11.1 Emergency Response, Facility Security & Water Loss Control

11.1 Emergency Response, Facility Security & Water Loss Control

Quick Answer: A water system must maintain a written Emergency Response Plan (ERP), assess its vulnerabilities, harden facility security, and run a water-loss control program that separates real losses (leaks, main breaks) from apparent losses (metering errors, unauthorized use). Federally, AWIA Section 2013 requires community systems serving more than 3,300 people to certify a risk and resilience assessment (RRA) and an ERP to EPA; smaller systems still need a plan under state rules. These protect public health, keep service running during disruptions, and control non-revenue water (NRW).

Emergency Response Plan (ERP)

An Emergency Response Plan (ERP) is a written document that defines how a water system prepares for, responds to, and recovers from disruptions — main breaks, contamination events, power outages, natural disasters, source contamination, or intentional acts. Community water systems serving more than 3,300 people must certify an ERP to EPA under AWIA Section 2013; every other system maintains and updates an ERP under its primacy agency (the state drinking water program that administers the Safe Drinking Water Act).

The required and recommended components of an ERP are:

• Chain of command — who is in charge during an emergency (an incident commander and alternates), with clear authority and decision-making power.
• Contact list — current after-hours phone numbers for operators, mutual-aid partners, the state primacy agency, laboratories, contractors, electric and gas utilities, police and fire, county emergency management, and the state's AWWA WARN (Water/Wastewater Agency Response Network) mutual-aid network.
• Risk/asset assessment — critical assets (source, treatment, pump stations, storage, SCADA), single points of failure, and credible hazards.
• Contingency/water-supply plan — alternate sources, interconnections, emergency storage, tanker fill points, bottled-water vendors, and a prioritized restoration sequence.
• Communication plan — templates for boil-water notices, do-not-use notices, public notifications, media coordination, and a designated spokesperson.
• Recovery/return-to-normal — flushing, rechlorination, bacteriological sampling, damage documentation, and after-action review to update the ERP.

A plan that sits on the shelf fails under stress — operators should drill the ERP at least annually and update contact lists whenever staff or mutual-aid partners change.

Vulnerability and Risk Assessments

Assessing vulnerabilities is a Need-to-Know task in its own right — "identify opportunities to mitigate risks." The federal requirement has moved:

The RRA covers the same ground the old VA did and more: risks from malevolent acts and natural hazards, and the resilience of pipes and constructed conveyances, physical barriers, source water, collection and pretreatment, treatment, storage and distribution, electronic/computer/automated systems (cybersecurity), monitoring practices, financial infrastructure, chemical use and storage, and operation and maintenance. Systems serving 3,300 or fewer are not federally required to certify one, but are strongly encouraged to assess risk using EPA or AWWA tools.

Whichever tool is used, the output is the same chain the operator sees in the field: critical assets → credible threats → consequences → countermeasures, feeding directly into the ERP and the system's security upgrade priorities.

Facility Security

Physical and cyber security measures for distribution facilities include:

• Perimeter controls — fencing (typically 6–7 ft chain-link with locked gates), lighting, and signage around wells, pump stations, storage, and treatment.
• Access control — keyed or badge-locked doors, locked hatches, and screened vents on tanks.
• Surveillance and alarms — security cameras, intrusion alarms, and SCADA (Supervisory Control and Data Acquisition) monitoring that flag unauthorized entry, low/high tank levels, sudden pressure loss, or chlorine feed failure.
• Cyber security — firewalls, segmented SCADA networks, unique credentials, multi-factor authentication, patching, and tightly limited vendor remote access.
• Hydrant and sampling-point security — locking hydrant caps where tampering is a concern and locked sampling stations.

Investigating System Tampering

Security is not only prevention; the Need-to-Know Criteria list investigating system tampering as its own operator task. Tampering shows up in three recognizable forms:

• Meter tampering / water theft — a reversed or bypassed meter, a cut or missing lock ring, a broken seal, a jumper around the meter, or an unauthorized hydrant connection. The usual signal is consumption that drops sharply with no change in occupancy.
• Facility intrusion — cut fence fabric, forced hatches or vault lids, damaged locks, tool marks on a well cap or tank hatch, or footprints and vehicle tracks inside a fenced site.
• Contamination attempt — anything introduced into a tank hatch, vent, well casing, or open sampling station; an unexplained residual loss or odor complaint clustered around one facility can be the first indication.

The response sequence matters more than the diagnosis:

1. Do not disturb the scene. Photograph the condition before touching anything; a cut lock is evidence.
2. Assess the water-quality risk first. If a contamination pathway is credible, isolate the facility, sample, and treat it as a water-quality emergency until proven otherwise.
3. Notify the supervisor, the state primacy agency, and law enforcement per the emergency response plan — contamination threats are reportable.
4. Document date, time, discovering employee, condition found, photographs, and every person notified.
5. Restore and harden — replace the lock or seal, repair the breach, and note whether the site needs better lighting, a stronger hatch, or an intrusion alarm.

Meter tampering is handled through the utility's billing and theft-of-service policy rather than as a public-health event, but it is documented the same way: photograph, record the register reading and seal number, and route it through the customer-service process instead of confronting the customer in the field.

Water Quality Emergencies

A boil-water notice is issued when microbiological contamination is confirmed or suspected — for example, total coliform positive with E. coli, loss of pressure, treatment failure, or a main break with potential intrusion. A do-not-use notice is stronger and is issued for chemical contamination where boiling does not help or makes exposure worse. Both require coordination with the state primacy agency, public notification within 24 hours for Tier 1 acute violations, and a lifting protocol that includes consecutive clean samples, flushing, rechlorination, and verification.

Water Loss Control

Non-revenue water (NRW) is the volume of water produced that is not billed — real losses plus apparent losses plus unbilled authorized use. The AWWA M36 Water Audit methodology is the industry standard for quantifying and managing NRW.

• Real losses — physical losses from the distribution system: main breaks, service leaks, tank overflow, and undetected leaks. Controlled by leak detection, pressure management, repair speed, and proactive main replacement.
• Apparent losses — water that is consumed but not billed: meter under-registration (small flows, aged meters), billing/data errors, and unauthorized use (theft, bypassed meters, illegal hydrant openings). Controlled by meter testing and replacement, billing audits, and enforcement.

Leak-detection methods include acoustic listening devices, leak noise correlators, step testing (valving off sections and watching flow), and minimum-night-flow analysis on district-metered areas. Pressure management reduces leak flow rate and main break frequency by installing pressure-reducing valves and avoiding excessive static pressures. A main replacement program prioritizes cast iron, asbestos-cement, and old galvanized mains by break history, age, and material.

Keeping NRW below 10–15% is a common industry benchmark; values above 25% warrant a full M36 audit and active intervention. Remember the contrast: a leak is a real loss (water physically leaves the system), while a slow meter is an apparent loss (water is delivered but not measured or billed).

Mutual Aid and Coordination

No system stands alone during a major event. The state WARN (Water/Wastewater Agency Response Network) allows utilities to share crews, equipment, and materials under a pre-signed mutual-aid agreement that addresses liability, cost reimbursement, and deployment. Operators should know how to request help through WARN and how to receive and stage incoming crews. Coordination extends to the county emergency operations center, the state primacy agency duty officer, and EPA regional contacts for contamination events. Documenting mutual-aid use in the ERP — including trigger thresholds and a sample request form — shortens the response time when hours matter.

During recovery, the operator in charge compiles a damage summary, logs all costs (eligible for FEMA Public Assistance in declared disasters), and convenes an after-action review with all responders to update the ERP. The ERP is a living document; every drill and every real event should produce at least one revision.