&EPA
United States
Environmental Protection
Agency
Consequence Management Primer
For Water Quality Surveillance and Response Systems
Office of Water (MC 140)
EPA817-B-15-002E
May 2015
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Consequence Management Primer
Introduction
A Water Quality Surveillance and Response System (SRS) provides a systematic framework for
enhancing distribution system monitoring activities to detect emerging water quality issues and respond
before they become problems. An SRS consists of six components grouped into two operational phases,
surveillance and response. The surveillance components are designed to provide timely detection of
water quality incidents in drinking water distribution systems and include: Online Water Quality
Monitoring, Enhanced Security Monitoring, Customer Complaint Surveillance and Public Health
Surveillance. The response components include Consequence Management and Sampling & Analysis,
which support timely response actions that minimize the consequences of a contamination incident. The
Water Quality Surveillance and Response System Primer provides a brief overview of the entire system
(USEPA, 2015a).
This document provides an overview of Consequence Management (CM), a
response component of an SRS. It presents basic information about the goals
and objectives of CM in the context of an SRS. This primer covers the
following four topics:
• Topic 1: What is CM?
• Topic 2: What are the major design elements of CM?
• Topic 3: What are common design goals and performance objectives
for CM?
• Topic 4: What are cost-effective approaches for CM?
Topic 1: What is CM?
In the context of an SRS, CM consists of actions taken to plan for, investigate, respond to, and recover
from drinking water contamination incidents. These actions, outlined in Figure 1, are meant to minimize
response and recovery timelines through a planned, coordinated effort. CM actions are initiated upon
identification of a possible contamination incident to: (1) establish the credibility of the possible
contamination incident, (2) minimize public health and economic consequences, and (3) guide the
remediation and recovery effort.
I nvestigative Acti ons
Site characterization
Check SRS component alerts
Field and laboratory analyses
Assess outside data sources
Operational Responses and
Notifications
Isolation
Flushing
Public notifications
Remediation and Recovery
Actions
System characteristics
Remedial action
Post-remediation activities
Figure 1. CM Actions Implemented in Response to a Contamination Incident
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Consequence Management Primer
While surveillance components can provide timely detection of possible water contamination, CM
describes the actions that can be implemented to minimize consequences. Additionally, CM seeks to
integrate common elements of existing utility plans and those developed by response partners into a
unified foundation for decision-making during water contamination incidents. Thus, the CM component
is critical to an SRS because it serves as the framework for coordinating and planning with response
partners, thereby optimizing the effectiveness of the overall response.
Topic 2: What are the major design elements of CM?
As illustrated in Figure 2, CM is organized into three design elements that build upon a utility's existing
resources, such as emergency response plans, established relationships with local response partners and
in-house communication equipment.
Incident Response Procedures
Step-wise framework for
investigation and response decision-
making during an incident, and for
communication during an incident
Response Partner Networks
Network to better integrate roles and
responsibilities during incident
response
Communication Equipment and
Methods
Methods for communication and
coordination during incident
response
Figure 2. CM Design Elements
Incident Response Procedures
CM incident response procedures include both a Consequence Management Plan (CMP) and a Risk
Communication Plan (RCP) (USEPA, 2013). The CMP and RCP are focused on incident-specific
procedures for response to and recovery from a drinking water contamination incident and should be
incorporated into a utility's overall Emergency Response Plan (ERP). Figure 3 outlines the general
relationship among a utility's ERP, CMP and RCP.
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Consequence Management Primer
Water Utility
Emergency Response Plan
Communication
Procedures
System Specific
Information
Incident Specific
Action Plans
l~
Contamination
Incident
Roles and
Responsibilities
Other Policies
(e.g., alternate water,
sampling, safety)
1 1
Natural
Disasters
Water Main
Breaks
Fire
Consequence Management Plan
I
Risk Communication Plan
Figure 3. Relationship among a Water Utility's ERP, CMP and RCP
Consequence Management Plan: The CMP documents roles and responsibilities, notification protocols
and response procedures. As Figure 4 illustrates, a CMP guides a utility through actions that should be
taken following detection of a possible water contamination incident. In general, the scope and
significance of these actions increases as the credibility of the incident increases. Thus, a utility-specific
CMP should include sections to address the following three phases of the credibility determination
process:
• Possible Contamination Phase is the investigation of a possible contamination incident to
determine whether additional information corroborates the information from the validated
alert. Information considered during this phase includes the status of other SRS surveillance
components and the results from site characterization, as described in the Sampling and
Analysis Primer (USEPA, 2015b). If the results of the investigation corroborate the initial
alert, contamination is considered credible. Operational response actions may be
implemented in an effort to limit the spread of the contaminant. Additionally, preparations
for public notification may begin during this phase. While proactive surveillance may
discover many possible contamination incidents, only a small percentage of these are
expected to progress to the credible contamination phase.
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Consequence Management Primer
Credible Contamination Phase is the continuation of an investigation to determine whether
a water contamination incident has definitively occurred. The results from the laboratory
analysis are critical to this phase of the investigation. Actions taken during this phase include
expanded operational responses as well as additional sampling and analysis. Public
notification is issued if not already done so during the possible phase. A credible incident is
confirmed when there is definitive evidence, such as positive analytical results, or a
preponderance of evidence demonstrating that the water has been contaminated.
Confirmed Contamination Phase begins once there is definitive evidence that water
contamination has occurred. During this phase, planning for remediation and recovery begins
in earnest. Ongoing communication with the public is essential during this phase to ensure
that the affected population is aware of any water use restrictions, and to keep the public
apprised of progress during remediation.
[Possible
Contamination Phase
Multiple Alerts Indicate
Credible Threat
.
.
Monitor for Multiple
"" SRS Alerts
^
v i
Perform Site
Characterization
r
r
Develop Public As
Notification Strategy 0|
1
i
w
Evaluate Field Results and
Additional Information
1
sess and Implement
>erational Responses
1
1
J Credible
Contamination Phase
i
1
Expand Sampling
Strategy
r
f
Issue Public Notification In
and Revise Strategy o
1
^
f
Evaluate Laboratory Results and
Additional Information
4
Confirmed
Contamination Phase
4
iplement Additional
jerational Responses
1
1
Continue Public Notification
and
Revise as Necessary
> ^ Remediation 4 i Ir
and Recovery O
nplement Additional
aerational Responses
Figure 4. Overview of CMP Phases
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Consequence Management Primer
Risk Communication Plan: An RCP outlines a process for getting the necessary information to the
target audience in an appropriate manner. Communication during a contamination incident is critical and
information must be presented in a timely, accurate and effective manner. The purpose of an RCP is to
guide the utility and its partners regarding:
• When and how to make notifications, including public notifications
• How to identify target audiences and develop messages
• How to work with the media
• How to develop a delivery system for the message
DID You KNOW?
Several utilities who implemented an SRS developed RCPs that supplement their CMPs. An RCP
generally describes the responsibilities of the utility's Public Information Officer during all phases of CM.
An RCP also covers communication within the utility and with external agencies, as well as with the press
and the public. An RCP may include an overview of basic crisis communication principles, CMP decision
trees adapted for use by the Public Information Officer, a section with tools and resources that provide
templates and sample notification documents and contact information.
Response Partner Networks
A robust response partner network provides a framework within which the utility and its response
partners can effectively and efficiently coordinate their respective responsibilities during a water
contamination incident. Figure 5 illustrates the various local, state and federal agencies that may become
involved as a water contamination incident escalates. This configuration reflects the manner in which a
contamination incident is initially investigated by the utility and local responders before involving state,
regional and federal partners as the incident escalates or when local capabilities are overwhelmed.
Federal Bureau of
Investigation
Centers For Disease
Control and Prevention
EPA Regional Offices
EPA Criminal
Investigation Division
Department of
Homeland
Security
State Emergency
Management
and
Homeland Security
Agencies
Local Health Local Wastewater
Department Utility
^~- -\
Local Fire, EMS, / ....
dHazM.it "^
^^ ^
^fc - - ^
Local Emergency Host
Management Facilities
State Law State Drinking and Waste
Enforcement Water Primacy Agencies
Local Law
Enforcement
^1 Local Civil
1 Government
'
Public Health and
Environmental
Laboratories
EPA National Response
Center
State Emergency
Responders
State Government
Neighboring Utilities Media
Figure 5. Example Response Partner Network
The roles and responsibilities section of a CMP describes the responsibilities of the utility as well as local,
state and federal partners. Table 1 provides a general overview of the roles and responsibilities that select
response partners may play in implementing a CMP.
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Consequence Management Primer
Table 1. Typical Responsibilities of Potential Response Partners in a CMP
Partner
Drinking water utility
incident command
Local health department
Local fire departments
and hazardous materials
team (HazMat)
Local law enforcement
Environmental and public
health laboratories
State drinking water and
wastewater primacy
agencies
Local government
Typical Responsibilities
Coordinates and implements overall CM activities including credibility determination,
response actions, and remediation and recovery. Provides appropriate notifications
to response partners.
Supports development of public notifications and serves as a conduit to state and
federal health departments and agencies. Provides information related to health
risks associated with suspected contaminants.
Coordinates with local fire units, helps protect the public and may assist in
distribution of alternate drinking water supply. HazMat may support sampling
activities.
Supports investigation activities by controlling access to a suspected contamination
site. May serve as a conduit to state and federal law enforcement and intelligence
agencies. May assist in distribution of alternate drinking water supply.
Provides analytical support for water samples during response and remediation
efforts. State public health laboratories provide access to the Centers for Disease
Control and Prevention's Laboratory Response Network.
Provides consultation during response and remediation, and advises the utility
regarding regulatory requirements for treating contaminated water, public
notification, environmental concerns about discharged water and the quality of
alternate drinking water supplies.
Communicates with constituencies regarding protective actions, details of the
investigation and updates on recovery efforts.
Communication Equipment and Methods
A variety of equipment and methods can be used to communicate information about a water
contamination incident with both internal and external response partners. Internal communication occurs
among utility employees as well as those persons involved in the investigation of and response to an
incident. External communication involves coordination with outside agencies, as well as populations
potentially impacted by an incident.
Communication equipment and methods can include the following, many of which your utility may
already use:
• Social media
• Landline telephones
• Cell phones
• Email
• Audiovisual systems (including intercoms and
closed-circuit television monitors)
• Written bulletins or newsletters
• Auto-dialer or reverse 911 voice recording
systems
• Hand-held radios
(Photo Credit: Lt. Col. Todd Harrell, 1.12.2014)
Each of these communication channels has inherent positive and negative characteristics, and good
communication planning should incorporate a combination of methods so that various groups of
personnel can exchange required information in a timely manner. When identifying the appropriate
means of communication, the following questions may be considered:
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Consequence Management Primer
• Does the communication method reach all targeted CM participants?
• Is the method reliable?
• Is the method fast enough to support timely decisions and actions?
• Is the method likely to be compromised by the circumstances resulting from a water
contamination incident?
• Is there a back-up or redundant system?
• Will the method preserve information security?
Regardless of the equipment and methods used to disseminate the message, your utility should ensure that
the public and response partners are both receiving and understanding the message. A few quick follow-
up calls to customers and response partners could achieve this as well as monitoring chatter on social
media sites.
Topic 3: What are common design goals and performance objectives
for CM?
The design goals and performance objectives established for CM by the utility provide the basis for the
design of an effective component.
CM Design Goals
Design goals are the specific benefits that utilities expect to achieve by implementing CM. The
fundamental design goal of CM is the ability to investigate, respond to and recover from water
contamination in a timely, efficient and coordinated manner. This goal is realized through the planning
and procedures developed as part of the utility CMP. In addition to this fundamental CM design goal,
other design goals can be established, examples of which are listed in Table 2.
Table 2. Examples of Common CM Design Goals
Design Goal
Strengthened incident command
structure
Improved information sharing and
communications
Strengthened interagency
relationships
Description
Develop a utility incident command structure to respond to all hazards,
while also outlining a unified command structure that integrates response
partner roles and responsibilities.
Establish procedures and protocols in an RCP that allow a utility to
effectively communicate not only with its own personnel, but also with
external stakeholders such as customers and the media. Also, evaluate
and identify any communication shortfalls in advance and work to fill gaps
before an incident occurs. These communication protocols can be
leveraged during response to any type of emergency.
Work collaboratively with public health and emergency response partners
in developing response procedures. This process allows a utility to
establish and develop relationships with local, state and federal partners in
a manner that improves support during any type of emergency.
CM Performance Objectives
Performance objectives are measurable indicators of how well the SRS meets the design goals established
by the utility. Throughout design, implementation and operation of the SRS or its components, the utility
can use performance objectives to evaluate the added value of each capability, procedure or partnership.
While specific performance objectives should be developed by each utility in the context of its unique
design goals, general performance objectives for an SRS are defined in the Water Quality Surveillance
and Response System Primer (USEPA, 2015a) and are further described in the context of CM as follows.
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Consequence Management Primer
• Timeliness of Response: For CM, timeliness of response refers to the time it takes a utility to
verify, characterize and respond to a water contamination incident as detected by one or more of
the SRS surveillance components. Factors that impact this
performance objective include the time it takes to:
o Notify response partners
o Deploy field personnel and equipment
o Collect and screen drinking water samples
o Identify and implement operational responses
o Implement public notification
o Restore the system to normal operations ,„, „ ,. „ „ „ „ , ,, , „„„„„„,„
J F (Photo Credit: Staff Sgt. De-Juan Haley, 1.11.2014)
• Sustainability: Sustainability is usually defined in terms of costs and benefits. CM is not an
equipment intensive component, and thus the cost to implement and maintain this component is
measured in labor hours. Developing the CMP and conducting the exercises entail the most
significant implementation costs, and both require the efforts of utility personnel and response
partners. The cost of maintaining CM may include labor hours associated with coordination of
exercises and training events to maintain readiness for response to possible water contamination
incidents.
Topic 4: What are cost-effective approaches for CM?
Utilities can take the following simple steps to develop the foundation for CM:
• Develop an initial CMP to guide basic actions, such as the formation of the utility incident
command structure and implementation of operational responses.
• Establish a response partner network that includes potential stakeholders and their resources. For
example, USEPA developed a checklist to help identify some items that should be coordinated
with a local emergency management agency before an incident occurs (USEPA, 2012).
• Outline emergency communication and notification procedures such as primary and alternate
communication methods with both internal and external partners. Also, develop drinking water
advisory and public notification templates.
Next Steps
Visit the Water Quality Surveillance and Response Website at http://water.epa.gov/infrastructure
/watersecuritv/lawsregs/initiative.cfm for more information about SRS practices. The Website contains
guidance and tools that will help a utility to enhance surveillance and response capabilities, as well as
case studies that share utility experiences with SRS implementation and operation.
References
USEPA. (2012). Coordination of the Water and Emergency Services Sectors: An Important Step to
Better Response, 817-K-12-001.
USEPA. (2013). Developing Risk Communication Plans for Drinking Water Contamination Incidents,
817-F-13-003.
USEPA. (2015a). Water Quality Surveillance and Response System Primer, 817-B-15-002.
USEPA. (2015b). Sampling and Analysis Primer, 817-B-15-002F.
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