/or the environment based on a contamination incident. Risk assessment activities
should be conducted to: 1) evaluate risk reduction resulting from immediate operational
response actions; 2) help establish Preliminary Remediation Goals and Final Remediation
Goals; and 3) assess potential risk reductions from implementation of a long-term remedy (if
necessary).
Development of
feasibility studies
The feasibility study is the mechanism for development, screening, and evaluation of
alternative remedial actions. It is conducted concurrently with system characterization and
involves identifying remedial action objectives, identifying potential treatment technologies or
other response actions that will satisfy these objectives, and screening the candidate
technologies.
Analysis and
selection of
preferred remedial
activities
The remediation and recovery plan should include directions for the selection of alternatives
for the treatment of contaminated water as identified in the feasibility studies.
Design, installation
and operation of
remedial activities
After the final remediation response is selected, plans for the remedial design, installation and
operation of remedial activities should be developed.
Disposal of
residuals
Once the specific contaminant has been identified, the utility should create a plan that
provides instructions in the management, classification, and disposal of remedial waste
according to applicable regulations. Remedial waste could include contaminated surface or
ground water, decontamination fluids, water treatment residuals (e.g., biosolids), contaminated
equipment (pipes, home water filters, ice makers, water heaters, and garden hoses), and
personal protection equipment.
Implementation of
post-remediation
operations and
monitoring
To ensure continued compliance with the remediation objectives, the utility should create a
plan to conduct post-remediation monitoring and operation. This will necessitate quantitative
verification that the contaminant concentration has been reduced to acceptable levels, through
methods specified by the lead agency.
Return to service
and public
involvement
After the water source and/or distribution system has been treated and rehabilitated, the utility
should continue sampling and monitoring activities to confirm that the remediation goals have
been attained. Based on sampling and analysis results, the water utility and the responsible
agency (i.e., primacy agency and/or health department) should determine whether the
contamination problem is mitigated and the water system can be returned to normal
operations.
Source: U.S. EPA Response Protocol Toolbox, Module 6, Remediation and Recovery Guide, EPA-817-D-03-006
Depending on the circumstances, remediation and recovery efforts will include support from a range of
disciplines including HazMat, law enforcement, and local health departments. Multiple jurisdictions may
also be involved, ranging from city, county, regional, State or Federal response partner agencies.
The utility should develop a comprehensive remediation and recovery plan as part of the CMP.4
Appendix B.7 provides an example of a decision tree for the remediation and recovery process. This
decision tree should be used as a guide when developing the sections of the utility-specific plan. The
remediation and recovery plan and material should be written to represent and reflect the specific utility
organizational structure and capabilities.
Refer to the RPTB Module 6, Section 6: Remediation and Recovery Guide (EPA-817-D-03-006) for further information on
remediation and recovery activities.
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Water Security Initiative: Consequence Management Plan Guidance
3.3 Step 3: Identification of Key Response Partners and Stakeholders
When constructing the initial draft of the CMP, the utility should identify partners and stakeholders that
may be involved in the development of the CMP and corresponding response activities. Teaming with
partners and stakeholders significantly streamlines response efforts and allows all parties the opportunity
to understand the official processes and procedures used in the event of a drinking water emergency. It
should also ensure that the CMP is integrated and consistent with external emergency response plans.
Figure 3-4 provides an overview of potential partners involved in the development and implementation of
a CMP.
Federal Bureau of
Investigation
State Emergency
Management
and
Homeland Security
Agencies
Department of
Homeland Security
State Law
Enforcement
Centers For Disease
Control and Prevention
EPA Regional Offices
^ A
Local Health Local Wastewater Local Law
Department Utility Enforcement
^- -^
Local Fire, EMS, / Wgter
and HazMat 1 utj|jty
^ ^
Local Emergency Host
Planning Committees Facilities
V^
State Drinking and Waste
Water Primacy Agencies
\ Local Civil
j Government
S
Public Health and
Environmental
Laboratories
Neighboring Utilities
EPA Criminal
Investigation Division
National Response
Center
State Emergency
Res ponders
State Government
Media
Figure 3-4. Potential Contamination Warning System Partners
As illustrated in Figure 3-4, the number and scope of partners potentially involved in responding to a
contamination incident can be significant. The figure includes local responders in the inner circle, with
State, regional and Federal partners in the outer circle. This configuration mirrors how a contamination
incident is initially investigated at the utility and local responder level, before involving State, regional
and Federal partners as the incident escalates or when local capabilities are overwhelmed.
When identifying partners, the utility should first consider those partners involved as "first responders"
based on the CMP. These may include local partner organizations such as local law enforcement, public
health and fire services. State, regional, and Federal partners should also be considered after local
responders are identified.
Specific responsibilities of partners and when they are engaged will vary by utility and jurisdiction.
However, Appendix D.2 provides a summary of possible local, State, regional and Federal response
partners and their potential role in design, implementation and/or response.
3.4 Step 4: Engagement of Response Partners and Stakeholders
When developing and implementing a comprehensive CMP, the external response partners identified in
the previous step should not only be specifically identified, but also effectively engaged. The utility
should collaborate with external response partner agencies to confirm and determine roles and
responsibilities, solidify lines of communication, identify shared resources, and ensure that the draft CMP
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Water Security Initiative: Consequence Management Plan Guidance
matches operational response plans held by other response partners. The utility should meet with and
confirm that other agencies agree with the earliest points of contact, have the correct contact information
and that expected response actions are correct.
Engaging the numerous partners involved in setting up a contamination warning system and the
corresponding CMP is a daunting challenge on its own, without the myriad of other tasks the utility
implementation team may be occupied with. It is not uncommon for the service area of a utility to extend
beyond city limits and county borders, and into the jurisdictions of numerous police, fire, and public
health agencies, not to mention the umbrella jurisdictions of hierarchical agencies such as county and
State emergency management, public health, and homeland security agencies, to name just a few.
Therefore, it is important to take full advantage of the existing groups and organizations in which these
partners may already participate. Figure 3-5 illustrates the recommended approach for engaging partners.
Dtrecf
with hey county,
84aift, andfedtral
partners
Engagement
ttirauQh existing
grcvp*
Figure 3-5. Recommended Strategy for Engaging Consequence Management Plan Partners
It is recommended that primary local partners should be engaged first, followed by the county, State, and
Federal level agencies. During this process, the utility and partners should also try to identify and
leverage existing communication and response networks that may have been established by other
programs, such as Local Emergency Planning Committees ^
(LEPCs). / LESSON LEARNED
The reason for engaging local partner agencies first is two-fold.
First, local agencies will likely be the first re spenders to
potential contamination incidents that originated in their
jurisdiction. Second, because they are the first responders, they
will be providing the initial response resources, including
staffing and equipment. As a result, the utility should know
what resources are at its disposal during the early stages of an
incident. The next step should be developing new supporting
materials and organizing meetings with expanded response
partners, including county, State, and Federal agencies.
Partner Meetings
When developing the CMP, partners can be engaged either
through one-on-one contact and meetings, workshops with all
partners, or a combination of both. It will be up to the utility to
Many utilities serve wide-ranging
areas that cover numerous
jurisdictions, counties, and even
states, making coordination activities
quite challenging. For the initial pilot
utility, engagement of local response
partners was limited to the two largest
jurisdictions in the service area. This
approach allowed for the CMP to be
developed in a comprehensive
manner while keeping the size of the
effort manageable in the early phases.
Once established, the CMP was
presented to corresponding response
partners in neighboring jurisdictions to
incorporate their roles into
consequence management activities.
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Water Security Initiative: Consequence Management Plan Guidance
assess the method that is most appropriate for its environment and situation. During these meetings, the
utility, along with local and expanded partners, should agree on response actions and decisions that will
likely occur both before response partner involvement as well as after response partners are contacted for
assistance. The ability to verify available capabilities and resources should also be confirmed, along with
contact information for all meeting participants. This process is also part of integrating the CMP with
other existing plans and operations that may be initiated during an incident.
For those agencies that cannot attend the planning meetings, an effort should be made to provide them
with copies of the draft plan, support materials, and revised plans for their input and comment. It is often
useful to use a scenario as a descriptor in covering this material, as it provides a context for decision
making. Scenarios addressed with these partners should include the process of credible determination
through response and recovery (e.g., a scenario where the utility and local partners have reason to suspect
the water has been contaminated based on a validated trigger which leads to the decision-making process
for the follow-up investigation).
One-On-One Meetings
One-on-one meetings have the advantage of building direct contact and relationships with partners. They
can be used to verify notification plans, roles and responsibilities and response capabilities should a water
contamination incident occur. Questions to be addressed should include:
How do partners want to be reached during a contamination incident?
Who is the point-of-contact or person in charge?
What information do they need regarding the incident?
Do they have a standard beeper/cell phone number which is passed to the next on-call
representative, or does each person have a dedicated beeper/cell?
Where will they meet during response?
What are their responsibilities and/or authorities?
Partner Workshops
Engaging partners through coordinated workshops is an effective
means to develop a CMP that is truly integrated with response / DUAL USE
partner actions. These workshops should consist of a utility
facilitator guiding the group through a draft of the CMP and
., ..,, , , ., .,... . , T partner meetings in the development
identifying roles and responsibilities at each major action. In £f jts CMp Th^se meetings .
this way, the actions and responsibilities for each partner are
confirmed and clarified. This open workshop environment helps
to verify assumptions between one agency and the utility as well
as assumptions that external agencies may have about each
other.
At the end of the workshop, all of the responses should be
The WS pilot utility held multiple
workshops had the added benefit of
allowing partners to clarify their roles
with other partners. Not only was the
utility able to gather its information and
contact numbers, but partners were
also able to confirm their roles and
responsibilities, resources and contact
information amongst each other, thus
collected and analyzed to identify the actions in the CMP that are \ uPdating their own P|ans-
to be expanded or corrected, as well as issues and gaps that need to
be resolved (e.g., communications, equipment, procedures, jurisdictions). Two major categories of issues
usually surface from the planning workshops include resources (e.g., equipment, personnel) and training.
The outcome of these partner meetings should be a near complete draft of the CMP. Keep in mind that
the CMP may never be "final," as it may be open to revision based on changing relationships, agency
reorganization, etc. Additionally, as the implementation of the contamination warning system progresses,
some changes may be warranted.
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Water Security Initiative: Consequence Management Plan Guidance
Once the roles and responsibilities of partners have been established and integrated into the CMP, the
next step should involve training. The utility should involve partners in all CMP-related training events.
In addition, the utility should take steps to become a member of the various groups, including LEPCs, and
engage in the training exercises that are sponsored by the partners (refer to Section 6.0 for information on
Training). Involving the utility in exercise efforts at the local, county, State, and even Federal level
should enhance response efforts for both the utility and response partners.
Considerations for Agreements with Local Partners
The use of memoranda of understanding, memoranda of agreement, mutual aid and assistance
agreements, and other agreements are becoming common in most jurisdictions. These documents often
contain language that is mutually agreed upon by the parties to the agreements and generally define
collaborative efforts that involve action items, equipment resources, or regional governance.
When engaging local, county, State and Federal partners in implementation activities, the utility should
address the subject of these types of agreements early in the process. Addressing formal agreements early
in the implementation process is extremely important, as they may
commit partner agencies to specific roles and actions. Without
them, implementation can be stalled by inter-agency
disagreements or misunderstandings, or an agency may be left
responsible for costs they believed would be covered by another.
IMPORTANT TIP
The utility should first identify its own protocols for establishing
formal agreements with external agencies, organizations, and
partners. This includes identifying who holds the authority to
enter the utility into these types agreements (who signs the
document), any procedural details, (e.g., minimum or maximum
review periods, paperwork routing procedures), restrictions on
the types of agencies/groups the utility may enter into
agreements with (public and private), or limits of commitment
(monetary or other). The utility should also obtain a clear
understanding of the same types of information from the
agencies it intends to engage. Subjects of the agreements extend
beyond simply who pays for equipment; commitments should be
made to provide personnel both for the implementation and
operation of the contamination warning system; allocation of
resources; etc. If funding is from an external source, all
applicable standards and regulations for establishing formal
agreements should be followed.
The water sector is actively
developing mutual aid and assistance
agreements, commonly referred to as
Water and Wastewater Agency
Response Networks (WARNs), which
provide a single mutual aid and
assistance agreement for both public
and private drinking water and
wastewater utilities within a state.
This agreement provides access to
personnel, equipment, and resources
from neighboring utilities that possess
the specialized resources needed to
support the response and recovery of
water sector operations.
While the WARN framework is
structured around utilities, it could
provide the foundation to leverage the
initial response partner meetings once
established and mature. Refer to
Appendix E for links to additional
information on mutual aid and
assistance networks.
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Section 4.0: Communications
Communication plans are an essential component of a contamination warning system and CMP. They
prepare drinking water utilities for both routine and incident-specific communications with customers,
response partner agencies (e.g., local, State and Federal government offices), the media, and the public at
large. The overall communication strategy includes developing plans, defining roles, and identifying
resources and equipment. Utilities can elect to develop communication plans as an integrated component
of the CMP, or as a standalone plan.
Information management is also a critical component of a sound communication plan and is used to
control the flow of information during response to a threat or incident. This section will assist the utility
in developing their general and risk communication plans, as well as crafting an information management
strategy.
4.1 General Communications
General communications involves plans for both internal and external response partner communications.
Internal utility communications include employees as well as those persons involved in the determination
of and response to an incident. External communications involve coordination with outside agencies and
populations directly involved in or having the possibility of being affected by an incident. Throughout
the CMP, particular attention should be paid to these types of communication plans in order to provide
timely and effective communication to CMP participants in the case of a contamination incident.
Internal Utility Communications
Internal communications should address what, when, and how a message will be provided to utility
employees who are directly and indirectly involved in an incident. Informing utility employees of a
contamination threat/incident increases awareness and better prepares them to provide informational and
logistical support. Direct communication also prevents the spread of negative rumors and adds to the
cohesiveness of response teams.
The internal communication plan should outline the personnel responsible for activating the plan, the
order in which notification occurs, and the members of the appropriate response teams (as outlined in the
ICS structure). In addition, the plan should provide information on the specific communication method(s)
that should be used (e.g., telephone, radio, email). If possible, the internal communication plan for the
CMP should leverage existing internal communication plans to identify gaps and opportunities for
improvement.
During a crisis or serious incident, organizations may consider using supervisors in a cascaded
communications process, whereby supervisors are responsible for communicating information to their
personnel. This ensures that information is delivered to employees through a credible source. Direct
supervisory communication also allows managers to answer employee questions and address their
concerns.
The effectiveness of internal communications - especially during a crisis - also depends on the rapid
communication of events and directions between the management team making response decisions and
the response personnel implementing the decisions. Rapid communication methods normally consist of
telephones, cell phones, emails, loudspeaker systems (including intercoms and closed-circuit television
monitors), written bulletins or newsletters, and hand-held radios. All of these communication channels
have inherent positives and negatives, and a good communication plan should incorporate a combination
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of methods so that the various groups of personnel can exchange required information on a timely basis.
When identifying the means of communication, consider the following parameters:
Does the communication method reach all consequence management participants?
Is the method reliable?
Is the method fast enough to support timely decisions and actions?
Is the method likely to be compromised by contamination incident conditions?
Is there a back-up or redundant system?
Will the method preserve facility security under threat conditions?
External Response Partner Communications
Communication and coordination with external response agencies
should be addressed throughout the CMP. External communications
involves agencies and groups that may be direct partners in
responding to a contamination threat/incident. This includes groups
that can be affected by the incident itself, either through
contamination or through mitigation efforts. In addition, other
agencies not directly involved in the initial response to a
contamination incident may need to be alerted so that they can
coordinate their support or resources accordingly.
The external communication plan should address when and how to
contact response partners during credible, confirmed and recovery
stages of a contamination incident. The external communication plan
should also leverage any existing communication plans to identify
gaps and opportunities for improvement.
The utility should include the following steps when developing their
external communication plan:
1. Compile a list of external response partners (Refer to Section 3.3).
DUAL USE
A communication method that may be
useful when providing the public with
information is a reverse phone
information system. Examples of this
include auto-dialer systems or a
reverse voice recording system based
on client records. This type of
equipment could be used to deliver
direct and concise phone messages
from the utility out to affected
populations.
The overall need and added value of a
reverse phone system would need to
be evaluated by each utility and would
depend on the type of phone system
and database used, along with
budgetary restrictions.
2. Determine contact information for each agency on the list and create a database containing the
information. This database should include primary and two alternate contacts, telephone/cell
phone numbers, email addresses, emergency or off-hours contact information (on-call lists, etc.).
3. Prepare/update the external communication procedures and establish:
Who will initiate external communication (e.g., Utility Director/IC);
Who will prepare communication/notification (e.g., PIO);
Who will make the actual notification;
Who will update and maintain the external communications database; and
Decision points within the CMP which will trigger external communications.
4. Conduct periodic drills of the external communication plan to verify operability.
Once a draft of the plan has been developed, the utility should meet with the agencies to verify
assumptions made in the steps listed above. The objective should be to confirm and coordinate external
roles and ensure that the draft CMP matches operational response plans of these other response agencies.
In accordance with the NIMS, the external communication plan should stress interoperable
communication processes and architectures to allow the utility and incident command to communicate
directly with outside agency first responders, EOC(s), and the incident command post. Beyond physical
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communication equipment, the utility and response partners should also establish shared emergency
response channels or frequencies for immediate use during a water contamination incident.
Communication equipment includes standard two-way radios and other communication devices, such as
800 MHz radios. Equipment resources should be evaluated during development of the plan and verified
for compatibility with outside partners.
4.2 Risk Communications
Drinking water crisis incidents will involve communications with
employees, government agencies, the public, the media, and others
about potential risks to health, infrastructure, and the environment.
The purpose of a risk communication plan is to guide the utility and
its partners on when and how to make notifications, how to define
the message, how to work with the media and how to develop a
delivery system for the message. The goal of risk communication
is to enhance knowledge and understanding of an incident, build
trust and credibility, encourage constructive dialogue, and provide
guidance on appropriate protective behavior and actions following
a crisis incident. Useful tools that should be included in the plan
are existing PN regulations and guidelines, diagrams and trees, and
sample message maps.
IMPORTANT CONCEPT
Message mapping is a process by
which the utility can prepare clear and
concise answers (message maps) to
these questions, along with supporting
information, ahead of time, and
practice effective message delivery
before a crisis occurs. Further
information on message mapping can
be found in EPA's Effective Risk and
Crisis Communication during Water
Security Emergencies Report:
http://www.epa.gov/nhsrc/pubs/report
CrisisCom040207.pdf.
Risk communication plans allow for a proactive, quick, and effective response during an emergency since
many of the necessary communication decisions and activities will have already been decided upon. If
carefully designed, a risk communication plan can save precious time when an emergency occurs and
enable leaders and spokespersons to focus on particulars of the emergency at hand and the quality,
accuracy, and speed of their responses.5 This section will assist the utility in developing its risk
communication plan as part of the CMP.
Roles
The first step in developing a risk communication plan is to identify the utility personnel responsible for
communicating with the public during a contamination incident. During a crisis, the communication
function can be broken down into the six distinct roles as described in Table 4-1. Ideally, there should be
one person assigned to each role, although one person can handle additional roles depending on the extent
of the emergency and the size of the utility. While other staff may be involved, the utility PIO is
ultimately responsible for all communication efforts. Each utility should create and define roles based on
its own organizational structure and capabilities.
Source: Adapted from HyerRN, Covello VT. Effective Media Communication during Public Health Emergencies: A WHO
Handbook, WHO/CDS/2005.31, World Health Organization, Geneva, 2005
(www.-who.int/csr/resources/publications/WHO_CDS_2005_3 I/en/)
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Table 4-1. Recommended Crisis Communication Roles
Title
Public Information Officer
(PIO)
Communication Responsibilities
Activates the risk communication plan after receiving authorization from the 1C and
directs the work related to the release of information.
Provide information to the public and other key internal and external audiences
through such activities as developing and distributing printed and electronic notices,
reports and informational materials; organizing and conducting special events
(internal and external); and maintaining content on a Web site.
Develops and maintains relationships and supports two-way communication with
public and private stakeholders, community groups and with the news media.
May develop speeches and presentations for utility executives and craft responses to
constituent inquiries received via letter, email or telephone call.
PIO Support Personnel
Content and Message
Coordinator
Media Coordinator
Direct Public Outreach
Coordinator
Partner/Stakeholder
Coordinator
Media Tracker
Develops mechanisms to receive information rapidly from the EOC regarding public
health emergencies and works with available subject matter experts to create situation-
specific fact sheets (e.g., "Q&A" fact sheets) and updates.
Assesses media needs and organizes mechanisms to fulfill those needs.
Activates a telephone information line, crisis Web site and develops public service
announcements.
Establishes communication protocols based on prearranged agreements with identified
partners and stakeholders.
Monitors internal and external communications, identifies misinformation, provides
feedback on the quality of communication, takes action to correct false information,
tracks media information releases, monitors news outlets and Web sites, and dispels
rumors.
Public Information Actions
The next step in developing a risk communication plan is to outline the public information actions that
correspond with the various response phases of a contamination incident. Note that public information
actions may occur early in the threat process, even before consequence management actions are initiated.
Thus, specific communication roles and activities that may be conducted by the PIO and other staff
during an incident should be developed for all response phases (e.g., possible, credible, confirmed).
Public information actions may include coordinating press briefings, developing communication plans,
preparing and disseminating notifications, and arranging public meetings. An example of actions linked
to specific contamination warning system phases can be found in Appendix C. Refer to this example
when outlining the public information actions for each response phase of a contamination warning
system.
Public Notification Requirements and Guidelines
When developing the risk communication plan, the utility should ensure that its plan is consistent with the
regulatory requirements for public notification (see 40 CFR 141, Subpart Q). When a utility determines
that a contamination threat is credible, the utility must consult with its primacy agency to determine if
public notification is required. Under federal regulations, public notice is required for "situations with
significant potential to have serious adverse effects on human health as a result of short-term exposure, as
determined by the primacy agency either in its regulations or on a case-by-case basis". The utility must
initiate consultation with the primacy agency to determine public notification requirements as soon as
practical, but not later than 24 hours after learning of the situation. These situations require a Tier 1
public notice. See 40 CFR 141, Subpart Q for information on the form, manner, and frequency of a Tier 1
public notice. Also refer to Appendix E for information on EPA's "Public Notification Handbook,"
which contains additional guidance regarding PN and the requirements of the notification rule.
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Tools and Resources for Working with the Media
One of the most important functions of the PIO is communicating with the media either directly or in
helping to prepare for press interactions by water utility officials. This is especially critical for risk
communications. Refer to Appendix E for a list of tools and resources for working with the media.
4.3 Information Management
Information management is the process of collecting, documenting, and managing the large amount of
information that may be used during the threat/incident determination process to support decisions about
various response actions, including communication. This includes collecting and documenting all aspects
of an incident so that vital information does not get lost. Developing an effective information
management strategy helps to promote and maintain overall awareness and understanding of an incident
within and across jurisdictions and thus contributes to sound communication principles. Documenting
incident information may also help to effectively manage liability issues, cost recovery, and meeting
certain regulatory requirements that may arise as a result of a contamination incident.
When developing an information management strategy, the utility should consider including pre-incident
information (e.g., baseline data), a chronological log of events, written record of all decisions and chain of
custody documentation for all laboratory samples. A useful tool for capturing this information is the ICS
Form 201, the Incident Briefing (Page 104 of the NIMS document:
http://www.fema.gov/pdf/emergency/nims/nims doc full.pdf). The form is intended to be used by the 1C
to document actions and situational information required for transfer of command. This, in turn, assists
the 1C in documenting information quickly while staff is limited and the incident is dynamic. Keep in
mind that this form can either be modified or the utility can create their own incident log in order to meet
their specific needs. Refer to Appendix E for additional information management tools.
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Section 5.0: Training and Exercises
Success in implementing the concepts, guidance and procedures contained in a utility-specific CMP
comes from execution. The ability to effectively execute a CMP comes from training personnel
responsible for its execution. The training and exercise process allows utility staff to face tasks and
situations normally outside of their daily operations to enable them to meet the challenges associated with
an actual contamination incident. In addition, effective training and exercise programs are useful for
integrating response procedures with those of external partners.
In the end, training and exercises allow the utility to learn from its mistakes, thereby recognizing potential
opportunities for change and enhancements in the plans and procedures already in place. This section
provides guidance on how to identify and conduct the appropriate training for the CMP.
5.1 How to Implement the CMP through Training
To ensure an effective consequence management program, training should be conducted to familiarize
utility staff and response partners with the CMP and their corresponding roles. Now that roles and
responsibilities have been more clearly defined in the CMP, training is critical to get the staff and partners
"up to speed." Training should include information concerning how the CMP is organized (e.g., credible,
confirmed, remediation and recovery), the corresponding steps associated with each response, and
identifying roles and responsibilities. Additionally, training activities associated with specific CMP
activities (e.g., field sampling, site characterization) may need to be conducted.
Training events should also stress integration of utility personnel with external partners to establish a
consistent, shared understanding of response roles and capabilities. The coordination roles of both parties
during an incident should be clearly understood, including the processes and applicability of working
together under an ICS.
Training Program
The personnel responsible for developing the CMP should coordinate the training exercises. There are
many resources that can be used to assist with training development, including Federal, State, local, and
even private sector entities which prescribe training programs designed to establish and maintain
operational competency for a wide variety of initiatives. The training strategy recommended for utility
CMPs is a suite of core courses in the ICS, augmented by a progression of exercises which are described
by the Department of Homeland Security's Homeland Security Exercise and Evaluation Program
(HSEEP).
HSEEP describes "Discussion-Based" exercises, which include tabletops, seminars, and workshops to
introduce and teach new concepts, followed by "Operations-Based" exercises including drills, functional
exercises and full-scale exercises to test and evaluate program effectiveness.
It may be challenging for most utilities to implement an entire HSEEP-based program, but by integrating
efforts with local partners, it may be achievable. A modified training program based on the HSEEP
strategy has been successfully implemented as part of the WS initiative consequence management pilot
program. This program started with "Discussion-Based" exercises, including a needs assessment
workshop, followed by an advanced tabletop (walk-through of the CMP with a contamination threat
scenario) for utility managers and supervisors. This was followed by specific functional exercises,
including Site Characterization Plan training, with utility and response partner agencies under several
what-if contamination scenarios. The final training program consisted of an "Operations-Based" full-
scale exercise of the CMP, with mobilization of both utility and support agency assets in a contamination
incident scenario.
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Utilities and response partner agencies should institute an ongoing program of internal drills to maintain
competency in their respective procedural roles, and should also schedule periodic integrated exercises to
assess program continuity. It is recommended that operations-based exercises be conducted every two
years and after changes to the CMP or significant changes in personnel. This assumes that there is a
regular program of drills of critical activities in place (e.g., trigger verification, site characterization).
Discussion-based exercises can be conducted annually based on routine updates to the CMP.
5.2 Training Courses and Materials
Consequence Management Plan Training
As previously stated, discussion-based training courses for the CMP should include information as to how
the CMP is organized (e.g., credible, confirmed, remediation and recovery), the corresponding steps
associated with each response, and identifying roles and responsibilities. Table 5-1 provides an example
of training exercises that were conducted for the WS initiative pilot utility. They can be used and
modified to train utility staff and external response partners.
Table 5-1. Example Consequence Management Plan Training Exercises
CMP Training Exercises
Training Events
Description
Audience
Utility Management
Training
The goal is to provide background and overview of the CMP
to utility upper management. In turn, they will provide the
necessary information and training to their respective
department staff.
Utility upper-management
Site Characterization
Plan Training
This training will serve to prepare participants in the use of
the CMP site characterization plan. The goal is to prepare
participants for field application of the plan material and
processes during real-world events with improved
understanding of operations and integration with other
teams. The training effort will increase the capability of
utility site characterization teams and improve the level of
preparedness in response to a potential water
contamination incident.
Target personnel actively
involved in site
characterization deployment
(response teams, who
deployed them)
CMP Training -
Functional Exercise
The purpose of this exercise is to assess utility and
stakeholder (local support organizations) familiarity with the
CMP through a series of scenarios/tabletops. The
exercises will target critical decisions made by key
personnel after receiving a validated trigger (from Concept
of Operations). Key personnel would include the 1C, ICS
Section Chiefs (leads), PIO and Agency representatives.
Specific roles for each of these individuals will be covered
through the exercise at various stages of a contamination
incident (Possible through Confirmed and Remediation &
Recovery). This training will help prepare utility staff and
their response partner agencies for the utility-wide
contamination warning system operations based full-scale
exercise.
Utility division heads,
supervisors, &
representatives from outside
agencies
Incident Command System Training
It is recommended that a core curriculum of ICS training be completed by utility and support agency
personnel. FEMA's Emergency Management Institute offers a suite of four ICS courses in its
independent study program:
IS-100: Introduction to Incident Command System for Public Works Personnel: This course
is designed for Federal disaster workers, public works, and law enforcement and public health
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personnel. The course describes the history, features, principles of ICS, and the relationship of
ICS to the NIMS.
IS-200 ICS for Single Resources and Initial Action Incidents: This course enables supervisory
personnel to operate efficiently within an ICS, and explains roles and responsibilities, and ICS
protocols?
IS-700 National Incident Management Systems (NIMS), an Introduction: Explains the
principles and structure of the NIMS, discusses ICS as a response model for NIMS and the
applicability of NIMS in wider-scope, multi-jurisdictional incidents?
IS-800 A National Response Framework (NRF), an Introduction: Describes how the Federal
government will work with State, local and tribal entities in responding to national emergencies?
It is recommended that management and supervisors complete all four courses, and that field personnel
complete at least the first two. Refer to Appendix E for information on these courses and additional
training resources.
Exercise Development and Scenarios
Once the plan has been drafted and staff are trained and prepared, the
overall CMP, including procedures and capabilities, should be
evaluated to identify opportunities for corrections and adjustments.
This is done through the use of "Operations-Based" exercises.
Exercises can be used to test and evaluate the utility and
stakeholder implementation of the functions and activities
associated with the CMP. They provide an opportunity for utility
and response partners to practice their assignments, including
hypothetical trigger scenarios of the contamination warning system
components and follow-through exercises. By conducting
exercises, the utility can identify and correct any deficiencies or
weaknesses in the CMP before a real incident occurs.
Scenarios developed for use in training exercises should only be
broad enough in scope to test the desired portion of the overall
CMP. An exercise to train utility personnel on the CMP should
contain incident threat triggers that go beyond normal operations
(e.g., multiple monitoring alarms being triggered, numerous
consumer complaints), but are still manageable by the utility. If the
objective is to test utility and support agency integration, the
exercise should contain elements that would trigger support agency
involvement.
Refer to Appendix E for additional exercise resources, including
FEMA courses on exercise design.
IMPORTANT TIP
The WS pilot utility conducted a full-
scale exercise for utility staff and
response partners. The focus was on
implementing and analyzing the
credibility determination and response
components of the contamination
warning system.
The exercise involved presenting a
scripted hypothetical contamination
incident to the utility, and then
evaluating actual response actions
versus those actions outlined in the
CMP. Both the utility and response
partners were actively involved in field
responses and used existing
communication equipment (e.g., 800
MHz radios). After completion of the
exercise, a detailed discussion ("Hot-
wash") of events took place in order to
analyze performance and capabilities.
Lessons learned were then
documented and used to make
changes and updates to their plans
based on weaknesses identified.
5.3 Revision of the CMP Based on Exercises or Actual Incidents
A comprehensive training program does much more than just test the knowledge and competency of the
participants; it reveals areas for improvement in the content and structure of the plan. It is therefore
extremely important that all exercise planning includes provisions for capturing results. Mechanisms to
document training actions may include evaluator or observer forms filled out during the exercise,
meticulous notes taken during the exercise, post-exercise debriefs or "Hot-washes" and formal after-
action reports prepared after exercise completion. The key is to assure that management and field
personnel are both made aware of the results, in a no-fault atmosphere, and that the personnel responsible
for maintaining the CMP oversee the incorporation of exercise results into plan improvements.
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In a like manner, actual incidents also generate information that should be assimilated into the CMP on a
continuing basis. Whether from false system monitoring alarms, accidental spills, or intentional
contamination of the system, actual incidents which are not "normal" operations result in "Lessons-
Learned" that should be captured, evaluated, and scrutinized for possible inclusion in the CMP. Incident
forms developed as part of the Response Protocol Toolbox: Response Guidelines can assist with
collection of this data. A link to this document can be found in Appendix E.
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Section 6.0: Implementation, Maintenance, and Updates
Once the CMP has been completed, there should be a predetermined plan of action for implementation
and maintenance. Implementation should involve the integration and sustainability of the plan within the
utility and surrounding community. Maintenance should involve scheduling reviews and updates of the
plan on a regular basis. Failure to formally implement or maintain the CMP will ultimately limit its
effectiveness. This section provides guidance on how utilities can best implement and maintain their
plans.
6.1 Plan Implementation
There are several steps typically involved with implementing a completed CMP, including
communication, assessment, and preparation. Communication involves familiarizing utility staff and
response partners with the CMP and their respective roles and responsibilities. Assessment involves
determining utility capabilities to manage consequences from a contamination incident. Preparation
involves training in the use of the plan and corresponding operational
components. Each of these steps should be addressed to ensure the
success of the CMP and its sustainability.
IMPORTANT TIP
Communication
The first step in implementing a CMP should be to ensure that the
major features of the plan are communicated to all participating
personnel (utility staff and response partner agencies).
Communication generally involves the following sequence of
activities:
Information officers from the utility and response partner
agencies should prepare and distribute an information package
to all personnel having a role in the CMP. The package
should describe the plan and its objectives.
The utility and response partner agencies should conduct "all-
hands" meetings with their staff to walk through the major
features of the plan and discuss their organization's role in
implementing it. Personnel should be invited to submit
comments and suggestions regarding the plan.
Assessment
Once utility staff and response partner agencies are familiar with the
plan, the utility should assess and identify the organizational
components needed to implement the various functions defined in the
CMP. This approach should include identifying the current
capabilities and resources on hand, comparing these capabilities and
resources to what is needed, and identifying corresponding improvements. The assessment should focus
on identifying and developing the utility's specific capabilities to manage and respond to a contamination
incident, including organization, staff skills, tools and equipment (e.g., sampling equipment, personal
protection equipment, field screening equipment, communications equipment, additional site
characterization equipment), related technology systems, and emergency plans/experience.
Preparation
Finally, once the major operational components of the plan have been assessed and identified, the utility
should prepare staff and response partner agencies for carrying out the functions of the CMP. This
involves implementing the integrated training and exercise program as discussed in Section 5.0. This
The CMP may contain sensitive
information, so utilities should take the
necessary steps to ensure its security
(e.g., secure Intranet/Internet site,
employee training). Sensitive
information should be placed in
appendices, or in sections that are not
readily available to unauthorized
personnel. The CMP, however,
should be easily accessible to
authorized personnel and should be
easily identifiable during a major
event. Steps taken to limit access by
unauthorized persons should consider
local and State information disclosure
requirements. Alternatively, you can
opt to make the CMP general in
nature and not include specific
information about system
vulnerabilities.
A secure copy of the CMP should be
maintained in an off-premises location
in the event that your primary copy
cannot be accessed. In addition, all
copies of the CMP should be
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Water Security Initiative: Consequence Management Plan Guidance
program should consist of a sequence of functional training and full-scale exercises to train personnel and
evaluate the effectiveness of the CMP. This should include the interaction between the utility and its
response partner agencies as well as the combined implementation of an ICS. After each of these
scheduled training events, the results should be incorporated into adjustments to the CMP and its
procedures.
6.2 Plan Maintenance and Updates
IMPORTANT TIP
Not only is it critical to maintain the
CMP, but it is also important to
maintain communications equipment
and inter-operability. Communication
equipment should be kept current,
maintained, and in good working
order. Utility personnel should have
equipment that allows them to
communicate between the field,
operations center and local partners.
The utility should also maintain other
redundant communications abilities,
such as email, land phone lines, short
range walkie-talkies, cell phones, etc
Once the CMP has been prepared (to the extent possible), the plan should
be properly maintained over time. The key to keeping a CMP relevant is
to treat it as a living and evolving guidance document. To accomplish
this, the utility should establish some maintenance guidelines. These
guidelines should specify the actions needed for routine and non-routine
updates to the CMP, the circumstances under which the updates will
occur and the organizations responsible for the updates.
Ideally, a standing maintenance committee should be assembled
comprised of utility management, field personnel, and support agency
representatives. The Utility Director or designee should act as the
committee chairperson. This committee would serve to coordinate the
maintenance of the plan and allow for input from the various
departments and operations. However, this type of support may not
always be available, so it is important to ensure that the responsibility for
plan maintenance is assigned to the appropriate utility staff.
Routine and Non-Routine Updates
The CMP Maintenance Committee, or individual assigned to its maintenance, should review and evaluate
the operability of the plan on a periodic basis. It is recommended that the CMP be reviewed on an annual
basis and after each scheduled training/exercise activity. This is important since operational changes
within the utility and response partner agencies occur on frequent basis.
The plan should also be reviewed for any potential changes and operability following non-routine
incidents:
After any personnel change that may alter management, field team, or ICS composition;
After any significant changes to sampling, analytical, or equipment procedures;
After any significant changes to the water treatment or distribution system;
After any significant changes to the monitoring system components, concept of operations, or
procedures; and
After any off-normal occurrence that triggered the activation of the CMP.
Any modifications to the plan should be evaluated to assess whether those changes and updates affect
coordination with response partner agencies. Response partner agencies should be advised of any
changes or revisions to the plan that might affect coordination assumptions between the two
organizations. Changes to processes and procedures should also be evaluated to determine how they
might affect other internal operations, plans and procedures.
It is recommended that the CMP Maintenance Committee, or individuals assigned to its maintenance,
make all indicated changes to the plan, coordinate the review and approval of signatory agencies, and
produce and distribute hard copies of the plan to those persons involved in operations and implementation
of the plan. One useful method is to have a secure Intranet/Internet Web site to host electronic versions of
the plan, as well as other emergency-related information.
October 2008
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Copies of the plan should be tracked and accounted for regularly. Copies of the plan should be numbered,
as it is likely to be considered sensitive information. A central list should keep track of which divisions
and other agencies have copies, where they store their copy, the person that is responsible for keeping it at
that location, and the last date that it was updated or issued a number.
Finally, it is recommended that the CMP be dated and re-certified as operable by plan signatories after
each update activity upon the recommendation of the CMP Maintenance Committee or the individual that
is in charge of the plan.
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Appendix A: Glossary
Anomaly. Deviation from an established base-state. For example, a water quality anomaly should be a
deviation from typical water quality patterns observed over an extended period (i.e., a base-state).
Operational Strategy. A process for routine operation of a drinking water contamination warning
system, which establishes specific roles and responsibilities, process and information flows, and
procedural activities. This includes the process for validation of a contamination warning system trigger
and determining whether or not contamination is possible.
Confirmed. In the context of the confirmed determination process, water contamination should be
characterized as confirmed when the analysis of water quality or public health surveillance has provided
definitive or nearly definitive evidence of the presence of a specific contaminant or class of contaminant.
Confirmed Determination. Confirmed determination describes the stage of an event where there is
definitive, or nearly definitive information, demonstrating that a water contamination event has occurred.
Confirmation transitions from the investigation of a threat (credible) to incident (confirmed) based on
analytical confirmation of the presence of a contaminant or substantial reason to believe that an event is
underway.
Consequence Management Plan (CMP). Provides a decision-making framework that governs when,
how, what, and who will be involved in making decisions in response to a possible contamination
incident in order to minimize the response timeline and implement operational or public health response
actions appropriately.
Contamination Warning System. Active deployment and use of monitoring technologies/strategies and
enhanced surveillance activities to collect, integrate, analyze, and communicate information to provide a
timely warning of potential water contamination incidents and initiate response actions to minimize
public health impacts.
Credible. In the context of the credibility determination process, water contamination should be
characterized as credible if information collected during the investigation of possible contamination
corroborates information from the validated contamination warning system trigger.
Credibility Determination. Contamination warning system triggers should be investigated to determine
whether or not they are indicative of possible contamination. Credibility determination is the subsequent
investigation to determine whether or not additional information, including data from other monitoring
and surveillance components, corroborates the information from the validated trigger. If the additional
information corroborates the trigger, contamination should be considered credible.
Event Detection System (EDS). A system designed specifically to detect anomalies from the various
monitoring and surveillance components of a contamination warning system. An EDS may take a variety
of forms, ranging from a complex set of computer algorithms to a simple set of heuristics that are
manually implemented. In essence, an EDS is a data mining tool that supports the efficient analysis of
large amounts of monitoring and surveillance data to pick out possible anomalies while at the same time
minimizing false alarms.
Field Results. Field results include information collected from site characterization process including the
site hazard assessment, field safety screening, and rapid field tests. This does not include the results of
the laboratory analysis conducted on samples collected at the end of the site characterization process.
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Monitoring and Surveillance. Element of a contamination warning system that provides a standardized
set of information streams used in the detection of potential contamination incidents.
Possible. In the context of the contamination warning system concept of operations, water contamination
should be characterized as possible if the cause of a trigger cannot be identified and/or determined to be
benign.
Remediation and Recovery. Remediation and recovery is the stage of an event after a confirmed
determination has occurred and operational responses have been undertaken. This stage involves the
implementation of characterization, remediation, and return to service with the goal of restoring the
drinking water resource and returning to operational service.
Risk Communication. Risk communication addresses the communication of issues and information,
both internally and externally to an organization, concerning the impact and outcome of an event
including public information releases.
Site Characterization. The process of collecting information from an investigation site to support the
evaluation of a drinking water contamination threat.
Threat Warning. An unusual occurrence, observation or discovery that indicates a potential
contamination incident and initiates actions to address this concern.
Trigger. Information from a monitoring and surveillance component indicating an anomalous or unusual
condition within the system, which generally warrants further investigation to determine if it is benign or
a possible contamination threat. The nature of a trigger can vary by component and may take the form of
an alarm, alert, threshold excursion, or warning. Event detection algorithms should be the tool by which
triggers should be identified for most monitoring and surveillance components.
Trigger Validation. The process of investigating potential causes of a contamination warning system
trigger to either rule out contamination or determine that contamination is possible.
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Water Security Initiative: Consequence Management Plan Guidance
Appendix B: CMP Decision Tree Templates
CMP Decision Tree Templates
Decision trees are invaluable in the design phase of consequence management planning as well as during
response. During design, decision trees aid in defining the comprehensive consequence management
process from phase to phase as well as allowing for visual verification of the steps and information. They
are especially useful in demonstrating and confirming the process and coordination points with external
agencies and partners. During an incident when time is a critical factor and events may seem chaotic, the
decision trees may also aid the utility in navigating response actions.
The decision trees and corresponding action items included in this appendix are provided as examples and
are intended to be used as a starting point when developing the credible, confirmed, and remediation and
recovery stages of a utility-specific CMP. Each utility should modify the trees, response actions, and
personnel listed in this appendix to meet its own specific needs.
The decision trees flow in sequential order from credible to confirmed, and are outlined in a step-wise
format. For each of the steps listed in the decision trees, there are corresponding recommended action
items that outline the utility's response during that stage of an incident. A decision tree to guide
remediation and recovery efforts is also included.
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Water Security Initiative: Consequence Management Plan Guidance
B.1 Credible Determination Decision Tree Template
c
'Possible" contamination threat
Step 1: Notify Utility Director and/or appropriate
utility management personnel; consider activating
ICS and notifying external agencies
Step 2a: Asses
operational responses
Step 2b: Conduct site
characterization
( Go to Tree B.2 J
1
Step 2c: Investigate for
other contamination
warning triggers
( Go to Tree B.3 J
Step 3a: Discuss field results and
additional information with
appropriate utility personnel and
select response partners
Step 3b: Coordinate and implement
laboratory sample analysis
Step 4a: Do field
results indicate
the presence of a
contaminant?
Step 4b: Have
other
contamination
warning triggers
been activated?
If either 4a or 4b
YES
If4a, 4b, &5
NO
Step 6: Contamination
is "Credible". Go to
Tree B.4
Step 5:Do laboratory
results confirm
contamination
incident?
Log incident, close
investigation, return to
normal operations.
v END /
YES
Step 7: Contamination
threat "Confirmed".
Proceed to Step 4 in
Tree B.4
LEGEND
Start of Process
Action Performed
Decision Step
End of Decision Tree
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Notify Utility Director and/or appropriate utility management personnel; consider
activating ICS and notifying external agencies.
Employee leading initial possible determination field investigation notifies the Utility Director
when field results indicate water contamination threat is possible.
Appropriate utility manager (e.g., Utility Director) determines if ICS should be activated.
Appropriate utility manager acts as the 1C until the investigation closed or until a UC is instituted.
Note: Regardless of whether or not a UC is established, the utility itself will still retain an
individual as their 1C (unless relieved by a higher authority).
Appropriate utility personnel (e.g., utility 1C, ICS Operations Section, or designated utility
personnel in charge of field response activities) compile all available information regarding the
incident, including forms, field notes, etc. 1C maintains an ongoing log of events and documents
all events associated with threat/incident.
Utility 1C determines which utility response teams are needed and requests their assistance (if ICS
is activated).
Appropriate utility personnel (e.g., utility 1C) notify local public health department if the threat
has possible health-related impacts.
Appropriate utility personnel (e.g., utility 1C) notify appropriate response partner agencies and
provide updates to the agencies depending on the situation.
Appropriate utility personnel (e.g., PIO) release statement to employees (as appropriate).
Step 2a: Assess operational responses.
Response teams (e.g., strike team, task force) under the command of the appropriate utility
personnel (e.g., 1C or ICS Operations Section) assess potential operational responses.
Go to Tree B.2, Operational Response Decision Tree for Credible Determination.
Step 2b: Conduct site characterization.
Go to Tree B.3, Site Characterization Decision Tree; then proceed to Steps 3a and 3b of this
decision tree.
Step 2c: Investigate for other contamination warning triggers.
Appropriate utility personnel (e.g., 1C or ICS Operations Section) collect additional information
to be analyzed in conjunction with site characterization and any laboratory results to help
determine if threat is credible. Information could include:
o Results of site characterization.
o Information derived from other threat warnings (e.g., security breaches, phone threats,
unusual consumer complaints).
Appropriate utility personnel (e.g., ICS Planning Section) initiate parallel investigation for other
contamination warning triggers.
Proceed to Step 3a of this decision tree.
Step 3a: Discuss field results and additional information with appropriate utility personnel and
select response partners.
Appropriate utility personnel (e.g., ICS Planning Section) and response team members discuss
field results from site characterization and additional information with the utility 1C. Field results
October 2008 46
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include information collected from the site hazard assessment, field safety screening, and rapid
field tests.
Appropriate utility personnel (e.g., 1C or designee) prepares brief summary of incident
information to aid in determining if the incident is credible.
Proceed to Steps 4a and 4b of this decision tree.
Step 3b: Coordinate and implement laboratory sample analysis.
Appropriate utility personnel (e.g., ICS Planning Section) contact the drinking water primacy
agency and local health departments to aid in sampling and analysis strategy. Consult lead law
enforcement agency as samples could be considered criminal evidence.
Appropriate utility personnel (e.g., ICS Planning Section) determine level of sampling required,
based on site characterization results.
Appropriate utility personnel (e.g., ICS Planning Section) identify additional sampling locations
as needed.
Notify internal and external laboratories of sampling plan. Laboratories should also be notified
prior to conducting site characterization activities.
Appropriate utility personnel (e.g., ICS Planning Section) implement sampling.
Response and sampling teams should be equipped with the necessary Personal Protective
Equipment (PPE) and sampling equipment. Some sites may have systems that automatically
take sample upon water quality alarm and may also have capability to remotely trigger manual
sample collection.
Proceed to Step 5 of this decision tree.
Step 4a: Do field results indicate the presence of a contaminant?
Appropriate utility personnel (e.g., ICS Planning Section) compare water quality results from site
characterization rapid field tests to baseline or "normal" levels.
Appropriate utility personnel (e.g., ICS Planning Section) consider other evidence or signs of
contamination (e.g., security breaches) from site characterization.
If YES, proceed to Step 6 of this decision tree.
If NO, proceed to Step 4b of this decision tree.
Step 4b: Have other contamination warning triggers been activated?
Appropriate utility personnel (e.g., 1C and ICS personnel) and response partner agencies review
information gathered during Step 2c of this decision tree.
If YES, proceed to Step 6 of this decision tree.
If NO for Steps 4a, 4b, and 5; Log incident, close investigation, and return to normal operations.
In addition, review response process and make modifications to the CMP, as necessary.
Step 5: Do laboratory results confirm contamination incident?
Results from outside laboratories may take 12 hours or more. Utility 1C has discretion to proceed
with investigation with or without laboratory results based on "preponderance of evidence".
If NO for Steps 4a, 4b, and 5; Log incident, close investigation, and return to normal operations.
In addition, review response process and make modifications to the CMP, as necessary.
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If YES, proceed to Step 7 of this decision tree.
Step 6: Contamination threat is Credible. Proceed to Decision Tree B.4, Confirmed Determination
Decision Tree.
Step 7: Contamination threat Confirmed. Proceed to Step 4 in Tree B.4, Confirmed Determination
Decision Tree.
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B.2 Operational Response Decision Tree Template for Credible Determination
/From "
Credible" determination^
decision tree
linationN
Step 1: Is the source or location
of contamination known?
NO or UNKNOWN
YES
Step 2: Consider immediate
isolation response
Step 3: Evaluate impact on
customers and water service
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Is the source or location of contamination known?
If YES, go to Step 2 of this decision tree.
If NO or UNKNOWN, go to Step 5 of this decision tree.
Step 2: Consider immediate isolation response.
Immediate isolation of a storage tank or pump station can significantly decrease the spread of the
contaminant.
The feasibility of isolation should depend on the following:
o Is the source of contamination known and located at a storage tank, pump station, or
other discrete and highly controllable area?
o Is isolation low risk and low impact (e.g., little or no depressurization anticipated)?
o Can isolation be undertaken quickly (e.g., automated or highly proximate valves are
available); do suspect facilities (e.g. storage tanks or pump stations) have working valves
required for isolation?
o Would isolation require customer alerts (such as for loss of service) or formal public
notification?
Step 3: Evaluate impact on customers and water service.
Appropriate utility personnel (e.g., supply, engineering, or distribution) estimate the relative
impact isolation may have on customers and utility operators (e.g., minimal number of customers
affected, pressure reduction compared to minimum pressure requirements, potential period of
impact). Consider impacts of implementing isolation plan on critical services such as fire flow,
industry, hospitals, schools, or wholesale customers. SOPs should be prepared regarding facility
isolation and impacts on customers.
Proceed to Step 4 of this decision tree.
Step 4: Are the impacts of isolation negligible from the perspective of customers and utility
operators?
Appropriate utility personnel (e.g., utility 1C) determine if impact of isolation on customers would
be detrimental. Consider number of customers affected, pressure reduction and potential period
of impact. Impacts of isolating certain areas of the system can be determined prior to an incident.
Note: Water quality results from site characterization may take 12 hours or more, especially for
biological contaminants. Utility 1C has discretion to proceed with isolation plans before the
resolution of investigation.
If NO, proceed to Step 5 of this decision tree.
If YES, then proceed to Step 6 of this decision tree.
Step 5: Do not proceed with isolation. Continue to assess operational responses. If threat is
Credible, proceed to Tree B.5.
Step 6: Isolate storage tank or pump station by closing appropriate valves and/or filling tank;
consider notifying impacted agencies/customers.
Some facilities have valves required for isolation. Some storage tanks can be temporarily isolated
by filling the tank and by closing the appropriate valves.
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Although isolation of a water storage tank or pump station may decrease system pressure, the risk
of a credible or confirmed incident is likely greater than the risks associated with reducing system
pressures. Note: Isolation may require notification to the surrounding community and utility
customers. Also, the utility will need to consider the impacts of isolation on fire suppression
capabilities which should be addressed and coordinated with the local fire department in the
affected area.
Appropriate utility personnel (e.g., utility 1C or PIO) notify the appropriate response partner
agencies or customers of potential impacts of operational changes (as necessary).
Appropriate utility personnel (e.g., utility 1C or PIO) notify the drinking water primacy agency of
isolation plan (as necessary).
Appropriate utility personnel (e.g., ICS Operations Section) proceed with isolation of storage tank
or pump station. Supply division staff can change hydraulics of system by turning pumps on or
off remotely or locally.
Appropriate utility personnel (e.g., ICS Operations Section) direct staff (e.g., Utility Distribution
Division) to close appropriate valves to tanks, pump stations, or transmission lines.
Proceed to Step 7 of this decision tree.
Step 7: Continue to assess operational responses. If threat is Credible, proceed to Tree B.5.
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B.3 Site Characterization Decision Tree Template
r
From "Credible"
^determination decision tree
eey
Step 1: Develop site
characterization plan and
perform initial site hazard
assessment
LEGEND
Start of Process
Action Performed
Decision Step
L J End of Decision Tree
Step 2: Is site
hazard level
LOW? /
NO
YES
Step 3: Conduct field safety screening
Step 4: Appropriate utility personnel (e.g., ICS
Operations Section) reports findings to 1C
/ Step 5: Does field team
\have approval to enter
NO
Step 9b: Contact appropriate
HazMat response partner to
complete site characterization
and collect samples
YES
Step 6: Conduct rapid field testing of the water
Step 7: Appropriate utility personnel (e.g., ICS
Operations Section) reports findings to 1C
Step 8: Does
Response Team have
approval to collect
water samples?
NO
YES
Step 9a: Complete site characterization and
collect samples
If site hazard level deemed
LOW by Fire or HazMat
t
Exit site
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Develop site characterization plan, and perform initial site hazard assessment.6
Appropriate utility personnel (e.g., utility 1C or ICS Operations Section) develop customized site
characterization plan in conjunction with the utility 1C, response team, other utility ICS staff, and
appropriate outside agencies (e.g., local law enforcement, drinking water primacy agency).
Steps involved in the development of the plan may include:
1. Performing initial evaluation of information about the threat.
2. Identifying one or more investigation sites and assessing potential site hazards, including
hazardous materials, secondary devices (e.g., improvised explosive devices, armed
intruder).
3. Developing a sampling approach.
4. Assembling site characterization team that includes utility ICS staff and, as appropriate,
response partner agencies including HazMat personnel and investigative law enforcement
personnel.
Initial threat evaluation and site hazard assessment includes a review of available information
from the warning triggers and details about suspected contamination site (e.g., assessing potential
site hazards, including hazardous materials, secondary devices). Appropriate utility personnel
(e.g., utility 1C or ICS Operations Section) and response team reviews alarms and security videos
(if available) and pertinent on-line water quality monitoring or grab samples data.
If suspected contamination site identified, it should be classified as the primary investigation site.
Additional investigation sites may be required if contamination has spread to other parts of
distribution system. If isolation is not possible or it cannot be assured that suspect water has been
contained, then the appropriate utility personnel (e.g., ICS Planning or Operations Sections)
should further evaluate and identify additional sampling locations.
Some triggers (e.g., written threat, notice from public health), may not be associated with a
specific location. If suspected contamination site cannot be identified, number of sampling
locations and frequency of sampling could be increased to help identify potential sites. A formal
site characterization would not need to be conducted for these sites until information becomes
available.
Appropriate utility personnel (e.g., utility 1C) takes proactive measures to gather information
from the field teams.
Utility 1C contacts the appropriate utility personnel (e.g., utility operations staff) before
implementing site characterization procedures (e.g., for site entry approval, assessing hazards,
and sampling approval). Communications proceed using appropriate methods.
Appropriate utility personnel (e.g., utility 1C or Liaison Officer) contacts appropriate laboratories
that may be involved in analysis of samples collected from site.
Proceed to Step 2 of this decision tree.
Step 2: Is site hazard level LOW?
Based on available threat information from the site hazard assessment, the appropriate utility
personnel (e.g., utility 1C or ICS Operations Section) determine whether site hazard level is
HIGH. Two hazard categories are considered in the context of site characterization:
Refer to the U.S. EPA Response Protocol Toolbox, Module 3, Site Characterization and Sampling Guide (EPA-817-D-03-003)
for further information when developing this decision tree.
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o LOW Hazard - No obvious signs of radiological, chemical, or biological contaminants
present at the site and water is harmful only if consumed. Sampling generally not
dangerous if splash protection is used. Utility staff will most likely sample.
o HIGH Hazard - Radiological, Chemical, Biological
Radiological - Presence of radiological isotopes or emitters tentatively identified
at the site or in the water (e.g., through the use of a field radiation detector).
Chemical - Presence of highly toxic chemicals (e.g., chemical weapons or
biotoxins), aerosols, or volatile toxic industrial chemicals tentatively identified at
the site or in the water, with a potential risk of exposure through dermal or
inhalation routes.
Biological - Presence of pathogens tentatively identified at the site, with a
potential risk of exposure through dermal or inhalation routes.
Conditions where utility may require assistance from fire department or HazMat unit include:
o Equipment limitations.
o Utility suspects tampering (e.g., presence of unknown empty containers or evidence of a
security breach).
o Combination of monitor alarms, security breach, consumer complaints or public health
calls.
o
Legitimate concern that a biohazard might exist, even for diluted samples.
Appropriate utility personnel (e.g., utility 1C or Liaison Officer) contacts the local health
department concerning related health issues.
Appropriate utility personnel (e.g., utility 1C or Liaison Officer) contacts law enforcement (if not
already involved).
If YES, proceed to Step 3 of this decision tree.
If NO, proceed to Step 9b of this decision tree.
Step 3: Conduct field safety screening.
If the site hazard level is LOW, utility response team conducting the site characterization updates
the appropriate utility staff selected by the utility 1C. Only utility staff with the appropriate level
of training [e.g., Occupational Safety and Health Administration (OSHA)] should be allowed on
the site.
If the site hazard level is anything but LOW, utility response team conducting site
characterization should consist of trained HazMat personnel. Local fire departments should also
be contacted for HazMat assistance. The responding fire department will assess what HazMat
resources are needed. Note: this may differ depending on locale.
During the approach to the site, establish site zones and conduct field safety screening. Consult
with local health department and local fire department. The appropriate utility personnel (e.g.,
utility 1C or ICS Operations Section) are responsible for managing each of these tasks and
reporting the findings to the utility 1C.
When approaching site, utility response team performs field safety screening and inspects the site
for potential hazards from the site perimeter. Required field safety screening techniques include:
o Looking for signs of obvious contaminants in the air or on surfaces in or around the
facility (approach, view from upwind of site).
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o Looking for discarded containers, PPE, and equipment that could have been used to
contaminate the water.
o Using portable field instruments to measure or detect radiation (e.g., Geiger counter).
o Observation of sick or dying animals and dead or discolored vegetation.
o Noting presence of unusual odors (move away from odors, upwind if possible).
o Looking for signs of intrusion, such as cut gate locks, tampered door locks, broken lights,
or unauthorized vehicles/persons on premises.
Utility response team members investigating the site should stay in constant communication with
the appropriate utility personnel (e.g., utility 1C or ICS Operations Section). Response team
members not investigating the site should remain outside site perimeter in the staging area.
If hazardous conditions exist (hazard level is HIGH), team members should return to their
vehicles at a safe distance from the site until help arrives. Response team members shall not
retreat beyond the site perimeter until they have been properly decontaminated, since personnel
may inadvertently spread a contaminant.
Proceed to Step 4 of this decision tree.
Step 4: Appropriate utility personnel (e.g., ICS Operations Section) report findings to 1C.
Appropriate utility personnel (e.g., ICS Operations Section) report findings for field safety
screening and initial observation of site conditions to the utility 1C.
Proceed to Step 5 of this decision tree.
Step 5: Does field team have approval to enter site?
Appropriate utility personnel (e.g., utility 1C), in consultation with local public health and local
fire department, determines if site is safe for utility staff to enter and conduct further
investigations.
If NO, proceed to Step 9b of this decision tree.
If YES, proceed to Step 6 of this decision tree.
Step 6: Conduct rapid field testing of the water.
Utility response team continues to monitor site conditions described in Step 3.
If hazardous conditions exist (hazard level is HIGH), team members should return to their
vehicles at a safe distance upwind from the site until additional help arrives. Response team
members shall not retreat beyond the site perimeter until they have been properly
decontaminated, since personnel may inadvertently spread a contaminant. Appropriate utility
personnel (e.g., utility 1C or ICS Operations Section) immediately report the findings to the utility
1C. Contact outside agencies such as local public health and fire departments for assistance with
the investigation.
If the hazard level LOW, the utility response team conducts rapid field testing. The three
objectives of rapid field testing of the water are to:
1. Provide additional information to assess the credibility of the threat.
2. Tentatively identify contaminants that would need to be confirmed by laboratory testing.
3. Determine if hazards tentatively identified in the water require special precautions during
sampling.
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Water quality tests include pH, chlorine residual, and other field tests, including toxicity
screening as requested by the utility 1C.
Report results of rapid field testing to local the health department and the drinking water primacy
agency.
Proceed to Step 7 of this decision tree.
Step 7: Appropriate utility personnel (e.g., ICS Operations Section) report findings to 1C.
Appropriate utility personnel (e.g., ICS Operations Section) report findings to the utility 1C. 1C
decides if safe for the team to collect water samples.
Proceed to Step 8 of this decision tree.
Step 8: Does Response Team have approval to collect water samples?
Proceed to Step 9b of this decision tree if the appropriate utility personnel (e.g., utility 1C or ICS
Operations Section) conclude the site is NOT safe for utility staff to collect water samples.
Proceed to Step 9a of this decision tree if the appropriate utility personnel (e.g., utility 1C, ICS
Operations Section, or HazMat Unit Leader (if previously contacted to conduct the site
characterization) concludes the site is safe for utility staff to collect water samples.
Utility staff should collect water samples only if site hazard level is classified as LOW.
Step 9a: Complete site characterization and collect samples.
Utility ICS staff conducts site characterization and collects water samples under the direction of
the utility 1C. This includes sampling the contaminated water - wherever it might be - and
looking upstream for sites where the contamination might have been introduced - particularly if
there is a chance that it could still be actively being introduced to the distribution system.
Utility response team collects water samples for laboratory analysis. Where possible, sample taps
or hose bibs should be used. Submersible sampling pumps may be required to collect water
samples from storage tanks or underground reservoirs. Only appropriate decontaminated pumps
and appurtenances shall be used to prevent compromising the samples.
Upon completing site characterization, utility field leader documents site investigation following
established procedures.
Step 9b: Contact appropriate HazMat response partner to complete site characterization and
collect samples.
Appropriate utility personnel (e.g., utility 1C or Liaison Officer) contacts the local fire department
(by calling 911) to request assistance from the local HazMat unit.
Provide fire dispatcher with information regarding reason for call (e.g., chemical spill, unusual
odor, or other unusual characteristics) observed during the site investigation.
Upon HazMat arrival, utility response team informs HazMat Commander of the type of sampling
required and provides the appropriate sampling equipment (bottles and labels, preservatives,
pumps, etc.).
Responding fire unit assesses what HazMat resources are needed (e.g., PPE).
HazMat may assume field incident command.
HazMat unit completes site characterization and collects water samples under the direction of the
appropriate utility personnel (e.g., utility 1C or ICS Operations Section).
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HazMat unit may consider the site hazard level LOW after completion of site characterization.
Return to Step 9a if utility is allowed to collect water samples by HazMat Unit Leader.
Upon completing site characterization, the appropriate utility personnel (e.g., utility 1C or ICS
Operations Section) complete a Site Characterization Report Form (Refer to the USEPA RPTB,
Module 3).
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Water Security Initiative: Consequence Management Plan Guidance
Confirmed Determination Decision Tree Template
c
"Credible" contamination threat
Step 1: Update appropriate agencies as necessary
Step 2: Continue to evaluate field results and
additional information with Incident Command/
Unified Command and appropriate public health, law
enforcement and other local, State, and Federal
response partners
Step 3a: Implement
additional operational
responses
Step 3b: Develop/
implement expanded
sampling strategy
( Go to Tree B.5 J
Step 3c: Consult with
the primacy agency
on public notification
Step 4: Is
contamination threat
confirmed?
( Go to Tree B.6 J
YES
Step 7: Contamination
Confirmed. Revise
operational response and
public notification plans
as needed. Complete
incident response.
Step 5: Evaluate
additional
information
Step 6: Is
threat still
credible?
YES
Step 8: Develop remediation and
I recovery plan. Proceed to Tree B.7
NO
:_og incident, close investigation,
eturn to normal operations. END
LEGEND
Start of Process
Action Performed
Decision Step
End of Decision Tree
October 2008
58
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Update appropriate agencies as necessary.
Update response partners and agencies. Example:
o Appropriate utility personnel (e.g., utility 1C) notifies appropriate utility manager (e.g.,
City Manager), who determines if activation of EOC is necessary. Utility ICS is
modified as needed to coordinate with the EOC.
o Appropriate utility personnel (e.g., utility 1C) updates relevant agencies with information
regarding contaminant/contaminant class and area affected (if known), and enlists their
assistance as follows (insert appropriate response partners):
Local health department may conduct local public health surveillance.
The drinking water primacy agency may provide assistance with developing the
sampling and analysis strategy, interpreting laboratory results, summarizing
regulatory requirements, and must be consulted regarding public notification.
State department of health may provide epidemiological assessments, confirm lab
results, and provide a radioactive material control team.
Wastewater treatment plant may provide laboratory assistance and monitor the
wastewater to serve as another contamination warning trigger.
o Appropriate utility personnel (e.g., utility 1C or designee) notifies all critical customers
affected [insert appropriate utility critical customers such as hospitals, nursing homes,
etc.].
o UC may manage the incident, and utility ICS staff provides support.
o Appropriate utility personnel (e.g., Utility Security Manager or designee) should report
the credible threat determination on Water Information Sharing and Analysis Center
(WaterlSAC) and Homeland Security Information Network.
o Through the EOC, notification of State EMA may be requested with information on
location, type of emergency, threat immediacy, immediate needs, and future logistics
issues.
o Local law enforcement may respond for any site security or criminal investigation needs.
Step 2: Continue to evaluate field results and additional information with IC/UC and appropriate
public health, law enforcement, and other local, State, and Federal response partners.
Field results from site characterization and additional information should be discussed and
evaluated with IC/UC, and appropriate public health, law enforcement, and other local, State, and
Federal response partners.
Appropriate utility personnel (e.g., utility 1C or designee) prepares a brief summary of the field
results and other pertinent information about the incident to aid in determining if the incident is
confirmed.
Proceed to Steps 3a, 3b, and 3c of this decision tree.
Step 3a: Implement additional operational responses.
Response teams implement operational responses developed previously in order to isolate the
contaminated area or mitigate the consequences of contamination.
Go to Tree B.5, Operational Response Decision Tree for Confirmed Determination; then proceed
to Step 4 of this decision tree.
October 2008 59
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Water Security Initiative: Consequence Management Plan Guidance
Step 3b: Develop/implement expanded sampling strategy.
Appropriate utility personnel (e.g., ICS Planning Section) contact the drinking water primacy
agency and local health departments to aid expanded sampling and analysis strategy.
Appropriate utility personnel (e.g., ICS Planning Section) determine level of sampling required,
based on continued evaluation of field results and additional information.
Appropriate utility personnel (e.g., ICS Planning Section) identify additional sampling locations
as needed.
Notify internal and external laboratories of sampling plan.
Appropriate utility personnel (e.g., ICS Planning Section) implement sampling.
Response and sampling teams should be equipped with the necessary PPE and sampling
equipment. Some sites may have systems that automatically take sample upon receiving water
quality alarm and may also have capability to remotely trigger manual sample collection.
Step 3c: Consult with the primacy agency on public notification.
Appropriate utility personnel (e.g., utility 1C and PIO) consult with the primacy agency to
determine if public notification is required. This may include issuing "boil water," "do not
drink," or "do not use" messages in order to minimize the potential for exposure.
Utility should participate in a JIC activated by the city or county. Local health department,
drinking water primacy agency, fire, police, other State and Federal agencies may also be
involved depending on the nature of the incident.
Go to Tree B.6, Public Notification Decision Tree; then proceed to Step 4 of this decision tree.
Step 4: Is contamination threat confirmed?
Positive laboratory analysis results should be considered when confirming the contamination
threat. Refer to the utility's laboratory notification protocols.
If confirmation of an incident through laboratory analysis is not feasible, additional information
sources may be considered in attempting to confirm the incident based on a "preponderance of
evidence." Information that might support confirmation includes:
o Results from laboratory analysis of samples collected during the initial or continuing site
characterization activities.
o Results and observations of continued site characterization activities.
o Information from public health officials, area hospitals, or call centers.
o Information about specific contaminants.
o Targeted information from external sources based on the collective knowledge of the
threat.
IC/UC may rely on utility's water treatment division as a technical resource when confirming
contamination, but IC/UC has the ultimate authority.
If YES, proceed to Step 7 of this decision tree.
If NO, proceed to Step 5 of this decision tree.
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Water Security Initiative: Consequence Management Plan Guidance
Step 5: Evaluate additional information.
If laboratory results do not confirm a contamination incident, the threat may still be credible.
This should be determined through analysis of existing and additional information relevant to the
threat.
Utility 1C (in conjunction with IC/UC, and other local, State, and Federal response partners)
should review contamination threat warning information from other CWS components, results
from site characterization, contaminant characteristics (e.g., Water Contaminant Information),
and other information sources listed in Step 4 of this decision tree.
Proceed to Step 6 of this decision tree.
Step 6: Is threat still credible?
If YES, return to Step 1 of this decision tree and revise the investigation.
If NO, log the incident, close the investigation, and return to normal operations.
Step 7: Contamination Confirmed. Revise operational response and PN plans as needed.
Complete incident response.
Public health and operational response procedures already implemented should be reassessed and
revised (if necessary). This may include revisions to containment strategies or PNs.
Appropriate utility personnel (e.g., utility 1C or designee) notify all response partners of a
confirmed contamination incident and inquires as to their potential role in remediation and
recovery activities.
Appropriate utility personnel (e.g., utility 1C or PIO) then notify affected residential customers
and critical customers.
Go to the Operational Response (B.5) and Public Notification (B.6) decision trees (if necessary);
then complete incident response and transition to remediation and recovery.
Proceed to Step 8 of this decision tree.
Step 8: Develop remediation and recovery plan.7 Proceed to Tree B.7, Remediation and Recovery
Decision Tree.
Refer to the U.S. EPA Response Protocol Toolbox, Module 6, Remediation and Recovery Guide (EPA-817-D-03) for further
information when developing this decision tree.
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Water Security Initiative: Consequence Management Plan Guidance
B.5 Operational Response Decision Tree Template for Confirmed Determination
CFrom "Confirmed"
determination decision tree
YES
Step 5: Isolate
contaminated area by
closing appropriate
valves or changing
hydraulic grade; notify
impacted customers
and appropriate
external agencies
Step 1: Is the source
or location of
contamination
known?
YES
Step 3: Estimate spread
of contamination
Step 4: Is isolation of
contaminated area
feasible and risk
acceptable?
NO
Step 6: Are alternate
operational responses
feasible and risk
acceptable?
NO
NO or
Unknown
Step 2: Continue to
monitor threat
information to inform/
revise operational
responses
YES
Step 7: Implement
appropriate
operational
response; notify
impacted customers
and appropriate
external agencies
Step 8: Do not proceed with
response actions at this time.
LEGEND
Start of Process
Action Performed
Decision Step
End of Decision Tree
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Is the source or location of contamination known?
If YES, go to Step 3 of this decision tree.
If NO or UNKNOWN, go to Step 2 of this decision tree.
Step 2: Continue to monitor threat information to inform/revise operational responses.
Continue to monitor contamination warning system components and consequence management
activities for additional information concerning contaminant type and location to inform/revise
operational responses.
Step 3: Estimate spread of contamination.
Appropriate utility personnel (e.g., ICS Planning Section) estimate spread of contamination using
information from the contamination warning system components, distribution system models
and/or utility personnel with knowledge of system.
Proceed to Step 4 of this decision tree.
Step 4: Is isolation of contaminated area feasible and risk acceptable?
Based on the results determined in Step 3, appropriate utility personnel (e.g., ICS Operations or
Planning Section) determine whether suspected area of contamination can be isolated.
Appropriate utility personnel (e.g., utility 1C) determine potential impact of isolation on
customers. Consider number of customers affected, pressure reduction and potential period of
impact. Impacts of isolating certain areas of the system can be determined prior to an incident.
Key feasibility considerations may include:
o Is enough information available concerning the contamination source and spread to
undertake a targeted isolation?
o Is the system configured well relative to isolation need (e.g., valve placement, grid
structure)?
o Can utility staff resources meet the isolation response requirements (e.g., multiple valves
in dispersed locations) within the credible and confirmed determination timelines?
o Is the sequencing of valve closure (particularly in a "grid" framework) too complex as
system hydraulics will change in response to flow curtailment?
Key impact considerations may include:
o Will isolation pose a system depressurization risk that may increase the risk of
contamination inflow through pipe walls?
o Will isolation exacerbate the contamination problem (e.g., increase concentrations,
raising customer contact and infrastructure damage risks)?
o Will isolation have substantial public health-related impacts, such as hygiene concerns
associated with lack of water for sanitation, large customer water needs, etc?
o What are possible impacts in maintaining public confidence outside of the isolated zone?
o Will any hydraulic changes resulting from isolation affect the on-going threat
investigation?
If YES, go to Step 5 of this decision tree.
If NO, go to Step 6 of this decision tree.
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Water Security Initiative: Consequence Management Plan Guidance
Step 5: Isolate contaminated area by closing appropriate valves or changing hydraulic grade; notify
impacted customers and appropriate external agencies.
Appropriate utility personnel (e.g., ICS Operations Section) proceed with the isolation plan.
Utility staff may be able to change hydraulics of system by turning pumps on or off remotely or
locally.
Appropriate utility personnel (e.g., ICS Operations Section) direct staff to close appropriate
valves to tanks, pump stations, or transmission mains.
Appropriate utility personnel (e.g., utility 1C or PIO) notify the appropriate agencies or customers
of operational changes based on the suspected impact of the operational changes on water
pressure or supply.
Note that the isolated (and potentially contaminated) water may still be accessible by customers.
Therefore, thorough and effective customer notification is critical to minimize the customer
contamination contact risk in place.
Provide alternate water supply to residential customers as needed. Contact appropriate response
partner agencies.
Step 6: Are alternate operational responses feasible and risk acceptable?
Flushing of distribution system mains is another operational response option, although the utility
should not view or carry out such an action as "routine."
Key considerations for flushing during a credible contamination incident may include:
o The type and concentration of the potential contaminant may be unknown at this time;
worker safety/protection measures should be taken and possible impacts to the
environment due to discharged water should be considered?
o Is enough information available concerning the contamination source and spread to
undertake targeted flushing operations?
o Is the system configured well relative to isolation need (e.g., valve placement, grid
structure)?
o Can utility staff resources meet the flushing response requirements (e.g., multiple
flushing points in dispersed locations) within the credible and confirmed determination
timelines?
o Has the primacy agency been consulted for any planned discharges to a wastewater
collection system or surface waters?
Conditions under which a utility may consider undertaking a flush operational response include:
o Isolation is infeasible;
o The utility has obtained the needed regulatory clearances;
o Customer notification is anticipated to have limited effectiveness (e.g., contamination
spread involves the notification of many, widespread users); and
o The weight of evidence suggests contamination is compatible with a flush response (e.g.,
the contaminant type and concentration are sufficiently well known and deemed low risk
in a release context or, in the absence of this specificity, there are strong indications that a
release from the system will have, on balance, tolerable environmental, general public
health, and sewer system impacts).
Appropriate utility personnel (e.g., utility 1C) determine if impact of alternate operational
procedures on customers and environment would be detrimental before implementing.
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Water Security Initiative: Consequence Management Plan Guidance
If YES, go to Step 7 of this decision tree.
If NO, go to Step 8 of this decision tree
Step 7: Implement appropriate operational response; notify impacted customers and appropriate
external agencies.
Appropriate utility personnel (e.g., ICS Operations Section) proceed with the appropriate
operational response.
Appropriate utility personnel (e.g., ICS Operations Section) direct staff to appropriate flushing
locations (e.g., hydrants).
Appropriate utility personnel (e.g., utility 1C or PIO) notify the appropriate agencies or customers
of operational changes based on the suspected impact of the operational changes on water
pressure or supply.
Note that the isolated (and potentially contaminated) water may still be accessible by customers.
Therefore, thorough and effective customer notification is critical to minimize the customer
contamination contact risk in place.
Provide alternate water supply to residential customers as needed. Contact appropriate response
partner agencies.
Step 8: Do not proceed with response actions at this time.
Contamination source, spread, or type remains insufficiently known to support operational
response actions at this time.
Proceed to Step 2 of this decision tree.
October 2008 65
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Water Security Initiative: Consequence Management Plan Guidance
B.6 Public Notification Decision Tree Template
' From "Confirmed
idetermination decision
n treey
Step 1: Assess potential consequences to
public health, economic impacts and consult
with the drinking water primacy agency
LEGEND
Start of Process
Action Performed
Decision Step
L J End of Decision Tree
Step 2: Is there a ^
threat to public j-
health? /
NO
Step 3: Public notification may
not be necessary
YES or UNKNOWN
Step 4: Drinking water primacy
agency, utility, and public health
response partners develop PN
strategy (other agencies to assist
as appropriate)
NO
Step 5a: Is the
contaminant known or
suspected?
YES
Step 5b: Is boiling
effective and
advisable?
YES
NO
Step 5c: Is there a risk v
of dermal or inhalation \-
ex pos u re? /
NO
YES
Step 6a: Issue a "boil water" advisory;
PIO disseminates advisory
Step 6b: Issue a "do not drink" advisory;
PIO disseminates advisory; consider
alternate water supply for consumption
Step 6c: Issue a "do not use"
advisory; PIO disseminates
advisory; consider alternate water
supply for consumption,
y
Step 7: Has water
v system returned to
\^ normal operations?
1
' YES
r
Step 8b: Hold press
conference and issue "safe to
L drink" notices .
^
NO
r
Step 8a: Provide updates
to public
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Assess potential consequences to public health, economic impacts and consult with the
drinking water primacy agency.
Appropriate utility personnel (e.g., utility 1C, PIO, and other utility staff) work with the drinking
water primacy agency and other response partners (e.g., public health agencies) to assess
available information on the public health consequences.
Consider the properties of the contaminant, as appropriate, including acute/chronic health effects,
taste/odor/color, aerosolization, toxicity values (e.g., LD50), hydrolysis, reactivity, solubility,
susceptibility to disinfection, etc. Refer to EPA's Water Contamination Information Tool
(WCIT), EPA's List of Drinking Water Contaminants and Maximum Contaminant Levels,
WaterlSAC, etc.
Consider health effects that may have been observed in the community. Contact appropriate
response partners to obtain information (e.g., public health agencies, hospitals).
Appropriate utility personnel (e.g., ICS Operations Section) estimate the spread of contamination
considering operational responses that have been performed. This may have been performed as
part of the Operational Response Decision Tree (B.5).
The use of a distribution system model can provide information to identify the area of the
distribution system that would be subject to water use restrictions and PN.
Proceed to Step 2 of this decision tree.
Step 2: Is there a threat to public health?
The drinking water primacy agency, with input from the utility and response partners (e.g., public
health agencies) determines whether the incident poses a significant potential for serious adverse
effects on human health as a result of short-term exposure based on the available information.
If YES, or UNKNOWN, proceed to Step 4 of this decision tree.
If NO, proceed to Step 3 of this decision tree.
Step 3: Public notification may not be necessary.
If there is no threat to public health, PN may not be necessary.
PN may be appropriate if operational responses (conducted as part of Operational Response
Decision Tree B.5) have affected consumers or if non-threatening or aesthetic water quality issues
are present. In this instance, follow utility SOPs for PN.
Step 4: Drinking water primacy agency, utility, and public health response partners develop PN
strategy (other agencies to assist as appropriate).
The drinking water primacy agency, with input from the utility and appropriate response partners
(e.g., public health agencies), develops the PN strategy in compliance with the Federal and State
PN regulations.
PN strategy should be modified based on the area affected. If the area is small, delivering
information pamphlets door-to-door and calling customers may be the most effective notification
method. If the area is large, then sending the message through media resources (e.g., television,
radio) may be the most appropriate method. Note: PN strategy should be in compliance with the
Federal and State PN regulations.
Whenever the media is notified or becomes aware of an incident, the City Manager's office (e.g.,
utility manager) should be advised.
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Water Security Initiative: Consequence Management Plan Guidance
Proceed to Steps 5a - c of this decision tree to assist in determining the appropriate PN advisory
level (e.g., "boil water," "do not drink," or "do not use") and identifying alternate water supplies,
ifneeded.
Step 5a: Is the contaminant known or suspected?
If the contaminant or class of contaminant is identified or suspected, proceed to Step 5b of this
decision tree.
If the type of contaminant is unknown, consider adopting a conservative approach and issue a "do
not use" notice. Proceed to Step 6c of this decision tree to issue a "do not use" advisory.
Step 5b: Is boiling effective and advisable?
The drinking water primacy agency, with input from the utility and appropriate response partners
(e.g., public health agencies), determines if boiling of water is effective and advisable.
A "boil water" advisory typically is issued when biological contaminants are present. Issuance of
a "boil water" advisory may be preferred if boiling will easily destroy the contaminant without
creating additional hazards through aerosolization.
If boiling water is deemed effective and will not produce additional public health concerns,
proceed to Step 6a of this decision tree to issue a "boil water" advisory.
If boiling water is deemed ineffective or unsafe, then proceed to Step 5c of this decision tree.
Step 5c: Is there a risk of dermal or inhalation exposure?
The drinking water primacy agency, with input from the utility and appropriate response partners
(e.g., public health agencies), determines if the risk of dermal or inhalation exposure exists.
If the contaminant does not pose a risk through inhalation or dermal exposure pathways, issuance
of a "do not drink" advisory may be appropriate. A "do not drink" advisory should restrict all use
of water if ingestion is possible (i.e., the water should not be consumed or used in food
preparation). Proceed to Step 6b of this decision tree to issue a "do not drink" advisory.
If there is a risk to public health through inhalation or dermal exposure, or if the risk of exposure
by these pathways is unknown, then a "do not use" notice should be considered. Proceed to Step
6c of this decision tree to issue a "do not use" advisory.
Step 6a: Issue a "boil water8" advisory; PIO disseminates advisory.
Notify city manager (e.g., utility manager) and PIO of decision to issue a "boil water" advisory.
With input from ICS Planning Section, public health agencies, drinking water primacy agency,
and PIO, modify existing templates for issuing a "boil water" advisory.
Keep the public updated of any changes to the advisory throughout the investigation.
Step 6b: Issue a "do not drink" advisory; PIO disseminates advisory; consider alternate water
supply for consumption.
Notify city manager (e.g., utility manager) and PIO of decision to issue a "do not drink" advisory.
Refer to the U.S. EPA Response Protocol Toolbox, Module 5, Public Health Response Guide (EPA-817-D-03-003) for example
notifications for "boil water", "do not drink", "do not use".
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Water Security Initiative: Consequence Management Plan Guidance
With input from the ICS Planning Section, public health agencies, drinking water primacy
agency, and PIO, modify existing templates for issuing a "do not drink" advisory.
Suspect water can still be used for purposes that do not involve ingestion (e.g., flushing toilets),
and it should be necessary to provide an alternate drinking water supply only for consumption
and related activities such as food preparation.
Appropriate utility personnel (e.g., utility 1C and ICS Operations Section chief (as appropriate))
should identify alternate water supplies for both short- and long-term consumption. Contact the
appropriate alternate water supply agencies, as appropriate.
Keep the public updated of any changes to the advisory throughout the investigation.
Step 6c: Issue a "do not use" advisory; PIO disseminates advisory; consider alternate water supply
for consumption, firefighting, and sanitation.
If there is a risk to public health through inhalation or dermal exposure, or if the risk of exposure
by these pathways is unknown, then a "do not use" notice should be considered.
Notify city manager (e.g., utility manager) and PIO of decision to issue a "do not use" advisory.
With the input of the ICS Planning Section, public health agencies, drinking water primacy
agency, city PIO, and local fire department, modify existing templates for issuing a "do not use"
advisory.
Appropriate utility personnel (e.g., utility 1C and ICS Operations Section chief (as appropriate))
should identify alternate water supplies for short- and long-term consumption, firefighting, and
sanitation. Contact the appropriate alternate water supply agencies.
Keep the public updated of any changes to the advisory throughout the investigation.
Step 7: Has water system returned to normal operations?
If YES, proceed to Step 8b of this decision tree.
If NO, proceed to Step 8a of this decision tree.
Step 8a: Provide updates to public.
With input from the ICS Planning Section, public health agencies, drinking water primacy
agency, and city PIO, provide periodic updates to the public until a "safe to drink" notice has
been issued (Step 8b of this decision tree).
Step 8b: Hold press conference and issue "safe to drink" notices.
Notify City Manager (e.g., utility manager) and city PIO of decision to issue "safe to drink"
notices.
With input from the ICS Planning Section, public health agencies, drinking water primacy
agency, and city PIO, modify existing templates for issuing a "safe to drink" notices.
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Water Security Initiative: Consequence Management Plan Guidance
B.7 Remediation and Recovery Decision Tree Template
Confirmed" contamination
1
r
Step V. Plan for remediation and
recovery
Provide long-term
alternative water supply
^
r
Step 1a: Conduct
system characterization
Contaminant NO
.kf nitiirillu -rlf hi
attenuating?
Step 1c: Conduct . .
Feasibility Study * *
i
r
Step 1b: Conduct risk
assessment
"No decontamination or removal"
Monitor water quality until
attenuation
Step 4: Design remedial
activities
Step 5: Install and operate
remedial action
Step 6: Return to service
Step 2: Conduct
detailed analysis of M-
available alternatives
Do alternatives
meet final
remediation
goals?
NO
YES
Step 3: Select preferred
remediation action
Decon
Decontamination
or removal?
\
Remove
No additional action
Step 5a: Properly
dispose of remediation
residuals
Seek expert advise
LEGEND
Step 6a: Conduct post-
remediation monitoring
j Start of Process
Action Performed
^ \ Decision Step
End of Decision Tree
October 2008
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Water Security Initiative: Consequence Management Plan Guidance
Step 1: Plan for remediation and recovery9.
Appropriate utility personnel (e.g., ICS Planning Chief), in consultation with the utility 1C,
should convene a meeting with response partners to engage in a systematic planning process for
remediation and recovery. The systematic planning process ensures that the information
collected is sufficient to:
o Address public health response.
o Conduct risk assessment.
o Make decisions related to system characterization, remedy selection, remedy
implementation and post-remedial monitoring.
o Provide information to address a public information campaign to assure public water is
safe to use again.
The following key decisions and outputs should result from the systematic planning process:
o Goals and Objectives: Appropriate utility personnel (e.g., ICS Planning Chief), in
consultation with the local health department and other planning partners, should
determine the goals to return the system to service as quickly as possible or a framework
for "what is an acceptably cleansed water system." The goals should be specified in
Qualitative terms (i.e., restoration of fire-protection and basic sanitation) and Quantitative
terms (i.e., concentration-based remediation goals for the water, system components, and
affected environmental media).
o Roles and Responsibilities: Based on the nature and extent of the contamination,
appropriate utility personnel (e.g., ICS Planning Chief), in consultation with the utility
Operations, Logistics, and Admin/Finance Section Chiefs, should identify utility and
response partners' roles and responsibilities for the remediation and recovery phase.
o Funding: Appropriate utility personnel (e.g., ICS Admin/Finance Chiefs), in conjunction
with the Utility Director and appropriate response partners and agencies, should plan for
how to fund remediation and recovery efforts.
o Schedules and Milestones: Appropriate utility personnel (e.g., ICS Planning Section)
should prioritize remediation and recovery efforts and establish schedules and milestones
to achieve goals.
o Development of a Conceptual Site Model: Appropriate utility personnel (e.g., ICS
Planning Chief) should direct the development of a conceptual site model based on use of
existing information. The conceptual site model provides a concise summary of
information about the nature and extent of contamination, and the fate and transport of
contaminants in the water system. An inter-agency team, including the utility, drinking
water primacy agency, public health departments, site remediation specialists, and
technical assistance providers [e.g., National Decontamination Team and National
Homeland Security Research Center (U.S. EPA)] should provide assistance in developing
the conceptual site model.
o Laboratory and Data Collection Needs: Appropriate utility personnel (e.g., ICS Planning
Section) should make the decisions related to identification of analytical laboratories,
types of data needed, sampling locations, and quality control procedures.
n
Refer to the U.S. EPA Response Protocol Toolbox, Module 6, Remediation and Recovery Guide (EPA-817-D-03) for further
information when developing this decision tree to plan for Remediation and Recovery.
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Water Security Initiative: Consequence Management Plan Guidance
o Long-Term Alternate Water: Appropriate utility personnel (e.g., ICS Planning Section),
with input from the drinking water primacy agency, public health officials, and the
appropriate State and Federal officials, should make decisions related to providing long-
term water (greater than a few days) to the customers (if necessary).
Step la: Conduct system characterization.
Appropriate utility personnel (e.g., ICS Planning Chief) should direct system characterization
efforts and activities. System characterization should be used to identify the nature, extent, and
fate of particular contaminants in the utility water system and its components to support the
selection of appropriate remediation actions. If the contamination is contained through
immediate operational response and is confined to a well-defined area, then extensive system
characterization may not be necessary. In this case, a reevaluation of the initial site
characterization (see Site Characterization Decision Tree) data and the information obtained
through the conceptual site model (developed under Step 1 of this decision tree) may provide
sufficient information to guide remediation and recovery efforts.
System characterization activities should include the following:
o Evaluate information gathered during initial site characterization to determine whether
additional characterization activities are necessary.
o Develop system characterization planning documents (e.g., System Characterization
Work Plan, Sampling and Analysis Plan, updating the Health and Safety Plan).
o Conduct and continue with sampling and analysis.
o Evaluate sample analysis results to characterize the system and determine the nature,
extent, and fate of contamination; and to evaluate potential remedial alternatives.
o Define the extent of the remedial action.
o Document all results in the final System Characterization/Feasibility Study report.
Appropriate utility personnel (e.g., ICS Operations Chief) should arrange for support activities
while coordinating with the Planning, Logistics, and Administration/Finance Chiefs to:
o Ensure access to all areas to be investigated.
o Procure equipment and supplies in a timely manner.
o Coordinate with analytical laboratories.
o Procure on-site facilities for office and laboratory space, decontamination equipment,
sample storage, and utilities.
o Provide for storage and disposal of contaminated material (Step 5a of this decision tree).
Appropriate utility personnel (e.g., ICS Operations Section Chief) should implement system
characterization as prescribed by the Planning Chief and approved by the 1C in planning
documents to define the nature, extent, and fate of contaminants in the water system by
conducting sampling and analysis and evaluation of results.
Appropriate utility personnel (e.g., ICS Planning Section) should determine whether data are
sufficient to evaluate potential remedial alternatives (Step Ic of this decision tree).
Determine whether human health and environmental risks are reduced through attenuation and/or
degradation of the contaminant in the water system within a reasonable period of time and where
an alternate water supply is available during this period. This determination will be based on the
framework for "what is an acceptably cleansed water system" (Step 1 of this decision tree).
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Water Security Initiative: Consequence Management Plan Guidance
o If contaminant is naturally self-attenuating, then "no decontamination or removal is
required"; proceed to monitor water quality until after attenuation, return to service and
conducting post remediation monitoring (Steps 6 and 6a of this decision tree).
o If contaminant is not naturally self-attenuating, proceed to Step Ic of this decision tree to
conduct a Feasibility Study with Risk Assessment (Step Ib of this decision tree).
Appropriate utility personnel (e.g., ICS Planning, Logistics, Administration/Finance Chiefs)
should document all results of system characterization in the final System Characterization /
Feasibility Study report (concurrent with Step Ic of this decision tree).
Step Ib: Conduct risk assessment.
Appropriate utility personnel (e.g., ICS Planning Section), in consultation with public health
departments, should direct appropriate utility staff to conduct risk management activities
following System Characterization (Step la of this decision tree) to:
o Evaluate risk reduction resulting from immediate operational response actions.
o Help establish preliminary remediation goals and final remediation goals.
o Assess potential risk reductions from implementation of a long-term remedy (if
necessary).
o Inform further system characterization and field investigations (Step la of this decision
tree).
o Evaluate the protectiveness of the candidate remediation technologies and remediation
alternatives.
To conduct risk assessment, consider using Superfund risk assessment guidance10, when
appropriate. For very large-scale remediation projects, consider using EPA resources - such as
regional On-Scene Coordinators, Remedial Project Managers, the National Decontamination
Team, and the National Homeland Security Research Center - and other national partners, such
as the Centers for Disease Control and Prevention (CDC).
Considering the framework for determining an acceptably cleansed system identified in Step 1 of
this decision tree, establish long-term, media-specific target concentrations (based on acceptable
risk levels to human health and the environment) or preliminary remediation goals to use in
screening and selecting remedial alternatives.
o For a known contaminant with an existing action level, such as a Maximum Contaminant
Level (MCL)11 or Effluent Limitation Guideline for treated water, the existing regulatory
level can be used as the preliminary remediation goals.
o If an action level does not exist, human health risk-based preliminary remediation goals
can be established by performing risk calculations used by the Superfund risk assessment
guidance.
Evaluate the protectiveness of the candidate remediation technologies and remediation
alternatives identified in the Feasibility Study (Step Ic of this decision tree).
Determine the final remediation goals after the completion of the system characterization,
Feasibility Study, and the identification of the remedial action objectives under Step Ic of this
decision tree.
U.S. EPA Superfund Risk Assessment http://www.epa.gov/oswer/riskassessment/risk_superfund.htm.
For more information on Drinking Water MCLs and associated health advisories go to:
http://www.epa.gov/waterscience/criteria/drinking/
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o In the absence of established drinking water standards such as an MCL and non-zero
MCL goals, use criteria modeled after EPA's risk and remediation goals in the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR 300.430(e) to
establish Final Remediation Goals.
Appropriate utility personnel (e.g., ICS Planning Chief) should report risk assessment outcomes
to the 1C and PIO.
Step Ic: Conduct Feasibility Study, if needed.
If determined to be necessary, the utility 1C should conduct the Feasibility Study concurrently
with the system characterization. The goal of the Feasibility Study is to develop, screen, and
evaluate remedial action alternatives. If remedial alternatives for the contaminant of concern are
known and well-defined, then combine Feasibility Study and detailed analysis of available
alternatives (Step 2 of this decision tree).
The Feasibility Study should be conducted to:
o Identify remedial action objectives based on feasibility criteria.
o Determine treatment technologies that are capable of reaching remediation objectives and
are reasonably available.
o Develop and screen remedial alternatives and conduct treatability studies (if necessary).
o Prepare a list of remedial alternatives to be evaluated in greater detail under Step 2 of this
decision tree.
Remedial Action Objectives should be established considering the contaminant, media of interest
(i.e. water, system components, storage tanks, distribution lines, filters, pumps, etc.), Preliminary
Remediation Goals, and degree of remediation necessary based on system-specific factors (e.g.,
need to treat water for consumption or treat to dispose/discharge and volume of water).
For the majority of remediation projects, EPA resources including regional On-Scene
Coordinators, Remedial Project Managers, National Decontamination Team, and National
Homeland Security Research Center, will provide technical support to conduct the Feasibility
Study.
Once the Feasibility Study is complete, prepare the System Characterization/Feasibility Study
Report and proceed to Step 2 of this decision tree.
Step 2: Conduct detailed analysis of available alternatives.
Appropriate utility personnel (e.g., utility 1C or ICS Planning Section) should be responsible for
the detailed analysis of remediation alternatives (selected under Step Ic of this decision tree) by
building on previous evaluations conducted during the development and screening of alternatives.
The analysis should be coordinated with other appropriate utility staff (e.g., engineering, security,
distribution, commercial, supply, treatment, technical specialists). If 1C cannot facilitate (e.g., if
utility does not have the expertise), this may become the responsibility of the local EMA.
Compliance with Federal regulations for alternative treatments should be determined by the
drinking water primacy agency.
The detailed analysis process should follow the steps below:
o Select alternatives for the treatment of contaminated water using available resources (e.g.,
EPA's WCIT and RPTB Module 6).
o Identify vendors of water treatment equipment and supplies.
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o Select alternatives for the rehabilitation/remediation of the affected system components
including infrastructure and hardware used to store, treat, and distribute water in the
water system, distribution system components, household plumbing, wastewater piping,
and sewer systems.
o Select alternatives for affected environmental media and use available resources as
necessary.
Consider seeking expert advice from the EPA National Decontamination Team and the National
Homeland Security Research Center if an established decontamination method is not available.
Present the relevant information needed for decision makers to select remedy to satisfy the
remedial action objectives under Step Ic of this decision tree. Categorize each remedy alternative
as:
o Containment technologies.
o Extraction or removal technologies.
o Treatment technologies.
o Institutional controls (e.g., use restrictions, access control, and notices).
o Combination of remedies.
o No decontamination or removal alternative for contaminated water if water treatment or
natural attenuation (for non-persistence in water) may be the most appropriate alternative.
o No additional action alternative for system components if removal or replacement may be
necessary.
Determine whether the selected alternatives meet the Final Remediation Goals:
o Proceed to Step 3 of this decision tree if selected alternatives meet the Final Remediation
Goals.
o If selected alternatives do not meet the Final Remediation Goals, conduct detailed
analysis of available alternatives following further screening of remedial alternatives
under Step Ic of this decision tree.
Step 3: Select preferred remedial action.
Appropriate utility personnel (e.g., ICS Planning), with input from other utility divisions (e.g.,
engineering, security, distribution, commercial, supply, treatment), should be responsible for
selecting the preferred remedial action and making the recommendation to the utility 1C. The
selected remedy should satisfy the Remedial Action Objectives.
The selection of the preferred remedial action should include the following steps:
o Evaluate potential remedial response alternatives developed under Step Ic and Step 2 of
this decision tree based on overall protection of human health and the environment,
compliance with applicable regulations, and long-term effectiveness and permanence.
o Analyze and select the preferred remedial activities by selecting alternatives for treatment
of contaminated water, rehabilitation/remediation of the affected system components,
including infrastructure and hardware, and rehabilitation of affected environmental
media.
o Determine whether selected alternatives meet the Final Remediation Goals.
o Present relevant information needed for decision makers to select a remedy that satisfies
the remedial action objectives.
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o Conduct a comparative analysis to evaluate the performance of each alternative relative
to one another.
o Prepare Remedy Selection Study Report, documenting all results of these analyses.
o Utility 1C should make the final decision in conjunction with the drinking water primacy
agency and other response partners.
If activated, the EOC/ UC should be informed of the decisions.
Determine whether decontamination or removal is necessary.
o Select the "no additional action" alternative and proceed to seek expert advice if removal
or replacement of system components is necessary.
o Proceed to Step 4 of this decision tree to design remedial activities if decontamination is
necessary.
Step 4: Design remedial activities.
The utility 1C should form a design team consisting of utility staff (e.g., engineering, supply,
distribution and treatment).
Appropriate utility personnel (e.g., ICS Planning and ICS Operations Section) should prepare a
Remedial Action Work Plan. This involves:
o Developing a Site Data Collection Plan (if necessary) to support remedial design efforts
(refer to Step la of this decision tree).
o Developing a remedial design to create technical plans for the selected remedy. The
remedial design will contain documents, specifications, and drawings that provide details
of steps to be taken during remedial action for treatment and containment of the system.
o Identifying the remedial design documentation by building and preparation of the
remedial system and verification that the contamination has been sufficiently reduced or
eliminated.
The utility should obtain State plan approval from the drinking water primacy agency or other
required regulatory agencies. The drinking water primacy agency or other regulatory agency may
set minimum criteria for remedial design approval.
Proceed to Step 5 of this decision tree.
Step 5: Install and operate remedial action.
Appropriate utility personnel (e.g., ICS Operations Section) should execute the Remedial Action
Work Plan according to the remedial design. Prepare for long-term monitoring and maintenance
if contaminated water needs to be treated during the same period that the system components are
rehabilitated or natural attenuation processes are used to reduce contaminant concentrations.
Document all remediation action activities in a Remedial Action Report(s), and verify whether
remedial action objectives have been met.
Appropriate utility personnel (e.g., ICS Planning Section) should review the water quality
information to verify that the remedial action objectives have been met and that the contaminant
concentrations have been reduced to acceptable levels (using methods specified by public health
departments, drinking water primacy agency).
1C should report results to the EOC if implemented.
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If remedial action objectives have not been met, go back to Steps 2 through 5 of this decision tree
and complete the sequence.
If remedial action objectives have been met, properly dispose of remediation residuals (Step 5a if
necessary), return the system to service (Step 6 of this decision tree) and conduct post-
remediation monitoring (Step 6a of this decision tree).
Step 5a: Properly dispose of remediation residuals.
The drinking water primacy agency, with additional guidance from EPA, should assist in the
management, classification, and disposal of remedial waste according to applicable regulations.
Remedial waste could include contaminated water, decontamination fluids, water treatment
residuals such as biosolids, contaminated equipment (home water filters, ice makers, water
heaters, and garden hoses), and PPE.
The utility, as 1C for remediation and recovery of the facility, should be responsible for
coordinating the disposal.
Step 6: Return to service.
Once the utility 1C, public health departments, and drinking water primacy agency determine that
all remedial action objectives have been met and initial post-remediation monitoring is
satisfactory, return the system to service. Continue post-remediation monitoring of the system
(Step 6a of this decision tree) after the water system is returned to service. The utility, public
health departments, and the drinking water primacy agency should assume responsibility for
continued monitoring of the system for the contaminants of concern to provide long-term
assurance that the system can maintain normal operation.
The utility, public health department, and the drinking water primacy agency should inform the
local EMA of ongoing monitoring.
Once the system has been returned to service, the utility should document the lessons learned
from the remediation and recovery process.
Step 6a: Conduct post-remediation monitoring and operation.
Appropriate utility personnel (e.g., ICS Planning), in consultation with the public health
department, should create a post-remediation monitoring plan to ensure continued compliance
with the remediation objectives. The monitoring activities include:
o Monitoring for the contaminants of concern.
o Periodic inspection and maintenance of treatment equipment remaining on site.
o Periodic inspection and maintenance of the water distribution system components.
o Maintenance of security measures or institutional controls.
o Public communication of monitoring activities and results.
The monitoring plan should include sampling locations, frequencies, parameters, and durations.
Sampling and monitoring should occur at various locations to help provide an analysis of
contamination levels over time for various points in the water system.
Appropriate utility personnel (e.g., ICS Operations) should conduct the sampling and monitoring
and will report the results to the Planning Section. ICS Planning Section (or appropriate utility
personnel) should review the results and report to 1C, if the ICS has been implemented, who
should report to the EOC. The public health department and the drinking water primacy agency
should also review the results.
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If unacceptable water quality information is obtained, the appropriate utility personnel (e.g., ICS
Planning Section), in consultation with other planning partners, should decide whether to go back
and complete a sequence of remedial steps.
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Appendix C: Public Information Action Plan
The guidance below was developed and adapted from a tool kit prepared by the California Department of
Health Services12 and provides an example of how public information activities might be planned during
each CMP response phase of a contamination incident. Each utility should modify these public
information actions to meet its own specific needs.
Credible Determination
1. Verify the Situation
a. Get the facts from your water system personnel
b. Obtain information from additional sources such as local public health, law enforcement
and fire departments, hospitals, or others
c. Ascertain information sources and determine threat credibility
d. Review and critically judge all information
i. Determine whether the information is consistent with other sources in other
markets
ii. Determine whether the characterization of the incident is plausible
iii. Clarify information through subject matter experts
iv. Attempt to verify the magnitude of the incident and human impact
2. Prepare Information and Obtain Approvals
a. Determine special populations
b. Prepare key messages and initial media statement
c. Develop incident questions and answers
d. Finalize advisories ("boil water," "do not drink," etc.)
e. Draft and obtain approval on initial news release
i. Provide only information that has been approved by the appropriate agencies
do not speculate
ii. State the facts about the incident
iii. Describe the data collection and investigation process
iv. Describe what the water system is doing about the crisis
v. Explain what the public should be doing
vi. Describe how to obtain more information about the situation
f Confirm media contact list
3. Prepare to Notify Employees, Partner Agency PIOs, Public, and Media
a. PIO consults with Utility Director/IC on timing of release of information to employees,
partner agencies. (Employees are the first to be notified.)
b. Develop/distribute scripts for all call takers and talking points for spokesperson
c. Develop questions and answers
4. Identify Staffing and Resource Needs
a. Assemble the crisis communications team
b. Secure an appropriate space, equipment and supplies for the duration of the incident
c. Ensure crisis information is being communicated to staff members
5. Continue Assessments/Activate Crisis Communication Plan
19
Adapted from: "Crisis Emergency Risk Communication Tool Kit, California Dept. of Health Services, March
2006.
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a. Continue to gather and check the facts
b. Activate the crisis communication team
c. Verify information provided by partners and stakeholders
d. Monitor what is being said about the incident for accuracy
6. Organize Assignments
a. Determine the current priorities
b. Identify subject matter experts and spokespersons
c. Decide whether communication should operate 10, 12, 20, or 24 hours a day
d. Decide whether communication should operate 5, 6, or 7 days a week
Confirmed Determination
(Note: Steps 7-12 could occur earlier during an incident and may not necessarily occur in the order
listed.)
7. Notify mayor, city manager, city PIO, utility employees, and call takers
a. Release initial information to utility employees and call takers
8. Release Initial Information to the Media, Public, and Partners through Arranged Channels
a. Distribute news release to media contacts and public officials (for city and other
jurisdictions, depending on affected areas/populations)
b. Ensure spokesperson(s) are standing by for potential media inquiries
c. Distribute media materials to partner/stakeholder organizations. Establish regular
briefing schedule and protocols with partners/stakeholders
d. Establish regular briefing schedule and protocols for working with the media
9. Decide if PN may be required and begin coordination. Consider the following:
a. Is there pressure or inquiry from outside groups/entities?
i. Media
ii. Law enforcement
iii. Political entities (e.g., Mayor)
iv. Citizens/customers
b. Large population or sensitive groups at risk?
c. Potential for major economic loss?
d. How soon will new or updated information arrive?
Incident Confirmed
10. Begin Coordination of PN (Note: This step could occur earlier.)
a. Finalize pre-prepared advisories (e.g., Do Not Use, Do Not Drink, Alternative Water
Supply); work with other agencies (e.g., local health departments) to modify existing
notification templates
b. Notify city manager and city PIO of decision to issue an advisory
c. Keep public updated on any changes or terminations of the advisory throughout the
course of the investigation
11. Update Media/Hold News Conference
a. Send follow-up release with additional incident information and details of any scheduled
news conferences/media briefings
b. Create additional materials, such as media advisory for news conference and media
briefings, as necessary
c. News Conference:
i. Plan agenda, messages, speakers
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ii. Rehearse
iii. Notify media of scheduled news conference
iv. Conduct news conference
v. Distribute press kit
vi. Gather information addressing unanswered journalist questions
vii. Notify media when next update will occur
12. Disseminate Additional Information
a. Send additional information to media, as available
Remediation and Recovery Phase
13. Obtain Information on Alternate Water Supply
a. Coordinate with EOC, county, and State environmental management or protection agency
b. Relay information to the public
14. Ongoing Communication with the Public
a. Report results of sampling and analysis to the public
b. Report any risks, risk reduction measures during decontamination and recovery phases
c. Provide the public with information on the contamination incident, the nature of the
contaminant, and ongoing rehabilitation of the water system
End of Incident and Return to Non-Emergency Operations
15. Provide Final Notice to Public
a. Lift all restrictions and close the incident
16. Obtain Feedback and Conduct Crisis Communications Evaluation
a. Compile and analyze communications and media coverage
b. Share results within utility
c. Determine need for changes to the crisis and emergency crisis communications plan
d. Revise crisis plan policies and procedures based on lessons learned
e. Institutionalize changes with appropriate training
17. Conduct Public Education
a. After incident:
i. Determine public perceptions and information needs related to the incident
ii. Update the community on the incident status through town hall meetings, flyers,
or other outreach activities
iii. For communications and messages for traumatized individuals, the PIO will
defer to local health or mental health officials/professionals to execute any
communications
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Appendix D: Roles and Responsibilities
This appendix provides a description of recommended roles and responsibilities for the CMP, including a
discussion of the ICS as it relates to a drinking water utility and local, State, regional, and Federal
partners.
Utility ICS and Local, State, and Federal Roles
Incident Command at the Water Utility
If a threat or incident is discovered first by water utility personnel, the utility should assume command
and establish their ICS. Under the National Incident Management System (NIMS)13, the ICS is the
national standard for the command, control, and coordination of a response. The flexible nature of the
ICS structure allows for the numbers and types of people on the response team to change over time as the
need for resources and skills changes.
Figure D-l provides an overview of an ICS structure for a drinking water utility. It is important to note
that the ICS structure is flexible and can be modified or enhanced to meet the utility's needs. Also, the
utility ICS may evolve during credible and confirmed determination, and all sections may not be activated
at once. As credible determination transitions to confirmed determination, resources within the ICS will
grow exponentially. At the same time, incident command may transition to higher levels of supervision
and management.
INCIDENT COMMANDER
SAFETY OFFICER
LIAISON OFFICER
PUBLIC INFORMATION
OFFICER
OPERATIONS
(e.g., WQT
Superintendent)
PLANNING
(e.g., Supply
Superintendent)
LOGISTICS
(e.g., Business
Services
Superintendent)
FINANCE/
ADMINISTRATION
(e.g., Accounts Manager)
Figure D-1. Overview of ICS Organization Structure
13
Refer to the FEMA National Incident Management System (NIMS) for further information on the Incident
Command System and Federal, State, and Local roles: www.fema.gov/emergency/nims/index.shtm.
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Unified Command and Local, State, and Federal Roles
As an incident escalates (e.g., credible, confirmed, remediation and recovery) and additional responders
arrive in response to utility notifications, a UC may be established under ICS. Under UC, local, State,
and Federal agencies may work together through the designated members of the UC to manage an
incident. UC may be used when incidents cross jurisdictional boundaries or cross the limits of individual
agency functional responsibility. The UC organization should consist of the ICs from the various
jurisdictions or agencies operating together to form a single command structure. An effective UC:
Enables all responsible agencies to manage an incident together by establishing a common set of
incident objectives and strategies.
Allows ICs to make joint decisions by establishing a single command structure.
Maintains unity of command. Each employee only reports to one supervisor.
The primary differences between a single command structure and a UC structure are that:
In a single command structure, the 1C is solely responsible (within the confines of his or her
authority) for establishing incident management objectives and strategies. The 1C is directly
responsible for ensuring that all functional area activities are directed toward accomplishment of
the strategy.
In a UC structure, the individuals designated by their jurisdictional authorities (or by departments
within a single jurisdiction) must jointly determine objectives, strategies, plans, and priorities and
work together to execute integrated incident operations and maximize the use of assigned
resources.
For example, in Figure D-2, the role of 1C has been replaced with a UC consisting of local, State and
Federal agencies. Note that this type of UC would be established for complex incidents where the State
and Federal government agencies have jurisdiction.
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UNIFIED COMMAND
Local 1C (e.g., utility, police, HazMat)
State 1C (e.g., primacy agency, health dept.)
Federal 1C (e.g., FBI, CDC)
SAFETY OFFICER
LIAISON OFFICER
PUBLIC INFORMATION
OFFICER
OPERATIONS
PLANNING
LOGISTICS
FINANCE/
ADMINISTRATION
Figure D-2. Unified Command for Multi-agency/Multi-jurisdiction Incident
In addition, Figure D-2 serves to graphically show how an Emergency Operations Center (EOC) and a
Joint Operations Center (JOC) may be integrated into the IC/UC structure. An EOC is a pre-designated
facility established at the agency, local, county, regional, and State level to coordinate the overall agency
or jurisdictional response to an emergency. It is not a part of on-scene incident management, but rather
supports the on-scene 1C or UC by arranging for needed resources. A JOC is essentially a federal
equivalent to the local EOC. Established by the FBI, a JOC would be activated during a bioterrorist or
weapons of mass destruction events. FBI agents would join the incident command structure at the local
level in order to feed information back to the JOC.
Regardless of whether or not a UC is established, the utility itself should still retain an individual as their
1C (unless relieved by a higher authority). Regardless of the organization responsible for incident
command, the utility should serve as a technical advisor to the 1C or UC for issues related to the operation
of the water system and ensuring water quality.
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Local, State, Regional, and Federal CMP Partners
Tables D-l through D-4 contain information on local, State, regional and Federal response partners that
may play a role under a UC. It is important to note that each utility's local and State policies and
procedures may require different actions than those described in the examples given below. This
characteristic illustrates why it is important to talk with and include local first responders, the local
emergency planning committee, and public health and primacy agencies in utility emergency response
planning efforts.
Table D-1. CMP Roles and Responsibilities for Local Partners
Local Partner
Organizations
Local health department
Local law enforcement
Local civil government
(e.g., elected officials,
chamber of commerce)
Local emergency
planning committees
(LEPCs) and emergency
management agencies
(EMAs)
Local fire and HazMat
Local wastewater utility
Citizen Corps
Corporate industries
Neighboring utilities
Local railroad
representatives
Nuclear plant
representatives
Poison Control Centers
CMP Roles and Responsibilities
Provide support including consultation and public notification. Serve as conduit to
State and Federal health departments and agencies. May have some degree of
analytical capability to support sampling and analysis.
Provide support through credibility determination and response. May also serve as
conduit to state and national law enforcement and intelligence agencies. In addition,
clarification and understanding of the police roles in securing a site under investigation
should be made so that the utility will have access to take necessary samples needed
to determine the type and extent of contamination.
Should be engaged early in the planning for implementation. Also, should an incident
occur, the elected officials of different jurisdictions should be appropriately informed of
the state of the situation so that they can effectively communicate with their
constituencies.
Primarily support consequence management activities as a conduit to other response
partner agencies at the State and Federal level. Can support provision of alternate
water supplies, coordination, disaster declaration, and transition to NRF
implementation. These groups are made up of industry experts, local emergency
planners-including county law enforcement and fire representatives, and other subject
matter experts.
Local fire department and HazMat play a critical role in consequence management,
including site characterization activities to support credibility determination.
Coordination with the local or volunteer fire units is necessary if water service in a
specific response area should be shut down. The fire department can notify affected
neighborhoods and can distribute alternate water supplies.
May provide analytical support for routine sampling and analysis. Should be consulted
in the development and implementation of CMPs due to the potential impact of
contamination on wastewater operations. Also important for remediation and recovery
because residuals or contaminated water could end up in the collection system.
FEMA-sponsored Community Emergency Response Team training groups can be
especially useful during the first hours of a disaster. They can be used as a first line of
defense until the main response team is operational. They can be used to alert local
citizens of the contamination incident, help guide traffic, assist with triaging medical
casualties, and provide manpower for most activities necessary to assist in the
response.
May provide assistance and resources during an incident. This can include equipment
and food resources (e.g., water, ice).
May provide support in the event of a contamination incident through mutual aid and
assistance. Assists with provision of alternate water supplies, remediation, and
recovery activities.
Can inform local utilities of common shipments which, if derailed, could impact water
management resources. Railroads often have chemical spill experts and HazMat
teams that can assist.
These industries are required to have extensive response plans. Coordination with
these partners is essential in preparing for these types of incidents. Nuclear mitigation
and response plans will indicate which water utilities are within a probable impact area.
Provide emergency poison management information to the utility, residents and their
health care providers.
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Local Partner
Organizations
Red Cross
Hospitals and clinics
Tribal officials
Media
CMP Roles and Responsibilities
May support emergency response crews/firefighters by providing food and drink. May
also provide temporary assistance to those families which are displaced as a result of
the disaster/incident. Assistance includes vouchers for lodging, food, and clothing, or
provision of a community shelter if local resources are not available. They also have
mental health service representatives that can assist first responders and displaced
families.
Hospitals and clinics may have specific information concerning the source of a potential
contamination outbreak and whether it is water-related.
Tribal officials whose reservation may be served by the water utility follow their own
governmental rules. Access to tribal sites will require permission from the designated
tribal representative(s).
Local media organizations may serve as a valuable resource in communicating
messages to the public in the event a contamination incident occurs.
Table D-2. CMP Roles and Responsibilities for State Partner Organizations
State Partner
Organizations
Drinking water and
wastewater primacy
agencies
Environmental and public
health laboratories
State government
State emergency
responders
State emergency
management and
homeland security
agencies
State law enforcement
State Department of
Health
State environmental
representative
Local National Guard
units
CMP Roles and Responsibilities
Primacy agencies can be public health agencies as well as separate State or local
environmental agencies, such as State or regional water quality boards. If
contamination does occur, there may be regulatory ramifications related to use of
contaminated water, public notification, environmental concerns for discharged water,
quality of alternative supplies, and other issues. Additionally, the primacy agency,
along with EPA, should be consulted on any potential remediation and recovery plan.
Provide analytical support during consequence management to assist in credibility
determination as well as response and remediation efforts. State public health
laboratories provide access to CDC's Laboratory Response Network.
May have a role in establishing formal agreements with State partners or coordinating
funding resources. Should be informed and engaged once contamination has been
confirmed to assist in coordination of resources and communication.
Provide support if a contamination incident is confirmed. Should be engaged in
consequence management planning to ensure efficient transition in the event a
contamination incident escalates. State Emergency Response Commissions (SERCs)
can be identified by contacting Emergency Planning and Community Right-to-Know
Act (EPCRA) hotline at 800-535-0202. LEPCs report up to the SERCs.
Provide support if a contamination incident is confirmed. Should be engaged in
consequence management planning to ensure efficient transition in the event a
contamination incident escalates.
Provide support if a contamination incident is confirmed. Should be engaged in
consequence management planning to ensure efficient transition in the event a
contamination incident escalates.
Can assist in tracking data to determine if there is a public health incident. They can
also provide preparedness actions by alerting health care providers of potential
contamination incidents and appropriate treatment methods.
The State environmental representative is sometimes located in the public health
department and sometimes located within the engineering department. Can assist in
providing guidance on engineering devices which could be used in cleanup as well as
monitoring wells/devices which can be used to determine the extent of contamination.
Could provide assistance in cordoning off quarantined or contaminated areas and may
be a key player in alternate water supply acquisition and distribution.
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Table D-3. CMP Roles and Responsibilities for Regional Partner Organizations
Regional Partner
Organizations
Regional Response
Teams (RRTs)
EPA On-Scene
Coordinator (OSC)
EPA Regional offices
and/or laboratories
Homeland security
representatives and
workgroups
CMP Roles and Responsibilities
There are 1 3 RRTs that are spread out over the U.S. RRTs are made up of
representatives from Federal agencies which make up the National Response Team
(NRT). RRTs work with local and State officials along with an On-Scene Coordinator
(OSC). RRTs have responsibilities for response, planning, training, and coordination
associated with chemical releases or oil spills. When resources are limited, RRTs can
request assistance from Federal or State entities to provide sufficient resources when
responding to an incident.
Usually from EPA Superfund, provides direction, guidance and support during
response activities.
May assist in coordination of federal resources (including EPA response resources),
provide technical assistance, and provide analytical surge capacity during phases of
consequence management.
These representatives are essential and should be included in CMP procedures. By
establishing two-way communication and coordination with these groups, they might
be able to support the determination of, and response to an intentional event.
Table D-4. CMP Roles and Responsibilities for Federal Partner Organizations
Federal and National
Partner Organizations
Agency for Toxic
Substance and Disease
Registry (ATSDR)
Centers for Disease
Control and Prevention
(CDC)
EPA Criminal
Investigation Division
(CID)
EPA Environmental
Response Team (ERT)
EPA National
Decontamination Team
(NOT)
Federal Bureau of
Investigation (FBI)
Federal Emergency
Management Agency
(FEMA)
National Response
Center (NRC)
CMP Roles and Responsibilities
Responds to incidents where toxic and hazardous substances were released which
might impact public health. They can be activated by calling the CDC Director's EOC
at 770-488-71 00 and asking for the on-call ATSDR Emergency Response
representative.
Provide oversight to the Laboratory Response Network, a network of public health
laboratories with the ability to analyze for select agents based on established analytical
protocols. Ensure member laboratories have appropriate training, equipment,
reagents, and resources. Provide technical consultation during credibility
determination and other phases of consequence management.
Provide support if a contamination incident is confirmed. Should be engaged in
consequence management planning to ensure efficient transition in the event a
contamination incident escalates.
Provide support if a contamination incident is confirmed. Should be engaged in
consequence management planning to ensure efficient transition in the event a
contamination incident escalates. EPA ERT can provide assistance and technical
guidance during response and can assist in evaluating threats to human health. The
team can also assist in providing technical bulletins, fact sheets, SOPs, and analytical
method development/evaluation.
Along with EPA National Response Team and the OSC, the National Decontamination
Team provides support and guidance in remediation and recovery activities.
May assist in site characterization and/or CMP development. Establishing a
relationship with local FBI agents early in the implementation process is critical due to
the need to establish and understand roles and responsibilities in the event
contamination occurs.
Can assist with provision of resources during a man-made or natural disaster.
NRC is the 24/7 response center which is manned by the U.S. Coast Guard. It is
where releases or spills should be reported. The main NRC hotline is 800-424-8802.
NRC can notify other agencies of the incident and can assist with technical support in
response to the situation. Although NRC is not a true partner to be involved in the
CMP process, it is a valuable resource.
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Appendix E: References and Tools
The following is a list of references and Internet links that may be useful in preparing a CMP.
Response Plan Guidance Documents, Publications, and On-line Tools
Agency for Toxic Substances and Disease Registry (ATSDR): ATSDR provides useful
information for substances not found in the EPA WCIT. http://www.atsdr.cdc.gov/
American Water Works Association (AWWA): EPA training developed through partnership
with AWWA covers security issues, including assessing vulnerabilities, emergency response
plans and risk communication. AWWA information can be accessed at the AWWA Web site,
http://www.awwa.org.
o Specific AWWA resources can be found at:
http://www.awwa.org/Resource s/Content.cfm?ItemNumber=29824&navItemNumber=29
837
o Additional information on mutual aid and assistance networks in the water sector can be
found at: http://www.nationalwarn.org
U.S. Army Corps of Engineers (USAGE): USAGE has typically been assigned by FEMA to
provide commodities such as bottled water and packaged ice (in the aftermath of disasters) to
State and local governments for distribution to victims. The distribution of these items to the
public is a local responsibility in coordination with the State, and is a labor-intensive operation.
For information on distribution methods go to:
http://www.usace.armv.mil/publications/eng-regs/er500-l-l/entire.pdf
The Association of State Drinking Water Administrators (ASDWA): ASDWA has
information on water security planning, training, and links to state programs and other
information sources. Go to the security link at http://www.asdwa.org.
U.S. Department of Labor Occupational Safety & Health Administration (OSHA):
Information concerning developing Health and Safety Plans (HASPs) can be found on the OSHA
website. Go to: http://www.osha.gov/dep/etools/ehasp/index.html for an electronic expert system
jointly developed by EPA and OSHA.
U.S. Environmental Protection Agency (EPA): EPA has numerous resources available in
addition to this guidance. The following are key sources:
o Compendium of Environmental Testing Laboratories: A network of laboratories which
provides emergency responders with an efficient mechanism to obtain essential
laboratory capability and capacity information during emergency situations (registration
required):
https://cfint.rtpnc.epa.gov/cetl/lblogin.cfm?action=None&CFID=368552&CFTOKEN=6
7904652&isessionid=ba3028ce85e96511236cTR
o Drinking Water Health Advisories: For more information on Drinking Water MCLs and
associated health advisories go to: http://www.epa.gov/waterscience/criteria/drinking/
o Large Water System Emergency Response Plan Outline: Guidance to assist community
water systems in complying with the Public Health Security and Bioterrorism
Preparedness and Response Act of 2002, available at:
http://www.epa.gov/safewater/watersecuritv/pubs/erp-long-outline.pdf
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o Emergency Response Plan Guidance for Small and Medium Community Water Systems:
Document published by EPA for use by community water systems serving a population
between 3,301 and 99,999 as they develop or revise emergency response plans. The
document should be of considerable value to key authorities with critical roles during
emergency response or remediation actions resulting from a drinking water
contamination threat or incident. This document is available at:
http://www.epa.gov/safewater/watersecurity/pubs/small medium ERP guidance040704.
rjdf
o Response Protocol Toolbox (RPTB): Planning for and Responding to Drinking Water
Contamination Threats and Incidents: The RPTB is composed of six interrelated modules
that focus on different aspects of planning a response to contamination threats and
incidents:
Overview (EPA-817-D-03-007), available at:
http://www.epa.gov/safewater/watersecurity/pubs/guide response overview.pdf
Water Utility Planning Guide - Module 1 (EPA-817-D-03-001), available at:
http://www.epa.gov/safewater/watersecurity/pubs/guide_response_modulel.pdf
Contamination Threat Management Guide - Module 2 (EPA-817-D-03-002),
available at:
http://www.epa.gov/safewater/watersecuritv/pubs/guide response module2.pdf
Site Characterization and Sampling Guide - Module 3 (EPA-817-D-03-003),
available at:
http://www.epa.gov/safewater/watersecuritv/pubs/guide response module3.pdf
Analytical Guide - Module 4 (EPA-817-D-03-004), available at:
http://www.epa.gov/safewater/watersecurity/pubs/guide response module4.pdf
Public Health Response Guide - Module 5 (EPA-817-D-03-005), available at:
http://www.epa.gov/safewater/watersecurity/pubs/guide_response_module5.pdf
Remediation and Recovery Guide - Module 6 (EPA-817-D-03-006), available at:
http://www.epa.gov/safewater/watersecurity/pubs/guide response module6.pdf
o Response Protocol Toolbox - Response Guidelines: An action oriented document to
assist drinking water utilities, laboratories, emergency responders, state drinking water
programs, technical assistance providers, and public health and law enforcement officials
during the management of an ongoing contamination threat or incident. This document
can be found at:
http://www.epa.gov/safewater/watersecurity/pubs/rptb response guidelines.pdf
o Water Contaminant Information Tool (WCIT): A secure, on-line database that provides
information on chemical, biological, and radiological contaminants of concern for water
security. Also can be used as a resource for contaminant-specific detailed information on
the effectiveness of treatment methods for drinking water and wastewater. This can be
found at: http ://www.epa. gov/wcit
Risk Communication Resources
California Department of Health Services and the Centers for Disease Control and
Prevention (CDC):
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o Crisis and Emergency Risk Communication Toolkit: Provides water systems the essential
resource materials to assist in effectively managing and communicating during an
emergency or crisis. This can be found at:
http://www.dhs.ca.gov/ps/ddwem/Homeland/PDFs/CERCtoolkit.pdf
U.S. Environmental Protection Agency (EPA): EPA has numerous resources available on PN
and risk communication. The following are key sources:
o Code of Federal Regulations for the Public Notification Rule (July 1, 2007 Edition): 40
CFRPart 141, Subpart Q (141.201-141.211). This can be found at:
http://www.access.gpo.gov/nara/cfr/waisidx 07/40cfrl41 07.html
o Revised Public Notification Handbook: This guide was developed for community water
systems and non-transient non-community water systems. It provides instructions and
includes templates that can be used for various types of public notices (EPA 816-R-07-
003, March 2007). This can be found at:
http://www.epa.gov/safewater/publicnotification/pdfs/guide_publicnotification_pnhandbo
ok.pdf
o Public Notification Handbook for Transient Non-community Water Systems: This guide
was developed for transient non-community water systems. It provides instructions and
includes templates that can be used for various types of public notices (EPA 816-R-07-
004, March 2007). This can be found at:
http://www.epa.gov/safewater/publicnotification/pdfs/guide_publicnotification_pnhandbo
ok_tncws.pdf
o PNiWriter: EPA released this web-based program to help public water systems comply
with the public notification requirements of the Safe Drinking Water Act. The PNiWriter
provides a fast, user-friendly format for creating public notices that meet all Federal
requirements. After users log in they will see a series of questions about the violation or
situation requiring public notice. After answering questions and filling in blanks they will
be able to print or download the public notice, an instruction sheet, and public notice
certification. The program is free and can be accessed at http://www.pniwriter.org. Users
may also access the program from the EPA web site at:
http://www.epa.gov/safewater/publicnotification/compliancehelp.html
o EPA Effective Risk and Crisis Communication during Water Security Emergencies
Report (EPA/600/R-07/027): This document includes sample messages for the following
scenarios: biological contamination, physical attack, receipt of a credible threat, power
loss, pesticide contamination, and chemical warfare agent contamination. The document
can be found at: http://www.epa.gov/NHSRC/pubs/600r07027.pdf
o For another overview of message mapping, refer to EPA Research Highlights on Risk
Management Research (http://www.epa.gov/nrmrl/news/news012006.html). This link
includes information on a new EPA workbook that is under development: "Risk
Communication in Action: Tools of Message Mapping."
o Response Protocol Toolbox (RPTB): Planning for and Responding to Drinking Water
Contamination Threats and Incidents. Public Health Response Guide - Module 5 (EPA-
817-D-03-005), available at:
http://www.epa.gov/safewater/watersecuritv/pubs/guide response module5.pdf
World Health Organization:
o Effective Media Communication during Public Health Emergencies: A WHO Handbook:
This handbook describes a seven-step process to assist public health officials and others
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to communicate effectively through the media during emergencies. This can be found at:
www.who.int/csr/resources/publications/WHO CDS 2005 3 I/en/
Information Management Resources
U.S. Department of Justice (DOJ): Crisis Information Management Software (CIMS) may be
useful, especially when interfaced with a central data repository and/or electronic data
management system. A description and comparison of several commercial CIMS packages has
been prepared by the DOJ, http://www.ncjrs.org/pdffilesl/nij/197065.pdf
U.S. Environmental Protection Agency (EPA): A Field Operations and Records Management
System (FORMS), originally developed for EPA's Contract Laboratory Program, may help
manage records relevant to sample documentation, analysis, and tracking during evaluation of
water threats. Can be accessed at: http://www.epa.gov/superfund/programs/clp/f21ite.htm
Training Resources
Federal Emergency Management Agency (FEMA):
o FEMA offers support and guidance in preparedness and planning. In addition, the FEMA
Emergency Management Training Institute offers on-line training for the NIMS/ICS
courses described in Section 5.0 of this document. This can be found at:
http://www.fema.gov/emergency/nims/nims_training.shtm
o FEMA Exercise Design Training:
IS 120: An Orientation to Community Disaster Exercises-
http: //training. fema. gov/EMPvVeb/IS/is 120. asp
IS 139: Exercise Design - http://training.fema.gov/EMPWeb/IS/is 139.asp
U.S. Environmental Protection Agency (EPA):
o Emergency Response Tabletop CD-ROM Exercise for Drinking Water and Wastewater
Systems: The CD-based tool contains tabletop exercises to help train water and
wastewater utility workers in preparing and carrying-out emergency response plans. The
exercises provided on the CD can help strengthen relationships between a water supplier
and its emergency response team (e.g., health officials, laboratories, fire, police,
emergency medical services, and local, State, and Federal officials). Users can adapt the
materials for their own needs. The exercises also allow water suppliers to test their
Emergency Response Plans before an actual incident occurs. This can be found at:
http://www.epa.gov/safewater/watersecurity/tools/trainingcd/.
o U.S. Department of Homeland Security (DHS): Extensive details for the development
of all types of exercises can be found at the Department of Homeland Security Web site,
httos://hseep.dhs.gov/.
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