12.5 Emergency Action Plans, Security Vulnerability, Spill Containment & CDPHE Tier 1/2/3 Public Notice

America's Water Infrastructure Act (AWIA) Compliance

Municipal water systems face complex operational threats ranging from extreme weather events to physical intrusion and sophisticated cyberattacks on Industrial Control Systems (ICS/SCADA). Section 2013 of America's Water Infrastructure Act (AWIA) of 2018 mandates that all Community Water Systems (CWS) serving more than 3,300 people develop or update two foundational security documents every 5 years:

1. Risk and Resilience Assessment (RRA): A comprehensive evaluation assessing the vulnerability of physical assets (raw water intakes, pump stations, treatment plants, distribution storage tanks, chemical feed systems) and cyber infrastructure (SCADA, automated telemetry, business networks). The RRA evaluates malevolent acts (vandalism, cyber intrusions, terrorism), natural disasters (wildfires, floods, earthquakes, severe blizzards), hazardous chemical releases, and supply chain vulnerabilities.
2. Emergency Response Plan (ERP): Actionable operational protocols, resource staging plans, and emergency standard operating procedures (SOPs) designed to maintain or rapidly restore critical water service during an emergency. The ERP integrates emergency power generation, cybersecurity incident mitigation, alternate water supply interconnections, and coordination protocols with Local Emergency Planning Committees (LEPC), first responders, and the Colorado Department of Public Health and Environment (CDPHE).

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Incident Command System (ICS / NIMS) Structure

During large-scale utility emergencies (e.g., major transmission main ruptures, treatment plant inundation, widespread electrical blackouts), utilities manage operations using the National Incident Management System (NIMS) Incident Command System (ICS). ICS provides a standardized, modular, scalable on-scene command architecture.

+-------------------------------------------------------------------------+
|                     INCIDENT COMMAND SYSTEM (ICS)                       |
+-------------------------------------------------------------------------+
|                        INCIDENT COMMANDER (IC)                          |
|          (Overall Incident Strategy, Tactical Goals, Life Safety)       |
|                                                                         |
|    +--------------------+---------------------+--------------------+    |
|    | PUBLIC INFO (PIO)  | SAFETY OFFICER      | LIAISON OFFICER    |    |
|    | (Media & Public)   | (Absolute Stop-Work)| (External Agencies)|    |
|    +--------------------+---------------------+--------------------+    |
|                                                                         |
|         +---------------+---------------+---------------+               |
|         |               |               |               |               |
|   +-----------+   +-----------+   +-----------+   +-----------+         |
|   |OPERATIONS |   | PLANNING  |   | LOGISTICS |   |  FINANCE/ |         |
|   | Tactical  |   | Resources |   | Material, |   |   ADMIN   |         |
|   | Field Ops |   | Docs, IAP |   | Comms, Eq |   | Cost/Time |         |
|   +-----------+   +-----------+   +-----------+   +-----------+         |
+-------------------------------------------------------------------------+

ICS Command & General Staff Roles

• Incident Commander (IC): Holds ultimate tactical and legal authority over on-scene incident operations, life safety, resource prioritization, and approving the Incident Action Plan (IAP).
• Command Staff:
  • Safety Officer: Assesses hazardous environments, monitors responder safety, and possesses absolute authority to immediately alter, suspend, or terminate any unsafe tactical operation.
  • Public Information Officer (PIO): Serves as the sole authorized voice for media releases, community public notifications, and press briefings.
  • Liaison Officer: Coordinates inter-agency communication between the utility, county emergency management, fire/police departments, CDPHE inspectors, and the EPA.
• General Staff Sections:
  • Operations Section: Executes tactical field directives (e.g., isolating broken mains, operating bypass pumps, deploying repair clamps, performing emergency superchlorination).
  • Planning Section: Collects incident intelligence, tracks resource status, documents operational maps, and formulates the written IAP for upcoming operational periods.
  • Logistics Section: Procures equipment, tools, emergency diesel generators, fuel, replacement ductile iron pipe, contracted vacuum trucks, food, and communication hardware.
  • Finance / Administration Section: Tracks personnel overtime hours, vendor invoices, equipment rental expenses, worker compensation claims, and compiles documentation for FEMA disaster reimbursement.
• Span of Control: Under NIMS guidelines, an effective supervisor-to-subordinate ratio must be maintained between 1:3 and 1:7, with 1:5 considered optimal.

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Drinking Water Contamination Emergencies & Tactical Actions

When microbial, chemical, or physical contamination enters the distribution system, operators must execute rapid tactical response measures:

+-------------------------------------------------------------------------+
|                 DISTRIBUTION CONTAMINATION TACTICAL ACTIONS             |
+-------------------------------------------------------------------------+
| 1. PRESSURE LOSS (< 20 psi) : Isolate affected pressure zones; close    |
|    boundary gate valves to prevent back-siphonage cross-contamination.  |
| 2. BOIL WATER ADVISORY (BWA): High-altitude Colorado standard requires  |
|    a vigorous ROLLING BOIL for a minimum of 3 MINUTES (altitudes >5,000 ft)|
|    (EPA baseline is 1 minute at sea level).                             |
| 3. DO NOT DRINK / DO NOT USE: Issued for volatile chemicals, petroleum, |
|    or toxic chemical spills where boiling could concentrate or vaporize |
|    toxic contaminants into indoor air.                                  |
| 4. EMERGENCY SUPERCHLORINATION (AWWA C651): Flush contaminated lines    |
|    with 25 to 50 mg/L chlorine for 24 hours (or 200 mg/L for 3 hours).  |
| 5. DECHLORINATION PRIOR TO DISCHARGE: Treat chlorinated flush water     |
|    with sodium bisulfite, sodium thiosulfate, or ascorbic acid to 0 mg/L|
|    residual before discharging to storm drains to prevent fish kills.   |
+-------------------------------------------------------------------------+

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Colorado CDPHE Regulation 11: Public Notification (PN) Rule

Under Colorado Regulation 11 (5 CCR 1002-11) and the federal Safe Drinking Water Act, public water systems must notify consumers whenever a regulatory violation or waterborne emergency occurs. Violations are classified into Three Distinct Regulatory Tiers based on the severity of public health risk:

+-------------------------------------------------------------------------+
|               CDPHE REGULATION 11 PUBLIC NOTIFICATION TIERS             |
+-------------------------------------------------------------------------+
| TIER 1: IMMEDIATE ACUTE HEALTH HAZARD                                   |
|         Notification Required: WITHIN 24 HOURS                          |
|         Channels: Broadcast TV/Radio, Door-to-Door, Automated Calls,    |
|                   Social Media, CDPHE 24-hr Notification.               |
|                                                                         |
| TIER 2: NON-ACUTE CHEMICAL / TREATMENT TECHNIQUE EXCEEDANCES            |
|         Notification Required: WITHIN 30 DAYS                           |
|         Channels: Direct Mail, Local Newspaper, Direct Delivery.        |
|                                                                         |
| TIER 3: OPERATIONAL, MONITORING & TESTING VIOLATIONS                    |
|         Notification Required: WITHIN 12 MONTHS                         |
|         Channels: Annual Consumer Confidence Report (CCR), Direct Mail. |
+-------------------------------------------------------------------------+

Tier-by-Tier Regulatory Breakdown

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Wastewater Spill Containment & 24-Hour Reporting Protocol

Domestic wastewater collection and treatment facilities are subject to strict spill reporting under Colorado discharge permits (CDPS) and Water Quality Control Division guidelines:

1. Immediate Containment & Mitigation: Deploy spill containment booms, construct earth/sandbag berms, block downstream storm sewer inlets, engage vacuum pumper trucks, and initiate bypass pumping around sewer collapses to prevent raw sewage from entering surface waters.
2. Environmental Water Quality Sampling: Collect immediate representative samples from three critical locations:
   • Point A: Upstream of the discharge point (unaffected baseline);
   • Point B: The direct point of discharge / outfall;
   • Point C: Downstream of the discharge point (to evaluate the mixing zone and downstream environmental impact).
   • Test samples for E. coli density, Biochemical Oxygen Demand ($BOD_5$), Total Suspended Solids ($TSS$), and Ammonia ($NH_3$).
3. Mandatory CDPHE 24-Hour Hotline Notification: Facility management or the Operator in Responsible Charge (ORC) must verbally notify the CDPHE 24-Hour Environmental Emergency Hotline (1-877-518-5608) within 24 hours of discovering the spill or sanitary sewer overflow (SSO).
4. Written 5-Day Noncompliance Report: A comprehensive written spill report must be submitted to the CDPHE Water Quality Control Division within 5 calendar days. The report must detail the root cause, estimated total gallons released, volume recovered, receiving water body affected, sampling lab results, cleanup measures, and long-term preventative corrective actions taken.