dEPA
   United States
   Environmental Protection
   Agency
   Sampling Guidance for Unknown
   Contaminants in Drinking Water
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
FINAL-110308

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          Sampling Guidance for Unknown Contaminants in Drinking Water
       U.S. Environmental Protection Agency
              Office of Water (4601M)
          1200 Pennsylvania Avenue, NW
              Washington, DC 20460
                   EPA-817-R-08-003
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
                                        Disclaimer

The U.S. Environmental Protection Agency (EPA) prepared this guide to help you enhance the security of
your water system.  This document does not impose legally binding requirements on EPA, states, tribes,
or the regulated community; and it may or may not be applicable to a particular situation depending on
the circumstances. EPA and state decision makers retain the discretion to adopt approaches on a case-by-
case basis that may differ from this guidance where appropriate. Any decisions regarding a particular
community water system will be made based on the applicable statutes and regulations.  Therefore,
interested parties are free to raise questions and objections about the appropriateness of the application of
this guide to a particular situation, and EPA will consider whether the recommendations or interpretations
in this guide are appropriate in that situation based on the law and regulations. EPA may change this
guidance in the future. To determine whether EPA has revised this guide or to obtain additional copies,
contact the Safe Drinking Water Hotline at (800) 426-4791.

Any mention of trade names, companies, products, or services in this guidance does not constitute an
endorsement by the EPA of any non-federal entity, its products, or its services.
                                  Acknowledgments

The Water Security Division within the U.S. Environmental Protection Agency's (EPA) Office of Water
would like to recognize the following organizations and individuals for their support in the development
of this document:

Office of Water

Steve Allgeier

Elizabeth Hedrick

Latisha Mapp

Jessica Pulz

Grace Robiou
Cindy Simbanin
Patricia Tidwell-Shelton

David Travers
Office of Research and Development - National Homeland Security Research Center

Alan Lindquist

Matthew Magnuson



United States Geological Survey

Lori Apodaca
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
                                 Table of Contents


SECTION 1.0 INTRODUCTION	1
1.1      Document Organization	2
SECTION 2.0 OVERVIEW OF RECOMMENDED SAMPLING APPROACH	3

SECTION 3.0 UTILITY ROLES AND RESPONSIBILITIES	5
3.1      Defining Sampling Requirements: Capabilities and Capacity	5
    3.1.1    Sampling for Baseline Monitoring	5
3.2      Sampling in Response to a Contamination Warning System Trigger	5
3.3      Sampling Team Preparation	6
3.4      Defining Analytical Support Requirements: Capabilities and Capacity	6
    3.4.1    Establishing Analytical Support Networks	6
3.5      On-site Sample Screening Capabilities (Field Kits and Procedures)	7
    3.5.1    Baseline Monitoring/Routine Monitoring: On-site Screening	7
    3.5.2    Triggered Monitoring: On-site Screening	7
SECTION 4.0 SAFETY AND PERSONAL PROTECTIVE EQUIPMENT	9
4.1      Personal Protective Equipment	9
4.2      Health and Safety Plans	12
4.3      Confined Space Entry	12
4.4      Personal Safety Considerations	13
4.5      General Safety Guidance	13
SECTION 5.0 PREPARATION FOR SAMPLE COLLECTION ACTIVITIES	15
5.1      Sample Collection Kits	15
5.2      Field Test Kits (On-site/Field Pre-screening)	16
    5.2.1    Core Field Test Kits	17
    5.2.2    Expanded Field Test Kits	18
    5.2.3    Examples of Field Testing Equipment.	19
5.3      Quality Assurance/Quality Control	21
5.4      Forensic Protection and Interagency Cooperation	22

SECTION 6.0 SAMPLE COLLECTION DOCUMENTATION	25
6.1      Sample Identification Numbers	25
6.2      Sample Container Labels	25
6.3      Standard Operating Procedures (SOP)	26
6.4      Records of Sample Collection Operations	26
6.5      Custody Seals	27
6.6      Chain of Custody Form	27

SECTION 7.0 SAMPLE COLLECTION PROCEDURES	29
7.1      Equipment for Biological (Pathogen and Toxin) Sampling	29
7.2      Equipment for Chemical and Radiochemical Sampling	29
7.3      Example of Sampling Procedures	30
7.4      General Sample Collection Guidance	30
7.5      Grab Sampling Procedures for Biological, Chemical, and Radiochemical Contaminants	30
    7.5.7    Volatile and Carbamate Pesticide Samples	31
    7.5.2    Other Chemical Contaminant Samples	32
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
7.6      Biological (Pathogen and Toxin), Chemical, and Radiochemical Sample Container and
Preservative Requirements	32
7.7      Biological Sample Concentration Procedures	34
    7.7.7     Ultmfiltmtion Procedure	34
    7.7.2    Membrane Filtration	34
SECTION 8.0 SAMPLE PACKAGING AND SHIPMENT	37
8.1      Packaging - Low Hazard Samples	37
8.2      Shipping - Low Hazard Samples	38
8.3      Hazardous Sample Packaging and Shipment	38
    8.3.1    Packaging for Biological Samples	38
    8.3.2    Packaging for Chemical Samples	38
    8.3.3    Packaging for Radiochemical Samples	38
    8.3.4    Shipping	38
SECTION 9.0 CONSEQUENCE MANAGEMENT	41

SECTION 10.0 REFERENCES	43
List of Tables
Table 5-1. Field Collection Kit- Example	15
Table 5-2. Core and Expanded Field Test Kits	17
Table 7-1. Biological (Pathogens and Toxins) Collection Guidelines	32
Table 7-2. Chemical Collection Guidelines	33
Table 7-3. Radiochemical Collection Guidelines	34


List of Figures
Figure 2-1. Sampling for Analyses of Unknown Contaminants in Drinking Water	4
Figure 6-1. Example Sample Container Label	26


Appendices
Appendix A    Acronyms and Other Abbreviations
Appendix B    Glossary
Appendix C    Example of a Generic Sampling Checklist
Appendix D    Example of a Sampling Event Report Form
Appendix E    Example of a Field Testing Report Form
Appendix F    Example of a Photograph Log
Appendix G    Example of a Chain of Custody Form
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 1.0  Introduction

Homeland Security Presidential Directive 9 (HSPD 9), in pertinent part, directed the U.S. Environmental
Protection Agency (EPA) and others to "build upon and expand current monitoring and surveillance
programs" to:
1. Develop robust, comprehensive, and fully coordinated surveillance and monitoring systems for water
quality that provide early detection and awareness of disease, pest or poisonous agents.

2. Develop nationwide laboratory networks for water quality that integrate existing federal and state
laboratory resources, are interconnected, and utilize standardized diagnostic protocols and procedures.

In response to the first task under HSPD 9, EPA proposed and initiated development of a Contaminant
Warning System. Sampling and sample screening are crucial components of the Contaminant Warning
System, which are addressed in this document.
The Sampling Guidance for Unknown Contaminants in Drinking Water provides comprehensive guidance
that integrates recommendations for pathogen, toxin, chemical, and radiochemical sample collection,
preservation, and transport procedures to support multiple analytical approaches for the detection and
identification of potential contaminants in drinking water.  The guidance is intended to support sampling
for routine and baseline monitoring to determine background concentrations of naturally occurring
pathogens, sampling in response to a triggered event, and sampling in support of remediation or
decontamination efforts. The primary intended audience of this guidance document is drinking water
utilities, but  it may also be a useful reference for emergency response personnel. Given the complexity of
a drinking water response, the response may quickly surpass the abilities of most utilities. Utilities are
likely to call upon emergency responders.  This guidance document can be used to supplement a drinking
water utility's emergency response plan by providing detailed recommended sampling procedures for use
by utility personnel in response to a potential contamination event. The sample collection procedures
described may also be used to support other monitoring activities for specific contaminants or classes of
contaminants, as appropriate.
The specific sampling procedures described may be modified to meet the analytical objectives or scope
(i.e., target analytes) of the sample collection event. For example, a subset of the sampling procedures
could be used to collect samples  targeting one or several contaminants while the entire suite of sampling
procedures could be used in situations where the presence or nature of the suspected contaminant(s) was
unknown. This document also provides guidelines for the development and training of effective and
responsive sampling teams. Recommendations for establishing appropriate communication and support
networks, information management systems, site characterization procedures, field screening and testing
procedures, and personnel safety and protection are included to support the integrated monitoring and
surveillance  activities of water utilities.
If there is evidence or information  suggesting a harmful contamination, then there is a possible threat to
the life or safety of the utility personnel. The utility should request a trained Hazardous Materials
(HazMat) emergency response team. Ideally, the utility emergency response plan should include pre-
established lines of communication with the HazMat emergency response team. However, in most
situations, calling 9-1-1 will also work.
This guidance document presents a model to guide emergency response actions in the event of a
contamination incident.  Capabilities of utilities are expected to vary. The suggestions in this document
are not mandated. Many small and medium sized utilities will not have the resources to implement most
of the measures discussed in this guidance.  However, small utilities can take initial steps to prepare for a
contamination incident.  These include:

    •   Contact local HazMat response units, familiarize them with the layout and procedures of the
       utility, and become aware of the utility's response capabilities

    •   Research the capabilities of the local laboratories within driving distance of the utility
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
    •   Become aware of the resources offered for emergencies by the Centers for Disease Control and
       Prevention (CDC) Laboratory Response Network (LRN), Regional Laboratory Response
       Network, and the EPA's Water Laboratory Alliance (WLA)

    •   Conduct a tabletop exercise to determine how the utility would respond to a variety of
       contamination scenarios with the resources at hand.  Invite representatives from the local HazMat
       response unit to these exercise discussions. Ask for their recommendations, and establish lines of
       communication for use during a response.

1.1    Document Organization
The remaining sections of this document describe the following aspects of collecting drinking water
samples to be analyzed for targeted or unknown contaminants:

•   Section 2.0: Overview of Sampling Approach. This section presents an overview of activities that
    should be completed or in place before sample collection activities begin.

•   Section 3.0: Utility Roles and Responsibilities.  This section presents an overview of the roles and
    responsibilities that drinking water utilities should have in place to establish appropriate sampling
    capabilities and procedures.

•   Section 4.0: Safety and Personal Protective Equipment.  This section provides general guidelines
    on the use of personal protective equipment for sampling teams.

•   Section 5.0: Preparation for  Sample Collection Activities. This section presents an overview of
    the quality assurance/quality control samples that should be used for sample collection.

•   Section 6.0: Sample Collection Documentation.  This  section describes sample collection
    documentation that should be completed before and during the sampling procedure.

•   Section 7.0: Sample Collection Procedures. This section describes recommended sample collection
    procedures.

•   Section 8.0: Sample Packaging and Shipment.  This section describes recommended packaging and
    shipping procedures for sample containers.

•   Section 9.0: Consequence Management. This section provides information on the current resources
    that are available for a utility that will aid them in writing a consequence management plan.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 2.0 Overview of Recommended Sampling Approach

This document is provided as a guidance, to outline an ideal level of preparedness. Responses to specific
events by utilities with lesser capabilities are expected to vary greatly. The recommended sampling
approach assumes that the utility has:

•   Defined sampling capabilities for biological, toxin, chemical, and radiochemical analytes
•   Developed on-site sample screening capabilities
•   Established sampling team requirements, such as personnel, training, etc.
•   Established a laboratory support network and chain of communication for the sampling teams
•   Established an information management system

Figure 2-1 provides a conceptual flow chart of the requirements for biological (including toxins),
chemical, and radiochemical sampling.
After a potential contamination incident has been identified, a site characterization should be conducted to
obtain samples and other evidence to help determine the level of threat.  Site characterization activities
include the site investigation, field safety screening, rapid field testing of the water, and sample
collection. The investigation site is the  focus of site characterization activities and is the location where it
is suspected that the  contaminant was introduced into the system. In addition to the investigation site,
other sampling sites  might be identified around the system if it is suspected that the contaminant might
have spread.
All sampling equipment and sample containers should be sterile for collection of samples to be used for
biological parameters. Pre-cleaned and certified containers should be used for chemical parameters.
Sampling kits should be prepared before an incident occurs. Preservatives may be applied in the
laboratory or preferably in the field.

The objective of sampling from the site of a suspected water contamination event is to preserve a sample
of the water at a particular time and location, such that it can be analyzed if deemed necessary.  To do this
effectively, an initial sample plan should be developed prior to sample collection activities. The two most
common types of environmental  samples are grab samples and composite samples. In general, it is
recommended that only grab samples be collected from distribution systems; however,  in some situations
it may be necessary to composite samples over time or position. A grab sample is a discrete aliquot
representative of a specific location at a given point in time. The sample is collected all at once and at
one particular point in the  sample medium. A composite sample is composed of more than one specific
aliquot collected  at various sample locations and/or different points in time.
Many of these field activities can be practiced during routine or baseline sampling. Baseline sampling is
a constructive exercise for utilities to undertake in order to understand the range of contaminants that exist
in the drinking water under normal operations.
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                      Sampling Guidance for Unknown Contaminants in Drinking Water
                      Figure 2-1. Recommended Sampling Process for Analyses of
                                 Unknown Contaminants in Drinking Water
                             Collect chemical and radiochemical samples for field screening
1
r
Chemical screen:
Turbidity, pH, ORP, Conductivity, Chlorine,
CN', Headspace VOCs2

1
r
Radiochemical screen:
Gamma screen - 12 second count2
                                                                            ,    Follow decision   .
                                                                          ^|  tree below only for  |
                                                                            I     appropriate     /
                                                                            \   sample class.   /
    Pathogen and toxin
        sampling
   Collect grab samples.
     See Table 7-1.
Chemical sampling

1
r
Collect grab samples as
necessary.
See Table 7-2.

Radiochemical sampling
 Collect grab samples.
    See Table 7-3.
                     Transport samples to laboratory in coolers with ice or ice packs. Include the chain of
                           custody form, field screening results, and site characterization forms.
                                                    I
             Receive samples at laboratory. For pathogens and toxins, sample concentration or membrane filtration
                                    is performed at the laboratory before analysis.
   1EPA recommends Technology Testing and Evaluation Program evaluations to be consulted prior to purchasing
    screening equipment.
   2The screening techniques mentioned are provided as common examples and do not constitute an exhaustive list.
   3Threshold values refer to those set during baseline monitoring or known background levels.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 3.0  Utility Roles and Responsibilities

Drinking water utilities are strongly encouraged to establish appropriate and standardized sampling
capabilities and procedures. Ideally, each utility will have "in-house" sampling teams that will be capable
of collecting and providing samples to the appropriate analytical laboratory for baseline contaminant
monitoring and in response to a triggered event. The following sections provide guidelines to assist
utilities in the preparedness planning, implementation and integration of these critical response elements.

3.1     Defining Sampling  Requirements: Capabilities and Capacity

In preparation for baseline contaminant monitoring and response to a trigger, the utility should evaluate
the utility's sampling capabilities to ensure that all required sample collection activities can be performed.
The utility manager should evaluate sampling capacity to ensure that adequately trained personnel  and
sufficient sampling equipment are available. Ideally, a utility should respond only with its own personnel
to a suspected contamination.  If there is evidence or information suggesting a harmful contamination,
discovery of HazMat receptacles, or a possible threat to the life of the utility personnel, the utility should
request a trained  HazMat emergency response team.  Ideally, the utility emergency response plan should
include pre-established lines of communication with the HazMat emergency response team.  However, in
most situations, calling 9-1-1 will also work.

3.1.1  Sampling for Baseline Monitoring

Once standardized sampling capabilities and procedures are in place, the utility should focus on
establishing a utility-specific profile or baseline levels of both priority contaminants and standard
chemical parameters (chlorine, pH, oxidation-reduction potential, etc.).  This baseline profile is critical to
distinguish background or naturally occurring levels of each contaminant from higher levels that may be
observed following a contamination incident. For many priority contaminants, the baseline is expected to
be zero or below the detection limit of the corresponding analytical methods. To address spatial and
temporal variables within the treatment and distribution systems, baseline monitoring should involve the
collection and analysis of multiple types and numbers of samples.

Baseline monitoring should use the  same sample collection and analysis procedures that would be used in
a triggered event. This way the utility will have an idea of what the analytical results for drinking water
are under normal conditions. This will eliminate unnecessary suspicion during a triggered event for low
level detects that are seen regularly. Baseline monitoring can also serve as practice for the sampling
teams and the utility's network of laboratories, so triggered events will go more smoothly.
Baseline monitoring may be either a very extensive activity, or a simple evaluation of data that the utility
normally collects. Naturally, the more extensive the baseline monitoring, the more confidence the  utility
will have when evaluating data during a response event. EPA drinking water methods using mass
spectrometry are routinely used in the regulatory data produced for utilities (e.g., Methods 200.8, 524.2
and 525.2). These mass spectrometry methods  can detect contaminants in drinking water that are not on
the calibration list. These contaminants  are referred to as "non-target analytes."  Non-target analytes are
not usually reported for most EPA drinking water methods. It would be beneficial for a utility to be
aware of non-target analytes that are usually present in drinking water samples, but not calibrated for or
reported using the method. This could prevent a false alarm during a response event.

3.2    Sampling in Response to a Contamination Warning System Trigger

Adaptation of routine sampling and analysis procedures is important if there is a potential hazard present.
The level of personal protective equipment (PPE) and field screening may need to be increased and all
sampling and analysis may become  evidence in a future case.  These issues are discussed in Sections 4
and 5.  In addition, sampling teams responding to a potential contamination event should be trained and
equipped to characterize the site, perform on-site hazard screening using available field-test kits, collect
samples, and prepare samples for transport. These functions are similar to those normally provided by a

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HazMat response team, and utility managers are encouraged to coordinate with local HazMat resources to
provide training and support in the event of a contamination event. Utilities located near state and federal
agencies that have HazMat response capability may also benefit from establishing relationships with these
agencies to coordinate response support. For example, any utility located near one of the EPA's National
Response Team offices may want to establish relationships with the regional office. More information
can be found about the EPA National Response Teams at
http://www.epa.gov/superfund/programs/er/nrs/nrsrrt.htm.  Additionally, states may also have response
teams that are part of the state's department of health. If the site is characterized as having levels of
contamination that are above a low hazard level, a HazMat response team should be available to continue
the site characterization activities.

3.3    Sampling Team Preparation
Sampling teams should be familiar with the utility's operation, including the treatment plant and
distribution system, and the utility manager should ensure that sampling teams are continually updated on
any changes in facility design or distribution. Sampling teams should be familiar with the utility's
Emergency Response Plan (ERP), Vulnerability Assessment (VA), and any other contingency plans that
may assist the team in developing an effective sampling strategy.  Utilities should make all response
documents and plans available to all parties that could participate in an emergency response. Sampling
teams should be familiar with the sampling techniques and associated activities presented in this
document and should use these during all sampling activities. Each drinking water utility should
determine the extent of site characterization capabilities that will be performed by either the sampling
team or by an external organization. A drinking water utility may choose to develop capabilities for
performing site characterization and core field testing in cases where a low hazard exists, but should make
arrangements with HazMat responders to provide support during the characterization of a potentially
hazardous site. It is critical that the utility plans for in-house site characterization activities and makes
arrangements with those agencies that would be called upon in the event that a situation exceeds the
utility's resources and capabilities.
All utilities should conduct field drills, ideally with local HazMat or other local emergency response
resources, to become efficient in carrying out their ERPs.

3.4    Defining Analytical Support Requirements: Capabilities and Capacity
It is critical that utilities evaluate their internal analytical capabilities and incident response capacity.
Some priority contaminants (select biological agents,  some chemical agents, and radiochemicals) should
be analyzed by qualified laboratories using specialized and or restricted analytical methods. It is
important that utilities participate in analytical support networks. They are encouraged to look into the
resources offered by the EPA Regional Laboratory Response Plans, the CDC's Laboratory Response
Network (LRN), and EPA's Water Laboratory Alliance.  Internal and external analytical support
networks should be in place and operational prior to initiating any baseline sampling and analysis
activities and in preparation for a triggered event.
Usually the closest LRN laboratory will be the state's department of health laboratory. For more
information, CDC can be contacted at 800-CDC-INFO, 888-232-6348(TTY), or cdcinfo@cdc.gov. More
information is also available at: http://www.bt.cdc.gov/lrn/.
Each EPA Region contains an EPA regional laboratory, which may also be able to provide support.

3.4.1  Establishing Analytical Support Networks
Establishing a support network of laboratory analytical capabilities and capacity will ensure that samples
can be processed properly and expeditiously. To assist in locating laboratories capable of providing the
necessary support, the EPA Environmental Laboratory Compendium includes a database of nationwide
environmental laboratories available to water utilities and to federal and state agencies, which can be
reached through a link in the references section. The database contains each laboratory's specific

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
capabilities for biological and chemical analyses as well as bioterrorism, chemical warfare, and
radiochemical agents.  This database was developed as a tool to quickly identify laboratories with
capabilities to support incident-specific response and recovery efforts and to assist water utilities and
federal and state agencies in responding to contamination threats, terrorist attacks or natural disasters.
Once an appropriate analytical laboratory support network has been identified, it is imperative to establish
a chain of communication between and among the utility and the supporting laboratories.  This will
enable logistical support and coordination between the utility's sampling activities and analytical
requirements and provide a framework for data reporting and information management.
Support laboratories should be consulted regarding specific sample collection, sample preservation, and
sample shipping requirements.  In some cases, support laboratories will train sampling teams in
specialized sample collection procedures (e.g., ultrafiltration).  The support laboratory may also provide
the utility with or assist with the preparation of sample kits to ensure that the samples are properly
prepared and preserved for the required analyses, particularly for sampling unknown or tentatively
identified contaminants. It is important to follow specific laboratory requirements since this may impact
the quality of the analytical results.  Some laboratories may request specific quality control (QC) samples
such as field duplicates, field blanks, trip blanks, and field matrix spikes and may require specific chain of
custody, notification, and shipping procedures.
A laboratory may request that the sampling team collect backup samples in case there is a problem with
the set of samples that are delivered to the laboratory, or if there is a need for additional samples for
confirmation or analysis by another entity (e.g., a specialty laboratory or law enforcement agency).
Backup samples should be properly stored, secured, and tracked  such that the integrity of the samples is
maintained.
If during a triggered sampling event the decision is made to analyze the samples immediately, the
laboratory should be contacted as soon as possible so they can prepare for arrival of the samples.
Laboratories may be responsible for the rapid analysis of samples collected in response to a
contamination threat; thus, they should be engaged during site characterization activities if possible.
Furthermore, the laboratory will need information from site characterization to support the development
of the analytical approach for a specific contamination threat.  In some cases, the laboratory may provide
support staff to assist with sample collection and field analyses, as long as this staff is trained in sampling,
field screening, and in the safety standard operating procedures (SOPs).

3.5    On-site Sample Screening Capabilities (Field Kits and Procedures)

Prior to initiating any sampling activities, each utility should evaluate their on-site sample screening
capabilities. Sample screening procedures should be well defined and specific protocols should be in
force for use by appropriately trained personnel prior to sample screening.  More specific detail on sample
screening procedures is located in Section 5.2 of this document.  EPA's Response Protocol Toolbox
(RPTB), Module 3: Site Characterization and Sampling Guide (USEPA, 2003) should also be referenced
for guidance related to on-site sample screening parameters.

3.5.1  Baseline  Monitoring/Routine Monitoring: On-site Screening
During baseline monitoring, sample screening will provide laboratories with information regarding
conditions in the environment and the water quality at the time of the sampling event.  Screening
activities may include the use of instrumentation or equipment to measure water quality parameters (i.e.,
pH, conductivity, chlorine residual, hardness,  and temperature) that may indicate the presence of harmful
contaminants or substances or conditions that may interfere with analyses.

3.5.2  Triggered Monitoring: On-site Screening
During a triggered event, water quality parameters should be measured after a site  characterization has
been performed, EPA RPTB, Module 3, and after it has been determined that it is safe to enter the site.

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The information provided by field test results can be valuable in making decisions early in the response to
a contamination threat, particularly during the transition from the "possible" to the "credible" stage.
Results from the on-site screening can also be used to refine the sampling plan.
Assuming that the threat has not been dismissed as "not credible" upon completion of the on-site
investigation, samples should be collected as a precaution such that they are available for analysis if
necessary.  Negative field test results are not a good reason to forgo sampling at this stage, since field
testing is limited in scope and there is a potential for false negative results.  The decision to send samples
to a laboratory for analysis should be based on the outcome of the entire threat evaluation, including site
assessment, evidence evaluation, and sample screening. Specifically, if a threat is determined to be
"credible," samples should be immediately delivered to the laboratory for analysis.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 4.0  Safety and  Personal Protective Equipment

Disclaimer: EPA is including this section on safety and personal protective equipment (PPE) for general
informational purposes. For up-to-date information and more specific details about safety and PPE
requirements and recommendations, please refer to the Occupational Safety and Health Act and
implementing regulations, directives, and guidance  (see  osha.gov).

Utilities are not expected to handle a contamination incident on their own when hazardous materials are
believed to be present in high concentrations. However, they are expected to coordinate closely with
local HazMat response teams.  The information in this section is provided to introduce utilities to
HazMat safety considerations.  It does not necessarily represent expected or required capabilities on
the part of the utility. Many utilities do not have personnel trained in hazardous waste operations  and
emergency response (HAZWOPER; 29 CFR 1910.120). Utilities without HAZWOPER-trained
personnel should focus on collaboration with local HazMat response units.  Some material in this section
(e.g., Level A and B PPE, confined space entry, etc.) should not be attempted by personnel who are not
trained to 29 CFR 1910.120 requirements.  HazMat response units will receive a level of training that far
exceeds the material covered in this section. As previously stated, the information in this section is
provided to introduce utilities to HazMat safety considerations.
Proper safety practices are essential to minimize the risks to the site teams and should be established prior
to an incident.  Training for all team members should conform to appropriate regulations, such as
Occupational Safety and Health Administration's (OSHA) Hazardous waste operations  and emergency
response regulations, 29 CFR 1910.120.  PPE for a low level contamination should consist at a minimum
of safety gloves, safety glasses with side  shields, covering of extremities, and safety shoes. Additional
levels such as clothing protection and respiratory protection may also be necessary but require  additional
training. All PPE should be treated as contaminated until the sample results are known.
The level of personal protection necessary to perform site characterization and/or activities will depend on
the assessment of site hazards that might pose a risk to the  site characterization team.  The results of the
field safety screening and initial site evaluation will be used to assess the site hazards, and are intended to
confirm the absence (or presence) of certain acute hazards prior to site entry.
The sampling team should follow good safety practices,  including:

•   Do not eat, drink or smoke at the site.
•   Do not smell or taste the water sample.
•   Avoid contact with the sample or water flow.
•   Minimize volatilization or aerosolization of contaminants into the air.
•   Minimize contact time with expected contamination by proper and efficient assessment and sampling.
•   Conduct response at sites with obvious signs of hazards using properly trained personnel and
    equipment, such as HazMat teams, EPA (or other federal) on-scene coordinators (OSCs), or other
    hazardous material response support.
This section provides some general guidelines in the use of PPE that are typically followed by HazMat
Response Teams, and are recommended for sampling environmental material in response to an unusual or
suspicious contamination event. This section also provides summary information regarding the types of
hazards that should be considered.

4.1      Personal  Protective Equipment
The level of PPE used should be determined by the level of potential risk associated with the respective
incident as assessed by the utility management. Most utilities have only the basic level of PPE available
for use by their staff, and are therefore expected to coordinate sampling procedures with local HazMat
units, who would arrive in response to an incident with high levels of PPE.  Specific guidance for
selection of PPE is provided in Appendix B to 29 CFR 1910.120. Factors that should be considered

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                   Sampling Guidance for Unknown Contaminants in Drinking Water
during selection include: contaminant identification, routes of exposure (i.e., inhalation, skin absorption,
ingestion, and injection), performance of equipment in protecting against exposure, activity duration, and
stress induced by work requirements. Because the use of PPE can also cause hazards to workers (e.g.,
heat stress, impaired vision and mobility), care should be taken to provide a level of protection that is
sufficient to prevent exposure yet is not too high so as to create other unnecessary hazards.
The following information about PPE is quoted directly from Appendix B to 29 CFR 1910.120:
       Part A. Personal protective equipment is divided into four categories based on the degree
       of protection afforded. (See Part B of this appendix for further explanation of Levels A,
       B, C, and D hazards.)
       I. Level A—To be selected when the greatest level of skin, respiratory, and eye protection
       is required.
       The following constitute Level A equipment; it may be used as appropriate;
        1. Positive pressure, full face-piece self-contained breathing apparatus (SCBA), or
       positive pressure supplied air respirator with escape SCBA, approved by the National
       Institute for Occupational Safety and Health (NIOSH).
       2. Totally-encapsulating chemical-protective suit.
       3. Coveralls.1
       4. Long underwear.1
       5. Gloves, outer, chemical-resistant.
       6. Gloves, inner, chemical-resistant.
       7. Boots, chemical-resistant,  steel toe and shank.
       8. Hard hat (under suit).1
       9. Disposable protective suit, gloves and boots (depending on suit construction, may be
       worn over totally-encapsulating suit).
        1 Optional, as applicable.
        II. Level B—The highest level of respiratory protection is necessary but a lesser level of
        skin protection is needed.
        The following constitute Level B equipment; it may be used as appropriate.
        1. Positive pressure, full-facepiece self-contained breathing apparatus (SCBA), or
        positive pressure supplied air respirator with escape SCBA (NIOSH approved).
        2. Hooded chemical-resistant clothing (overalls and long-sleeved jacket; coveralls; one or
        two-piece chemical-splash suit; disposable chemical-resistant overalls).
        3. Coveralls.1
        4. Gloves, outer, chemical-resistant.
        5. Gloves, inner, chemical-resistant.
        6. Boots, outer, chemical-resistant steel toe and shank.
        7. Boot-covers, outer, chemical-resistant (disposable).1
        8. Hard hat.1
        9. [Reserved]

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        10. Face shield.

        1 Optional, as applicable.
        III. Level C—The concentration(s) and type(s) of airborne substance(s) is known and the
        criteria for using air purifying respirators are met.
        The following constitute Level C equipment; it may be used as appropriate.
        1. Full-face or half-mask, air purifying respirators (NIOSH approved).
        2. Hooded chemical-resistant clothing (overalls; two-piece chemical-splash suit;
        disposable chemical-resistant overalls).
        3. Coveralls.1
        4. Gloves, outer, chemical-resistant.
        5. Gloves, inner, chemical-resistant.
        6. Boots (outer), chemical-resistant steel toe and shank.1
        7. Boot-covers, outer, chemical-resistant (disposable).1
        8. Hard hat.1
        9. Escape mask.1
        10. Face shield.1
        1 Optional, as applicable.
        IV. Level D—A work uniform affording minimal protection: used for nuisance
        contamination only.
        The following constitute Level D equipment; it may be used as appropriate:
        1. Coveralls.
        2. Gloves.1
        3. Boots/shoes, chemical-resistant steel toe and shank.
        4. Boots, outer, chemical-resistant (disposable).1
        5. Safety glasses or chemical splash goggles.1
        6. Hard hat.1
        7. Escape mask.1
        8. Face shield.1
         Optional, as applicable.
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4.2     Health and Safety Plans
Health and Safety Plans (HASPs) and the required level of PPE that should be used to collect samples
during an emergency response will vary depending on the site, the response event, and the responsible
organization. The purpose of these plans is to ensure maximum protection to workers, the environment,
and surrounding communities, in a way that is consistent with requirements needed to perform
operational activities.
When collecting samples that potentially contain unknown biological or chemical hazards, responders
should follow the HASP that is specific to their organization or to the event. HASPs should include, at a
minimum, instructions and guidelines regarding:

•   Names, positions and contact information of key personnel and health and safety personnel
•   Site or event-specific  risk analysis
•   Training requirements for specific events
•   PPE on site and usage requirements
•   Medical surveillance requirements (maintain confidential documents properly and securely)
•   Contact information and location of the nearest medical facility; directions (and map) to the facility
•   Site or event control
•   Emergency response plan
•   Entry procedures
•   Spill containment
•   Decontamination procedures

In the case of emergency response, these plans also should ensure protection of potential evidence,
criminal or forensic (see discussion in Section 5.4).

4.3     Confined Space Entry

Many utility infrastructures contain areas that qualify as confined spaces.  On their Web site,
http://www.osha.gov/SLTC/confinedspaces/index.html. OSHA defines a confined space as having
"... limited or restricted means for entry or exit, and it is not designed for continuous employee
occupancy. Confined spaces include, but are not limited to underground vaults, tanks, storage bins,
manholes, pits, silos, process vessels, and pipelines. OSHA uses the term  'permit-required confined
space'  (permit space) to describe a confined space that has one or more of the following characteristics:
contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential
to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a
smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health
hazard, such as unguarded machinery, exposed live wires, or heat stress."

One of the greatest risks associated with confined spaces is that the entrant will be working in an area that
does not have a sustainable atmosphere for life.  This could be due to very poor ventilation, displacement
of oxygen by another gas, or a poisonous/corrosive atmosphere.  "Permit-required confined spaces" (29
CFR 1910.146) outlines entry requirements. Training regulations for persons entering confined spaces
are contained in 29 CFR 1910.146(g).  Confined space training is commercially offered as a 12-hour
training course.

The training ensures that personnel entering confined spaces are aware of the ventilation and air
monitoring requirements necessary for entering confined spaces.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
4.4    Personal Safety Considerations
The following general guidelines should be considered and followed by first responders and sample
collectors in the aftermath of an event that may involve biological or chemical agents:

•   Stop  and assess the situation.
•   Contact the appropriate trained personnel.
•   Remove all non-essential personnel from exposure but do not allow them to leave the site.
•   Wear appropriate PPE.
•   Approach the site upwind of the suspected source or contamination area.
•   Handle contaminated materials with minimum manipulation.
•   Maintain  decontamination and contamination free zones properly.
•   Contain all contaminated PPE and sampling equipment for disposal or decontamination.

This guidance is general, and site-specific procedures should be followed on a case-by-case basis.

4.5    General Safety Guidance
The following general guidelines should be considered and followed prior to sample collection (Note: this
pertains to sampling in response to an incident, not routine sampling):

•   It is recommended that at least two personnel are involved in sample collection. The primary sampler
    has control of the sampling activity and is responsible for physical sample collection,  filling the
    containers, and cleaning the outside of the containers. The second sample collector or technician is
    responsible for labeling, packaging, record keeping and communication with the personnel outside of
    the contaminated area.  If site geography or the contamination warrants, a third person with the sole
    task of record keeping should accompany the sampling team.  This third party will carry any cameras
    and will stay in frequent radio communication with others outside of the contaminated area.

•   Be aware of potential safety hazards associated with ignitable or explosive environments.  Equipment
    that could potentially be a source of ignition (i.e., cell phones, cameras, radios, etc.) should not be
    used  in these areas.

•   Review any available information regarding the site or contamination  event to determine if any
    additional equipment or PPE is needed. It is better to be prepared than to risk exposure to the
    sampling  team.

•   Note  the full extent of the contamination area including whether the contamination is  general or
    concentrated in areas. If possible, note the migration or potential routes of the contamination.

•   Assemble more sampling kits than are expected to be needed. Sampling kits are composed of a
    scalable bag with the required container(s), documentation forms, storage and transport containers,
    decontamination materials, and sample collection equipment.

•   Complete the sample container labels as much as possible prior to  sample collection.  A label should
    be attached to every container and outermost containment bag/container to assist in easy collection.
    This  pre-sampling organization is significantly easier and less time consuming to do while in the
    comfort of an office, staging location, or vehicle than while sampling in PPE in the field.

•   At a minimum, wear safety glasses and two pairs (layers) of nitrile gloves over regular safety
    equipment.  Only the outer gloves need to be changed between each sample as long as the inner
    gloves remain clear of all contamination. Proper safety practices should always be observed. Potable
    water should be  carried to remove contaminated materials from skin or eyes.
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•   Leave the sampling kits at the perimeter of the contaminated area, on the clean side of the
    contaminated area, preferably in the decontamination area. Sample containers should be treated as
    requiring custody to eliminate the potential for inadvertent or criminal external contamination, and
    should not be left unsupervised. Radio contact should be maintained with someone outside of the
    contaminated area. This contact provides safety and can assist in identifying the hazard(s) by
    relaying information to additional members of the assessment team.

•   A sampler or technician should be available to record a log of everything the sampling team does,
    note the time and record other details that might assist in interpreting the analytical data generated by
    the laboratory or screening facility.  Take at least one picture  of the area at the entry to the
    contaminated area and several pictures of the impacted area.  Take pictures of the areas to be
    sampled. If possible, lay a ruler or tape measure by the sampling points to allow the viewers of the
    pictures to know the scale of the photograph.

•   All PPE should be decontaminated or at least contained after use. All decontamination materials and
    disposable sampling equipment should be contained until the  nature of the contaminant is known.

•   Leave the sampling site as undisturbed as possible, as it may prove to be of evidentiary value, and
    return to the decontamination area to gather supplies and/or additional personnel.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 5.0  Preparation for Sample Collection Activities

This section contains information regarding sampling supplies, field test kits, field sampling quality
assurance/quality control, forensic protection and interagency cooperation.

5.1    Sample Collection Kits

Sample collection kits should contain all sample bottles, materials, supplies, and forms necessary to
perform sample collection activities from a hose bib, faucet, or other sample taps.  Other equipment may
be needed when collecting samples from fire hydrants, valves, distribution storage tanks or aquifers.
Table 5-1 lists the basic recommended components for a sampling kit as indicated by the EPA's RPTB:
Module 3, Site Characterization and Sampling Guide. The following list of suggested equipment for the
Field Collection Kit is presented as an example. Some utilities may decide it is appropriate to substitute
or include additional items.

Table 5-1. Field Collection Kit - Example

Note: When sampling for unknowns, collecting unpreserved samples should be the first priority.
Item
Quantity
Notes
FIELD RESOURCES AND DOCUMENTATION
Field guide
Health and safety plan
Sample labels
Sample documentation forms
Custody tape (or seals)
Chain of custody forms
Lab marker
2
2
2 times the
number of
bottles
24
2 rolls
24
2
Resource for field personnel
If required for the site
Waterproof (filled out in advance, if possible)
For recording sample information
Used on sample or shipping containers
For documenting sample custody
Waterproof, 1 red, 1 black
GENERAL SAMPLING SUPPLIES
Sample containers
Device for grab sampling
10 liter HOPE container
Lab grade tape
Miscellaneous glassware/labware
Collapsible cooler
Rigid shipping container
1 quart zippered freezer bags
Paper towels
Tables 7-1, 7-
2, and 7-3
1
4
3 rolls
N/A
1 or more
1 or more
1 pack/100
2 rolls
For collecting samples
For sampling large water bodies
For collection of large volume water samples
For temporary labeling in the field
Beakers, graduated cylinders, spatula, etc.
For sample storage
For shipping by overnight service if needed.
For double bagging ice and sample containers
Wiping wet containers and containing spills
BIOLOGICAL SAMPLING SUPPLIES
Tubing and clamp
Stopwatch & graduated cylinder
Ultrafiltration or membrane filtration
apparatus
1
1
1
For sample tap flushing, etc.
For measuring flow rate
For concentrating biological (pathogen and toxin)
samples
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Item
Quantity
Notes
REAGENTS (may need to be kept separate from the rest of the kit)
Laboratory grade water
Sodium thiosulfate crystals
Ascorbic acid
Sodium sulfite crystals
Potassium dihydrogen citrate
6 Molar ACS grade hydrochloric acid
(HCI)
6 Molar trace metal-grade nitric acid
(HNO3)
10 Normal Sodium hydroxide (NaOH)
Sulfuric acid (H2SO4)
pH paper in ranges from 0 to 4 and 10
to 14
5 liters
100 grams
100 grams
100 grams
100 grams
25 mL
25 mL
25 mL
25 mL
50 strips
For sample dilution in the field
For water sample disinfectant reduction
For water sample disinfectant reduction
For water sample disinfectant reduction
For carbamate preservation
In dropper bottle for preservation of samples for organic
analyses
In dropper bottle for preservation of samples for trace
metals analysis
In dropper bottle for preservation of samples for cyanide
analyses
In dropper bottle for preservation of samples for pesticide
preservation
For checking the pH of samples preserved with acid or
base (sensitive to 0.5 pH units)
SAFETY SUPPLIES
Splash resistant goggles
Disposable gloves
Disposable shoe covers
Clear, heavy duty plastic trash bags
Rinse water
Antiseptic wipes
Squirt bottle
First aid kit
Flashlight/headlamp
2
1 box per
size (S, M, L,
XL)
2 pairs
4
20 liters
1 container
2
1
3
One per individual (minimum)
Nitrile or polyethylene, powder-free
One pair per individual (minimum)
For disposal of lab coat, gloves, etc.
For general use and first aid
For cleaning hands, sample containers, etc.
For use with rinse water or lab grade water
For general first aid
For working at night or in dark locations
5.2     Field Test Kits (On-site/Field Pre-screening)

The generic types of screening and detection devices and kits listed in Table 5-2 could be included in a
field test kit.  The core field test kit should include the equipment necessary to conduct the recommended
minimum level of field safety screening and rapid water testing. Additional technologies that might be
used to perform expanded field testing are listed in the second section of the table.  The target parameter
for screening and rapid water testing may be a specific contaminant, a contaminant class, or a general
indicator of potential contamination. The class indicates whether the technology is suitable for field
safety screening, rapid water testing or both. The methodology describes the general principle of
detection for the technology.

Due to the wide range of available field testing equipment, specific devices and vendors are not listed
here; however, there are sites that do provide a detailed listing of commercially available detection
technologies, such as http://www.epa.gov/safewater/security/guide/index.html
http://www.ojp.usdoj.gov/nij/pubs-sum/190747.htm, and http://www.ojp.usdoj.gov/nij/pubs-
sum/184449.htm. Detailed verification reports for detectors that have undergone independent testing
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through the Environmental Technology Verification (ETV) program are available at
http://www.epa.gov/etv/verifiedtechnologies.html.

Additionally, EPA recommends Technology Testing and Evaluation Program (TTEP) evaluations to be
consulted prior to purchasing screening equipment.  TTEP is a non-biased EPA group that evaluates
testing equipment.

Table 5-2. Core and Expanded Field Test Kits
CORE FIELD TEST KIT
Target Parameter
Radioactivity (alpha, beta,
and gamma)
Cyanide
Chlorine residual
pH/conductivity
Class
Primarily a
Safety Screen
Water Testing
Water Testing
Water Testing
Methodology
G-M probe and meter
Colorimetric or ion selective
electrode
Colorimetric
Ion selective electrode
Comments
May be expanded to water testing
with a special probe.
Test water for cyanide ion, not
combined forms.
Absence of residual may indicate a
problem.
Abnormal pH or conductivity may
indicate a problem.
EXPANDED FIELD TEST KIT
Target Parameter
General hazards
Volatile chemicals
Chemical weapons (VX,
sarin, etc.)
Water quality parameters
Pesticides (OP and
carbamates)
VOCs and SVOCs
Toxins (ricin, botulinum,
etc.)
Pathogens (Bacillus
anthracis, Francisella
tularensis, etc.)
Toxicity
Class
Safety Screen
Safety Screen
Safety Screen
and/or , Water
Testing
Water Testing
Water Testing
Water Testing
Water Testing
Water Testing
Water Testing
Methodology
HAZCAT (explosives, oxidants,
etc.)
"Sniffer"-type devices
Enzymatic / Colorimetric
Variable (e.g., ion probes,
Colorimetric)
Immunoassays
Portable GC/MS
Immunoassays
Immunoassays and PCR
Inhibition of biological activity.
Comments
Should be performed by trained
HazMat responder.
Detects chemicals in air.
Many kits may also detect certain
pesticides. Some are sensitive
enough to use in water.
Kits available for a variety of
common parameters.
Semi-quantitative screening method,
few steps required.
Expensive, but expands field
capability for chemicals.
Semi-quantitative screening method,
few steps required.
Pre-concentration will increase
sensitivity.
Need to establish a baseline.
This list has been taken from the EPA Response Protocol Toolbox Module 3 document. It is not meant to be an
exhaustive list.

5.2.1   Core Field Test Kits
The core field test equipment should include a radiation detector capable of detecting alpha, beta, and
gamma radiation for field safety screening. It is used to quickly determine if ionizing radiation is present.
If detected levels of radioactivity are significantly higher than normal background levels, the site would
be characterized as a radiochemical hazard. A radiation detector is essential to determine whether or not
the site has been contaminated with radioactive material. Typically the components that form the detector
are sold separately and include  a probe (e.g., a pancake Geiger-Mueller [G-M] probe) and a rate meter.
Radiation detectors are an established technology, widely used by responders, simple to operate,
relatively inexpensive (<$1,000), and available from a variety of vendors.
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Water is an effective shield to both alpha and beta radiation, and weak forms of radiation may not
penetrate water at all. Thus, a negative result from a typical pancake G-M probe (designed to detect
radiation in air) does not provide assurance that the water is free of radioactive contamination. There are
devices, such as sodium iodide probes, that are designed to detect radiation (gamma) in water. In the
most cases, the presence of gamma radiation in a sample also suggests the possibility of alpha or beta-
emitters, and the absence of a gamma-emitter usually rules it out. Water shields alpha and beta
radioactivity.
Cyanide detectors should be included in the core field kit to quickly rule out, or tentatively identify,
cyanide as a potential contaminant in the water. Most commercially available cyanide test kits are based
on either colorimetric or ion selective electrode technologies. Several commercially available cyanide
detectors were verified by EPA's ETV program in 2003, and the verification reports can be found at
http://www.epa.gov/etv/.
Chlorine, pH, and conductivity detectors should be included in the core field test kit as general indicators
of water quality, and deviations from established baseline values may indicate a potential problem.
Chlorine residual measurements (both free and total) should be of particular interest in distributed
drinking water since the absence of a residual disinfectant is undesirable under any circumstance.
Chlorine residual test kits incorporate established technologies that are widely used in the drinking water
treatment industry.  Chlorine residual test kits are typically based on colorimetric techniques.
Most pH instruments are based on ion-selective electrodes, and are regularly used  at every utility.  Some
pH instruments can also measure conductivity.
Conductivity is another useful indicator of water quality changes (assuming that a baseline for
conductivity has been established).

5.2.2   Expanded Field  Test Kits
The equipment listed under the expanded field test kit section is intended to provide an indication of the
other types of detection technology that are currently available and which might be considered for
inclusion in a field test kit.  These additional detection technologies can provide additional information
for characterizing hazards at a particular site or increasing the range of contaminants that can be
tentatively identified during rapid field testing of the water.  Expanded field testing might include volatile
chemicals, chemical weapons, additional water quality parameters, pathogens, toxins, and general
toxicity. The technologies may be relatively simple and inexpensive, as is the case for many
immunoassay test kits,  or complex and expensive, as is the case for mobile gas chromatography/mass
spectrometry (GC/MS) instruments. Volatile organic compound (VOC) "sniffer"  devices may warrant
special consideration as they are commonly used in environmental monitoring, are relatively easy to use,
and can provide a rapid indication of potential volatile hazards.  Many of the technologies available for
pathogens and toxins are not sensitive  enough for use with drinking water.
False positive or false negative results from field testing can result in inappropriate decisions with
potentially significant consequences. Some utilities may choose to perform their own evaluation of a
field testing technology to characterize the performance of the detector so that it can be used with
confidence during a site characterization activity.
As with sample collection kits, field test kits should be maintained so that the equipment and chemical
reagents are in proper working order when the kits are needed.  This generally includes proper calibration
of instruments, ensuring that all reagents are fresh, checking batteries, and conducting any other
maintenance or operational checks recommended by the equipment manufacturer.  Furthermore, it is
critical to provide staff training in the actual use of any field technology that will be used to support site
characterization activities in response to contamination threats.  This can be accomplished through field
exercises or incorporation of the field testing technology into routine monitoring activities. The latter will
also provide an opportunity to develop baseline information for the monitored parameters. Such baseline
data are important for interpreting field testing results in the event of a threat.

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5.2.3  Examples of Field Testing Equipment
Below is a list of the examples of field testing equipment used along with brief summaries of the
procedures for use, strengths, and weaknesses for the equipment types.

Turbidity

Turbidity is the measurement of how many solid particles are suspended in a given volume of water.
Most turbidimeters measure the ratio of scattered light to determine how turbid the water is, and usually
cost about $800-900.  A sample of water is put into a cell which is then placed in the instrument to
determine turbidity. A daily calibration is usually required, with a more in depth calibration periodically
(e.g.,  quarterly). After calibration, it is best to perform the turbidity measurement at the sampling site
very soon after sampling. If this is not possible, it should be done within 24 hours.

pH, Oxidation Reduction Potential, and Conductivity
Many commercial screening  instruments are  available that can measure pH, oxidation reduction potential
(ORP), and conductivity of water samples using multiple electrodes contained in one instrument. These
instruments cost about $700. Measurements are taken by filling small cells with sample, and then
submerging the instruments electrodes into the sample cell.  Conductivity and pH checks usually should
be performed at the beginning of each day before taking the multi-parameter probe into the field. ORP
electrodes rarely give false readings unless there are problems with the reference electrode. For this
reason, and because calibration solutions for ORP are highly reactive and potentially hazardous, most
multi-parameter probes have an electronic ORP calibration.

Cyanide and Chlorine

Cyanide and chlorine can both be detected in the field using colorimeters. These instruments usually cost
about $1,000.  There are separate procedures for cyanide and chlorine. The most common cyanide
procedure utilizes isonicotinic acid and barbituric acid reagents that react with cyanide to form strongly
absorbing compounds. The measurement is performed by mixing the water sample with specific
reagents, and then placing the sample in a cell which is inserted into the colorimeter.  Note that this
"field" procedure reports only free cyanide and not total cyanide.  Chlorine is also measured by mixing
the sample with a reagent, and then placing the sample in the colorimeter.
The colorimeter should be calibrated periodically, and the instrument should be recalibrated before
expiration of calibration period.

Sample Headspace VOC Measurement
A photoionization detector (PID) that can detect volatile organic compounds (VOCs) down to part per
billion levels should be used  to measure VOCs volatilizing from a drinking water sample or liberated
from the sample by shaking or agitation.  These instruments usually cost about $7,000. The PID is a
nonspecific total organic vapor detector.  It does not give the concentration of any single, specific
chemical in the headspace. The PID measures VOCs in the range 1 to 9999 ppb. There are two
calibration checks to be performed, a fresh air calibration, and a span gas calibration.  Generally, the fresh
air calibration or "instrument zeroing" should be done each time the instrument is turned on. Calibration
of the PID with span gas is generally performed once a month.  After calibration is performed the
measurement of VOC  concentration in a sample container headspace can be performed.

M272 Water Testing Kit for Chemical Warfare Agents

M272 kits were originally developed by the U.S. Army, but currently many commercial vendors
manufacture identical  kits. These kits cost about $650 each, and can analyze only about 20 samples. The
testing is somewhat time-consuming, so these kits are often used only as a backup analysis if chemical
warfare agents are suspected. M272 kits screen water samples for chemical warfare agents (Lewisite,

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
nerve agents, sulfur mustard, and cyanide) using a series of color changing chemical reactions.  The test
kit will also respond to less toxic substances with similar chemical properties as chemical warfare agents.
Some of the substances are relatively common, so it is important to remember that a positive result on the
M272 does not always mean that a chemical warfare agent is present.  The lower detection limit of the
tests are 20 mg/L for cyanide, 2 mg/L for mustard, 2 mg/L as arsenic for Lewisite, and 0.02 mg/L for G
and V nerve agents. The test is qualitative and does not distinguish between different compounds within
a class.  The procedure varies depending on which test is performed.

Field Site Atmosphere Safety Screening: VOC, Oxygen, Combustibles, and Toxic Gases

Several brands of multi-gas meters are commercially available. The most common type of multi-gas
meter contains detectors for volatile organic compounds (VOCs), oxygen (O2), combustibles, and toxic
gases (carbon monoxide [CO] and hydrogen sulfide [H2S]). These instruments cost about $4,000.  Their
main purpose for sampling activities is to monitor the atmosphere in the vicinity of a drinking water
sampling location.  The instrument requires periodic calibrations or calibration checks. There are three
calibration checks to be performed; fresh air calibration, multi-sensor calibration, and PID VOC
calibration. Generally, the fresh air calibration or "instrument zeroing" should be done each time the
instrument is turned on. Calibrations of the multi-gas sensors and the PID are generally performed once a
month. After calibrations have been performed, readings can be made with the multi-gas monitor. The
instrument readouts are updated about every second.

Field Site Safety Radiation Measurement and Water Sample Testing

A kit containing multiple radioactivity detectors for alpha,  beta, and gamma radiation is much more
sensitive than a standard G-M detector, but also costs significantly more (about $2,300).  The multiple
detectors will not identify the actual isotope (radioactive material element and mass) or source of
radiation being detected by the instrument.  However it, will tell the user whether alpha, beta, or gamma
radiation is the primary emission. These detectors will respond to naturally occurring, background
radiation. The background level varies by location.  Radiation detection instruments should be
maintained with a periodic (usually annual) factory calibration procedure, and frequent QC checks
(usually with every use) with radiation check sources are also important.
Some pancake-type detectors can detect alpha, beta, or gamma radiation, whereas the Gamma
Scintillation detector and Gamma Survey Detector are used only for gamma radiation. A scanning survey
determines the levels of contamination in an area, whereas a point survey determines the level of
contamination of a certain object (such as a bottle of water) in an area or before being shipped off site.
Never contact the surface of the detector with the contaminated area, as to prevent the transfer of radiation
to the detector.  After each instrument is calibrated and checked, measurements can be made.

Rapid Toxicity via  Chemiluminescence

Chemiluminescence water test kits, specifically arsenic tests and rapid toxicity tests via a
chemiluminescence technique, referred to as "Chemiluminescence Toxicity (CT)" are good overall
indicators of whether toxic chemicals  are present in  drinking water. The results of the
chemiluminescence technique can be significantly influenced by factors such as turbidity, rust, and even
normal, small, day-to-day variation in processing at the water treatment plant. Accordingly, establishing
the instrumental response baseline before leaving to respond to an incident may result in data important in
interpreting the test results.
The CT test should be  performed last, for it can be time consuming. The luminometer for the CT test
should be formally calibrated before each use.  CT reagents used for calibration and for measuring
samples, can be temperature sensitive. If diluted reagents (described in the instrument manual) are not
refrigerated, they should be remade every 72 hours.  Reagents will remain stable for 1 year if refrigerated.
After calibration, measurements can be made.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
5.3    Quality Assurance/Quality Control
The sampler should employ a quality assurance/quality control (QA/QC) program. The following general
protocols for quality control should not be considered to be exhaustive. The program should include the
collection of equipment blanks, field blanks, and field replicates, when available and as appropriate for
the intended analyses. Field QA/QC requirements should be specified in sampling or site plans and
analytical support laboratories should be included in the discussion as analytical QA/QC requirements
will greatly impact field sampling. This program should also include the routine calibration of all field
instrumentation used for rapid on-site testing.  The frequency of performing these QA/QC samples is
dependent on the data quality needs and objectives.
The purpose of any QA/QC protocol is to ensure that 1) the laboratory receives samples that accurately
represent the conditions existing at the sample site, 2) appropriate method-specific controls are provided
to the analytical laboratory, and 3) the results of the analyses are traceable to the specific sample location
or event.  The following QC procedures should be included, as appropriate:

•   Decontamination of Sampling Equipment: The field sampling plan should address the extent of
    decontamination and specify the procedures to prevent sample contamination.  Sampling may be
    performed using separate laboratory cleaned equipment for each sample location.

•   Sample Container Cleanliness Requirements: Specify the level  of QC for sample containers.  Pre-
    cleaned containers meeting EPA method-specific cleanliness protocols are available from many
    suppliers.  If pre-cleaned containers are used, the serial number and QA batch number of each
    container should be recorded in the Field Log Book/Notes or Field Form.  If sample containers are re-
    used, they  should be decontaminated, and field blank samples should be submitted to the laboratory to
    verify container cleanliness.

•   Field Duplicates and Split Samples: Field duplicates are two separate samples taken from the same
    source and are used to determine data repeatability based on field conditions. Field duplicate samples
    are assigned different sample numbers,  specified in the Field Log Book/Notes or on the Field Form,
    distinguished from the  regular field samples on the chain of custody (COC) form, and often submitted
    blind to the laboratory to provide objectivity. The comparability of the results provides information
    on the repeatability of the field extraction and analytical procedures. Split samples are two or more
    representative portions taken from one sample and submitted to different laboratories for identical
    analyses to obtain information on inter-laboratory repeatability.

•   Equipment Decontamination Blank: These samples provide information on the levels of cross-
    contamination resulting from field or laboratory sample preparation actions. The equipment blank is
    reagent water that is free of the analytes of interest, transported to the site, opened in the field, and
    poured over or through the sample collection device, collected in a sample container,  and returned to
    the laboratory and analyzed. Equipment blanks are collected for each type of equipment used in
    sampling during the day. Equipment blanks are assigned sample numbers and are not distinguished
    from regular field samples on the COC  form.

•   Field Blanks: Field blanks check the cleanliness of sample containers, environmental contamination,
    purity of reagents, or solvents used in the field.  A sample container is filled with laboratory  grade
    reagent water, preserved, and submitted for analysis for the same parameters as the regular field
    sample.

•   Trip Blanks: A trip blank is used when collecting VOC samples. A blank may consist of two 40-mL
    VOC vials filled at the laboratory with laboratory grade reagent water, transported to the sampling
    site, and returned to the laboratory without being opened. This blank serves as a check on sample
    contamination during sample transport and shipping.

•   Matrix Spike/Matrix Spike Duplicates (MS/MSD): Some analytical methods require that the
    laboratory  spike a portion of the matrix at a frequency dependent on the heterogeneity of the sample
    matrix, with a predetermined quantity of analytes prior to sample extraction/digestion and analysis.

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
    For MSB, a second portion of the matrix is spiked. A spiked sample is processed and analyzed in the
    same manner as the sample. The results of the spike compared with the non-spike sample indicate the
    ability of the test procedures to repeat recovery of the analyte from the matrix and also provides a
    measure of the performance of the analytical method.  Additional containers may be specified to
    provide enough material for this procedure. The sample containers are assigned the same sample
    number as the regular field sample and are designated MS/MSD on the COC form.

5.4    Forensic Protection and Interagency Cooperation
When collecting samples following a contamination event, sampling activities should be conducted with
the cooperation of any and all agencies investigating the incident.  Such cooperation will help ensure that
the necessary steps are taken to preserve a potential crime  scene and that proper evidence is collected and
protected. Special care should be taken to avoid moving any evidence until adequate documentation is
conducted and the appropriate officials are notified.  The following general protocols for maintaining
crime scene integrity are provided as guidance only, and should not be considered to be exhaustive. The
agency or agencies responsible for site investigation should be consulted for information regarding
evidence requirements.

•   Collection of environmental samples is time sensitive due to the public health and sample
    preservation implications. Thus, collection of samples may precede collection of physical evidence,
    and care should be taken not to disturb the crime scene while performing these activities.

•   Physical evidence should be collected in cooperation with the appropriate law enforcement agency.
    Specially trained teams from the law enforcement community (e.g., the HazMat Unit) are best suited
    (and may be required) for the collection of physical evidence from a contaminated crime scene.

•   Samples collected  during a criminal  investigation will be monitored by the local, state, or federal
    authorities and may be confiscated.  All actions taken within a criminal investigation should be
    documented.  Copies of all documentation should be maintained by all agencies present.

•   Special care  should be taken to avoid moving or disturbing any potential physical evidence or
    spreading the contaminant. Substantial physical evidence of a contamination event might include
    discarded PPE, equipment (such as pumps and hoses), and containers with residual material.

•   Samples may be considered evidence, and thus could be subject to security measures.  These
    measures may include keeping samples under the control of designated personnel at all times. When
    these samples are not in the possession of designated personnel, the samples should be secured (e.g.,
    locked in a secure area) and accessible only by designated personnel.  In the field, samples may need
    to be locked  in a vehicle.

•   It may be necessary to collect duplicate samples for law enforcement and to take photographs of the
    samples at the site  of collection as an additional form of sample documentation.

•   The samplers should, when possible, take pictures of the sample location and the sample container(s)
    at the location where the sample was collected.  If appropriate, Global Positioning System (GPS)
    coordinates should be obtained for sample locations.  Law enforcement should be consulted for
    proper handling during and after taking photographs/videos to ensure integrity of the evidence.
    Information concerning the times and locations of photographs taken or video recorded should be
    noted in a site logbook. A COC form should be maintained for all film development to ensure proper
    handling and tracking.
    Note: Photographs or video taken in areas of high security,  as well as notations and information
    collected regarding the area, may need to be discussed with the law enforcing agency prior to entry.
    Videos and pictures may not be possible in areas of high security; as a result,  drawings and written
    descriptions  may become critical documentation.

•   Sample COC documentation should  be initiated immediately after sample collection.

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
    Since analytical results may be considered to be evidence, it is important to use a qualified laboratory
    for analytical support and to gain written authorization to release documentation.

    Before exiting the site, samplers should practice the following:
    o  Verify that the perimeter has been properly secured before leaving the site. Verify that hatches,
       locks, etc.,  are properly secured.
    o  Remove all samples, equipment, and materials from the site. Remove all PPE at site perimeter
       and place disposable PPE and other trash into a heavy-duty plastic trash bag.
    o  Verify that all samples are in a transport container and properly seal the container.
    o  Ensure that all documentation has been completed.
    o  Comply with any other site control measures required by participating agencies.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 6.0  Sample Collection Documentation

Thorough documentation of sample collection and identification is important to ensure the validity of
samples and corresponding analytical results. This documentation is used to ensure that samples are
representative, protected from tampering, have been collected in accordance with any applicable
collection requirements, and have not been exposed to compromising conditions. Sample collection
documentation should include:

•   Sample identification and label
•   Records of sample collection operations and procedures
•   COC form

6.1    Sample Identification Numbers

Each sample consists of all the material collected from a given location at one time and of one matrix. A
sample identification number that is unique for each sample should be created by the sample collector, the
receiving laboratory, or a program or project manager.  Sample identification numbers often consist of
elements describing the sample type, matrix, location, and date and time of collection. This number is
unique to each sample. It is generally included in the sample documentation, and used to identify the
sample in field reports and log books, COC forms, and sample containers and labels. The number can
also be used on corresponding analytical data reports or evaluations.

6.2    Sample Container Labels

Each sample container should have a label that clearly provides information identifying and describing
the sample. Ideally,  sample container labels should provide the following information:

•   Site name
•   Sample identification number
•   Date and time the sample was collected
•   Sampling location (e.g., site name or address)
•   Container size
•   Container type
•   Type of sample (grab or composite)
•   Analysis (Emergency response personnel may not know what analyses will be assigned to a sample.
    This line may not always be filled out.)
•   Preservatives added, if applicable
•   Dechlorination method, if applicable
•   Name or initials  of sample collector(s)
•   Hazard warning labels (The decision to use hazard warning labels should depend on the level of risk
    associated with the respective incident as assessed by the utility management, and should be used at
    their discretion.)

All of the information on the sample label should be identical to the information on the COC form.  The
sample collector should be able to recollect where and when the samples were taken in case additional
sampling or analysis is necessary.
To facilitate sample collection activities and ensure proper labeling, sample containers should be pre-
labeled as much as is practical prior to sample collection. Sample labels should be completed with a
waterproof pen and securely affixed to each sample container to identify each sample clearly.  If a
waterproof pen is not used, it is recommended that the sampler cover the label(s) with clear packaging
tape after writing the sampling information onto the label.  An example sample label is provided in Figure
6-1.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
                          Figure 6-1. Example Sample Container Label
Site Name:
Sample ID Number:
Date: Time:
Location:
Container Size:
Container Type:
Sample Type (e.g., grab,
Analysis:
Preservative:
composite):


Dechlorination:
Collected by (initials):

6.3    Standard Operating Procedures (SOP)

All field activities should be performed in accordance with SOPs. Utilities should prepare SOPs for the
entire sampling process.

6.4    Records of Sample Collection Operations

Field report forms should include any details that might assist in the interpretation of the data/results from
laboratory analyses and in the overall assessment of the contamination situation.  Notes on changes to
flows, coloration, field data, field conditions or unexplained flora/fauna can assist in understanding the
analytical data. The  "Generic Sampling Checklist" (Appendix C) provides a guideline to ensure that all
information is captured during a sampling event. This includes site location, conditions, field screening
that was performed, and relevant observations.
The field reporting forms (Sample Event Report Form and Field Testing Report Form) should
prominently show the sample identification number, date and time of collection, sample location, and
sample collector name(s). An example of a Sampling Event Report Form is provided in Appendix D, and
a Field Testing Report Form is provided in Appendix E. These reports should also contain a description
of the sample and any information the samplers witnessed or know about the sample, including:

•   Level of PPE used
•   Weather conditions
•   Agencies involved in the sampling effort
•   Sample amount including units
•   Number of people  exposed
•   Symptoms of those exposed to the sample
•   General conditions of exposed flora and fauna (if available)
•   Field screening methods, instruments used and their results
•   Name  and signatures of sample collectors and others present during collection
•   Contact information of samplers or agency coordinators or managers
The information contained in the field reports can be used to help the laboratory determine an appropriate
screening or analytical strategy. If certain types of sample screening have been performed in the field,
laboratory pre-screening may not be necessary and the results may expedite sample analysis in the
laboratory. Information regarding any symptoms or environmental effects caused by the contamination
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
also will greatly aid sample recipients in regards to sample handling precautions and the level of PPE
needed.
Photographs are important field documentation at any site where there are forensic concerns. All site
photography should begin with a wide overall view and then progress to more detailed photos.  Entry and
exit photos should always be included. Always try to provide wide angle, medium, and close-up
photographs of the  relevant areas of the site.  Whenever possible, include a device to measure scale in the
photographs.  This  is best done with a ruler or tape measure displayed visibly in the photograph.
Photograph logs should be maintained during the sampling event.  An example  of a photograph log is
provided in Appendix F.

6.5     Custody Seals
Custody seals are attached to each sample over the cap to ensure the sample has not been opened or
tampered with after collection. Alternately, the shipping container can be custody sealed by placing a seal
over the closed opening making it impossible to open the container without ripping the seal.  Two custody
seals should be used on each container to maintain the integrity of the sample custody process.  Custody
seals contain the signature of the person responsible for packing the container and the  date sealed.  The
tape should be sturdy to resist incidental contact but able to break when the cap/lid is removed.

6.6     Chain of Custody Form
The COC form should include any available information regarding the potential hazards associated with
the sample, handling procedures required for the samples, sample identification number, sample
concentration, if known, sampling location, sample date and time, sample matrix, names and signatures of
the samplers, and signatures of all individuals who had custody of the samples.  A COC form should
remain with the samples from collection to laboratory receipt.  If samples are split into two or more
shipping containers, copies of the COC form should be placed with each container and directly indicate
the contents.
A COC form creates an accurate written record that can be used to trace the creation, possession, and
handling of the sample from the moment it is collected through analysis. A COC form is used and
required, without exception, for the tracking and recording of on-site or off-site sample collection,
transport and analysis. An example COC form is provided in Appendix G.  A COC form accompanies
each sample or group of samples as custody of the sample(s) is transferred from one custodian to another.
One copy of the form is retained by the original sample collector, and the original is obtained by the
receiving laboratory.  If multiple laboratories are receiving a sample, individual COC forms should be
submitted; each COC form represents the contents of the sample shipment.  Each laboratory or facility
representative who accepts an incoming sample shipment signs and dates the COC form. It is typically
the laboratory or facility's responsibility to maintain internal logbooks and custody records throughout
sample preparation and analysis. Sample custodians are typically responsible for initiating, maintaining,
and completing COC tracking. A sample custodian is the person responsible for the custody of a sample
or samples at a particular time, until custody is transferred to another person (and so documented), who
then becomes the new custodian. A sample is under a person's custody if:

•   It is in that person's possession,
•   It is in that person's view, after being in that person's physical possession,
•   It was in that person's physical possession and then he/she locked it up to prevent tampering, or
•   It was in that person's physical possession and then he/she placed it in a designated and identified
    secure area.
Handling of COC forms during sample transportation depends on the method of transport.  If the
laboratory is within driving distance, the sample containers can be couriered to the laboratory.  In this
case, then the courier should sign off on the COC.  It is important to note that common commercial
carriers will not usually accept responsibility for handling and completing COC forms. This  often
necessitates packing the  COC form in the shipping container (enclosed with other documentation in a

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
plastic zipper-type bag).  As long as COC forms are sealed inside the shipping or transport container and
the container's custody seals are intact, commercial carriers are not required to sign the COC form.  Using
a computer and the Web, the tracking information generated by a common carrier can be obtained if
complete COC tracking is required. This documentation is attached to the COC form to show that the
sample container was in the possession of the carrier during the missing COC time. This time period
should be noted as "common carrier" on the COC form between the final custodian at the sample site
location and laboratory receipt.

Although COC forms vary in style, format, and detail, the forms should contain the same minimal
information required to identify the sample. Procedures for filling out other styles of COC forms will be
very similar. It is best for the samplers to fill out the COC form provided by the party receiving the
samples. The COC form provided in Appendix G assumes that the samplers do not know what analyses
to request for the sample.  Sample screening can influence the strategy used for sample  analysis.
The following information should be provided and the following steps should be followed to complete
COC forms:

•   General incident information (sample owners, contact information, site name)
•   Sample specific information for each sample that will be traveling in the same cooler/transport
    container (i.e., sample identification number, sample type [matrix], grab or composite, number and
    type of sample containers, and date  and time sample was collected)
•   Sign, date, and enter the time under "Relinquished by" entry. Have the person receiving the sample
    sign the "Received by" entry. If shipping samples by a common carrier, print the carrier to be used in
    this space (e.g., Federal Express, UPS).
•   If a common carrier is used, a copy  of the airbill is to be kept for recording purposes by both the
    sender and recipient.
•   Place the original signed copy of the COC form in a plastic zipper-type bag or other appropriate
    waterproof sample shipping package. Retain a copy with the field records.
•   Complete carrier-required shipping  papers.
•   If possible, fax or scan and email a copy of the COC  form and field report to the party receiving the
    samples.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 7.0  Sample Collection Procedures
Samples containing suspected biological, chemical, and radiochemical contaminants are generally
collected by grab sampling. Grab samples for biological analyses (suspected and unknown contaminants)
should be collected when water samples are expected to contain sufficiently high levels of a
contaminant(s) for analysis and/or the presence of particulates (turbidity) precludes field concentration of
the sample. If the contaminant or contaminant class is unknown, it may be necessary to provide the
analytical laboratory with a complete set of samples for biological, chemical, and radiochemical analyses
(see Tables 7-1 to 7-3).  This requires anywhere from 125 mLto more than 100 liters of sample for the
biological analyses and almost 20 liters of sample for the chemical and radiochemical analyses. Because
biological contaminants present in water systems are likely to be dilute, large volumes of sample are often
needed.  In these cases, samplers  should either collect large volumes of water for concentration in the
laboratory or be prepared to concentrate large sample volumes on site.

7.1    Equipment for Biological (Pathogen and Toxin) Sampling
The following materials should be used to collect grab samples (125 mL - 10 L) from water that may
contain high levels of biological contaminants and/or particulates (e.g., wastewater, brackish water, etc.).
•   Sterile plastic bottles (125-mL,  1-L) with lids or sterile cubitainers (10-L)
•   Sampling pole (aluminum pole  with clamp to hold sampling bottle)
•   Gallon-sized, self-sealing bags
•   Cooler
•   Chlorine test kit (Fischer Scientific 15-398-398 or equivalent)
•   Disinfectant reducing agent (sodium thiosulfate solution, 10% w/v, sterile)
•   pH meter or pH indicator paper (see Table 5-1)
•   Turbidity meter
•   Thermometer
•   Pump and pump tubing

7.2    Equipment for Chemical and Radiochemical Sampling
The following materials should be used to collect grab samples (125 mL - 10 L) from water that may
contain high levels of chemical or radiochemical  commandants and/or particulates (e.g. wastewater,
brackish water, etc.):
•   Certified clean sample containers
•   Graduated cylinder
•   Stop watch
•   Paper towels
•   Storage bags for contaminated garbage/PPE
•   Transporting container with ice and proper labels
•   Sealing tape
•   PPE (including clean, disposable nitrile gloves)
•   Individually wrapped disposable bleach wipes
•   Potable water (to flush any materials from skin, eyes or other surfaces that have come into contact
    with contaminated water)
•   Tools to open taps or other sample locations
•   Sampling pole (i.e., a pole attached to a sample container)
•   Extra bottles for dipping
•   Depth sampling devices
•   pH meter or pH indicator paper (see Table 5-1)
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7.3    Example of Sampling Procedures

The following are examples of common utility sampling locations, and some of the basic nuances to
sampling these locations.
Sampling from Accessible Water Taps: Remove the aerator, if present; aeration would remove VOCs
from the sample. Maintain a steady flow of water until the water temperature is constant, and then hold
the sample container under the discharge at an angle so that the sample flows down the inside wall of the
sample container. This also minimizes aeration. Fill the container(s) to the fill line (if present) or to the
top of the container lip.
Sampling from Fire Hydrants: Remove the small cap from the low-pressure side of the hydrant, adjust
the flow down to a manageable level for sample collection, and collect the sample as if from a tap.
Sampling from Water Towers: Allow the water to run for at least 20 to 30 minutes to clear the
plumbing leading to the sample port before sampling. If there is no sampling port, then a pump should be
used. Lower the pump into the water reservoir to depth(s) prescribed by the routine sampling plan or by
the person in charge of the investigation.

Sampling from Underground Tanks or Reservoirs: If there is a sampling port, allow the water to run
for at least 20 to 30 minutes, and then collect the sample.  If there is no sampling port, use a
decontaminated submersible pump and set the flow on the pump to about 500 mL/min; then collect the
water samples for analysis.

7.4    General Sample Collection Guidance
When collecting samples, it is important to take many aspects of the collection process into consideration.
The following sections provide additional guidance that may be helpful to the collection of samples:

•  Drinking water samples to be analyzed for radiochemicals, volatile organics, metals, nitrogen, and
   cyanides require pH adjustment or other chemical preservation. Preservation should be performed
   immediately upon collection of the sample for each analysis. Sample containers  with appropriate
   preservatives may be obtained from the analytical laboratory or other supplier. When it is necessary
   to perform a sample pH adjustment, the acid or base will first be added to a separate and equal
   volume of water collected from the same sample location. This separate sample will be tested with
   either pH paper or a pH meter to determine how much acid or base needs to be added.  The separate
   sample volume can now be disposed of. Then the same amount of acid or base will be added to the
   investigative sample that will be  sent to the laboratory.  This sample will not be tested for pH, so there
   is no risk that the pH testing imparts contamination to the sample.

•  The sample locations should be clean of all debris and attachments such as hoses or clamps, which
   should be removed to allow for proper collection.

•  Proper PPE (e.g., outer gloves) should be worn and changed prior to each sample collection point to
   reduce potential carry-over contamination.

•  The sampler should have all required sample containers and preservatives at the sample location prior
   to sampling.

7.5    Grab Sampling  Procedures for Biological, Chemical, and Radiochemical
       Contaminants
The following guidance should be considered whenever sampling for biological, chemical, and/or
radiochemical contaminants is performed:

•  Determine the exact sampling point (including depth if necessary) and obtain proper sampling
   equipment.  Depth collection requires discrete sampling equipment, such as a peristaltic pump or an
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
    adjustable-rate, positive displacement submersible pump, that can be used to suction water from a
    desired depth.
Note: A peristaltic pump cannot be used if samples need to be drawn from depths greater than 25-30
vertical feet.

•   When sampling from a tap, remove the aerator or screen from the tap.

•   Purge the sample point prior to collection if practical. The amount of purge water necessary varies
    depending on the sample location (immediate valved location vs. potential static location). The
    purged water should be collected in containers, labeled, and stored until the analytical data is
    assessed.

•   Adjust the flow from the tap to about a % inch diameter flow (i.e., the stream width should resemble
    the width of a pencil). Fill the containers directly from the tap.

•   If the sample is being collected from a non-tap location such as an open pit or stream, a clean  1-L
    glass container should be used to dip the sample and fill the sample containers.  If a sample is  to be
    collected at a specified depth, a "weighted bottle sampler" can be used to submerge a bottle to the
    correct depth and open it to sample at the desired location with the pull of a trigger.

•   If applicable, preservation is added to each sample container without touching the sample or container
    to reduce cross contamination. Do not mix sample preservatives, as these chemicals are not
    compatible and may rapidly increase temperature,  spontaneously produce toxic fumes, and/or cause
    additional hazards, and/or compromise sample integrity and analytical objectives.

•   Open the sample container, being careful not to contaminate the inside of the cap, the inside of the
    bottle, or the bottle threads.

•   Fill the sample containers to % inch from the top and cap the bottles unless otherwise indicated (e.g.,
    volatiles and carbamate pesticide samples).

•   Wipe off the entire exterior of the container.

•   Record the sample identification number, date and time of sample collection, sample location, and
    any other pertinent information on the sample label with a permanent marker and complete
    appropriate sample documentation form(s).

•   Ensure that the appropriate sample label(s) is permanently or securely affixed to each sample
    container.  It is often easier to fill out the labels and attach them to the containers before mobilizing to
    the field. Do not populate the  date and time until sampling has occurred, as the date and time  should
    be entered on the container label in the field.  After labeling is complete, the label should be covered
    with clear tape so that the fresh ink will not wash off or smear.

•   Complete all sample documentation and shipping forms (see Section 6.0) and pack the sample
    containers for shipment (Section 8.0).

•   Handle all PPE and waste as contaminated waste and place into a garbage bag or other secure  storage
    until the analytical data are assessed and proper disposal procedures are determined.

7.5.1   Volatile and Carbamate Pesticide Samples
The following additional guidance should be considered when collecting volatile and carbamate pesticide
samples:

•   Sample collection vials for volatiles should contain ascorbic acid (0.25-0.5 g) prior to the addition of
    the sample to act as a disinfectant reducing agent.  Sample collection vials for carbamate pesticides
    should contain sodium thiosulfate (-12.5  mg) prior to the addition of the sample to act as a
    disinfectant reducing agent.


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•   Sample vials should be completely filled so that the sample forms a convex meniscus at the top prior
    to pH adjustments. Hydrochloric acid is then added to the volatile sample vials (typically 5-7 drops)
    to adjust the final volume to a pH less than 2. Potassium dihydrogen citrate is added to the carbamate
    pesticide sample vials to adjust the final pHto 3.8.

•   When it is necessary to perform a sample pH adjustment, the amount of acid or base to be added to
    each sample container should be determined on a separate and equal volume of water collected from
    the same sample location prior to collecting the investigative sample (see first bullet of 7.4 for more
    detail).

•   Ensure the vial contains no head space.

7.5.2  Other Chemical Contaminant Samples

After a sample has been collected, preserved, capped, and inverted for mixing, the sample should be
checked to determine if pH adjustment is required. This is performed by pouring a small amount of
sample into the vial  or bottle and measuring the sample pH using the appropriate range (0-4, 6-10) pH
indicator (Table  5.1). If pH adjustment of the sample is appropriate (see Section 7.6) adjust by drop wise
addition of acid or base (as appropriate) to the sample, mix, and repeat pH measurement.  Appropriate
sample pH adjustments (amount of acid or base additive) should be determined on a separate and equal
volume of water collected from the same sample location prior to collecting and adjusting the pH of the
sample.

7.6    Biological (Pathogen and Toxin), Chemical, and  Radiochemical  Sample Container
and Preservative Guidelines

Tables 7.1 through 7.3, listed below, summarize typical specifications contained in the analytical methods
for collecting samples for each of the various contaminants described in this guidance. Listed methods
are taken from the RPTB, Module 4. When sampling for unknowns, the priority is to collect unpreserved
samples first.

Table 7-1. Biological (Pathogens and Toxins) Collection Guidelines
Contaminant
Class/Type
Biological
Fecal
coliforms, £.
CO//
Biological
(pathogens
and toxins)
Bacterial
Pathogens
Container
Volume and
Type
125mLto250
ml_, Plastic
10 to 100 L,
Plastic
1 to 2 L, Plastic
Sample
Concentration
Volume
None
250 to 500 ml_
(ultrafiltration)
2-4 mL
(membrane
filtration)
Disinfection
Reducing
Agent
Sodium
thiosulfate
(0.05% final)
Sodium
thiosulfate
(0.05% final)
Sodium
thiosulfate
(0.05% final)
Preservative
< 4°C + 2°C,
do not freeze
Sample
concentrate
< 10°C, do not
freeze
Sample
concentrate
< 10°C, do not
freeze
Holding Time
24 - 30 hours
TBD
TBD
Analytical Technique
(or Instrumentation)
Culture Methods
(multiple-tube
fermentation/
membrane filtration)
PCR and
immunoassay
PCR and
immunoassay
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Table 7-2. Chemical Collection Guidelines
Contaminant
Class/Type
Volatiles
(Methods
502.2, 8021 B,
524.2, 8260B)
Carbamate
Pesticides
(Methods
531.1, 531.2)
Unknown
organics
(volatile)
Metals/
Elements
(Methods
200.7, 200.8,
200.9)
Organometallic
compounds
Toxicity
Cyanide
(Methods
335.2, 335.3,
335.4)
Quaternary
nitrogen
compounds
(Method 549.2)
Semi-volatiles
(Methods
525.2,
8270D/3535A)
Unknown
organics
(general)
Container
Volume and
Type
40 ml_, Glass w/
Teflon faced
septa
40 ml_, Glass w/
Teflon faced
septa
40 ml_, Glass w/
Teflon faced
septa
125 ml_, Plastic
(i.e., HPDE)
125 ml_, Plastic
(i.e., HPDE)
125 ml_, Glass
1 L, Plastic
1 L, Amber PVC
or silanized
glass
1 L, Amber w/
Teflon-lined
screw caps
1 L, Amber
glass
No. of
Containers
5
4
5
2
2
2
2
4
4
4
Disinfection
Reducing
Agent
Ascorbic acid
(0.25-0.5 g)
Sodium
thiosulfate
(12.5mg)
None
None
None
Consult
manufacturer's
instructions
Ascorbic acid
(0.06 g)
Sodium
Thiosulfate
(100mg)
Sodium sulfite
(40 - 50 mg)
None
Preservative
1:1 HCLtopH
<2
stored <4°C
Potassium
dihydrogen
citrate; adjust
sample pH to
-3.8
stored <4°C
None - mark
samples not
preserved
stored <4°C
Trace metal
grade nitric
acid to pH <2
Nitric acid to
PH<2
Consult
manufacturer's
instructions
Sodium
hydroxide to
pH> 12
stored <4°C
Sulfuric acid to
PH<2
stored <4°C
BMHCIto
PH<2
stored <4°C
None - mark
samples not
preserved
stored <4°C
Holding Time
14 days
28 days
7 days
6 months
30 days
Consult
manufacturer's
instructions
14 days
14 Days
7 days to
extraction,
28 days to
analysis
7 days to
extraction,
28 days to
analysis
Analytical
Technique
P&T - GC/MS
P&T - GC/PID/ELCD
HPLC-fluorescence
P&T - GC/MS
ICP-MS
ICP-AES
AA
AA- cold vapor
manual
AA- cold vapor
automated
Rapid toxicity assay
(several vendors)
Titrimetric
Spectrophotometric
SPEHPLC-UV
SPE GC/MS
Prep: SPE, SPME,
micro LLE, direct
aqueous injection,
headspace
Analysis: GC/MS,
GC, HPLC, LC-MS
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
Contaminant
Class/Type
Unknown
inorganics
Water quality:
Chemistry
Container
Volume and
Type
1 L, Plastic
1 L, Plastic or
Glass
No. of
Containers
2
1
Disinfection
Reducing
Agent
None
None
Preservative
None - mark
samples not
preserved
None - mark
samples not
preserved
Holding Time
28 days
Immediate to
14 days
Analytical
Technique
ICP-MS
Conductivity, pH,
alkalinity, hardness,
turbidity
Preservation is recommended at the time of collection for metals; however, samples should be preserved
in the laboratory within 2 weeks of collection.

When mass spectrometry methods are used during a response event, the utility should request that the
laboratory report all tentatively identified compounds.  This may result in the initial identification of the
contaminant, even if it is not calibrated.

Table 7-3. Radiochemical Collection Guidelines
Contaminant
Class/Type
Radiochemical
Container
Volume and
Type
1, 5-L
cubitainer or
4, 1-L plastic
containers
Number of
Containers
2
Disinfection
Reducing
Agent
None
Preservative
Trace metal
grade nitric
acid to pH <2
Holding
Time
6 months
Analytical Technique
(or Instrumentation)
Gross alpha, gross
beta, gamma isotopes,
specific radionuclides
The analytical method and any applicable state requirements are both factors in determining the
preservation method to use for samples intended for radiochemical analyses. Preservatives for
radiochemicals can be added at the analytical laboratory within 5 days of collection, but the analysis
cannot begin until 16 hours after acidification.  This practice is not encouraged, as it delays the analysis
time by as much as 16 hours.  If the laboratory agrees to add the preservative, then no preservative is
needed for the sample.

7.7    Biological Sample  Concentration Procedures

For some sampling methods, it is necessary to concentrate the sample before testing.  The following are
two methods for concentrating samples so that a contaminant may be detected.

7.7.1  Ultrafiltration Procedure

The difficulty of confirming the presence/absence of a biological contaminant in a water source is that a
biological warfare agent can be very dilute in a large amount of water and yet still be dangerous.  A large
sample volume is required to thoroughly analyze the sample for biological agents. Large volumes of
water are concentrated prior to analysis using an ultrafiltration device that concentrates viruses, bacteria,
toxins, and protozoa. Ultrafiltration devices will concentrate more than 10 to 100 liters of water and
result in a 250-mL concentrated sample. Ultrafiltration is typically performed by a laboratory in the LRN.
Certification and training is generally needed to complete these procedures,  and additional guidance for
this process can be  obtained from the CDC or a local LRN laboratory.

7.7.2  Membrane Filtration

The use of membrane filtration for the concentration and subsequent analysis of bacterial contaminants
for baseline and triggered monitoring may provide an alternate sampling approach for targeted monitoring
of these agents. Slight modifications of conventional membrane filtration-culture techniques have been
used to recover bacteria from the membrane for subsequent analysis by polymerase chain reaction (PCR)-
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
based and/or immunoassay techniques. This procedure may be used in situations where the identity of the
contaminant is suspected to be of bacterial origin and/or the concentration of the bacterial contaminant is
suspected to be relatively low.
The following procedure describes the recommended process for filtration of a drinking water sample and
the subsequent recovery of bacterial contaminants from the membrane filter:

    •  Drinking water (1-2 L) is collected using the sample collection procedures in Section 7.5 in a
       suitable container. Reduce the disinfectant using sodium thiosulfate.

    •  The sample is filtered using a commercially available, sterile, disposable filtration assembly
       containing a 47 or 90 mm diameter, 0.45 micron pore size, mixed cellulose ester membrane filter.

    •  Following sample filtration, the membrane filter is removed from the filtration assembly and
       placed in a sterile, disposable polystyrene centrifuge tube  (15 mL or 50 mL) containing 2-4 mL
       of a phosphate buffer saline (PBS), usually containing surfactant (0.05 %).

    •  The tube containing the sample filter is capped and subjected to vigorous mixing using a vortex
       mixer to wash bacteria from the filter.

    •  The filter is removed and discarded, and the filter eluate, containing bacteria (or protozoa), is
       processed for analysis by PCR or immunoassay.

    •  The concentrated sample (2-4 mL) represents a 250- to 1,000-fold concentration of the original
       drinking water sample.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 8.0 Sample Packaging and Shipment

This section describes recommended procedures for properly packaging and shipping environmental or
drinking water samples collected from a sampling site.  These procedures should be performed after all
samples have been collected and placed in the proper containers, and if necessary, sealed in containment
bags. Biohazards should be communicated through labeling and biohazards signs. Where biologically
active substances and wastes are used, handled or stored, sampling personnel should use the universal
biohazard symbol. The decision to use hazard warning labels should depend on the level of risk
associated with the respective incident as assessed by the utility management and should be used at their
discretion (e.g., how likely is this incident to be a false alarm; are there any warnings indicating that
biological contaminants are present?).
The following information provides guidelines for proper packaging, labeling and shipping of sample
containers.  Additional information and applicability can be obtained from common carriers' Hazardous
Material Center hotlines.

8.1    Packaging - Low Hazard Samples

Samples defined as "Low Hazard" should be packaged and shipped as follows:

•   Samples requiring cooling preservation should be placed in a cooler/overpack with ice immediately to
    ensure the sample temperature does not exceed preservation requirements until analysis is performed.
    Note: Shipping containers should be sealed shut.

•   Each sample bottle should be securely wrapped with bubble-wrap.

•   A picnic type  cooler or overpack can be used as a shipping container.  Only hard plastic, impact
    resistant coolers in good condition should be used.  In preparation for shipping samples, if present, the
    drain plug should be taped shut from the inside and outside, and a large, new, clean plastic bag should
    be used as a liner for the cooler.

•   Sample containers should be placed upright and can be sealed in individual plastic water-tight
    scalable bags in the lined cooler in such a way that they do not touch and will not touch during
    shipment. Place bubble-wrap, or other suitable material that will retain its integrity if it gets wet,
    between each sample bag to take up any void  space and to prevent the containers from touching.
    Place a temperature blank, if needed, in close proximity to the samples.

•   As required, chemically preserved samples  should be shipped to the laboratory on ice and chilled to
    4°C.  Some methods require chilling only to 6°C.  The most common temperature to preserve
    biological samples is 10°C, but this may vary  slightly by method.  Place ice inside a double layer of
    water-tight scalable bags. Place the bagged ice around, among, and on top of the sample bottles to
    assure samples will arrive at the laboratory  or screening facility at 4°C or less. The liner bag should
    then be secured with a twist-tie or knot.

•   The paperwork (e.g., original copy of COC form) going to the laboratory should be placed inside a
    plastic bag. The bag should be sealed and taped to the inside of the cooler lid. The last block of the
    COC form should indicate the overnight carrier and the associated air bill number.  A copy of the
    COC form should be retained with the project document files.  The air bill should be filled out before
    the samples are handed over to the carrier.

•   The cooler should be closed and taped shut with strapping tape (filament-type) by running the tape
    around both ends of the cooler at least two times.

•   At least two signed custody seals should be placed on the cooler, one on the front and one on the side,
    to maintain the integrity of the sample custody process.

•   A copy of the COC form and the air bill should be faxed or scanned and emailed to the receiving
    laboratory to assist in tracking of potentially misrouted coolers.

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
8.2    Shipping - Low Hazard Samples

When the cooler is handed over to an overnight carrier, a standard air bill is necessary for environmental
samples.  The air bill is affixed to the top of the cooler and should contain both the shipped-from and
ship-to address. The shipper's copy of the air bill should be retained with project document files as
evidence. The laboratory or receiving facility will document the common carrier information upon
receipt. However, if the laboratory is within driving distance, the coolers can be sent via courier to the
laboratory, and the courier would sign off on the COC form.

8.3    Hazardous Sample Packaging and Shipment

Hazardous samples require additional packaging and shipping guidance due to their possible adverse
health effects.  The following precautions should be followed when shipping these samples.  The
following subsections 8.3.1 through 8.3.4 are purely informational for utility personnel. These activities
should be performed by a HazMat unit.

8.3.1  Packaging for Biological Samples

Packing requirements and procedures for biological samples have been developed by the CDC to
facilitate safe shipment of the samples to LRN laboratories.  In summary, "triple" (primary receptacle,
water tight secondary packaging, and durable outer packaging) packaging is required for a biological
agent of human disease or materials that are known or suspected of containing them.  This packaging
requires the "Infectious Substance" label on the outside of the package.

8.3.2  Packaging for Chemical Samples

If the sample has a known hazardous component, it should be packaged and shipped in accordance with
any applicable regulations (e.g., 49 CFR 173.24 and 173.24a).  The type of container, correct labeling,
proper naming of the hazardous material, proper labeling and transportation type are required.
Samples containing high  levels of contamination should be shipped as Environmental Hazardous, Class 9
or by the proper shipping name of the contaminant.  The package may consist of one  or more receptacles,
absorbent materials and devices for cooling or absorbing mechanical shocks.  The conveyance, tie-down
system, and auxiliary equipment may sometimes be designated as part of the packaging. Trained
hazardous materials responders should make the selection of the most appropriate packaging for the
specific hazard. Transporters should be contacted prior to an event to ensure authorized transportation
can be  made if required.  Transporters typically have a license to transport Hazardous Materials.

8.3.3  Packaging for Radiochemical Samples

In the case of a triggered  sampling event, radioactive materials should be packaged in accordance with
any applicable regulations (e.g., as a class 7 material regulated by 49 CFR  173.401-173.476). The type
of packaging is typically  dependent on the nature of the radioactive hazard (specific radionuclide and
amount of radioactivity),  and the selection of the most appropriate packaging for the specific radioactive
hazard should be made by trained hazardous materials responders.

8.3.4  Shipping

The decision to use hazard warning labels should depend on the level of risk associated with the
respective incident, and whether any evidence  suggests the presence of these hazard classes, as assessed
by the utility management, and should be used at their discretion. All containers and  outside containers
should contain labeling corresponding to the particular hazard class as follows:

•   Class 1 Explosives
•   Class 2 Flammable and Nonflammable Gas
•   Class 3 Flammable Liquid
•   Class 4 Solids

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
•   Class 5 Oxidizers and Organic Peroxides
•   Class 6 Poison
•   Class 7 Radioactive
•   Class 8 Corrosives
•   Class 9 Miscellaneous

Labeling requirements for sample and shipping containers for U.S. Department of Transportation (DOT)
Hazardous Materials are described in 49 CFR 172.400.  Most HazMat teams licensed to transport
hazardous materials have additional requirements for labeling packages.  These may include such things
as:

•   Shipper's address
•   Recipient's address
•   Proper shipping name as designated by DOT
•   The sample description

Most small businesses use a commercial transporter to ship hazardous waste.  These transporters can give
advice on specific requirements for placarding, labeling, marking, and packaging; however, the sample
owner remains responsible for compliance. For guidance on DOT regulations (49 CFR Parts 172 and
173), call the DOT hazardous materials information line at (202) 366-4488.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 9.0 Consequence  Management

The Public Health Security and Bioterrorism Preparedness and Response Act of 2002, commonly known
as the Bioterrorism Act, P.L. 107-188, amended the Safe Drinking Water Act of 1974 (SDWA, P.L. 93-
523), which was amended in 1996 (P.L. 104-182) and which is codified at 42 U.S.C.  Sec. 300f et seq., by
adding, among other requirements, requirements for community water systems serving populations
greater than 3,300 to conduct a vulnerability assessment (VA) and either prepare or revise an Emergency
Response Plan (ERP) that incorporates the results of its VA. The ERP must include "plans, procedures,
and identification of equipment that can be implemented or utilized in the event of a terrorist or other
intentional attack" on the community water system (42 U.S.C. 300i-2(b); SDWA 81433(b)). The ERP
also must include "actions, procedures, and identification of equipment which can obviate or significantly
lessen the  impact of terrorist attacks or other intentional actions on the public health and the safety and
supply of drinking water provided to communities and individuals" (42 U.S.C. 300i-2(b); SDWA
81433 (b)). For more information on the requirements for an ERP or VA, please see the following EPA
guidance documents:

•   Emergency Response Plan Guidance for Small and Medium Community Water Systems to Comply
    with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002  (USEPA,
    2004)
•   Large  Water  System Emergency Response Plan Outline: Guidance to Assist Community Water
    Systems in Complying with the Public Health Security and Bioterrorism Preparedness and Response
    Act of 2002 (USEPA, 2003)
The Water Security Initiative-Contamination Warning System (WS-CWS) is a response to HSPD 9,
which directed EPA to demonstrate an effective system for timely detection and appropriate response to
drinking water contamination incidents that would have broad application to the nation's drinking water
utilities. The Consequence Management Plan (CMP) is a key element of the WS-CWS, and describes the
actions that the given utility should take upon notification of a "possible" contamination incident, as
determined through investigation of an alarm generated by one of the WS-CWS monitoring and
surveillance components: online water quality monitoring, sampling and analysis, enhanced security
monitoring, consumer complaint surveillance, and public health surveillance.
EPA has worked  with a pilot utility to develop a pilot CMP that can be used as a resource for other
utilities that are in the process of creating or revising their own consequence management protocols. The
final CMP created by a utility should provide a decision-making framework that governs when, how,
what, and  who will be involved in making decisions in response to contamination threat warnings to
minimize the response timeline and implement operational or public health response actions
appropriately.  The CMP should also include SOPs that address field sampling and analysis protocols for
rapidly characterizing the nature of a contamination incident.
Utilities may want to request a copy of the pilot CMP and its appendices drafted for the pilot study taking
place at the Greater Cincinnati Water Works (GCWW). It may provide an example of how the guidance
in this document  can be integrated into other utilities' CMPs. The RPTB should also  be referenced as it
served as a technical reference for the Contaminant Warning System consequence management protocol.
Consequence management refers to the process and procedures for implementing response actions that
are initiated upon detection of a "possible" contamination event and continues through restoration and
remediation of the system. An initial trigger indicating possible contamination could come from single or
multiple monitoring and surveillance information streams. Indication of possible contamination will
prompt the water utility to conduct follow-up actions such as site characterization, triggered sampling and
analysis for unknown contaminants, notifications, and precautionary actions, to reduce consequences
should the event be later determined credible or confirmed. As information from the  initial response
actions and/or additional detection information is collected from or coordinated with the water utility,
additional  response actions should be considered and implemented as the event is assessed for credibility.
This process of continuous information collection followed by assessment and action should be

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                  Sampling Guidance for Unknown Contaminants in Drinking Water
performed by the water utility and their local offices of state and federal governments. The CMP can
provide the decision logic guidance designed to:  mitigate the consequences, provide internal and external
notifications, coordinate additional resources for response and analysis, and help manage all related
emergency response requirements associated with the specifics of the incident.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
 Section 10.0  References

DOT. Additional general requirements for non-bulk packagings and packages. 49 CFR 173.24a. Revised
as of October 1, 2005. http://edocket.access.gpo.gov/cfr_2007/octqtr/49cfrl73.24a.htm.
DOT. Class 7 (Radioactive) Materials. 49 CFR 173.401-173.476. Revised as of October 1, 2005.
http://www.access.gpo.gov/nara/cfr/waisidx  05/49cfrl73 05.html
DOT. Class 9 - Definitions. 49 CFR 173.140. Revised as of October 1, 2005.
http://edocket.access.gpo.gov/cfr_2005/octqtr/49cfrl73.140.htm
DOT. General labeling requirements. 49 CFR 172.400. Revised as of October 1, 2005.
http://edocket.access.gpo.gov/cfr_2005/octqtr/49cfrl72.400.htm
DOT. General requirements for packagings and packages. 49 CFR 173.24. Revised as of October 1,
2005. http://edocket.access.gpo.gov/cfr_2005/octqtr/49cfrl73.24.htm
DOT. Purpose and use of hazardous materials table. 49 CFR 172.101. Revised as of October 1, 2005.
http://edocket.access.gpo.gov/cfr_2005/octqtr/49cfrl72.101 .htm
OSF£A. Hazardous waste operations and emergency response. 29 CFR 1910.120. Revised as of July 1,
2006. http://edocket.access.gpo.gov/cfr 2006/iulqtr/29cfrl910.120.htm
OSF£A, Safety and Health Topics: Confined spaces. Content Reviewed November 3, 2008,
http://www.osha.gov/SLTC/confinedspaces/index.html
OSHA, Permit-required confined spaces, 29 CFR 1910.146, Revised as of July 1, 2006,
http://edocket.access.gpo.gov/cfr 2006/julqtr/29cfrl910.146.htm
OSHA. Hazardous waste operations and emergency response. 29 CFR 1926.65. Revised as of July 1,
2006. http://edocket.access.gpo.gov/cfr 2006/julqtr/29cfrl926.65.htm
U.S. Congress. Public Health Security and Bioterrorism Preparedness and Response Act of 2002. PL
107-188. June 2002. http://frwebgate.access.gpo.gov/cgi-
bin/getdoc.cgi?dbname=107cong_publiclaws&docid=f:publ 188.107.pdf
U.S. Congress. Safe Drinking Water Act as ammended. 42 U.S.C. Chapter 6A, Subchapter XII,  §300f et
seq. In Effect as of January 2003.
http://www.access.gpo.gov/uscode/title42/chapter6a  subchapterxii.html
USEPA. Emergency Response Plan Guidance for Small and Medium Community Water Systems to
Comply with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, April
2004. http://www.epa.gov/safewater/watersecurity/pubs/small_medium_ERP_guidance040704.pdf
USEPA, Environmental Laboratory Compendium, On-Line Database.
httDs://cfint.rtpnc.epa.gov/cetl/lblogin.cfm?action=None&CFID=22136&CFTOKEN=67039796&isessio
nid=2830cf8a51bl2fl6256fTR
USEPA. Large Water System Emergency Response Plan Outline: Guidance to Assist Community Water
Systems in Complying with the Public Health Security and Bioterrorism Preparedness and Response Act
of 2002, July 2003. http://www.epa.gov/safewater/watersecuritv/pubs/erp-long-outline.pdf
USEPA. Response Protocol Toolbox: Planning for and Responding to Drinking Water Contamination
Threats and Incidents, Module 3: Site Characterization and Sampling Guide, December 2003. Interim
Final, http://cfpub.epa.gov/safewater/watersecuritv/home.cfm7program id=8#response toolbox
USEPA, Response Protocol Toolbox: Planning for and Responding to Drinking Water Contamination
Threats and Incidents, Module 4: Analytical Guide, December 2003. Interim Final.
http://cfbub.epa.gov/safewater/watersecuritv/home.cfm7program  id=8#response toolbox
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                Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix A - Acronyms and Other Abbreviations




% w/v        Percent weight over volume




AA          Atomic absorption




ACS         American Chemical Society




CDC         Centers for Disease Control and Prevention




CN"          Cyanide




CO          Carbon monoxide




COC         Chain of custody




CFR         Code of Federal Regulations




CMI         Consult manufacturer's instructions




CT          Chemiluminescence toxicity




DRA         Disinfectant reducing agent




DOT         U.S. Department of Transportation




ELCD        Electrolytic conductivity detector




EPA         Environmental Protection Agency




ERP         Emergency response plan




ETV         Environmental Technology Verification




g            Gram




GC          Gas chromatograph




GC/MS       Gas chromatography/mass spectrometry or gas chromatograph/mass spectrometer




G-M         Geiger-Mueller




GPS         Global positioning system




H2S          Hydrogen sulfide




HASP        Health and safety plan




HAZCAT     Hazardous characterization




HazMat       Hazardous materials
HAZWOPER  Hazardous Waste Operations and Emergency Response




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HC1          Hydrochloric acid




HDPE        High density polyethylene




HMT         Hazardous materials table




HNO3         Nitric acid




HPLC        High performance liquid chromatography




HSPD 9       Homeland Security Presidential Directive 9




H2SO4        Sulfuric acid




ICP-AES      Inductively coupled plasma atomic emission spectroscopy




ICP-MS       Inductively coupled plasma mass spectrometry




L             Liter




LC-MS        Liquid chromatography-mass spectrometry




LLE          Liquid-liquid extraction




LRN          Laboratory Response Network




M            Molar




mg           Milligrams




mg/L         Milligrams per liter




mL           Milliliters




mm          Millimeters




MS/MSD      Matrix spike/matrix spike duplicate




N/A          Not applicable




NaOH        Sodium  hydroxide




O2            Oxygen




OP           Organophosphate




ORP          Oxygen reduction potential




OSC          On-scene coordinator (EPA or other federal agency)




OSHA        Occupational Safety and Health Administration




P             Preservative
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
P&T          Purge and trap




PCR          Polymerase chain reaction




PBS          Phosphate buffer saline




PID          Photoionization detector




P.L.          Public Law




ppb           Parts per billion




PPE          Personal protective equipment




PVC          Polyvinyl chloride




QA           Quality assurance




QC           Quality control




RPTB         Response Protocol Toolbox




SDWA        Safe Drinking Water Act




SCBA         Self contained breathing apparatus




SOP          Standard operating procedure




SPE          Solid-phase extraction




SPME         Solid-phase microextraction




SVOC         Semi-volatile organic compound




TBD          To be determined




TTEP         Technology Testing Evaluation Program




UN/NA       United Nations/North American Hazardous Materials Code




U.S.C.         United States Code




UV           Ultraviolet




VA           Vulnerability assessment




VOC          Volatile organic compound
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                   Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix B - Glossary

Composite Sample - a sample composed of several specific aliquot collected at various sample locations
and/or different points in time, which are then combined to form one composite sample.

"Confirmed" - in the context of the threat evaluation process, a water contamination incident is
"confirmed" if the information collected over the course of the threat evaluation provides definitive
evidence that the water has been contaminated.

Contamination Site  - the location where a contaminant is known or suspected to have been introduced
into a drinking water system. For example, a distribution system storage tank where a security breach has
occurred may be designated as a suspected contamination site. The contamination site will likely be
designated as an investigation site for the purpose of site characterization.

Core Field Testing - analysis performed at the investigation site for radiation, cyanide, residual chlorine,
and pH. Core field testing  is performed as part of site characterization and is composed of two elements,
field safety screen and rapid field testing.

"Credible" - in the context of the threat evaluation process, a water contamination threat is characterized
as "credible" if information collected during the threat evaluation process corroborates information from
the threat warning.

Emergency Response Plan - a document that describes the actions that a drinking water utility would take
in response to various emergencies, disasters, and other unexpected incidents.

Expanded Field Testing - analysis of water at the site of a suspected contamination incident for
parameters beyond those covered under core field testing (e.g., VOCs, chemical weapons, toxins, etc).

Field Safety Screening  - screening performed to detect any environmental hazards (e.g., in the air or on
surfaces) that might pose a threat to the site characterization team. Monitoring for radioactivity as the
team approaches the site is an example of field safety screening.

Grab Sample - a single sample collected at a particular time and place that represents the composition of
the water, air, or soil only  at that time and location.

Infectious Substance - a material known to contain, or reasonably expected to contain, a pathogen.

Investigation Site - the  location where site characterization activities are performed. If a suspected
contamination site has been identified, it will likely be designated as a primary investigation site.
Additional or secondary investigation sites may also be identified due to the potential spread of a
contaminant.

Pathogen - an infectious microbial organism that is capable of causing disease.

Personal protective equipment (PPE) - equipment and supplies designed to protect employees from
serious injuries or diseases resulting from contact with chemical, radiochemical, biological, or other
hazards. PPE includes face shields, safety glasses, goggles, laboratory coats, gloves, and respirators.
Additional requirements can be determined after a site specific review for potential contaminants or other
safety requirements.

"Possible" - in the context of the threat evaluation process, a water contamination threat is characterized
as "possible" if the circumstances of the threat warning appear to have provided an opportunity for
contamination.

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                   Sampling Guidance for Unknown Contaminants in Drinking Water
Quality Assurance - an integrated system of management activities involving planning, implementation,
documentation, assessment, reporting, and quality improvement to ensure that a process, item, or service
is of the type and quality needed and expected by the client.

Quality Control - the overall system of technical activities that measures the attributes and performance of
a process, item, or service against defined standards to verify that they meet the stated requirements
established by the client; operational techniques and activities that are used to fulfill requirements for
quality.

Rapid Field Testing - analysis of water during site characterization using  rapid field water testing
technology in an attempt to tentatively identify contaminants or unusual water quality.

Responder - Person or Persons who initially act upon an emergency scene. First responders are typically
internal trained personnel, police or fire fighters. These people are generally trained in OSF£A First
Response.

Site Characterization - the process of collecting information  from an investigation site to support the
evaluation of a drinking water contamination threat. Site characterization activities include the site
investigation, field safety screening, rapid field testing of the water, and sample collection.

Site Perimeter - the boundary of the protective action zone at the site of a suspected contamination
incident.

Transporter - person or company who assumes custody of samples between packing and receipt by a
certified laboratory. This person or company  should sign all  documentation or provide written
documentation of delivery to ensure that samples have not been tampered with.

Note: A cooler can be custody  sealed at the sampling site to provide evidence that it has not been opened
and the samples tampered with if a commercial carrier is used.

Ultrafiltration - a filtration process for water that uses a selective membrane to preferentially separate and
retain particles that are  larger than the membrane's molecular weight cut-off, typically greater than 30,000
Daltons.
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                Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix C - Example of a Generic Sampling Checklist

Note: this checklist is from the RPTB: Module 3 and has been changed to fit the purposes of this
document.
GENERAL INFORMATION
    Date: 	
     Time arrived at investigation site:
    Name of Site Characterization Team Leader:
    Phone No.:
                 Fax No.:
LOCATION OF INVESTIGATION SITE
    Site Name:  	
    Type of facility:
       D Distribution main
       D Elevated storage tank
       D Finished water reservoir
       D Treatment plant

    Address:    	
D Ground storage tank
D Hydrant
D Pump station
D Other
D  Sampling Tap
D  Service connection
D  Source water
    Weather Conditions at Site:
    Additional Site Information:
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APPROACH TO SITE
     Time of Approach to Site:
    Initial Field Safety Screening (as listed in the "Site Characterization Plan"):
       D Biological agents             D HAZCAT                 D Radiation
       D Chemical weapons            D None                     D Volatile chemicals
       D Other	

       Report results of field safety screening in "Field Testing Report Form."
       If any field safety screening result is above the corresponding reference value, immediately
       notify incident command and do not proceed further into the site.

    Initial Observation and Assessment of Immediate Hazards
       D Unauthorized individuals present at the site
       D Fire or other obvious hazard
       D Signs of a potential explosive hazard (e.g., devices with exposed wires)
       D Signs of a potential chemical hazard (e.g., dead animals, unusual fogs, unusual odors)
       D Unusual and unexplained equipment at the site
       D Other signs of immediate hazard 	

       If there are any indicators of immediate hazard, immediately notify incident command and do
       not proceed further into the site.

    Report initial observations and results to incident commander.
       Approval  granted to proceed further into the site?                    D Yes    D No

SITE INVESTIGATION
    Time of Entry to Site:  	
    Repeat Field Safety Screening
       D Biological agents             D HAZCAT                 D Radiation
       D Chemical weapons            D None                     D Volatile chemicals
       D Other	

       Report results of field safety screening in "Field Testing Report Form."
       If any field safety screening result is above the corresponding reference value, immediately
       notify incident command and do not proceed further into the site.
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                 Sampling Guidance for Unknown Contaminants in Drinking Water
    Signs of Hazard:
       D None
       D Unexplained dead or stressed vegetation
       D Unexplained liquids

       Describe signs of hazard:  	
               D Unexplained dead animals
               D Unexplained clouds or vapors
               D Other
    Unexplained or Unusual Odors:
       D Bitter almond
       D Irritating
       D None

       Describe unusual odor: 	
D New mown hay
D Pungent
D Skunky
D Sulfur
D Sweet/Fruity
D Other	
    Unusual Vehicles Found at the Site:
       D Car/sedan                    D  Flatbed truck
       D Construction vehicle          D  None
       D Other 	
                             D Pickup truck
                             D SUV
       Describe vehicles (including make/model/year/color, license plate #, and logos or markings):
    Signs of Tampering:
       D Cut locks/fences
       D Facility in disarray
       D Missing/damaged equipment
       D Other 	
               D  None
               D  Open/damaged access hatches
               D  Open/damaged gates, doors, or windows
       Signs of sequential intrusion (e.g., locks removed from a gate and hatch)?
       D Yes                                                      D No
       Describe signs of tampering:
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
    Unusual Equipment:
       D Discarded PPE (e.g., gloves, masks)
       D Hardware (e.g., valves, pipe)
       D Lab equipment (e.g., beakers, tubing)
       D Other 	
            D None
            D Pumping equipment
            D Tools (e.g., wrenches, bolt cutters)
       Describe equipment:
    Unusual Containers:
       Type of container:
          D Bottle/Jar
          D Box/Bin
          D Bulk container

       Condition of container:
          D Damaged/leaking
          D Intact/dry

       Size of container: 	
       Describe labeling on container:
D Drum/Barrel
D None
D Plastic bag
D New
D Old
 D  Pressurized cylinder
 D  Test Tube
 D  Other 	
 D  Opened
 D  Unopened
       Describe visible contents of container:
    Rapid Field Testing of the Water
       D Cyanide                     D
       D General toxicity              D
       D None                       D
       D Chlorine Residual   D Other
 Pesticides
 pH / conductivity
 Radiation
D Residual disinfectant
D Toxins
D VOCsandSVOCs
    Report results of rapid field testing of the water on the "Field Testing Report Form."
    If any field test result is above the corresponding reference value, immediately notify incident
    command and wait for instruction regarding how to proceed.
    Report findings of site investigation to incident commander.
       Approval granted to proceed with sample collection?
                                 D  Yes     D No
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
SAMPLING
     Time Sampling was Initiated / Completed:
    Implement Sampling Procedures Appropriate for the Hazard Conditions at the Site:
       D Biological hazard                          D Low hazard
       D Chemical hazard                           D Radioactive hazard
    If the site is characterized as a biological, chemical, or radioactive hazard, then special sampling
    and safety procedures should be followed.

    Safety Checklist:
       D Do not eat, drink, or smoke at the site.
       D Do not taste or smell the water samples.
       D Do use the general PPE included in the emergency water sampling kit.
       D Avoid all contact with the water, and flush immediately with clean water in the case of
           contact.
       D Slowly fill sample bottles to avoid volatilization and aerosolization.
       D Minimize the time that personnel are on site and collecting samples.

    General Sampling Guidelines:
       D Properly label each sample bottle.
       D Carefully flush sample taps prior to sample collection, if applicable.
       D Collect samples according to method requirements (e.g., without headspace for VOCs).
       D Add preservatives or disinfection reducing agents as specified.
       D Carefully close sample containers and verify that they do not leak.
       D Wipe the outside of sample containers with a mild bleach solution if there was any spillage.
       D Place sample containers into a scalable plastic bag.
       D Place samples into an appropriate, rigid shipping container.
       D Pack container with frozen ice packs.
       D Complete "Sampling Event Report Form".
       D Complete "Chain of Custody Form".
       D Secure shipping container with custody tape.
       D Comply with any other sample security provisions required by participating agencies.
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                  Sampling Guidance for Unknown Contaminants in Drinking Water
EXITING THE SITE
     Time of Site Exit:
     Site Exit Checklist
       D Verify that hatches, locks, etc., are properly secured.
       D Remove all samples, equipment, and materials from the site.
       D Verify that all samples are in the cooler and properly seal the cooler.
       D Remove all PPE at site perimeter.
       D Place disposable PPE and other trash into a heavy-duty plastic trash bag.
       D Verify that the perimeter has been properly secured before leaving the site.
       D Ensure that all documentation has been completed before leaving the site perimeter.
       D Comply with any site control measures required by participating agencies.
       D Contact incident commander and inform them that the team is leaving the site.
SIGNOFF
  Site Characterization Team Leader:

      Print name  	
      Signature   	   Date/Time:
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                           Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix D - Example of a Sampling Event Report Form
Sampling Event Report Form
Collection Information Date: Site Name:
Sample Owner and/or Collector: Signature:
Level of PPE Used:
Weather Conditions:

Additional Agencies Involved: Agency Contact Information:
Signature of Agency Representative(s):
Site and Sample Description
Sample ID









Sample Location Time Sam
(vol









Matrix: DW = Drinking Water, RW = Reservoir Water, UW=Untreated Water, SD = Sediment, SL = Sludge, SO
pie Amount Sample Type
unie or weight) (Matrix)









= Soil, SM = Misc. Solid Material
Incident Details
Describe the number of people exposed and the types of symptoms they are experiencing:
General conditions of exposed flora and fauna (if available):
Describe the event and reason for sample collection:
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                            Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix E - Example of a Field Testing Report Form
Field Testing Report Form
Date of Testing: Site Name: Field Tester: Contact Information:
Sample ID


















Parameter


















Units


















Screen


















Meter/Kit
ID


















Testing Location


















Time


















Results


















Reference
Value


















Comments/Additional Information:
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                                  Sampling Guidance for Unknown Contaminants in Drinking Water
FINAL-110308                                                                                                           60

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                Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix F - Example of a Photograph Log
                             Example Photograph Log
  Sample Identification Number and Location:
                                      Photographer
  Camera:
Video
                       Digital
                     Nondigital
IfNondigital:
Film Type
                         Film Roll Number
         Photo #
         Date and Time
                    Location/Description
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FINAL-110308                                                                         62

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                                 Sampling Guidance for Unknown Contaminants in Drinking Water
Appendix G - Example of a Chain of Custody Form
                                                Chain of Custody Form
Site Name:
                                                  Sample Owner/Collector:
Contact Information:
                                                  Signature
Sample ID
Collection
Date/Time (24 h)
Sample Location
Sample Type
(Matrix)
Grab/
Composite
Preservative(s)
No./Type
of Bottles
Comments
Matrix: DW = Drinking Water, RW = Reservoir Water, UW=Untreated Water, SD = Sediment, SL = Sludge, SO = Soil, SM = Misc. Solid Material
Relinquished By:	  Received by:                                Date/Time:
Relinquished By:
                              Received by:
                                                        Date/Time:
Relinquished By:
                              Received by:
                                                        Date/Time:
Relinquished By:
                              Received by:
                                                        Date/Time:
Relinquished By:
                              Received by:
                                                        Date/Time:
Dispatched by:
                   Date/Time:
                                   Received by:
                                     Date/Time
Method of Sample Transport
Shipper:
                        Phone No.
                                                 Tracking No.
Attach additional pages as required.
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