**Emergency Response Plan Guidance for Small and Medium Community Water
Systems** to Comply with the Public Health Security and Bioterrorism
Preparedness and Response Act of 2002

Office of Water (4601M)

EPA 816-R-04-002

www.epa.gov/safewater/security

April 2004 Printed on Recycled Paper

**Disclaimer**: This document is provided as guidance only. It contains
nationally recognized standards on the types of information that should
be contained in an Emergency Response Plan (ERP). EPA recognizes that
sections of this guidance may not be applicable to every Community Water
System (CWS) and all potential situations may not be identified. It is
each CWS's responsibility to evaluate the potential vulnerabilities
related to their system and determine the appropriate responses. As
site-specific needs dictate, this guidance can be modified.

Table of Contents

[Introduction 1](#introduction)

[I. Before You Begin Developing or Revising Your ERP
3](#i.-before-you-begin-developing-or-revising-your-erp)

[II. Emergency Response Plan---Eight Core Elements
4](#ii.-emergency-response-planeight-core-elements)

[A. System Specific Information (Element 1)
4](#system-specific-information-element-1)

[B. CWS Roles and Responsibilities (Element 2)
5](#cws-roles-and-responsibilities-element-2)

[C. Communication Procedures: Who, What, and When (Element 3)
6](#communication-procedures-who-what-and-when-element-3)

[1. Internal Notification List 7](#internal-notification-list)

[2. External Non-CWS Notification List
7](#external-non-cws-notification-list)

[3. Public/Media Notification: When and How to Communicate
8](#publicmedia-notification-when-and-how-to-communicate)

[D. Personnel Safety (Element 4) 8](#personnel-safety-element-4)

[E. Identification of Alternate Water Sources (Element 5)
9](#identification-of-alternate-water-sources-element-5)

[F. Replacement Equipment and Chemical Supplies (Element 6)
11](#replacement-equipment-and-chemical-supplies-element-6)

[G. Property Protection (Element 7) 11](#property-protection-element-7)

[H. Water Sampling and Monitoring (Element 8)
12](#water-sampling-and-monitoring-element-8)

[III. Putting Your ERP Together and ERP Activation
12](#iii.-putting-your-erp-together-and-erp-activation)

[A. Putting All Your Core ERP Elements Into a Single Comprehensive Plan
12](#putting-all-your-core-erp-elements-into-a-single-comprehensive-plan)

[B. ERP Activation 13](#erp-activation)

[IV. Action Plans 15](#iv.-action-plans)

[A. Response to Vulnerability Assessment Findings
15](#response-to-vulnerability-assessment-findings)

[B. Natural Disasters and Other Significant Events
16](#natural-disasters-and-other-significant-events)

[V. Next Steps 16](#v.-next-steps)

[Reproduction of ERP Certification
19](#reproduction-of-erp-certification)

[Glossary 22](#glossary)

Appendix A: Public Communications Strategy

Appendix B: Guarding Against Terrorist and Security Threats - Suggested
Measures for Drinking Water and Wastewater Utilities (Water Utilities)

Appendix C: Example Action Plans

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# Introduction

What is the purpose of this document?

The purpose of this document is to provide guidance on developing or
revising Emergency Response Plans (ERPs) for small- and medium-sized
community drinking water systems. An ERP is a documented plan that
describes the actions that a Community Water System (CWS) would take in
response to various major events. A major event refers to:

-   Credible threats, indications of terrorism, or acts of terrorism;

-   Major disasters or emergencies such as hurricanes, tornadoes,
    storms, earthquakes, fires, flood, or explosion regardless of cause;
    and

-   Catastrophic incidents that leave extraordinary levels of mass
    casualties, damage, and disruption severely affecting the
    population, infrastructure, environment, economy, and government
    functions.

On June 12, 2002, President Bush signed into law the Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (PL
107-188, referred to as the Bioterrorism Act). In the Bioterrorism Act,
Congress recognizes the need for drinking water systems to undertake a
more comprehensive view of water safety and security. The Act amends the
Safe Drinking Water Act and specifies actions CWSs and the U.S.
Environmental Protection Agency (USEPA) must take to improve the
security of the Nation\'s drinking water infrastructure.

CWS characteristics vary greatly, so CWSs should apply the information
contained in this document to meet their particular needs and
circumstances. This document should be used as a flexible template.

Why should a CWS develop or revise an ERP?

Protecting public health is the primary goal of community drinking water
systems, and having an up-to-date and workable ERP helps achieve this
goal in any crisis situation. The Bioterrorism Act amends the Safe
Drinking Water Act (SDWA) by adding, among other requirements, section
1433. Section 1433(b) requires community water systems serving
populations greater than 3,300 to either prepare or revise an ERP that
incorporates the results of its Vulnerability Assessment (VA). The ERP
must include "plans, procedures, and identification of equipment that
can be implemented or utilized in the event of a terrorist or other
intentional attack" on the CWS. The ERP also must include "actions,
procedures, and identification of equipment which can obviate or
significantly lessen the impact of terrorist attacks or other
intentional actions on the public health and the safety and supply of
drinking water provided to communities and individuals."

Who should use this document?

In using the terms "small and medium-sized" within this document, USEPA
is referring to CWS which serve populations from 3,301 to 99,999. A CWS
serving a population from 3,301 to 99,999 should use this document to
either develop or revise its ERP and address findings from its VA. A VA
is also a requirement for a CWS serving a population greater than 3,300
under the Bioterrorism Act. Completing a VA is a necessary step before a
comprehensive ERP can be developed or revised.

[Note: Any reference to "CWS," "you," or "I" in this document is a
reference to a CWS serving a population from 3,301 to 99,999 unless
otherwise noted]{.underline}.

How do I use this document?

This document is divided into five sections that will assist you in
developing or revising your ERP. The sections are:

> **I. Before You Begin Developing or Revising Your ERP:** Describes
> steps and actions you would need to complete before you could
> successfully develop or revise your ERP.
>
> **II. Emergency Response Plan---Eight Core Elements:** Describes core
> elements that are universal to any ERP. If you are beginning to
> develop your ERP, you should use this section as a general template.
> If you have an existing ERP, you can use this section to check if your
> existing ERP is comprehensive and complete. The core ERP elements are:

-   System Specific Information;

-   CWS Roles and Responsibilities;

-   Communication Procedures: Who, What, and When;

-   Personnel Safety;

-   Identification of Alternate Water Sources;

-   Replacement Equipment and Chemical Supplies;

-   Property Protection; and

-   Water Sampling and Monitoring.

> **III. Putting Your ERP Together and ERP Activation:** Describes steps
> and issues you need to address once you have all your core ERP
> elements in place and how to put these elements together into a single
> comprehensive plan. Additionally, you will need to understand the
> types of events that will trigger use of the plan. An effective ERP
> now needs to address intentional acts of terrorism as well as other
> emergencies and natural disasters. Planning for these events makes
> developing, updating, and deciding to activate the ERP more
> challenging than in the past.
>
> **IV. Action Plans:** Describes how Action Plans (AP) are developed
> and used to tailor emergency response actions to specific incidents or
> events. Under the Bioterrorism Act, you are required to address the
> findings of a VA in an ERP. An AP identifies the steps to take to
> address specific vulnerabilities and respond to a given incident.
>
> **V. Next Steps:** Describes steps to take after completing an ERP,
> for example, submitting a certification to EPA, conducting training,
> and updating your plan.

Will my ERP contain sensitive information?

Your ERP may contain sensitive information, so you should consider steps
you need to take to ensure the security of your ERP. Sensitive
information should be placed in appendices, or in sections that are not
readily available to unauthorized personnel. The ERP, however, should be
easily accessible to authorized personnel and should be easily
identifiable during a major event. Steps taken to limit access by
unauthorized persons should consider local and state Freedom of
Information Act (FOIA) laws. Alternatively, you can opt to make your ERP
general in nature so that everyone can use it and not include specific
information about system vulnerabilities.

A secure copy of your ERP should be maintained in an off-premises
location in the event that your primary copy cannot be accessed.

# I. Before You Begin Developing or Revising Your ERP

What steps do I need to take before I start to develop or revise my ERP?

Before you begin to develop or revise your ERP, there are two steps that
you need to take. First, you need to have completed a VA as required
under the Bioterrorism Act. The findings from your VA will be addressed
in your ERP through specific Action Plans (AP), which are discussed in
detail in Section IV, "Action Plans."

Second, you should identify and coordinate with first responders and ERP
partners who will help and assist you during a major event. As required
by Section 1433(b) of the Bioterrorism Act, partners should include, to
the extent possible, Local Emergency Planning Committees (LEPCs)
established under the Community Right-to-Know Act such as local law
enforcement departments, fire departments, health departments, local
environmental agencies, hospitals, broadcast and print media, community
groups, and nearby utilities. Other partners could include State and
Federal agencies, and laboratories. **Figure I-1** shows local entities
(in the shaded area) as well as State and Federal entities (in the white
area) that may assist you during a major event. EPA strongly recommends
that you consult with local and State entities as you develop your ERP.
The purpose of the consultation is to form partnerships and seek advice.
Through these partnerships, each party knows and understands its role
and responsibilities in emergency situations. These partnerships help
everyone respond better to an emergency.

![](media/image1.wmf)

Are there any tools, training courses, or guides that can assist me in
either developing or revising my ERP?

Emergency response has been around for quite some time, so many tools,
training courses, and guides already exist on the topic of developing an
ERP. Possible resources on how to develop or revise sections of your ERP
include the following (see also the "References and Links" section of
this document):

-   ERP material from other Federal agencies \[for example, Incident
    Command System information from the Federal Emergency Management
    Agency (FEMA) and the Department of Homeland Security (DHS)\];

-   State ERP guidance;

-   Risk Management Plans as required by the Clean Air Act section
    112(r) (if applicable to your CWS);

-   Water association ERP guides and training courses; and

-   USEPA's Response Protocol Tool Box (for water contamination
    incidents)
    <http://www.epa.gov/safewater/security/index.html#emergency>.

Many of the above resources address specific topics or subject areas in
greater detail than this guidance document. Again, the purpose of this
guidance document is to help produce a single comprehensive ERP that
would meet the response needs of a variety of events. Use ERP resources
available to you to help build a single and comprehensive ERP that
includes response actions to terrorist or other intentional events.

# II. Emergency Response Plan---Eight Core Elements

What does USEPA mean by "ERP core elements"?

Core elements form the basis, or foundation, for responding to any major
event. USEPA has identified eight core elements common to an ERP that
you should plan to utilize or bring to bear during water emergencies.

1.  System Specific Information;

2.  CWS Roles and Responsibilities;

3.  Communication Procedures: Who, What, and When;

4.  Personnel Safety;

5.  Identification of Alternate Water Sources;

6.  Replacement Equipment and Chemical Supplies;

7.  Property Protection; and

8.  Water Sampling and Monitoring.

If you already have an ERP in place and just need to revise it, use the
following sections to check if you are missing any key information. If
you are just beginning to develop your ERP, use the following sections
as a general template for what should be included in your ERP. Use the
following sections to develop or revise your ERP according to your
needs.

## System Specific Information (Element 1)

Why do I need to keep system-specific information on hand?

During a major event, you need to have basic technical information
readily available for your personnel, first responders, repair
contractors/vendors, the media, and others. The information needs to be
clearly documented and readily accessible so your staff can find and
distribute it quickly to those who may be involved in responding to the
major event. The location of critical documents, such as distribution
maps, detailed plan drawings, site plans, source water locations, and
operations manuals, should be identified and readily available during a
major event. You should have located and reviewed much of this
information while conducting your VA, so the ERP should only need to
identify it.

What basic information do I need to have?

Basic information that may be presented in an ERP includes:

1.  Public Water System (PWS) ID, Owner, Administrative Contact Person,
    Alternate Administrative Contact Person;

2.  Population Served and Service Connections;

3.  Distribution Map;

4.  Pressure Boundary Map;

5.  Overall Process Flow Diagrams;

6.  Site Plans and Facility "As-Built" Engineering Drawings

    a.  Pumping and Storage Facilities

    b.  Reservoirs and Retention Facilities

    c.  Water Treatment Facilities

    d.  Booster Pump Stations

    e.  Pressure-Regulating Valve (PRV) Sites

    f.  Distribution System Process and Instrumentation Diagrams (P&ID)

    g.  Equipment and Operations Specifications

    h.  Emergency Power and Light Generation

    i.  Maintenance Supplies

7.  Operating Procedures and System Descriptions including back-up
    systems and interconnections with other systems;

8.  Supervisory Control and Data Acquisition (SCADA) System/Process
    Control Systems Operations;

9.  Communications System Operation;

10. Site Staffing Rosters and Employees' Duties and Responsibilities;
    and

11. Chemical Handling and/or Storage Facilities and Release Impact
    Analyses (i.e., chemical releases into air or water).

It is important to note that not all of this technical information may
be needed to document how you operate. The level of technical
documentation should reflect the complexity of your CWS.

## CWS Roles and Responsibilities (Element 2)

What roles and responsibilities do I need to define?

You should designate an Emergency Response Lead (ER Lead) and Alternate
ER Lead. The ER Lead will be the main point of contact and
decision-maker during a major event. This person will have
responsibility for evaluating incoming information, managing resources
and staff, and deciding on appropriate response actions. This person
will also have the responsibility of coordinating emergency response
efforts with first responders. The ER Lead should be heavily involved in
forming the partnerships described in Section I, "Before You Begin
Developing or Revising Your ERP."

You should also identify an Alternate ER Lead who would step in should
the ER Lead be unavailable. The ER Lead and the Alternate ER Lead need
to be reachable 24 hours a day, seven days a week. A clear chain of
command, or command structure, should also be established so that
personnel and staff know their individual roles and responsibilities. If
you have the resources and staff, you may consider forming an ER team
that uses a well-defined command structure. At a minimum, your ERP
should include the following basic information:

  ------------------ ---------------- ------------------ -----------------
  Name of ER Lead                     Name of Alternate  
                                      ER Lead            

  Work Telephone No.                  Work Telephone No. 

  Home Telephone No.                  Home Telephone No. 

  Cell Phone No.                      Cell Phone No.     

  Pager No.                           Pager No.          

  Radio Call No.                      Radio Call No.     
  ------------------ ---------------- ------------------ -----------------

I saw a reference to a Water Utility Emergency Response Manager (WUERM)
in another USEPA document. What is a WUERM?

A WUERM is basically your ER Lead. An ER Lead can have a variety of
titles but the basic role and responsibility of the ER Lead does not
change. Do not get confused or bogged down with titles and terminology.
The main contact person and decision-maker during a major event is the
ER Lead, regardless of job title.

What is an Incident Command System (ICS)? Do I need to have ICS?

Briefly, ICS is the model tool for command, control, and coordination of
an emergency response and provides a means to coordinate the efforts of
first responders as they work toward the common goal of stabilizing a
major event and protecting life, property, and the environment. ICS uses
a well-defined command structure in order to specify roles and
responsibilities in responding to a major event. In ICS, the main
contact person and decision-maker is the Incident Commander. At the CWS
level, the ER Lead has the role of Incident Commander, unless the
incident is of such significance that local, State, or Federal officials
take over the command. You could use ICS to help organize yourself and
your ER team, whether the team consists of staff from your CWS or other
emergency responders. You do not need to have a complex command
structure in place, but one that reflects your capabilities and also
works effectively.

First responders may use ICS when responding to a major event. Your
State may also have adopted ICS to respond to major events, and you may
be required to abide by this command structure. If you are not required
to use ICS, you should be familiar with ICS terms and command structure
at a minimum. Other first responders may take over the role and
responsibilities of Incident Commander in the latter stages of a major
event, and you should know how this affects your role and
responsibilities. You (or more appropriately the ER Lead) should address
roles, responsibilities, and the command structure when forming the
partnerships described in Section I, "Before You Begin Developing or
Revising Your ERP."

More information on ICS can be obtained from FEMA at
<http://training.fema.gov/EMIWeb/IS/is195.asp>. Federal departments and
agencies use an ICS under the National Incident Management System
(NIMS)(<http://www.dhs.gov/dhspublic/interweb/assetlibrary/NIMS-90-web.pdf>).

## Communication Procedures: Who, What, and When (Element 3)

What communication procedures do I need to have in place?

Appropriate and timely communication is essential during an emergency.
The ERP should identify clear communication channels for CWS staff and
personnel, external non-CWS entities, and the public/media. As part of
your ERP, you should maintain internal and external notification lists
that contain information on all appropriate entities to be contacted,
including their names, titles, mailing addresses, e-mail addresses, all
applicable land line and cellular phone numbers, and pager numbers.
These lists should be updated as necessary. In a major event (e.g., a
terrorist attack), it may not be possible to use normal channels of
communication. Provisions need to be made for an efficient and fail-safe
form of communication to be available during conditions when the use of
normal means may not be possible. Communication procedures with the
public and media may already be part of your day-to-day operations, but
these procedures need special attention during a major event in order to
provide the public and media with timely, accurate, and complete
information.

### Internal Notification List

Who should be on my internal notification list?

The ER Lead and the Alternate ER Lead should be the first persons
notified, because responding to a major event is their primary
responsibility. If you have an ER team, then team members should be
notified as well. Your ER team should consist of essential CWS personnel
to be notified during an emergency. You should notify CWS management.
Your internal notification list also should clearly identify all
appropriate staff and personnel to be notified. Internal notification
lists should include the name of the employee, work and home telephone
numbers, and any other numbers at which the employee can be reached,
such as cell phone, pager, or radio phone.

### External Non-CWS Notification List

Who should be on my external non-CWS notification list?

Your external non-CWS notification list should ensure that all
appropriate first responders and affected customers or critical users
are notified. Procedures should also be established as to who should be
notified, when they should be notified, and who is responsible to make
the notifications from your CWS.

Below is a short list of possible first responders. These organizations
are not listed in any particular order of preference.

-   Local

> \- Local 911
>
> \- Police
>
> \- Fire
>
> \- Local Emergency Planning Committee (LEPC)
>
> \- Elected Officials
>
> \- Power Utility
>
> \- Hazardous Materials (HAZMAT) personnel

-   State

> \- Drinking Water Primacy Agency
>
> \- Department of Health

-   State 24-hr Emergency Communications Center Telephone

-   State Office of Homeland Security

> \- HAZMAT
>
> \- State Police

-   Federal

> \- FBI
>
> \- EPA Headquarters and Regional Office
>
> \- Department of Homeland Security (DHS)
>
> \- Department of Health and Human Services (HHS)
>
> \- National Response Center (800-424-8802, <http://www.nrc.uscg.mil/>)

-   Other

> \- Water Information Sharing & Analysis Center
> (<http://www.waterisac.org/>)

When you are identifying the list of groups to be notified during a
major event, critical users (e.g., hospitals) and commercial and
industrial customers such as those that incorporate water into their
product (e.g., bottling and canning companies), should also be
considered. You should maintain a list of critical users as part of your
ERP. Some of these users should be given priority notification due to
their public health mission and because they may serve customers
considered "sensitive sub-populations" (e.g., senior residential
housing, child care centers, medical facilities). Specific notification
procedures should be developed for these groups.

### Public/Media Notification: When and How to Communicate

What special items or issues do I need to consider when communicating
with the public and media?

Effective public and media communications is a key element of your ERP.
You should designate in advance who the CWS spokesperson will be during
a major event. The spokesperson should be someone who is knowledgeable
and credible, has good communication skills, and, if possible, is not a
key person needed for implementing ERP response actions during the major
event. In communicating with the media, the lead spokesperson may be
someone external to the CWS if another organization has taken over the
role of lead agency or Incident Commander (e.g., a representative from
the health department or the State Drinking Water Primacy Agency). You
should consider having both field and office staff respectfully defer
questions to the designated spokesperson.

You can plan now for public and media notification needs by developing a
communication plan or strategy for the spokesperson to follow. The
communication plan or strategy should be a set of general guidelines for
the spokesperson to follow in order to craft clear and concise messages
for the public and to also deal with the media. The communication plan
or strategy should be targeted to reach several audiences, such as your
customers (both residential and business), local health professionals,
and others. You can draft press releases and public water restriction
notices in advance. The key to remember is that your message should be
clear, accurate, and easily understood by your audience. Appendix A
presents additional guidance on recommended communications plans or
strategies.

## Personnel Safety (Element 4)

Why do I need to address personnel safety in my ERP?

Protecting the health and safety of everyone in your CWS as well as the
surrounding community is a key priority during an emergency. During an
emergency, personnel may be at risk of harm, injury, or even death. This
section of your ERP should provide direction personnel on how to safely
implement a variety of response actions.

What procedures should the plan describe to provide for personnel
safety?

When considering personnel safety the following factors should be taken
into account:

-   ***Evacuation Planning***: Develop a CWS evacuation policy and
    procedures.

-   ***Evacuation Routes and Exits***: Designate primary and secondary
    evacuation routes and ensure that they are clearly marked, well lit,
    unobstructed at all times, and unlikely to expose evacuating
    personnel to additional hazards.

-   ***Assembly Areas and Accountability***: Obtaining an accurate
    account of personnel requires planning and practice. Designate
    assembly areas where personnel should gather after an evacuation and
    specify procedures for taking a head count and identifying
    personnel.

-   ***Shelter***: In some major events, the best means of protection is
    to take shelter (also known as shelter in place) either within the
    CWS or away from the CWS in another building.

-   ***Training and Information***: Train staff and personnel in
    evacuation, shelter, and other safety procedures.

-   ***Emergency Equipment***: Consider developing written procedures
    for using and maintaining your emergency response equipment. This
    should apply to any emergency equipment relevant to a response
    involving a toxic chemical, including all detection and monitoring
    equipment, alarms and communications systems, and Personal
    Protective Equipment (PPE) not used as part of normal operations.

-   ***First Aid***: Discuss proper first aid and emergency medical
    treatment for employees and others who are onsite at the CWS. This
    should include standard safety precautions for victims as well as
    more detailed information for medical professionals. Indicate also
    who is likely to be responsible for providing the appropriate
    treatment (i.e., an employee with specialized training or a medical
    professional).

Are there other sources of information that can help me with developing
personnel safety procedures?

You should focus on standard Occupational Safety and Health
Administration (OSHA), Spill Prevention Control and Countermeasures
(SPCC), Risk Management Program (RMP), and State procedures to define
your own personnel safety procedures. Your staff should understand when
to evacuate, when and how to use PPE, and how to rapidly locate
additional safety information, such as chemical-specific Material Safety
Data Sheets (MSDS). You also could consult with other utilities and
water organizations.

##  Identification of Alternate Water Sources (Element 5)

What should I consider when identifying alternate water sources in my
ERP?

You should consider the amount of water needed to address short-term
(hours to days) and long-term (weeks to months) outages. As part of your
ERP, you should identify the alternate water supplies available to you
during both types of outages. To do this, you need to have a
comprehensive understanding of your current water supply, your water
distribution system, and your water system demand requirements. You
should clearly understand the location and capabilities of other
regional CWS, including available excess capacity and ease of connection
to your distribution system. In addition, you should also understand the
interconnection agreements your partners have in place and potential
issues that could arise if multiple CWS are affected. These are
important issues that should be addressed when you are forming the
partnerships described in Section I, "Before You Begin Developing or
Revising Your ERP."

What should I consider for short-term outages?

Short-term outages might be due to contamination or electrical power
outages. If your CWS has been contaminated, a public health notification
such as "boil water," "do not drink," or "do not use," may be issued by
the drinking water primacy agency. If a "boil water" notice is issued,
no alternative water source is needed. If a "do not drink" order is
issued, then the suspect water can still be used for other activities
that do not involve ingestion of the water. In this situation, it will
only be necessary to provide an alternate drinking water supply for
consumption and related activities such as food preparation.

A "do not use" order is much more restrictive. You will need sufficient
alternate water sources to supply water for consumption, hygiene, and
emergency needs. A "do not use" notice may also have implications with
respect to water used for firefighting. Although a prohibition on use of
water for firefighting is likely to occur only if the water is
contaminated with certain substances, an alternate source of
firefighting water, such as a pond, river, or stream, may be necessary
in this event.

As part of your ERP, you should consider the potential effects of a
power outage. Your utility could be without power due to a major event,
and it may take several days for power to be restored. Your plan should
include contingencies for back up power generation and alternative power
sources.

As part of your ERP, you also should identify agencies or private
companies that could provide water supplies (bottled or bulk) in the
event of a major event and establish mutual aid agreements with
surrounding communities, industries, contractors and related utilities
as appropriate. Your source list should be maintained to include
accurate information on points of contacts for the alternate sources.
Possible short-term alternate water supply options include (but are not
limited to) the following:

-   Bottled water provided by outside sources;

-   Bottled water provided by local retailers;

-   Bulk water provided by certified water haulers;

-   Bulk water transported or provided by military assets (i.e.,
    National Guard or U.S. Army Corps of Engineers (USACE));

-   Bulk water provided by neighboring water utilities by truck or via
    pipeline;

-   Bulk water from hospitals, universities, and local industry that
    maintain backup water supplies for consumption;

-   Interconnections with nearby public water systems;

-   Water treated by plant and hauled to distribution centers (i.e., in
    the case of water distribution system contamination);

-   Water pumped from surface water sources, treated at the plant or
    nearby plants, and hauled to distribution centers;

-   Water for firefighting from Federal agencies such as the USACE and
    FEMA; and

-   Water from unaffected wells owned by local citizens and businesses.

Additional equipment may be available from:

-   Local businesses such as dairies, well drillers, irrigation supply
    firms, or distributors that may have tank trucks that can be made
    suitable for carrying water, chlorinators or generators that can be
    used for emergency disinfection, and pipe that can be used to extend
    water supply lines.

-   Other water utilities in the area that may have spare parts (such as
    valves, pumps, and pipe) available for use in an emergency.

-   FEMA, USACE, and the U.S. Forest Service that may be able to provide
    firefighting equipment.

You may also want to plan for water conservation measures to be used if
a major event causes a reduction in service or a "do not use" notice is
issued. For example, if a major event causes a reduction in service, you
could limit water use by advising customers not to do laundry, run the
dishwater, or water the garden and to limit the duration of showers. To
plan for a "do not use" notice, you could advise consumers to maintain
an emergency supply of water, such as keeping a certain amount of
bottled water in their homes.

What should I consider for long-term water outages?

If your CWS will need extensive cleaning, or if portions of the system
have been destroyed, you will need a long-term alternate water supply.
The following are examples of possible long-term water supply options:

-   Connection of the water distribution system to an existing municipal
    or private water supply (assumes existing water treatment plant and
    distribution system is intact and useable);

-   Connection of the water distribution system with a new
    uncontaminated groundwater or surface water source (assumes existing
    water treatment plant and distribution system is intact and
    useable);

-   Development of new water distribution system (assumes existing water
    treatment plant and source water is uncontaminated and useable); and

-   Development of oversized community storage facilities to compensate
    for loss of existing system capacity.

## Replacement Equipment and Chemical Supplies (Element 6)

What pieces of equipment and chemical supplies do I need to identify in
my ERP?

Your ERP should identify equipment that can significantly lessen the
impact of a major event on public health and protect the safety and
supply of drinking water. You should maintain an updated inventory of:

-   Current equipment (e.g., pumps);

-   Repair parts;

-   Chemical supplies for normal maintenance and operations; and

-   Information on mutual aid agreements.

Based on the findings of your VA, you should identify how and where to
find the equipment, repair parts, and chemicals that you would need to
respond adequately to a particular vulnerability. You should consider
establishing mutual aid agreements with other CWS to address any
deficiencies. These agreements should identify the equipment, parts, and
chemicals available to you under the agreement.

##  Property Protection (Element 7)

Why do I need to address property protection in my ERP?

Protecting CWS facilities, equipment and vital records is essential to
restoring operations once a major event has occurred. Your ERP should
identify measures and procedures that are aimed at securing and
protecting your CWS following a major event. Items that should be
considered include:

-   "Lock down" procedures;

-   Access control procedures;

-   Establishing a security perimeter following a major event;

-   Evidence protection measures for law enforcement (should the major
    event also be declared a crime scene);

-   Securing buildings against forced entry; and

-   Other property protection procedures and measures.

## Water Sampling and Monitoring (Element 8)

What water sampling and monitoring issues do I need to address in my
ERP?

Water sampling and monitoring should be an integral part of your ERP and
not an afterthought. How else can you determine whether the drinking
water that you supply is safe for public consumption and use? During the
stage of forming partnerships described in Section I, "Before You Begin
Developing or Revising Your ERP," you should consult with your State
Drinking Water Primacy Agency on the issues of water sampling and
monitoring. In your ERP you will need to identify and address special
water sampling and monitoring issues that may arise during and after a
major event. Some water sampling and monitoring issues to consider
include:

-   Identifying proper sampling procedures for different types of
    contaminants;

-   Obtaining sample containers;

-   Determining the quantity of required samples;

-   Identifying who is responsible for taking samples;

-   Identifying who is responsible for transporting samples (in time
    sensitive situations);

-   Confirming laboratory capabilities and certifications; and

-   Interpreting monitoring or laboratory results.

For a more detailed discussion on water sampling and monitoring issues,
please see USEPA's Response Protocol Tool Box Module 3, "Site
Characterization and Sampling Guide" (EPA-817-D-03-003) at
<http://www.epa.gov/safewater/security/pdfs/guide_response_module3.pdf>
and Module 4, "Analytical Guide" (EPA-817-D-03-004) at
<http://www.epa.gov/safewater/security/pdfs/guide_response_module4.pdf>

# III. Putting Your ERP Together and ERP Activation

##  Putting All Your Core ERP Elements Into a Single Comprehensive Plan

I have addressed all my core ERP elements. What do I do next?

You now want to organize and document all the information that you
gathered or produced while addressing your core ERP elements. Your goal
is to produce a single comprehensive ERP document that is accessible to
appropriate personnel, and that can be updated or modified as the need
arises. Your ERP document may be organized into:

-   Overall ERP polices;

-   General ERP procedures;

-   Any mutual aid agreements;

-   Reference documents; and

-   Action Plans (see Section IV, "Action Plans," for more details).

How you ultimately organize and document your ERP is up to you and can
depend on whether you are developing an ERP from scratch, or are
revising an existing ERP. Other Federal and State requirements may also
influence how you organize and document your ERP. The Bioterrorism Act
requires that you maintain a copy of your ERP for five years after you
have sent your ERP certification to USEPA (see also Section V, "Next
Steps"). A secure copy of your ERP should also be maintained in an
off-premises location in the event that your copy cannot be accessed.

##  ERP Activation

What is "ERP Activation" and why is it important?

Knowing when to activate or set your ERP in motion is as important as
having a prepared and documented ERP. In the past, emergency response
mostly dealt with emergencies such as natural disasters and accidents.
The definition of a "major event" in this guidance includes a major
disaster or other emergency as well as a terrorist attack. Being
prepared to respond to a terrorist attack requires special attention.
This section discusses ways in which you may learn about a threat, the
threat decision process, and activation of your ERP.

What things should I pay special attention to before activating my ERP?

![](media/image2.png){width="1.5692913385826772in"
height="2.333464566929134in"}You should pay attention to any "threat
warning." The Homeland Security Advisory System shown in **Figure
III-1** contains five threat condition levels. Low Condition (Green) is
declared when there is a low risk of terrorist attacks. Guarded
Condition (Blue) is declared when there is a general risk of terrorist
attacks. Elevated Condition (Yellow) is declared when there is a
significant risk of terrorist attacks. High Condition (Orange) is
declared when there is a high risk of terrorist attacks. Finally, Severe
Condition (Red) reflects a severe risk of terrorist attacks. EPA has
issued supplemental guidance for water utilities to increase security
based on threat conditions described by the five-tiered Homeland
Security Advisory System (see Appendix B).

A "threat warning" is an occurrence or discovery that indicates a threat
of a malevolent act and triggers an evaluation of the threat. These
warnings should be evaluated in the context of typical CWS activity and
previous experience in order to avoid false alarms. The threat warnings
presented in **Figure III-2** and described below are intended to be
inclusive of those most likely to be encountered, but this listing is by
no means comprehensive of all possibilities.

![](media/image3.wmf)

-   ***Security Breach***. Physical security breaches caused by lax
    operations such as unsecured doors or criminal acts such as
    trespassing are probably the most common threat warnings.

-   ***Witness Account***. You or your neighbors may see suspicious
    activity, such as trespassing, breaking and entering, and other
    types of tampering.

-   ***Notification by Perpetrator***. A threat may be made directly to
    you, either verbally or in writing. Historical incidents indicate
    that verbal threats made over the phone are more common than written
    threats.

-   ***Notification by Law Enforcement***. You may receive notification
    about a threat directly from law enforcement, whether it is county,
    local, State, or Federal. Such a threat could be a result of a
    report of suspicious activity or through information gathered by law
    enforcement.

-   ***Notification by News Media***. A threat 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 law
    enforcement and either the reporter or law enforcement would
    immediately contact the CWS.

-   ***Unusual Water Quality***. You should investigate possible causes
    of unusual water quality (i.e., changes from baseline). You want to
    rule out unusual results that can be explained or those that are due
    to known causes.

-   ***Consumer Complaint***. An unexplained or unusually high incidence
    of consumer complaints about the aesthetic qualities of drinking
    water may indicate a potential threat. Many chemicals can impart a
    strong odor or taste to water, and some may discolor the water.

-   ***Public Health Notification***. The first indication that a
    water-related incident has occurred may involve victims showing up
    in local emergency rooms and health clinics. 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.

What do I do once I discover a threat warning?

Once a threat warning is received, the threat decision (or threat
evaluation) process begins. The ER Lead or Alternate ER Lead should be
notified immediately because they will be involved in this decision
process and make decisions about who else (e.g., other emergency
responders) should be involved. The threat decision process is
considered in three successive stages: 'possible', 'credible', and
'confirmed'. As the situation escalates through these three stages, the
actions that might be considered also change. The following describes
the stages, actions that might be considered, and activation of your
ERP.

-   **Stage 1: "Is the threat 'possible'?"** If you are faced with a
    threat, you 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. Knowing the
    findings from your VA could help you determine whether a certain
    threat is possible or not.

-   **Stage 2: "Is the threat 'credible'?"** There must be information
    to corroborate the threat in order for it to be considered credible.
    For example, your information source may be highly credible,
    hospitals may be reporting a potential incident, or your may have
    monitoring results that are unusual. At this stage, you may activate
    additional portions of your ERP, such as initiating internal and
    external notifications, conducting water sampling and analysis, or
    issuing public health advisories. At this stage, you're not sure
    whether a major event has occurred but are preparing to respond
    should the threat actually lead to a major event.

-   **Stage 3: "Has the incident been 'confirmed'?"** Confirmation
    implies that definitive evidence and information has been collected
    to establish that an incident has occurred. Confirmation of an
    incident may be obvious, such as structural damage to a CWS; in such
    a case, Stages 1 and 2 would be omitted. Upon confirmation of the
    incident, you should fully implement your ERP. Your ERP should
    contain Action Plans (see Section IV) that address specific major
    events, and these Action Plans should be implemented immediately.

The application of this threat decision process will vary significantly
with the circumstances. The ER Lead should work through the threat
decision process and implement the ERP as needed. In summary, judgment
must be exercised when determining how to appropriately manage a
specific threat or incident.

# IV. Action Plans

What are Action Plans?

Action Plans (APs), also known as Response Guidelines, are tailored ERPs
that address specific major events. APs describe response actions to
take for events that you think might occur at your facility based on the
specific vulnerabilities identified in your VA.

An AP should provide a quick approach for responding to a specific major
event and it complements actions already initiated under the ERP. You
may only need one to two pages to cover specific response information
since you have already addressed basic emergency response steps in the
core elements of your ERP. An AP should be an accessible (i.e., "rip and
run") document that can be detached and taken to the field by the ER
Lead or Alternate ER Lead. An AP should include the following basic
information:

-   Any special notification requirements;

-   Special response steps to be taken upon ERP activation; and

-   Recovery actions to bring the CWS back into operation.

## Response to Vulnerability Assessment Findings

How do I go about developing Action Plans for my VA findings?

The Bioterrorism Act requires that prepared or revised ERPs incorporate
the results of completed VAs. During the VA process, you should have
determined your high priority vulnerabilities. An Action Plan defines
the specific actions you would take to respond to events where your high
priority vulnerabilities have been compromised. In addition, we
recommend that you develop APs for certain high consequence events
regardless of whether these are among your high-priority
vulnerabilities. Events and threats of events that should be considered
in APs include the following:

-   Contamination of the Drinking Water;

-   Structural Damage/Physical Attack;

-   SCADA, Computer, or Cyber Attack; and

-   Intentional Hazardous Chemical Release (e.g., release of chlorine or
    ammonia from storage).

Even if your VA did not identify any vulnerabilities, you are encouraged
to consider contingency planning for the possibility of these events.

Example Action Plans for the four intentional events listed above are
included in Appendix C. Each AP goes through the threat decision process
described in Section III.B, "ERP Activation." It should be noted that
these simplified examples are for discussion purposes only and that you
should develop "Action Plans" specific to the needs of your water system
and surrounding community. You also could consult EPA's Response
Protocol Toolbox,
<http://www.epa.gov/safewater/security/index.html#emergency>, as an aid
in developing APs for contamination events.

So, what about all of the sensitive information in my Action Plans
referring to my vulnerabilities?

APs should be easily accessible to authorized personnel and should be
easily identifiable during a major event. However, you may want to limit
access to APs containing sensitive information and specifics related to
intentional events. Again, steps taken to limit such access should
consider local and state Freedom of Information Act (FOIA) laws.
Alternatively, you can opt to make your APs general in nature so that
everyone can use them and place sensitive information in the ERP
appendices, or in sections that are not readily available to
unauthorized personnel.

## Natural Disasters and Other Significant Events

#### How should my ERP deal with natural disasters and other emergencies?

If you already have an ERP in place to address other major events, you
may want to tailor response actions in light of discussions in this
section. You may wish to develop individual Action Plans for other major
events that are not terrorist-related. A similar approach to that
described above could be used to plan for natural disasters and other
significant events. Natural disasters and other significant events
include:

-   Fire;

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-   Flood;

-   Hurricane and/or Tornado;

-   Severe Weather (snow, ice, temperature, lightning, drought);

-   Earthquake;

-   Electrical Power Outage;

-   Mechanical Failure;

-   Water Supply Interruption;

-   Contaminated Water Treatment Chemicals;

-   Accidental Hazardous Chemical Spill/Release;

-   Construction Accidents;

-   Personnel Problems (Loss of operator, medical emergencies);

-   Vandalism; and

-   Unintentional Contamination of the Water Supply (e.g., waterborne
    disease outbreak, accidental cross connections, etc.).

# V. Next Steps 

What do I do once my ERP is completed or revised?

Once you prepare or revise your ERP, you are required under the
Bioterrorism Act to submit a written certification stating that the plan
has been completed by a certain deadline date. (Do not submit a copy of
the ERP to EPA.) USEPA has produced a separate document that addresses
ERP certification submittal entitled *Instructions to Assist Community
Water Systems in Complying with The Public Health Security and
Bioterrorism Preparedness and Response Act, Title IV*. Please consult
this document to answer your specific questions about submittal
procedures and deadline dates. This document can be found at
<http://www.epa.gov/safewater/security/community.html>. A copy of the
ERP certification is presented at the end of this section.

Additionally, as required under Section 1433(c) of the Bioterrorism Act
you must maintain a copy of your ERP for five (5) years after you submit
your ERP certification to USEPA.

Where do I send my signed ERP Certification?

We recommend that you submit the ERP certification using an express or
courier service such as Federal Express, United Parcel Service,
Airborne, etc., which provides tracking and certification of delivery.
Using one of these services will ensure that the submission is delivered
directly to the persons authorized to receive and process these items.

Use the following address for express or courier service deliveries to
USEPA. This location is open for deliveries between 8:30am and 4:30pm
Eastern Time. Call the number under the address below before attempting
delivery outside of those hours.

> U.S. Environmental Protection Agency
>
> Water Resource Center (WSD-RAR)
>
> Room 1119 EPA West Building
>
> 1301 Constitution Ave., NW
>
> Washington DC 20004

Couriers are to use phone number 202-566-1729.

As stated above, more detailed guidance on preparing and submitting the
ERP certification can be found at
<http://www.epa.gov/safewater/security/community.html>.

What additional State requirements must I meet?

Depending on your State, you may be required to provide a copy of your
ERP to State authorities or certify that you have completed or revised
your ERP. You should coordinate with your State Drinking Water Primacy
Agency to determine what requirements apply to your CWS.

When should I update my ERP?

It is important to note that an ERP is a "living" document that you
should update periodically (i.e., at least annually or if there is a
major change to your CWS configuration). The ER Lead and appropriate CWS
management staff should approve the ERP and identify the time period for
routinely updating the ERP (e.g., annually). Updates should occur if
there are changes in CWS staff, internal and external contacts, roles
and responsibilities of anyone involved in response, or there are
changes made in infrastructure.

If you update your ERP, you are not required to resubmit a written ERP
certification to the USEPA.

What type of training is appropriate?

You should make sure that your staff is trained on their ERP
responsibilities. Training can include briefing sessions, classroom
sessions, or mock exercises. You should also remember to do "refresher"
training on a regular basis. Training should include testing of the ERP.
Drills and exercises that challenge the information in the ERP should be
conducted at least annually. There are many sources (State, Federal, and
industry specific) that describe what should be included in emergency
training. These typically include the following four types of training:

-   **Orientation Sessions**: Orientation sessions work well for basic
    instruction and explaining ERP procedures. Written tests may be
    employed to ensure some level of comprehension by the attendees.

-   **Table-Top Workshop**: Table-top workshops involve developing
    scenarios that describe potential problems and provides certain
    information necessary to address the problems. The idea is to
    present staff and emergency response officials with a fabricated
    event, have them verbally respond to a series of questions, and then
    evaluate whether the responses match what is written in the ERP.

-   **Functional Exercises**: The Functional Exercise is considered the
    most effective training tool, next to a real emergency, because a
    team of simulators is trained to develop a realistic major event. By
    using a series of pre-scripted messages, the simulation team sends
    information in to personnel assigned to carry out the ERP
    procedures. Both the simulators and personnel responding to the
    simulation are focused on carrying out the procedures to test the
    validity of the ERP.

-   **Full Scale Drills**: These are the most costly and time-consuming
    training programs but can be extremely effective. In a full-scale
    drill, emergency response personnel and equipment are mobilized to a
    scene, an emergency scenario is presented, and they respond as
    directed by the ERP.

The bottom line is that time, resources, and personnel need to be
dedicated to accomplishing the training. Use the training to identify
lessons learned, debrief staff of lessons learned to enhance future
response and recovery efforts, and update plans to incorporate lessons
learned.

# Reproduction of ERP Certification 

ERP Certification (continued)

**References and Links**

The following is a list of references and Internet links that may be
useful to you in preparing your Emergency Response Plan.

**Department of Homeland Security (DHS):** DHS is the overall lead
agency for homeland security issues. DHS will become involved in
incident response if needed. General information about DHS is available
at <http://www.dhs.gov/dhspublic>. DHS administers the National Incident
Management System (NIMS), which provides a nationwide template to enable
Federal, State, local, and tribal governments and private-sector and
nongovernmental organizations to work together to prepare for, prevent,
respond to, and recover from domestic incidents, including terrorism.
Information on the NIMS can be found at
<http://www.dhs.gov/interweb/assetlibrary/NIMS-90-web.pdf>.

**Environmental Protection Agency:** EPA has numerous resources
available in addition to this guidance. The following are key sources:

-   Water Infrastructure Security information, guidance, and training
    information can be found at
    <http://www.epa.gov/safewater/security/index.html>.

-   More information on Local Emergency Planning Committees (LEPCs) can
    be found at <http://www.epa.gov/ceppo/lepclist.htm>.

**The Center for Disease Control and Prevention (CDC):** The CDC
develops resources to assist hospital staff, clinics, and physicians in
diagnosing diseases related to terrorism, reporting incidences of
disease, and controlling the spread of infection. Information on
emergency preparedness and response can be found at
[http://www.bt.cdc.gov](http://www.bt.cdc.gov/).

-   To assist in the development of a Public Health Response Plan, the
    CDC published a planning document entitled *The Public Health
    Response to Biological and Chemical Terrorism: Interim Planning
    Guidance for State Public Health Officials (July 2001)*, which can
    be found at
    <http://www.bt.cdc.gov/Documents/Planning/PlanningGuidance.pdf>.

-   *Interim Recommended Notification Procedures for Local and State
    Public Health Department Leaders in the Event of a Bioterrorist
    Incident* can be found at
    <http://www.bt.cdc.gov/EmContact/Protocols.asp>.

**Federal Emergency Management Agency (FEMA):** On March 1, 2003, FEMA
became part of the U.S. Department of Homeland Security. FEMA's mission
is to reduce loss of life and property and protect our nation\'s
critical infrastructure from all types of hazards through a
comprehensive, risk-based, emergency management program of mitigation,
preparedness, response and recovery. General information can be found at
[http://www.fema.gov](http://www.fema.gov/). In addition, several online
training courses relevant to emergency management are available on-line
from FEMA at <http://training.fema.gov/EMIWeb/IS/crslist.asp>.

**The American Water Works Association (AWWA):** EPA training developed
through partnership with AWWA covers security issues including assessing
vulnerabilities, emergency response plans and risk communication. AWWA
information can be accessed at their website,
[http://www.awwa.org](http://www.awwa.org/). Specific AWWA resources can
be found at
<http://www.awwa.org/communications/offer/secureresources.cfm>.

**The Association of State Drinking Water Administrators (ASDWA):**
ASDWA has information on water security planning, training, and links to
State programs and other information sources. Go to the security link at
[http://www.asdwa.org](http://www.asdwa.org/).

**National Rural Water Association (NRWA):** NRWA developed the
\"Security and Emergency Management System\" (SEMS) Software Program,
which can be loaded on a personal computer. It is based on NRWA/ASDWA\'s
*Security Vulnerability Self-Assessment Guide for Small Drinking Water
Systems Serving Populations Between 3,300 and 10,000*. You can find more
information at [http://www.nrwa.org](http://www.nrwa.org/).

# Glossary 

Definitions in this glossary are specific to the Emergency Response Plan
Guidance but have been conformed to common usage as much as possible.

**Action Plans:** specific plans designed to be used during the response
to a threat or incident. Action plans should be easy to use and contain
forms, flow charts, and simple instructions to support staff in the
field or decision officials during management of a crisis.

**Bioterrorism Act:** the Public Health Security and Bioterrorism
Preparedness and Response Act of 2002.

**Chain of Command:** a clear and definitive structure of authority.

**'Confirmed':** a stage in the threat evaluation process in which there
is definitive evidence and information to establish that an incident or
major event has occurred.

**'Credible':** a stage in the threat evaluation process in which there
is information to corroborate a threat.

**Drinking Water Primacy Agency:** the agency that has primary
enforcement responsibility for national drinking water regulations,
namely those promulgated under 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 the State Health Agency, the State
Environmental Agency, or the USEPA regional office.

**Emergency Response (ER) Lead:** the pre-designated main point of
contact and decision-maker for a CWS during a major event.

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

**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.).

**Local Emergency Planning Committee (LEPC):** established by the
Emergency Planning and Community Right-to-Know Act, LEPCs have the job
of increasing community hazardous materials safety through public
education, emergency planning, responder training, conducting exercises,
and reviewing actual responses to releases.

**Major Event:** a domestic terrorist attack, major disaster, or other
emergency (from Homeland Security Presidential Directive/HSPD-8)
(<http://www.whitehouse.gov/news/releases/2003/12/20031217-6.html>)

**Notification:** the process of communicating information to interested
parties.

**Personal Protective Equipment (PPE):** equipment and supplies designed
to protect employees from serious injuries or illnesses resulting from
contact with chemical, radiological, biological, or other hazards. PPE
includes face shields, safety glasses, goggles, laboratory coats,
gloves, and respirators.

**'Possible':** a stage in the threat evaluation process in which
available information indicates there is an opportunity for an incident
(i.e., the threat is possible).

**Response Decisions:** part of the threat management process in which
decisions are made regarding appropriate response actions that
consider 1) the conclusions of the threat evaluation, 2) the
consequences of the suspected incident, and 3) the impacts of the
response actions on drinking water customers and the utility.

**Security Breach:** an unauthorized intrusion into a secured facility
that may be discovered through direct observation, an alarm trigger, or
signs of intrusion (e.g., cut locks, open doors, cut fences). A security
breach is a type of threat warning.

**Spokesperson:** 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 spokesperson per
incident.

**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.

**Threat:** an indication of possible violence, harm, or danger.

**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 an 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 Warning:** an occurrence or discovery that indicates a threat
of a malevolent act and triggers an evaluation of the threat.

**Vulnerability Assessment (VA):** 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.

**Appendix A: Public Communications Strategy**

***Developing a Public Communications Strategy***

Developing a public communications strategy will prepare you to
effectively communicate with the public and media at the time of an
emergency or crisis. As a CWS, you should remember that any public
notification or communication will have an immediate and direct impact
on your customers and consumers. Consumers may be instructed to boil
water, limit their water uses to activities that do not involve
consumption, or not use the water at all. A good public communications
strategy will help you get your message out effectively and outline who
needs to do what and when. Items that should be considered in a public
communication strategy include:

-   Designating a spokesperson and any alternate spokespersons (should
    the main spokesperson be unavailable);

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-   Organizing basic facts about the CWS and the situation the CWS is
    facing;

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-   Having a method in place to develop key messages to use with the
    media that are clear, brief, and accurate;

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-   Making sure the messages are carefully planned and have been
    coordinated with other appropriate officials and organizations;

-   Making sure the messages are targeted to reach different audiences
    such as residential and business customers, local health
    professionals, etc.; and

-   Having methods in place for delivering messages;

-   Determining how to reach the largest number of customers and key
    stakeholders by selecting delivery methods that are likely to
    produce the best results. The reach and impact of the message and
    information will increase if the same message is distributed via
    different delivery methods more than one time.

While it may seem that developing a public communications strategy may
be a lot of work and effort, you should already have experience with
public and media communication through your compliance with the public
notification requirements of the 1996 Safe Drinking Water Act (SDWA)
amendments. In fact, many of the suggestions found in this appendix on
developing and implementing a public communication strategy are excerpts
from the "Public Notification Handbook" (EPA 816-R-00-010, 2000)
(<http://www.epa.gov/safewater/pws/pn/handbook.pdf>). For example, the
sample public notices shown on the following pages are taken from the
handbook. Additionally, other publications and tools are available that
can assist you in developing and implementing a public communications
strategy not only in response to major events, but also in improving
your public and media communications in general.

***Making Public and Media Communications Work***

Making public and media communications work involves implementing your
public communications strategy effectively. This takes practice and a
lot of work BEFORE any notice or communication is issued. Below are some
tips and suggestions that would help make your public communications
strategy work. Please note that these tips and suggestion are not all
inclusive. Many are taken directly from USEPA's "Public Notification
Handbook" (EPA 816-R-00-010, 2000).

[Communication Tips and Suggestions:]{.underline}

-   Any decision to issue a public notification should be made in
    consultation with your Drinking Water Primacy Agency. You also
    should make arrangements with your local health department and/or
    other appropriate organizations prior to a major event in order to
    establish clear lines of communication and ensure access to decision
    officials on a 24/7 basis.

-   Typical press releases and notices should be ready beforehand to
    save hours of time and possibly prevent serious health problems for
    water users. In your press release or notice you should explain to
    the media what information you are trying to communicate and why.
    The most important information, including a description of the
    situation, populations at risk, instructions to consumers, and
    potential health effects, should be near the beginning of any press
    release or notice. Be sure to include a contact name and telephone
    number so that the media can call you for more information.

-   Remember to avoid technical or confusing language in your press
    releases and notices.

-   When you send a press release or notice to the media, write "PRESS
    RELEASE FOR PUBLIC SAFETY" at the top to emphasize its importance.

-   Work with the media ahead of time and develop an ongoing
    relationship. Explain to them what constitutes a major event and
    what your needs will be during a crisis. Hold an annual media day
    where you can explain how your CWS operates, including any
    improvements you may be implementing. The more informed the members
    of the media are about your CWS then the more accurate and effective
    they are helping get your message out to the public. The box below
    provides some general tips when directly working with the media.

-   Establish contacts with institutions and people who can translate
    press release and notices into other languages for you and who can
    help you target non-English speaking populations.

-   If you are going to provide bottled water, you should confirm ahead
    of time and periodically reconfirm that available bottled water
    supplies meet the Food and Drug Administration or State safety
    standards.

-   Consider beforehand which communication delivery methods would work
    best, particularly during a major event. Delivery methods during a
    major event could include:

```{=html}
<!-- -->
```
-   Broadcast media (radio and television);

-   Government access channels;

-   Web site (local government and others);

-   Listserve e-mail;

-   Newspaper;

-   Phone banks;

-   Broadcast phone messages ("reverse 911" messaging);

-   Broadcast faxes;

-   Posting in conspicuous locations;

-   Mass distribution through partners (e.g., churches, retailers,
    restaurants);

-   Hand delivery;

-   Door-to-door canvassing; and

-   Direct notification to critical users (e.g., schools, hospitals,
    nursing homes, prisons, etc.).

+-----------------------------------------------------------------------+
| **[General Tips on Working with the Media]{.underline}**              |
|                                                                       |
| -   Be truthful and up-front.                                         |
|                                                                       |
| -   Answer questions as well as you can, but don't be afraid to say   |
|     that you need to check on something if there is a question you    |
|     can't answer (once you find the information, quickly report back  |
|     on what you've found).                                            |
|                                                                       |
| -   Keep in mind that reporters are not familiar with State or        |
|     Federal requirements for safe drinking water -- avoid technical   |
|     jargon!                                                           |
|                                                                       |
| -   Provide additional sources of information (for instance,          |
|     referrals to State contacts).                                     |
|                                                                       |
| -   Be sensitive to the fact that reporters may be working on tight   |
|     deadlines.                                                        |
|                                                                       |
| -   Provide a list of the elements that should be addressed.          |
|                                                                       |
| -   Don't be upset if a newspaper article or news report isn't        |
|     exactly as you would want it, but politely tell a reporter if a   |
|     significant piece of information is wrong or missing.             |
|                                                                       |
| -   Don't be defensive when answering questions.                      |
+-----------------------------------------------------------------------+

**Example Boil Water Notice**

**WARNING**

**BOIL YOUR WATER BEFORE USING**

**\[The Holly County Water System\] water is contaminated with \[fecal
coliform/E. coli\]**

\[Fecal coliform or E. coli\] bacteria were found in the water supply on
\[November 5\]. These bacteria can make you sick and are a particular
concern for people with weakened immune systems.

**What should I do?**

-   DO NOT DRINK THE WATER WITHOUT BOILING IT FIRST. Bring all water to
    a boil, let it boil for ten minutes, and let it cool before using,
    or use bottled water. Boiled or bottled water should be used for
    drinking, making ice, brushing teeth, washing dishes, and preparing
    food until further notice. Boiling kills bacteria and other
    organisms in the water.

-   Fecal coliform and E. coli are bacteria whose presence indicates
    that the water may be contaminated with organisms that can cause
    illness in humans. These organisms can cause diarrhea, cramps,
    nausea, headaches, or other symptoms. They may pose a special health
    risk for infants, young children, some of the elderly, and people
    with severely compromised immune systems.

-   Organisms in drinking water are not the only cause of the symptoms
    above. If you experience any of these symptoms and they persist, you
    may want to seek medical advice. People at increased risk should
    seek advice about drinking water from their health care providers.

What happened? What is being done?

The water distribution system was contaminated with fecal coliform. We
are working with law enforcement and the public health department to
investigate/resolve this issue. We are currently increasing the
chlorination levels at the treatment plant as well as at the chlorine
booster stations throughout the system. In addition, we are evaluating
all available information and conducting tests to confirm the extent of
the contamination of the system. We will inform you when tests show no
bacteria and you no longer need to boil your water. We anticipate
resolving the problem within the next 48 hours.

For more information, please contact \[Joseph Smith\] at
\[555-555-6789\]. General guidelines on ways to lessen the risk of
infection by microbes are available from the EPA Safe Drinking Water
Hotline at

1-800-426-4794 and \[the Public Health Department Hotline at
1-800-123-4567\].

Please share this information with all the other people who drink this
water, especially those who may not have received this notice directly
(for example, people in apartments, nursing homes, schools, and
businesses). You can do this by posting this notice in a public place or
distributing copies by hand.

This notice is being sent to you by \[Holly County Water System\]. State
Water System ID# \[10001\]. Date distributed: \[November 6, 2003\]

**Example Do Not Drink Notice**

**WARNING**

#  {#section .TEXT_BOLD}

**DO NOT DRINK THE WATER**

\[Cyanide\] found in the \[City of Rolling Brook\] water supply on
\[October 10th\]

**Bottled water can be obtained at \[Islington Station High School and**

**Penn Road High School 24 hours per day\].**

**What should I do?**

-   Do NOT drink the water.

-   Symptoms associated with cyanide include dry mouth, itchy throat,
    headache, sweating, flushed skin, muscle rigidity, fever, confusion,
    lethargy, seizures, loss of consciousness, coma, and death.

-   If you or someone you know exhibits any of these symptoms,
    immediately contact your health care provider. In addition, please
    notify the public health department at 1-800-123-4567.

**What happened? What is being done?**

On October 10th, the water distribution system was contaminated with
cyanide. We are working with law enforcement and the public health
department to investigate/resolve this issue. We have tested the water
in various parts of the distribution system to verify the extent of the
cyanide contamination. Based on these tests, we have isolated the
portion of the system located north of Aspen Street and east of River
Road. Everyone in this portion of the system **should not drink the
water**. We have implemented additional security procedures to protect
the system against further contamination. Additional information will be
provided 24 hours/day on Channel 57- the local government television
channel.

For more information, please contact \[Joseph Smith\] at
\[555-555-6789\]. More information is also available from the EPA Safe
Drinking Water Hotline at 1-800-426-4794 and \[the Public Health
Department Hotline at 1-800-123-4567\].

Please share this information with all the other people who drink this
water, especially those who may not have received this notice directly
(for example, people in apartments, nursing homes, schools, and
businesses). You can do this by posting this notice in a public place or
distributing copies by hand.

This notice is being sent to you by \[City of Rolling Brook Water
System\]. State Water System ID#\[50005\]. Date distributed: \[October
10, 2003\]

**Example Do Not Use Notice**

**WARNING**

**DO NOT USE THE WATER**

**\[Lyonelle Water System\] water is contaminated with \[parathion\]**

Bottled water can be obtained at \[Murray High School and

Central High School 24 hours per day\].

Parathion was found in the water supply on \[November 14\]. This
chemical can make you sick and may result in death.

What should I do?

-   DO NOT USE THE WATER. You should ***not*** use the water for
    drinking, making ice, brushing teeth, washing dishes, washing
    clothes, bathing, food preparation, or watering lawns. Bottled water
    should be used for all of the above necessities until further
    notice.

-   Parathion is a chemical usually used to kill insects. It can cause
    constriction of the pupils, blurred vision, muscle and abdominal
    cramps, excessive salivation, sweating, nausea, vomiting, dizziness,
    headaches, convulsions, diarrhea, weakness, labored breathing,
    wheezing, and unconsciousness. Exposure can even lead to death.

-   If you or someone you know exhibits any of these symptoms,
    immediately contact your health care provider. In addition, please
    notify the public health department at 1-800-123-4567.

What happened? What is being done?

The water distribution system was contaminated with parathion. We are
working with law enforcement and the public health department to
investigate/resolve this issue. We have tested the water in various
parts of the distribution system to verify the extent of the parathion
contamination. Based on these tests, we have isolated the portion of the
system located north of Lincoln Avenue and east of Maple Road. Everyone
in this portion of the system **should not use the water**. We have
implemented additional security procedures to protect the system against
further contamination. Additional information will be provided 24
hours/day on Channel 57- the local government television channel.

For more information, please contact \[Joseph Smith\] at
\[555-555-6789\]. More information is also available from the EPA Safe
Drinking Water Hotline at 1-800-426-4794 and \[the Public Health
Department Hotline at 1-800-321-4567\].

Please share this information with all the other people who drink this
water, especially those who may not have received this notice directly
(for example, people in apartments, nursing homes, schools, and
businesses). You can do this by posting this notice in a public place or
distributing copies by hand.

This notice is being sent to you by \[Lyonelle Water System\]. State
Water System ID# \[90008\]. Date distributed: \[November 14, 2003\]

**Appendix B: GUARDING AGAINST TERRORIST AND SECURITY THREATS**

**Suggested Measures for Drinking Water and Wastewater Utilities (Water
Utilities)**

**Appendix C: Example Action Plans**

***Water System Contamination\****

**Threat Warning Stage**

+-----------------+----------------------------------------------------+
| Threat Warning  | [Special actions and notifications to be           |
| Received        | taken:]{.underline}                                |
|                 |                                                    |
|                 | -   Notify ER Lead or Alternate ER Lead            |
|                 |                                                    |
|                 | -   Record and document all information pertaining |
|                 |     to the threat warning                          |
|                 |                                                    |
|                 | -   Do not disturb site if the threat warning      |
|                 |     could be a possible crime scene                |
|                 |                                                    |
|                 | -   Return to normal operations if no further      |
|                 |     action is required (i.e., the threat warning   |
|                 |     can be explained)                              |
|                 |                                                    |
|                 | -   Begin the "Threat Decision Process" if the     |
|                 |     threat warning cannot be explained             |
+-----------------+----------------------------------------------------+

**Threat Decision Process Stage**

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Possible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 1)       | -   Notify local law enforcement                   |
|                 |                                                    |
|                 | -   Notify State Drinking Water Primacy Agency     |
|                 |                                                    |
|                 | -   Evaluate threat warning and make decisions in  |
|                 |     consultation with State Drinking Water Primacy |
|                 |     Agency and local law enforcement               |
|                 |                                                    |
|                 | -   Initiate basic precautionary measures:         |
|                 |                                                    |
|                 | 1.  Alert staff and personnel about threat warning |
|                 |                                                    |
|                 | 2.  Prepare additional notification lists if the   |
|                 |     situation escalates to the "Is the Threat      |
|                 |     Credible?" stage                               |
+-----------------+----------------------------------------------------+

If the threat is not possible, then return to normal operations.
Otherwise, proceed to "Is the Threat Credible" stage.

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Credible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 2)       | -   Activate notification and personnel safety     |
|                 |     portions of ERP                                |
|                 |                                                    |
|                 | -   Evaluate whether the threat is credible in     |
|                 |     consultation with assisting agencies           |
|                 |                                                    |
|                 | -   Visually inspect physical evidence and         |
|                 |     determine whether there is a change in normal  |
|                 |     system operating parameters (i.e., chlorine    |
|                 |     residuals, turbidity, odor, color, pH, etc.)   |
|                 |                                                    |
|                 | -   Conduct actions and testing as recommended by  |
|                 |     monitoring and sampling experts                |
+-----------------+----------------------------------------------------+

If the threat is not credible, then return to normal operations.
Otherwise, proceed to "Has the Threat been Confirmed" stage.

+-----------------+----------------------------------------------------+
| Has the         | [Special actions and notifications to be           |
| Incident Been   | taken:]{.underline}                                |
| Confirmed?      |                                                    |
|                 | -   Initiate full ERP activation                   |
| (Stage 3)       |                                                    |
|                 | -   Follow State Incident Command System           |
|                 |                                                    |
|                 | -   Isolate portion of system or backflush         |
|                 |                                                    |
|                 | -   Shut down system if obvious or confirmed       |
|                 |     contamination warrants                         |
|                 |                                                    |
|                 | -   Issue public notice and issue follow-up media  |
|                 |     press releases                                 |
|                 |                                                    |
|                 | -   Continue sampling and water monitoring         |
|                 |                                                    |
|                 | -   Assess need to remediate storage tanks,        |
|                 |     filters, sediment basins, solids handling,     |
|                 |     etc.                                           |
+-----------------+----------------------------------------------------+

\*This is a simplified Action Plan example that includes the threat
decision process to determine if the major event is just a threat or
actual event. You should develop this "Action Plan" specific to the
needs of your CWS and surrounding community.

***Structural Damage/Physical Attack to Water System or
Facility(ies)\****

**Threat Warning Stage**

+-----------------+----------------------------------------------------+
| Threat Warning  | [Special actions and notifications to be           |
| Received        | taken:]{.underline}                                |
|                 |                                                    |
|                 | -   Notify ER Lead or Alternate ER Lead            |
|                 |                                                    |
|                 | -   Record and document all information pertaining |
|                 |     to the threat warning                          |
|                 |                                                    |
|                 | -   Do not disturb site if the threat warning      |
|                 |     could be a possible crime scene                |
|                 |                                                    |
|                 | -   Return to normal operations if no further      |
|                 |     action is required (i.e., the threat warning   |
|                 |     can be explained)                              |
|                 |                                                    |
|                 | -   Begin the "Threat Decision Process" if the     |
|                 |     threat warning cannot be explained             |
+-----------------+----------------------------------------------------+

**Threat Decision Process Stage**

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Possible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 1)       | -   Notify local law enforcement                   |
|                 |                                                    |
|                 | -   Notify State Drinking Water Primacy Agency     |
|                 |                                                    |
|                 | -   Evaluate threat warning and make decisions in  |
|                 |     consultation with State Drinking Water Primacy |
|                 |     Agency and local law enforcement               |
|                 |                                                    |
|                 | -   Initiate basic precautionary measures:         |
|                 |                                                    |
|                 | 1.  Alert staff and personnel about threat warning |
|                 |                                                    |
|                 | 2.  Heighten security at critical facilities       |
|                 |                                                    |
|                 | 3.  Prepare additional notification lists if the   |
|                 |     situation escalates to the "Is the Threat      |
|                 |     Credible?" stage                               |
+-----------------+----------------------------------------------------+

If the threat is not possible, then return to normal operations.
Otherwise, proceed to "Is the Threat Credible" stage.

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Credible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 2)       | -   Activate notification and personnel safety     |
|                 |     portions of ERP                                |
|                 |                                                    |
|                 | -   Physically secure water system facilities      |
|                 |                                                    |
|                 | -   Evaluate whether the threat is credible in     |
|                 |     consultation with assisting agencies           |
+-----------------+----------------------------------------------------+

***If the threat is not credible, then return to normal operations.
Otherwise, proceed to "Has the Threat been Confirmed" stage.***

+-----------------+----------------------------------------------------+
| Has the         | [Special actions and notifications to be           |
| Incident Been   | taken:]{.underline}                                |
| Confirmed?      |                                                    |
|                 | -   Initiate full ERP activation                   |
| (Stage 3)       |                                                    |
|                 | -   Follow State Incident Command System           |
|                 |                                                    |
|                 | -   Deploy damage assessment team                  |
|                 |                                                    |
|                 | -   Isolate damaged facility from rest of water    |
|                 |     system                                         |
|                 |                                                    |
|                 | -   Coordinate alternative water supply, as        |
|                 |     needed, or consider alternate (interim)        |
|                 |     treatment schemes                              |
|                 |                                                    |
|                 | -   Issue public notice and issue follow-up media  |
|                 |     press releases                                 |
|                 |                                                    |
|                 | -   Repair damaged facilities                      |
|                 |                                                    |
|                 | -   Assess need for additional protection/security |
|                 |     measures                                       |
+-----------------+----------------------------------------------------+

\*This is a simplified Action Plan example that includes the threat
decision process to determine if the major event is just a threat or
actual event. You should develop this "Action Plan" specific to the
needs of your CWS and surrounding community.

***Cyber Attack on SCADA or Operational Computer System\****

**Threat Warning Stage**

+-----------------+----------------------------------------------------+
| Threat Warning  | [Special actions and notifications to be           |
| Received        | taken:]{.underline}                                |
|                 |                                                    |
|                 | -   Notify ER Lead or Alternate ER Lead            |
|                 |                                                    |
|                 | -   Record and document all information pertaining |
|                 |     to the threat warning                          |
|                 |                                                    |
|                 | -   Do not disturb site if the threat warning      |
|                 |     could be a possible crime scene                |
|                 |                                                    |
|                 | -   Return to normal operations if no further      |
|                 |     action is required (i.e., the threat warning   |
|                 |     can be explained)                              |
|                 |                                                    |
|                 | -   Begin the "Threat Decision Process" if the     |
|                 |     threat warning cannot be explained             |
+-----------------+----------------------------------------------------+

**Threat Decision Process Stage**

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Possible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 1)       | -   Notify local law enforcement                   |
|                 |                                                    |
|                 | -   Notify State Drinking Water Primacy Agency     |
|                 |                                                    |
|                 | -   Evaluate threat warning and make decisions in  |
|                 |     consultation with State Drinking Water Primacy |
|                 |     Agency and local law enforcement               |
|                 |                                                    |
|                 | -   Initiate basic precautionary measures:         |
|                 |                                                    |
|                 | 1.  Alert staff and personnel about threat warning |
|                 |                                                    |
|                 | 2.  Temporarily shut down SCADA system and go to   |
|                 |     manual operation using established protocol    |
|                 |                                                    |
|                 | 3.  Prepare additional notification lists if the   |
|                 |     situation escalates to the "Is the Threat      |
|                 |     Credible?" stage                               |
+-----------------+----------------------------------------------------+

If the threat is not possible, then return to normal operations.
Otherwise, proceed to "Is the Threat Credible" stage.

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Credible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 2)       | -   Activate notification and personnel safety     |
|                 |     portions of ERP                                |
|                 |                                                    |
|                 | -   Continue manual operation using established    |
|                 |     protocol                                       |
|                 |                                                    |
|                 | -   Consider whether to isolate source water       |
|                 |                                                    |
|                 | -   Consider whether to shut down system and       |
|                 |     provide alternate water                        |
|                 |                                                    |
|                 | -   Evaluate whether the threat is credible in     |
|                 |     consultation with assisting agencies           |
|                 |                                                    |
|                 | -   Conduct actions/testing recommended by         |
|                 |     monitoring and sampling experts                |
+-----------------+----------------------------------------------------+

***If the threat is not credible, then return to normal operations.
Otherwise, proceed to "Has the Threat been Confirmed" stage.***

+-----------------+----------------------------------------------------+
| Has the         | [Special actions and notifications to be           |
| Incident Been   | taken:]{.underline}                                |
| Confirmed?      |                                                    |
|                 | -   Initiate full ERP activation                   |
| (Stage 3)       |                                                    |
|                 | -   Follow State Incident Command System           |
|                 |                                                    |
|                 | -   Continue manual operation, source water        |
|                 |     isolation, or system shut down and alternate   |
|                 |     water supply, as appropriate                   |
|                 |                                                    |
|                 | -   Issue public notice and issue follow-up media  |
|                 |     press releases                                 |
|                 |                                                    |
|                 | -   Make image copy of all system logs to preserve |
|                 |     evidence                                       |
|                 |                                                    |
|                 | -   With law enforcement assistance, check for     |
|                 |     implanted backdoors and other malicious code   |
|                 |     before restarting SCADA system                 |
|                 |                                                    |
|                 | -   Install safeguards before restarting SCADA     |
|                 |     system                                         |
|                 |                                                    |
|                 | -   Bring SCADA system up and monitor system       |
|                 |                                                    |
|                 | -   Assess/implement additional precautions for    |
|                 |     SCADA system                                   |
+-----------------+----------------------------------------------------+

\*This is a simplified Action Plan example that includes the threat
decision process to determine if the major event is just a threat or
actual event. You should develop this "Action Plan" specific to the
needs of your CWS and surrounding community.

***Hazardous Chemical Release from Water System Facility(ies)\****

**Threat Warning Stage**

+-----------------+----------------------------------------------------+
| Threat Warning  | [Special actions and notifications to be           |
| Received        | taken:]{.underline}                                |
|                 |                                                    |
|                 | -   Notify ER Lead or Alternate ER Lead            |
|                 |                                                    |
|                 | -   Record and document all information pertaining |
|                 |     to the threat warning                          |
|                 |                                                    |
|                 | -   Do not disturb site if the threat warning      |
|                 |     could be a possible crime scene                |
|                 |                                                    |
|                 | -   Return to normal operations if no further      |
|                 |     action is required (i.e., the threat warning   |
|                 |     can be explained)                              |
|                 |                                                    |
|                 | -   Begin the "Threat Decision Process" if the     |
|                 |     threat warning cannot be explained             |
+-----------------+----------------------------------------------------+

**Threat Decision Process Stage**

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Possible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 1)       | -   Notify local law enforcement                   |
|                 |                                                    |
|                 | -   Notify State Drinking Water Primacy Agency     |
|                 |                                                    |
|                 | -   Evaluate threat warning and make decisions in  |
|                 |     consultation with State Drinking Water Primacy |
|                 |     Agency and local law enforcement               |
|                 |                                                    |
|                 | -   Initiate basic precautionary measures:         |
|                 |                                                    |
|                 | 1.  Alert staff and personnel about threat warning |
|                 |                                                    |
|                 | 2.  Post full-time operations personnel at the     |
|                 |     chemical treatment areas of the facility       |
|                 |                                                    |
|                 | 3.  Verify that monitoring, leak detection, and    |
|                 |     personal protection equipment are fully        |
|                 |     operational                                    |
|                 |                                                    |
|                 | 4.  Prepare additional notification lists if the   |
|                 |     situation escalates to the "Is the Threat      |
|                 |     Credible?" stage                               |
+-----------------+----------------------------------------------------+

If the threat is not possible, then return to normal operations.
Otherwise, proceed to "Is the Threat Credible" stage.

+-----------------+----------------------------------------------------+
| Is the Threat   | [Special actions and notifications to be           |
| Credible?       | taken:]{.underline}                                |
|                 |                                                    |
| (Stage 2)       | -   Activate notification and personnel safety     |
|                 |     portions of ERP                                |
|                 |                                                    |
|                 | -   Physically secure water system facilities and  |
|                 |     specifically the chemical treatment areas of   |
|                 |     the facility                                   |
|                 |                                                    |
|                 | -   Identify potentially hazardous chemical(s) to  |
|                 |     appropriate assisting agencies                 |
|                 |                                                    |
|                 | -   Based on Risk Management program and ERP,      |
|                 |     evaluate potential extent of public evacuation |
|                 |     or shelter in place order                      |
|                 |                                                    |
|                 | -   Evaluate whether the threat is credible in     |
|                 |     consultation with assisting agencies           |
+-----------------+----------------------------------------------------+

If the threat is not credible, then return to normal operations.
Otherwise, proceed to "Has the Threat Been Confirmed" stage.

+-----------------+----------------------------------------------------+
| Has the         | [Special actions and notifications to be           |
| Incident Been   | taken:]{.underline}                                |
| Confirmed?      |                                                    |
|                 | -   Initiate full ERP activation                   |
| (Stage 3)       |                                                    |
|                 | -   Follow State Incident Command System           |
|                 |                                                    |
|                 | -   Determine extent/concentration of chemical     |
|                 |     release and deploy damage assessment team      |
|                 |                                                    |
|                 | -   Turn off chemical treatment equipment and      |
|                 |     isolate chemical treatment areas from rest of  |
|                 |     water system                                   |
|                 |                                                    |
|                 | -   Depending on extent and concentration of       |
|                 |     release, issue evacuation or shelter in place  |
|                 |     order per Risk Management Program and ERP      |
|                 |                                                    |
|                 | -   Coordinate alternative water supply, as        |
|                 |     needed, or consider alternate (interim)        |
|                 |     treatment schemes                              |
|                 |                                                    |
|                 | -   Issue public notice and issue follow-up media  |
|                 |     press releases                                 |
|                 |                                                    |
|                 | -   Repair damaged facilities                      |
|                 |                                                    |
|                 | -   Assess need for additional protection/security |
|                 |     measures                                       |
+-----------------+----------------------------------------------------+

\*This is a simplified Action Plan example that includes the threat
decision process to determine if the major event is just a threat or
actual event. You should develop this "Action Plan" specific to the
needs of your CWS and surrounding community.