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14 CHAPTER THREE PRACTICES AND FINDINGS FROM INTERVIEWS This chapter presents the major findings of the participant interviews, supplemented with background information from the synthesis references. The findings of this synthesis are presented in four sections: The first section presents three detailed case studies of water quality events that affected airports. Following the case stud- ies, information from other airports that differs from the case studies is presented. The second section presents information from five airports that have not experienced water quality events. The interviews with the airport representatives included a description of the potential implications of drinking water quality events on airlines and other airport tenants, and the types of events that could affect an airport. The interviews then focused on considerations of how notification of the events could be managed. The third section summarizes information on water quality event notification experiences gathered from interviews with three airlines, four EPA Regions with oversight responsibility for the ADWR, three water utilities, and the FDA ITP Manager. The fourth section describes suggested elements of an SOP for notifications related to a water quality event; this SOP is compiled from synthesis participant input and references. CASE STUDIES OF WATER QUALITY EVENT EXPERIENCES The airports interviewed with water quality event experience have a good understanding of the implications of such events on airlines and other tenants. In these cases, airports either have an informal notification process of passing along information to the airport community or they have a written SOP that details who should be contacted based on the specifics of each situation. Informal notification processes rely heavily on the airport personnelâs working relationships with the station managers and other airport tenants. These informal processes appear to be more common in smaller airports with fewer employees. Large-hub airports interviewed for this study and airports with a history of multiple water quality events either have already developed specific SOPs to ensure that all affected tenants and airlines are notified, or are in the process of developing those documents. This section presents three case studies of airport experiences with water quality events. Two of the case studies reflect input from the water utility and airport representatives. The third case study presents information from a water utility that has had water quality event experience and serves a small non-hub regional airport. Following the case studies, a summary of airport experiences with water quality events other than those included in the case studies is presented. The summaries emphasize the situations encountered, responses, and lessons learned. Case Study 1: (Large-Hub) Water Main Break at an Airport Public Water System The Airport Water System This large-hub airportâs public water system is regulated under the SDWA as a non-transient, non-community public water system. This means that it serves at least 25 of the same people over 6 months per year but does not serve a residential community. The airport purchases finished water from two water utilities and can add additional chlorine as needed. It is required by the stateâs drinking water program to meet minimum chlorine residual and certain monitoring and reporting requirements of the SDWA. The airport has separate pump stations that receive water from each water utility, and the water from each pump station is discharged into the same piping network where the two sources are eventually mixed. The airportâs public water system also has water storage tanks with a total capacity of more than twice their typical peak
15 summer day demand. The reliability of this airportâs public water system is attributed to the redundancy in supply from two feed points and pressure maintenance. Operators of the airport public water system monitor the free chlorine residual of the incoming water and add chlorine as needed to maintain at least the minimum required residual. They also perform the required coliform bacteria monitoring (120 samples per month), which is based on the average daily population served by the airport. Although total coliform bacteria are occasionally detected in routine water samples, repeat samples have been total coliform-negative and the routine results do not trigger notification of the public, although airport management is informed. Additional monitoring includes sampling for lead and copper, inorganic and organic chemicals, and secondary contaminants (secondary contaminants, such as iron and manganese, affect the taste or appearance of the water). Water quality monitoring is the responsibility of this airportâs Energy, Transportation, and Asset Management Group. Case Study Details For the event profiled in this case study, a road contractor accidently damaged a water main within the airport public water system, interrupting water service to the airport water users. The pressure drop caused by the break immediately alerted airport operations personnel to the problem. The operators in the Airport Energy and Utility section contacted the Assistant Vice President of Energy and Utilities (the primary contact for water quality events) within 10 minutes of their detecting the main break. Operators continued to monitor the pressure drop and pump response, and determined within an hour that it was necessary to notify air carriers, concession partners, and the airport fire department through the Airport Operation Center (AOC). Subsequent monitoring was initiated by the Energy, Transportation, and Asset Management Group, and coliform bacteria were not detected in any water samples. Figure 2 illustrates the water system configuration that serves this airport. Public Water Systems A and B are the two water utilities that provide finished water to the airport. The red exclamation point above the water icon illustrates the relative loca- tion of the water main break that occurred within the airport public water system. FIGURE 2 Case Study 1: Airport Public Water System Configuration with Two Water Sources. Source: The Cadmus Group LLC. Airport Water Quality Event Notification Procedures The airport representatives indicated that there have not been any water quality events since the one reported in this case study, and they continue to use the same procedures to address any events that may arise. In those procedures, the AOC is the point of contact with the public for general information; it handles communications for any utility impacts. It is co-located with the Airport Energy and Utility section and the Emergency Operations Center (EOC). During water quality events, the AOC is responsible for contacting air carriers, concession partners, and other relevant water users. The decision of whom to contact is made by the AOC based on the circumstances of each event.
16 Communication mechanisms also differ according to the situation, but generally the AOC communicates through an email distribution list. The EOC is used for incident notification if the event warrants that level of notification; water quality events would meet the criteria to use the EOC. The EOC uses Everbridge® Communication Software, an auto-dial telephone system that initiates contact by telephone. Airlines and other tenants contact the AOC to subscribe to the contact list. Text, email, and call options are all available through the Everbridge® auto-dial system. The EOC also sends a web-enabled status update to the airportâs infrastructure website and the Web Status Board. All airport personnel, airport tenants, and station managers at the airport have access to the Web Status Board, which provides text alerts using scrolling text and color coding. A typical text alert starts with a notice of utility disruption and the areas of impact. As more information is received, it is posted to the online text alert. As a response to the event occurs, the Web Status Board is updated. Ultimately, the Web Status Board communicates the status of the repair response, restoration of service, collection of samples, and sample results. Terminal managers also reach out to tenants to ensure that they are informed of any events. All of these communication methods were used simultaneously during the water quality event profiled in this case study. The airport also notified tenants using these methods when the event was resolved and normal use could be resumed. Figure 3 illustrates the channels of communication from within the airport and modes of communication used during the water quality event at the airport. FIGURE 3 Case Study 1: Channels of Communication for an Event That Occurred at the Airport Source: The Cadmus Group LLC. Case Study 2: (Large-Hub Airport) Water Main Break at a Wholesale Water Utility Affects a Large Service Area The Airport Water System The airport in this case study is a customer of a water utility. That water utility is a consecutive systemâmeaning that it receives finished water from a wholesale water utility. The wholesale water utility also provides water to several other con- secutive water systems. There are water storage tanks at the airport that are owned by the airport, provide excess capacity, and are not used for fire- suppression purposes. The airport personnel also perform sampling for coliform bacteria with analysis of coliform-positive samples for the presence of E. coli. Although the airport does not add chlorine, it monitors the chlorine residual and has found low chlorine levels when the water lines are not adequately flushed before samples are collected. The airport also monitors the water for heterotrophic plate count bacteria.
17 Case Study Details In this water quality event, the wholesale water utility experienced a major water transmission break in its distribution system. This incident required the wholesale water utility to use an emergency source of water while the water main was taken out of service for repair. Because of the large water service area impacted by the event, the governorâs office was immediately con- tacted. The significance of the event dictated that it be managed at the state level by a unified command structure that included the affected consecutive water systems that are customers of the wholesale water utility, the State Department of Public Health, Department of Environmental Protection, Emergency Management Agency (EMA), and Office of the Governor. The event was front-page news in all the regional papers, with ongoing coverage on their websites. It was carried live by local television sta- tions with continuing coverage, including a frequently updated crawl across the bottom of the screen during other programming. Use of the emergency supply triggered the issuance of a boil water notice as a precautionary step. Although some pressure zones in the distribution system were not affected, the governor and state authorities determined that a system-wide boil water notice was necessary to avoid public confusion. This initial outreach included the airport. Water quality samples collected from the area of the distribution system receiving the emergency water supply contained no coliform bacteria. However, because coliform test results require a few days to process after samples are collected, the airlines and other airport tenants implemented their response plans during the period between when the notice was first received and when the coliform test results indicated that the water quality event was resolved. Figure 4 illustrates the how the different water utilities provide water to the airport. The red exclamation point above the water icon illustrates the location of the water main break relative to the other stakeholders in this extensive configuration of interconnected water systems. FIGURE 4 Case Study 2: Wholesale and Consecutive Water System Serving the Airport. Source: The Cadmus Group LLC. Airport Water Quality Event Notification Procedures The wholesale water utility used a reverse 911 system to contact priority customers (local police departments, fire depart- ments, municipal governments, etc.) and relied on city governments to use their reverse 911 systems to contact local officials. The wholesale water utility publishes its emergency numbers. It routes all sensitive users and directs public calls to a special incident response center. Response center personnel respond to caller inquiries and answer any questions from sensitive users (questions related to food service, food production establishment, medical facilities, etc.). The questions are often directed to the incident command team for resolution. During the water quality event, the wholesale water utility also received many calls from members of the public at its EOC, although the main function of the EOC is to coordinate emergency response efforts among the multiple response agencies, stakeholders, and municipal governments.
18 The wholesale water utility coordinated with the stateâs EMA to conduct public notification. The EMA helped manage ini- tial public notification and coordinated a widespread outreach effort including highway signs and recorded announcements in subways. The wholesale water utility provided updates on matters such as system conditions, repair progress, and water qual- ity testing. The updates were provided to its response partners (including communities and other agencies) and to the public via media updates and website updates. The EMA later provided major updates to the media from the responding agencies. The consecutive water utility that provides water to the airport received a call directly from the wholesale water utility. The consecutive water utility first contacted the fire departments in its service area, including the airport fire department. The consecutive water utility also notified the mayorâs office, the cityâs public health commission, and airport operations person- nel. Because the consecutive water utility that serves the airport is a separate entity from the city, it lacked both its own reverse 911 system as well as access to the cityâs reverse 911 system. Figure 5 illustrates the channels of communication from the wholesale water utility (indicated as the wholesale public water system in the figure) where the water quality event occurred and modes of communication used during the event. FIGURE 5 Case Study 2: Communications Channels Between the Large Wholesale and Consecutive Water Systems to the Public and Airport. Source: The Cadmus Group LLC. Within the airport, Airport Operations bears responsibility for notifying the appropriate parties when there is a water quality event; this is the same group that handles fire, police, and lost baggage. During emergency situations, Airport Opera- tions personnel contact terminal managers, facilities control, and air carriers through a National Incident Management Sys- tem Standard situational awareness message (SAM). A SAM is issued unilaterally so that terminal managers, air carrier personnel, and facilities control personnel are alerted simultaneously. All airport personnel are on the emergency message list, and they receive emergency notifications by phone, email, and text messages, depending on the recipientâs preference. If operational personnel are physically called, the call is first directed to one person on airside operations (e.g., watering points, catering services) and one on landside operations (e.g., terminal building, public transportation). When a water quality event occurs, Airport Operations personnel contact the Airport Facilities Department and then the Airport Water Department. If airport tenants are affected, a tenant advisory is issued through the Airport Business Office. Airline station managers receive a phone call directly from Airport Operations. The exact timeline of notifications is not pre- cisely defined, but the calls happen quickly. All SAM notifications and direct phone calls are logged by Airport Operations to track notification accuracy. Since the time of this event, the airport has developed an SOP specifically for boil water orders that they issue or that they receive from the water utility serving the airport. The SOP includes a communications plan, a response action flowchart, and methods for the communications. In addition to addressing airport personnel, airlines, and other tenants, the SOP includes response actions to protect the public, such as bagging water fountains, posting notices in restrooms, and notifying food estab- lishments. The SOP also specifies types of sampling and a sample analysis plan to confirm that the event has been addressed
19 as well as specific additional actions, such as flushing lines to purge contaminated water. The SOPs were not shared for this synthesis because they had not been approved for release at the time this report was prepared. They have been incorporated into the suggested elements of an SOP included in this chapter. Figure 6 illustrates the channels of communication from the airport to various individuals at the airport as well as modes of communication used during the event. FIGURE 6 Case Study 2: Communication Channels Within the Airport. Source: The Cadmus Group LLC. Case Study 3: Water Utility Serving a Regional Airport (Non-Hub) The Airport Water System This regional, city-owned airport is a customer of the cityâs water utility. The airport does not perform any water quality monitoring or add any treatment. The water utility uses a sampling site located approximately a quarter of a mile from the airport for some of its water quality monitoring. Case Study Details Two events in the city have triggered boil water notices for the entire service area, including the airport. One event was caused by a short-term water treatment problem that resulted from heavy rainfall; the other event was due to a natural disaster that caused water main breaks and depressurized the water system. Figure 7 illustrates the water system configuration for the regional airport. The water icon with the red exclamation point represents the system depressurization caused by the water main breaks.
20 FIGURE 7 Case Study 3: Water System Configuration from the City to the Regional Airport. Source: The Cadmus Group LLC. Water Quality Event Notification Procedures The water utility issued water quality notices for both of these events in accordance with the EPAâs Public Notification Rule requirements. It also immediately contacted city officials and the state program that oversees SDWA compliance. The boil water notices were communicated through media (e.g., TV, radio, newspaper) and the cityâs reverse 911 system. The content of the water quality notice was developed using information required by the state and templates provided by the state. The water utilityâs SOP specifically includes the airport personnel on the emergency contact list. The emergency contact list is not restricted; the water utilityâs policy is to add individuals and organizations to the list upon request. The exact contact list used for each emergency is determined by water utility managers based on the details of the incident. Emergency contacts are also included in the reverse 911 call procedures. The water utilityâs water quality supervisor or field services supervisor typically calls the airport manager directly if a water quality event that affects the airport occurs. After the initial water quality notice is sent, the water utility provides updates to consumers using the same communication procedure (e.g., media announcements and reverse 911 calls). Figure 8 illustrates the channels and modes of communication used by the water utility during the two water quality events. FIGURE 8 Case Study 3: Modes of Communication from the Water System to Consumers and the Regional Airport. Source: The Cadmus Group LLC.
21 Water Utility Comments on Emergency Communications Systems and Water Quality Events Although the water utility has not experienced significant water quality events since those described in this case study, it has continued efforts to improve its emergency communications protocols. The water utility makes direct personal calls to contacts on its critical contacts list and implements a reverse 911 system to other customers using a CodeRED® community notification system. To be added to either list, individuals must contact the utility and provide their contact information. They must also contact the water utility to update the contact information. The critical contacts list includes hospitals, food processing facilities, the airport manager, and other similar entities for which prompt notice is essential. When making direct calls to critical contacts, the water utility will continue attempts to reach the contact until it has confirmation that the information was received. This can be resource-intensive for the water utility if contact details are not kept current. The water utility has found that some contact information was not valid within a year after it was provided. The water utility prefers to work with local personnel rather than communicate with corporate environmental offices. It tries to make sure it has local contacts but will accommodate others, as needed, as long as they help keep the contact informa- tion up to date and compatible with the water utilityâs communications system. The water utility emphasized that it can be difficult to identify specific areas of the water distribution system that are affected by a water quality event. Because protection of public health is a primary responsibility of the water utility, the area it identifies as impacted will be large enough to provide confidence there are no potential health risks. The water utility rec- ognizes lost water service can mean significant revenue loss and economic risk for their customers, so it makes such decisions carefully. Other Airport Experiences with Water Quality Event Notifications Some airport participants in this synthesis project shared additional water quality event notification experiences that illustrate the diversity of water quality events that can affect an airport. The following summaries convey key points of the situations encountered, airport responses, and lessons learned. E. coli Contamination of the Public Water System Serving a Large-Hub Airport A city with a major international airport serving more than 600 flights per day issued a boil water alert due to the presence of E. coli in the distribution system. The airport personnel received notification of the event via a public alert, mass-notification system used for the general public; they were not directly contacted by the county health department or the water utility. The airportâs emergency manager worked with the airportâs properties and concessions personnel to notify tenants and post signs, but was unaware of the implications of the ADWR on airlines at the time. At this airport, any water quality information is passed to senior management to decide on a course of action. It is unclear whether there were delays in releasing the notice as a result of the steps required to determine the course of action and the messaging. The researchers attempted to be added to the list used by the public alert system to learn about the process and determine what alerts would be provided. To be included on the list, the user must access the system through the cityâs website and pro- vide a residential address. The automated system sends alerts to the address for a variety of emergencies or situations (e.g., school closures, road closures). The alerts can target certain areas or the entire system. Boil water alerts are listed as one of the options. Each user selects the types of notices of interest and provides contact information in a user profile. It is up to each user to maintain those contact details. For purposes of using this system to alert airport or airline personnel, reliance on a residential address may be problematic if the appropriate personnel do not live near the airport. The information provided to users also explained the potential limitations of the system if it becomes overloaded by a large volume of activity or if there is a power failure. The airportâs emergency manager indicated that there is not a current direct line of communication or established SOP within the airport for a water quality event. The emergency manager conveyed that airport personnel are very familiar with the established overall emergency response process and that the current emergency notification system provides many options that could address these events. The emergency manager also noted that standard procedures could be developed to address how to respond to a water quality eventâregardless of how or by whom the notice is initially received.
22 Emergency communications within the airport are issued through an electronic system (Passer®). The system dissemi- nates information electronically by email, calls, or text messages, but users must configure their own alerts based on their specific interests. The emergency manager also suggested that SOPs similar to those used for communicable diseases may be helpful, including call-out sheets that identify specific steps to be taken. For those communicable disease events, the emer- gency manager relies on establishing and maintaining strong relationships with local health department personnel to support reliable communications when an event occurs. The emergency manager believed a similar process could be implemented with the water utility that serves the airport. Two Events Prompt a Large-Hub Airport to Develop a More Robust Water Program A significant water main break and a separate event involving backflow of coolant water through a cross-connection prompted an airport to develop a full drinking water program with robust communication protocols. The protocols use an airport response center. The response center was not online at the time of the events, but it is currently operational and disseminates information to airlines, station managers, terminal operators, and maintenance personnel. The system functions airport-wide but can also be targeted to specific users. The airport water program includes total coliform bacteria and total chlorine residual testing and a cross-connection con- trol program. If sample results indicate a problem, program personnel notify affected tenants and flush water mains to restore the chlorine residual, if needed. The airport also adopted stricter lock-out tag-out and reactivation procedures that reduced contractor discretion regarding these activities. It has also completed a hazard analysis, which is a process for identifying risk and implementing control measures to maintain and protect the quality of the water distributed throughout the airport. Although the airport is a customer of a water utility, it has significant water pipes, plumbing, and fixtures within the airport water complex. There are now structures in place at this airport for communications regarding a variety of events (e.g., active shooters, suspi- cious packages), and the system can be adapted to disseminate information related to water quality to the airport community. The airport relies on receiving notifications from the water utility via the cityâs Emergency Response Center. Airport per- sonnel believe that the delay in receiving this notice would be the weakest link in the communications process. Boil Water Order for One of Two Water Utilities Serving a Large-Hub Airport At this airport, two water utilities serve distinct and separate terminals. This airport is affiliated with the county, so it is on a priority list to be contacted immediately when water quality events occur. The airport operations manager is well aware of which terminals are fed by which water utility and directs airlines to the alternative source if one side is affected. In such an event, the operations manager also disconnects water to the potable units so that no water is available at the fill-lines. The operations manager has issued precautionary alerts when planned maintenance or repairs will affect the airport. Details in the alerts include what is planned, the estimated duration of the event, and the activities that will be taken to return the system to service, such as disinfection and flushing and total coliform sampling. Update messages are also issued. To contact air carriers, concessions, and other tenants, the airport uses a communication system similar to that of other air- ports (Everbridge® Communication Software). The airport operations manager noted the airlines often follow up by request- ing specific details of the event to help identify flights that departed during the water quality event. This airport participant emphasized that when a water quality event occurs, airport personnel should not hesitate to use the EOC and notification process. This airportâs notification process is available for use at all times. The airport reported that the weakest link in its water quality event notification and management is the time required for a decision to be made regarding whether to issue a notification to airport tenants. Summary of Findings from Airports and Water Utilities with Water Quality Event Experiences The following list summarizes what was learned from airports and water utilities that have had drinking water quality events: ⢠The time required for notification to be received by airports can be significant. It is beneficial for airports to have direct communication with the water utilities that serve them so that notice is received promptly.
23 ⢠Having airport personnel listed on the local water utilityâs critical contact list, if available, is extremely helpful. ⢠Water quality events should be handled as emergency events and responded to appropriately. ⢠Existing emergency communications systems with targeted contact lists are an effective way to disseminate water qual- ity event information to airlines and other interested tenants. ⢠It is critical that emergency contact lists be kept current, and that process relies on the recipient of the notices to provide updates. ⢠SOPs that address water quality eventsâfrom receipt of notification from the water utility, dissemination of the infor- mation, and a return to normal serviceâare important for airport operations. ⢠Although they occur infrequently, water quality events occur on airport property as well as in the water utilities that serve the airport. AIRPORTS WITH NO WATER QUALITY EVENT EXPERIENCES Interviewees included five airport representatives who had no experience assisting in notifications related to water quality events but who had extensive experience with notification procedures during other emergency events. These interviews com- monly evolved to discuss how the airports could use their existing notification systems (e.g., mass text, mass email, automated phone calls) to assist in conveying information about water quality events to affected parties. Airport personnel were also generally interested in updating their emergency SOPs to include water quality event response procedures. Through the synthesis interviews it became clear that airports without water quality event experience were not sure whether notification efforts fell under the responsibility of the environmental manager, the emergency manager, or other airport per- sonnel. The environmental manager is typically responsible for water sampling (if conducted) as well as other environmental activities related to storm water, chlorinated water discharge, de-icing, etc. The emergency manager has the responsibility of managing any airport emergency, which includes communicating information to appropriate parties during an emergency. Emergency managers for these airports tended to already have contact lists of airport personnel, airlines, food service pro- viders, ground service providers, and other tenants. They also described efforts to ensure up-to-date contact lists. Some air- ports viewed water quality events as emergency events rather than environmental events. Others included consultation with environmental and airport operations personnel to determine whether event-specific details should trigger the emergency notification system or another communication method. Approximately half of the airport representatives interviewed for this synthesis were not aware of the ADWR and the implications of water quality events on airline operations. These airports have a communication plan as part of their airport emergency plan that cover many different types of emergencies, but did not have any SOPs or informal practices related to water quality event notifications. Once they were aware of the consequences of an aircraft boarding unsafe water, they often expressed interest in developing informal or formal procedures to be prepared for an event. Some indicated they planned to immediately contact the water utility serving the airport to be included in the critical contact list. Others responded with plans for incorporating water quality events into existing emergency response procedures. Those plans often included increased outreach to the traveling public in addition to contacting airport tenants. Airports with similar emergency notification systems had varying policies on who could be added to contact lists. Some were open to including airline corporate contacts along with station managers. A very large airport conveyed that it would prefer to restrict the list to station managers so that those individuals are responsible for disseminating information appropri- ate to their respective companiesâbut that they would include corporate contacts if the request was provided in writing to the system administrator for approval. To keep its contact list current, one airport reported using regularly emailed bulletins, from the general manager, that address a variety of specific concerns. Additionally, it has monthly station manager meetings that it also uses to keep its lists up to date. A small non-hub airport director indicated that he had not had a water-related event that he could remember in over 25 years, and the airport lacks a formal SOP. He expected to be directly notified by the cityâs water utility if a water quality event occurred. The airport has a small staff and few airlines and other tenants. The following list summarizes what was learned from airports with no experiences with drinking water quality events: ⢠Educational materials to help raise airport management awareness of the causes and implications of drinking water quality events at airports would be beneficial.
24 ⢠While the environmental manager may be responsible for many other airport environmental activities, including water sam- pling, the environmental manager may have access to better tools to quickly disseminate information to the appropriate parties. ⢠It appears feasible to use existing emergency notification systems and update them regularly in order to quickly notify appropriate parties of water quality events. ⢠SOPs for the various types of situations that trigger water quality events would be helpful, as would tabletop exercises that address them. AIRLINES, EPA REGION ADWR COORDINATORS, AND FDA INTERSTATE TRAVEL PROGRAM MANAGER EXPERIENCES U.S. Airlines The three airline representatives who contributed to this synthesis described effective practices, challenges, and opportunities related to water quality events at airports. Airline representatives described their activities that demonstrate they take the provision of safe drinking water very seri- ously. They have extensive operations, maintenance, and recordkeeping practices addressing the quality of the water they board, the procedures used to board the water, and their aircraft water systems. They reported that airports with effective prac- tices collaborate early and often with station managers and other airline contacts to ensure that they are notified promptly and kept informed of water quality events. They also reported that their main challenge to effective notifications is to be promptly informed of a water quality event, whether by the water utility or airport management. They noted that the communication methods for water utilities that are specified by EPAâs Public Notification Rule rely on indirect contact via mass media (e.g., TV or radio) or airport employees to convey the information. Airline representatives must frequently investigate the water quality events that triggered the notices. Their investigations are necessary in order to verify if an event is affecting the airport and if the nature of the water quality issue involves aircraft public water systems. This information is necessary for the airline to make operational decisions such as whether to board water. Because it is not operationally feasible for captain or pilot logs or water cabinet logs to track when water is boarded onto each aircraft at each airport, airline representatives assume that all aircraft that departed the airport boarded water and must therefore undergo the corrective actions in accordance with the ADWR. Water quality event investigation activities are often coordinated through each airlineâs corporate environmental departments. The airlines noted that they work hard to disseminate information they receive to other airlines. Mutual cooperation in non- competitive situations such as environmental compliance is typical, as are responses to emergencies. Airlines share emailed notifications and use Google alerts and other technologies to pass notifications to each other. Airlines also expressed concern that airports that have never experienced a water quality event are generally unaware of all the implications an event can have on their operations. This lack of knowledge can lead to delayed dissemination of informa- tion to the air carriersâor even a complete lack of information dissemination by airports. Airlines also expressed concern regarding routine operations and maintenance of aircraft watering points that are not under their jurisdiction. In addition, they described challenges in identifying the correct contact people at each water utility and the procedures needed to be included on each emergency contact list. Many airlines serve a large number of airports and are aware of the diversity of the public communications protocols used by the water utilities that serve each airport. The airline representatives suggested that collaborating through each airportâs standard emergency notification and communication sys- tems presents a feasible and effective option. EPA Region ADWR Coordinators Personnel from four EPA Regional Offices provided information for the synthesis. EPA Regional Offices perform regulatory oversight and enforcement of the ADWR. There are 10 regions, and each one is responsible for overseeing the U.S. airlines that have corporate headquarters in its region. EPA Regional Officesâ ADWR Coordinators are not in a direct line of com- munication from the water utility to the airport or airlines. One resulting challenge is that there may be three or more steps in a communication process for them to be informed of a water quality event. For example, the water system would contact the state drinking water program, which might then contact the EPA Regional Office personnel who oversee state programs
25 (although this is not required), who would then need to contact the EPA Regional ADWR Coordinator. Upon receiving noti- fication of an event, the ADWR Regional Coordinator calls the public water system to confirm that the event occurred and to determine the nature and time of the event as well as whether it affects the airport. The ADWR Regional Coordinator then contacts the appropriate airlines to ensure that they are aware of the event. The coordinator also contacts other EPA regions to help disseminate the information to other airlines. United States Food and Drug Administration Interstate Travel Program Manager The FDA ITP Manager provided comments on the role of the FDA District Offices in the regulation and oversight of interstate commerce carriers. The ITP is responsible for inspection of aircraft and other passenger-carrying conveyances that operate in interstate traffic (e.g., charter coaches, railroad passenger cars, and vessels) during their construction and operation. The ITP is also responsible for the support facilities for those conveyances. Support facilities include caterers and commissaries (which supply food and beverages), watering points, and waste-handling facilities. The ITP Manager conveyed that it is not uncommon for airline ice and food caterers to obtain their water from the same water utility that serves the airport. During a water quality event, FDA District Office personnel contact the caterers for which they are responsible to ensure that they are aware of the event. They may also go on-site and ensure that watering points are not used. Challenges arise from the diversity and situation-specific nature of the communication methods that FDA District Offices use to obtain information on water quality events. FDA also maintains an online list of aircraft watering points and servicing areas that are in accordance with FDA require- ments. The list, which can be sorted by airport, is intended for use by airlines and is also available to the public. Although it is updated quarterly, it does not provide real-time status updates of watering points that are affected by water quality events at airports. Opportunities exist for the FDA ITP program to share information with airlines and for airports to improve notifica- tion practices. Summary of Findings from Airlines, EPA Regional Office ADWR Coordinators, and the FDA Interstate Travel Program Manager The following list summarizes what was learned from airlines, EPA Region ADWR Coordinators, and the FDA ITP Manager. ⢠Airlines take drinking water quality very seriously and frequently collaborate with other airlines to ensure drinking water notices are disseminated rapidly. ⢠Airlines must frequently investigate notices about a drinking water quality event to find out if the airport or a specific terminal is affected by the notice and if the nature of the event is one that will influence their operational decisions. Further investigation is a major problem when time is critical and airline staff must respond quickly to minimize impacts. ⢠Airlines recognize that airports without experience with drinking water events may not understand the implications an event can have on airline operations. This can lead to delayed notification or a lack of notification. ⢠Airlines recognize that there is a diversity of public notification protocols at water utilities, and it is challenging for airlines to identify the correct contacts and contact lists for each utility. ⢠EPA Regional Office ADWR Coordinators are not in a direct line of communication from the water utility to the airport or airlines. EPA staff members do not always receive notice of a drinking water event; when they do it is rarely timely, and they may need to further identify the impacted area before they can assist airline and airport notifications. ⢠FDA ITP staff members may delegate responsibility to local health departments for some aspects of response activities during a drinking water quality event, resulting in diverse communication procedures. ⢠FDA ITP staff members contact caterers and food service providers to ensure that water is not used during a water qual- ity event. This notification process would also benefit from improved communications with other stakeholders. SUGGESTED ELEMENTS OF AN SOP FOR WATER QUALITY EVENTS AT AIRPORTS Although copies of SOPs for water quality events at airports were not available, synthesis participants identified several ele- ments that they recommend be included. The SOP elements fit into three main functions: notify impacted parties, manage the contaminated water and its use, and restore normal operations. Figure 9 illustrates how these three functions overlap during a water quality event.
26 FIGURE 9 Three Functions Inherent to a Water Quality Event SOP. Source: The Cadmus Group LLC. Continuing notification throughout the event was recommended to keep affected parties informed. Another recommenda- tion was ongoing management of the use of the water until the issue is resolved and normal operations are resumed. Notification activities may include: ⢠Confirmation of event details. This requires communication with the water utility. Necessary event details include the date and time the event occurred, the situation or violation that triggered the notice from the water utility, whether the event affects all or part of the airport, and measures necessary to protect public health (e.g., boil the water or do not use the water). Content from two informative water quality alert email notices provided by interviewees are included in Table 4. TABLE 4 EXAMPLES OF WATER QUALITY ALERT EMAIL NOTICES Example Boil Water Alert Email Content Subject: RE: Boil water notice at ÇÇÇ airport We received this at 1:10 a.m. from the EPA. "I wanted to let you know that the City of ÇÇÇ has issued a boil water advisory to the entire city that includes the airport (ÇÇÇ). The boil water advisory is a result of the lack of chlorine in the drinking water supply.â Example Precautionary Boil Water Notice E-mail Content âThis is a notice regarding water main shutdown for maintenance in the ÇÇÇ Airport, Terminal 3 - Concourse F. Work will begin on Monday, September 12, 2016, and continue through Tuesday, September 13, 2016. The work is estimated to last approximately four (4) hours on Monday, beginning at 11:00 p.m., and water ser- vice will be restored when work is completed. The work on Tuesday, beginning at 11:00 p.m., will require water main shutdown again for approximately 4 hours; water service will be restored when work is completed. During this period, four (4) fire hydrants will be affected, and water service will be interrupted for seven (7) customer service connections in the area near Terminal 3. The County Aviation Department has been notified of the planned maintenance event and will receive a Precautionary Boil Water Notice before water service is restored late Tuesday/early Wednesday; the notice will remain in effect until bacteriological testing confirms that the water is safe to drink.â ⢠Notification of tenants. Based on the details of the event, the content and manner of tenant notice should be quickly prepared and disseminated. Essential elements of public notification that could be distributed include: ⢠A clear statement that the water is non-potable and that there are use restrictionsâfor example, whether it is a boil water notice, a do not drink notice, or a do not use notice. ⢠A description of the violation or situation triggering the notice, including the contaminant(s) of concern. ⢠When the violation or situation occurred. ⢠Any potential adverse health effects from the violation or situation, as appropriate.
27 ⢠Which populations are at risk, including sensitive subpopulations particularly vulnerable if exposed to the contami- nant in the drinking water. ⢠What the water utility is doing to correct the violation or situation. ⢠When the water utility expects to return the system to normal operation. ⢠Placement of airport signage. To inform the traveling public and airport and tenant employees, notices of the water quality event should be physically posted in restrooms, work areas, and near drinking fountains and other locations where water is accessible. ⢠Announcement over the intercom. Provide announcements as needed to ensure that the public is aware of the event as well as any applicable restrictions on water use. ⢠Daily briefings with tenants. Maintain frequent communications on the water quality eventâs status, including its resolution. Management of the contaminated water supply and the use of that water may consider: ⢠Utilize physical controls to prevent water use, such as shutting off drinking fountains or closing valves to isolate spe- cific areas of the distribution system. Consideration should be given to whether water should be provided to maintain essential services such as toilet flushing. ⢠Provide hand sanitizer to help maintain sanitary conditions while the water cannot be used. ⢠Provide supplemental potable water for drinking and aircraft. ⢠Prioritize water use for critical services such as fire protection and non-potable uses such as toilet flushing. Activities related to restoration of normal water use could include: ⢠Localized repair and maintenance, if applicable to correct the problem. ⢠Instruction from the water utility to initiate airport water system flushing to purge the contaminant from the storage tanks, distribution pipes, and watering points. Entities responsible for flushing each of the water system infrastructure components and water cabinets, carts, and hoses would be specified. ⢠Sampling and sample analysis plan to confirm the water is safe to consume, including who receives notification of the results and how these individuals are notified. ⢠Coordination with FDA ITP personnel and other relevant agencies to confirm that normal operations may resume. ⢠Event resolution notification of all affected tenants. ⢠Removal of physical controls to allow resumed use of the water. ⢠Documentation of the event, including a response summary, challenges to the airport and tenants, and lessons learned. ⢠Implementation of SOP revisions and training as well as practice drills to improve the process.
