United States
Environmental Protection
Agency
Response Protocol Toolbox:
Planning for and Responding to
Drinking Water Contamination
Threats and Incidents
Interim Final - December 2003
Overview and Application

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                      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C.  20460
                                        DEC   18
Dear Colleague,
        I am writing to announce the release of the interim final Response Protocol Toolbox: Planning for and
Responding to Drinking Water Contamination Threats and Incidents (the Response Protocol Toolbox). The
Response Protocol Toolbox was produced by EPA, building on the experience and expertise of several drinking
water utilities, in particular, the Metropolitan Water District of Southern California.  Our objective in providing
this interim final guidance is to help the water sector effectively and appropriately plan for and respond to
contamination threats and incidents.

        The Response Protocol Toolbox will be of value to drinking water utilities, laboratories, emergency
responders, state drinking water programs, technical assistance providers, and public health and law-
enforcement officials.  While the Response Protocol Toolbox provides useful direction, it is primarily a
planning tool.  EPA recommends that users practice implementing this proposed framework and carry-out drills
and training to improve preparedness.  This draft release includes Modules 1 through 4, as well as an overview
of the entire Response Protocol Toolbox. Users are encouraged to read the overview before using other
Modules.  Please note that Modules 5 and 6 will be included in the  final release, due in spring 2004. The titles
of the Modules are as follows:

        Overview of the Response Protocol Toolbox (EPA-817-D-03-007)
        Water Utility Planning Guide - Module 1 (EPA-817-D-03-001)
        Contamination Threat Management Guide - Module 2 (EPA-817-D-03-002)
        Site Characterization and Sampling Guide - Module 3 (EPA-817-D-03-003)
        Analytical Guide - Module 4 (EPA-817-D-03-004)
        Public Health Response Guide - Module 5 (EPA-817-D-03-005) under development
        Remediation and Recovery Guide - Module 6 (EPA-817-D-03-006) under development

        The Response Protocol Toolbox modules can be found in electronic PDF format on the EPA website at:
http://www.epa.gov/safewa.ter/security/ under Emergency Response Tools. Printed copies, in limited quantity,
can be obtained from the Water Resource Center by phone: 800-832-7828 or 202-566-1729, by fax: 202-566-
1736, or by e-mail: center. water-resource(a)epa.gov.  If additional information  is needed, please call the Safe
Drinking Water Hotline at 1 -800-426-4791.

        1 ask for your assistance in publicizing the availability of the Response Protocol Toolbox to ensure that
it reaches the drinking water systems, government officials, laboratories,  and first responders who will benefit
from it most.
                                             Sincerely
                                                            lerty,
                                                   of Ground Water and Drinking Wate:
                                   Internet Address (URL) • http://www.epa.gov
               Recycled/Recyclable »F'nnted wrth Vegetable Oil Based Inks or; Recycled Paper ^Mmtmym 30'''^

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            Response Protocol Tool box:
           Planning for and Responding to
Drinking Water Contamination Threats and Incidents

             Overview and Application
                  Interm Final - December 2003
                  PLANNING AND PREPARATION
                        Threat Warning
                     Initial Threat Evaluation
                     Immediate Operational
                       Response Actions
                    Site Characterization and
                          Sampling
                     Public Health Response
                          Actions
                       Sample Analysis
                         Is Incident
                         Confirmed?
                    Remediation and Recovery

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                                                                       Overview and Application
                                   ACKNOWLEDGEMENTS

                                  	Primary Authors	
Steven C. Allgeier, U.S. EPA - OGWDW - WSD
Bart Koch, MWD Southern California
 Matthew L. Magnuson, U.S. EPA-ORD-NRMRL-WSWRD
 Ricardo DeLeon, MWD Southern California
                                        Utility Workgroup
Ron Hunsinger, East Bay MUD
Cliff Bowen, California DHS
Andy DeGraca, San Francisco PUC
Walter Grayman, Grayman Associates
Bart Koch, MWD Southern California
Ed Means, McGuire Consulting
Melinda Rho, Los Angeles DWP
Mic Stewart, MWD Southern California
Kelvin Yamada, California DHS
Manoucher Boozarpoor, San Francisco PUC
Phillippe Daniel, COM
Ricardo DeLeon, MWD Southern California
Jack Jacobs, EMA Inc.
Razmik Manoukian, Los Angeles DWP
Pankaj Parekh, Los Angeles DWP
Raymond Riordan, Riordan Associates
Irish Wathen, California DHS
                                       Additional Support
Bob Barles, U.S. EPA - OGWDW
Kim Fox, U.S. EPA - ORD - NHSRC
Jonathan Herrmann, U.S. EPA - ORD - NHSRC
Dennis Juranek, CDC
Nelson Mix, U.S. EPA - OSWER
Janet Pawlukiewicz, U.S. EPA - OGWDW - WSD
Grace Robiou, U.S. EPA - OGWDW - WSD
Diane Van DeHei, AMWA
 Susan Dolgin, U.S. EPA - OGWDW - WSD
 Brian Frazer, U.S. EPA - OGWDW - WSD
 Vince Hill, CDC
 Alan Lindquist, U.S. EPA - ORD - NHSRC
 Bridget O'Grady, ASDWA
 Alan Roberson, AWWA
 Tom Schaeffer, AMWA
                                       Technical Reviewers
Phillip Adams, New Mexico Department of Health
Andrew Bielanski, U.S. EPA - OGWDW - WSD
Timothy Croley, Virginia State Laboratory
David Degenhardt, Wisconsin State Lab of Hygiene
Christina Egan, State of New York Dept. of Health
Ed George, Environmental Health Labs
Greg Grover, U.S. EPA - Region 6
Dan Hickman, Oregon DEQ Laboratory
Janet Jensen, U.S. Army - SBCCOM
Marcis Kempe, Massachusetts WRA
Carrie Lewis, Milwaukee Water Works
Denise MacMillan, Army Corp of Engineers
Robert Maxfield, U.S. EPA - Region 1
Anand Mudambi, U.S. EPA - OSWER
Trikam Patel, New York City DEP
Kusum Perera, California DHS
Steve Rhode, Massachusetts WRA
Dave Siburg, Kitsap Public Utility District
Stanley States, Pittsburgh Water & Sewer Authority
Marty Swickard, U.S. EPA - Region 8
Caroline Wehling, U.S. EPA - OGC
Caryn Wojtowicz, Ecology and Environment Inc.
 Joseph Barbera, George Washington University
 R. Broxter, Kansas Dept. or Health and Environment
 Rick Danielson, BioVir Laboratories
 Jane Downing, U.S. EPA - Region 1
 Michael Eldert, Hampton Roads Sanitation District
 John Griggs, U.S. EPA - ORIA
 David Hartman, Cincinnati Water Works
 Charlie Hooper, U.S. EPA - Region 4
 Michael Johnson, U.S. EPA - OSWER
 Ewa King, Rhode Island Public Health
 Ted Lyter, Pennsylvania DEP
 Brad Mahanes, U.S. EPA - OECA - OCEFT - CID
 Maureen McClelland, U.S. EPA - Region 1
 Julianne Nassif, Massachusetts Dept.  of Public Health
 Jim Pearson, Virginia State Laboratory
 Frances Pouch Downes, Michigan DCH
 Paul Servizio, Massachusetts Dept. of Public Health
 Drew Smith, Monroe County Environmental Lab
 Paul Swedenborg, Minnesota Department of Health
 Gene Taylor, U.S. EPA - Region 10
 Michael Wichman, University of Iowa Hygienic Lab
 Marvin Young, U.S. EPA - Region 9
 The Response Protocol Toolbox has been reviewed by U.S. EPA Office of Water, Office of Research and
 Development, and Office of General Counsel, and approved for release as non-binding guidance.
                                                                          Interim - December 2003

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                                                         Overview and Application


                            TABLE OF CONTENTS


1   INTRODUCTION	4

2   OVERVIEW OF THE RESPONSE PROTOCOL TOOLBOX	5

  2.1    MODULE 1, WATER UTILITY PLANNING GUIDE	5
  2.2    MODULE 2, CONTAMINATION THREAT MANAGEMENT GUIDE	5
  2.3    MODULE 3, SITE CHARACTERIZATION AND SAMPLING GUIDE	6
  2.4    MODULE 4, ANALYTICAL GUIDE	7
  2.5    MODULE 5, PUBLIC HEALTH RESPONSE GUIDE (IN PREPARATION)	8
  2.6    MODULE 6, REMEDIATION AND RECOVERY GUIDE (IN PREPARATION)	9

3   APPLICATION OF THE RESPONSE PROTOCOL TOOLBOX	11

  3.1    PLANNING A RESPONSE TO A CONTAMINATION THREAT	11
  3.2    REVISING "EMERGENCY RESPONSE PLANS"	12
  3.3    DEVELOPING "RESPONSE GUIDELINES"	13
  3.4    OTHER APPLICATIONS OF THE RPTB	13

LIST OF FIGURES

FIGURE O-l: RELATIONSHIPS AMONG THE MODULES IN THE RESPONSE PROTOCOL TOOLBOX
          (RPTB)	4
FIGURE O-2: EXAMPLES OF THE USE OF THE RESPONSE PROTOCOL TOOLBOX (RPTB) BY
          VARIOUS INTEREST GROUPS	12
                                                            Interim - December 2003

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                                                              Overview and Application
1   Introduction
The Response Protocol Tool Box (RPTB) is composed of six interrelated modules, in addition to
this overview, which focus on different aspects of planning a response to contamination threats
and incidents, long before they occur. The RPTB is primarily concerned with drinking water
contamination threats, whereas physical and cyber attacks are mostly related to other security
issues and are the subject of documents being prepared separately. Figure O-l illustrates the
interconnected relationships among the modules.  Module 1 is an overarching document that
serves both as a primer on contamination threats to drinking water systems and an overall guide
to utility planning for such incidents. As depicted in Figure O-l, Module 2 is the hub of the
toolbox in that it addresses the overall management of a contamination threat. The remaining
modules support Module 2 by presenting information and protocols for investigating the
contamination threat or implementing actions in response to a contamination threat or incident.
The current overview describes the entire RPTB and provides guidance on its application.
                                    Module 1
                           Water Utility Planning Guide
                   Module 3
             Site Characterization
                     and
               Sampling Guide
    Module 4
Analytical Guide
                                     Module 2
                               Threat Management
                                      Guide
                   Module 5
                 Public Health
                Response Guide
    Module 6
 Remediation and
 Recovery Guide
Figure O-l. Relationships among the Modules in the Response Protocol Toolbox (RPTB).
The RPTB is a planning tool, and should be integrated into a user's specific emergency response
planning activities in order to effectively manage an actual threat.  The modules in the RPTB
were not prepared for use during the response to an emergency.  Response Guides are intended
for that purpose and are described below in Section 3.3. Furthermore, the RPTB does not
implement any specific statutory directive and does not establish any requirements.  It is
provided as guidance to aid utilities and other users in planning a response to contamination
threats.
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                                                               Overview and Application


2   Overview of the Response Protocol Toolbox

The six modules that constitute the RPTB are:
   1.  Water Utility Planning Guide
   2.  Contamination Threat Management Guide
   3.  Site Characterization and Sampling Guide
   4.  Analytical Guide
   5.  Public Health Response Guide
   6.  Remediation and Recovery Guide

This section provides an overview, presents the objectives, and describes the intended audience
for each of these modules. While various modules were developed with a specific target
audience in mind, any user may benefit from review of all the modules in the RPTB in order to
become familiar with the various aspects of the response to a drinking water contamination threat
or incident.
2.1  Module 1, Water Utility Planning Guide
Overview. Module 1 provides a brief discussion of the nature of the contamination threat to the
public water supply. The module also describes the planning activities that a utility may
undertake to effectively manage contamination threats and incidents.

Objectives. The objectives of Module 1 are to:
    1)  Familiarize the reader with the nature of water contamination threats and incidents.
    2)  Provide an understanding of the various planning activities associated with the
       management of water contamination threat or incident.

Audience. While the planning aspects of this module are targeted at drinking water utilities,
much of the information provided will be of interest to any user that might support a drinking
water utility during response to a contamination threat.  This extended audience might include
drinking water primacy agencies, law enforcement agencies, public health agencies, or crisis
management organizations.

Highlights. Module 1:
       •   Provides an overview of contamination threats.
       •   Describes the various warning signs of a potential contamination incident.
       •   Discusses the concept of "due diligence" in responding to contamination threats.
       •   Lists several areas where planning and preparation are necessary to the effective
          management of a contamination threat.
2.2  Module 2, Contamination Threat Management Guide
Overview. The threat management process involves two parallel and interrelated activities:
1) Evaluating the threat, and 2) Making decisions regarding appropriate actions to take in
response to the threat. The first step of the threat evaluation process involves the collection of
information to help determine if the threat is 'possible'; that is, do the circumstances of a threat
                                                                  Interim - December 2003

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                                                                Overview and Application


indicate the opportunity for contamination? Following the determination that the threat is
'possible', additional information is gathered to help determine if the threat is 'credible'; that is,
does the additional information corroborate the information already known about the threat?
Finally, efforts are taken to 'confirm' the contamination incident; that is, is there definitive
evidence that the water has actually been contaminated with a harmful substance?  This is a
progressive evaluation in which more serious response actions are considered as the threat is
elevated through these three stages.

There are a number of difficult management decisions that must be made before, during, and
after a contamination threat, such as: 1) How to decide if an incident has occurred, as opposed to
a hoax; 2) What actions to take in response to a threat; 3) How to determine that a perceived
threat is not 'credible' and can be dismissed; and 4) How to manage a confirmed contamination
incident.

Objectives. The objectives of Module 2 are to:
       1) Present a framework for evaluating  a water contamination threat and making
          decisions at key points in the process.
       2) Describe the type of information that may be useful for conducting a threat
          evaluation.
       3) Describe the actions that might be implemented in response to a contamination threat,
          giving consideration to the potential consequences of various actions.

Audience.  The primary audience for this module is the water utility emergency response
manager (WUERM),  who will likely have some role in the threat management process
throughout the response. Furthermore, other individuals that might be involved in the
management of a contamination threat, such as members of law enforcement, the drinking water
primacy agency, and the public health department, should also review this module.

Highlights. Module 2:
       •  Describes the three stages of a threat evaluation: possible, credible, and confirmed.
       •  Describes the information that might support both the threat evaluation and the
          response actions that might be considered at each of these stages.
       •  Identifies the types of individuals and organizations that might become involved at
          various stages of the contamination  threat management process.
       •  Provides examples regarding the manner in which the threat management process is
          applied to different incident warnings.
       •  Contains various forms that might aid in the documentation of incident warnings and
          the subsequent threat evaluation process.  The readers may find these forms useful in
          preparing their own Response Guidelines, described below in Section 3.3 below.
2.3  Module 3, Site Characterization and Sampling Guide
Overview. Site characterization is defined as the process of collecting information from the site
of a suspected contamination incident at a drinking water system. Site characterization activities
include the site investigation, field safety screening, rapid field testing of the water, and sample
collection.
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                                                                 Overview and Application
Objectives. The objectives of Module 3 are to:
       1) Describe considerations for personnel involved in the planning or execution of site
          characterization activities in response to a water contamination threat.
       2) Present protocols and procedures for the site investigation, field safety screening,
          rapid field testing, and sample collection.

Audience. Any individuals involved in planning or implementing site characterization activities
are encouraged to review this module in its entirety. Laboratories that may tend to focus on
Module 4 (Analytical Guide) may also find the information in Module 3 useful, particularly with
respect to the screening activities that occur in the field and directly impact the safety
considerations of the laboratory.

Highlights. Module 3:
   •   Provides an overview of planning for safe and effective site characterization.
   •   Describes the qualifications of individuals sent to the site, as well as the steps taken to
       ensure the safety of the site characterization team.
   •   Contains various sample forms that may be useful for planning and documenting the
       results of site characterization and sampling activities, including chain of custody.  The
       readers may find these forms useful in preparing their own Response Guidelines, as
       described in Section 3.3.
   •   Describes field safety screening and the contents of a core and an expanded field test kit.
   •   Lists the contents of a model sample collection kit.
   •   Presents considerations for shipping the collected samples to the laboratory for analysis.
2.4   Module 4, Analytical Guide
Overview. The analytical guide presents an approach to the analysis of samples that may be
collected from the site of a suspected contamination incident. The purpose of the Analytical
Guide is not to provide a detailed protocol. Rather, it describes a framework for developing
an approach for the analysis of water samples collected during site characterization. The
framework is flexible and will allow the approach to be crafted based on available information
about the threat and the requirements of the specific situation.  The framework is also
designed to promote the effective and defensible performance of laboratory analysis.

Objectives. The objectives of Module 4 are to:
       1)  Describe special laboratory considerations for handling and processing emergency
           water samples suspected of contamination with a harmful substance.
       2)  Present model approaches and procedures for analysis of water samples suspected
           of contamination with a known or unknown substance(s).
       3)  Encourage planners to develop site-specific analytical approaches that follow the
           general principles of the framework and model analytical approaches presented in
           Module 4.

Audience. This module should be reviewed by both laboratory and utility planners and by
laboratory personnel.
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                                                                 Overview and Application
Highlights. Module 4:
    •   Describes existing laboratory infrastructure for the analysis of water contaminants,
       including a link to a compendium of laboratories that might support utilities in the
       analysis of emergency water samples.
    •   Discusses considerations for the analysis of water samples collected during an
       emergency, including safety, quality assurance, and legal admissibility of scientific
       evidence.
    •   Summarizes those aspects of site characterization issues that relate to laboratory safety
       and analysis.
    •   Introduces a general approach for the analysis of unknowns, which integrates  site
       characterization results to produce a rapid, defensible, and comprehensive analysis.
    •   Presents an analytical approach for chemicals and pathogens based on two forms of
       screening for specific classes of contaminants. This approach utilizes a combination of
       standardized methods and sound exploratory  techniques.
    •   Provides examples of the customization of the analytical approach to specific  laboratory
       objectives.
2.5   Module 5, Public Health Response Guide (in preparation)
Overview: Module 5 deals with the public health response measures that would potentially be
used to minimize public exposure to potentially contaminated water.  It discusses the important
issue of who is responsible for making the decision to initiate public health response actions, and
considers the role of the water utility in this decision process. Specifically, it examines the role
of the utility during a public health response action, as well as the interactions between the
utility, the drinking water primacy agency, the public health community, and other parties with a
public health mission.

Objectives: The objectives of Module 5 are to:
       1) Identify the organizations and officials responsible for making and implementing
          public health response decisions for drinking water.
       2) Describe the role of the drinking water utility in the public health response to a water
          contamination threat.
       3) Develop communication protocols and structures within the responding public health
          agencies and also for communication with the public and the media.
       4) Identify resources  and techniques to aid in evaluation of public health consequences
          associated with specific contaminants.
       5) Consider acute and chronic effects via ingestion, inhalation, and dermal exposure
          pathways.
       6) Develop response  options, including containment and public notification.
       7) Identify potential short-term alternative water supplies.
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                                                                Overview and Application


Audience.  The primary intended users of this module include water utility staff and entities that
will assist small water utilities (e.g., drinking water primacy agencies). In addition, public health
response agencies (e.g., public health departments) are encouraged to read this module since they
will likely make the decisions regarding the public health response actions that are taken (e.g.,
public notification) during a water contamination threat.

Highlights. Module 5:
   •   Describes the organizations that may be involved in making public health decisions,
       various response options that may be considered, and the need for an effective
       communication plan.
   •   Describes the contaminant characteristics that should be considered when making public
       health decisions.
   •   Describes methods of estimating the spread of contaminated water and containment
       options.
   •   Discusses public notification, including applicable regulatory requirements, as a means of
       reducing or mitigating exposure and avoiding public panic, types of notifications,  and
       information that is readily available or may be developed to educate the public (e.g., fact
       sheets).
   •   Discusses alternate water supply issues pertaining to domestic consumption, sanitation,
       fire-fighting, and needs of critical customers.
2.6   Module 6, Remediation and Recovery Guide (in preparation)
Overview. Following a confirmed water contamination incident, it will be necessary to
remediate the system and demonstrate that the system has been successfully restored prior to
resuming normal operation. This process involves a sequence of activities, including system
characterization and selection of remedy options.  Following implementation of the remediation
plan, steps must be taken to demonstrate that the system can be returned to normal operation.
Furthermore, plans will need to be made for the long-term supply of alternate drinking water
during remediation. Module 6 describes the planning and implementation of these remediation
and recovery activities, the types of organizations that would likely be involved in this stage of a
response, and the utility's role during remediation and recovery.

Objectives: The objectives of Module 6 are to:
       1)  Identify the organizations and officials responsible for making and implementing
          decisions regarding remediation and recovery activities for contaminated drinking
          water.
       2)  Describe the role of the drinking water utility during the remediation and recovery
          stage of a contamination incident.
       3)  Describe how a systematic planning process can be applied to ensure that the right
          type, quantity, and quality of data are obtained to support the remediation and
          recovery activities.
       4)  Describes the process for selecting a remedial technology,  both for treatment of
          contaminated drinking water and remediation of contaminated system components.
       5)  Present the issues and considerations associated with returning to normal operation
          following remediation and recovery activities.
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                                                                Overview and Application
Audience. The target audience for this module includes individuals that will be involved in
system characterization, risk assessment, and remedial response action activities following a
confirmed contamination incident.  The target audience also includes decision-makers who will
determine the need for long-term alternate water supplies, select remedial technologies,
determine when to return to normal operations, and communicate with the public.

Highlights.  Module 6:
    •   Presents procedures for characterization of the contaminated area.
    •   Describes considerations for providing a long-term alternate supply of drinking water
       during the remediation and recovery stage.
    •   Describes a flexible sequence of steps designed to select the appropriate remedial
       response to address a contaminated drinking water system.
    •   Describes regulations that must be considered when managing wastes generated from the
       remediation of a contaminated waste system.
    •   Presents special considerations for system restart with emphasis on public outreach and
       communication.
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                                                               Overview and Application
3   Application of the Response Protocol Toolbox
The following subsections list three main areas in which the RPTB may be applied, as well as
some examples of those applications. Ultimately, the RPTB will be packaged in an electronic
format that will allow users to easily integrate the elements best suited to their individual needs
and the unique aspects of their water supply. Accordingly, the intent of the material in this
section is to encourage users to take advantage of the robust and flexible nature of this toolbox in
crafting their own plans.
3.1  Planning a Response to a Contamination Threat
It is important to remember that the RPTB is much more effective as a planning tool than as a
reference during an actual contamination threat when decisions will need to be made rapidly and
with limited information.  As a planning tool, it provides a framework to guide the utility's
response to contamination threats. These plans can help identify credible threats and dismiss
hoaxes, and support decisions regarding response actions that are appropriate for the situation.
To increase the effectiveness of these plans, utilities should exercise them under conditions that
simulate the stresses resulting from an actual contamination threat.

The RPTB  does not attempt to define who will be involved in various stages of a response.
These decisions are best left to local authorities, who have an intimate knowledge of the
organizations and systems that exist within their water utility, government, and community for
providing support during an emergency. For example, the utility and local or state authorities
will need to determine:
   •   Who will respond?
   •   Who will sample?
   •   Who will perform analyses?
   •   Who will make public health decisions?
   •   Who will manage remediation and recovery activities?

The specific application of the RPTB as a planning tool is based on the particular function and
responsibility of the user in responding to a drinking water contamination threat. Figure O-2
illustrates several potential uses of the RPTB by various parties. Figure O-2 is not intended to
prescribe a  particular use, nor is it intended to be comprehensive. Rather, it is intended to
provide several examples and suggestions about how various users might apply the modules that
comprise the RPTB.
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                                                                Overview and Application
            Enviro. Chemistry Lab
            Develop analytical approach
            for unknown chemicals in
            water using Modules 1 and 4
            Small Utility
            Update ERP using
            Module 1
            Law Enforcement
            Review Modules 1 and 2 to
            appreciate public health
            mission of water systems.
            First Responders
          Large Utility
Response
 Protocol
 Toolbox
            Integrate sampling & screening
            procedures for water (Modules
            1-3) into existing protocols.
          Develop comprehensive plan
          for contamination threats using
          Modules 1-6
          -«=>
State Water Program
Develop comprehensive
response plan using
Modules 1-6
                                                      Public Health Agency
             Review Modules 2 and 5
             to understand public health
             response options available
             to a utility.
Figure O-2. Examples of the use of the Response Protocol Toolbox (RPTB) by various
interest groups.
3.2  Revising "Emergency Response Plans"
Information contained in the RPTB may be helpful in the revision of the utility's emergency
response plan (ERP), particularly for contamination threats.  It should be noted, however, that
there is no regulatory requirement to use the RPTB in the revision of the ERP. Guidance on the
preparation of ERPs is being prepared separately (EPA, "Drinking Water Model Emergency
Response Plan," in preparation). Some of the information from the RPTB that the utilities may
find useful in revising their ERPs are:
    •   The discussion of the nature of the contamination threats (Module 1).
    •   The framework and approach for managing contamination threats (Module 2).
    •   The procedures for characterizing a potential contamination site and collecting samples
       (Modules).
    •   A framework for developing an analytical approach for water samples potentially
       containing an unidentified contaminant (Module 4).
    •   The public health response  measures considered during and after an incident (Module 5).
    •   Steps in planning for remediation and recovery following a confirmed contamination
       incident (Module 6).

It is hoped that the RPTB will provide answers to the multitude of questions utilities may ask
when revising an ERP to encompass a contamination threat.
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                          Interim - December 2003

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                                                                Overview and Application


3.3  Developing "Response Guidelines"
Although not a formal part of an ERP, utilities may wish to develop Response Guidelines (RGs),
which are essentially a field guide for responding to contamination threats. Note that there is no
regulatory requirement to do this, but it may be a prudent step in preparing for a response to
contamination threats. RGs are discussed in Module 1, and a sample RGs outline is presented in
the appendix to Module 1. Development of RGs can be facilitated by extracting information
directly from RPTB, including: protocols, figures, tables, forms, etc. and integrating them into a
user's own RGs. In this manner, the RPTB can be customized to meet a user's specific needs
and responsibilities in responding to a contamination threat.


3.4  Other Applications of the RPTB
Several other types of guides could be crafted from material in the RPTB to meet the needs and
responsibilities of various parties, such as EPA, states, utilities, laboratories, and others. These
include, but  are not limited to, the following:

   •   Drinking Water Primacy Agency Response Guideline: These will be more generic than a
       utility RGs  and may help the primacy agency to fulfill various responsibilities, such as
       assisting smaller water utilities in responding to contamination threats.

   •   Small system guide: The needs and capabilities of small systems vary greatly. Some
       small systems may be capable of customizing the RPTB to their needs.  Others will need
       some authority, such as EPA or the drinking water primacy agency, to do this for them.

   •   Laboratory  Guide (LG) for laboratories:  Module 4 presents a general analytical guide
       developed from a national perspective. Laboratories may prepare a customized LG based
       on their local need, capabilities, and responsibilities.

   •   Emergency Responder Guide (ERG):  This guide is designed for responders that will help
       utilities, particularly with site characterization activities.  For example, responders may
       integrate the information and procedures from part of the RPTB, such as Module 3, into
       their existing procedures.

   •   Public Health Guide: Utilities may prepare a guide or fact sheet for their local public
       health department and water customers explaining the benefits  of various public health
       response actions. It should also briefly summarize relevant system operations (i.e.,
       ability to isolate certain components).

   •   Remediation and Recovery Guide: This utility document may detail the technical plan
       for returning the system to service under various contamination scenarios.

   •   Consumer Guide:  Not a technical document, this guide might be aimed at water
       customers to encourage them to prepare for situations in which there are temporary
       restrictions  on water usage.  This could be  a variation  on existing disaster preparation
       guides.
                                        13                          Interim - December 2003

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                                                              Overview and Application


•  Law Enforcement Guide:  This guide may explain to the law enforcement community
   relevant aspects of water utility operation and contamination response planning. This
   guide may facilitate coordination in planning and response to contamination threats.

•  Utility Coordination Guide: Larger water systems that supply water to smaller,
   independent water utilities may prepare a suitable guide for their smaller associates.
   Identifying these roles, capabilities and responsibilities may prove valuable to all parties
   in preparing a response to a contamination threat or incident.
                                     14                         Interim - December 2003

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Office of Ground Water and Drinking Water
Water Security Division
EPA817-D-03-007
www.epa.gov/safewater/security
December 2003
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on
   100% Postconsumer, Process Chlorine Free Recycled Paper

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