United States
   Environmental Protection
Response Protocol Toolbox:
Planning for and Responding to
Drinking Water Contamination
Threats and Incidents

Interim Final - December 2003

Module 1:
Water Utilities Planning Guide

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

     Module 1: Water Utilities Planning Guide
                  Interm Final - December 2003
                       Threat Warning
                     Initial Threat Evaluation
                     Immediate Operational
                      Response Actions
                    Site Characterization and
                    Public Health Response
                       Sample Analysis
                         Is Incident
                    Remediation and Recovery

                                       MODULE 1:  Water Utility Planning Guide


Module 1: Water Utility Planning Guide (December 2003)
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 prepare for response to contamination threats and incidents.

Module 2: Contamination Threat Management Guide (December 2003)
Module 2 presents the overarching framework for management of contamination
threats to the drinking water supply.  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.

Module 3: Site Characterization and Sampling Guide (December 2003)
Module 3 describes the site characterization process in which information is gathered
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.

Module 4: Analytical Guide (December 2003)
Module 4 presents an approach to the analysis of samples 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 that may contain an unknown contaminant.
The framework is flexible and will allow the approach to be crafted based on the
requirements of the specific situation. The framework is also designed to promote the
effective  and defensible performance of laboratory analysis.

Module 5: Public Health Response Guide (available March 2004)
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 among the utility, the drinking water primacy agency, the
public health community, and other parties with a public health mission.

Module 6: Remediation and Recovery Guide (available March 2004)
Module 6 describes the planning and implementation of remediation and recovery
activities that would be necessary following a confirmed contamination incident. The
remediation process involves a sequence of activities, including: system
characterization;  selection of remedy options; provision of an alternate drinking water
supply during remediation activities; and monitoring to demonstrate that the system
has been  remediated.  Module 6 describes the types of organizations that would likely
be involved in this stage of a response,  and the utility's role  during remediation and
                                                      Interim Final - December 2003

                                           MODULE 1: Water Utility Planning Guide
                             TABLE OF CONTENTS







    4.1.2     PERSONNEL	23
    4.1.3     CUSTOMERS	23



    6.2.2     FEDERAL RESPONSE PLAN	39
    6.3.2     EARLY WARNING SYSTEMS	43



          STAGES	31
                                                         Interim Final - December 2003

                                              MODULE 1: Water Utility Planning Guide


AWWARF   American Water Works Association Research Foundation
C/B          Chemical/Biological
CD          Compact disk
CDC         Centers for Disease Control and Prevention
DBF         Disinfection by-product
DHS         Department of Homeland Security
DOC         Department of Commerce
DOD         Department of Defense
DOE         Department of Energy
DOT         Department of the Interior
DOJ         Department of Justice
DOL         Department of Labor
DOS         Department of State
DOT         Department of Transportation
EPA         U.S. Environmental Protection Agency
ERP         Emergency response plans
ESF         Emergency support function
EWS         Early warning system
FBI          Federal Bureau of Investigation
FCO         Federal coordinating officer
FEMA       Federal Emergency Management Agency
FRP         Federal Response Plan
GIS          Geographic information system
GSA         Government services agency
HazMat      Hazardous materials
HHS         Department of Health and Human Services
1C           Incident commander
ICS          Incident Command System
ILSI         International Life Sciences Institute Risk Science Institute
IO           Information officer
JIC          Joint information center
JOC         Joint operations center
LFA         Lead federal agency
LO          Liaison officer
LPoC        Laboratory point of contact
LRN         Laboratory Response Network
NCP         National Oil and Hazardous Substances Pollution Contingency Plan
NIIMS       National Interagency Incident Management System
NIMS        National Incident Management System
NRC         Nuclear Regulatory Commission
NRP         National Response Plan
OSC         On-scene coordinator
FDD         Presidential decision directive
RG          Response guideline
                                                             Interim Final - December 2003

                                               MODULE 1: Water Utility Planning Guide
RPTB        Response Protocol Toolbox
RST         Regional support team
SCADA      Supervisory control and data acquisition
SDWA       Safe Drinking Water Act
TOC         Total organic carbon
URL         Uniform resource locator
USAGE      United States Army Corps of Engineers
USCG       United States Coast Guard
USDA       United States Department of Agriculture
UV          Ultraviolet
WCIT        Water contaminant information tool
WHO        World Health Organization
WUERM     Water utility emergency response manager
WUOCM     Water utility emergency operations center manager
                                                              Interim Final - December 2003

                                                 MODULE 1:  Water Utility Planning Guide


Definitions in this glossary are specific to the Response Protocol Tool Box but conform to
common usage as much as possible.

Agency - a division of government with a specific function, or a non-governmental organization
(e.g., private contractor, business, etc.) that offers a particular kind of assistance. In the incident
command system, agencies are defined as jurisdictional (having statutory responsibility for
incident mitigation) or assisting and/or cooperating (providing resources and/or assistance).

Agency Representative - an individual assigned to an incident from an assisting or cooperating
agency who has been delegated authority to make decisions on matters affecting that agency's
participation at the incident.

Assisting Agency - an agency directly contributing tactical or service resources to another

Bioterrorism Act - the Public Health Security and Bioterrorism Preparedness and Response Act

Chain of Command - a series of management positions in order of authority.

'Confirmatory' Stage - the third stage of the threat evaluation process from the point at which
the threat is deemed 'credible' through the determination that a contamination incident either has
or has not occurred.

'Confirmed' - in the context of the threat evaluation process, a water contamination incident is
'confirmed' if the information collected over the course of the threat evaluation provides
definitive evidence that the water has been contaminated.

Contamination Site - the location where a contaminant is known or suspected to have been
introduced into a drinking water system.  For example, a distribution system storage tank where
a security breach has occurred may be designated as  a suspected contamination site.  The
contamination site will likely be designated as an investigation site for the purpose of site

Cooperating Agency - an agency supplying assistance, other than direct tactical or support
functions, or resources to the incident control effort (e.g., Red Cross, telephone companies).

Coordination - the process of systematically analyzing a situation,  developing relevant
information, and informing the appropriate command authority of viable alternatives for
selection of the most effective combination of available resources to meet specific objectives.
The coordination process (which can  be either intra- or inter-agency) does not involve dispatch
actions. However, personnel responsible for coordination may perform command or dispatch
functions within the limits established by specific agency delegations, procedures, legal
authority, etc.
                                                                Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide
'Credible' - in the context of the threat evaluation process, a water contamination threat is
characterized as 'credible' if information collected during the threat evaluation process
corroborates information from the threat warning.

'Credible' Stage - the second stage of the threat management process from the point at which
the threat is deemed 'possible' through the determination as to whether or not the threat is

Drinking Water Primacy Agency - the agency that has primary enforcement responsibility for
national drinking water regulations, namely, the Safe Drinking Water Act as amended.  Drinking
water primacy for a particular state may reside in one of a variety of agencies, such as health
departments, environmental quality departments, etc. The drinking water primacy agency is
typically the State Health Agency or the State Environmental Agency. The drinking water
primacy agency may also play the role of technical assistance provider to drinking water

Emergency Operations Center - a pre-designated facility established by an agency or
jurisdiction to coordinate the overall agency or jurisdictional response and support to an

Emergency Response Plan - a document that describes the  actions that a drinking water utility
would take in response to various emergencies, disasters, and other unexpected incidents.

Event - a planned, non-emergency activity (e.g., parades, concerts, sporting events, etc.).

Immediate Operational Response - an action taken in response to a 'possible' contamination
threat in an attempt to minimize the potential for exposure to the potentially contaminated water.
Immediate  operational response actions will generally have a negligible impact on consumers.

Incident - a confirmed occurrence that requires response actions to prevent or minimize loss of
life or damage to property and/or natural resources.  A drinking water contamination incident
occurs when the presence of a harmful contaminant has been confirmed.

Incident Command System - a standardized on-scene emergency management concept
specifically designed to allow its user(s) to adopt an integrated organizational structure
appropriate for the complexity and demands of single or multiple incidents, without being
hindered by jurisdictional boundaries.

Incident Commander - the individual responsible for the management of all incident

Incident Objectives - statements of guidance and direction necessary for the selection of
appropriate strategy(ies), and the tactical direction of resources.  Incident objectives are based on
realistic expectations of what can be accomplished when all allocated resources have been
                                                                Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide

effectively deployed. Incident objectives must be achievable and  measurable, yet flexible
enough to allow for strategic and tactical alternatives.

Information Officer - the individual responsible for interfacing with the public and media or
with other agencies requiring information directly from the incident.  Under the ICS, there is
only one Information Officer per incident.

Investigation Site - the location where site characterization activities are performed. If a
suspected contamination site has been identified, it will likely be designated as a primary
investigation site.  Additional or secondary investigation sites may also be identified due to the
potential spread of a contaminant.

Jurisdiction - the range or sphere of authority.  Public agencies have jurisdiction at an incident
related to their legal responsibilities and authority for incident mitigation. Jurisdictional
authority at an incident can be political/geographic (e.g., city, county, State, or Federal boundary
lines) or functional (e.g., police department, health department,  etc.).

Multi-jurisdiction Incident - an incident requiring action from multiple agencies that have a
statutory responsibility for incident mitigation. In ICS, these incidents will be managed under
Unified Command.

National Interagency Incident Management System - a program developed by the National
Wildfire Coordinating Group consisting of five major subsystems which collectively provide a
total systems approach to all-risk incident management. The subsystems are the Incident
Command System, Training, Qualifications and Certification, Supporting Technologies, and
Publications Management.

Notification - the process of communication information to interested parties.

Opportunity Contaminant - contaminants that might be readily  available in a particular area,
even though they may not be highly toxic or infectious or easily dispersed and stable in treated
drinking water.

'Possible' - in the context of the threat evaluation process, a water contamination threat is
characterized as 'possible' if the circumstances of the threat warning appear to have provided an
opportunity for contamination.

'Possible' Stage - the first stage of the threat management process from the point at which the
threat warning is received through the determination as to whether or not the threat is 'possible.'

Quality Assurance - an integrated system of management activities  involving planning,
implementation, documentation, assessment, reporting, and quality improvement, to ensure that a
process, item, or service is of the type and quality needed and expected by the client.

Quality Control  - the overall system of technical activities that measures the attributes and
performance of a process, item, or service against defined  standards to verify that they meet the
                                                                Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide

stated requirements established by the client; operational techniques and activities that are used
to fulfill requirements for quality.

Response Guidelines - a manual designed to be used during the  response to a water
contamination threat.  Response Guidelines should be easy to use  and contain forms, flow charts,
and simple instructions to support staff in the field or decision officials in the Emergency
Operations Center during management of a crisis.

Secure Area - a locked space, such as a cabinet or vault, with access restricted to authorized

Site Characterization - the process of collecting information from an investigation site in order
to support the evaluation of a drinking water contamination threat. Site characterization
activities include the site investigation, field safety screening, rapid field testing of the water, and
sample collection.

Technical Assistance Provider - any organization or individual that provides assistance to
drinking water utilities in meeting their mission to provide an adequate and safe supply of water
to their customers. The drinking water primacy agency may serve as a technical assistance

Threat - an indication that a harmful incident, such as contamination of the drinking water
supply, may have occurred.  The threat may be direct, such as a verbal or written threat, or
circumstantial, such as a security breach  or unusual water quality.

Threat Evaluation - part of the threat management process in which all available and relevant
information about the threat is  evaluated to determine if the threat is 'possible' or 'credible', or if
a contamination incident has been 'confirmed.'  This is an iterative process in which the threat
evaluation is revised  as additional information becomes available.  The conclusions from the
threat evaluation are considered when making response decisions.

Threat Management - the process of evaluating a contamination threat and making decisions
about appropriate response actions.  The threat management process includes the parallel
activities of the threat evaluation and making response decisions.  The threat management
process is considered in three stages: 'possible', 'credible', and  'confirmatory.'  The severity of
the threat and the magnitude of the  response decisions escalate as  a threat progresses through
these stages.

Threat Warning - an unusual occurrence, observation, or discovery that indicates a potential
contamination incident and initiates actions to address this concern.

Unified Command - a unified team effort which allows all agencies with responsibility for the
incident, either geographic or functional, to manage an incident by establishing a common set of
incident objectives and strategies. This is accomplished without losing or abdicating agency
authority, responsibility, or accountability.
                                                                Interim Final - December 2003

                                                MODULE 1: Water Utility Planning Guide

Unity of Command - the concept by which each person within an organization reports to only
one designated person.

Vulnerability Assessment - a systematic process for evaluating the susceptibility of critical
facilities to potential threats and identifying corrective actions that can reduce or mitigate the risk
of serious consequences associated with these threats.

Water Contamination Incident - a situation in which a contaminant has been successfully
introduced into the system.  A water contamination incident may or may not be preceded by a
water contamination threat

Water Contamination Threat - a situation in which the introduction of a contaminant into the
water system is threatened, claimed, or suggested by evidence. Compare water contamination
threat with water contamination incident. Note that threatening a water system may be a crime
under the Safe Drinking Water Act as amended by the Bioterrorism Act.

Water Utility Emergency Operations Center Manager - the individual responsible for
carrying out the plan for emergency operations at the water utility during an emergency incident.

Water Utility Emergency Response Manager (WUERM) - the individual(s) within the
drinking water utility management structure that has the responsibility and authority for
managing certain aspects of the utility's response to an emergency (e.g., a contamination threat)
particularly during the initial stages of the response. The responsibilities and authority of the
WUERM are defined by utility management and will likely vary based on the circumstances of a
specific utility.
                                        10                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

1    Introduction: Why Should I  Read this Module?

The primary audience for this module is drinking water utilities, which need to plan for and
practice managing and responding to contamination attacks.  However, there are many other
groups that may be involved in responding to water contamination threats and incidents, and
they also may benefit from reviewing this module to assist in their planning activities.  These
groups include analytical laboratories, emergency responders, state drinking water primacy
agencies., technical assistance providers, public health officials, federal agencies (including
EPA), and law enforcement agencies, among others. The objectives of this module are:
   •   To familiarize the reader with the nature and warning signs  of water contamination
       threats and incidents.  The reader will learn that drinking water contamination incidents
       are possible and that contamination threats are probable.
   •   To describe the overall framework for responding to a range of contamination threats,
       ranging from hoaxes to confirmed contamination incidents.  This framework, the primary
       focus of the Response Protocol Toolbox (RPTB), is one of the highest water security
       priorities identified by the water sector and the EPA.
   •   To help readers prepare for responding to contamination threats through: 1) Careful
       planning; 2) Development of Response Guidelines; 3) Establishing notification
       procedures and internal chain of command, and 4) Performing training exercises.

This module is organized into five sections as described below.
       Section 1:     Introduction: describes the objectives and overall organization of this

       Section 2:     What are Contamination Threats and Incidents? Provides background
                    information on the contamination threat to water systems, including a
                    discussion of potential warning signs of contamination.

       SectionS:     How Should I Respond to Water Contamination Threats?  Discusses
                    the need for response and introduces the concept of 'due diligence' in
                    responding to contamination threats.

       Section 4:     What Can I do to Prepare? Highlights several areas in which utilities
                    can enhance their preparedness for contamination threats.

       Section 5:     References and Resources: Lists the references used in the
                    development of this module as well as additional information resources.

       Section 6:     Appendices:  Provides a sample outline for utility Response Guidelines,
                    describes the roles of federal agencies under  two U.S. government
                    response plans, and provides an overview of drinking water security
                    applications for on-line monitoring systems.
Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

2   What are Contamination Threats and Incidents?

2.1   Overview of Contamination Threats and Incidents
Both water contamination threats and water contamination incidents could be designed to
interrupt the delivery of safe water to a population, interrupt fire protection, create public
panic, or cause disease or death in a population.  A water contamination threat occurs when
the introduction of a contaminant into the water system is threatened, claimed, or suggested
by evidence. A water contamination incident occurs when a contaminant is successfully
introduced into the water supply.  The water contamination incident may be preceded by a
threat, but not always. Both water contamination threats  and incidents may be of particular
concern due to the range of potential consequences:
   •   Creating an adverse impact on public health within a population.
   •   Disrupting system operations and interrupting the supply of safe water.
   •   Causing physical damage to system infrastructure.
   •   Reducing public confidence in the water supply.
   •   Long-term denial of water and the cost of remediation and replacement.

Some of these consequences would only be realized in the event of a successful contamination
incident; however, the mere threat of contamination can have  an adverse impact on a water
system if improperly handled.

In characterizing any threat, both the possibility and probability should be considered. A
general assessment of the threat of intentional contamination of drinking water indicates that it
is possible to cause varying degrees of harm by contaminating a water system. Specifically,
this assessment indicates that:
   •   Only a few contaminants have the potential to produce widespread death or disease in
       a population.  These contaminants include concentrated pathogens, biotoxins, and a
       few highly toxic chemicals that may remain stable in water long enough to adversely
       impact public health.
   •   A larger group of contaminants could produce localized death or disease in a segment
       of a population, including several dozen toxic chemicals.
   •   Hundreds of contaminants could potentially disrupt service or undermine consumer
       confidence but would not result in death or disease in the population.

While it is important to consider the range of possibilities associated with a particular threat,
assessments are typically based on the probability of a particular occurrence.  Determining
probability is somewhat subjective, and is often based on intelligence and previous incidents.
There are historical accounts of intentional contamination of drinking water supplies with
biological  or chemical contaminants, but most have been associated with wartime activities
(http://www.who.int/emc/pdfs/BIOWEAPONS FULL TEXT2.pdf).  The few documented
accounts of intentional contamination of public water systems in the U.S. have not resulted in
any reported fatalities. The American Water Works Association Research Foundation
(AWWARF) is preparing a report on this subject (AWWARF, 2003). Based on these
accounts, it would appear that the probability of a successful contamination incident on a
drinking water system is relatively low.  However, there has been a reported increase in the
interest of various terrorist  groups in biological and chemical weapons.  Furthermore, some
                                       12                      Interim Final - December 2003

                                                  MODULE 1: Water Utility Planning Guide

intelligence information indicates that terrorist organizations have considered water
infrastructure as a possible target.  Thus, the potential for such an incident does exist.

While the probability of an actual contamination incident may be considered low relative to
other modes of attack, the probability of the threat of contamination may be relatively high
compared to other forms of attack. Many of the apparent security breaches at drinking water
utilities that have occurred since 9/11 have been perceived as potential contamination
incidents. Although a few threats have been verbal, most have been circumstantial, such as a
low-flying airplane over a reservoir or a lock cut from the hatch of a distribution system
storage tank. Given the possibility of contamination, many utilities chose to treat these
security breaches as potential contamination threats.  These incidents demonstrate the need for
a protocol to guide an appropriate response to contamination threats.

In order to prepare for contamination threats, there is a general sense that it is necessary to
generate a list of priority contaminants.  However, the generation of such a list is a significant
challenge due to the wide range of adverse effects that might result from intentional
contamination, as discussed at the beginning of this section.  Furthermore, no list of
contamination threats should be considered definitive or complete. A document prepared under
the auspices of the World Health Organization succinctly sums up this dilemma, and places it in
the context of planning for a response to a biological or chemical contamination incident:

    "A  central  consideration in such preparedness planning is that it is neither possible
    nor necessary to specifically plan for attack  by all possible biological and chemical
    agents.  If a country is seeking to increase its preparedness to counter the effects of
    biological and chemical attacks, the  targeting of its preparation and training on a
    limited but well  chosen group of agents will  provide the necessary capability  to deal
    with a far wider range of possibilities.  Knowledge of the general properties of this
    representative  group  of agents  will  enable  certain  measures to be taken  against
    virtually any other agent.  In addition  to being  impractical from  a preparedness
    perspective, long and exhaustive lists of agents also give  a misleading impression of
    the extent of possible threats."
          In: Public health response to biological and chemical weapons: WHO guidance, 2nd edition
    (Draft, March 2003), (http://www.who.int/csr/delibepidemics/biochemguide/en/index.html')

Nonetheless, many federal and private organizations have generated contaminant lists that
reflect the specific priorities and assumptions of that organization. For instance, the military
is largely concerned with safeguarding the readiness of our combat troops and hence focuses
on the classical weapons of chemical and biological warfare, while other organizations are
more focused on infectious diseases. While it is possible to use the experience gained from
the preparation of these lists, it is very important to consider the special needs and challenges
presented by safeguarding public health through protection of the drinking water supply. For
instance, there is essentially no tolerance by the public toward sudden disease and death from
tainted water supplies. Another challenge is that drinking water is used not only for
consumption but also for other uses such as fire protection, sanitation, and industrial
processes.  In fact, most treated drinking water is  used for purposes other than consumption.
                                         13                       Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide
Table 1-1 presents a number of contaminant classes that would potentially have an adverse
impact if introduced into the drinking water supply. This is not intended to be an exhaustive
list, and there may be many others that may be used to contaminate a water supply.

Table 1-1 Contaminant Classes, their Availabilities, and Restrictions
Examples (not exhaustive)
Limited access?
Bacillus anthracis, Brucella spp., Burkholderia spp.,
Campylobacterspp., Clostridium perfringens, E. coli
O157:H7, Francisella tularensis, Salmonella typhi,
Shigella spp., Vibrio cholerae, Yersinia pestis, Yersinia
Caliciviruses, Enteroviruses, Hepatitis A/E, Variola,
VEE virus
Cryptosporidium parvum, Entamoeba histolytica,
Toxoplasma gondii
Naturally occurring,
laboratories1, state- sponsored
Naturally occurring,
laboratories1, state- sponsored
Naturally occurring,
Microbiological laboratories1
Yes for Select
Yes for Select
Corrosives and
Cyanide salts or
oxyanions, organo-
Toilet bowl cleaners (hydrochloric acid), tree-root
dissolver (sulfuric acid), drain cleaner (sodium
Sodium cyanide, potassium cyanide, amygdalin,
cyanogen chloride, ferricyanide salts
Mercury, lead, osmium, their salts, organic compounds,
and complexes (even those of iron, cobalt, copper are
toxic at high doses)
Arsenate, arsenite, selenite salts, organoarsenic,
organoselenium compounds
Retail, industry
Supplier, industry (esp.
Industry, supplier, laboratory
Some retail, industry,
supplier, laboratory
Hydrocarbons and
their oxygenated
and/or halogenated
noxious, foul-
tasting, and/or
Water-mi scible
Sodium trifluoroacetate (a rat poison), fluoroalcohols,
fluorinated surfactants
Paint thinners, gasoline, kerosene, ketones (e.g., methyl
isobutyl ketone), alcohols (e.g., methanol), ethers (e.g.,
methyl ferf-butyl ether or MTBE), halohydrocarbons
(e.g., dichloromethane, tetrachloroethene)
Organophosphates (e.g., Malathion), chlorinated
organics (e.g., DDT), carbamates (e.g., Aldicarb) some
alkaloids (e.g., nicotine)
Thiols (e.g., mercaptoacetic acid, mercaptoethanol),
amines (e.g., cadaverine, putrescine), inorganic esters
(e.g., trimethylphosphite, dimethylsulfate, acrolein)
Acetone, methanol, ethylene glycol (antifreeze),
phenols, detergents
Supplier, industry, laboratory
Retail, industry, laboratory,
Retail, industry, supplier
(varies with compound)
Laboratory, supplier, police
supply, military depot
Retail, industry, supplier,
Interim Final - December 2003

                                                        MODULE 1:  Water Utility Planning Guide
Pesticides other
than insecticides
Examples (not exhaustive)
Herbicides (e.g., chlorophenoxy or atrazine derivatives),
rodenticides (e.g., superwarfarins, zinc phosphide, a-
naphthyl thiourea)
cardiac glycosides, some alkaloids (e.g., vincristine),
antineoplastic chemotherapies (e.g., aminopterin),
anticoagulants (e.g., warfarin). Includes illicit drugs
such as LSD, PCP, and heroin.
Retail, industry, agriculture,
Laboratory, supplier,
pharmacy, some from a
natural source
Limited access?
Schedule 1
Chemical Weapons
organophosphate nerve agents (e.g., sarin, tabun, VX),
vesicants, [nitrogen and sulfur mustards (chlorinated
alkyl amines and thioethers, respectively)], Lewisite
Suppliers, military depots,
some laboratories
produced toxins
Biotoxins from bacteria, plants, fungi, protists, defensive
poisons in some marine or terrestrial animals. Examples
include ricin, saxitoxin, botulinum toxins, T-2
mycotoxins, microcystins.
Laboratory, supplier,
pharmacy, natural source5,
state- sponsored programs
Does not refer to nuclear, thermonuclear, or neutron
bombs. Radionuclides may be used in medical devices
and industrial irradiators (Cesium- 137 Iridium-192,
Cobalt-60, Strontium-90). Class includes both the
metals and salts.
Laboratory, state sources,
waste facilities
1. The quantity of bacteria, viruses, or parasites needed for widespread contamination of a water system is not available in a
typical clinical laboratory, although the seed cultures could be available. For viruses, vaccine production-grade volumes would
be needed, requiring special equipment and facilities, perhaps with state-sponsorship.
2. Availability may be commercially limited for the more toxic metals, especially the heavy metals, which can be quite
expensive. Iron and copper are readily available, but not usually in soluble (bio-available) forms.
3. Availability of arsenicals and selenium compounds in the retail sector has been reduced owing to environmental regulations,
but such products can occasionally be found as part of older inventories of merchandise, especially in small-town hardware
stores. Supplies of such materials may generally be too small to cause concern.
4. This grouping includes riot-control agents and other mucous membrane irritants.
5. The quantity available from laboratories, suppliers, and pharmacies needed for widespread contamination of a water system
are typically not available from these sources. Many biotoxins that occur naturally would need to be purified or prepared to be of
significant concern to water, which could make production beyond the capabilities of most terrorists.

The specific contaminants in Table 1-1  do not directly correspond to the highest priority
contaminants; the table is merely illustrative of the relevant contaminant  classes.  The list of high
priority contaminants was used to inform  the development of the material in the RPTB
(particularly Module 4).  The list of high priority  contaminants is not included in the RPTB for
two reasons.  First, as discussed above,  such lists are inherently incomplete and hence may
provide a false sense of security. Second, such a  list could be used with malicious intent if
included in a widely circulated document. Accordingly, to support emergency management of
water threats and incidents, a resource for contaminant specific  information, the Water
Contaminant Information Tool (WCIT), is being developed specifically for use by the water
sector. The WCIT, along with related information resources, is described in more detail in
Module 2,  Appendix 8.9.
Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide

In reviewing the contaminant classes listed in Table 1-1, it may be apparent that many are not
tightly controlled and are considered to be readily available. Most threat analysts consider
availability to be the most important characteristic of a contaminant that might be used in a
terrorist or criminal activity. The phrase opportunity contaminant has been used to describe
contaminants that might be readily available even though they may be considered less than
optimal from a lethality or dissemination standpoint. In many cases, specific opportunity
contaminants may be more readily available on a regional or local basis. For example, a
particular industrial chemical or pesticide may be produced at a facility in close proximity to the
water treatment plant and its associated distribution system.  Such site specific considerations
should be incorporated into a utility's planning and response activities, particularly with
regards to threat management (Module 2) and analytical approach (Module 4).

In addition to availability, there are other factors that should be considered to better understand
the contamination threat to water. Therefore, a broad group of potential contaminants, similar to
those contained in Table 1-1, were prioritized with respect to  their ability to adversely impact
public health. The criteria used to prioritize the contaminants are described in Table 1-2.  This
prioritization was not intended to be comprehensive for all potential threats to water, but rather to
be inclusive of contaminant classes that warrant consideration during the evaluation of a
contamination threat or the analysis of a water sample for an unknown contaminant.

Table 1-2. Prioritization Criteria for Potential Water Contaminants
Aesthetic impacts
Chlorine resistance
Handling difficulty
Outcome of exposure
Public fear factor
Changes in appearance, odor, or taste of contaminated water that might alert a consumer to
the potential danger.
The ease with which the material can be obtained, synthesized, or harvested from natural
The time that a contaminant remains toxic or infectious after introduction into water
containing a chlorine residual under typical distribution system conditions.
The ease with which a contaminant can be effectively dispersed in water.
The technical challenges associated with handling the material and introducing it into water.
The health effects within the population resulting from exposure to the contaminant.
The amount of contaminant that would be required to contaminate a reference volume of
water at a lethal or infectious dose. The smaller the amount of material, the higher the rank.
Perception of the public regarding the risks associated with the contaminant.
The time that a contaminant remains toxic or infectious after introduction into an aqueous
The time that a contaminant remains toxic or infectious while in storage.
2.2   Warnings Signs of a Contamination Threat
A threat warning is an occurrence or discovery that indicates a potential contamination threat
that triggers an evaluation of the threat. The use of information about a threat warning during the
initial stage of the threat evaluation process is described in more detail in Module 2. It is
important to note that these warnings must be evaluated in the context of typical utility activity
and previous experience in order to avoid false alarms. Figure 1-1 summarizes several potential
threat warnings.
                                        16                       Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide
Figure 1-1. Summary of Threat Warnings

The threat warnings shown in this figure are intended to be inclusive of those most likely to be
encountered, but this listing is by no means comprehensive. Following is a brief description of
each of these warnings.  A thorough discussion of these warnings is provided in Module 2.

   >  Security Breach. Physical security breaches, such as unsecured doors, open hatches, and
       unlocked/forced gates, are probably the most common threat warnings. In most cases,
       the security breach is likely related to lax operations or typical criminal activity such as
       trespassing, vandalism, and theft rather than intentional contamination of the water.
       However, it may be prudent to assess any security breach with respect to the possibility
       of contamination.

   >  Witness Account. Awareness of an incident may be triggered by a witness account of
       suspicious activity, such as trespassing, breaking and entering, and other types of
       tampering. Utilities should be aware that individuals observing suspicious behavior near
       drinking water facilities will likely call 911 and not the water utility.  In this case, the
       incident warning technically might come from law enforcement, as described below.
       Note: the witness may be a utility employee engaged in their normal duties.

   >  Direct Notification by Perpetrator.  A threat may be made directly to the water utility,
       either verbally or in writing. Historical incidents would indicate that verbal threats made
       over the phone are more likely than written threats.  While the notification may be a
       hoax, threatening a drinking water system may be a crime under the Safe Drinking Water
       Act as amended by the Bioterrorism Act, and should be taken seriously.

   >  Notification by Law Enforcement.  A utility may receive notification about a
       contamination threat directly from law enforcement, including local, county, state, or
       federal agencies. As discussed previously, such a threat could be a result of suspicious
       activity reported to law enforcement, either by a perpetrator, a witness, or the news
       media.  Other information, gathered through intelligence or informants, could also lead
       law enforcement to conclude that there may be a threat to the water supply. While law
       enforcement will have the lead in the criminal investigation, the utility has primary
Interim Final - December 2003

                                             MODULE 1: Water Utility Planning Guide

   responsibility for the safety of the water supply and public health. Thus, the utility's role
   will likely be to help law enforcement to appreciate the public health implications of a
   particular threat as well as the technical feasibility of carrying out a particular threat.

>  Notification by News Media. A threat to contaminate the water supply might be
   delivered to the news media, or the media may discover a threat. A conscientious
   reporter would immediately report such a threat to the police, and either the reporter or
   the police would immediately contact the water utility. This level of professionalism
   would provide an opportunity for the utility to work with the media and law enforcement
   to assess the credibility of the threat before any broader notification is made.

>  Unusual  Water Quality Parameters.  The relationship between contamination and changes
   in water  quality parameters is not well understood.  However, it is appropriate to
   investigate the cause of unusual changes in water quality parameters.  For water systems,
   changes in  water quality parameters, such as pH, chlorine residual, turbidity, etc. may be
   detected  through the use of either on-line monitors or grab samples. In utility operations,
   this data  may arise from several sources: samples collected for plant operations, routine
   baseline  monitoring programs (Section 4.9), and monitoring systems designed to provide
   early warning of changes in water quality (Section 6.2). The results of these approaches
   may be used to warn of a threat.  However, as discussed in Sections 4.9 and 4.10, it is
   vital to consider the reliability of the results from the particular detection method or on-
   line monitoring system (i.e., false positives/false negatives, known interferences,
   instrument reliability, and unusual water quality conditions associated with a known
   cause, such as overdosing of coagulant).

>  Consumer Complaint.  An unexplained or unusually high incidence of consumer
   complaints about the aesthetic qualities of drinking water may indicate potential
   contamination. Many chemicals can impart a strong odor or taste to water, and some
   may discolor the water. Taste and odor complaints are quite common for water utilities,
   but unique  taste and odor problems, particularly very unusual tastes and odor complaints
   clustered in a geographical area, may indicate additional problems.

>  Public Health Notification. In this case, the first indication that contamination has
   occurred is the appearance of victims in local emergency rooms and health clinics.
   Utilities may therefore be notified, particularly if the cause is unknown or linked to water.
   An incident triggered by a public health notification is unique in that at least a segment of
   the population has been exposed to a harmful substance.  If this agent is a chemical
   (including biotoxins), then the time between exposure and onset of symptoms may be on
   the order of hours, and thus there is the potential that the contaminant is still present.  On
   the other hand, the incubation period for most pathogens is on the order of days to weeks;
   thus, the  pathogen may have moved through the distribution system and may therefore be
   below detectable limits, or present only in trace quantities.
                                     18                       Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

3   How should I Respond to Water Contamination Threats?

This section is not designed to discuss what specific steps to take in responding to a
contamination threat. Various "What to do?" steps in the response process will be discussed in
Section 4 and associated modules. Rather, the questions addressed in this section are "Why is it
necessary to respond to contamination threats at all?" and "When have I done enough?"
3.1  I'm Just a Utility—Why Do I Need to do Anything at All?
As discussed in Section 2, it is technically possible to introduce a contaminant into a public
water supply, and historical evidence suggests that the threat of contamination is indeed
probable. Regardless of whether contamination is actual or threatened, both deeply impact the
public health mission of water utilities. Water utilities play an essential role in providing safe
and reliable drinking water supplies, preventing many problems and diseasees that flourish in the
absence of safe water programs. Most water utilities take their public health mission very
seriously, and some are proactive in developing their plans to respond to water contamination
threats.  They do this often because they realize that planning for contamination events may also
be beneficial in developing a more effective response to other types of emergencies.

Proper planning is a delicate process because public health measures are rarely noticed or
appreciated except when they fail.  Consumers are particularly upset by unsafe water because
safe drinking water is often viewed as an entitlement, and indeed, it is reasonable for consumers
to expect a high quality product. Public health failures during response to contamination threats
often take the form of too much or too little  action. The results of too little action, including no
response at all, can have disastrous consequences potentially resulting in public disease or
fatalities. On the other hand, a disproportionate response to contamination threats that have not
been corroborated (i.e., determined to be 'credible') can also have serious repercussions when
otherwise safe water is unavailable. Not only would the water be unavailable for human
consumption, but it would also be unavailable for sanitation, firefighting, industry, and the many
other uses of public water supply.  These adverse impacts must be considered when evaluating
response options to a contamination threat.

Considering the potential risks  of an inappropriate response to a contamination threat, it is clear
that a systematic approach is needed to evaluate contamination threats.  This systematic approach
is developed throughout the RPTB. One overriding question is "When  has a drinking water
utility done enough?"  This question may be  particularly difficult to address when considering
the wide range of agencies that may be involved in a threat situation. Other organizations, such
as EPA, CDC, law enforcement agencies, health departments, etc., will each have unique
obligations or interests in responding to a contamination threat.
3.2  Due Diligence—When Have I Done Enough?
The guiding principle for responding to contamination threats is one of 'due diligence' or "what
is a suitable and sensible response to a contamination threat?"  As discussed above, some
response to contamination threats is warranted due to the public health implications of an actual
contamination incident. However, a utility could spend a lot of time and money over-responding
                                        19                      Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide

to every contamination threat, which would be an ineffective use of resources. Furthermore,
over-response to a contamination threat carries its own adverse impacts.

Ultimately, the answer to the question of 'due diligence' must be decided at the local level and
will depend on a number of considerations. Among other factors, local authorities must decide
what level of risk is reasonable in the context of a perceived threat. Careful planning is essential
to developing an appropriate response to contamination threats, and in fact, one primary
objective of the RPTB is to aid users in the development of their own site-specific plans that are
consistent with the needs and responsibilities of the user.  Beyond planning, the RPTB considers
a careful evaluation of any contamination threat, and an appropriate response based on the
evaluation, to be the most important element of due diligence.

Figure 1-2 provides an overview of the response process presented in the RPTB that illustrates
(through the two expanding vertical arrows) that response actions escalate as the credibility of a
threat increases.  In the RPTB, the threat management process is considered in three successive
stages: 'possible',  'credible'., and 'confirmed'. Thus, as the threat escalates through these three
stages, the actions that might be considered due diligence expand accordingly. The following
paragraphs describe, in general terms, actions that might be considered as due diligence at these
various stages. Module 2 describes the evaluation of these stages, and associated response
actions that might be considered at each stage.

   >  Stage 1: "Is the threat possible?" If a utility is faced with a contamination threat, they
       should evaluate the available information to determine whether or not the threat is
       'possible' (i.e., could something have actually happened). If the threat is 'possible,'
       immediate operational response actions might be implemented, and activities such as site
       characterization would be initiated to collect additional information to support the next
       stage of the threat evaluation.

   >  Stage 2: "Is the threat credible?" Once a threat is considered  'possible,' additional
       information will be necessary to determine if the threat is 'credible.' The threshold at the
       credible stage is  higher than that at the possible stage, and in general there must be
       information to corroborate the threat in order for it to be considered 'credible.' Given the
       higher threshold at this stage, more significant response actions might be considered,
       such as restrictions on public use of the water (e.g., issuance of a 'do not drink' notice).
       Furthermore, steps should be initiated to confirm the incident and positively identify the

   >  Stage 3: "Has the incident been confirmed?" Confirmation implies that definitive
       evidence and information have been collected to establish the presence of a harmful
       contaminant in the drinking water.  Obviously, at this stage the concept of due diligence
       takes on a whole new meaning since authorities are now faced with a potential public
       health crisis. Response actions at this point include all steps necessary to protect public
       health, to supply the public with an alternate source of drinking water, and to begin
       remediation of the system.
                                        20                       Interim Final - December 2003

                                                  MODULE 1:  Water Utility Planning Guide
                                    PLANNING AND PREPARATION
                                        Incident Warning
                                        Initial Notifications
                                      Preliminary Assessment
                                      Precautionary Response
                                      Site Characterization and
                                      Public Health Response
                                        Sample Analysis
                                     Remediation and Recovery
Figure 1-2. Overview of Response to a Contamination Threat
If the process outlined in Figure 1-2 is followed as far as the situation warrants, and the
responsible parties use it as a guide in making appropriate response decisions, then they may be
viewed as exercising 'due diligence.' All the modules of the RPTB contain in-depth information
about the application of the process. In particular, Module 2 describes threat management and
the three stages of the threat evaluation in great detail. The application of this process to a
specific contamination threat will vary significantly with the circumstances of the threat.
In summary, judgment must be exercised when determining how to appropriately manage a
specific contamination threat.  Tabletop exercises, described below in Section 4.7, may provide
valuable practice in this regard.
Interim Final - December 2003

                                                MODULE 1: Water Utility Planning Guide
4   What Can I do to Prepare?
One of the steps that utilities can take to prepare for contamination threats is to read relevant
modules of the "Response Protocol Toolbox" and use the information contained within to
develop their own specific Response Guidelines and updated Emergency Response Plans!
Specific planning and preparation activities are summarized in the following subsections.
4.1  Know your Water System

4.1.1  Construction and Operation
Each water system is unique with respect to age, operation, and complexity.  Distribution
systems are particularly unique in that many are a complex, and often undocumented, mix of
relatively new and old components. Accordingly, understanding a distribution system as it
relates to water security and response planning may be an equally complex task. Despite the
challenges to understanding a water supply system, the benefits of doing so could include
effectively managing threats and preventing the spread of potentially contaminated water. For
instance, the water system may have structural features that enable effective isolation of a
contaminated area. Also, it may be readily apparent from knowledge of system vulnerabilities
that it would be very easy to introduce a contaminant at a particular location.

There are many ways to gain a better understanding of a particular water system, one of which is
through a vulnerability assessment. Perpetrators who intentionally contaminate water may seek
to produce an adverse  consequence through exploitation of vulnerabilities. All drinking water
plants are, to some degree, vulnerable to intentional contamination incidents.  The nature and
extent of these vulnerabilities depends on a number of factors such as source water type,
treatment plant type, type of primary disinfectant used, residual disinfectant used in the
distribution system,  and security measures already in place.  An assessment of the  drinking water
plant and system may help to identify key locations that are vulnerable to intentional
contamination, or the availability of opportunity contaminants that might be prevalent in the
area. Better understanding the vulnerabilities of a water system provide a basis for improving
physical security against intentional contamination  and preparing for the evaluation of
contamination threats. Accordingly, the Bioterrorism Act established requirements that
community water systems serving more than 3,300  individuals perform a system specific
vulnerability assessment for potential terrorist threats, including intentional contamination
(http ://www. epa. gov/safewater/security/community. html).

Another aspect of the water system that may be important, particularly in evaluating the potential
spread of a suspected contaminant, is its hydraulic configuration and operation.  Propagation of a
contaminant through a system is dependent on a number of factors, including: mixing conditions
at the point of contamination, hydraulic conditions within the system at the time of the
contaminant introduction, and reactions between the contaminant and other materials in the
system.  There are several techniques for understanding the hydraulics of a water supply system.
As discussed more completely in Module 2, Section 2.3.1, developing this understanding may be
as complex as utilizing a GIS system in conjunction with a hydraulic modeling program or as
simple as manually mapping the pressure and flow  zones within a system.
                                        22                       Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide
Information about construction materials used in the system may be contained within the utility
records and can be useful in evaluating the fate and transport of a particular contaminant through
a system.  For example, a particular contaminant may adsorb to the pipe material used in a
utility's distribution system, and this type of information would be critical in evaluating
remediation options following a contamination incident (see Module 6).
4.1.2  Personnel
The employees of a water utility are generally its most valuable asset in preparing for and
responding to water contamination threats and incidents.  They have knowledge of the system
and water quality, and may also have experience in dealing with previous contamination threats.
The importance of knowledgeable and experienced personnel is highlighted by the complexity of
most water treatment and distribution systems.  This complexity makes a successful
contamination of a specific target contingent upon detailed knowledge of the system
configuration,  hydraulic conditions, usage patterns, and water quality.  If perpetrators have
somehow gained a sophisticated understanding  of a water supply system, the day-to-day
experience of water system personnel will prove an invaluable tool to countering any attacks.
For instance, personnel may continually look for unusual aspects of daily operation that might be
interpreted as a potential threat warning, and may also be aware of specific characteristics of the
system that make it vulnerable to contamination.

4.1.3  Customers
Knowledge of water system customers is an important component of preventing and managing
contamination incidents. Prevention is based largely on understanding potential targets of
contamination. Of special  concern may be hospitals, schools, government buildings, or other
institutions where large numbers of people could be directly or indirectly affected by a
contamination threat or incident.  Steps taken to protect the drinking water supply for these
critical customers, such as  enhancements to the  physical security  of distribution system elements
at these locations, may deter the attack itself.

Water customers vary significantly with regard  to their expectations  of what constitutes
acceptable water service, so it is necessary to consider the manner in which water is used in a
particular system. For example, high water demand that is largely driven by industry has
different implications compared to high usage rates in an urban center with a high population
density.  Some customers,  such as hospitals and nursing homes, may have certain water quality
requirements.  Sensitive sub-populations, including children and the  elderly, can exhibit adverse
health effects at doses more than an order of magnitude lower than those necessary to produce
disease or death in a healthy adult. That being said, for the purposes of managing water
contamination threats, it is important to keep in mind that the most important goal is protecting
the health of the public as a whole. Planning, preparation, and allocation of resources should be
directed toward protecting the public at large, beyond specific demographic groups or individual
                                        23                      Interim Final - December 2003

                                               MODULE 1: Water Utility Planning Guide

4.2  Update Emergency Response Plans for Intentional Contamination
Emergency response plans (ERPs) are nothing new to water utilities, since many have developed
ERPs to deal with natural disasters, accidents, civil unrest, etc.  Because water utilities are a vital
part of the community, it has been prudent for many utilities to develop these in order to help
ensure the continuous flow of water to the community.  However, many water utility ERPs
developed prior to 9/11 do not explicitly deal with terrorist threats, such as intentional
contamination.  Recently, the U.S. Congress required community water systems serving a
population greater than 3,300 to prepare or revise, as necessary, an ERP to reflect the findings of
their vulnerability assessment and to address terrorist threats
(http ://www. epa. gov/safewater/security/community. html).

In response to the legal mandate to revise ERPs, there is an increased demand for guidance that
addresses terrorist threats to water supply systems. The U.S. EPA is preparing this guidance,
which will be published in a separate document (U.S. EPA, 2003b, "Drinking Water Model
Emergency Response Plan," in development. See also U.S. EPA, 2003c, "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).  For those existing plans that can be revised, information contained in this RPTB may
help  utilities to address the contamination threat in their revised ERPs, although it should be
noted that there is no regulatory requirement to use the RPTB in this manner. However, the
RPTB does provide a framework that will aid utilities in planning an effective response to
contamination threats, which might be considered during revision to their ERP.
4.3  Develop Response Guidelines for Intentional Contamination
Although not a formal part of an ERP, utilities may wish to develop Response Guidelines (RGs)
for managing contamination threats. RGs are different from ERPs in that they are essentially a
"field guide" for responding to contamination threats.  RGs may be developed in many different
formats, but a core feature of any RG is that it is easy to use in the field and under crisis
conditions. Because RGs are used in the field, they should be action-oriented, easy to follow,
and contain all the necessary forms and information.  For instance, they should contain forms to
document observations at the site of a suspected contamination incident and to log samples
collected from the site. Additionally, the guidelines might include flow charts depicting the steps
of a process, simple reference tables, and other information that can easily be used during the
intense period of an initial response to a threat.  A trained individual should be able to follow a
well organized RG with minimal difficulty.  While the RPTB is not set up in the streamlined
format of an effective set of RGs, the material contained in the RPTB can certainly support the
development of guidelines, and an example outline for a set of RGs is included in Appendix 5.1
of this Module.  The outline may be filled using model text, figures, and forms contained in the
various modules of the RPTB, in addition to the users' own materials.
4.4  Establish Structure for Incident Command
One of the primary reasons that ERPs and RGs fail (for any type of emergency, not just water
contamination) is that there is no clear leader established by the plan.  Thus, in planning for a
water emergency, it is important to establish a command structure. This involves establishing a
                                       24                      Interim Final - December 2003

                                                MODULE 1: Water Utility Planning Guide

chain of command, identifying key individuals, and clearly defining their roles and
responsibilities, so that they may effectively manage the emergency situation. This section
describes an incident command structure based on the Incident Command System (ICS).  See
http://training.fema.gov/EMIWeb/IS/is 195.asp for ICS training material produced by FEMA.

In summary, ICS is the model tool for command, control, and coordination of a response to a
public crisis.  The tool provides a means to coordinate the efforts of individual agencies as they
work toward the common goal of stabilizing the incident and protecting life, property, and the
environment. The rationale is that large-scale disasters may be multi-jurisdictional and require
cooperation among several agencies. Furthermore, ICS is used by many local, state and federal
response agencies and is part of the National Interagency Incident Management System
(NIIMS).  Note that NIIMS is different than the National Incident Management System (NIMS),
which is under development for use by the National Response Plan (see Appendix 6.2 of this

Federal  law requires hazardous materials (HazMat) responders to use ICS, and many States are
adopting ICS as their standard for responding to all types of incidents.  However, in the
'possible'  stage of the evaluation of a water contamination threat, HazMat will probably not be
involved, and the mandated ICS may not be applied.  Rather, the utility, or possibly a technical
assistance provider such as a state drinking water primacy agency, would manage the threat.
However,  at some point following the determination that a contamination threat is 'credible,' the
existing ICS at the local or State level would likely be implemented.  For major disasters and
emergencies, including terrorist acts, the Federal Response Plan (see Appendix 6.3 of this
Module) provides the mechanism for federal departments and agencies to coordinate delivery of
Federal  assistance and resources to augment efforts of overwhelmed  local and State
governments. Fortunately, one of the benefits of ICS is its ability to  expand and contract based
on the needs of the situation. Thus, to make potential expansion as seamless as possible, it seems
logical that utilities adopt ICS conventions during their response to a contamination threat, even
during the 'possible'  stage, to facilitate coordination between the utility and other responding
agencies that may become involved at a later stage.

Figure 1-3 (left) provides a schematic of ICS for a water utility during a 'possible' threat, in
which utility staff have primary responsibility for managing the threat (see Module 2, Section 3).
It is anticipated that during this initial stage, the water utility staff will conduct the threat
evaluation (Figure 1-3, top middle). At some point during the response to a 'credible' threat,
various responding agencies would be organized under ICS according to the principle of unified
command, and the 1C might be someone from an outside organization such as FBI or the
State/local health department (Figure 1-3, bottom middle). Unified command is a team effort
which allows all agencies with responsibility for the incident,  either geographic or functional, to
manage an incident by establishing a common set of incident objectives and strategies. This is
accomplished without abdicating agency  authority, responsibility, or accountability. When
command is transferred, it is anticipated that water utility staff will continue to occupy roles in
the command structure, but this is at the discretion of the new incident commander. Figure 1-2
(right) is an example  of unified command under ICS that might be assembled to respond to a
'confirmed' water contamination incident. For 'confirmed' incidents, it is assumed that an
agency external to the water utility has assumed responsibility for incident command.  However,
                                        25                       Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

the utility will still have a role in this incident command structure since they are responsible for
the operation and maintenance of the drinking water system.

Figure 1-3 is primarily intended to illustrate the expanding nature of the incident, show model
ICS structures, and point out the changing role of the water utility in the command structure. It
must be customized for a particular situation, and should be expanded and contracted as
necessary. Regardless of the size and shape, the command structure operates most efficiently if
each person  in an organization reports only to one designated individual, a concept known as
unity of command. Likewise, communication outside of the command structure should be made
only through designated individuals (i.e., information officers, liaison officers, or points of
contact). Following are some definitions used in Figure 1-3.

   1.  Incident commander (1C):  The 1C sets incident objectives and priorities, and has overall
       responsibility for management of the incident.  Thus, for water contamination, the
       incident commander coordinates all the activities involved, whether they are related to
       the water utility, local civil defense, public health, public works, etc. One key role of
       incident command is to effectively communicate with all participants involved in the
       management of the incident, including those outside of the water utility's own command
       structure. Various individuals may assume the role of incident commander depending on
       the stage of the response. In ICS, the initial incident commander is traditionally defined
       as the senior first-responder to arrive at the scene. However, due to the nature of water
       contamination events triggered by the warnings described above, it is likely that there
       will need to be a designated individual at the water utility who becomes the incident
       commander when a threat is reported. This individual is known as the water utility
       emergency response manager (WUERM).

   2.  Water Utility Emergency Response Manager (WUERM): The WUERM is an individual
       (or several individuals) with designated responsibility for managing the utility's response
       to a contamination threat or incident. As discussed above, the WUERM will likely serve
       as 1C during the early stages of the response. Given this responsibility, the WUERM
       should be empowered to make decisions regarding the threat evaluation (i.e., determining
       whether or not a threat is 'possible') and response decisions in the early stages of the
       threat management process. Should the threat rise to an appropriate level, the WUERM
       may  recommend that the emergency operations center (EOC) be activated.  Once the
       threat or incident rises to a level such that responsibility for incident command is
       transferred to another organization, the WUERM will still have a significant role in the
       response, and will likely serve as the utility's representative in the ICS structure.

   3.  Water Utility Emergency Operations Center Manager (WUOCM):  The WUOCM is an
       'emergency manager' who heads the water utility's EOC, which is responsible for
       operational and resource management during an emergency. The general position of
       'emergency manager' is  described in FEMA's training documents,
       http://training.fema.gov/EMIWeb/IS/is 1.asp, although specific duties for water utilities
       may  differ. In most cases, responsibilities of the WUOCM and the WUERM will fall
       upon different individuals.
                                        26                      Interim Final - December 2003

                                                               'Credible' stage investigation by utility
                                                                                                                                                 Module 1:   Water Utility Planning Guide
      "Possible" threat
       Incident Commander
     from water utility (WUERM)
Information Officer
 from water utility
 Safety Officer
from water utility
                     Utility Operations
                    Utility Plant Manager
Incident Commander
from utility (WUERM)
Information Officer
from water utility
|_ Utility Head

Safety Officer

from water utility
Liason Officer
from water utility
Pol ce, Fire, FBI
Public Health Contact
HAZMAT contact
Utility Operations
                                                       I                  I                 I
                                                Site Characterization    Utility Plant Manager     Laboratory PoC
                                                                                          SCADA coordi

                                                                                            Unit Operator
                                                                                                   I in at or   L-
                                                                                                             Section Heads
                                                                                                              - Key Personnel
                                                          'Credible' threat investigated by unified command
                                                                          Incident Commander
                                                                          from Unified Command
                                                                       (Local Law, FBI, Health, Utility)
                                                                Information Officer
                                                               from unified command
                                                                  Safety Offii
                                                               from unified
                                                               Agency Representative    _
                                                             from water utility (WUERM)
                                                                    Liason Officer
                                                                  from unified command
                                                                   Operations Section
                                                                   (Local Fire or Law)
                                                                                              Law Branch
                                                                                            (Police, Fire, FBI)
                                                                                             Hazmat Group
                                                                                       ' (Local Fire, Health, Water Utility)
                                                                                            Site Characterization
                                                                                           Technical Specialists
                                                                                              (Water Utility)
                                                                                            Utility Plant Operations

                                                                                            Utility Laboratory(ies)
                                                                                                                                                'Confirmed' threat investigated by unified command
              Incident Commander
              from Unified Command
             (EPA, FBI, Health, Utility)
  Information Officer
ar Joint Information Center
                                                                                                                      Safety Officer
                                                                                                                   from unified commai
                                                                                                                                         Agency Representative
                                                                                                                                         from utility (WUERM)
                                                                                                                                   Water Utility Emergency Operations Center
                                                                                                                                          - Utility Plant Operations

                                                                                                                                          - Utility Laboratories)
  Liason Officer
from unified command
                                            Operations Section
                                            (Local Fire or Law)
                                                                                                                                                                     Technical Specialists
                                                                                                                                                                      from water utility
                                                            Law Branch
                                                          (Police, Fire, FBI)

                                                           Hazmat Group
                                                      (Local Fire, Health, water utility)

                                                         Public Health Group

                                                     L-  External Laboratory

                                                        L-      LPoC

                                                      Other Agency Representatives
   Figure  1-3. Expansion of, and  Changes to, Incident Command Structure  for the  Three Threat Evaluation Stages
                                                                                         Interim Final - December 2003

                                                 MODULE 1:  Water Utility Planning Guide

   4.  Information Officer (IO):  The IO is part of the command staff and reports directly to the
       1C.  The IO is responsible for planning the information strategy, discussed in Section 4.5
       below. Another very important role of the IO is interfacing with the media and
       disseminating public information.

   5.  Liaison Officer (LO):  The LO is part of the command staff and is the on-scene contact
       for representatives from other agencies assisting with the incident.

   6.  Laboratory Point of Contact (LPoC): The LPoC is the designated person at the
       laboratory with whom the WUERM (or 1C) communicates.  The LPoC coordinates
       analytical activities with the WUERM (or 1C) and reports analytical results only to the
       WUERM (or 1C).

   7.  Safety Officer:  The Safety Officer's function is to develop and recommend measures for
       assuring personnel safety, and to assess and/or anticipate hazardous and unsafe situations.
       Only one Safety Officer should be assigned per incident.  The Safety Officer may have
       assistants as necessary, and the assistants may also represent assisting agencies or
       jurisdictions.  Safety assistants may have specific responsibilities such as air operations,
       hazardous materials, etc.

   8.  Agency Representatives: In many multi-jurisdiction incidents, an agency or jurisdiction
       will send a representative to assist in coordination efforts. An Agency Representative is
       an individual assigned to an incident from an assisting agency or cooperating agency
       who has been delegated authority to make decisions on matters affecting that agency's
       participation at the incident.  Agency Representatives report to the Liaison Officer, or to
       the Incident Commander in the absence of a Liaison Officer. As illustrated in Figure 1-3,
       if the WUERM is not the incident commander, then the WUERM may be the agency
       representative for the drinking water utility in the ICS.

   9.  Technical Specialists:  Certain incidents or events may require the use of Technical
       Specialists who have a specialized knowledge and expertise. As illustrated in Figure 1-3,
       Technical Specialists may be assigned to any aspect of the response where their services
       are required. Because water utility staff have intimate knowledge of their own system,
       there role in this position will be invaluable during every stage of the response.

The identity of the WUERM, WUOCM, IO, LO, LPoC, and other designated individuals should
be determined locally, based on the utility's size, needs, and responsibilities. Large systems may
need to designate multiple WUERMs such that one is always available. Small utilities and small
communities may have an abbreviated version of command structure. In this case, the WUERM,
WOURC, IO, LO, and other designation individuals could be the same person, or some of these
positions may be filled by individuals outside of the utility (e.g., from local government).  For
the case of the small utility, it may greatly enhance the response process if the particular
individual understands ICS, because the small utility may need to coordinate with a larger, better
resourced organization, like a state or federal entity.  Also, in  small systems, the WUERM will
likely need to engage other decision officials at the state or local level earlier in the process than
will the WUERM at large utilities.
                                        28                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide
4.5  Develop Information Management Strategy
As described previously, the role of the IO is to manage the large amount of information that
might be used during the threat evaluation process and to support decisions about various
response actions. For instance, Module 2 describes a number of information resources that may
be of use during the threat evaluation process, but only if the information has been properly
managed and is readily accessible. Thus, provisions should be made to readily access this

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 Department of
Justice (DOJ, http://www.ncjrs.org/pdffilesl/nij/197065.pdf). A Field Operations and Records
Management System (FORMS), originally developed for EPA's Contract Laboratory Program,
may also help manage records relevant to sample documentation, analysis, and tracking during
evaluation of water threats (http://www.epa.gov/superfund/programs/clp/f21ite.htm).

Another component of information management is planning for the flow of information during
the response to a threat or incident. The individuals or agencies responsible for receipt and
management of information are related to the communication strategy described in the next
section. However, as part of the information management strategy, a plan must be developed for
the flow of information to appropriate individuals within the ICS structure.  The release of
inaccurate information at an inappropriate time can have severe consequences for the response,
criminal investigation, and well-being of the public.

The proper flow of communications during a crisis can be facilitated through the establishment
of a Joint Information Center (JIC), a structure that works within the framework of ICS (See
http://www.nrt.org/production/nrt/home.nsf/Resources/publications/$FILE/JIC.pdf for a JIC
model). This model documents a plan for conducting crisis communications during response to
emergencies in which multiple organizations need to collaborate to provide timely, useful, and
accurate information to the public and other stakeholders. The model was designed based on
requirements identified by the National Response Team (http://www.nrt.org). Although the
model was not developed expressly for water utilities, some of the criteria used in the model's
development are appropriate for a water utility's information management strategy. Because it is
designed on the basis of function, the model can be used during any situation in which there is a
need for centralized communications support involving multiple organizations.

It is important to highlight the lO's responsibility as a contact for the media and public.   In this
manner, the media and public receive information from a single source, which may help
eliminate the confusion inherent to an emergency situation.  It is important for the media and
public to understand that the IO is the only official source of information about the emergency,
and that they are receiving information from a consistent source. For this reason, it may be
desirable that the IO remains the same even if the incident commander changes, as may be the
case for incidents that reach the 'confirmed' stage (see Figure 1-3).
                                       29                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

4.6   Establish Communication and Notification Strategy
The ICS requires communication strategies be planned and made available to all potential
participants prior to an actual incident or threat. For the purposes of responding to a water
contamination threat, the ICS structure illustrated in Figure 1-3 indicates there could be several
management levels within the utility, as well as external to the utility, that may be involved in
the management of a contamination threat. The hierarchy of potential participants includes: the
utility, local government, the regional government (e.g., county), state government, and federal
government. Not all of these levels would necessarily be involved in  every situation; however,
the mechanism and process through which they interact must be decided in advance of an
incident to achieve optimal public health and environmental protection.  Due to the number and
variety of possible participants, planning for effective communication is critical. ICS employs
two main strategies to ensure effective communication.  The first is the use of common
terminology, and the second is unity of command.

Regardless of the strategy employed within the ICS, developing the plan requires a significant
level of effort. An effective communication plan is more than just the telephone directory of
utility employees and external contacts, although such a directory is often beneficial.  Rather,
planning communications involves developing a notification hierarchy for reporting threat
warnings and other critical information to  appropriate individuals at each stage of the response.
Many of the individuals that would need to be notified at key points in the response are identified
in the ICS, but others may be outside the ICS  chain of command. For example, the head of the
utility or the drinking water primacy agency may wish to be notified in the case of any threat,
although neither may be in the ICS chain of command.  However, in general, communications
should proceed along the chain of command of the ICS.  The number  of people notified will
increase as the incident expands and decreases as it contracts toward its conclusion. The exact
persons notified will be at the discretion of the 1C with interaction with the IO, and should be
planned in advance. Local requirements may influence the required communication at the
various stages.

Figure 1-4 is designed to illustrate the expanding nature of notifications as the threat evaluation
proceeds through the 'possible,' 'credible,' and 'confirmed' stages. Figure 1-4 is primarily
intended to show the utility's role in the communications, which is based on the ICS structure
shown in Figure 1-4. Accordingly, the communications depicted in Figure 1-4 are only those
parts of Figure 1-3 in which the utility is involved.  The three stages in Figure  1-4 illustrate a
possible structure of the communication hierarchy upon expansion but does not necessarily
define the exact path or circumstances under which expansion will occur as a threat escalates.
Careful planning and thoughtful actions during the management of the threat will dictate how
this expansion will occur. Figure 1-4 shows an example notification hierarchy for each stage of
the threat management process, and in the situation in which the credibility determination is
made by the utility and the credibility determination is made by an external organization.
Utilities should plan communication schemes for both of these  cases because, although the role
of individuals within the ICS may change, the individual involved will not.
                                        30                      Interim Final - December 2003

                                                                   MODULE 1:   Water Utility Planning Guide
      'Possible' stage evaluation by utility
           'Credible' stage evaluation by utility
                24/7 Call Center
xxx-xxx-xxxx (home)
xxx-xxx-xxxx (cell)
wuerm@xxx.xxx (text messenger)

formation Officer
rom water utility

Utility Head

Safety Officer
from water utility

Utility Operations
     xxx-xxx-xxxx (home)
      xxx-xxx-xxxx (cell)
wuerm@xxx.xxx (text messenger)
Site Characterization
team leader

Utility Plant Manager


Laboratory PoC
SCADA coordinator
Unit Operator

Section Heads
      'Credible' stage evaluation by unified command
           Agency Representative from Utility (WUERM)
                     xxx-xxx-xxxx (home)
                      xxx-xxx-xxxx (cell)
                 wuerm@xxx.xxx (text messenger)
Utility Plant Operator

Laboratory PoC
SCADA Coordinator
Unit Operator

Section Heads

                                                                      'Confirmed' stage evaluation by unified command
           Agency Representative from Utility (WUERM)
                     xxx-xxx-xxxx (home)
                     xxx-xxx-xxxx (cell)
                wuerm@xxx.xxx (text messenger)
                                                                                   Technical Specialists
                                                                                      (Water Utility)
                                                                       Water Utility Emergency Operations Center (WUEOCM)
                                                                                    xxx-xxx-xxxx (home)
                                                                                     xxx-xxx-xxxx (cell)
                                                                                wuerm@xxx.xxx (text messenger)
Utility Plant Operator

Laboratory PoC
SCADA Coordinator
Unit Operator


Section Heads

Key Person ne

Maintenance Head


Key Personnel
Public Works Interface

Figure 1-4.  Sample Communication Schemes for the Three Threat Evaluation Stages
                          Interim Final - December 2003

                                                   MODULE 1:  Water Utility Planning Guide

For the 'possible' stage (Figure 1-4, top left), most of the communications and notifications are
internal and begin with the WUERM being notified about the threat. However, depending on the
nature of the threat warning, it may be necessary to notify external agencies at the 'possible'
stage (e.g., notification of law enforcement in the case of a direct threat from a perpetrator).
Utilities must establish some mechanism for informing the WUERM of the incident. A 24/7
operations center may be effective for this purpose. The scale and staffing of an operations
center will vary substantially with utility.  For example, a large utility may have a continually
staffed center.  A smaller utility may provide the WUERM(s) with a cell phone or perhaps
leverage other call centers that exist within the local government.

The WUERM is notified first, and then the WUERM may notify the heads of other departments
to get their support for the threat evaluation. The WUERM would also continue notification
along the management chain to keep them apprised of the situation. As the threat management
process expands, it may be necessary to activate the IO to manage communications with the
utility's management chain, as well as external parties.  This will allow the WUERM to focus on
the overall management of the response to the contamination threat.

It is likely that the utility will carry out the initial  phases of the threat evaluation at the 'credible'
stage. Figure 1-4 (top right) shows a sample communication scheme, based on internal utility
staff and also external parties that may be able to provide information and technical assistance
relevant to the threat evaluation.  Figure 1-5 expands on some  of the "other" external parties that
the IO or LO in Figure 1-4 (top right) may need to contact.  Note that the local entities in this
figure may be contacted earlier than those at higher levels of government.
                        Federal Bureau
                        of Investigation
                        State Law
   Centers for       EPA National
   Disease Control     Response Center
                                    Local Health
             Local Law
Local First
Local Civil
                                                            EPA Region
                                                         / State Emergency
                             State Environmental
      Public Health
Figure 1-5. Overview of Potential External Notifications
Figure 1-5 does not seek to define a notification scheme or their possible role within the ICS
structure - both of these tasks will be incident-specific and/or dictated at the local level.  Rather,
the figure provides a basic structure for the parties typically involved. These parties are divided
into those that are external but still local, and those that are external but at higher levels of
government. Notifications by the utility during the threat evaluation at the 'credible' stage
                               Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

include the drinking water primacy agency (often the State), the emergency response community
(including HazMat, EMS, etc.), law enforcement agencies (local, state, and/or federal),
government agencies (local, state, and/or federal), the public health community, and external
laboratories. Not all of these notifications need to be made in every incident—the overall
response plan may  dictate what level of notifications should occur and at what stage of the threat
evaluation, which in turn dictates who will make the notification. For instance, depending on
State requirements, it may not be appropriate for the utility to  contact the EPA National
Response Center directly. Nevertheless, contact information should be available for all
individuals and organizations that may need to be contacted.

If additional support agencies (e.g., HazMat or law enforcement) respond during the 'credible'
stage of the threat evaluation, then incident command may be  transferred to one of these agencies
(Figure 1-4, bottom left). However, staff from the utility's command structure, such as the
WUERM, IO and the LO, may still be extremely helpful advisors to the new incident
commander; thus, the utility's contact list should be available  to unified command. Unified
command will handle most communications at this point, so Figure 1-4 (bottom left) only depicts
those parts of the ICS structure in which the utility will be involved. The communication
strategy represented in Figure 1-4 (bottom left) conforms to Figure 1-3.  In this case, more
specialized individuals at the water utility become involved as technical specialists, and the
WUERM is now acting as the Agency Representative from the water utility.  The technical
specialists will be a very important part of the ICS, and the utility should plan communication
with these individuals carefully.

The 'confirmed' stage pictured in Figure 1-4 (bottom right), represents a significant change in
the communication structure because an external agency operating under unified commend will
be in charge of the  response. Also, the Water Utility Emergency Operations Center (WUEOC)
will likely be activated (if it was not already during the 'credible' stage). The chain of
communications may proceed through the WUEOC manager (WUEOCM). Technical
Specialists that participate in the ICS operated under unified command may also be part of the
EOC staff.  Additional technical specialists may need to be notified, such as those responsible for
repair and maintenance, who would not necessarily be engaged before the incident is confirmed.
The role of the utility in overall management and command of the incident may proportionally
decrease as many other external parties become involved (see Figure 1-5).
4.7  Perform Training and Desk/Field Exercises
In addition to a lack of planning, another reason that emergency response plans fail is lack of
training and practice.  Training provides the necessary means for everyone involved to acquire
the skills to fulfill their role during an emergency. It may also provide important 'buy-in' to the
response process from both management and staff, which is essential to the success of any
response plan. Desk exercises (also known as  'tabletops' or 'sand lots') along with field
exercises allow participants to practice their skills. Also, these exercises will provide a test of
the plan itself, revealing strengths and weakness that may be used to improve the overall plan.
Improvements can include measures not only for intentional contamination of water, but also for
other emergencies faced by the water utility and the community at large.
                                        33                       Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

Training may be available from EPA or other federal partners.  For instance, several online
training courses relevant to emergency management are available on-line from FEMA
(http://training.fema.gov/EMIWeb/IS/crslist.asp). These courses cover a range of topics
including community disaster exercises, emergency manager orientation, and animal health and
safety during disasters. Further, it is worthwhile mentioning some areas where formal training is
desirable, but not currently available. For example, in addition to training for sampling and site
characterization, there are also training needs for a general understanding of the overall threat
management process and the ability to make important decisions quickly and with limited
information.  In the absence of formal training, the reports, forms, templates, SOPs, and
checklists that make up a set of RGs may be used as worksheets to practice potential scenarios.
4.8   Enhance Physical Security
Denying physical access to key sites within the water system may act as a deterrent to a
perpetrator.  Criminals often seek the easiest route of attack, just like a burglar prefers a house
with an open window. Aside from deterring actual attacks, enhancing physical security has other
benefits. For example, installation offences and locks may reduce the rate of false alarms.
Without surveillance equipment or locks, it may not be possible to determine whether a
suspicious individual has actually entered a vulnerable area.  The presence of a lock and a
determination as to whether it has been cut or broken provides sound, although not definitive,
evidence that an intrusion has occurred. Likewise, security cameras can be used to review
security breaches and determine if the incident was simply due to trespassing or is a potential
contamination threat.  The costs of enhancing physical security may be justified by comparison
to the cost of responding to just one 'credible' contamination threat involving site
characterization and laboratory analysis for potential contaminants.

The correct choice of security enhancements varies by utility, and a number of resources are
available to assist in this selection process.  For instance, a vulnerability assessment (see Section
4.1.1) may provide a sound basis for making security upgrades.  The American Water Works
Association has developed a field guide (AWWA, 2002) to help meet security challenges. EPA
has developed a series of Security Product Guides to assist treatment plant operators and utility
managers in reducing risks from, and providing protection against, possible natural disasters and
intentional terrorist attacks (http://www.epa.gov/safewater/security/guide/index.html).
4.9   Establish Baseline Monitoring Program
Background concentrations of suspected or tentatively identified contaminants may be extremely
important in determining if a contamination incident has occurred. In some cases, and for some
contaminants, background levels may be at detectable concentrations.  If unrecognized, these
may be confused with an actual contamination incident. Baseline occurrence information,
discussed more thoroughly in Module 3, Section 3.5, is derived from monitoring data and is used
to characterize typical levels of a particular contaminant or water quality parameter. Baseline
data may be used for two purposes in the context of emergency water sampling:
    •   If general water quality parameters, such as pH, chlorine residual, or conductivity, among
       others,  are used as indicators of possible contamination incidents, a baseline must be
       established such that significant deviations from the baseline can be observed.
                                        34                      Interim Final - December 2003

                                                 MODULE 1:  Water Utility Planning Guide

    •   If a specific contaminant is detected in the water, knowledge of typical background levels
       may be necessary to properly interpret the results.

4.10  Utilize and Understand On-line Monitoring
On-line monitors are a topic of much interest, although there is a significant level of debate
regarding their effectiveness as an early warning system (EWS).  AWWARF has published a
report discussing on-line monitoring for drinking water utilities (AWWARF, 2002), which
outlines the cost-benefit analysis for online monitoring.  Many of the costs and benefits are based
on issues of general water quality, plant operations, and regulatory compliance.  One definite
benefit is early detection of changes in water quality parameters, such as pH, chlorine residual,
and turbidity. Changes in these parameters relate to treatment plant operation, and may also
indicate potential water contamination if properly interpreted. For instance, on-line monitoring
may help establish typical background levels of the monitored parameters. These established
background levels  can then be compared with levels recorded during a suspected contamination
incident. Another benefit of on-line monitoring for water security is that it can free operators
from manual data collection, and facilitate analysis and interpretation of the data for routine as
well as security purposes.  Such information should be integrated into the information
management plan (see Section 4.5).

In summary, the use of on-line monitors may serve to increase the quality of water in general,
but there are unanswered questions regarding their applicability as EWSs.  Currently, there are
efforts underway within EPA and the water industry to attempt to resolve these issues and also to
verify that commercially available on-line monitors perform as effectively as their manufacturers
claim. Results of this work may be reported in later versions of the RPTB. The results of EPA
efforts to verify monitoring technologies can be found at http://www.epa.gov/etv. Because of
interest in on-line monitoring systems that are currently available, a discussion of the two main
types, conventional systems and EWSs, is included in Appendix 6.2.
                                        35                      Interim Final - December 2003

                                               MODULE 1:  Water Utility Planning Guide

5   References and Resources

References and information cited or used to develop this module are listed below. The URLs of
several sources are cited throughout the text. These URLs were correct at the time of the
preparation of this document. If the document is no longer available at the URL provided, please
search the sponsoring organization's Web site or the World Wide Web for alternate sources. A
copy of referenced documents may also be provided on the CD version of this module, although
readers should consult the referenced URL for the latest version.

AWWA.  2002. Water System Security: A Field Guide, American Water Works Association,
Denver, CO.

AWWARF. 2002. Online monitoring for drinking water utilities.  Editor, Erika Hargesheimer,
AWWA Research Foundation and CRS PRO AQUA, American Water Works Association,
Denver, CO.

AWWARF. 2003. Actual and Threatened Security Events, AWWARF Project 2810, American
Water Works Association, Denver, CO.

DHS. 2003a. "Initial National Response Plan"
http://www.dhs.gov/interweb/assetlibrary/Ini tial_NRP_100903.pdf

FEMA. 2003a. "IS-195 Basic Incident Command System - EMI Independent Study Program"
http://training.fema. gov/EMIWeb/IS/is 195. asp

FEMA. 2003b. "Independent Study Course List"
http://training.fema. gov/EMIWeb/IS/crslist. asp

FEMA. 2003c. "Federal Response Plan"
http://www.fema. gov/rrr/frp/

DOJ/NIJ. 2002. "Crisis Information Management Software (CIMS) Feature Comparison Report"

WHO. 2001. "Health Aspects of Biological and Chemical Weapons"
http://www.who.int/emc/pdfs/BIOWEAPONS FULL TEXT2.pdf

U.S. EPA. 2002. "EPA Community Drinking Water Security Requirements"
http ://www. epa. gov/safewater/security/community. html

U.S. EPA. 2003a. "The Safe Drinking Water Act"
http ://www. epa. gov/safewater/sdwa/sdwa.html

U.S. EPA. 2003b. Model Emergency Response Plan, in preparation.
                                       36                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

U.S. EPA. 2003c. "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"
http ://www. epa. gov/ogwdw/security/pdfs/erp-l ong-outline.pdf

U.S. EPA. 2003d. "FORMS II Lite" http://www.epa.gov/superfund/programs/clp/f21ite.htm

U.S. EPA. 2003e. "Security Product Guides"
http ://www. epa. gov/safewater/security/guide/index.html

U.S. EPA. 2003f. "Environmental Technology Verification (ETV) Program"
http ://www. epa. gov/etv

International Life Sciences Institute Risk Science Institute. (ISLI). 1999. Early Warning
Monitoring to Detect Hazardous Events in Water Supplies.  ILSI PRESS, Washington, DC.

NRT. 2000. "NRT Joint Information Center Model:  Collaborative Communications During
Emergency Response"

NRT. 2003. "National Response Team" (2003) http://www.nrt.org

WHO. 2003. "Public health response to biological and chemical weapons: WHO guidance, 2nd
edition (Draft, May 2003)" http://www.who.int/csr/delibepidemics/biochemguide/en/index.html
                                       37                      Interim Final - December 2003

                                               MODULE 1:  Water Utility Planning Guide
6   Appendices
6.1  Sample Outline of Response Guideline
A Response Guideline is essentially a "field guide" for responding to contamination threats, and
may be composed of appropriate figures, forms, templates, text, and checklists, which can be
found in Modules 2 through 6. Expanding the outline below with the content from Modules 1-6
(as listed and/or linked within the outline) should result in an essentially complete response
guideline.  See the table of contents for the modules for exact locations.

    1.  Overview of/Introduction to Response Guidelines (Module 1, Section 4.3)
    2.  Threat Warning Descriptions (Module 1, Section 2.2)
    3.  Initial Communication and Notifications (Module 1, Section 4.6)
    4.  Threat Evaluation
          a. Threat Warning Report Forms (Module 2, Appendix 8.3-8.8)
          b. Threat Evaluation Worksheets (Module 2, Appendix 8.2)
    5.  Site Characterization
          a. Site Characterization Plan Template (Module 3, Appendix 8.1)
          b. Field Testing Results Form (Module 3, Appendix 8.3)
          c. Site Characterization Report Form (Module 3, Appendix 8.2)
          d. Sample Documentation Form (Module 3, Appendix 8.4)
    6.  Planned Responses
          a. Response Planning Matrix (Module 2, Appendix 8.1)
          b. Action Plan (Module 2, Section 2.4)
          c. Guidelines for Contaminant Containment (Module 5, Section 4)
          d. Contaminant Identification (Module 4)
          e. Treatment, Removal And/or Disposal of Contaminant (Module 6, Section 6)
          f. Public Notification (Module 5, Section 5)
          g. Alternate Domestic Water (Module 6, Section 5)
          h. Fire Flow Supply (Module 6, Section 5)
          i. Expanded Communications (Module 1, Section 4.6)
    7.  Plan for Return of Water System to Service (Module 6, Section 8)
    8.  Appendixes
          a. Appendix I: Phone Directories for Notifications (Module 1, Section 4.6)
          b. Appendix II: Drinking Water Advisories (Module 5, Appendices 8.2 - 8.5)
                                       3 8                      Interim Final - December 2003

                                               MODULE 1:  Water Utility Planning Guide

6.2 U.S. Government Response Plans
6.2.1   National Response Plan
The U.S. Department of Homeland Security was tasked by the Homeland Security Presidential
Directive 5 (HSPD-5) to develop, submit to the Homeland Security Council, and administer a
National Response Plan (NRP). HSPD-5 required the development and publication of an Initial
NRP (INRP), which was released on September 30, 2003. Pending the development of the full
NRP, the INRP provides an interim implementation of the domestic incident management
authorities, roles, and responsibilities of the Secretary of Homeland Security as defined in
HSPD-5. It also provides interim guidance on Federal coordinating structures and processes for
domestic incident management. The INRP is applicable to domestic incident management in the
context of terrorist attacks, major disasters, and other emergencies. A final NRP will eventually
replace the INRP. In the interim period, until the full NRP becomes effective, current Federal
incident management and emergency response plans remain in effect, except as specifically
modified by the INRP. The full text of the INRP is available at
http://www.dhs.gov/interweb/assetlibrary/Initial NRP  100903.pdf and a fact sheet is found at

INRP represents a significant first step towards an overall goal of integrating the current family
of Federal domestic prevention, preparedness, response, and recovery plans into a single all-
discipline, all-hazards plan. The INRP will be supported by the National Incident Management
System (NIMS), a national system under development that creates standardized incident
management processes, protocols, and procedures.

There are five current emergency response plans that are linked by the INRP:
   •   Federal Response Plan
   •   U.S. Government Interagency Domestic Terrorism Concept of Operations Plan
   •   Federal Radiological Emergency Response Plan
   •   Mass Migration Response Plans
   •   National Oil and Hazardous Substances Pollution Contingency Plan

Of these, perhaps the Federal  Response Plan is most relevant to water contamination, and it is
more completely described below in Appendix 6.2.2.
6.2.2  Federal Response Plan
The Federal Response Plan (FRP, http://www.fema.gov/rrr/frp/) provides the mechanism for
federal departments and agencies to coordinate delivery of Federal assistance to State and local
governments during a major disaster or emergency, including terrorist acts.  The FRP supports
implementation of the Robert T.  Stafford Disaster Relief and Emergency Assistance Act
(Stafford Act), as amended (42 U.S. Code 5121, et seq.), as well as individual agency statutory
authorities. Under the Stafford Act, a State Governor may request the President to declare a
major disaster or an emergency if an event is beyond the combined response capabilities of the
                                       3 9                     Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

State and affected local governments. Only after the President makes a declaration is the FRP

As directed by Presidential Decision Directive (PDD)-39, U.S. Policy on Counter-terrorism, and
as articulated in the FRP (FEMA, 2003c), the Department of Justice (DOJ) is designated as the
lead federal agency for threats or acts of terrorism within U.S. territory. DOJ assigns lead
responsibility for "crisis management" to the Federal Bureau of Investigation (FBI), who acts
predominantly in a law enforcement capacity. Crisis management refers to the process by which
resources needed to apprehend and prosecute  perpetrators are identified, acquired and utilized.
Within that process, the FBI operates as the on-scene manager for the Federal Government.  It is
FBI policy that crisis management will involve only those Federal agencies requested by the FBI
to provide expert guidance and/or assistance, as described in the PDD-39 Domestic Deployment
Guidelines (classified) and the FBI Weapons of Mass Destruction (WMD) Incident Contingency

FEMA, a branch of the Department of Homeland Security (DHS), supports the lead federal
agency for "consequence management" throughout the Federal response, or serves as the lead
federal agency when the Attorney General transfers the role to DHS. Consequence management
refers to measures to protect public health and safety, restore essential government services, and
provide emergency relief to governments, businesses, and individuals affected by the
consequences of terrorism. It is DHS policy to use  FRP (FEMA, 2003c) structures to coordinate
all Federal assistance to State and local governments for consequence management.

The FRP provides more detailed guidance on  the post-incident management and responsibilities
of various federal  departments and agencies (see Terrorism Incident Annex, Section V, FEMA
2003c). In summary, no single agency or organization at the Federal, State, local, or private-
sector level possesses the authority and expertise to unilaterally implement remediation and
recovery actions.  If Federal assistance is provided under the authorities of the Stafford Act,
responsibility for specific tasks will be delegated by the lead agency to those entities that possess
the skills and resources required for implementing them.  Key areas of responsibility that would
potentially support water system remediation  and recovery  efforts are highlighted below:

DOJ/FBI. DOJ delegates the role of lead federal agency (LFA) to the FBI for operational
response.  The FBI responsibilities potentially supportive of remediation and recovery will
    •   Designating and establishing a Joint Operations Center (JOC) in the field;
    •   Appointing an FBI On-Scene Commander (OSC) who will convene and chair meetings
       of  operational decision makers representing lead State and local agencies, DHS/FEMA,
       and other supporting Federal agencies (e.g., EPA);
    •   Working with DHS to establish and operate a Joint Information Center (JIC) in  the field
       as  a focal point for information to the public and media concerning Federal response;
    •   Issuing and tracking the status of crisis management actions assigned by the FBI; and
    •   Designating appropriate liaison and advisory personnel to support DHS.

DHS. DHS supports the overall LFA by operating  as the lead agency for consequence
management until the overall LFA role is transferred to DHS.  DHS will:
                                       40                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

   •   Work with the FBI to establish and operate a JIC in the field as the focal point for
       information to the public and the media concerning the Federal response to the
   •   Establish the primary Federal operations centers for consequence management in the
       field and Washington, DC;
   •   Appoint a Regional Support Team (RST) Director or Federal Coordinating Officer (FCO)
       to manage and coordinate the Federal consequence management response in support of
       State and local governments. In coordination with the FBI, the RST Director or FCO will
       convene meetings with decision makers to formulate incident action plans, define
       priorities, review status, resolve conflicts. These meetings may also be used to identify
       issues that require decisions from higher authorities, and evaluate the need for additional
       resources.  Decision makers present at meetings may include Federal, State, and local
       emergency management and technical support agencies, as appropriate;
   •   Issue and track the status of consequence management actions assigned by DHS;
   •   Designate appropriate liaison and advisory personnel to support the FBI; and
   •   As needed, provide assets of the National Disaster Medical System and/or the
       Metropolitan Medical Response System.

HHS.  As directed in PDD-39, the Department of Health and Human Services (HHS) will
activate technical operations capabilities to support the Federal response to threats or acts of
WMD  terrorism. HHS may coordinate with individual agencies identified in the HHS Health
and Medical Services Support Plan for the Federal Response to Acts of Chemical/Biological
(C/B) Terrorism. Coordination efforts will use the structure, relationships, and capabilities
described in the HHS plan to support response operations. Note that CDC, and thus the
Laboratory Response Network (LRN), is part of HHS.  If the HHS plan is  implemented:
   •   The HHS on-scene representative will coordinate the HHS plan response with the DHS;
   •   The HHS plan response may include consultation, agent identification, epidemiological
       investigation, hazard detection and reduction, decontamination, public health support,
       medical support, and pharmaceutical support operations; and
   •   HHS will issue taskings that draw on  funding from the responding  HHS plan agencies.

EPA.  As directed in PDD-39, the EPA will activate technical operations capabilities to support
the Federal response to acts of WMD terrorism. EPA may coordinate with individual agencies
identified in the National Oil and Hazardous  Substances Pollution Contingency Plan (NCP)1 to
use the structure, relationships, and capabilities of the National Response System as described in
the NCP [40 CFR Part 300 subpart B] to support response operations.  If the NCP is
   •   The Hazardous Materials On-Scene Coordinator under the NCP will coordinate the NCP
       response with the DHS official (either the RST Director or the FCO), who is responsible
       under PDD-39 for on-scene coordination of all Federal support to State and local
       governments; and
1 Agencies listed in the NCP include: USCG, FEMA, DOD, DOE, USD A, DOC, HHS, DOI, DOJ, DOL, DOT,
DOS, NRC, and GSA.
                                       41                      Interim Final - December 2003

                                                 MODULE 1:  Water Utility Planning Guide

    •   The NCP response may include threat assessment, consultation, agent identification,
       hazard detection and reduction, environmental monitoring, decontamination, and long-
       term site restoration (environmental cleanup) operations.

USAGE. Under FRP Emergency Support Function (ESF) #3, Public Works and Engineering
Annex, the U.S. Army Corps of Engineers (USAGE) serves as the primary agency responsible,
in part, for emergency restoration of critical public facilities. Activities can include the
temporary restoration of water supplies and emergency contracting to support public health and
safety, such  as providing for potable water.

State and Local Authorities. State and local authorities maintain initial responsibility for
managing domestic incidents. The Federal Government will assist State and local authorities
when their resources are overwhelmed or when Federal interests are involved. In those cases,
the local or state agencies (e.g., local health department) should work in partnership with the

Water Utility. The water utility will possess the most detailed first-hand knowledge and
technical expertise regarding the  configuration and operation of the water source, storage,
treatment, and distribution systems.  Accordingly, water utility personnel will serve as technical
advisors to lead agency personnel responsible for system characterization, remediation, and
recovery.  If Federal assistance is provided under the authorities of the Stafford Act,
responsibility for specific tasks most likely will be delegated to the water utility by DHS/FEMA
or EPA (who will support long-term site restoration and environmental cleanup).  In addition, the
water utility can play a key role in planning for a remedial response to contamination, including
evaluating containment options, and ensuring rapid site access and access to operating records,
engineering  drawings, etc., that may be required by response action personnel.
                                        42                      Interim Final - December 2003

                                                MODULE 1:  Water Utility Planning Guide

6.3 On-Line Monitoring Systems
6.3.1  Conventional systems
Conventional on-line monitoring systems are largely designed to measure typical water quality
parameters in a near-real or real-time fashion.  Examples of these parameters include:
temperature, turbidity, particle counts, color, conductivity, total dissolved solids, alkalinity, pH,
chlorine residual, specific UV absorbance, TOC, along with a host of inorganic and organic
chemicals.  In addition, water flow, level, and pressure may be automatically recorded.  Many of
these systems are designed to meet regulatory goals related to the reduction of turbidity, DBF
formation, and other water quality parameters. These  systems are often connected to a utility's
SCADA and/or GIS system. The water quality parameters accessible through these systems may
also have water security applications, specifically by providing a warning of a possible threat, as
discussed in Section 2.2. However, interpretation of this data must be performed cautiously,  as
discussed in Module 2.
6.3.2  Early warning systems
The goal of an early warning system (EWS) is to identify a low probability/high impact
contamination incident in a water system allowing sufficient time for an appropriate response
that mitigates or eliminates any adverse impact resulting from the incident (ILSI, 1999).
Typically, an EWS for water would be designed to detect the introduction of toxic or infectious
contaminants that pose a risk to public health.  According to the ILSI report, an ideal EWS
would 1) be fully automated, 2) have a rapid response time and high sampling rate, 3) provide a
specific and sensitive screen for a range of contaminants, 4) have a low occurrence of false
positives and negative, 5) be reliable and rugged, 6) be easy to use, and 7) be affordable to install
and operate. Although there are many on-line monitoring systems currently being discussed for
use as EWSs, currently, an EWS with all of these features does not exist.

Among the technologies currently promoted as potential EWSs are toxicity monitors, which rely
on a biological species as a sentinel for the presence of the contaminant.  These range from large
animals such  as fish to various microbial species of algae. Another approach relies on
conventional monitors, in which changes in conventional water quality parameters, such as
temperature, chlorine residual, color, conductivity, and pH,  are used discretely or in a multi-
parameter analysis to infer the presence of a contaminant. Ideally, computerized data systems
for these detectors may automatically report significant changes in these parameters. It is
important to note, however, that the baseline of these parameters needs to be carefully
understood, as well as the relationship between changes in the water quality parameters and the
presence of specific contaminants.

Implementation of a poorly characterized monitoring technology will result in a false sense  of
security since there is no assurance that it is capable of meeting the monitoring objectives. In a
worst-case scenario, implementation of a poorly characterized system could result in false alarms
that undermine the effectiveness of a monitoring program and result in a needless expenditure of
resources to follow up on the false positive result.
                                        43                       Interim Final - December 2003

                                                 MODULE 1: Water Utility Planning Guide
Before initiating an early warning monitoring program, the objectives of the program should be
clearly defined, and a plan should be developed for the interpretation, use, and reporting of
monitoring results. It is critical that this plan be developed before there is a need to monitor or
respond to a threat warning and that the plan be developed in coordination with the water utility,
local and state health departments, emergency response units, and local political leadership.  The
consequences of improper coordination among authorities or inappropriate responses to
monitoring results can be severe.  The key is to have these guidelines and procedures in place
prior to deployment of the monitoring system.

As part of the monitoring plan, a hierarchy for dissemination of positive monitoring results
should be developed, and this notification hierarchy should be consistent with the utility's
overarching ERP.  This hierarchy should be based on consideration of who needs the information
to make public health decisions and at what time the information is needed.  Initially, the results
might need to be rapidly disseminated to the WUERM, utility management, emergency response
personnel, and the State or local health department. These preliminary monitoring results might
trigger various response actions,  such as a threat evaluation, additional sampling and
confirmatory analysis, and immediate operational response actions.

Another consideration is whether or not to communicate to the public information regarding
monitoring efforts designed to counter terrorism. On one hand, public support may be necessary
to secure funding for such a monitoring effort, and this may bolster public confidence in the
water supply.  Also, it could be argued that monitoring could serve as a deterrent to potential
criminal or terrorist activities. However, the counter argument is that publicizing a monitoring
system, or other security measures, may be viewed as a challenge to terrorists and may increase
the likelihood of threats, hoaxes,  or attacks. Furthermore, it may provide enough information to
allow a criminal entity to determine which contaminants are being monitored and to simply use a
contaminant that cannot be detected in an attack on a water supply. It has been suggested that
efforts taken to counter terrorism and improve security be put into a context of general
preparedness for a variety of incidents or emergencies (ILSIRI,  1999). This will allow a utility
to communicate efforts that are being taken to ensure continued operation and the safety of the
water supply without focusing on any one specific threat, such as intentional contamination
through terrorist activity.
                                        44                      Interim Final - December 2003

Office of Ground Water and Drinking Water
Water Security Division
December 2003
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on
   100% Postconsumer, Process Chlorine Free Recycled Paper