**Planning for and Responding to**

**Drinking Water Contamination Threats and Incidents**

**Response Protocol Toolbox**

**Module 1: Water Utility Planning Guide**

**December 12, 2003**

![](media/image1.wmf)

**OTHER RESPONSE PROTOCOL TOOLBOX MODULES**

> **Module 1: Water Utility Planning Guide** *(December 2003)*
>
> Module 1 provides a brief discussion of the nature of the
> contamination threat to the public water supply. The module also
> describes the planning activities that a utility may undertake to
> prepare for response to contamination threats and incidents.
>
> **Module 2: Contamination Threat Management Guide** *(December 2003)*
>
> Module 2 presents the overarching framework for management of
> contamination threats to the drinking water supply. The threat
> management process involves two parallel and interrelated
> activities: 1) evaluating the threat, and 2) making decisions
> regarding appropriate actions to take in response to the threat.
>
> **Module 3: Site Characterization and Sampling Guide** *(December
> 2003)*
>
> Module 3 describes the site characterization process in which
> information is gathered from the site of a suspected contamination
> incident at a drinking water system. Site characterization activities
> include the site investigation, field safety screening, rapid field
> testing of the water, and sample collection.
>
> **Module 4: Analytical Guide** *(December 2003)*
>
> Module 4 presents an approach to the analysis of samples collected
> from the site of a suspected contamination incident. The purpose of
> the Analytical Guide is **not** to provide a detailed protocol.
> Rather, it describes a framework for developing an approach for the
> analysis of water samples that may contain an unknown contaminant. The
> framework is flexible and will allow the approach to be crafted based
> on the requirements of the specific situation. The framework is also
> designed to promote the effective and defensible performance of
> laboratory analysis.
>
> **Module 5: Public Health Response Guide** *(available March 2004)*
>
> Module 5 deals with the public health response measures that would
> potentially be used to minimize public exposure to potentially
> contaminated water. It discusses the important issue of who is
> responsible for making the decision to initiate public health response
> actions, and considers the role of the water utility in this decision
> process. Specifically, it examines the role of the utility during a
> public health response action, as well as the interactions among the
> utility, the drinking water primacy agency, the public health
> community, and other parties with a public health mission.
>
> **Module 6: Remediation and Recovery Guide** *(available March 2004)*
>
> Module 6 describes the planning and implementation of remediation and
> recovery activities that would be necessary following a confirmed
> contamination incident. The remediation process involves a sequence of
> activities, including: system characterization; selection of remedy
> options; provision of an alternate drinking water supply during
> remediation activities; and monitoring to demonstrate that the system
> has been remediated. Module 6 describes the types of organizations
> that would likely be involved in this stage of a response, and the
> utility's role during remediation and recovery.

**TABLE OF CONTENTS**

1 INTRODUCTION: WHY SHOULD I READ THIS MODULE?
[11](#introduction-why-should-i-read-this-module)

2 WHAT ARE CONTAMINATION THREATS AND INCIDENTS?
[12](#what-are-contamination-threats-and-incidents)

2.1 OVERVIEW OF CONTAMINATION THREATS AND INCIDENTS
[12](#overview-of-contamination-threats-and-incidents)

2.2 WARNINGS SIGNS OF A CONTAMINATION THREAT
[16](#warnings-signs-of-a-contamination-threat)

3 HOW SHOULD I RESPOND TO WATER CONTAMINATION THREATS?
[19](#how-should-i-respond-to-water-contamination-threats)

3.1 I'M JUST A UTILITY---WHY DO I NEED TO DO ANYTHING AT ALL?
[19](#im-just-a-utilitywhy-do-i-need-to-do-anything-at-all)

3.2 DUE DILIGENCE---WHEN HAVE I DONE ENOUGH?
[19](#due-diligencewhen-have-i-done-enough)

4 WHAT CAN I DO TO PREPARE? [22](#what-can-i-do-to-prepare)

4.1 KNOW YOUR WATER SYSTEM [22](#know-your-water-system)

4.1.1 CONSTRUCTION AND OPERATION [22](#construction-and-operation)

4.1.2 PERSONNEL [23](#personnel)

4.1.3 CUSTOMERS [23](#customers)

4.2 UPDATE EMERGENCY RESPONSE PLANS FOR INTENTIONAL CONTAMINATION
[24](#update-emergency-response-plans-for-intentional-contamination)

4.3 DEVELOP RESPONSE GUIDELINES FOR INTENTIONAL CONTAMINATION
[24](#develop-response-guidelines-for-intentional-contamination)

4.4 ESTABLISH STRUCTURE FOR INCIDENT COMMAND
[24](#establish-structure-for-incident-command)

4.5 DEVELOP INFORMATION MANAGEMENT STRATEGY
[29](#develop-information-management-strategy)

4.6 ESTABLISH COMMUNICATION AND NOTIFICATION STRATEGY
[30](#establish-communication-and-notification-strategy)

4.7 PERFORM TRAINING AND DESK/FIELD EXERCISES
[33](#perform-training-and-deskfield-exercises)

4.8 ENHANCE PHYSICAL SECURITY [34](#enhance-physical-security)

4.9 ESTABLISH BASELINE MONITORING PROGRAM
[34](#establish-baseline-monitoring-program)

4.10 UTILIZE AND UNDERSTAND ON-LINE MONITORING
[35](#utilize-and-understand-on-line-monitoring)

5 REFERENCES AND RESOURCES [36](#references-and-resources)

6 APPENDICES [38](#appendices)

6.1 SAMPLE OUTLINE OF RESPONSE GUIDELINE
[38](#sample-outline-of-response-guideline)

6.2 U.S. GOVERNMENT RESPONSE PLANS [39](#u.s.-government-response-plans)

6.2.1 NATIONAL RESPONSE PLAN [39](#national-response-plan)

6.2.2 FEDERAL RESPONSE PLAN [39](#federal-response-plan)

6.3 ON-LINE MONITORING SYSTEMS [43](#on-line-monitoring-systems)

6.3.1 CONVENTIONAL SYSTEMS [43](#conventional-systems)

6.3.2 EARLY WARNING SYSTEMS [43](#early-warning-systems)

**LIST OF TABLES**

TABLE 1-1: CONTAMINANT CLASSES, THEIR AVAILABILITIES, AND RESTRICTIONS
14

TABLE 1-2: PRIORITIZATION CRITERIA FOR POTENTIAL WATER CONTAMINANTS 16

**LIST OF FIGURES**

FIGURE 1-1: SUMMARY OF THREAT WARNINGS 17

FIGURE 1-2: OVERVIEW OF RESPONSE TO A CONTAMINATION THREAT 21

FIGURE 1-3: EXPANSION OF, AND CHANGES TO, INCIDENT COMMAND STRUCTURE FOR
THE THREE THREAT EVALUATION STAGES 27

FIGURE 1-4: SAMPLE COMMUNICATION SCHEMES FOR THE THREE THREAT EVALUATION

STAGES 31

FIGURE 1-5: OVERVIEW OF POTENTIAL EXTERNAL NOTIFICATIONS 32

**ACRONYMS**

AWWARF American Water Works Association Research Foundation

C/B Chemical/Biological

CD Compact disk

CDC Centers for Disease Control and Prevention

DBP Disinfection by-product

DHS Department of Homeland Security

DOC Department of Commerce

DOD Department of Defense

DOE Department of Energy

DOI Department of the Interior

DOJ Department of Justice

DOL Department of Labor

DOS Department of State

DOT Department of Transportation

EPA U.S. Environmental Protection Agency

ERP Emergency response plans

ESF Emergency support function

EWS Early warning system

FBI Federal Bureau of Investigation

FCO Federal coordinating officer

FEMA Federal Emergency Management Agency

FRP Federal Response Plan

GIS Geographic information system

GSA Government services agency

HazMat Hazardous materials

HHS Department of Health and Human Services

IC Incident commander

ICS Incident Command System

ILSI International Life Sciences Institute Risk Science Institute

IO Information officer

JIC Joint information center

JOC Joint operations center

LFA Lead federal agency

LO Liaison officer

LPoC Laboratory point of contact

LRN Laboratory Response Network

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NIIMS National Interagency Incident Management System

NIMS National Incident Management System

NRC Nuclear Regulatory Commission

NRP National Response Plan

OSC On-scene coordinator

PDD Presidential decision directive

RG Response guideline

RPTB Response Protocol Toolbox

RST Regional support team

SCADA Supervisory control and data acquisition

SDWA Safe Drinking Water Act

TOC Total organic carbon

URL Uniform resource locator

USACE United States Army Corps of Engineers

USCG United States Coast Guard

USDA United States Department of Agriculture

UV Ultraviolet

WCIT Water contaminant information tool

WHO World Health Organization

WUERM Water utility emergency response manager

WUOCM Water utility emergency operations center manager

**GLOSSARY**

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

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

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

**Assisting Agency** B an agency directly contributing tactical or
service resources to another agency.

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

**Chain of Command** B a series of management positions in order of
authority.

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

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

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

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

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

**'Credible'** B in the context of the *threat evaluation* process, a
water contamination threat is characterized as 'credible' if information
collected during the threat evaluation process corroborates information
from the *threat warning*.

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

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

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

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

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

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

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

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

**Incident Commander** B the individual responsible for the management
of all incident operations.

**Incident Objectives** B statements of guidance and direction necessary
for the selection of appropriate strategy(ies), and the tactical
direction of resources. Incident objectives are based on realistic
expectations of what can be accomplished when all allocated resources
have been effectively deployed. Incident objectives must be achievable
and measurable, yet flexible enough to allow for strategic and tactical
alternatives.

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

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

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

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

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

**Notification** B the process of communication information to
interested parties.

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

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

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

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

**Quality Control** B the overall system of technical activities that
measures the attributes and performance of a process, item, or service
against defined standards to verify that they meet the stated
requirements established by the client; operational techniques and
activities that are used to fulfill requirements for quality.

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

**Secure Area** B a locked space, such as a cabinet or vault, with
access restricted to authorized personnel.

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

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

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

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

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

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

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

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

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

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

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

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

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

#  Introduction: Why Should I Read this Module?

The primary audience for this module is drinking water utilities, which
need to **plan** for and **practice** managing and responding to
contamination attacks. However, there are many other groups that may be
involved in responding to water contamination *threats* and *incidents*,
and they also may benefit from reviewing this module to assist in their
**planning** activities. These groups include analytical laboratories,
emergency responders, state *drinking water primacy agencies*,
*technical assistance providers*, public health officials, federal
agencies (including EPA), and law enforcement agencies, among others.
The objectives of this module are:

-   To familiarize the reader with the nature and warning signs of water
    contamination threats and incidents. The reader will learn that
    drinking water contamination incidents are possible and that
    contamination threats are probable.

-   To describe the overall framework for responding to a range of
    contamination threats, ranging from hoaxes to confirmed
    contamination incidents. This framework, the primary focus of the
    Response Protocol Toolbox (RPTB), is one of the highest water
    security priorities identified by the water sector and the EPA.

-   To help readers prepare for responding to contamination threats
    through: 1) Careful planning; 2) Development of *Response
    Guidelines*; 3) Establishing *notification* procedures and internal
    *chain of command*; and 4) Performing training exercises.

This module is organized into five sections as described below.

> Section 1: [Introduction]{.underline}: describes the objectives and
> overall organization of this module.
>
> Section 2: [What are Contamination Threats and Incidents?]{.underline}
> Provides background information on the contamination threat to water
> systems, including a discussion of potential warning signs of
> contamination.
>
> Section 3: [How Should I Respond to Water Contamination
> Threats?]{.underline} Discusses the need for response and introduces
> the concept of 'due diligence' in responding to contamination threats.
>
> Section 4: [What Can I do to Prepare?]{.underline} Highlights several
> areas in which utilities can enhance their preparedness for
> contamination threats.
>
> Section 5: [References and Resources]{.underline}: Lists the
> references used in the development of this module as well as
> additional information resources.
>
> Section 6: [Appendices]{.underline}: Provides a sample outline for
> utility Response Guidelines, describes the roles of federal agencies
> under two U.S. government response plans, and provides an overview of
> drinking water security applications for on-line monitoring systems.

# What are Contamination Threats and Incidents?

## Overview of Contamination Threats and Incidents

Both *water contamination* *threats* and *water contamination*
*incidents* could be designed to interrupt the delivery of safe water to
a population, interrupt fire protection, create public panic, or cause
disease or death in a population. A water contamination threat occurs
when the introduction of a contaminant into the water system is
threatened, claimed, or suggested by evidence. A water contamination
incident occurs when a contaminant is successfully introduced into the
water supply. The water contamination incident may be preceded by a
threat, but not always. Both water contamination threats and incidents
may be of particular concern due to the range of potential consequences:

-   Creating an adverse impact on public health within a population.

-   Disrupting system operations and interrupting the supply of safe
    water.

-   Causing physical damage to system infrastructure.

-   Reducing public confidence in the water supply.

-   Long-term denial of water and the cost of remediation and
    replacement.

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

In characterizing any threat, both the **possibility** and
**probability** should be considered. A general assessment of the threat
of intentional contamination of drinking water indicates that it is
**possible** to cause varying degrees of harm by contaminating a water
system. Specifically, this assessment indicates that:

-   Only a few contaminants have the potential to produce widespread
    death or disease in a population. These contaminants include
    concentrated pathogens, biotoxins, and a few highly toxic chemicals
    that may remain stable in water long enough to adversely impact
    public health.

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-   A larger group of contaminants could produce localized death or
    disease in a segment of a population, including several dozen toxic
    chemicals.

-   Hundreds of contaminants could potentially disrupt service or
    undermine consumer confidence but would not result in death or
    disease in the population.

While it is important to consider the range of possibilities associated
with a particular threat, assessments are typically based on the
**probability** of a particular occurrence. Determining probability is
somewhat subjective, and is often based on intelligence and previous
incidents. There are historical accounts of intentional contamination of
drinking water supplies with biological or chemical contaminants, but
most have been associated with wartime activities
(<http://www.who.int/emc/pdfs/BIOWEAPONS_FULL_TEXT2.pdf>). The few
documented accounts of intentional contamination of public water systems
in the U.S. have not resulted in any reported fatalities. The American
Water Works Association Research Foundation (AWWARF) is preparing a
report on this subject (AWWARF, 2003). Based on these accounts, it would
appear that the probability of a successful contamination incident on a
drinking water system is relatively low. However, there has been a
reported increase in the interest of various terrorist groups in
biological and chemical weapons. Furthermore, some intelligence
information indicates that terrorist organizations have considered water
infrastructure as a possible target. Thus, the potential for such an
incident does exist.

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

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

"A central consideration in such preparedness planning is that it is
neither possible nor necessary to specifically plan for attack by all
possible biological and chemical agents. If a country is seeking to
increase its preparedness to counter the effects of biological and
chemical attacks, the targeting of its preparation and training on a
limited but well chosen group of agents will provide the necessary
capability to deal with a far wider range of possibilities. Knowledge of
the general properties of this representative group of agents will
enable certain measures to be taken against virtually any other agent.
In addition to being impractical from a preparedness perspective, long
and exhaustive lists of agents also give a misleading impression of the
extent of possible threats."

In: *Public health response to biological and chemical weapons: WHO
guidance, 2nd edition (Draft, March 2003),*
(<http://www.who.int/csr/delibepidemics/biochemguide/en/index.html>)

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

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

**Table 1-1** Number range CHAPTER**Contaminant Classes, their
Availabilities, and Restrictions**

+----------+------------------------------+----------------+----------+
| *        | **Examples (not              | Sources        | *        |
| *Class** | exhaustive)**                |                | *Limited |
|          |                              |                | a        |
|          |                              |                | ccess?** |
+==========+==============================+================+==========+
| *        |                              |                |          |
| *MICROBI |                              |                |          |
| OLOGICAL |                              |                |          |
| CONTAM   |                              |                |          |
| INANTS** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Bacteria | *Bacillus anthracis,         | Naturally      | Yes for  |
|          | Brucella* spp*.,             | occurring,     | Select   |
|          | Burkholderia* spp*.,         | M              | Agents   |
|          | Campylobacter* spp*.,        | icrobiological |          |
|          | Clostridium perfringens, E.  | la             |          |
|          | coli* O157:H7, *Francisella  | boratories^1^, |          |
|          | tularensis, Salmonella       | s              |          |
|          | typhi, Shigella* spp*.,      | tate-sponsored |          |
|          | Vibrio cholerae, Yersinia    | programs       |          |
|          | pestis, Yersinia             |                |          |
|          | enterocolitica*              |                |          |
+----------+------------------------------+----------------+----------+
| Viruses  | Caliciviruses,               | Naturally      | Yes for  |
|          | Enteroviruses, Hepatitis     | occurring,     | Select   |
|          | A/E, Variola, VEE virus      | M              | Agents   |
|          |                              | icrobiological |          |
|          |                              | la             |          |
|          |                              | boratories^1^, |          |
|          |                              | s              |          |
|          |                              | tate-sponsored |          |
|          |                              | programs       |          |
+----------+------------------------------+----------------+----------+
| P        | *Cryptosporidium parvum,     | Naturally      | No       |
| arasites | Entamoeba histolytica,       | occurring,     |          |
|          | Toxoplasma gondii*           | M              |          |
|          |                              | icrobiological |          |
|          |                              | l              |          |
|          |                              | aboratories^1^ |          |
+----------+------------------------------+----------------+----------+
| **       |                              |                |          |
| CHEMICAL |                              |                |          |
| CONTAM   |                              |                |          |
| INANTS - |                              |                |          |
| Ino      |                              |                |          |
| rganic** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Co       | Toilet bowl cleaners         | Retail,        | No       |
| rrosives | (hydrochloric acid),         | industry       |          |
| and      | tree-root dissolver          |                |          |
| caustics | (sulfuric acid), drain       |                |          |
|          | cleaner (sodium hydroxide)   |                |          |
+----------+------------------------------+----------------+----------+
| Cyanide  | Sodium cyanide, potassium    | Supplier,      | Yes      |
| salts or | cyanide, amygdalin, cyanogen | industry (esp. |          |
| cya      | chloride, ferricyanide salts | e              |          |
| nogenics |                              | lectroplating) |          |
+----------+------------------------------+----------------+----------+
| Metals   | Mercury, lead, osmium, their | Industry,      | Yes^2^   |
|          | salts, organic compounds,    | supplier,      |          |
|          | and complexes (even those of | laboratory     |          |
|          | iron, cobalt, copper are     |                |          |
|          | toxic at high doses)         |                |          |
+----------+------------------------------+----------------+----------+
| Nonmetal | Arsenate, arsenite, selenite | Some retail,   | Yes^3^   |
| ox       | salts, organoarsenic,        | industry,      |          |
| yanions, | organoselenium compounds     | supplier,      |          |
| organo-n |                              | laboratory     |          |
| onmetals |                              |                |          |
+----------+------------------------------+----------------+----------+
| **       |                              |                |          |
| CHEMICAL |                              |                |          |
| CONTAM   |                              |                |          |
| INANTS - |                              |                |          |
| O        |                              |                |          |
| rganic** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Flu      | Sodium trifluoroacetate (a   | Supplier,      | Yes      |
| orinated | rat poison), fluoroalcohols, | industry,      |          |
| organics | fluorinated surfactants      | laboratory     |          |
+----------+------------------------------+----------------+----------+
| Hydr     | Paint thinners, gasoline,    | Retail,        | No       |
| ocarbons | kerosene, ketones (e.g.,     | industry,      |          |
| and      | methyl isobutyl ketone),     | laboratory,    |          |
| their    | alcohols (e.g., methanol),   | supplier       |          |
| ox       | ethers (e.g., methyl         |                |          |
| ygenated | *tert*-butyl ether or MTBE), |                |          |
| and/or   | halo­hydro­carbons (e.g.,      |                |          |
| hal      | dichloromethane,             |                |          |
| ogenated | tetrachloroethene)           |                |          |
| der      |                              |                |          |
| ivatives |                              |                |          |
+----------+------------------------------+----------------+----------+
| Inse     | Organophosphates (e.g.,      | Retail,        | Yes      |
| cticides | Malathion), chlorinated      | industry,      |          |
|          | organics (e.g., DDT),        | supplier       |          |
|          | carbamates (e.g., Aldicarb)  | (varies with   |          |
|          | some alkaloids (e.g.,        | compound)      |          |
|          | nicotine)                    |                |          |
+----------+------------------------------+----------------+----------+
| Mal      | Thiols (e.g., mercaptoacetic | Laboratory,    | Yes      |
| odorous, | acid, mercaptoethanol),      | supplier,      |          |
| noxious, | amines (e.g., cadaverine,    | police supply, |          |
| foul-    | putrescine), inorganic       | military depot |          |
| tasting, | esters (e.g.,                |                |          |
| and/or   | trimethylphosphite,          |                |          |
| lach     | dimethylsulfate, acrolein)   |                |          |
| rymatory |                              |                |          |
| chem     |                              |                |          |
| icals^4^ |                              |                |          |
+----------+------------------------------+----------------+----------+
| O        | Acetone, methanol, ethylene  | Retail,        | No       |
| rganics, | glycol (antifreeze),         | industry,      |          |
|          | phenols, detergents          | supplier,      |          |
| Water-   |                              | laboratory     |          |
| miscible |                              |                |          |
+----------+------------------------------+----------------+----------+
| Pe       | Herbicides (e.g.,            | Retail,        | Yes      |
| sticides | chlorophenoxy or atrazine    | industry,      |          |
| other    | derivatives), rodenticides   | agriculture,   |          |
| than     | (e.g., superwarfarins, zinc  | laboratory     |          |
| inse     | phosphide, α-naphthyl        |                |          |
| cticides | thiourea)                    |                |          |
+----------+------------------------------+----------------+----------+
| Pharmac  | cardiac glycosides, some     | Laboratory,    | Yes      |
| euticals | alkaloids (e.g.,             | supplier,      |          |
|          | vincristine), antineoplastic | pharmacy, some |          |
|          | chemotherapies (e.g.,        | from a natural |          |
|          | aminopterin), anticoagulants | source         |          |
|          | (e.g., warfarin). Includes   |                |          |
|          | illicit drugs such as LSD,   |                |          |
|          | PCP, and heroin.             |                |          |
+----------+------------------------------+----------------+----------+
| **       |                              |                |          |
| SCHEDULE |                              |                |          |
| 1        |                              |                |          |
| CHEMICAL |                              |                |          |
| WARFARE  |                              |                |          |
| AGENTS** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Schedule | organophosphate nerve agents | Suppliers,     | Yes      |
| 1        | (e.g., sarin, tabun, VX),    | military       |          |
| Chemical | vesicants, \[nitrogen and    | depots, some   |          |
| Weapons  | sulfur mustards (chlorinated | laboratories   |          |
|          | alkyl amines and thioethers, |                |          |
|          | respectively)\], Lewisite    |                |          |
+----------+------------------------------+----------------+----------+
| **BIO    |                              |                |          |
| TOXINS** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Biol     | Biotoxins from bacteria,     | Laboratory,    | Yes      |
| ogically | plants, fungi, protists,     | supplier,      |          |
| produced | defensive poisons in some    | pharmacy,      |          |
| toxins   | marine or terrestrial        | natural        |          |
|          | animals. Examples include    | source^5^,     |          |
|          | ricin, saxitoxin, botulinum  | s              |          |
|          | toxins, T-2 mycotoxins,      | tate-sponsored |          |
|          | microcystins.                | programs       |          |
+----------+------------------------------+----------------+----------+
| **RADI   |                              |                |          |
| OLOGICAL |                              |                |          |
| CONTAM   |                              |                |          |
| INANTS** |                              |                |          |
+----------+------------------------------+----------------+----------+
| Radio    | Does not refer to nuclear,   | Laboratory,    | Yes^2^   |
| nuclides | thermonuclear, or neutron    | state sources, |          |
|          | bombs. Radionuclides may be  | waste          |          |
|          | used in medical devices and  | facilities     |          |
|          | industrial irradiators       |                |          |
|          | (Cesium-137 Iridium-192,     |                |          |
|          | Cobalt-60, Strontium-90).    |                |          |
|          | Class includes both the      |                |          |
|          | metals and salts.            |                |          |
+----------+------------------------------+----------------+----------+

1\. The quantity of bacteria, viruses, or parasites needed for
widespread contamination of a water system is not available in a typical
clinical laboratory, although the seed cultures could be available. For
viruses, vaccine production-grade volumes would be needed, requiring
special equipment and facilities, perhaps with state-sponsorship.

2\. Availability may be commercially limited for the more toxic metals,
especially the heavy metals, which can be quite expensive. Iron and
copper are readily available, but not usually in soluble (bio-available)
forms.

3\. Availability of arsenicals and selenium compounds in the retail
sector has been reduced owing to environmental regulations, but such
products can occasionally be found as part of older inventories of
merchandise, especially in small-town hardware stores. Supplies of such
materials may generally be too small to cause concern.

4\. This grouping includes riot-control agents and other mucous membrane
irritants.

5\. The quantity available from laboratories, suppliers, and pharmacies
needed for widespread contamination of a water system are typically not
available from these sources. Many biotoxins that occur naturally would
need to be purified or prepared to be of significant concern to water,
which could make production beyond the capabilities of most terrorists.

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

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

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

Table 1-2. Prioritization Criteria for Potential Water Contaminants

  --------------- --------------------------------------------------------
  **Criterion**   **Description**

  Aesthetic       Changes in appearance, odor, or taste of contaminated
  impacts         water that might alert a consumer to the potential
                  danger.

  Availability    The ease with which the material can be obtained,
                  synthesized, or harvested from natural sources.

  Chlorine        The time that a contaminant remains toxic or infectious
  resistance      after introduction into water containing a chlorine
                  residual under typical distribution system conditions.

  Dispersion      The ease with which a contaminant can be effectively
                  dispersed in water.

  Handling        The technical challenges associated with handling the
  difficulty      material and introducing it into water.

  Outcome of      The health effects within the population resulting from
  exposure        exposure to the contaminant.

  Potency         The amount of contaminant that would be required to
                  contaminate a reference volume of water at a lethal or
                  infectious dose. The smaller the amount of material, the
                  higher the rank.

  Public fear     Perception of the public regarding the risks associated
  factor          with the contaminant.

  Stability       The time that a contaminant remains toxic or infectious
                  after introduction into an aqueous environment.

  Storability     The time that a contaminant remains toxic or infectious
                  while in storage.
  --------------- --------------------------------------------------------

## Warnings Signs of a Contamination Threat

A *threat warning* is an occurrence or discovery that indicates a
potential contamination threat that triggers an evaluation of the
threat. The use of information about a threat warning during the initial
stage of the *threat evaluation* process is described in more detail in
Module 2. It is important to note that these warnings must be evaluated
in the context of typical utility activity and previous experience in
order to avoid **false alarms**. Figure 1-1 summarizes several potential
threat warnings.

![](media/image2.wmf)

**Figure 1-1. Summary of Threat Warnings**

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

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

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

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

-   [Notification by Law Enforcement.]{.underline} A utility may receive
    notification about a contamination threat directly from law
    enforcement, including local, county, state, or federal agencies. As
    discussed previously, such a threat could be a result of suspicious
    activity reported to law enforcement, either by a perpetrator, a
    witness, or the news media. Other information, gathered through
    intelligence or informants, could also lead law enforcement to
    conclude that there may be a threat to the water supply. While law
    enforcement will have the lead in the criminal investigation, the
    utility has primary responsibility for the safety of the water
    supply and public health. Thus, the utility's role will likely be to
    help law enforcement to appreciate the public health implications of
    a particular threat as well as the technical feasibility of carrying
    out a particular threat.

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

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

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

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

# How should I Respond to Water Contamination Threats?

This section is not designed to discuss what specific steps to take in
responding to a contamination threat. Various "What to do?" steps in the
response process will be discussed in Section 4 and associated modules.
Rather, the questions addressed in this section are "Why is it necessary
to respond to contamination threats at all?" and "When have I done
enough?"

## I'm Just a Utility---Why Do I Need to do Anything at All?

As discussed in Section 2, it is technically possible to introduce a
contaminant into a public water supply, and historical evidence suggests
that the threat of contamination is indeed probable. Regardless of
whether contamination is actual or threatened, both deeply impact the
public health mission of water utilities. Water utilities play an
essential role in providing safe and reliable drinking water supplies,
preventing many problems and diseasees that flourish in the absence of
safe water programs. Most water utilities take their public health
mission very seriously, and some are proactive in developing their plans
to respond to water contamination threats. They do this often because
they realize that planning for contamination events may also be
beneficial in developing a more effective response to other types of
emergencies.

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

Considering the potential risks of an inappropriate response to a
contamination threat, it is clear that a systematic approach is needed
to evaluate contamination threats. This systematic approach is developed
throughout the RPTB. One overriding question is "When has a drinking
water utility done enough?" This question may be particularly difficult
to address when considering the wide range of agencies that may be
involved in a threat situation. Other organizations, such as EPA, CDC,
law enforcement agencies, health departments, etc., will each have
unique obligations or interests in responding to a contamination threat.

## Due Diligence---When Have I Done Enough?

The guiding principle for responding to contamination threats is one of
'due diligence' or "what is a suitable and sensible response to a
contamination threat?" As discussed above, some response to
contamination threats is warranted due to the public health implications
of an actual contamination incident. However, a utility could spend a
lot of time and money over-responding to every contamination threat,
which would be an ineffective use of resources. Furthermore,
over-response to a contamination threat carries its own adverse impacts.

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

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

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

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

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

![](media/image3.wmf)

**Figure 1-2. Overview of Response to a Contamination Threat**

If the process outlined in Figure 1-2 is followed as far as the
situation warrants, and the responsible parties use it as a guide in
making appropriate response decisions, then they may be viewed as
exercising 'due diligence.' All the modules of the RPTB contain in-depth
information about the application of the process. In particular, Module
2 describes threat management and the three stages of the threat
evaluation in great detail. **The application of this process to a
specific contamination threat will vary significantly with the
circumstances of the threat.** In summary, judgment must be exercised
when determining how to appropriately manage a specific contamination
threat. Tabletop exercises, described below in Section 4.7, may provide
valuable practice in this regard.

# What Can I do to Prepare?

One of the steps that utilities can take to prepare for contamination
threats is to read relevant modules of the "Response Protocol Toolbox"
and use the information contained within to develop their own specific
Response Guidelines and updated Emergency Response Plans! Specific
planning and preparation activities are summarized in the following
subsections.

## Know your Water System

### Construction and Operation

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

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

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

Information about construction materials used in the system may be
contained within the utility records and can be useful in evaluating the
fate and transport of a particular contaminant through a system. For
example, a particular contaminant may adsorb to the pipe material used
in a utility's distribution system, and this type of information would
be critical in evaluating remediation options following a contamination
incident (see Module 6).

### Personnel

The employees of a water utility are generally its most valuable asset
in preparing for and responding to water contamination threats and
incidents. They have knowledge of the system and water quality, and may
also have experience in dealing with previous contamination threats. The
importance of knowledgeable and experienced personnel is highlighted by
the complexity of most water treatment and distribution systems. This
complexity makes a successful contamination of a specific target
contingent upon detailed knowledge of the system configuration,
hydraulic conditions, usage patterns, and water quality. If perpetrators
have somehow gained a sophisticated understanding of a water supply
system, the day-to-day experience of water system personnel will prove
an invaluable tool to countering any attacks. For instance, personnel
may continually look for unusual aspects of daily operation that might
be interpreted as a potential threat warning, and may also be aware of
specific characteristics of the system that make it vulnerable to
contamination.

### Customers

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

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

## Update Emergency Response Plans for Intentional Contamination

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

In response to the legal mandate to revise ERPs, there is an increased
demand for guidance that addresses terrorist threats to water supply
systems. The U.S. EPA is preparing this guidance, which will be
published in a separate document (U.S. EPA, 2003b, "Drinking Water Model
Emergency Response Plan," in development. See also U.S. EPA, 2003c,
"Large Water System Emergency Response Plan Outline: Guidance to Assist
Community Water Systems in Complying with the Public Health Security and
Bioterrorism Preparedness and Response Act of 2002). For those existing
plans that can be revised, information contained in this RPTB may help
utilities to address the contamination threat in their revised ERPs,
although it should be noted that there is no regulatory requirement to
use the RPTB in this manner. However, the RPTB does provide a framework
that will aid utilities in planning an effective response to
contamination threats, which might be considered during revision to
their ERP.

## Develop Response Guidelines for Intentional Contamination

Although not a formal part of an ERP, utilities may wish to develop
*Response Guidelines* (RGs) for managing contamination threats. RGs are
different from ERPs in that they are essentially a "field guide" for
responding to contamination threats. RGs may be developed in many
different formats, but a core feature of any RG is that it is easy to
use in the field and under crisis conditions. Because RGs are used in
the field, they should be action-oriented, easy to follow, and contain
all the necessary forms and information. For instance, they should
contain forms to document observations at the site of a suspected
contamination incident and to log samples collected from the site.
Additionally, the guidelines might include flow charts depicting the
steps of a process, simple reference tables, and other information that
can easily be used during the intense period of an initial response to a
threat. A trained individual should be able to follow a well organized
RG with minimal difficulty. While the RPTB is not set up in the
streamlined format of an effective set of RGs, the material contained in
the RPTB can certainly support the development of guidelines, and an
example outline for a set of RGs is included in Appendix 5.1 of this
Module. The outline may be filled using model text, figures, and forms
contained in the various modules of the RPTB, in addition to the users'
own materials.

## Establish Structure for Incident Command

One of the primary reasons that ERPs and RGs fail (for any type of
emergency, not just water contamination) is that there is no clear
leader established by the plan. Thus, in planning for a water emergency,
it is important to establish a command structure. This involves
establishing a chain of command, identifying key individuals, and
clearly defining their roles and responsibilities, so that they may
effectively manage the emergency situation. This section describes an
incident command structure based on the *Incident Command System (ICS)*.
See <http://training.fema.gov/EMIWeb/IS/is195.asp> for ICS training
material produced by FEMA.

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

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

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

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

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

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

3.  [*Water Utility Emergency Operations Center Manager*
    (WUOCM)]{.underline}: The WUOCM is an 'emergency manager' who heads
    the water utility's EOC, which is responsible for operational and
    resource management during an emergency. The general position of
    'emergency manager' is described in FEMA's training documents,
    <http://training.fema.gov/EMIWeb/IS/is1.asp>, although specific
    duties for water utilities may differ. In most cases,
    responsibilities of the WUOCM and the WUERM will fall upon different
    individuals.

![](media/image4.wmf)

![](media/image7.wmf)

Figure 1-3. Expansion of, and Changes to, Incident Command Structure for
the Three Threat Evaluation Stages

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

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

6.  *[Laboratory Point of Contact (LPoC)]{.underline}*: The LPoC is the
    designated person at the laboratory with whom the WUERM (or IC)
    communicates. The LPoC coordinates analytical activities with the
    WUERM (or IC) and reports analytical results only to the WUERM (or
    IC).

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

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

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

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

## Develop Information Management Strategy

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

Crisis Information Management Software (CIMS) may be useful, especially
when interfaced with a central data repository and/or electronic data
management system. A description and comparison of several commercial
CIMS packages has been prepared by the Department of Justice (DOJ,
<http://www.ncjrs.org/pdffiles1/nij/197065.pdf>). A Field Operations and
Records Management System (FORMS), originally developed for EPA's
Contract Laboratory Program, may also help manage records relevant to
sample documentation, analysis, and tracking during evaluation of water
threats (<http://www.epa.gov/superfund/programs/clp/f2lite.htm>).

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

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

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

## Establish Communication and Notification Strategy

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

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

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

![](media/image8.wmf)

![](media/image9.wmf)

**Figure 1-4. Sample Communication Schemes for the Three Threat
Evaluation Stages**

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

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

It is likely that the utility will carry out the initial phases of the
threat evaluation at the 'credible' stage. Figure 1-4 (top right) shows
a sample communication scheme, based on internal utility staff and also
external parties that may be able to provide information and technical
assistance relevant to the threat evaluation. Figure 1-5 expands on some
of the "other" external parties that the IO or LO in Figure 1-4 (top
right) may need to contact. Note that the local entities in this figure
may be contacted earlier than those at higher levels of government.

![](media/image12.wmf)

**Figure 1-5. Overview of Potential External Notifications**

Figure 1-5 does not seek to define a notification scheme or their
possible role within the ICS structure -- both of these tasks will be
incident-specific and/or dictated at the local level. Rather, the figure
provides a basic structure for the parties typically involved. These
parties are divided into those that are external but still local, and
those that are external but at higher levels of government.
Notifications by the utility during the threat evaluation at the
'credible' stage include the drinking water primacy agency (often the
State), the emergency response community (including HazMat, EMS, etc.),
law enforcement agencies (local, state, and/or federal), government
agencies (local, state, and/or federal), the public health community,
and external laboratories. Not all of these notifications need to be
made in every incident---the overall response plan may dictate what
level of notifications should occur and at what stage of the threat
evaluation, which in turn dictates who will make the notification. For
instance, depending on State requirements, it may not be appropriate for
the utility to contact the EPA National Response Center directly.
Nevertheless, contact information should be available for all
individuals and organizations that may need to be contacted.

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

The 'confirmed' stage pictured in Figure 1-4 (bottom right), represents
a significant change in the communication structure because an external
agency operating under unified commend will be in charge of the
response. Also, the Water Utility Emergency Operations Center (WUEOC)
will likely be activated (if it was not already during the 'credible'
stage). The chain of communications may proceed through the WUEOC
manager (WUEOCM). Technical Specialists that participate in the ICS
operated under unified command may also be part of the EOC staff.
Additional technical specialists may need to be notified, such as those
responsible for repair and maintenance, who would not necessarily be
engaged before the incident is confirmed. The role of the utility in
overall management and command of the incident may proportionally
decrease as many other external parties become involved (see Figure
1-5).

## Perform Training and Desk/Field Exercises

In addition to a lack of planning, another reason that emergency
response plans fail is lack of training and practice. Training provides
the necessary means for everyone involved to acquire the skills to
fulfill their role during an emergency. It may also provide important
'buy-in' to the response process from both management and staff, which
is essential to the success of any response plan. Desk exercises (also
known as 'tabletops' or 'sand lots') along with field exercises allow
participants to practice their skills. Also, these exercises will
provide a test of the plan itself, revealing strengths and weakness that
may be used to improve the overall plan. Improvements can include
measures not only for intentional contamination of water, but also for
other emergencies faced by the water utility and the community at large.

Training may be available from EPA or other federal partners. For
instance, several online training courses relevant to emergency
management are available on-line from FEMA
(<http://training.fema.gov/EMIWeb/IS/crslist.asp>). These courses cover
a range of topics including community disaster exercises, emergency
manager orientation, and animal health and safety during disasters.
Further, it is worthwhile mentioning some areas where formal training is
desirable, but not currently available. For example, in addition to
training for sampling and site characterization, there are also training
needs for a general understanding of the overall threat management
process and the ability to make important decisions quickly and with
limited information. In the absence of formal training, the reports,
forms, templates, SOPs, and checklists that make up a set of RGs may be
used as worksheets to practice potential scenarios.

[]{.mark}

## Enhance Physical Security 

Denying physical access to key sites within the water system may act as
a deterrent to a perpetrator. Criminals often seek the easiest route of
attack, just like a burglar prefers a house with an open window. Aside
from deterring actual attacks, enhancing physical security has other
benefits. For example, installation of fences and locks may reduce the
rate of false alarms. Without surveillance equipment or locks, it may
not be possible to determine whether a suspicious individual has
actually entered a vulnerable area. The presence of a lock and a
determination as to whether it has been cut or broken provides sound,
although not definitive, evidence that an intrusion has occurred.
Likewise, security cameras can be used to review security breaches and
determine if the incident was simply due to trespassing or is a
potential contamination threat. The costs of enhancing physical security
may be justified by comparison to the cost of responding to just one
'credible' contamination threat involving site characterization and
laboratory analysis for potential contaminants.

The correct choice of security enhancements varies by utility, and a
number of resources are available to assist in this selection process.
For instance, a vulnerability assessment (see Section 4.1.1) may provide
a sound basis for making security upgrades. The American Water Works
Association has developed a field guide (AWWA, 2002) to help meet
security challenges. EPA has developed a series of Security Product
Guides to assist treatment plant operators and utility managers in
reducing risks from, and providing protection against, possible natural
disasters and intentional terrorist attacks
(<http://www.epa.gov/safewater/security/guide/index.html>).

## Establish Baseline Monitoring Program

Background concentrations of suspected or tentatively identified
contaminants may be extremely important in determining if a
contamination incident has occurred. Number range CHAPTERIn some cases,
and for some contaminants, background levels may be at detectable
concentrations. **If unrecognized, these may be confused with an actual
contamination incident.** Baseline occurrence information, discussed
more thoroughly in Module 3, Section 3.5, is derived from monitoring
data and is used to characterize typical levels of a particular
contaminant or water quality parameter. Baseline data may be used for
two purposes in the context of emergency water sampling:

-   If general water quality parameters, such as pH, chlorine residual,
    or conductivity, among others, are used as indicators of possible
    contamination incidents, a baseline must be established such that
    significant deviations from the baseline can be observed.

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

## Utilize and Understand On-line Monitoring

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

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

# References and Resources

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

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

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

AWWARF. 2003. Actual and Threatened Security Events, AWWARF Project
2810, American Water Works Association, Denver, CO.
<http://www.awwarf.org/research/TopicsAndProjects/projectSnapshot.aspx?pn=2810>

DHS. 2003a. "Initial National Response Plan"

<http://www.dhs.gov/interweb/assetlibrary/Initial_NRP_100903.pdf>

FEMA. 2003a. "IS-195 Basic Incident Command System -- EMI Independent
Study Program"

<http://training.fema.gov/EMIWeb/IS/is195.asp>

FEMA. 2003b. "Independent Study Course List"

<http://training.fema.gov/EMIWeb/IS/crslist.asp>

FEMA. 2003c. "Federal Response Plan"

<http://www.fema.gov/rrr/frp/>

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

<http://www.ncjrs.org/pdffiles1/nij/197065.pdf>

WHO. 2001. "Health Aspects of Biological and Chemical Weapons"

<http://www.who.int/emc/pdfs/BIOWEAPONS_FULL_TEXT2.pdf>

U.S. EPA. 2002. "EPA Community Drinking Water Security Requirements"

<http://www.epa.gov/safewater/security/community.html>

U.S. EPA. 2003a. "The Safe Drinking Water Act"

<http://www.epa.gov/safewater/sdwa/sdwa.html>

U.S. EPA. 2003b. Model Emergency Response Plan, in preparation.

U.S. EPA. 2003c. "Large Water System Emergency Response Plan Outline:
Guidance to Assist Community Water Systems in Complying with the Public
Health Security and Bioterrorism Preparedness and Response Act of 2002"

<http://www.epa.gov/ogwdw/security/pdfs/erp-long-outline.pdf>

U.S. EPA. 2003d. "FORMS II Lite"
<http://www.epa.gov/superfund/programs/clp/f2lite.htm>

U.S. EPA. 2003e. "Security Product Guides"

<http://www.epa.gov/safewater/security/guide/index.html>

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

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

<http://www.ilsi.org/file/EWM.pdf>

NRT. 2000. "NRT Joint Information Center Model: Collaborative
Communications During Emergency Response"
<http://www.nrt.org/production/nrt/home.nsf/Resources/publications/$FILE/JIC.pdf>

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

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

# Appendices

## Sample Outline of Response Guideline

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

*[EMERGENCY RESPONSE GUIDE OUTLINE]{.underline}*

1.  Overview of/Introduction to Response Guidelines (Module 1, Section
    4.3)

2.  Threat Warning Descriptions (Module 1, Section 2.2)

3.  Initial Communication and Notifications (Module 1, Section 4.6)

4.  Threat Evaluation

    a.  Threat Warning Report Forms (Module 2, Appendix 8.3-8.8)

    b.  Threat Evaluation Worksheets (Module 2, Appendix 8.2)

5.  Site Characterization

    a.  Site Characterization Plan Template (Module 3, Appendix 8.1)

    b.  Field Testing Results Form (Module 3, Appendix 8.3)

    c.  Site Characterization Report Form (Module 3, Appendix 8.2)

    d.  Sample Documentation Form (Module 3, Appendix 8.4)

6.  Planned Responses

    a.  Response Planning Matrix (Module 2, Appendix 8.1)

    b.  Action Plan (Module 2, Section 2.4)

    c.  Guidelines for Contaminant Containment (Module 5, Section 4)

    d.  Contaminant Identification (Module 4)

    e.  Treatment, Removal And/or Disposal of Contaminant (Module 6,
        Section 6)

    f.  Public Notification (Module 5, Section 5)

    g.  Alternate Domestic Water (Module 6, Section 5)

    h.  Fire Flow Supply (Module 6, Section 5)

    i.  Expanded Communications (Module 1, Section 4.6)

7.  Plan for Return of Water System to Service (Module 6, Section 8)

8.  Appendixes

    a.  Appendix I: Phone Directories for Notifications (Module 1,
        Section 4.6)

    b.  Appendix II: Drinking Water Advisories (Module 5, Appendices 8.2
        -- 8.5)

## U.S. Government Response Plans

### National Response Plan

The U.S. Department of Homeland Security was tasked by the Homeland
Security Presidential Directive 5 (HSPD-5) to develop, submit to the
Homeland Security Council, and administer a National Response Plan
(NRP). HSPD-5 required the development and publication of an Initial NRP
(INRP), which was released on September 30, 2003. Pending the
development of the full NRP, the INRP provides an interim implementation
of the domestic incident management authorities, roles, and
responsibilities of the Secretary of Homeland Security as defined in
HSPD-5. It also provides interim guidance on Federal coordinating
structures and processes for domestic incident management. The INRP is
applicable to domestic incident management in the context of terrorist
attacks, major disasters, and other emergencies. A final NRP will
eventually replace the INRP. In the interim period, until the full NRP
becomes effective, current Federal incident management and emergency
response plans remain in effect, except as specifically modified by the
INRP. The full text of the INRP is available at
<http://www.dhs.gov/interweb/assetlibrary/Initial_NRP_100903.pdf> and a
fact sheet is found at
<http://www.dhs.gov/dhspublic/interapp/press_release/press_release_0278.xml>

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

There are five current emergency response plans that are linked by the
INRP:

-   Federal Response Plan

-   U.S. Government Interagency Domestic Terrorism Concept of Operations
    Plan

-   Federal Radiological Emergency Response Plan

-   Mass Migration Response Plans

-   National Oil and Hazardous Substances Pollution Contingency Plan

Of these, perhaps the Federal Response Plan is most relevant to water
contamination, and it is more completely described below in Appendix
6.2.2.

### Federal Response Plan

The Federal Response Plan (FRP, <http://www.fema.gov/rrr/frp/>) provides
the mechanism for federal departments and agencies to coordinate
delivery of Federal assistance to State and local governments during a
major disaster or emergency, including terrorist acts. The FRP supports
implementation of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act (Stafford Act), as amended (42 U.S. Code 5121, et seq.),
as well as individual agency statutory authorities. Under the Stafford
Act, a State Governor may request the President to declare a major
disaster or an emergency if an event is beyond the combined response
capabilities of the State and affected local governments. Only after the
President makes a declaration is the FRP used.

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

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

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

**DOJ/FBI.** DOJ delegates the role of lead federal agency (LFA) to the
FBI for operational response. The FBI responsibilities potentially
supportive of remediation and recovery will include:

-   Designating and establishing a Joint Operations Center (JOC) in the
    field;

-   Appointing an FBI On-Scene Commander (OSC) who will convene and
    chair meetings of operational decision makers representing lead
    State and local agencies, DHS/FEMA, and other supporting Federal
    agencies (e.g., EPA);

-   Working with DHS to establish and operate a Joint Information Center
    (JIC) in the field as a focal point for information to the public
    and media concerning Federal response;

-   Issuing and tracking the status of crisis management actions
    assigned by the FBI; and

-   Designating appropriate liaison and advisory personnel to support
    DHS.

**DHS.** DHS supports the overall LFA by operating as the lead agency
for consequence management until the overall LFA role is transferred to
DHS. DHS will:

-   Work with the FBI to establish and operate a JIC in the field as the
    focal point for information to the public and the media concerning
    the Federal response to the emergency;

-   Establish the primary Federal operations centers for consequence
    management in the field and Washington, DC;

-   Appoint a Regional Support Team (RST) Director or Federal
    Coordinating Officer (FCO) to manage and coordinate the Federal
    consequence management response in support of State and local
    governments. In coordination with the FBI, the RST Director or FCO
    will convene meetings with decision makers to formulate incident
    action plans, define priorities, review status, resolve conflicts.
    These meetings may also be used to identify issues that require
    decisions from higher authorities, and evaluate the need for
    additional resources. Decision makers present at meetings may
    include Federal, State, and local emergency management and technical
    support agencies, as appropriate;

-   Issue and track the status of consequence management actions
    assigned by DHS;

-   Designate appropriate liaison and advisory personnel to support the
    FBI; and

-   As needed, provide assets of the National Disaster Medical System
    and/or the Metropolitan Medical Response System.

**HHS.** As directed in PDD-39, the Department of Health and Human
Services (HHS) will activate technical operations capabilities to
support the Federal response to threats or acts of WMD terrorism. HHS
may coordinate with individual agencies identified in the HHS Health and
Medical Services Support Plan for the Federal Response to Acts of
Chemical/Biological (C/B) Terrorism. Coordination efforts will use the
structure, relationships, and capabilities described in the HHS plan to
support response operations. Note that CDC, and thus the Laboratory
Response Network (LRN), is part of HHS. If the HHS plan is implemented:

-   The HHS on-scene representative will coordinate the HHS plan
    response with the DHS;

-   The HHS plan response may include consultation, agent
    identification, epidemiological investigation, hazard detection and
    reduction, decontamination, public health support, medical support,
    and pharmaceutical support operations; and

-   HHS will issue taskings that draw on funding from the responding HHS
    plan agencies.

**EPA.** As directed in PDD-39, the EPA will activate technical
operations capabilities to support the Federal response to acts of WMD
terrorism. EPA may coordinate with individual agencies identified in the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP)[^1] to use the structure, relationships, and capabilities of the
National Response System as described in the NCP \[40 CFR Part 300
subpart B\] to support response operations. If the NCP is implemented:

-   The Hazardous Materials On-Scene Coordinator under the NCP will
    coordinate the NCP response with the DHS official (either the RST
    Director or the FCO), who is responsible under PDD-39 for on-scene
    coordination of all Federal support to State and local governments;
    and

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

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

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

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

## On-Line Monitoring Systems

### Conventional systems

Conventional on-line monitoring systems are largely designed to measure
typical water quality parameters in a near-real or real-time fashion.
Examples of these parameters include: temperature, turbidity, particle
counts, color, conductivity, total dissolved solids, alkalinity, pH,
chlorine residual, specific UV absorbance, TOC, along with a host of
inorganic and organic chemicals. In addition, water flow, level, and
pressure may be automatically recorded. Many of these systems are
designed to meet regulatory goals related to the reduction of turbidity,
DBP formation, and other water quality parameters. These systems are
often connected to a utility's SCADA and/or GIS system. The water
quality parameters accessible through these systems may also have water
security applications, specifically by providing a warning of a possible
threat, as discussed in Section 2.2. However, interpretation of this
data must be performed cautiously, as discussed in Module 2.

### Early warning systems

The goal of an early warning system (EWS) is to identify a low
probability/high impact contamination incident in a water system
allowing sufficient time for an appropriate response that mitigates or
eliminates any adverse impact resulting from the incident (ILSI, 1999).
Typically, an EWS for water would be designed to detect the introduction
of toxic or infectious contaminants that pose a risk to public health.
According to the ILSI report, an ideal EWS would 1) be fully automated,
2) have a rapid response time and high sampling rate, 3) provide a
specific and sensitive screen for a range of contaminants, 4) have a low
occurrence of false positives and negative, 5) be reliable and rugged,
6) be easy to use, and 7) be affordable to install and operate. Although
there are many on-line monitoring systems currently being discussed for
use as EWSs, currently, an EWS with all of these features does not
exist.

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

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

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

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

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

[^1]: Agencies listed in the NCP include: USCG, FEMA, DOD, DOE, USDA,
    DOC, HHS, DOI, DOJ, DOL, DOT, DOS, NRC, and GSA.