Allgeier, Steven C.

Magnuson, Matthew L.

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JOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATION UCOWR13Allgeier and MagnusonResponding to Threats and Incidents ofIntentional Drinking Water ContaminationSteven C. Allgeier1 and Matthew L. Magnuson2U.S. Environmental Protection Agency, Cincinnati, OH1OW/OGWDW/Water Security Division 2ORD/NRMRL/Water Supply and Water Resources DivisionBoth water contamination threats andintentional water contamination incidentscould be designed to disrupt the delivery ofsafe water to a population, interrupt fire protection,create public panic, or cause disease or death in apopulation.  A water contamination threat occurswhen the introduction of a contaminant into the watersystem is threatened, claimed, or suggested byevidence.  A water contamination incident occurswhen a contaminant is successfully introduced intothe water supply.  A water contamination incidentmay be preceded by a threat, but not always.  Bothwater contamination threats and incidents may beof particular concern due to the range of potentialconsequences:1. Creating an adverse impact on public healthwithin a population2. Disrupting system operations and interruptingthe supply of safe water3. Causing physical damage to systeminfrastructure4. Reducing public confidence in the water supply5. Long-term denial of water and the cost ofremediation and replacement.Some of these consequences would only be realizedin the event of a successful contamination incident;however, the mere threat of contamination can havean adverse impact on a water system if improperlyhandled.In characterizing any threat, both the possibilityand probability should be considered.  A generalassessment of the threat of intentional contaminationof drinking water indicates that it is possible to causevarying degrees of harm through contamination ofthe drinking water supply.  However, an evaluationof past incidents at drinking water facilities wouldindicate that the probability of an actualcontamination incident is relatively low, but theprobability of a contamination threat is relatively high.Many of the apparent security breaches at drinkingwater utilities that have occurred since 9/11 havebeen perceived as potential contamination incidents.Although a few threats have been verbal, most havebeen circumstantial, such as a low-flying airplaneover a reservoir or a lock cut from the hatch of adistribution system storage tank.  Given the possibilityof contamination, many utilities choose to treat thesesecurity breaches as potential contamination threats.Vulnerabilities to intentional contamination existin all drinking water systems.  While it may bepossible to improve security at some critical systemlocations to reduce the level of vulnerability, it isimpossible to eliminate all vulnerabilities.  Thus, thecontamination threat may be most effectivelymanaged through thorough planning, carefulevaluation of any specific threats, and implementationof appropriate response actions.Managing a Contamination ThreatManagement of a contamination threat involves:1) planning for the response prior to an incident, 2)evaluating the credibility of the threat, and 3)implementing appropriate response actions based onavailable information and the circumstances of thesituation.  This article provides an overview of theUNIVERSITIES COUNCIL ON WATER RESOURCESJOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATIONISSUE 129, PAGES 13-17, OCTOBER 2004Responding to Threats and Incidents of Intentional Drinking Water Contamination14JOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATIONUCOWRprocess for managing a contamination threat, whilemore detailed guidance is available from theResponse Protocol Toolbox: Planning for andResponding to Drinking Water ContaminationThreats and Incidents (EPA 2003a).  This toolboxis organized into six modules, which discuss waterutility planning (EPA 2003b), water contaminationthreat management (EPA 2003c), sitecharacterization and sampling (EPA 2003d), sampleanalysis (EPA 2003e), public health response, andwater system remediation and recovery.  Additionalresources for drinking water security in general maybe found at the EPA Water Security Division website(http://www.epa.gov/safewater/security/).1. Planning a Response to ContaminationThreatsPlanning is the foundation of making goodresponse decisions.  For water contamination threatsand incidents, planning takes on a special meaningbecause of the multitude of potential and/orthreatened contaminants, whether they arebiological, chemical, or radiological.  However, toparaphrase the World Health Organization, it isneither possible nor necessary to specifically planfor attack with all possible contaminants, butincreasing preparedness to counter the effects forsuch an attack by planning and preparation canprovide the capabilities to deal with a wide range ofpossibilities (WHO 2003).Planning for any type of emergency, includingwater contamination threats and incidents, begins atthe local level.  Officials within the utility and localgovernment will have a collective knowledge of theorganizations and systems that exist to providesupport during an emergency.  During this planning,the utility and local or state authorities will need todetermine:1. Who will respond to the initial threat?2. Who will determine if the threat is possible orcredible?3. Who will evaluate the site and collect samples?4. Who will perform analyses?5. Who will make public health decisions?6. Who will manage remediation and recoveryactivities?In many cases, the answers to these questionswill not be immediately evident, or may vary withthe circumstances of the situation.  This is especiallytrue in the case of drinking water contaminationthreats where it is unclear whether or not the waterhas been contaminated and presents a threat to publichealth.  Proper planning should establish roles andresponsibilities of various parties under a variety ofscenarios.  There are many planning activities thata drinking water utility can undertake to improvepreparedness and the ability to respond effectivelyto a drinking water contamination threat or incident,and several are briefly described below.1. Know your water system:  This includesdocumentation of construction, design, operation,and personnel; assessment of vulnerabilities tocontamination threats; and identification ofcritical customers.2. Update Emergency Response Plans:  Manyutilities have existing Emergency ResponsePlans (ERPs); however they may need to beupdated to cover terrorist threats, includingintentional contamination.3. Develop Response Guidelines:  A set ofResponse Guidelines (RG) is a streamlined,action-oriented, easy-to-follow document thatis intended to support responders and decisionofficials in the midst of a crisis.  An RG mightinclude organizational charts, notification trees,contact information, standard operatingprocedures, decision trees, and reporting formsamong other tools.4. Establish Structure for Incident Command:  Theleadership and chain-of-command must beclearly established prior to an actual threat orincident.  There is a formal Incident CommandSystem that has been adopted by many responseorganizations (FEMA 2003).  IncidentCommand for drinking water response isintricate because the water utility may behandling the early stages of the threat evaluation,while other parties, such as law enforcement,may be in charge during later stages(EPA 2003b).5. Develop Information Management Strategy:Timely and accurate information will be key toevaluating the credibility of a threat and takingsteps to protect public health as necessary.  Asystem should be in place to manage the flowof this critical information.6. Establish Communication and NotificationStrategy:  Predefined communication pathwaysand notification trees are essential to theeffectiveness of any incident commandJOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATION UCOWR15Allgeier and Magnusonstructure and will help to ensure that importantparties are notified at the right time.7. Perform Training and Conduct Desk/FieldExercises:  Training and practice are essentialto the proper application of any emergency plan(e.g., ERP, RG).  Desk-top or field exercisesthat involve all of the key players are a valuabletest of the plan.8. Enhance Physical Security:  Enhancements tophysical security at sites identified as particularlyvulnerable to contamination, or which have beensubject to intrusion in the past, may significantlyreduce false alarms that would otherwiseexpend utility resources.9. Establish a Baseline Monitoring Program:Unusual water quality data or consumercomplaints may indicate a potential problem, butonly if the results can be compared against anestablished baseline that accounts for normalfluctuations.2. Evaluating a Contamination ThreatA contamination threat is typically triggered byan occurrence or discovery that indicates thepotential for water contamination.  Several potentialthreat warnings are summarized in Figure 1.  Threatwarnings occur on a regular basis if they aremonitored; however, the vast majority are due toharmless activity and require no response.Nonetheless, every threat of potential drinking watercontamination should be evaluated in order to identifythe handful of credible threats that might exist amongthe large number of threat warnings.The overall response to a contamination threat isschematically depicted in Figure 2 and indicates twoparallel and inter-related activities: the threatevaluation and response actions.  A fundamentalprinciple of this process is the concept of expandedresponse actions as the credibility of the threatincreases.  This is intended to avoid both under- andover-response to a contamination threat since bothhave potential adverse consequences to the public.For example, a complete lack of response to acredible threat might put the public at anunacceptable risk of exposure to a harmfulcontaminant.  On the other hand restrictions placedon water usage, such as a notice not to drink thewater, in response to a threat that has not beendetermined to be credible carries its ownconsequences.A threat evaluation is a process that considersavailable information about a contamination threatto determine if it is “possible,” “credible,” or a“confirmed” incident.  Each of these stages isdepicted in Figure 2 as a decision point and describedin more detail below:1. Stage 1: “Is the threat possible?”  A watercontamination threat is characterized as“possible” if the circumstances of the threatInitial Threat EvaluationTHREAT EVALUATIONPROCESSIs ThreatPossible?Threat WarningPLANNING AND PREPARATIONIs ThreatCredible?Is IncidentConfirmed?Site Characterization andSamplingImmediate OperationalResponse ActionsPublic Health ResponseActionsSample AnalysisRemediation and RecoveryEXPANDEDRESPONSE ACTIONSFigure 2. Overview of Response to a Contamination ThreatTHREATWARNINGSecurityBreachWitnessAccountNotification byPerpetratorNotification byLaw EnforcementNotification byNews MediaUnusual WaterQualityConsumerComplaintPublic HealthNotificationFigure 1. Summary of Threat WarningsResponding to Threats and Incidents of Intentional Drinking Water Contamination16JOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATIONUCOWRwarning appear to have provided an opportunityfor contamination.  Response to a “possible”threat might include immediate operationalresponse actions in an attempt to contain thewater, and collection of additional informationto help establish whether or not the threat is“credible.”  Site characterization activities aredesigned to collect additional information tosupport this determination.2. Stage 2: “Is the threat credible?”  A watercontamination threat is characterized as“credible” if information collected during thethreat evaluation process (e.g., sitecharacterization activities) corroboratesinformation from the threat warning.  Thethreshold at the credible stage is higher than thatat the possible stage, thus more significantresponse actions might be considered, such asrestrictions on public use of the water (e.g.,issuance of a “do not drink” notice).Furthermore, steps should be initiated to confirmthe incident and positively identify thecontaminant.3. Stage 3: “Has the incident been confirmed?”  Awater contamination incident is “confirmed” ifthe information collected over the course of thethreat evaluation provides definitive evidencethat the water has been contaminated.  Responseactions at this point include all steps necessaryto protect public health, supply the public withan alternate source of drinking water, and beginremediation of the system.3. Responding to a Contamination ThreatFigure 2 illustrates the elevation of potentialresponse actions as the threat evaluation progressesthrough the “possible,” “credible,” and “confirmed”stages.  In addition to the results of the threatevaluation, consideration should be given to thepotential consequences of the suspectedcontamination incident as well as the impact ofresponse actions on consumers.  The consequencesof contamination are a function of contaminantproperties (e.g., toxicity, infectivity, persistence inwater, etc.), the concentration profile of thecontaminant through the system, and the populationwithin the contaminated area.  In many cases, it willbe difficult to accurately assess the potentialconsequences since the identity of the contaminantmay be unknown and the information necessary toestimate the spread of the contaminant through thesystem may be unavailable.  Nonetheless, even anestimate of potential consequences within a coupleorders of magnitude may be useful in makingdecisions regarding response actions (e.g., are tensor thousands of people potentially affected?).Various response actions will have differentimpacts on consumers.  For example, immediateoperational response actions such as containmentmay go unnoticed by the public.  On the other hand,restrictions on water usage could have a substantial,negative impact on consumers.  Consumers mayneed to find an alternate supply of water forconsumption and food preparation.  For the mostsevere restrictions, sanitation and fire fighting mayalso be adversely impacted.Early in the response to a contamination threat,before credibility has been established andconsequences evaluated, relatively low impactresponse actions would be appropriate.  For example,isolation of a storage tank, reservoir, or small areaof the distribution system might be a suitableresponse to a ‘possible’ contamination threat.  Oncea threat has been deemed ‘credible’ it may benecessary to take steps to limit public exposure.  Thismight involve more extensive isolation, or if thesuspect water cannot be contained, it may benecessary to notify the public and place restrictionson water usage (i.e., issue a “do not drink” order).Finally, once a contamination incident is confirmed,all actions necessary to limit exposure and protectpublic health should be initiated.  Furthermore, it willbe necessary to arrange for an alternate watersupply and begin planning for remediation activities.SummaryAll drinking water systems have some degree ofvulnerability to contamination, and analysis showsthat it is possible to contaminate drinking water atlevels causing varying degrees of harm.Furthermore, experience indicates that the threat ofcontamination, overt or circumstantial, is probable.Thus, there is a clear need to address thecontamination threat.  While certain steps may betaken to reduce the vulnerabilities and preventintentional contamination, it is impossible tocompletely eliminate this vulnerability, although autility could spend a lot of resources trying to do so.Instead, it may be more effective to plan forresponding to contamination threats that do arise.JOURNAL OF CONTEMPORARY WATER RESEARCH AND EDUCATION UCOWR17Allgeier and MagnusonAcknowledgementsThe authors would like to acknowledge the hard work andcontributions of Bart Koch, Ric DeLeon, and Mic Stewart ofthe Metropolitan District of Southern California and RonHunsinger of the East Bay Municipal Utility District.Author Bio and Contact InformationSTEVEN ALLGEIER has been an environmental engineer with U.S.EPA, OGWDW in Cincinnati, Ohio since 1996.  He is currentlyinvolved in both the drinking water regulatory and securityprograms with a focus on contaminant removal through advancedtreatment processes.  Address: 26 W. Martin Luther King Drive,Cincinnati OH 45268.  Email address: allgeier.steve@epa.gov.MATTHEW MAGNUSON has been a research chemist at the U.S.EPA/ORD/NRMRL in Cincinnati, Ohio since 1996.  He iscurrently involved in both security programs and researchdirected towards a wide range of problems in environmentalanalytical chemistry related to risk management research ofcontaminants in watersheds and drinking water.  Address: 26W. Martin Luther King Drive, Cincinnati OH 45268.  Emailaddress: magnuson.matthew@epa.gov.ReferencesFederal Emergency Management Agency (FEMA). 2003a. IS-195 Basic Incident Command System – EMI IndependentStudy Program.Washington, DC: Federal EmergencyManagement Agency. Available at http://training.fema.gov/EMIWeb/IS/is195.asp.U.S. Environmental Protection Agency (USEPA). 2003a.Overview of the Response Protocol Toolbox. EPA-817-D-03-007. Washington, DC: U.S. Environmental ProtectionAgency, Office of Water. Available at http://www.epa.gov/safewater/security/pdfs/guide_response_overview.pdf.U.S. Environmental Protection Agency (USEPA). 2003b. WaterUtility Planning Guide - Module 1. EPA-817-D-03-001.Washington, DC: U.S. Environmental Protection Agency,Office of Water. Available at http://www.epa.gov/safewater/security/pdfs/guide_response_module1.pdf.U.S. Environmental Protection Agency (USEPA). 2003c.Contamination Threat Management Guide - Module 2 EPA-817-D-03-002.  Washington, DC: U.S. EnvironmentalProtection Agency, Office of Water. Available at http://w w w . e p a . g o v / s a f e w a t e r / s e c u r i t y / p d f s /guide_response_module2.pdfU.S. Environmental Protection Agency (USEPA). 2003d. SiteCharacterization and Sampling Guide - Module 3. EPA-817-D-03-003. Washington, DC: U.S. EnvironmentalProtection Agency, Office of Water. Available at http://w w w . e p a . g o v / s a f e w a t e r / s e c u r i t y / p d f s /guide_response_module3.pdf.U.S. Environmental Protection Agency (USEPA). 2003e.Analytical Guide - Module 4. EPA-817-D-03-004.Washington, DC: U.S. Environmental Protection Agency,Office of Water. Available at http://www.epa.gov/safewater/security/pdfs/guide_response_module4.pdf.World Health Organization (WHO). 2003. Public healthresponse to biological and chemical weapons: WHOguidance, 2nd ed. (Draft, March 2003). Available at http://www.who.int/csr/delibepidemics/biochemguide/en/index.html.

Responding to Threats and Incidents of Intentional Drinking Water Contamination

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Responding to Threats and Incidents of Intentional Drinking Water Contamination

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