Airport Community, Water Quality Events, and the Aircraft Drinking Water Rule (2018)

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11 CHAPTER TWO METHODS LITERATURE REVIEW The researchers conducted a review of online resources to identify existing literature on current knowledge, practices, and relevant information pertaining to water utility and airport notification responses to water quality events. Water quality events were defined as boil water orders or health advisories addressing contamination of biological, chemical, or unknown contami- nants wherein the water supply should not be used for human consumption. Human consumption of water was assumed to include drinking water and water-based beverages as well as brushing teeth, handwashing, and dishwashing. The literature review included searches for SOPs, regulatory requirements, guidance documents, and potential case-study information related to the notices. Websites for EPA (including the SDWA and ADWR), FDA, the Centers for Disease Con- trol, and specific airports were searched for keywords and phrases including: “boil water order,” “water advisory,” “health advisory,” “emergency procedures,” “boil water alert,” “boil water notice,” and “interstate commerce.” Searches were also conducted to identify resources applicable to responses to water quality events by other airport tenants such as caterers and food service establishments. One reference identified through the literature search, Identifying the Gaps in Understanding the Benefits and Costs of Boil Water Advisories (Raucher et al. 2014), investigated whether a repository or database exists that compiles the number and types of boil water advisories or other drinking water alerts for U.S. public water systems. The researchers were unable to identify such a resource and reported that “[a]lthough issuing advisories for boiling water is considered a standard practice, there is no substantive U.S.-based literature on public health interventions, utility actions, and related risk communication.” The researchers also noted that “discussions of [boil water alerts] and related communication and public health intervention approaches remain scarce in the literature” (Raucher et al. 2014). A survey of state drinking water agencies completed as part of their research found that states routinely use boil water alerts as a precautionary technique and that there is considerable variation across state drinking water programs in terms of the triggers used for precautionary boil water advisories, with some states issuing such advisories on a fairly routine basis and others doing so rarely. The researchers also concluded that distribution system issues (main repairs and pressure loss) are becoming predominant drivers for issuing precautionary boil water advisories. These conclusions indicate that precautionary alerts may become more commonplace; as a result, the airport community may encounter these events more frequently. The literature review identified websites for some state drinking water programs that maintain lists of current drinking water quality alerts; website links for Ohio and Washington State programs are included in the bibliography. The review did not identify other published or unpublished literature or references on water utility and airport notification procedures for drinking water quality events. Resources identified through the literature review are included in the References section of this synthesis report. Applicable information has been incorporated into this report. INTERVIEWS Interview participants were invited to participate based on a number of criteria, including whether they have experience with drinking water quality events. Table 3 summarizes the number of interview participants and their experience with such events. All interviews occurred between July 2016 and April 2017.

12 TABLE 3 SYNTHESIS INTERVIEW PARTICIPANTS’ DRINKING WATER QUALITY EVENT EXPERIENCE Interview Participant Number of Interview Participants Airports with water quality event experience 6 Airports with no water quality event experience 5 Airlines with water quality event experience 3 EPA Regional Office and FDA personnel with water quality event experience affecting ADWR-related responses 5 Water utilities with water quality event experience 3 Total number of interview participants 22 Airport Interviews Conducted via conference call, interviews of airport personnel from 11 airports yielded valuable information. The airports invited to participate were selected based on characteristics considered to represent a diversity of water system operations and notification protocols. Airport selection was based on the following criteria and preferences: • Diversity of airport size, which potentially reflects the complexity of notification procedures used for the airport com- munity. Eight large hubs, one medium hub, one small hub, and one non-hub airport participated. The U.S. air carrier airports ranged from small regional facilities with fewer than 10 flights per day to large international airports with more than 1,000 flights per day. • Geographic distribution, which included airports in seven of the FAA Regions. The two regions that did not have airport participation were the Alaskan and Central Regions. • Experience with unsafe or potentially unsafe drinking water quality events. Six of the airports interviewed had experience in notifications of drinking water quality events and five had no such experience. The five airports without any experiences were included to report on their level of familiarity with notifications related to such events and whether SOPs were in place to address them should they occur. • Regulation as a public water system. One of the airports is a regulated public water system, so it is required by the SDWA to perform water quality sampling and other water system operations and maintenance-related activities. The other 10 airports obtain drinking water from a water utility. • Obtain water from more than one water utility. Two of the airports receive water from more than one water utility and therefore manage responses to water quality events and messaging from multiple water systems. Both had experi- ences with drinking water quality events. • Obtain water from a water utility with frequent distribution system events. One of the airports is served by a water utility known to have relatively frequent distribution main breaks that might result in precautionary drinking water quality notices. However, the water utility had not experienced a drinking water quality event that affected the airport. Airport personnel who participated in the interviews included environmental managers, emergency managers, emergency response coordinators, energy and utility department managers and personnel, planning and development personnel, and chief airport engineers. The interviews, 30 to 60 minutes each, focused on airport experience with notifications related to water quality events. The questionnaire provided in Appendix B was used during the interviews to guide the discussion. Interview questions addressed the complexity of the airport in terms of the number of flights per day, number of airlines, and number of watering points. Questions were also targeted to gather specific event details regarding the time and method of notification of the airport by the water utility and how those notices were disseminated to airport tenants. Airports with no prior experience with water quality events were verbally provided background information on the impli- cations of a boil water alert on airline operations as required by the ADWR. They were then asked whether and how existing emergency notification procedures might be adapted to address those events. All interviewees were asked to share existing emergency response SOPs and communication protocols, and to indicate whether they included water quality events. Some provided related documents or excerpts from SOPs, which have been incorporated into the suggested elements of an SOP. In accordance with our agreement with the airport interviewees, information and observations they shared have been aggregated to maintain anonymity of the sources of the information.

13 Airlines, EPA Region ADWR Coordinators, Water Utility, and FDA Interstate Travel Program Manager Interviews Interviews were also conducted with three airline representatives, three water utilities that have experienced water quality events and that serve airports, the FDA Interstate Travel Program (ITP) Manager, and four representatives of EPA Regional Offices responsible for ADWR oversight. These individuals were asked to participate based on their experience with the ADWR, water quality events, and established professional relationships. Interviews with airline representatives were very similar to those with airports. They each lasted 30 to 60 minutes and focused on interviewees’ experiences with receiving notification of a water quality event and implementing requirements of the ADWR. These airlines serve multiple airports and have dealt with multiple ways information is distributed. Representatives of three water utilities were interviewed to obtain information on how notifications of water quality events are provided to customers, including airports. Two of the water utilities served one airport through a series of consecutive water systems, and one water utility had experienced two significant water quality events that required immediate public notifications. For the FDA ITP Manager interview, the discussion focused on responses to water quality events as they apply to food and ice caterers as well as on FDA District Office roles in clearing aircraft watering points after a drinking water quality event has been resolved. Conversations with the four EPA representatives focused on how they hear about unsafe or potentially unsafe drinking water quality events at water utilities within their jurisdictions and how they respond to that information to assist the notification process.