&EPA
   United States
   Environmental Protection
   Agency
Response Protocol Toolbox:
Planning for and Responding to
Drinking Water Contamination
Threats and Incidents

Interim Final - December 2003

Module 3:
Site Characterization and Sampling Guide

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              Response Protocol Tool box:
             Planning for and Responding to
  Drinking Water Contamination Threats and Incidents

Module 3: Site Characterization and Sampling Guide

                    Interm Final - December 2003
                    PLANNING AND PREPARATION
                         Threat Warning
                      Initial Threat Evaluation
                       Immediate Operational
                        Response Actions
                      Site Characterization and
                           Sampling
                      Public Health Response
                           Actions
                         Sample Analysis
                           Is Incident
                          Confirmed?
                     Remediation and Recovery

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      OTHER RESPONSE PROTOCOL TOOLBOX MODULES

Module 1: Water Utility Planning Guide (December 2003)
Module 1 provides a brief discussion of the nature of the contamination threat to the
public water supply.  The module also describes the planning activities that a utility
may undertake to prepare for response to contamination threats and incidents.

Module 2: Contamination Threat Management Guide (December 2003)
Module 2 presents the overarching framework for management of contamination
threats to the drinking water supply.  The threat management process involves two
parallel and interrelated activities: 1) evaluating the threat, and 2) making decisions
regarding appropriate actions to take in response to the threat.

Module 3: Site Characterization and Sampling Guide  (December 2003)
Module 3 describes the site characterization process in which information is gathered
from the site of a suspected contamination incident at a drinking water system.  Site
characterization activities include the site investigation, field safety screening, rapid
field testing of the water, and sample collection.

Module 4: Analytical Guide (December 2003)
Module 4 presents an approach to the analysis of samples  collected from the site of a
suspected contamination incident.  The purpose of the Analytical Guide is not to
provide a detailed protocol. Rather, it describes a framework for developing an
approach for the analysis of water samples that may contain an unknown contaminant.
The framework is flexible and will allow the approach to be crafted based on the
requirements of the specific situation. The framework is also designed to promote the
effective  and defensible performance of laboratory analysis.

Module 5: Public Health Response Guide (available March 2004)
Module 5 deals with the public health response measures that would potentially be
used to minimize public exposure to potentially contaminated water.  It discusses the
important issue of who is responsible for making the decision to initiate public health
response  actions, and considers the role of the water utility in this decision process.
Specifically, it examines the role of the utility during a public health response action,
as well as the interaction among the utility, the drinking water primacy agency, the
public health community, and other parties with a public health mission.

Module 6: Remediation and Recovery Guide (available March 2004)
Module 6 describes the planning and implementation of remediation and recovery
activities that would be necessary following a confirmed contamination incident.  The
remediation process involves a sequence of activities, including: system
characterization;  selection of remedy options; provision of an alternate drinking water
supply during remediation activities; and monitoring to demonstrate that the system
has been  remediated.  Module 6 describes the types of organizations that would likely
be involved in this stage of a response,  and the utility's role  during remediation and
recovery.
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                                  MODULE 3: Site Characterization and Sampling Guide


                             TABLE OF CONTENTS


1   INTRODUCTION	11

2   OVERVIEW OF SITE CHARACTERIZATION PROCESS	13

  2.1    PROCESS OVERVIEW	13
  2.2    ROLES AND RESPONSIBILITIES	16

3   PLANNING FOR SITE CHARACTERIZATION	18

  3.1    SAFETY AND PERSONNEL PROTECTION	18
  3.2    SAMPLE COLLECTION KITS AND FIELD TEST KITS	20
    3.2.1   SAMPLE COLLECTION KITS	20
    3.2.2   FIELD TEST KITS	27
  3.3    GENERIC SITE CHARACTERIZATION PLAN	30
  3.4    EVALUATION OF BASELINE WATER QUALITY INFORMATION	31
    3.4.1   GENERAL WATER QUALITY PARAMETERS	31
    3.4.2   BACKGROUND LEVELS OF SPECIFIC CONTAMINANTS	32
  3.5    QUALITY ASSURANCE FOR FIELD TESTING AND SAMPLING	34
  3.6    MAINTAINING CRIME SCENE INTEGRITY	34

4   SITE CHARACTERIZATION PROTOCOL	36

  4.1    CUSTOMIZING THE SITE CHARACTERIZATION PLAN	36
    4.1.1   INITIAL EVALUATION	36
    4.1.2   IDENTIFICATION OF INVESTIGATION SITE	37
    4.1.3   SITE HAZARD ASSESSMENT	39
    4.1.4   SAMPLING APPROACH	41
    4.1.5   FORMATION OF A SITE CHARACTERIZATION TEAM	44
    4.1.6   EXAMPLES OF SITE CHARACTERIZATION PLAN CUSTOMIZATION	45
  4.2    APPROACHING THE SITE	50
    4.2.1   ESTABLISH SITE ZONES	50
    4.2.2   FIELD SAFETY SCREENING	50
    4.2.3   INITIAL OBSERVATION OF SITE CONDITIONS	50
  4.3    CHARACTERIZING THE SITE	52
    4.3.1   EVALUATION OF SITE CONDITIONS	53
    4.3.2   RAPID FIELD  TESTING	53
  4.4    COLLECTING SAMPLES	54
    4.4.1   GENERAL SAMPLING PROCEDURES	54
    4.4.2   CHEMICAL SAMPLING PROCEDURES	56
    4.4.3   MICROBIOLOGICAL SAMPLING PROCEDURES	57
  4.5    EXITING THE SITE	60

5   SITE CHARACTERIZATION REPORT	62

6   SAMPLE PACKAGING AND TRANSPORT	64

  6.1    LOW HAZARD SAMPLES	65
    6.1.1   PACKAGING	65
    6.1.2   TRANSPORT	65
  6.2    HIGH HAZARD SAMPLES	66
    6.2.1   PACKING	66
    6.2.2   TRANSPORT	68

7   REFERENCES AND RESOURCES	69

8   APPENDICES	71
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  8.1    SITE CHARACTERIZATION PLAN TEMPLATE	71
  8.2    SITE CHARACTERIZATION REPORT FORM	75
  8.3    FIELD TESTING RESULTS FORM	81
  8.4    SAMPLE DOCUMENTATION FORM	82
  8.5    CHAIN OF CUSTODY FORM	83

LIST OF TABLES

TABLE 3 -1: EXAMPLE DESIGN OF AN EMERGENCY WATER SAMPLE COLLECTION KIT	21
TABLE 3-2: SAMPLES OF CONTAINERS FOR EMERGENCY WATER SAMPLE COLLECTION KIT	22
TABLE 3-3: CORE AND EXPANDED FIELD TEST KITS	28
TABLE 3-4: CHARACTERISTICS OF EXAMPLE CHEMICAL CONTAMINANTS	52

LIST OF FIGURES

FIGURE 3-1: OVERVIEW OF THE SITE CHARACTERIZATION PROCESS	14
FIGURE 3-2: INTEGRATION OF SITE HAZARD ASSESSMENT INTO SITE CHARACTERIZATION
          PROCESS	40
FIGURE 3-3: INTEGRATION OF SITE HAZARD ASSESSMENT INTO THE SAMPLING APPROACH	43
FIGURE 3-4: SAMPLING APPROACH FOR MICROBIAL CONTAMINANTS	57
FIGURE 3-5: ULTRAFILTRATION FIELD CONCENTRATION APPARATUS	59
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                                   ACRONYMS

AWWARF   American Water Works Association Research Foundation
CDC         Centers for Disease Control and Prevention
CHRIS       Chemical Hazards Response Information System
ERP         Emergency response plan
ETV         Environmental Technology Verification
FBI          Federal Bureau of Investigation
FEMA       Federal Emergency Management Agency
FRP         Federal Response Plan
HazMat      Hazardous materials
HOPE       High density polyethylene
ISAC        Information Sharing and Analysis Center
LRN         Laboratory Response Network
MWCO      Molecular weight cut-off
OSC         On scene coordinator
PPE         Personal protective equipment
psi           Pounds per square inch
QA          Quality assurance
QC          Quality control
SCADA      Supervisory control and data acquisition
SDWA       Safe Drinking Water Act
SVOC       Semi-volatile organic chemical
TOC         Total organic carbon
URL         Uniform resource locator
US EPA      United States Environmental Protection Agency
USGS       U.S. Geological Survey
UV          Ultraviolet
VOC         Volatile organic chemical
WCIT       Water contaminant information tool
WUERM     Water utility emergency  response manager
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                                     GLOSSARY

Definitions in this glossary are specific to the Response Protocol Tool Box but conform to
common usage as much as possible.

Analytical Approach - a plan describing the specific analyses that are performed on the
samples collected in the event of a water contamination threat. The analytical approach is based
on the specific information available about a contamination threat.

Analytically Confirmed - in the context of the analytical approach., a contaminant is
considered to be analytically confirmed if it has undergone analytical confirmation, as defined
herein.

Analytical Confirmation - the process of determining an analyte in a defensible manner.

Causative Agent - the pathogen, chemical, or other substance that is the cause of disease or
death in an individual.

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.

Drinking Water Primacy Agency - the agency that has primary enforcement responsibility for
national drinking water regulations, namely the Safe Drinking Water Act as amended.  Drinking
water primacy for a particular state may reside in one of a variety of agencies, such as  health
departments, environmental quality departments, etc. The drinking water primacy agency is
typically the State Health Agency or the State Environmental  Agency.  The drinking water
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primacy agency may also play the role of technical assistance provider to drinking water
utilities.

Emergency Operations Center - a pre-designated facility established by an agency or
jurisdiction to coordinate the overall agency or jurisdictional response and support to an
emergency.

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,
biotoxins, 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.

Field Sample Concentrate - the term used for the retentate  from the ultrafiltration device used
for sampling/concentration of unknown microbial contaminants.

Filtrate - in ultrafiltration, the water that passes through the  membrane and which contains no
particles smaller than the molecular weight cutoff of the membrane.

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.

Hazard Assessment - the process of evaluating available information about the site for identify
potential hazards that might pose a risk to the site characterization team.  The hazard assessment
results in assigning one of four levels to risk: low hazard, radiological hazard, high chemical
hazard, or high biological hazard.

Immediate  Operational Response - an action taken in response to a 'possible' contamination
threat in an attempt to minimize the potential for exposure to the potentially contaminated water.
Immediate operational response actions will generally have a negligible impact on consumers.

Incident Commander - the individual responsible for the management of all incident
operations.

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.
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Personal protective equipment (PPE) - equipment and supplies designed to protect employees
from serious injuries or diseasees resulting from contact with chemical, radiological, biological,
or other hazards. PPE includes face shields, safety glasses, goggles, laboratory coats, gloves, and
respirators.

'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.

Protective Action Zone - at the site of a hazardous materials incident, this is the zone that is
potentially dangerous to life and health, and specialized PPE is required to enter and perform
work in this zone. This zone may also be referred to as the exclusion zone.

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.

Response Guidelines - a manual designed to be used during the response to a water
contamination threat. Response Guidelines should be easy to use and contain forms, flow charts,
and simple instructions to support staff in the field or decision officials in the Emergency
Operations Center during management of a crisis.

Retentate - in ultrafiltration, the retentate is the solution that contains the particles that do not
pass through the membrane filter. The retentate is also called the concentrate.

Secure Area - a locked space, such as a cabinet or vault, with access restricted to authorized
personnel.

Site Characterization - the process of collecting information from an investigation site in order
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 Characterization Plan - a brief document that summarizes the activities that will occur
during the characterization of an investigation site.  The plan may be generic in that it covers the
general scope of activities, or customized to describe the activities that will occur at a specific
investigation site in response to a specific threat warning.
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 Site Characterization Team - the individual or group that is responsible for the implementation
 of all site characterization activities, including: the site investigation, field safety screening, rapid
field testing of the water, and sample collection. A site characterization team benefits from
 expertise in the areas of water quality, security, and operations. Under hazardous conditions,
 individuals with expertise in responding to hazardous sites should be part of the team.

 Site Characterization Team Leader - the individual or group that is responsible for the
 coordinating the site characterization activities in the field and ensuring that incident command
 remains informed as those activities progress.

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

 Staging Area - location  set up outside of the protective action zone at the site of a suspected
 contamination incident where resources can be placed while awaiting assignment and other
 operations such as personnel decontamination can be  safely performed.

 Technical Assistance Provider - any organization or individual that provides assistance to
 drinking water utilities in meeting their mission to provide an adequate and safe supply of water
 to their customers.  The drinking water primacy agency may  serve as a technical assistance
 provider.

 Tentative Identification - the contaminant identity is hypothesized based on available
 information from the site characterization report. Examples of situations in which tentative
 identification might occur include: a specific contaminant named in a threat; tentatively positive
 results for a specific contaminant during field safety screening or rapid field testing; physical
 evidence at the site pointing to a specific contaminant; and clinical evidence of the identity of the
 disease-causing agent.

 Threat - an indication that a harmful incident, such as contamination of the drinking water
 supply, may have occurred.  The threat may be direct, such as a verbal or written threat, or
 circumstantial, such as a  security breach or unusual water quality.

 Threat Evaluation - part of the threat management process in which all available and relevant
 information about the threat is evaluated to  determine if the threat is 'possible' or 'credible', or if
 a contamination incident has been 'confirmed.'  This is an iterative process in which the threat
 evaluation is revised as additional information becomes available.  The conclusions from the
 threat evaluation are considered when making response decisions.

 Threat Management - the process of evaluating a contamination threat and making decisions
 about appropriate response actions.  The threat management process includes the parallel
 activities of the threat evaluation and making response decisions. The threat management
 process is considered in three stages: 'possible', 'credible', and 'confirmatory.'  The severity of
 the threat and the magnitude of the response decisions escalate as a threat progresses through
 these stages.
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Threat Warning - an unusual occurrence, observation, or discovery that indicates a potential
contamination incident and initiates actions to address this concern.

Ultrafiltration - a filtration process for water that uses membranes to preferentially separate
very small particles that are larger than the membrane's molecular weight cut-off, typically
greater than 10,000 Daltons.

Water Contamination Incident - a situation in which a contaminant has been successfully
introduced into the system. A water contamination incident may or may not be preceded by a
water contamination threat.

Water Contamination Threat - a situation in which the introduction of a contaminant into the
water system is threatened, claimed, or suggested by evidence.  Compare water contamination
threat with water contamination incident.  Note that tampering with a water system is a crime
under the Safe Drinking Water Act as amended by the Bioterrorism Act.

Water Utility Emergency Response Manager (WUERM) - the individual(s) within the
drinking water utility management structure that has the responsibility and authority for
managing certain aspects of the utility's response to an emergency (e.g., a contamination threat)
particularly during the initial stages of the response. The responsibilities and authority of the
WUERM are defined by utility management and will likely vary based on the circumstances of a
specific utility.
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                                      MODULE 3: Site Characterization and Sampling Guide
1   Introduction
Site characterization is defined as the process of collecting information from an investigation
site in order to support the evaluation of a drinking water contamination threat.  Site
characterization activities include the site evaluation, field safety screening, rapid field testing of
the water, and sample collection. The investigation site is the focus of site characterization
activities, and if a suspected contamination site has been identified, it will likely be designated as
the primary investigation site.  Additional or secondary investigation sites may be identified due
to the potential  spread of a suspected contaminant. The results of site characterization are of
critical importance to the threat evaluation process described in Module 2.  Module 3 describes
procedures and protocols for implementing site characterization activities, which should be
adapted to a user's specific needs and objectives rather than interpreted as prescriptive
guidelines.

There are two broad phases of site characterization: planning and implementation.  The incident
commander is responsible for planning, while the site characterization team is responsible for
implementing the site characterization plan.  This module  is intended as a resource for those
involved in either the planning or implementation phases of site characterization.  While the
target audience is primarily drinking water utility managers and staff, other organizations may be
involved in site characterization activities.  Thus, this module may be useful to first responders
(e.g., police and fire departments), HazMat responders, law enforcement (e.g., FBI and EPA
criminal investigators), Civil Support Teams, and environmental response teams from EPA or
other government agencies.

This module, like the entirety of the "Response Protocol Toolbox," was  developed as a planning
tool. Individuals involved in planning or implementing site characterization activities  are
encouraged to review this module in its entirety, as well as the other modules in the "Response
Protocol Toolbox," to obtain a more comprehensive understanding of the threat management
process.  The objectives of Module 3 are to:
      Describe planning and implementation of site characterization activities in response to a
       water contamination threat.
      Describe procedures for the site evaluation, field safety screening, rapid field testing,
       sample collection, and sample transport.

This module is organized into eight sections as described below.

       Section  1:     Introduction:  Describes the objectives and overall organization of this
                     module.

       Section 2:     Overview of Site Characterization Process:  Summarizes the process of
                     site characterization, including planning, conducting  on-site activities,
                     sample collection and  sample shipping to a laboratory for analysis.
                     Detailed information is presented in subsequent sections.
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Section 3:     Planning for Site Characterization:  Describes planning and preparation
              necessary for the safe and effective implementation of site characterization
              activities.

Section 4:     Site Characterization Protocol:  Describes the activities performed under
              each of the five stages of site characterization: customizing the site
              characterization plan, approaching the site, characterizing the site, sample
              collection, and exiting the site.

Section 5:     Site Characterization Report: Describes how information from site
              characterization activities can be documented in order to evaluate the
              credibility of a threat and make decisions regarding appropriate response
              actions.

Section 6:     Sample Packing and Transport:  Describes how samples should be
              packaged and transported to an analytical laboratory for analysis  or
              archiving.

Section 7:     References and Resources: Lists the references cited in this module and
              additional information resources.

SectionS:     Appendices: Provides forms that support this module, which can be used
              to develop a utility's site-specific Response Guidelines.
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2   Overview of Site Characterization  Process

2.1   Process Overview
Figure 3-1 is a flow chart illustrating the site characterization process, and serves as a roadmap to
the rest of the document. The site characterization process is considered in five stages:
   1.  Customizing the Site Characterization Plan. A site characterization plan is developed for
       a specific threat (possibly from a generic site characterization plan) and guides the team
       during site characterization activities (Section 4.1).
   2.  Approaching the Site. Before entering the site, an initial assessment of site conditions
       and potential hazards is conducted at the site perimeter (Section 4.2).
   3.  Characterizing the Site.  The customized site characterization plan is implemented by
       conducting a detailed site investigation and rapid testing of the water (Section 4.3).
   4.  Collecting Samples. Water samples are collected in the event that laboratory analysis is
       required (Section 4.4).
   5.  Exiting the Site.  Following completion of site characterization, the site is secured and
       personnel  exit the site and undergo any necessary decontamination (Section 4.5).

These five stages  are shown in the center of Figure 3-1. Various activities that may be
performed during each of these stages are shown on the right side of the figure.

While site characterization can be considered and implemented as a discrete process, it is
important to regard it as an element of the threat evaluation process, as discussed in Module 2.
In particular, site characterization is an activity initiated in response to a 'possible' contamination
threat in order to gather information to help determine whether or not the threat is 'credible.'
This is graphically depicted in Figure 3-1 in which the threat evaluation process is represented
the large arrow on the left with linkages to the site characterization process at key points.
Initially,  information from the threat evaluation supports the development of the  customized site
characterization plan. As this plan is implemented, the observations and results from  site
characterization feed into the threat evaluation. In turn, the revised threat evaluation may
indicate that the threat is 'credible,' 'not credible,' or that the site characterization plan needs to
be revised in the field to collect more information in order to make this determination.  Because
threat evaluation and site characterization are interdependent, the incident commander must be in
constant communication with the site characterization team while they are performing their
tasks.

The first step is to develop a customized site characterization plan, which is based on the specific
circumstances of the threat warning. This customized plan may be adapted from a generic site
characterization plan, which is developed as part of a utility's preparation for responding to
contamination threats. The site characterization team will use the customized plan as the basis
for their activities at the investigation site.  After an initial evaluation of available information, it
is necessary to identify an investigation site where site characterization activities will be
conducted. During the development of the customized plan, it is important to conduct an initial
assessment of site hazards, which is critical to the safety of the site characterization team and
may  impact the makeup  of the team. If there are obvious signs of hazards at the site, then teams
trained in hazardous materials safety and handling techniques, such as HazMat, may need to
conduct an initial  hazard assessment at the site and either "clear" the site for entry by utility
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personnel, or the HazMat team may decide to perform all site characterization activities
themselves. Obvious signs of hazards would provide a basis for determining that a threat is
'credible.' Furthermore, the site might be considered a crime scene if there are obvious signs of
hazards, and law enforcement may take over the site investigation.
          Initial threat
          evaluation
           Threat is
           'possible'
              NO
       Place samples in
        secure storage
 Customize the Site
Characterization Plan
    (Section 4.1)
                             Approaching the Site
                                 (Section 4.2)
                             Characterize the Site
                                 (Section 4.3)
                                Collect Sample
                                 (Section 4.4)
                                Exiting the Site
                                 (Section 4.5)
                             YES-
 Ship samples to lab
     (Section 6)
                                 Initial evaluation
                                   (Section 4.1.1)
                                                          Identify investigation site
                                                               (Section 4.1.2)
 Characterize site hazards
	(Section 4.1.3)	
                                                         Develop sampling approach
                                                        	(Section 4.1.4)	
                                                       Form site characterization team
                                                                (Section 4.1.5)	
                                                        Conduct field safety screening
                                                               (Section 4.2.2)
                            Observe site conditions and
                             determine signs of hazard
                           	(Section 4.2.3)	
                                                        Repeat field safety screening
                                                               (Section 4.2.2)
                            Investigate site and evaluate
                                     hazards
                           	(Section 4.3.1)	
                                                         Conduct field water testing
                                                               (Section 4.3.2)
       Figure 3-1. Overview of the Site Characterization Process
                                         14
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Upon arrival at the site perimeter', the team first conducts field safety screening and observes site
conditions. The purpose of field safety screening activities is to identify potential environmental
hazards that might pose  a risk to the site characterization team. The specific field safety
screening performed should be identified in the site characterization plan, and might include
screens for radioactivity and volatile organic chemicals (VOCs).  If the team detects signs of
hazard, they should stop their investigation and immediately contact the incident commander to
report their findings.

If no immediate hazards are identified during approach to the site, the incident commander will
likely approve the team to enter the site and perform the site characterization.  During this stage,
the team will continue field safety screeningat the site,  conduct a detailed site  investigation, and
perform rapid field testing of the water that is suspected of being contaminated.

Rapid field testing has three objectives: 1) provide additional information to support the threat
evaluation process; 2) provide tentative identification of contaminants that would need to be
confirmed later by laboratory  testing; and 3) determine if hazards tentatively identified in the
water require special handling precautions.  The specific rapid field testing performed should be
identified in the site characterization plan, and might include tests for chlorine residual and
cyanide for example. Specific field testing performed should be based on the  circumstances of
the specific threat and should  consider the training, experience and resources of the site
characterization team. Negative field test results are not a reason to forgo water sampling (see
below), since field testing is limited in scope and can result in false negatives.

Following rapid field testing,  samples of the potentially contaminated water will be collected for
potential laboratory analysis.  The decision to send samples to a laboratory for analysis should be
based on the outcome of the threat evaluation (Figure 3-1). If the threat is determined to be
'credible,' then samples should be immediately delivered to the laboratory for analysis per the
guidance in Section 6. The analytical approach for samples collected from the site should be
developed with input from the supporting laboratory(ies), based on information  from the site
characterization and threat evaluation (see Module 4 for guidance on developing an analytical
approach).  On the other hand, if the threat is determined to be 'not credible,' then samples
should be secured and stored for a predetermined period in the event that it becomes necessary to
analyze the samples at a later time.

At this point, response actions may be implemented to  protect public health, as discussed in
Module 2.  However, if the threat is determined to be "not credible," then samples may be
collected, preserved and stored in the event that it becomes necessary to analyze them later.
Sample preservation is discussed below.

Upon completion of site characterization activities, the team should prepare to exit the site. At
this stage, the team should make sure that they have documented their findings,  collect all
equipment and samples, and re-secure the site (e.g., lock doors, hatches and gates).  If the site is
considered to be a potential hazardous site or crime scene, there may be additional steps involved
in exiting the site.
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2.2   Roles and Responsibilities
The incident commander and the site characterization team leader are key personnel in site
characterization.  As discussed in Module 1, Section 4.4, the incident commander has overall
responsibility for managing the response to the threat, and is responsible for planning and
directing site characterization activities.  The incident commander may also approve the site
characterization team to proceed with their activities at key decision points in the process (e.g.,
whether or not to enter the site following the approach).

The site characterization team leader is responsible for implementing the site characterization
plan in the field and supervising site characterization personnel.  The site characterization team
leader must coordinate and communicate with the incident commander during site
characterization.

Depending on the nature of the contamination threat, other agencies and organizations may be
involved or otherwise assume some responsibility during planning and implementation of site
characterization activities. Various organizations that may be involved in site characterization
are described below, with their potential roles and responsibilities.  The incident commander has
ultimate responsibility for determining the scope of the site characterization activities and the
team makeup.  Federal roles and responsibilities are dictated by the Federal Response Plan
(FRP), which is described in Module 1, Appendix 6.2.

   Water Utility - The water utility will be responsible for incident command(the water utility
   emergency response manager (WUERM) would be designated as the incident commander),
   unless another organization is designated.  As incident commander, the WUERM would be
   responsible for planning  and coordinating site characterization  activities. Regardless of the
   organization responsible for incident command, the utility will  be involved in site
   characterization activities.  An employee of the water utility may be designated as the site
   characterization team leader. In cases where that responsibility is designated to another
   agency (e.g., HazMat), utility staff should be included on the site characterization team or as
   technical advisors to the team.

   HazMat - Specialized response teams, such as HazMat, may assume responsibility  for
   oversight of site characterization activities in situations where hazardous materials are
   suspected.  In some situations, the HazMat team may limit their activities to characterization
   of site hazards and "clearing" the site for entry by utility personnel. The HazMat team may
   also elect to perform all site characterization activities with guidance from utility staff. The
   WUERM should understand how and under what circumstances HazMat teams might
   support site characterization activities.

   Technical Assistance Providers - Other agencies, such as the drinking water primacy
   agency, US EPA hazardous material responders, or other specially trained response  teams
   may assume responsibility for planning, oversight, and implementation of site
   characterization activities.  Furthermore, this may provide the only means of performing site
   characterization for smaller utilities with limited resources.  However, even at the smallest
   utility, the staff will at least need to play an advisory role during site characterization.
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   Laboratories - Laboratories will likely be responsible for the rapid analysis of samples
   collected by the site characterization team in response to a contamination threat. Thus, the
   laboratory(ies) should be engaged during both the hazard evaluation and site characterization
   activities if possible.  The laboratory may provide the utility with sample kits to ensure that
   the sample containers are properly prepared and preserved for the methods and techniques
   that the laboratory would use in their analytical  approach for unknown, or tentatively
   identified, contaminants in water samples. 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 be willing to send their staff to the
   site to assist with sample collection.

   Local Law Enforcement Agencies - A law enforcement agency may assume responsibility
   for incident command in situations where criminal activity, excluding federal crimes, is
   suspected.  In this case, law enforcement would likely manage the site in order to maintain
   the integrity of the crime scene while they proceed with their investigation.  Local law
   enforcement and the utility should work together so that site characterization activities  can be
   performed to determine if the threat is 'credible' or not, without compromising crime scene
   integrity.

   Federal Bureau of Investigation (FBI) - FBI will assume responsibility for incident
   command when a federal crime,  including terrorism, is suspected.  As with local law
   enforcement, the FBI will maintain control of the site, and the utility will need to work with
   the FBI in a technical support role during site characterization. If FBI becomes involved and
   assumes command of the situation, they will make the credibility determination. Under these
   circumstances, site characterization is not as critical for threat evaluation but may be critical
   for determining the identity of the contaminant and the extent of contamination.

The site characterization activities presented in this module range from relatively simple
activities, such as evaluating site conditions, to complex activities, such as field testing for
unusual contaminants.  The drinking water utility will need to decide in advance the extent of
site characterization capabilities that they will develop within their own organization and those
that would be provided by an external organization. For  example, a drinking water utility may
choose to develop a capability for performing the site evaluation and core field testing at low
hazard sites. The utility may make arrangements with HazMat responders to provide support
during the characterization of potentially hazardous site.  The utility may also arrange with the
contract lab to provide sample kits and sample containers. It is critical that the utility plan  for
those site characterization activities that they will take responsibility for,  and make arrangements
with agencies that will support the utility in the event that a situation exceeds the utility's
resources and capability.
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3   Planning for Site Characterization

This section describes the planning phase of site characterization and is divided into the
following five subsections:
       Section 3.1, Safety and Personnel Protection: Summarizes basic safety practices
       appropriate for site characterization activities under low hazard conditions.
       Section 3.2, Sample Collection and Field Test Kits: Presents example designs for sample
       collection kits and field test kits, including a detailed discussion of the content of each.
       Section 3.3, Generic Site Characterization Plan: Describes how to develop a generic site
       characterization plan that may be customized in response to a specific contamination
       threat.
       Section 3.4, Evaluation of Baseline Water Quality Information: Discusses the importance
       of baseline data during the interpretation of the results of field testing and sample
       analysis.
       Section 3.5, Quality Assurance for Field Testing and Sampling: Provides general
       guidance regarding quality assurance activities that may be appropriate during site
       characterization activities.
       Section 3.6, Maintaining Crime Scene Integrity: Provides general guidelines for
       maintaining crime scene integrity during site characterization activities.

Providing training of staff involved in site characterization and sampling activities is critical.
Responding to the site of a potential contamination incident is very different from routine
inspection and sampling activities performed by utility staff.  The equipment and safety
procedures used at the site of a potential contamination incident  may differ significantly from
those used during more typical field activities. Providing staff training in the procedures
presented in this module will help to ensure that they are properly and safely implemented during
emergency situations (Module 1, Section 4.7 provides additional discussion of training needs).
3.1   Safety and Personnel Protection
Proper safety practices are essential for minimizing risk to the site characterization team and
must be established prior to an incident in order to be effective. Field personnel involved in site
characterization activities should have appropriate safety training to conform to appropriate
regulations, such as OSHA 1910.120 (http://www.osha.gov), which deals with hazardous
substances. If planners and field personnel do not conclude that these regulations are applicable
to them, they may still wish to adopt some of the safety principles in these regulations.  The
following guidance is provided to help the user develop their own safety policies and practices.
These safety policies should be consistent with the equipment and capabilities of the site
characterization team and any applicable regulations.

The appropriate level of personal protection necessary to safely perform the site characterization
activities will depend on the assessment of site hazards that might pose a risk to the site
characterization team.  An initial site hazard assessment will be performed during the
development of a customized site characterization plan(see Section 4.1.3).  The hazard
assessment may be further refined during the approach to the site, based on the results of the
field safety screening and initial observation of site conditions. Two general scenarios  are
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considered, one in which there are no obvious signs of immediate hazards, and one in which
there are indicators of site hazards.

In most cases, the investigation site or suspected contamination site will not present a significant
hazard to the site characterization team, and basic equipment and training will be sufficient to
conduct site characterization activities safely.  Under these conditions, it is presumed that any
contaminants that might be present are confined to water and are present at dilute concentrations
where the risk to personnel can be minimized through the use of good safety practices, including:
       Do not eat, drink, or smoke at the site.
       Do not taste or smell the water samples.
       Do use general personal protective equipment (PPE) such as splash-proof goggles,
       disposable gloves, proper footwear (i.e., no open toe or open heel shoes), disposable shoe
       covers, a chemical resistant, disposable lab coat, and long pants.
       Avoid  all skin contact with the water, and if incidental contact does occur, immediately
       flush the affected area with clean water brought to the site for that purpose.
       Fill sampling containers slowly to avoid volatilization or aerosolization of contaminants.
       Minimize the time that personnel are on the site and collecting samples.

(Note that the PPE described above is only intended to minimize incidental contact with the
contaminated water or chemical reagents used during sample collection or field testing).

Basic good safety practices such as those listed above should be incorporated into a set of
concise safety  guidelines for personnel responsible for performing site characterization activities.
These guidelines may be formalized into a health and safety plan (HASP). Information on
HASPs is available at http://www.ertresponse.com/health  safety/index.htm, along with an
electronic expert system jointly developed by EPA and OSHA
(http://www.osha.gov/dts/osta/oshasoft/ehasp/) to help determine the  appropriate health and
safety hazards necessary for a particular situation.

In some cases, obvious signs of hazard may  be observed at the time the threat is discovered or
during the approach to the site, as described in Section 4.2.3. Under these conditions, only
personnel with proper equipment and training for response to hazardous situations should enter
the site and perform characterization activities, such as HazMat teams, EPA On Scene
Coordinators (OSCs) and their supporting contractors, or FBI hazardous materials response
teams.

Hazardous site conditions may also require the use of specialized sampling techniques in order to
manage the risk of incidental exposure during sampling, sample transport, or sample receipt at a
laboratory. Furthermore, it may be necessary to develop a site-specific safety plan for work
performed on the  site. If the specific hazards are known or suspected, such a site-specific plan
can be tailored to  those hazards, and appropriate personal protective equipment (PPE) for
specific chemical  contaminants can be found at the Chemical Hazards Response Information
System (CHRIS) at http://www.chrismanual.com.

While the absence of signs of hazards may indicate that there is minimal risk to the site
characterization team, it is not a certainty. There are risks associated  with any on-site activities,
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whether they are related to the threat of intentional contamination or not.  It is impossible to
eliminate all risks, but risk can be managed through planning, training, and the use of proper
techniques and procedures in the field.


3.2   Sample Collection Kits and Field Test Kits
Two types of kits are discussed in this section, sample collection kits and field test kits. Sample
collection kits will generally contain all sample containers, materials, supplies, and forms
necessary to perform sample collection activities. Field test kits contain the equipment and
supplies necessary to perform field safety screening and rapid field testing of the water. Sample
collection kits will generally be less expensive to construct than field test kits, and by
constructing these two types of kits separately, sample  collection kits can be pre-positioned
throughout a system while the more expensive field test kits may be assigned to specific site
characterization teams or personnel.

The design and construction of sample collection and field test kits is a planning activity, since
these kits must be ready to go at a moments notice in response to a 'possible' contamination
threat. In addition to improving the efficacy of the site characterization and sampling activities,
advanced preparation of sample collection and field test kits offers several advantages:
      Sample collection and field test kits can be standardized throughout an area to facilitate
       sharing of kits in the event of an emergency that requires  extensive sampling.
      Collection of a complete sample set is more likely to be achieved through the use of pre-
       designed kits.
      Sample collection kits can be pre-positioned at key locations to expedite the sampling
       process.
      Personnel responsible for site characterization can  become familiar with the content of
       the kits and trained in the use of any specialized equipment.

3.2.1  Sample Collection Kits
Table 3-1  presents an example of a sample collection kit, while Table 3-2 provides a detailed
listing of the sample containers included in the kit, and which are consistent with the analytical
protocols presented in Module 4. The sample collection kit includes:
      Large plastic  container for holding sample kit supplies
      Field resources and documentation
      General sampling supplies, including sample containers
      Pathogen sampling supplies
      Reagents
      Safety supplies

The sample collection kit described in this section is intended to illustrate the type of materials
and supplies that might be useful during  sampling activities; however, the design of a specific  kit
should be tailored to the needs and  sampling objectives of the user. Furthermore, other
organizations may need to be consulted in the design of a sample collection kit. For example,
the laboratory may wish to provide sample containers and  reagents that are consistent with the
analytical approach for water samples potentially containing non-target analytes.
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                                   MODULE 3: Site Characterization and Sampling Guide
Table 3-1. Example Design of an Emergency Water Sample Collection Kit
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
48
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
Collapsible cooler
Rigid shipping container
1 qt. zippered freezer bags
Thermometer
Paper towels
Table 3-2
1
4
3 rolls
N/A
1
1
1 pack 100
2
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
For checking water temperature
Wiping wet containers and containing spills
Pathogen Sampling Supplies
Tubing and clamp
Stopwatch & graduated cylinder
Ultrafiltration apparatus
1
1
1
For sample tap flushing, etc.
For measuring flow rate
For concentrating pathogen samples
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 (HC1)
6 Molar trace metal-grade nitric
acid (HNO3)
10 Normal Sodium hydroxide
(NaOH)
pH paper in ranges from 0-4 and
10- 14
5 liters
100 grams
100 grams
100 grams
100 grams
25mL
25mL
25mL
50 strips
For sample dilution in the field
For water sample dechlorination
For water sample dechlorination
For water sample dechlorination
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
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
Disposable laboratory coats
Clear, heavy duty plastic trash bags
Rinse water
Antiseptic wipes
Bleach solution (at least 5%)
Squirt bottle
First aid kit
Flashlight/headlamp
2
6 pairs
2 pairs
2
4
20 liters
1 container
1 gallon
2
1
3
One per individual (minimum)
Nitrile or polyethylene, powder-free
One pair per individual (minimum)
One per individual (minimum)
For disposal of lab coat, gloves, etc.
For general use and first aid
For cleaning hands, sample containers, etc.
For decontamination if necessary
For use with rinse water or lab grade water
For general first aid
For working at night or in dark locations
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Table 3-2. Samples Containers for Emergency Water Sample Collection Kit
Sample Type
Container Container
Size Type
No.
Dechlorinating
Agent
Preservative
Analytical
Technique
Reference
Methods
CHEMISTRY - BASIC SCREEN (Established Techniques)
Organic Analytes
Volatiles
Semi-volatiles
Quarternary
nitrogen
compounds
Carbamate
Pesticides
40mL
1L
1L
40mL
Glass w / Teflon
faced septa
Amber w /
Teflon-lined
screw caps
Amber PVC or
silanized glass
Glass w / Teflon
faced septa
5
4
4
4
Ascorbic acid
Sodium sulfite
Sodium
thiosulfate
Sodium
thiosulfate
l:lHCltopH<2
See method.
6MHC1. See
method.
Sulfuric acid to pH 2
Potassium
dihydrogen citrate
sample pHto -3.8
P&T-GC/MS
P&T-
GC/PID/ELCD
SPE GC/MS
SPE HPLC - UV
HPLC-fluorescence
EPA 524.2,
8260B
EPA 502.2,
8021B
525.2,
8270D/3535
549.2
531.2
Inorganic Analytes
Metals/Elements
Organometallic
compounds
Cyanide
Radiological
125 mL
125 mL
1L
2L
Plastic
(i.e. HPDE)
Plastic
(i.e. HPDE)
Plastic
Plastic
2
2
2
2
None
None
Ascorbic acid
None
Trace metal grade
nitric acid. See
method.
Nitric acid to pH <2.
See method.
Sodium hydroxide to
pH 12. See method.
None - mark samples
not preserved
ICP-MS
ICP-AES
AA
AA - cold vapor
manual
AA - cold vapor
automater
Titrimetric
Spectrophotometric
Colorimetric UV
Gross alpha, gross
beta, gamma
isotopes, specific
radionuclides
200.8
200.7
200.9
245.1
245.2
335.2
335.3
900 Series
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                               MODULE 3: Site Characterization and Sampling Guide
Sample Type
Container Container
Size Type
No.
Dechlorinating
Agent
Preservative
Analytical
Technique
Reference
Methods
CHEMISTRY - EXPANDED SCREEN (Exploratory Techniques)
Unknown organics
(volatile)
Unknown organics
(general)
Unknown
inorganics
Immunoassays
40mL
1L
1L
1L
Glass w / Teflon
faced septa
Amber Glass
Plastic
Amber Glass
5
4
2
2
None
None
None
Consult
manufacturers
instructions
None - mark samples
not preserved
None - mark samples
not preserved
None - mark samples
not preserved
Consult
manufacturers
instructions
P&T-GC/MS
Prep: SPE, SPME,
micro LLE, direct
aqueous injection,
headspace
Analysis: GC/MS,
GC, HPLC, LC-MS
ICP-MS
Consult
manufacturers
instructions
See Module 4
See Module 4
See Module 4
None
PATHOGENS - EXPANDED SCREEN (Established and Exploratory Techniques)
Pathogens - culture
Pathogens - PCR
lOOmL
lOOmL
HOPE (plastic)
HOPE (plastic)
2
2
Thiosulfate
Thiosulfate
TBD
TBD
Per target pathogens
Per target pathogens
See Module 4
See Module 4
BASELINE WATER QUALITY PARAMETERS (See Section 3.4)
Water quality:
bacteria
Water quality:
chemistry
Surrogates
Toxicity
250 mL
1L
1L
125 mL
Plastic
Plastic
Amber glass
Glass
1
1
2
2
Thiosulfate
None
None
Consult
manufacturers
instructions
None
None - mark samples
not preserved
None - mark samples
not preserved
Consult
manufacturers
instructions.
Fecal coliforms, E-
coli,
Conductivity, pH,
alkalinity, hardness,
turbidity
Total organic
carbon, ultraviolet
absorbance, color,
chlorine demand
Rapid toxicity assay
(several vendors)
Standard
methods
Standard
methods
Standard
methods
None
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The field resources and documentation listed in Table 3-1 includes field guides, forms, and labels
intended to support sampling activities.  The field guide is a resource containing simple flow-
charts, checklists, reporting forms, and concise summaries of field protocols to assist the team in
performing activities such as field testing and sampling. The guide also includes forms for
sample documentation and chain of custody (also see Appendices 8.4 and 8.5, respectively).  In
some cases, a HASP may be required, and may be generic or site-specific.

The sampling supplies listed in the table include sample containers as well as miscellaneous
glassware, and supplies used during sample collection.  Several clean 10-liter, high density
polyethylene (HDPE) containers, such as collapsible cubitainers, are included in the kit in the
event that large volume water samples need to be collected.  Other supplies such as tape,
spatulas, pipette bulbs, foil, etc., should be included based on experience with other sampling
activities.  A collapsible cooler can be used to keep samples chilled following collection until
they are transferred to a refrigerator, packed for shipment to a laboratory, or delivered to a
designated recipient.

Note that shipment to a remote laboratory via an overnight service will require a rigid shipping
container, such as a cooler; furthermore, certain hazardous samples may only be shipped in
approved containers, as discussed in Section 6.  If samples will be taken back to the utility prior
to shipment, then the rigid shipping container does not need to be included in the sample kit.
Frozen ice packs may be included with the sample kit to chill the samples, but a more practical
approach may be to fill sealable plastic freezer bags with ice and seal them in a manner to
prevent leaking (e.g., double bag the ice and seal with waterproof tape).

Special supplies are required for the field collection of samples for analysis of unknown
pathogens.  The ultrafiltration apparatus is used in the field to concentrate pathogens in a water
sample in order to improve method sensitivity and reduce the sample volume to a manageable
size (see Section 4.4.3 for a description  of the ultrafiltration apparatus).  The tubing and clamp
may be used to aid in flushing sample taps, but should not be used for the collection of samples
for  organic analysis, as materials may leach from the plastic and interfere with analysis.  The
stopwatch and plastic graduated cylinder are used to measure the flow rate from the
ultrafiltration apparatus, if necessary. Once the ultrafiltration apparatus is standardized, it may
not be necessary to measure flow rates in the field.

The sample containers in the kit are listed in Table 3-2, which describes the container size and
type, preservatives and dechlorinating agents, and specific analyses to be performed on the
sample. Four subsets of sample containers are shown in Table 3-2 to align with the analytical
approach presented in Module 4: a basic chemistry screen, an expanded chemistry screen, a
pathogen screen, and general water quality parameters.

Since the analyses used in the basic chemistry screen are based on standard methodologies, the
requirements for sample containers and  preservation are well documented.  The expanded
chemistry screen relies on exploratory techniques, and samples for these analyses should be
collected without preservation.
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The sample containers for pathogen analysis include containers for general bacteriological water
quality indicators and 100 mL plastic containers for the collection of concentrated aliquots for
analysis of pathogens using culture and PCR techniques.  Alternately, one 250 mL sample may
be collected for pathogen analysis and  split for PCR and culture analysis in the lab. If
ultrafiltration is not performed in the field, the alternate approach for pathogen sampling is to
collect one or more 10-liter containers  such that the water can be transported to the laboratory for
filtration, extraction,  and analysis. Sample containers for baseline water quality parameters will
depend on the specific parameters to be analyzed, and a few examples are shown in the table.
Table 3-2 illustrates the types of sample containers that might be included in a sample collection
kit; however, the specific containers included in the kit should be determined in consultation
with the laboratory that would be analyzing the samples.

The laboratory should be consulted regarding appropriate sample preservation that is consistent
with the types of analyses that will be performed.  In general, there are three options for sample
preservation: no preservation, minimal preservation, and preservation according to a
standardized method.

      No preservation - samples are simply collected in clean glass or plastic containers. This
       approach may be appropriate if the samples will be analyzed within 24 hours of sample
       collection.  The advantage of this approach is that sampling is simplified and maximum
       flexibility during sample analysis is maintained.  The disadvantage is that samples must
       be quickly analyzed, and some  contaminants may degrade even in a short time period.
       Note that samples collected for the expanded chemistry screen may not be preserved in
       any case since many of these techniques are not based  on standardized methods with
       documented preservation requirements.

      Minimal preservation - samples are preserved according to some preservation strategy
       other than that dictated by the method. For example, a dechlorinating agent may be
       added to all samples. If this approach is used, the laboratory should be asked to confirm
       that the preservative used does  not interfere with the analysis.

      Preservation according to the method - this approach is recommended if the samples are
       to be held for any appreciable time, or in situations where a particular contaminant is
       suspected.  Table 3-2 lists specific preservatives and dechlorinating agents for analytes
       sampled according to EPA method specifications. The methods  should be consulted for
       details regarding sample preservation  and holding times.

Regardless of the method of preservation used,  the preservatives added to a sample must be
clearly communicated to the laboratory. If method specified preservation techniques are not
used during sample collection, the laboratory may need to consult the method to determine if
they  need to add a reagent or adjust the sample  pH prior to analysis.

The reagents listed in Table 3-1 include preservatives, dechlorinating agents, and laboratory
grade water. The kit  also includes pH  paper that may be used to test the pH  of samples that
undergo pH adjustment. It is generally recommended that the preservatives  and dechlorinating
agents, if used, be added to the sample  containers in the proper amounts during preparation of the
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sample kit, as this will simplify sample collection and minimize the number of reagents that need
to be taken into the field. Where both a dechlorinating agent and an acid is required for
preservation, it is recommended that the dechlorinating agent be added to the empty container
before adding the sample, then adding the sample, and  finally adding the acid, to avoid a reaction
of the acid and dechlorinating agent before sample is added. If it is necessary to take
preservatives or dechlorinating agents into the field, it is desirable to store them separately from
the rest of the kit since they may expire more quickly than other materials in the kit.

Laboratory grade water (distilled or deionized water) is primarily for sample dilution in the field,
if necessary; however, it may have other uses such as conducting field testing.  Laboratory grade
water should not be stored in the kit, but rather collected fresh from the laboratory (or from a
commercial source) as the site characterization team departs for the investigation site.
Laboratory grade water should only be placed into clean organic-free glass or Teflon containers.

The safety supplies listed in Table 3-1 include splash-proof safety goggles, disposable nitrile or
polyethylene gloves (without powder), chemical resistant disposable lab coats,  and disposable
shoe covers. This basic PPE is intended to protect samplers from strong acids and bases used for
sample preservation, as well as to reduce the risk of incidental  contact with the water while
collecting samples or performing field tests. This PPE is appropriate for sites that are
characterized as low hazard (see  Section 4.1.3). Upon  exiting the site, the heavy-duty plastic
trash bag is used to collect any disposable PPE and supplies used on site.

The 20-liter reservoir of rinse water listed in Table 3-1  can be used to rinse skin or other
materials accidentally exposed to the  suspect water. Tap water collected from an unaffected area
can be used for this purpose. This water does not need to be included in the kit, rather the
reservoir can be stored in the utility vehicle that would be used by the site characterization team.
Rinse water should not be used for sample dilution or other activities where laboratory grade
water is required. The antiseptic wipes are included for cleaning hands or wiping the outside of
sample containers. A one-gallon container of bleach may be included in the kit in case more
aggressive decontamination is necessary.

Emergency water sampling kits are likely to receive little actual use and may remain in storage at
predetermined locations for extended periods,  during which time reagents may expire. To ensure
that sample collection kits are properly maintained, it is recommended that they be dated and
periodically refurbished  on at least an annual basis. At a minimum, sample containers with
preservatives should be replaced with fresh containers, and the contents  of the kit should be
inspected to ensure that it is complete and all items are still functional. Expired kits can be used
in field drills, which  provides an opportunity to train staff and verify that the equipment is
functional.

The sample kit presented in Table 3-1 contains the basic equipment necessary to collect water
samples from locations with a hose bib, faucet, or other sample tap. Other equipment may be
necessary to collect samples from sites that are not equipped with suitable sample taps.  For
example, in order to safely sample from fire hydrants, hoses, couplings, pressure reducers, and
valves may be needed. Likewise, some distribution system storage tanks may not have sample
taps in locations conducive to collecting representative samples from the body of water in the
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tank.  This represents a similar challenge to that of collecting a representative sample from a
large body of water, such as a reservoir.  Thus the practices and equipment used for source water
sampling may be applicable to sampling large tanks and reservoirs in the distribution system.
Techniques for sampling from large or deep bodies of water may require the use of a boat, depth
samplers, Van Doren samplers, or bacon bomb samplers, among others.  Typical equipment for
sampling from source waters is listed in the U.S. EPA,  Environmental Response Team SOP
#2013 (http://www.ertresponse.com/sops/2013-rlO.pdf).
3.2.2  Field Test Kits
Two types of field tests will potentially be performed during site characterization: field safety
screening and rapid field testing of the water. Field safety screening and rapid field testing
procedures are discussed in Sections 4.2.2 and 4.3.2, respectively. This section describes the
equipment that is used to support these activities.

While different equipment may be used for safety screening and water testing, it's efficient to
construct field test kits that contain equipment for both.  The field test kit should include the field
detectors used in safety screening or rapid water testing, supporting equipment, reagents, spare
parts (including batteries), and documentation necessary to perform field testing.  It is also
recommended that the field test kits be constructed such that they are separate from sample
collection kits, due to relatively high cost of field test kits.  This approach allows numerous
sample collection kits to be pre-positioned at strategic sites, while a smaller number of field test
kits can be assembled and assigned to  specific teams or personnel.

Table 3-3 lists the generic types of screening and detection devices and kits that could be
included in a field test kit.  The core field test kit includes 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 through the Environmental Technology  Verification (ETV) program are available at
http ://www. epa. gov/etv.

The core field test  equipment includes a radiation detector capable of analyzing for alpha, beta,
and gamma radiation for field safety screening. This detector is used to quickly identify
radiological hazards or eliminate them from consideration.  If levels of radioactivity are detected
that pose an immediate risk to life or health, the site would be characterized as a radiological
hazard (see Section 4.1.3). Without a radiation detector, it may be impossible to determine
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whether or not the site has been contaminated with radioactive material.  Typical the components
that form the detector are sold separately and include a probe (e.g., a pancake 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.  Examples
of radiation detectors and related information can be found at www.ludlums.com and
www. gei gercounter s. com.

Water is an effective shield to 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.  However,
there are devices, such as sodium iodine probes, which are designed to detect radiation (beta and
gamma) in water.

Cyanide detectors are 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/.

Table 3-3. 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.
Tests water for cyanide ion, but
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
Biotoxins (ricin,
botulinum, etc.)
Pathogens (tularemia,
anthrax, plague, etc.
Toxicity
Class
Safety Screen
Safety Screen
Both
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.
Kits available for a variety of
common parameters.
Quick and simple to use.
Expensive, but expands field
capability for chemicals.
Quick and simple to use.
Preconcentration will increase
sensitivity.
Need to establish a baseline.
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Chlorine residual measurements (both free and total) are of particular interest in distributed
drinking water since the absence of a residual disinfectant is undesirable under any circumstance.
Chlorine residual test kits and pH meters are established technologies that are widely used in the
drinking water treatment industry. Chlorine residual test kits are typically based on colorimetric
techniques, while pH instruments are based on ion-selective electrodes.  Some pH instruments
can also measure conductivity, which is another useful indicator of water quality changes
(assuming that a baseline for conductivity has been established). These general parameters are
included in the core field test kit as general indicators of water quality, and deviations from
established baseline values (see  Section 3.4.1) may indicate a potential problem.

The equipment listed under the expanded field test kit section  of Table 3-3 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 (see Section 4.1.3)
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, biotoxins, 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 GC/MS instruments. 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 technologies and detectors are commercially available that could be used for expanded
field testing However, few of these technologies have undergone a thorough and
independent performance evaluation.  The use of field testing technologies for which
performance has not been characterized is strongly discouraged. 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 in order to characterize the performance of the detector so that it can be used
with confidence during a site characterization activity.

EPA's ETV program is planning to evaluate several of these technologies. Toxicity assays were
evaluated in the summer of 2003, and there are plans to evaluate immunoassay kits and field
PCR systems by early 2004.  Potential users of these technologies are strongly encouraged to
review the ETV reports prior to making a decision regarding the implementation of any of these
monitoring technologies.  It is important to note that ETV is not a certification program and does
not approve technologies.  Rather it is a program for the independent evaluation of monitoring
and detection equipment that simply reports the results of the verification study for a given
technology.

As with sample collection kits, field test kits must be maintained so that the equipment and
chemical reagents are in proper working order when the kits are needed.  This requires 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
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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 (see Section 3.4).


3.3   Generic Site Characterization Plan
A site characterization plan is developed to provide direction and communication between the
incident commander and the site characterization team, which will facilitate the safe and efficient
implementation of site characterization activities.  The plan should be developed expeditiously
since the site characterization results are an important input to the threat evaluation process.  The
rapid development of a site characterization plan can be facilitated by the development of a
generic site characterization plan, which is easily customized to a specific  situation.  While the
circumstances of a particular threat warning will dictate the specifics of a customized site
characterization plan, many activities and procedures will remain the same for most situations,
and these common aspects can be documented in the generic site characterization plan.  Potential
elements of a generic plan include:  pre-entry criteria, communications, team organization and
responsibilities, safety, field testing, sampling, and exiting the site.

Pre-entry criteria define the conditions and circumstances under which site characterization
activities will be initiated and the manner in which these activities will proceed. At each stage of
the process (i.e., approach to the site, on-site characterization activities, sample collection, and
exiting the site), specific criteria may be defined for proceeding to the next stage. The pre-entry
criteria may also specify the general makeup of the site characterization team under various
circumstances. For example, under low hazard  conditions utility teams may perform site
characterization, while specially trained responders might be called upon to assist in the case of
potentially hazardous conditions at the site. The criteria developed for a particular utility should
be consistent with the role that the utility has assumed in performing site characterization
activities.

The generic plan should define communication  processes to ensure rapid transmittal of findings
and a procedure for obtaining approval to proceed to the next stage of site characterization. It is
advisable for the site characterization team to remain in constant communication with the
incident commander for the entire time that they are on site. The plan should provide an
approval process for the team to advance through the approach and on-site evaluation stages of
the characterization, to ensure that the team is not advancing into a hazardous situation.
Communication devices (e.g., cell phone, two-way radio, or panic button) can be used to alert
incident command of problems/observations encountered in the field. The communication
section of the generic plan should also discuss coordination with other agencies (e.g., law
enforcement, fire department) and contingencies for contacting HazMat responders.

Field testing and sampling may be handled in the generic plan by presenting a menu that covers
all potential options available to the utility, based on both internal and external  capabilities. In
developing a customized plan, the incident commander can simply check off the field tests and
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sampling requirements that are appropriate for the specific situation.  The site characterization
plan may also need to be revised in the field based on the observations of the team.

Many of the elements of a generic site characterization plan are captured in the "Site
Characterization Plan Template" (see Appendix 8.1). The plan is customized by simply filling in
the form based on the specific circumstances of the threat.


3.4  Evaluation of Baseline Water Quality Information
Baseline water quality information is derived from routine monitoring data and used to
characterize typical levels of a particular contaminant or water quality parameter.  While there
are no requirements to develop baseline water quality information, it can be a valuable resource
when interpreting the results from site characterization and laboratory analysis, specifically:
     The results of general water quality parameters, such as pH, chlorine residual, or
       conductivity,  among others, should be compared against a baseline to determine whether
       or not the results represent a significant deviation from typical levels.
     A positive result for a specific contaminant may need to be compared against typical
       background levels in order to properly interpret the results.

Since each of these applications of baseline data has different requirements, they are discussed
separately in the following subsections.


3.4.1  General Water Quality Parameters
General water quality data collected during the on-site investigation and subsequent sample
analysis may indicate water contamination if the results differ from an established baseline or
typical water quality  values. In order for such a comparison to be made, it is necessary to
establish a baseline for the water quality parameter(s) of interest.  Some parameters vary  as a
function of time and  position in the system while others may experience seasonal fluctuations.
These normal variations should be captured in the baseline data. Two approaches for
establishing a general water quality baseline are:
     Evaluate historical water quality monitoring data.
     During site characterization performed in response to a specific threat, baseline
       monitoring for target water quality parameters may be performed in an area of the
       distribution system that is not expected to fall within the potentially contaminated area.

Many water utilities routinely collect data that could be used to establish a baseline; however,
this data would need  to be analyzed and reduced to information that can be readily interpreted
and used during an emergency situation. Trend charts and statistical summaries are two
approaches for summarizing baseline water quality data.

In addition to using historical water quality data to establish a baseline, monitoring of unaffected
sites may be used for comparison with water quality data collected from the potentially
contaminated area. The unaffected site might be upstream or downstream  of the potentially
contaminated area, and ideally it would be hydraulically isolated from this area. However, the
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results of supplemental baseline monitoring must consider typical water quality variations that
occur at different locations within a distribution system.

A baseline can be established for any water quality parameter that is routinely monitored. The
following list of routinely monitored water quality parameters illustrates factors that may be
considered when establishing a baseline:

       pH of the distributed water is determined by the pH of the finished water at the entry
       point to the distribution system. In well-buffered waters, pH will typically remain fairly
       constant throughout a distribution system if the water is in equilibrium with the pipe
       material; however, it may vary if there are corrosion problems.

       Conductivity of the distributed water is determined by the conductivity of the finished
       water at the entry point to the distribution system.  It will typically remain fairly constant
       throughout a distribution system if the water is in equilibrium with the pipe material;
       however, it may vary if there are corrosion problems.

       Chlorine/chloramine residual levels vary as a function of temperature, pH, degree of
       nitrification, pipe wall demand (i.e., from biofilm or corrosion), and distribution system
       residence time (i.e., water age). The initial residual is established at the plant by the
       disinfectant dose and oxidant demand of the water. Oxidant demand will vary as a
       function of water quality, and typically experiences seasonal fluctuations. The use of
       disinfectant booster stations in the distribution system must also be considered when
       evaluating baseline residual data.

       Total organic carbon (TOO levels in the distribution system will remain relatively
       constant with respect to the finished water TOC. However, use of strong oxidants, such
       as ozone, can increase the biodegradable fraction of TOC, potentially resulting in greater
       variability in TOC levels in the distribution system.

       UV absorbance is typically used as a surrogate for TOC, but is more indicative of the
       aromatic fraction of TOC.  UV absorbance will experience variations similar to TOC, and
       UV absorbance is also impacted by oxidants and disinfectants used in water treatment.

Another factor to consider when establishing a baseline for distribution system water quality is
the potential for blending of water quality from different treatment plants.  If multiple treatment
plants feed the distribution system, the water quality will be a function of the blending ratio of
the water from the different plants, in addition to the other factors described above. The task of
establishing a baseline for such systems is further complicated by the fact that the blending ratios
will vary both spatially and temporally.
3.4.2  Background Levels of Specific Contaminants
The second application of baseline data is to support the interpretation of the site characterization
results for a specific contaminant. If a contaminant is tentatively identified or analytically
confirmed, it may be prudent to compare the results to baseline concentrations of that
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contaminant in the distribution system. This would be particularly important for typical water
contaminants (such as cyanide, arsenic, specific disinfection byproducts, certain pesticides, E.
co//', etc.).  As with general water quality parameters, there are two approaches for estimating
baseline levels of a specific contaminant in a distribution system:
      Evaluate historical monitoring results for the specific contaminant, if available.
      During site characterization performed in response to a specific threat, sampling for the
       specific contaminant may be performed in an area of the distribution system that is not
       expected to be contaminated.

In general, few contaminants of concern are monitored frequently enough to provide sufficient
data to estimate a baseline. Typically, contaminants would only be monitored if required for
compliance with drinking water standards, or if unregulated contaminants are known to occur in
the finished water and are of significant importance or interest to the utility. When such data are
available, it should be compiled and summarized to produce information that can be used to
estimate baseline occurrence in the event of an emergency (e.g., using trend charts or statistical
summaries). When compiling historic data, the baseline information should also identify  any
contaminants that are known to not occur in the finished water.

Assuming that field test kits  are developed during planning for site characterization activities, as
discussed in Section 3.2.2, utilities will know those contaminants that will be screened for in the
field. In these cases, a utility may choose to integrate field testing for these contaminants into
routine monitoring programs in order to generate data that can be used to establish a baseline for
the specific contaminant. Additional benefits of routine field testing include exercising the
equipment to ensure that it is calibrated and in proper working order and that the staff have an
opportunity to become familiar with the operation of this equipment.

If a specific contaminant is identified and historic baseline occurrence data are not available,
baseline sampling for the suspected contaminant might be performed to determine if the
contaminant is present (and at what concentration) in non-affected areas of the system. Baseline
sampling must be performed at a location that is located outside the contaminated area but which
is also representative of the area that may be contaminated. For example, if multiple treatment
plants feed a common distribution system, baseline sampling might be performed at a location
that is fed by the same treatment plant that feeds the potentially contaminated area but in a
different pressure zone.

While it may generally be assumed that a contaminant found near typical background levels is
just background, this may not always be the case. Another possibility is that sampling only
picked up the tail of a transient slug of a contaminant that was introduced at another point in the
system at  much higher levels. Other information from the threat evaluation process (Module 2)
should be considered when making a determination between these two possibilities. For
example, there may be physical evidence at the investigation site indicating potential
contamination, in which case one might consider the possibility that the low level concentration
is the tail of a larger slug. In this case, field testing and/or sampling for the specific contaminant
at additional investigation sites may be appropriate.
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3.5   Quality Assurance for Field Testing and Sampling
Because of the diversity of potential field testing and sampling activities during site
characterization, there may be no specific quality assurance (QA) activities which apply to all
sampling procedures.  However, the following general QA principles would apply in most cases
and are consistent with the QA guidelines published by EPA's Environmental Response Team
(http://www.ertresponse.com/sops/2013-rlO.pdf):
      All data should be documented on field data sheets or within site logbooks.
      All instrumentation should be operated in accordance with operating instructions as
       supplied by the manufacturer, unless otherwise specified in the work plan. Equipment
       checkout and calibration activities should occur prior to site characterization and
       documented.
      Any relevant QA principles and plans specific to the particular water utility or responding
       organization should be observed.
      Additional QA principles are contained within the sampling guidelines presented in
       Section 4.4.  It should be noted that these sampling guidelines also have various quality
       control (QC) elements built in, and these QC elements are often documented in the
       specific analytical methods.


3.6   Maintaining Crime Scene Integrity
The suspected contamination site that is the focus of site characterization activities could
potentially become the scene of a criminal investigation. If law enforcement takes responsibility
for incident command because they believe a crime has been committed, they will control the
site and dictate how any additional activities, such as site characterization, are performed. In
cases in which the utility is still responsible for incident command, it may still be prudent to take
precautions to maintain the integrity of the potential crime scene during site characterization
activities.  The following guidelines for maintaining crime scene integrity are provided, although
this should not necessarily be considered an  exhaustive list:
      If there is substantial physical evidence of contamination at a site, the threat will likely be
       deemed 'credible' from a utility and a law enforcement perspective.  In this case, law
       enforcement may take control of the  site and limit the activities performed by other
       organizations at the site.
      Substantial physical evidence of contamination might include discarded PPE, equipment
       (such as pumps and hoses), or containers with residual material.  Special care should be
       taken to avoid  moving or disturbing any potential physical evidence.
      Evidence should not be handled except at the direction of the appropriate law
       enforcement agency.  Specially trained teams from the law enforcement community are
       best suited (and may be jurisdictionally required) for the collection of physical evidence
       from a contaminated crime scene.
      The collection  of physical evidence is not generally considered time sensitive; however,
       site characterization and sampling activities are time sensitive due to the public health
       implications of contaminated water.  Thus, collection of water samples may precede
       collection of physical evidence, and care must be taken not to disturb the crime scene
       while performing these  activities.  If samples can be collected outside of the boundaries
       of the suspected crime scene, it may avoid concerns about the integrity of the crime
       scene.
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  Water samples collected for the purpose of confirming/dismissing a contamination threat
   and identifying a contaminant could potentially be considered evidence and should be
   handled accordingly.
  Since the analytical results may be considered evidence as well, it is important to use a
   qualified laboratory for analytical support (see Module 4). If law enforcement has taken
   control of the situation prior to sample collection, they may require the collection of an
   additional sample set to be analyzed by their designated lab.
  Photographs and videos can be taken during the site characterization for use in the
   criminal investigation. Law enforcement should be consulted for proper handling during
   and after taking photographs/videos to ensure integrity of the evidence.

Maintaining crime scene integrity during site characterization is largely an awareness issue.
If the site characterization team integrates the guidelines outlined  above into their on-site
activities, they will go a long way towards maintaining the integrity of the crime scene.  It is
also recommended that the WUERM and site characterization team lead coordinate with law
enforcement, as part of emergency response planning, regarding appropriate procedures for
activities performed at the site of a potential contamination incident.
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4   Site Characterization Protocol

This section presents guidance and procedures for conducting site characterization activities.
The site characterization protocol is divided into five stages, which are described in the
following subsections and summarized below:
      Section 4.1, Customizing the Site Characterization Plan: Review the initial threat
       evaluation, review and customize the generic site characterization plan, identify the
       investigation site, conduct a preliminary hazard assessment, develop a sampling
       approach, and form the site characterization team.
      Section 4.2, Approaching the Site: Establish the site zone, conduct field safety screening,
       and observe site conditions.
      Section 4.3, Characterizing the Site: Repeat field safely screening, conduct the detailed
       site evaluation, and perform rapid field testing of the water.
      Section 4.4, Collecting Samples: Fill sample containers, preserve samples if necessary,
       and initiate chain of custody.
      Section 4.5, Exiting the Site: Perform final site check, remove all equipment and samples
       from the site,  and re-secure the location.

Documentation of the site characterization activities and findings is an ongoing effort throughout
each phase and result in a site characterization report as described in Section 5.


4.1   Customizing the Site Characterization Plan
The first stage of the  site characterization process is the customization of the generic plan
developed as part of planning and preparation for responding to contamination threats (Section
3.3).  In general, the incident commander (most likely the WUERM) will develop the customized
plan in conjunction with the site characterization team leader. The steps involved in the
development of the plan include: 1) perform an initial evaluation of information about the  threat;
2) identify one or more investigation sites; an assessment of potential site hazards; 3) develop a
sampling approach; and 4) assemble a site characterization team. Each of these steps is
discussed in the following section, followed by three examples that demonstrate customization of
the site characterization plan.  A template for the development of a site characterization plan is
provided in Appendix 8.1.
4.1.1  Initial Evaluation
Figure 3-1 indicates that an initial evaluation of a contamination threat, followed by a
determination that the threat is 'possible' may lead to site characterization activities. The
information used to support the initial threat evaluation (see Module 2, Sections 3.1 and 3.2) is
essential to the development of a customized site characterization plan. The initial evaluation
should include a review of all available information from the threat warning as well as details
about the suspected contamination site. The WUERM and site characterization team leader
should review any alarms and security video that may be available from the area of the
investigation site, as well as any on-line water quality monitoring data collected in the vicinity of
the site. Much of this information should be summarized in the "Threat Evaluation Worksheet"
in Module 2, Appendix 8.2.
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4.1.2  Identification of Investigation Site
In order to proceed with site characterization activities, it is necessary to identify one or more
investigation sites. This may be relatively straightforward or fairly complex depending on the
circumstances of the threat.  Factors to consider when selecting an investigation site include:
       Whether or not the physical location of suspected contaminant introduction is known.
       Whether or not the affected area was isolated from the rest of the system in time to
       contain the potentially contaminated water.
       Whether or not baseline monitoring/sampling is necessary (as discussed in Section 3.4).

If a suspected contamination site can be identified, it will likely be designated as the primary
investigation site. Examples in which a suspected contamination site would be apparent include
a security breach at a specific facility,  a witness account of tampering at a particular location, or
a verbal/written threat in which the site of contaminant introduction is named.

In the case of a threat warning  in which a specific location is not evident, another approach must
be taken to select investigation sites. Under this scenario, vulnerable sites, as identified in a
utility's vulnerability assessment, might be considered as potential investigation sites. However,
it may be more prudent to forgo a complete site characterization at an arbitrarily selected site,
and instead increase the number of locations and frequency of sampling for water quality
parameters routinely monitored and which have established baselines. Other approaches might
involve increased monitoring of consumer complaints regarding unusual tastes or odors and/or
working with local public health officials to identify unusual cases of disease that may be related
to contaminated water. These latter approaches are intended to provide additional information to
help determine whether or not the threat is 'credible' in situations where it may not be possible to
conduct a thorough site characterization at a meaningful investigation site.

Some activities performed during site characterization depend only on the physical location of
the site, such as the evaluation  of site conditions and physical evidence. However, selection of
sites for rapid field testing and  water sampling must consider the potential spread of the
contaminant in order to produce meaningful results.  If the suspected contamination site is
quickly isolated  following the discovery of a contamination threat, the potential spread of the
contaminant may be minimized, emphasizing the importance of rapidly initiating immediate
operational response actions (Module 2, Section 3.3.2). If isolation is not possible or cannot
assure that the suspect water has been  contained to well defined area, then the potential spread of
the contaminant should be considered when selecting secondary investigation sites (i.e.,
investigation sites other than the suspected contamination site).

Secondary investigation sites are selected to characterize the spread of a contaminant through a
distribution system, which is a  function of:
The suspected location of contaminant introduction.
         The elapsed time between contaminant introduction and water sampling/testing.
         The hydraulic operation of the system during this time period.
         The amount and purity of contaminant introduced.
         Fate and transport processes that might impact the contaminant concentration.
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To rigorously address all of these factors when predicting the spread of a contaminant would be a
lengthy and complex process in almost any situation. Furthermore, it is unlikely that the time of
possible contaminant introduction will be known with a great degree of certainty, unless the
tampering incident was directly observed, recorded, or triggered an alarm at a known time. Also,
unless the identity of the contaminant is known and its properties well characterized, there will
be insufficient information to predict the impact of various fate and transport processes on the
concentration of the contaminant.

However, it may be possible to develop a rough estimate of the spread of a contaminant that will
be sufficient for the purpose of selecting secondary investigation sites.  To develop such an
estimate, it will typically be necessary to assume both a location and time of contaminant
introduction.  As discussed previously, a potential contamination site may be evident from the
threat warning, while the time of contaminant introduction will likely be unknown. However, it
may be possible to bracket the time of the suspected contamination incident between the last
time the site was visited and the time the threat was discovered.  Once a location and time have
been selected, the spread of the suspected contaminant can be estimated based on the hydraulics
of the system.

Two approaches for estimating the spread of a suspected contaminant through a water system
are: 1) application of operational knowledge of the system, and 2) application of a hydraulic
model of the distribution system.  The first approach requires knowledge of pressure zones and
typical flow patterns through a distribution system, as well as information derived from  SCAD A,
to estimate the spread of a possible contaminant slug through a system. The second approach
involves the use of hydraulic models such as EPA Net, PipelineNet, MWHSoft, Stoner,  and
Haestad,  among others. While this latter approach is more rigorous, these models are
sophisticated and require a certain level of skill and a significant amount of time to run;  thus, it
may not be practical to use such models for the purpose of identifying investigation sites.
Furthermore, the first approach may be sufficient for identifying secondary investigation sites for
field testing and water sampling.

It is generally assumed that the identity and amount of contaminant introduced into the system
will be unknown.  In this case, the effect of fate and transport processes on the contaminant
might be assumed negligible (i.e., the contaminant is not diluted or degraded), which would
produce a conservative estimate of the contaminant concentration in the system. One could also
assume an initial concentration of "100%" at the point of contaminant introduction, which would
allow the fractional concentration to be tracked through the system as the contaminant is diluted.

Finally, if the contaminant is suspected to have spread through a portion of the system, it may be
desirable to identify investigation sites for the purpose of baseline sampling. The analysis
described above to estimate the spread of a suspected contaminant through a distribution system
might also support the selection of investigation sites for baseline sampling. However, these
sites should be outside of the potentially contaminated area. Other factors that may impact the
baseline, as described in Section 3.4, should also be considered during the selection of secondary
investigation sites for baseline sampling.
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In all cases, it is critically important to identify investigation sites promptly so that site
characterization activities can begin shortly after discovery of a contamination threat.  The
objective of site characterization is to gather information quickly in order to evaluate whether or
not a threat is 'credible.'  As discussed in Module 2, it is important to make this credibility
determination in a relatively short period of time (the target time period is less than eight
hours from the time the threat warning is received) such that response actions to protect
public health can be implemented if necessary.
4.1.3  Site Hazard Assessment
During the development of a customized site characterization plan, an initial assessment of
potential site hazards should be performed.  Four hazard categories are considered in the context
of site characterization:
       1)  Low hazard - no obvious signs of radiological, chemical, or biological contaminants
           are present at the site (i.e., in air or on surfaces).  Contaminants that may be present in
           the water are assumed to be dilute and confined to the water.
       2)  Radiological - presence of radiological isotopes or emitters tentatively identified at
           the site or in the water (i.e., through the use of a field radiation detector).
       3)  Chemical - presence of highly toxic chemicals (e.g., chemical weapons or biotoxins)
           or volatile toxic industrial chemicals tentatively identified at the site or in the water,
           with a potential risk of exposure through dermal or inhalation routes.
       4)  Biological - presence of pathogens tentatively identified at the site, with a potential
           risk of exposure through dermal  or inhalation routes.

The site hazard assessment is integral to the site characterization process and is intended to
minimize the risk to the site characterization team. Figure 3-2 illustrates how information
from site characterization activities may be used to refine the hazard assessment, which in turn
may dictate the course of the site characterization. This figure also illustrates the importance of
communication between the site characterization team and the incident commander during the
course of on-site activities.

At the planning stage, the only information available to perform a site hazard assessment will be
from the initial threat evaluation, as discussed in Section 4.1.1. The forms in the appendix to
Module 2 that are designed to collect information to support the threat evaluation can also be
used to support the initial site hazard assessment. Given the limited amount of information at
this stage, it may only be possible to determine whether the site presents a low or high hazard.  A
'low hazard' site would have no obvious signs of contaminants present in the environment (air
and surfaces), while conditions at a 'high hazard' site would indicate a potential risk to personnel
at the site.  If the site is initially characterized as a low hazard, the standard safety procedures
discussed in Section 3.1 should provide adequate protection to the site characterization team. On
the other hand, if the site is characterized as a high hazard, HazMat responders with training and
PPE appropriate for the site conditions should be contacted to provide support for site
characterization activities.
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                                        MODULE 3: Site Characterization and Sampling Guide
            Site Characterization Planning
            - Perform initial site hazard assessment.
            Approaching the Site
            - Conduct field safety screening
            - Observe site for signs of hazard
              Report findings to incident command
                   and assess site hazards
                                                       HALT SITE CHARACTERIZATION
                                                        Contact law enforcement and
                                                            HazMat responders
            Characterizing the Site
            - Conduct field safety screening
            - Observe site for signs of hazard
            - Conduct rapid field testing of the water
              Report findings to incident command
                   and assess site hazards
                   Notify incident command
Figure 3-2. Integration of Site Hazard Assessment into Site Characterization Process
During the approach to the site, the team will perform field safety screening and observe the site
for potential hazards from the site perimeter (see Section 4.2).  At a minimum, field safety
screening for radiation is recommended since it is a straightforward means of eliminating
potential radiation hazards. Detection of excessive levels of radiation would result in the site
being categorized as a radiological hazard. If expanded field safety screening techniques are
employed, chemical and biological hazards might be tentatively identified at the site.  For
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example, a VOC sniffer might detect certain chemical hazards in the air. While field safety
screening is a useful tool, it is just as important to carefully observe the site for potential signs of
hazard, as discussed in Section 4.2.3. Due to the limited capability of even the most advanced
field safety screening, site observations may be the most reliable indicator of potential hazards.

Upon completion of field safety screening and initial observation of site conditions, the site
characterization team leader should report the findings to the incident commander, who will
make a decision regarding whether or not it is safe for the team to enter the site. If there are
indicators of a potential hazard, then incident command will likely halt the site characterization
activities and contact law enforcement, and potentially HazMat, for assistance. In the absence of
such indicators, the incident commander may clear the team to proceed further into the site.

Once at the investigation site, the team will commence their detailed site characterization
including additional field safety screening, observation of potential site hazards, and rapid field
testing of the water. The results of these activities are reported to the incident commander who
will use this information to revise the site hazard assessment.  If the incident commander
determines that the site poses an unacceptable risk to the team, they may be instructed to retreat
from the  site. If there was the potential for personnel to become contaminated, they may need to
retreat to the site perimeter and remain there until additional help arrives. If the site is still
categorized as a low hazard, the incident commander may clear  the team to proceed with
sampling and complete the characterization. If the site is characterized as a chemical, biological,
or radiological hazard,  special sampling precautions may be necessary, as discussed in Section
4.1.4.

Upon exiting the site, the team leader should notify the incident commander to verify that
everyone is safe and accounted for, that all necessary samples have been collected and secured,
equipment has been collected, and the site has been secured. Outstanding or unresolved issues at
this point should be communicated.
4.1.4  Sampling Approach
The objective of sampling from a suspected contamination site, or secondary investigation site, is
to obtain and preserve a sample of the water at a particular time and location, so that it can be
analyzed later if necessary.  In order to perform sampling effectively, sampling requirements
should be considered in the development of the customized site characterization plan. Factors to
consider during the development of a sampling approach include:
      Which contaminants or contaminant classes will be sampled?
      What type of samples will be collected (i.e., grab or composite)?
      When and where will samples be collected?
      Are any special precautions necessary during sample collection?

The "Site Characterization Plan Template" in Appendix 8.1 includes a section for documenting
the sampling requirements.  It is important to consider that the initial sampling approach
documented in the plan may need to be revised based on the findings of site characterization
activities, as discussed later in this section.
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Selection of target contaminants during development of a customized site characterization plan
will be based on an initial assessment of information about the threat.  Prior to site
characterization, it is likely that little will be known about the identity of suspected water
contaminants. In this case, the sampling approach may need to be comprehensive and include all
analytes covered by the sample kit (see Table 3-2). In some cases, the available information
about the threat may indicate the presence of a particular contaminant or contaminant class, and
the sample plan may be adjusted accordingly. However, during this initial stage of site
characterization, it may still be prudent to plan to collect a complete sample set (i.e., all sample
containers in the utility's emergency water sampling kit) from the investigation site.

The two most common types of environmental samples are grab samples and composite samples.
A grab sample is a single sample collected at a particular time and place that represents the
composition of the water only at that time and location. The sample is collected all at once and
at one particular point in the sample medium. A composite sample is 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. Analysis of a composite sample produces an
average value and can, in certain instances, be used as an alternative to analyzing a number of
individual grab samples and calculating an average value.

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.  An
example of a  scenario  in which it may be necessary to collect composite samples is sampling
conducted to characterize a large reservoir where collection and analysis of a large number of
discrete samples may be time and cost prohibitive.  One disadvantage of composite samples is
that they may dilute concentrations of contaminants that would otherwise be detected in discrete
grab samples.  Another disadvantage is that if a contaminant is detected, it is impossible to know
which specific individual sample was the source of the contaminant.

The time and location  of sample collection will be addressed by the selection of investigation
sites, as discussed in Section 4.1.2.  Due to the potential spread of a suspected contaminant
through a distribution  system, sampling may be performed at secondary investigation sites rather
than the primary site.

The need for special precautions during sample collection will likely be determined by the site
hazard assessment described in thee previous section.  Figure 3-3 illustrates four sampling
approaches based on the hazard categories defined in  Section 4.1.3.  Prior to the initiation of site
characterization activities, there may be limited information available to determine which
sampling approach is appropriate.  However, the results of the site evaluation and field testing
may allow for a more precise characterization of the hazards at the site, and thus provide a basis
for refining the sampling approach. For example, the site evaluation may indicate the presence
of a hazardous chemical (e.g., unexplained dead animals at the site), which may indicate that
precautions are necessary during sample collection for chemicals, as shown in Figure 3-3.

Under low hazard conditions, no special sampling techniques are necessary beyond good safety
practices as described  in Section 3.1. Under this scenario, samples for chemical and pathogen
analysis are collected according to the procedures described in Section 4.4.
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If the site is characterized as a radiological hazard due to the detection of excessive levels of
radioactivity during field safety screening, samples should be collected for radiological analysis
by personnel trained and equipped to work at radioactive contamination sites (e.g., Superfund
teams).  Figure 3-3 also suggests the collection of a large volume water sample using the 10-liter
containers listed in Table 3-1, in case it is necessary to perform analyses for additional
contaminants following radiological analysis.  The large volume water samples should only be
handled by the trained responders and stored in appropriate facilities that would minimize the
risk of potential exposure to radiation.
                                   Develop initial sampling
                                approach based on initial site
                                     hazard assessment
                                 Evaluate site conditions and
                                    perform field testing
                                             I




Revise the site hazard
assessment based on site
characterization results


Revise sampling approach based
on the site hazard category






ill
/ LOW \ / RADIOLOGCAL \ / CHEMICAL \ /
\ HAZARD / \ HAZARD / \ HAZARD / \


Collect samples
for chemical
analysis


Collect samples
for radiological
analysis

Pre-concentrate
sample using
ultrafiltration


Collect retentate
for pathogen
analysis

Make dilutions of
1/1,000 and 1/100

Collect and hold
large volume
water sample


Use dilute samples
for hazardous
chemical analysis


Collect and hold
large volume
water sample
(not diluted)



I
' BIOLOGICAL N
v HAZARD /


Pre-concentrate
sample using
ultrafiltration


Collect retentate
for pathogen
analysis


Collect and hold
large volume
water sample
Figure 3-3.  Integration of Site Hazard Assessment into the Sampling Approach
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If the site is characterized as a chemical hazard, dilution of samples collected for chemical
analysis may be an appropriate sampling strategy to reduce the risk during sample transport and
analysis. Dilution does not reduce the risk to personnel collecting the sample since they are
working with the undiluted water; thus site procedures appropriate for a chemical hazard
should still be followed. Dilutions of 1/1,000 and 1/100 are appropriate for chemical hazards
already present in water (a 1/10,000 would only be appropriate for concentrated material). The
most dilute sample (i.e., 1/1,000 dilution) should be delivered to the laboratory  for analysis first.
The remaining diluted samples should be stored in a safe and secure location  and  delivered to the
laboratory if the result from the analysis of the 1/1,000 dilution turns up nothing unusual. In
addition to the diluted samples, it is suggested that a large volume water  sample (not diluted) be
collected in case it is necessary to perform analyses for additional contaminants following
analysis of the diluted samples. The large volume water samples should only  be handled by
trained responders and stored in appropriate facilities that would minimize the risk of potential
exposure to hazardous chemicals.

If the site is characterized as a biological hazard, pathogen sampling should be conducted
according to the procedures described in Section 4.4.3.  Figure 3-3 also suggests the collection of
a large volume water sample in case it is necessary to perform analyses for additional
contaminants following pathogen analysis. Another potential strategy for sampling for
chemicals from the site of a biological hazard, which is not shown in Figure 3-3, is the use of UV
irradiation to inactivate pathogens in the processed sample. UV irradiation will inactivate a
majority of the suspected pathogenic organisms and provide a degree of protection for the
analysts. UV irradiation does not reduce the risk to personnel collecting the sample since
they are working with the non-irradiated water; thus site procedures appropriate for a
biological hazard should still be followed. Irradiation of the sample can be most effectively
accomplished through the use of a flow-through UV irradiation device, but may also be
performed in batch mode, although the latter is likely to be less effective or require more time to
achieve the desired results.  Note that the dose required for the inactivation of most biological
agents has not been fully characterized, nor has the effect of UV irradiation on all chemicals of
concern. Thus, it is generally recommended that a large volume sample be collected for possible
chemical analysis, as shown in Figure 3-3, rather than employing UV irradiation.  The large
volume water samples should only be handled by the trained responders and stored in
appropriate facilities that would minimize the risk of potential exposure to biological hazards.
4.1.5  Formation of a Site Characterization Team
The site characterization team will be responsible for performing the site investigation, field
safety screening, rapid field testing, and sampling collection.  The makeup of the team may for a
specific site characterization activity will depend on the results of the initial site hazard
assessment, as discussed in Section 4.1.3.  If the site is characterized as anything other than a low
hazard, a HazMat response team should be contacted to support site characterization activities.
The HazMat responders may 'clear' the site for entry by utility personnel or may perform the
actual site characterization. Under low hazard conditions, utility personnel may be able to
perform site characterization activities if they receive training in basic safety practices and use of
any specialized equipment.
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For safety reasons, the team should include at least two people, with one person in constant
communication with incident command.  One member of the team should have
experience/knowledge of security investigations, including the analysis of security breaches
(e.g., vandalism, opportunistic break-ins) and basic procedures for maintaining the integrity of a
crime scene. The other team member should have experience in water quality, sampling, and use
of field test equipment. Additional team members may be added as appropriate for a given
situation (e.g., an individual from the utility's operations department may be included to support
decisions regarding containment of the suspect water).  All members of the site characterization
team should be capable of performing a critical evaluation of site conditions and documenting
the findings from site characterization activities.
4.1.6  Examples of Site Characterization Plan Customization
The customized site characterization plan developed before the team is sent to the site may be
very similar to the generic plan due to the limited amount of information that will be available at
this initial stage. Customization of the plan may actually occur in the field as the team begins to
gather information.  In particular, the field testing and sampling activities may need to be revised
based on the initial observations at the site. The plan should be revised through collaboration
between the incident commander (most likely the WUERM) and site characterization team
leader.

The following three examples are intended to illustrate how a customized site characterization
plan might evolve from the point that the threat warning is discovered through the conduct of site
characterization activities. In these examples, it is assumed that a generalized plan has been
developed with the following elements:
      Sample kits developed according to the example presented in Table 3-1 and including all
       of the sample containers listed in Table 3-2.  The kit contains a 'Field Guide' with the
       forms in the appendix to this module, simple SOPs, and other supporting documentation.
      A field test kit developed according to the example of the core field test kit presented in
       Table 3-3, including:  a radiation meter, a pH/conductivity probe, a chlorine residual test
       kit, and a cyanide test kit.
      A utility site characterization team, consisting of a security specialist and a water
       quality specialist, has been formed and trained in basic safety procedures, use  of field
       testing equipment, and use of basic PPE (i.e., the PPE listed in Table 3-1).
      A communication plan to keep the WUERM informed during all stages of site
       characterization.

Example 1: A threat warning is received in the form of an alarm trigger on an access  hatch to a
distribution system storage reservoir.  The operator immediately informs the WUERM, and
actions are quickly taken to hydraulically isolate the tank from the system. This immediate
operational response is  determined to be effective for preventing the water in the tank from
spreading to the rest of the system.

The WUERM and site characterization team leader immediately begin to customize the site
characterization plan. While there is very limited information about the threat, the suspected
contamination site is obvious from the threat warning. Thus, the storage tank is designated as the
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primary investigation site. There is insufficient information to characterize the potential site
hazards; however, the decision is made to treat this as a low hazard site until evidence is
collected to indicate otherwise.  The reason for this decision is that false alarm triggers do occur
with some frequency, and to date, none have presented hazardous conditions. Furthermore,
safeties are built into the site characterization process that are designed to minimize the risk to
the site characterization team.

At this point, there is insufficient information to further customize the site characterization plan.
A decision is made to dispatch the utility site characterization team to the investigation site,
equipped with the standard field test kit and two sample kits.  The plan will be reevaluated
following the site characterization team's initial observations of the site.

Upon arrival at the location of the tank, the team establishes a perimeter at a safe distance from
the tank to perform their initial evaluation.  From the perimeter, the site characterization team
conducts field safety screening using the radiation meter and observes that levels are well below
a predetermined trigger level. Their initial observations indicate that the hatch is open, but no
other signs of potential hazard are evident.  The team leader contacts the WUERM using a two-
way radio and reports their initial findings.  The WUERM clears the team to proceed with site
characterization activities.

At the perimeter, the team dons the PPE in the sample kit and cautiously approaches the site.
They observe that the lock on the access hatch is missing, but no other individuals are in the area
and there is no obvious evidence of contamination at the site.  The team continues the
characterization and conducts rapid field testing of the water for pH, conductivity, chlorine
residual, and cyanide. The water quality parameters all appear normal, and the results of the
cyanide test are negative. The team leader contacts the WUERM to  report the results of the site
characterization and discuss the need for any modification to the site characterization plan at this
point.  The sense is that the threat is not 'credible,' but it is decided to collect one set of samples
that will be stored at the utility laboratory in case there is a need to analyze the samples later.

The team collects the samples, completes the documentation of the site characterization, and
prepares to exit the site. Before leaving, the team places a new lock on the hatch and secures the
site (this is important to avoid future false alarms).  Upon leaving the site, the team leader
contacts the WUERM to report that the team has completed its investigation and is in transit to
the utility laboratory to deliver the samples for storage.

Commentary.  In this example, customization of the site characterization plan only involved
the identification of the suspected contamination site and an initial assessment that the site
probably did not pose  a  significant hazard.  The evaluation that the  site did not pose a
significant  hazard was based on previous incidents  and the experience of the WUERM.
During site characterization, there were no signs of hazard or contamination; thus a decision
was made  to  collect a  single  set   of  samples  and  not pursue any  additional  site
characterization activities at this time.  These samples were taken  as a precaution and will
only be sent to a laboratory  for analysis if it is  later determined to  be necessary.  The
WUERM may  continue  the threat evaluation  following  the  completion of these site
characterization activities,  since  other information  may  be relevant to the  evaluation
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regarding whether or not the threat is 'credible' (see Module 2).  Furthermore, the decision to
return the tank to normal operation will be based on the outcome of the threat evaluation, not
solely on the results of the site characterization. Of course the site characterization provides
important information to support the threat evaluation process.

Example 2: A threat warning is received in the form of security breach discovered at a water
distribution system tank by a utility crew. Furthermore,  evidence at the site indicates that
material may have been introduced into the tank.  The WUERM is immediately notified and asks
the operational staff to review the  SCADA data and inspection records for this tank.  This
evaluation indicates that 48 hours  have elapsed between the time the breach was discovered and
the most recent inspection that found the site secured, and that the storage tank was feeding the
distribution system for at least 12 hours during that period, but it is not known whether or not
this occurred before or after the security breach.

The WUERM and site characterization team leader immediately begin to customize the site
characterization plan.  Since the tank is  the site of suspected contamination, it is designated as
the primary investigation site. However, due to the potential spread of the suspected
contaminant into the distribution system, secondary investigation sites are designated in the
distribution system. These secondary sites are selected using operational knowledge of the
system, as discussed in Section 4.1.2. Eight secondary sites are selected in the area impacted by
the potentially contaminated water, and an additional eight  sites are selected outside of this area
for the purpose of baseline monitoring.  At each investigation site, the standard set of field tests
will be conducted and a complete  set of samples will be  collected.  However, only the primary
site (i.e., the location of the tank) will undergo a full investigation.

Due to the circumstances of the threat warning, the WUERM notifies utility management, law
enforcement, and HazMat. This is in accordance with procedures outlined in the utility's
emergency response plan (ERP).  The incident commander (which  may or may not be the
WUERM in this case) determines  that the secondary sites can be characterized by utility
sampling crews trained in the site  characterization  procedures. HazMat will characterize the
primary site due to the presence of suspicious material at the site, but the utility site
characterization team leader will support the HazMat team on issues related to water quality and
sampling.

The HazMat team takes command of the primary investigation site and implements their
procedures for field safety screening and characterizing any potentially hazardous  materials at
the site, in particular residual  materials found in a container. The HazMat team does not detect
any hazards during their safety screen, although they do find a suspicious material at the site that
is collected for subsequent analysis.  At this point,  the utility site characterization team leader is
cleared to enter the site and provides guidance to the HazMat responders as they perform field
testing of the water and  collect water samples.

The results of limited rapid field testing performed at all investigation sites showed no obvious
signs of contamination; however, there was evidence of potential contamination at the storage
tank (i.e., the suspicious material in the  container). Based on the collective information and
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results of the threat evaluation, a decision is made to immediately deliver all samples to the
laboratory for analysis.

Commentary.  In this example, the site characterization plan was complicated by the fact that
there was the  potential  for potentially contaminated water to enter the distribution system.
The plan addressed this by identifying additional sites for field testing and sampling in the
distribution system.  Secondary sites were selected to look for indicators of contamination in
the potentially  contaminated area as well as to characterize baseline levels outside of this
area.  This is particularly important for the non-specific field tests included in the kit, which
require comparison to a baseline to effectively interpret the results.

This example also involves a situation in which the discovery of the threat warning yielded
information about potential  site hazards and evidence of contamination.  This information
influenced both the threat evaluation as well as the site characterization plan. Implicit in this
example is the decision that the threat had some level of initial credibility  such that it was
necessary to contact  law enforcement and HazMat.  This in turn impacted the makeup of the
site characterization team.

Example 3. A citizen observes a suspicious looking individual hurriedly leaving the fenced area
surrounding a distribution system storage tank. The concerned citizen calls 911, but the police
do not arrive in time  to apprehend the suspect. The responding officer notices that the lock was
cut from the perimeter fence and the access hatch was left open. The officer calls dispatch and
requests that the water utility be contacted immediately.  The WUERM is notified and
immediately contacts operations to determine whether or not the storage tank can be isolated.
Within an hour, the tank is physically isolated from the rest of the distribution system.

The WUERM  and site characterization team leader immediately begin to customize the site
characterization plan. As the potential site of contamination, the storage tank is designated as the
primary investigation site. It is unclear whether or not the tank was isolated quickly enough to
prevent the spread of water into the system; however, for the initial plan it is decided that only
the primary site will be characterized. Since no indicators of potential hazard were observed by
law enforcement, it is decided to treat this as a low hazard site until evidence is collected to
indicate otherwise.

At this point there is  insufficient information to customize the site  characterization plan further.
A decision is made to dispatch the utility site characterization team to the investigation site
equipped with the standard field test kit and two sample kits.  In addition to the standard field
test kit, the team also takes a field detector that the utility recently  purchased to expand their
capabilities. While some basic testing has been done with the new detector, there has been
insufficient time to perform much baseline monitoring or a rigorous performance evaluation.

Upon arrival at the location of the tank, the team establishes a perimeter at a safe distance from
the tank to perform their initial assessment. From the perimeter, the site characterization team
conducts field  safety screening using the radiation detector and observes that levels  are well
below  a predetermined trigger level.  There initial observations indicate that the hatch is open,
but no other signs of potential hazard are evident. The team leader contacts the WUERM using a
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two-way radio and reports their initial findings. The WUERM clears the team to proceed with
site characterization activities.

At the perimeter, the team dons the PPE in the sample kit and cautiously approaches the site.
They observe that the lock on the access hatch is missing, but no other individuals are in the area
and there is no obvious evidence of contamination at the site.  The team continues the
characterization and conducts rapid field testing of the water for pH, conductivity, chlorine
residual, and cyanide. The water quality parameters all appear normal and the results of the
cyanide test are negative. However, the new detector used for expanded field testing yields a
positive result for a contaminant of concern. The team leader contacts the WUERM to report the
results of the site characterization, particularly the tentative identification of the contaminant.
The WUERM and site characterization team leader realize that this tentative result will need to
be confirmed through laboratory analysis, and revise the site characterization plan based on this
result.

The operations  staff believes that the tank was isolated in time to contain any contaminated
water, but since they don't know how long the suspect was at the tank, they cannot be certain.
Based on this information, the plan is modified as follows. Two complete sample sets will be
collected from the tank and prepared for immediate delivery to the laboratory.  In parallel with
this activity, two additional utility sampling teams will be sent out to several locations within two
specific areas of the distribution system. One team is sent to an area of the distribution system
that normally receives water from the suspect tank to evaluate whether or not the contaminant
has spread.  The other team is sent to an area of system that is hydraulically isolated from the
area served by the storage tank in order to conduct baseline sampling.  Both teams are equipped
with several complete sample kits.  They are instructed to conduct expanded field testing at
several locations within their assigned areas, and if they observe a positive result, to collect two
complete sample sets. Each team is instructed to collect at least one complete sample set from
within their target area, even if all field test results are negative.

Commentary.  This example illustrates how  the results of site  characterization, particularly
field testing, may be used to revise the site characterization plan in the field.  Given the
eyewitness account of the intrusion and the positive field test results, this may be considered
a 'credible' threat, and additional response measures  may be  appropriate (see Module  2).
However, interpretation of the expanded field test results is complicated by the fact that this
technology is relatively new to the utility  and there is  insufficient baseline data to support
interpretation of the results. While expanded field testing can be a valuable tool during site
characterization, it is important to  evaluate the technology and characterize the baseline
before the technology is used during an actual site characterization.

Like the previous case, this example illustrates how the potential spread of the contaminant
can complicate the selection of investigation sites.  The solution  in this case was to use the
expanded field testing for the purpose of identifying additional sites for sample collection,  as
well as collecting additional data on the tentatively identified contaminant.  The revised plan
also specified the  collection  of at least one  set of samples in  each zone, which is  prudent
since the performance of the expanded field test has not been well  characterized.
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4.2  Approaching the Site
Once the site characterization plan has been customized to a particular situation, the site
characterization team will be dispatched to the investigation site. The next stage of the process is
the approach to the site, which is primarily intended to ensure that conditions are safe for the
team to proceed with the characterization.  This stage will also provide information to refine the
site hazard assessment, as discussed in Section 4.1.3. During the approach to the site, site zones
are established, field safety screening is conducted, and the conditions at the site are observed.
These steps are described in this section.


4.2.1  Establish Site Zones
The site area should be defined and secured If the site  hazard assessment indicates a potential
radiological, chemical,  or biological hazard, HazMat officials will likely establish  a protective
action zone.  This is the zone where specialized PPE is required and may be further defined by
HazMat officials per hazardous materials emergency response guidelines. The boundary of the
protective action zone is referred to as the site perimeter.

A staging area may be  established at the site perimeter to control entrance and exit of personnel
and perform operations such as personnel and equipment decontamination.  If the situation is
deemed hazardous, the  staging area should be located far outside of the protective action zone,
and upwind from the investigation site, in an area that does not require specialized PPE.
Security, law enforcement, or the fire department can secure the area and can help control traffic
into and out of the area. The WUERM should be notified of any site zones that are established at
the site of a suspected contamination incident, even if the WUERM is not the incident
commander.
4.2.2  Field Safety Screening
The goal of field safety screening is to screen the site for potential hazards to determine if
additional safety precautions are necessary as site characterization activities proceed. Field
safety screening is conducted using a field test kit (see Section 3.2.2) and involves an evaluation
of the environment at the site (i.e., in air and on surfaces). Field safety screening begins at the
site perimeter with screening for excessive levels of radioactivity in the vicinity.  Expanded field
safety screening may be conducted for other hazards, such as volatile chemicals, chemical
weapons, and biological contaminants.  However, such equipment should only be used by
individuals trained in its use, and the performance of the equipment should be validated.

The results of field safety screening should be immediately reported to the incident commander
who will instruct the team whether or not to proceed with the site characterization.  The results of
field safety screening should be documented using a form such as the "Field Testing Results
Form" included in Appendix 8.3.


4.2.3  Initial Observation of Site Conditions
Assuming that permission to proceed with site characterization has been granted, the site
characterization team should cautiously approach the site, from upwind if possible. The team
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should begin the investigation by looking for signs that unauthorized individuals might still be at
the site. Potential signs of the presence of intruders include visual observation of individuals,
unexplained vehicles at the site, voices or other noises coming from the site, or unexplained
equipment or materials left at the site.  If it is suspected that intruders may still be present, the
site characterization team should retreat to  a safe location and immediately contact law
enforcement. If the team can do so safely,  they may want to maintain visual contact with the site
until law enforcement arrives (i.e., to observe the activities of the unauthorized individual(s) at
the site).

It is recommended that only one member approach the site while the other remains on the
perimeter maintaining visual and verbal contact at all times. The person on the perimeter should
maintain contact with the incident commander to be able to call for assistance if necessary. The
team member approaching the site should continue to perform field safety screening and observe
the site for potential hazards as he/she approaches the site.  If any signs or evidence indicate
hazardous conditions, the team should exit the site, immediately notify the incident commander,
and return to the vehicle and remain there until assistance arrives.  It is important not to leave the
site completely since decontamination of personnel and equipment may be necessary. Once the
team member approaching the site has completed an initial  observation of site conditions and
determined that it is safe, the other team  member can proceed into the site.

While approaching the site,  all team members should look for indicators of contamination.
These include general evidence  of contamination as well as signs specific to the presence of
chemical contaminants.

General evidence of contamination, including chemical, biological, and radiological material,
may include:
      Discarded PPE  such as gloves, masks, goggles, and protective outerwear.
      Discarded equipment such as tubing, hoses, pumps, sprayers, lab equipment, etc.
      Empty containers unusual for the site (i.e., not litter or other items typically  discarded in
       the area).  Be aware  of containers with labels for biohazards, radiological hazards, or
       chemical hazards.
      Unexplained or unusual  residual material around the site, such as powders, granules, oily
       liquids, and metallic debris.  Such residual material  should be considered a potential
       hazard and should only be handled  or sampled by properly equipped HazMat responders.
      Unexplained or unusual  water conditions, such as oily films, foaming, or discoloration.

Signs specific to the presence of chemical contamination include:
      Evidence of dead/dying/sick animals, beyond normal carrion (e.g., road kill).
      Numerous dead insects in a localized area that are not a result of a local pest control
       program (e.g., spraying for mosquitoes).
      Isolated areas at the  site  where vegetation (bushes, lawns, trees, shrubs, food crops,
       weeds), are dead, discolored, or withered (assuming no drought conditions).
      Numerous oily liquid droplets on surfaces or an oily film on the water surface.
      Unusual odors,  such as those listed  in Table 3-4. It is important to consider whether the
       particular odor is unexpected or unusual for the surrounding area.
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      A low-lying fog that is not explained by current weather conditions.

If any of these obvious signs of chemical contamination are evident, the team should return
to their vehicle at a safe distance from the site until additional help arrives and
immediately contact incident command.  It is important not to retreat beyond the site
perimeter since personnel may inadvertently spread a contaminant if they are not properly
decontaminated before completely exiting the  site.

Specific signs of radiological and biological contamination are less obvious than those associated
with chemical contamination; however, the general evidence of contamination listed above still
applies. The lack of obvious signs of radiological contamination underscores the importance of
including field testing for elevated levels of radioactivity. While there may be no reliable
indicators specific to biological contamination, a disinfectant residual can offer protection
against many pathogens, thus field testing for disinfectant residual is recommended (see Section
4.3.2).

     Table 3-4. Characteristics of Example Chemical Contaminants1
Chemical
Aldicarb
Chloropicrin
Cyanide
Dicrotophos
Lewisite
Mustard
Oxamyl
Phorate
Sarin
Soman
TEPP
VX
Physical State
Solid or powder
Oily liquid
Solid or powder
Liquid
Liquid
Liquid
Crystalline solid
Liquid
Liquid
Liquid
Liquid
Oily liquid
Odor
Sulfur
Sharp and irritating
Bitter almonds
Ester
Geraniums
Garlic
Sulfur
Skunky
Fruity
Fruity
Fruity
Sulfur
Color

Colorless

Yellow-brown


White
Colorless
Colorless
Colorless
Yellow
Colorless
1: These are characteristics of the concentrated chemical and may not be evident if diluted in
water.

At this stage, it is critical to rapidly relay information to incident command, thus the team should
stay in constant communication with the incident commander and report the findings of the
initial site evaluation immediately. The observations made during the approach to the site should
be documented using a form such as the "Site Characterization Report Form" included in
Appendix 8.2.
4.3   Characterizing the Site
Following approval to enter the site, the team will begin the detailed site characterization
process.  The purpose of this stage of the process is to continue activities to evaluate potential
risks to the team and collect information that will inform the threat evaluation process. During
this stage, the team will evaluate site conditions and conduct rapid field testing of the water, as
discussed in the following section.
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4.3.1  Evaluation of Site Conditions
Upon entry to the investigation site, the team should continue field safety screening. Verbal
results should be communicated to the incident commander, and permission to proceed should be
obtained once the team has arrived at the actual site.

The team should continue to evaluate the site for indicators of contamination as discussed in
Section 4.2.3 and document additional findings using the form in Appendix 8.2.  Potential
indicators of contamination or other hazards should be verbally reported to the incident
commander immediately. If included in the sample kit, a camera and/or video camera can be
used to photograph any unusual conditions or findings to assist in the documentation of site
conditions.  If the site is considered hazardous, or a crime scene, special handling of the
equipment and film development will be necessary.

If there are any obvious signs of contamination at the site, the team should return to their
vehicle at a safe distance from the site until additional help arrives and immediately contact
incident command.  It is important not to retreat beyond the site perimeter since personnel
may inadvertently spread a contaminant if they are not properly decontaminated before
completely exiting the site.
4.3.2  Rapid Field Testing
There are three objectives of field testing the water: 1) To provide additional information to
assess the credibility of the threat; 2) To tentatively identify contaminants that would need to be
confirmed by laboratory testing; and 3) To determine if hazards tentatively identified in the water
require special precautions during sampling. Furthermore, the field test results will support the
site hazard assessment process described in Section 4.1.3. Because these results are important
for both the threat evaluation and site hazard assessment, they should immediately be reported to
the incident commander. Results of rapid field testing of the water can be documented using the
"Field Testing Results Form" included in Appendix 8.3.

The field test kit presented in Table 3.3 identifies a core set of rapid field tests for water, which
includes chlorine residual, pH, and cyanide (it may also be possible to test the water for
radioactivity depending on the probe). Table 3.3 also presents several options for expanded
rapid field testing of the water. The decision to include any expanded field testing capability
should be made during general planning for site characterization activities. As discussed in
Section  3.2.2, any field detectors or kits planned for use during site characterization should be
evaluated and characterized with respect to performance, and a baseline established for the
monitored parameter.

Use of detectors or equipment that have not been characterized during an emergency may lead to
greater uncertainty with respect to how to respond. For example, how would one respond to a
positive result from an anthrax test kit without knowledge of the rate of false positive results or
information regarding typical background levels?
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Field test results should be evaluated in the context of the performance characteristics of the test
and should generally be considered tentative until confirmed through some other definitive
means. For example, a negative result may not indicate the absence of a contaminant if the field
test has a high rate of false negative results or is not sufficiently sensitive to detect the
contaminant at levels of concern. Likewise, positive results might be due to interferences or may
represent contaminants other than the target. Thus, positive results should generally be
confirmed through laboratory analysis. While it is important to consider these limitations, 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, as discussed in Module 2.  Results from rapid field testing of the water can also
be used to refine the sampling plan, as discussed in Section 4.1.4.
4.4   Collecting Samples
Following field safety screening and rapid field testing, the site characterization team will collect
samples for possible laboratory analysis. At this stage of the site characterization, sample
collection may be viewed as a precautionary measure to capture the water quality at the location
and time of sample collection. If the threat is determined to be 'credible,' then samples may be
shipped to the laboratory for analysis, as shown in Figure 3-1. If not, the samples should be held
until the investigation is closed.

This section provides general procedures for sampling, as well as procedures specific to chemical
and biological sampling. In addition to the guidance presented in this module, EPA and USGS
have developed sampling guidance for other purposes that  may be relevant to emergency water
sampling. Some useful links to additional sampling guidance include:
      A series of standard operating procedures published by EPA's Environmental Response
       Team at http://www.ertresponse.org/Response Resrcs/index.htm.
      Training developed for EPA on scene coordinators  at
       http ://www. epaosc. org/training.htm.
      USGS field procedures for water sampling at
       http://water.usgs.gov/owq/Fieldprocedures.html.
4.4.1  General Sampling Procedures
The following general guidelines are applicable to sampling for both chemicals and pathogens,
while specific sampling procedures for these two contaminant classes are provided in Sections
4.4.2 and 4.4.3, respectively.

These guidelines are applicable to the collection of samples from investigation sites within the
distribution system, including storage tanks, pressurized pipes, and other distribution system
elements.  In most cases, samples will be collected from a tap connected to the distribution
system element. However, it may be necessary to collect samples from a large body of water,
such as a finished water reservoir. Sampling from such large bodies of water, whether finished
or source water, requires different sampling techniques than those used to  sample from
distribution systems. Guidance developed for the collection of samples from surface water
sources, such as the EPA Environmental Response Team's standard operation procedure #2013,
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may also be applicable to sampling from large finished water reservoirs
(http://www.ertresponse.com/sops/2013-rlO.pdf).

General Water Sampling Guidelines
1) Review the site characterization plan prior to sampling to ensure that all samples are
   collected.
2) Each sample container should be properly labeled using a waterproof marker with the
   following information: analysis, preservative (if any), dechlorinating agent (if any), sample
   location, sample identification, sample collection date and time, and sampler's initials.
   Additional information requested on the sample label should be provided as well.
3) To minimize the time spent on the site during the sample collection stage, it is recommended
   that  sample labels for each container be completed before beginning sample collection.
4) Check for the presence of any in-line filters (e.g., home treatment devices) that might
   interfere with sampling. Remove such devices if present.
5) Flush sample taps for a time sufficient to displace the water in connecting lines in order to
   obtain a representative sample from distribution system element of interest.
   a) Keep the flow rate from the sample tap sufficiently low in order to avoid splashing and
      aerosolizing water droplets. Divert water to a drain if possible.
   b) If the water flushed from the tap might pose a hazard to the discharge area, it may need to
      be collected for decontamination.
6) Critical information for each sample should be documented:
   a) The same information captured on the sample labels should be transferred to a sample
      documentation form to serve as a sample inventory (see Appendix 8.4 for an example
      form).
   b) Sample custody should be closely tracked and documented using a chain of custody form
      (see Appendix 8.5 for an example form).
7) Samples may be considered evidence, and thus should be subject to appropriate security
   measures:
   a) Samples should be under the control of designated personnel at all times.
   b) When samples are not in the possession of designated personnel, they should be secured
      (e.g., locked in a secure area) and only accessible by designated personnel.  In the field,
      samples may need to be locked in a vehicle.
   c) Chain of custody should be initiated immediately after sample  collection.
   d) If necessary, duplicate samples can be collected for law enforcement.
   e) If necessary, take photographs of the samples at the site of collection as another form of
      sample documentation.
8) If 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.
9) If the decision is made to hold samples rather than send them to the laboratory  for immediate
   analysis, the following precautions should be taken:
   a) Samples should be chilled, but protected from freezing.
   b) Samples should be held until the threat evaluation has been completed and the decision
      has been made to either analyze the samples or close the investigation.
   c) The shortest holding time for a particular analysis will dictate the maximum time that
      samples should be held prior to analysis. Holding times for preserved samples are
      contained in their respective analytical methods (see Module 4), and are typically 7-28
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       days for properly preserved samples, although the respective analytical method should be
       consulted for details about holding samples.  If it is necessary to store unpreserved
       samples, the stability of the target analyte in water should be considered  when
       determining how long an unpreserved sample might be stored.

It is important to follow any special laboratory requirements regarding sample collection and
transport since this may affect the quality of the analytical results.  For example, some
procedures or laboratories may require analysis of special QC samples such as field duplicates,
field blanks, trip blanks, and field matrix spikes. There may also be specific chain of custody,
notification, and shipping requirements. Arrangements should be made with a laboratory prior to
an incident so that samplers are aware of, and can prepare for, any special requirements.

It may also be advisable to collect backup samples in case there is a problem with the set that is
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).  Backup samples
should be properly stored, secured, and tracked such that the integrity of the samples is
maintained. While collection of individual backup samples may be appropriate  in some cases, it
may be logistically simpler to collect a large volume sample in a 10-liter container as a backup.
4.4.2  Chemical Sampling Procedures
The following procedures are appropriate for collecting samples for chemical analysis from
drinking water distribution systems.  If samples need to be collected from a large body of water
without a suitable sample tap, the surface water sampling guidelines referenced in Section 4.4.1
may be used. If the samples are considered to be hazardous, it may be necessary to implement
certain hazardous materials sampling techniques, as discussed in Section 4.1.4, in addition to the
guidelines presented below.

General Water Sampling Procedures for Chemical Contaminants
1.  Carefully fill sample containers with water flowing from the sample tap. Avoid splashing or
   aerosolizing water droplets during sample collection. Do not use rubber or plastic tubing for
   the collection of samples for chemical analysis
2.  Do not rinse or overfill the sample containers. This is especially important if the sample
   container contains a preservative or dechlorinating agent.
3.  If necessary, add any preservatives and/or dechlorinating agents.  Preservatives and/or
   dechlorinating agents may be added to the sample containers during sample kit preparation,
   which can significantly decrease  the complexity and time required for sample collection.
   (See note on preparation of pre-preserved sample containers in Section 3.2.1.)
4.  If necessary, adjust the pH of the sample per method instructions.
5.  When sealing sample containers that have open top caps and septa,  make certain that the
   Teflon side  (smooth side) is facing towards the water.
6.  VOC samples should be collected with no headspace.
7.  For containers with closed top caps (pesticides, etc.) attempt to fill the container to the top
   leaving very little or no headspace.
8.  Wipe the outside of the sealed containers with an antiseptic wipe or a mild bleach solution if
   deemed necessary.
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9.  If the sample container is not pre-labeled, place a label on the container and complete the
   requested information. Transfer the information on the sample label to the sample
   documentation form (Appendix 8.4).
10. Attach a custody seal to the individual sample container, if required by the organization
   responsible for sample collection and handling. In some cases, it may be sufficient to place
   the custody seal on the shipping container rather than the individual sample containers
   themselves. Record the information on chain of custody record (Appendix 8.5).
11. Place the sample container into a sealable plastic bag (bubble wrap baggies can provide
   protection against breakage of glass sample containers).
12. Place the sealed plastic bags containing the samples into an appropriate, rigid shipping
   container and pack with frozen ice packs (preferred) or sealable freezer bags filled with ice.
   If ice is used, the bag should be thoroughly sealed to avoid leakage.  See Section 6 for more
   details on sample packaging and shipment.
4.4.3  Microbiological Sampling Procedures
Sampling for microbiological contaminants is closely coupled to the analytical approach for
pathogens as discussed in Module 4, Section 8.  In particular, there are two general approaches to
pathogen sampling and analysis that depend on whether or not a pathogen has been tentatively
identified, as illustrated in Figure 3-4.
                                       Specific
                                       Microbial
                                      Tentatively
                                      Identified?
                                                       Perform Unknown
                                       stablishe
                                     Concentration
                                       Method
                                      Available?
     Perform Unknown
        Microbial
      Concentration
        Procedure
                                        Virus
                                        Filter
                                     Concentration
                                      in the Field
  Protozoa
 10 Liter Grab
Sample or Filter
 Concentration
          Figure 3-4.  Sampling Approach for Microbial Contaminants
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If the microbiological contaminant has been tentatively identified and has an established
analytical technique suitable for water, then samples should be collected in accordance with that
technique.  However, established and validated sample collection and analytical techniques for
microbial contaminants in water are limited to a few pathogenic microorganisms, principally
enteric bacteria, viruses and protozoa, and a few other organisms with known waterborne
transmission. Module 4, Section 8.2 provides additional information on those pathogens with
established analytical techniques.  Figure 3-4 indicates the following sampling approach for
bacteria, virus, and protozoa:
       Bacteria: collect a four-liter grab sample for membrane filtration and culture of several
       different types of bacteria through use of selective media.
       Virus: filter between 100 and 1,200 liters of water through a positively charged filter
       (ICR Microbial Laboratory Manual, EPA/600/R-95/178, April 1996,
       http://www.epa.gov/nerlcwww/). The processed filters can be  shipped to the laboratory
       or viruses adsorbed to the filter can be eluted in the field and shipped as a one-liter
       retentate (or concentrate) to a laboratory for further processing by conventional
       procedures.
       Protozoa: collect a 10-liter grab sample for shipment to a laboratory where it is filtered
       to concentrate the protozoa for subsequent processing and analysis (Method 1623:
       Cryptosporidium and Giardia in Water by Filtration by IMS/FA, EPA-821-R-99-006,
       April  1999, http://www.epa.gov/nerlcwww/). Another alternative is to perform the
       filtration in the field, similar to the approach for virus.

Many microbiological methods also specify the addition of a dechlorinating agent in order to
maintain the viability of the organisms so that they can be cultured.  The established method for
the target microbiological contaminant should be consulted to determine the appropriate
dechlorination and preservation techniques.

If the microbial contaminant is unknown, sample collection is performed through the use of
ultrafiltration, which is a membrane filtration process that retains particles, including
microorganisms, larger than the molecular weight cut-off (MWCO) of the membrane. The
solution containing the concentrated particles and pathogens is called the retentate, while the
water that passes through the ultrafiltration membrane is called the filtrate. Ultrafiltration can
concentrate viruses, bacteria, spores, and parasites if the MWCO is sufficiently small. Thus, the
method is suitable for sampling water with an unknown microbiological contaminant.

There are several reasons for using the ultrafiltration sampling approach rather than sampling for
one or more specific pathogens using existing, standardized methods.  First, the sample may
contain a mixture of microbial contaminants; thus use of methods for specific pathogens may
miss other pathogens that are present. Second, due to the low oral infectious dose of most
waterborne pathogens, a sample of 100 liters of finished water may need to be concentrated to
obtain a suitable level of sensitivity. Third, sample concentration methods for viruses and
protozoa require separate field equipment and procedures and are practical only if the microbial
contaminant is suspected or identified as one amenable for concentration by each of these
specific technologies. Thus, it may be necessary to utilize a more general sample concentration
procedure based on ultrafiltration since it targets a wider range of microorganisms.
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In general, the ultrafiltration procedure involves the concentration of a large (100 liters or more)
volume of water using an ultrafiltration field concentration apparatus, such as that shown in
Figure 3-5. The basic elements of this apparatus include an input reservoir for sample collection,
a peristaltic pump, a cross-flow hollow fiber membrane cartridge, a retentate reservoir and a
filtrate reservoir.  Operating the unit in cross-flow mode is preferable because the high velocity
of water scours the membrane surface, preventing excessive deposition of material on the
surface. Non-reactive membranes are preferable such as polysulfone or low protein binding
membranes.

Sample filtration is conducted by recirculating water (necessary to maintain cross-flow
conditions) with a 5-10 psi differential between the feed and filtrate pressure. The  pressure
differential forces water through the hollow fiber membrane, while particles and microorganisms
are concentrated in the retentate. The volume of the retentate is reduced to approximately 250
mL by recirculating the concentrated sample through the smaller retentate loop for capture in the
retentate reservoir.  The retentate reservoir vessel can be used for sample shipping if necessary.
The sample retentate can also be recovered by backflushing (reversing the flow through of the
hollow fiber membrane cartridge). Research is currently underway to refine the design of the
ultrafiltration apparatus, and future versions of this module will provide more detail on its design
and operation.
                          3-way valve
                                                        Ultra filter
                                                                         Filtrate
                                                                        reservoir
                                                      Pressure
                                                       gauge
Figure 3-5. Ultrafiltration Field Concentration Apparatus
Some of the general water sampling procedures listed for chemicals also apply to sampling for
pathogens, as listed below.
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General Water Sampling Procedures for Microbiological Contaminants
1.  Avoid splashing or aerosolizing water droplets during sample collection or field
   concentration.
2.  Do not rinse or overfill the sample containers.  This is especially important if the sample
   container contains a preservative or dechlorinating  agent.
3.  Any sample aliquot collected for culture analysis should be handled in a manner such that
   viability of the microorganisms is maintained.
4.  If necessary, add any preservatives and/or dechlorinating agents.  Preservatives and/or
   dechlorinating agents may be added to the sample containers during sample kit preparation,
   which can significantly decrease the complexity and time required for sample collection.
   (See note on preparation of pre-preserved sample containers in Section 3.2.1.)
5.  Wipe the outside of the sealed containers with an aseptic wipe or a mild bleach solution.
6.  If the sample container is not pre-labeled, place a label on the container and complete the
   requested information. Transfer the information on the sample label to the sample
   documentation form (Appendix 8.4).
7.  Attach custody seal to the individual sample container, if required by the organization
   responsible for sample collection and handling. In  some cases, it may be sufficient to place
   the custody seal on the shipping container rather than the individual sample containers
   themselves. Record the information on chain of custody record (Appendix 8.5).
8.  Place the sample container into a sealable plastic bag (bubble wrap baggies can provide
   protection against breakage of glass sample containers).
9.  Additional instructions for packaging samples potentially containing infectious biological
   contaminants are provided in Section 6.
10. Place the sealed plastic bags containing the  samples into an appropriate, rigid shipping
   container and  pack with frozen ice packs (preferred) or sealable freezer bags filled with ice.
   If ice is used, the bag should be thoroughly  sealed to avoid leakage. See Section 6 for more
   details on sample packaging and shipment.
4.5   Exiting the Site
For a site characterized as a low hazard, it should not be necessary to implement extensive
procedures for exiting the site. The following general precautions are recommended when
exiting a low hazard site:
       Verify that any hatches, locks, etc., are properly secured before leaving the site.
       Collect all samples, equipment, and materials and move them to the site perimeter.
       Anything brought onto the site should be removed from the site.
       Make sure that all samples are in the cooler(s) along with ice packs and that the cooler is
       sealed with chain of custody tape, if applicable.
       Remove all PPE at the site perimeter, and place disposable PPE, along with any other
       garbage, into the heavy-duty plastic trash bag. Close the bag securely.
       Place all equipment, samples, and the sealed plastic trash bag into the vehicle.
       If the site has perimeter security (e.g., a fence and gate), verify that the perimeter has
       been properly secured before leaving the site.
       Ensure that all forms have been completely filled out before leaving the site.
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If the site was categorized at a higher hazard level and/or if the site is considered a crime scene,
then special procedures for exiting the site will likely be required by HazMat officials or law
enforcement. For example, personnel and equipment may be required to undergo
decontamination prior to exiting the site, and access to the site is likely to be tightly controlled.
If the site is considered a crime scene, the site may be secured by law enforcement, and qualified
investigators will be responsible for collecting any physical evidence from the site (such as
empty containers, dead animals, etc.).  A detailed discussion of site exit procedures required
under these conditions is beyond the scope of this document, and will likely vary depending on
the organization responsible for incident command and site characterization.
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5    Site Characterization Report

In order to provide useful information to support the threat evaluation process and the
development of an analytical approach, the findings of the site characterization should be
summarized in a report.  This report is  not intended to be a formal document, but simply a
concise summary of information from the site activities that can be quickly assembled within an
hour or two. The recommended content of the report includes:
       General information about the site.
       Information about potential  site hazards.
       Summary of observations from the site evaluation.
       Field safety screening results, including any appropriate caveats on the results.
       Rapid field water testing results, including any appropriate caveats on the results.
       Inventory of samples collected, and the sites from which they were collected.
       Any  other pertinent information developed during the site characterization.

The "Site Characterization Report Form" (Appendix 8.2), "Field Testing Results Form"
(Appendix 8.3), and "Sample Documentation Form" (Appendix 8.4) are designed to record most
of this information during site characterization activities, and these completed forms may serve
as the core of the site characterization report.  If multiple investigation sites were characterized in
response to a particular threat, the results from all site characterization activities should be
assembled into a single report.

The information contained in the site characterization report will likely be used to support
several follow-on activities:
       Hazard assessment of the site.
       Threat evaluation.
       Implementation of precautionary actions to protect public health.
       Estimate  of the spread of the contaminant.
       Analytical plan (including the decision regarding whether or not to analyze samples).

These activities lead into the latter phases of the response to  a contamination threat, which are
discussed in other modules of the "Response Protocol Toolbox."

The site hazard assessment should be completed at the conclusion of site characterization
activities; thus, it may only be necessary to document the conclusions of the assessment in the
report. This provides the incident commander with an overall understanding of the site hazard
conditions and provides the opportunity to revise the assessment, if necessary.

Following site characterization, a significant amount of new information should be available to
support the threat evaluation initiated at the time threat warning is received (see Module 2).
Thus, the threat evaluation should be revised following review of the results from the site
characterization. In many  cases, these results will be critical to the determination regarding
whether or not the contamination threat is 'credible.' This determination should be documented
in the "Threat Evaluation Worksheet" included in Module 2, Appendix 8.2.  This revised
worksheet should be included at the front of the site characterization report since it represents the
outcome of the site characterization activities.
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The revised threat evaluation will dictate the next steps in the response process (sample analysis,
public health response, and remediation/recovery).  If the threat is determined to be 'not credible'
following site characterization, then the investigation may be closed and the system returned to
normal operation. On the other hand, if the threat is deemed 'credible' at this stage, it may be
necessary to take steps to protect public health as the response progresses. This may require an
estimate of the spread of the suspected contaminant through the system, and the site
characterization results may support such an analysis (particularly if multiple investigation sites
were characterized).

If a decision is made to analyze the samples collected from the site in an attempt to 'confirm' a
contamination incident, it will be necessary to develop an analytical approach. The site
characterization report can serve as a valuable resource when developing the analytical approach;
thus it is critical that the laboratory and other parties involved in designing the analytical plan
have immediate access to the report. A briefing among relevant parties is  recommended in order
to transition from site characterization to laboratory analysis.  The development of an analytical
approach, and the link between  site characterization and  sample analysis, is described in Module
4, Section 5.

Finally, it is important to maintain records of all site characterization activities, even for
incidents that were ultimately dismissed as 'not credible.' Good records management practices
are important since documentation about a particular activity might need to be accessed later,
long after the details of the incident have faded from memory.  Furthermore, by maintaining
documentation about all threat warnings that occur at a utility, a historic record can be
established that may help in evaluating future threats.  Such a record is considered as a potential
information resource in the threat evaluation process (see Module 2, Section 4.1.2).
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6   Sample Packaging and Transport

In order to perform analysis of samples beyond rapid field testing, it will be necessary to
properly package the samples for transport to the appropriate laboratories as quickly as possible.
Prompt and proper packaging and transport of samples will:
      Protect the integrity of samples from changes in composition or concentration caused by
       bacterial growth or degradation that might occur at increased temperatures.
      Reduce the chance of leaking or breaking of sample containers that would result in loss
       of sample volume, loss of sample integrity, and potential exposure of personnel to
       hazardous substances.
      Help ensure compliance with shipping regulations.

Sampling packaging and transport is governed by a number of regulations, as administered by
the International Air Transport Association (IATA, http://www.iata.org/) and the U.S.
Department of Transportation (DOT, http://www.dot.gov/).  In addition, there may be additional
requirements specified by states, local authorities, and/or shipping companies. The regulations
and requirements that govern the packaging and transport of samples will depend on the nature
of the material in the samples. The pertinent regulations are largely based on whether the
samples are classified as a hazardous material.  Hazardous material is defined as any substance
that appears in the 49 CFR Hazardous Materials Table  (http://hazmat.dot.gov/rules.htm), subject
to certain exemptions based on the quantity and concentration of material.

For the purpose of this module, two general classes of samples are considered: environmental
samples and hazardous samples. Environmental samples are those collected from environmental
media, such as natural or treated waters, that are not expected to be contaminated with hazardous
materials at concentrations that would pose a risk to unprotected personnel. The vast majority of
water samples collected are expected to be classified as environmental samples.

Hazardous samples typically consist of concentrated hazardous materials (as defined above), and
they are typically collected from drums,  tanks, lagoons, pits, waste piles, fresh spills,  or areas
previously identified as contaminated. Accordingly, they require special handling procedures
due to their potential toxicity or hazard.  The distinction between environmental samples and
hazardous samples becomes blurred when hazardous materials might be present in an
environmental sample at unknown concentrations.

The decision regarding the classification of a sample as environmental or hazardous may be
based on the hazard classification of the site from which samples were collected.  In Section
4.1.3, four broad site hazard categories are defined for the site of a suspected water
contamination incident: low, radiological, hazardous chemical, and infectious biological agent.

Samples collected from a low hazard site may be considered environmental samples in most
cases.  By contrast, samples collected from sites categorized as a radiological, chemical, or
biological hazard may be classified as potentially hazardous materials. However, the use of
certain sample collection techniques, such  as dilution and UV irradiation (as discussed in Section
4.1.4), may reduce the hazard and allow samples to be considered environmental.  Following is
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some general information regarding packaging and transport of low hazard (environmental) and
high hazard samples.


6.1  Low Hazard Samples

6.1.1  Packaging
The sampling procedures in Section 4.4 end with the sample being placed into a prepared cooler.
Cooler preparation is an important part of packaging, and it is imperative that samples are
correctly and carefully packed in shipping containers to prevent the sample containers from
breaking or leaking. Following are steps in preparing a cooler:

   1.  Use a clean cooler to prevent cross contamination.  Seal all drain holes of the cooler, both
       inside and out, to prevent leakage in the event of a compromised sample container.
   2.  Check all lids/caps to make sure they are tightly sealed and will not leak.
   3.  Seal samples within a clear plastic bag.
   4.  If possible, fully chill samples to 4C or less prior to placement within suitable packing
       materials.
   5.  For additional protection in case of breakage, the cooler may be lined with non-
       combustible, absorbent packing material such as rock wool, ground corncobs, perlite, or
       clay-based absorbents (e.g., kitty litter or 'oil dry ').
   6.  After the samples are placed in the cooler, conduct an inventory of the contents of the
       shipping cooler  against the corresponding sample inventory and chain of custody records.
   7.  Cover samples in double-bagged ice, or frozen ice packs, to prevent water damage to
       packing materials. Do not pour loose ice directly into the sample cooler. The bagged ice
       will maintain the temperature of the samples within the shipping cooler.
   8.  A temperature blank may be included within each cooler being shipped. The temperature
       blank may be a 40 mL vial filled with water and labeled "temperature blank." There are
       also "memory" thermometers and other data-logging devices available for this purpose.
   9.  Include necessary paperwork (copies of sample documentation and chain of custody
       forms) in the cooler. It may be convenient to place all of this in a plastic bag or pouch
       and affix it to the underside of the lid of the cooler. The original documentation should
       be maintained by the utility.
   10. After the contents of the cooler have been checked for completeness, all openings of the
       cooler should be sealed with tape.  Correct chain of custody seals, if required, should be
       attached to the cooler in a manner such that it would be apparent if the cooler has been
       opened prior to laboratory receipt.
   11. Prepare the cooler appropriately for shipping depending on the way the container is to be
       transported.
   12. Clearly label the cooler with the address of the laboratory where the samples are to be
       sent.
6.1.2  Transport
In some cases, it may be desirable to have the site characterization team transport the samples
directly to the laboratory. During sample transport, it is important that the team take steps to
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maintain sample integrity and chain of custody. Maintaining sample integrity may involve
delivering the samples to the laboratory as soon as possible, without making any unnecessary
stops. Lengthy, unnecessary stops may allow time for the samples to degrade, even when the
samples are chilled, reducing the quality of the results. Coolers also have limited insulation
value, so if a cooler is left in a warm vehicle while the driver performs errands, the samples
could heat up, potentially degrading some sample components.  In addition, leaving the sample
unattended may violate chain of custody procedures, which must be observed at all times. If it is
necessary to hand over control of the cooler to another responsible party, this transfer should be
noted on the chain of custody form.

While the site investigation team would typically deliver samples by ground transportation, some
transport may be accomplished by  air, i.e., airplanes or helicopters. In this case, those
responsible for sample transport should consider the effects of their flight patterns on integrity of
the samples. For instance, sudden  changes in air pressure might cause some previously sealed
containers to burst or vent.

In other cases, the only option may be to use an overnight shipping company to deliver the
samples to the laboratory.  Many shipping companies currently do not have special requirements
for shipment of environmental water samples in coolers, other than leak prevention.  If overnight
shipping is to be used, the site characterization team should have ready access to all pertinent
information about the shipping company, including: name, phone number, hours of operation,
shipping schedule, any special shipping requirements, and pick-up/drop-off requirements. There
is a block for this information in the "Site Characterization Plan Template" in Appendix 8.1.
Chain of custody is also important when using an overnight shipping service.  Snipping records
should be maintained as part of documenting chain of custody. Most major companies are able
to maintain chain of custody upon  sample receipt, although this should be verified.
6.2  High Hazard Samples
In general, HazMat teams will likely have packaging and shipping procedures for high hazard
samples that might contain radiological, chemical, or biological contaminants.  It is important to
verify that local HazMat teams that might assist in site characterization activities do have the
procedures and capabilities in place to transport hazardous samples. A brief overview of
considerations for shipment of high hazard samples is provided below.
6.2.1  Packing
Hazardous materials shipments must be packaged in compliance with sections 173.24 and
173.24a of 49 CFR (http://hazmat.dot.gov/rules.htm). Often this is accomplished by the use of
United Nations Performance Oriented Package. In 49 CFR, hazardous materials are divided into
nine classes, which refer mostly to concentrated materials.  Relevant classes for high hazard
water samples include Class 2.3 (poisonous gases), Class 6.1 (poisonous materials, inhalation
hazard), Class 6.2 (infectious substance), and Class 7 (radioactive substances).

Radiological Hazards. Packaging of radioactive materials is regulated under CFR 49 173.401-
173.476 as a Class 7 material. In general, for Class 7 materials the package may consist of one
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or more receptacles, absorbent materials, spacing structures, thermal insulation, radiation
shielding, devices for cooling or absorbing mechanical shocks, and service equipment for filling,
emptying, venting and pressure relief. The conveyance, tie-down system, and auxiliary
equipment may sometimes be designated as part of the packaging.  The type of packaging is
dependent on the nature of the radioactive hazard (specific radionuclide and amount of
radioactivity). Trained hazardous materials responders should select of the most appropriate
packaging for a specific radioactive hazard.

Chemical Hazards. Chemical hazards may be broken down into chemical warfare agents,
biotoxins, and conventional toxic chemicals (e.g., cyanide, pesticides, industrial chemicals, etc.).
Packaging requirements for chemical hazards are similar to those for low hazard chemicals
except that special care is necessary to prevent release of the contaminated water, as might occur
through water leaks or volatilization. Preventing such release may involve providing  multiple
layers of containment, and a regular cooler by itself might not offer appropriate protection.
Placing  the sample inside an approved shipping container, which in turn is placed inside the
cooler, may satisfy the packaging requirement. Some approved shipping containers include a
temperature control system (i.e., freezer packs), so the cooler may not be necessary. Approved
containers that meet regulatory requirements are readily available since hazardous materials are
packaged and shipped routinely in a number of industries. There may be volume or weight
limits to the quantity of water that may be packaged in an approved container, largely due to
limitations in the structural integrity of the container.

Transport of hazardous materials requires proper labeling and declaration of hazards.  This
labeling and declaration may be necessary even if a commercial shipper is not used. For
instance, if samples are transported to the laboratory by vehicle, it is important that the content,
and potential  hazards, of the packages by clearly documented to facilitate proper safety and
handling precautions during transfer of sample custody.

A special situation exists for chemical weapons. Following collection, the samples must be
placed under  a tent for a set period of time and the tent monitored for the potential release of
chemical weapon vapors using a suitable detector. If chemical weapons are suspected, law
enforcement should be contacted as they will have access to expertise and procedures for safely
packaging and transporting these types of samples.

Biological Hazards. Packing requirements and procedures for biological samples have been
developed by the CDC to facilitate safe shipment of the samples to LRN laboratories, which may
be found at http://www.bt.cdc.gov/labissues/PackagingInfo.pdf  In summary, triple packaging
(primary receptacle, water tight secondary packaging, and durable outer packaging) is required
for infectious biological agents or materials that are known or suspected of containing them.

For biological hazards,  the "Infectious Substance" label (shown at the web site listed above)
must be placed on the outside of the package. This packaging must be certified to meet rigorous
performance tests as outlined in the IATA, DOT, USPS,  and PHS regulations.  Detailed
information about this packaging is found in "Biosafety in Microbiological  and Biomedical
Laboratories," United States Department of Health and Human Services, 4th Ed., edited by J.Y.
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Richmond and R.W. McKinney, U.S. Government Printing Office, 1999.  This document is also
available at: http://www.cdc.gov/od/ohs/biosfty/bmbl4/bmbl4sl.htm.

Currently, the largest available container size that meets the CDC shipping requirements is four
liters; however, CDC is working on packaging designs to accommodate 10-liter samples. There
are also specific requirements and guidance available for certain agents, such as anthrax,
http://hazmat.dot.gov/guide_anthrax.htm, although the applicability of this guidance to water
samples should be carefully considered.
6.2.2  Transport
Many of the same principles that apply to the transport of low hazard samples also apply to high
hazard samples, assuming they are properly packaged and labeled.  Depending on the nature of
the hazard, law enforcement may be involved in the transport of hazardous samples, especially if
the services of a specialty laboratory are required.  For instance, if chemical weapons are
suspected, a technical escort service from the military may take custody of the samples and
transport them to a chemical weapons laboratory. Other technical escort services are available
for a variety of samples, but this resource is limited and may be accessed only through specific
channels, such as law enforcement.

Many commercial shipping companies (such as FedEx, UPS, USPS, etc) have varying policies
regarding labeling and documentation, some based on regulatory requirements, for overnight
shipping of hazardous materials..  Some  companies offer free advice and training on packaging
and shipping such samples. The site characterization team should be familiar with the regulatory
requirements, as well as other shipping company policies. In general, commercial shipping
companies may transport some many hazardous samples provided that packaging and declaration
requirements are fulfilled. However, the shipper may not pick up potentially hazardous samples,
but require that they be delivered to the shipping center.

Maintaining and documenting the chain  of custody is important when using an overnight
shipping service for both high hazard and low hazard samples.  Shipping records should be
maintained as part of documenting chain of custody, and  it should be verified that the company
can maintain chain of custody throughout the delivery process.

As part of planning activities, it is recommended that a potential shipping company be contacted
with a request for their lists of allowable and prohibited hazardous materials.  The prohibited
materials often include substances  within the following classes: Class 2.3 (poisonous gases),
Class 6.1 (poisonous materials, inhalation hazard), Class  6.2 (infectious substances), and Class 7
(radioactive material II and III). Thus, many hazardous substances may be listed as prohibited
materials by many commercial shipping  company. For example, it is unlikely that a commercial
shipper could transport a sample containing chemical warfare agents. However,  exemptions to
these policies may be available for some hazardous materials. For example, many infectious
substances may be acceptable if packaged according to CDC guidelines, which were designed
with shipping regulations in mind.  Exemptions will vary from company to company.
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7   References and Resources

References and information cited or used to develop this module are listed below. The URLs of
several sources are cited throughout the text. These URLs were correct at the time of the
preparation of this document. If the document is no longer available at the URL provided, please
search the sponsoring organization's Web site or the World Wide Web for alternate sources. A
copy of referenced documents may also be provided on the CD version of this module, although
readers should consult the referenced URL for the latest version.

Chemical Hazards Response Information System  (CHRIS), http://www.chrismanual.com

FBI Handbook of Forensic Services
http ://www.fbi. gov/hq/lab/handbook/intro.htm

Hazardous Materials Guide for First Responders.  http://www.usfa.fema.gov/fire-
service/hmgfrS .cfm

Interagency Intelligence Committee on Terrorism (IICT). Chemical/Biological/Radiological
Incident Handbook. October 1998. http://fas.org/iip/threat/cbw/CBR  hdbk.htm

National Institute of Justice. U.S. Department of Justice. An Introduction to Biological Agent
Detection Equipment for Emergency First Responders, NIJ Guide 101-00. December 2001.
http ://www. oj p .usdoj. gov/nij /pub s-sum/190747. htm.

National Institute of Justice. U.S. Department of Justice. Guide for the Selection of Chemical
Agent and Toxic Industrial Material Detection Equipment for Emergency First Responders, NIJ
Guide 100-00. June 2000.  http://www.ojp.usdoj.gov/nij/pubs-sum/184449.htm.

NIOSH Emergency Response Resources, http://www.cdc.gov/niosh/topics/emres/

OSHA, 2002, "Safety and Health Topics Personal Protective Equipment"
http://www.osha.gov/SLTC/personalprotectiveequipment/index.html

OSHA, 2003a, "OSHA e-HASP Software -Version 1.0, September 2003"
http ://www. osha. gov/dts/osta/oshasoft/ehasp/

OSHA, 2003b, "Occupational Safety and Health Administration Homepage"
http ://www. osha. gov

U.S. Army Soldier and Biological Chemical Command. Law Enforcement Officers  Guide for
Responding to Chemical Terrorist Incidents.  January 2003.

Standard Emergency Management System (SEMS) Guidelines
http://www.oes.ca.gov/Operational/OESHome.nsf/Content/B49435352108954488256C2A0071E
038?OpenDocument

U.S. Environmental Protection Agency. On Scene Coordinator homepage
http://www.epaosc.org
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U.S. Environmental Protection Agency.  On Scene Coordinator Training
http ://www. epaosc. org/training.htm.

U.S. Environmental Protection Agency.  Chain of Custody guidelines
http ://www. epa. gov/safewater/certlab/laba.html

U.S. Environmental Protection Agency.  Environmental Technology Verification program for
field detection technologies, http://www.epa.gov/etv/

U.S. Environmental Protection Agency.  Environmental Response Team.  Standard Operating
Procedures.  http://www.ertresponse.org/Response Resrcs/index.htm.

U.S. Environmental Protection Agency.  Environmental Response Team.  Health and Safety.
http://www.ertresponse.com/health safety/index.htm

U.S. Environmental Protection Agency.  Environmental Response Team. General Field
Sampling Guidelines Standard Operating Procedure (#2001). August 11, 1994.
http://www.ertresponse.com/sops/2001.pdf.

U.S. Environmental Protection Agency.  Environmental Response Team. Surface Water
Sampling Standard Operating Procedures (#2013). January 17, 2002.
http://www.ertresponse.com/sops/2013-rlO.pdf

U.S. Environmental Protection Agency.  ICR Microbial Laboratory Manual, EPA/600/R-95/178,
April 1996, http://www.epa.gov/nerlcwww/

U.S. Environmental Protection Agency.  Method 1623: Cryptosporidium and Giardia in Water
by Filtration by IMS/FA, EPA-821-R-99-006,  April 1999, http://www.epa.gov/nerlcwww/

U.S. Geological Survey.  Field Procedures for  Water Sampling
http://water.usgs.gov/owq/Fieldprocedures.html.
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8   Appendices
 8.1   Site Characterization Plan Template

 INSTRUCTIONS
 This form is intended to support in the development of a customized site characterization plan
 developed in response to a specific water contamination threat. The incident commander and
 site characterization team leader should develop this plan jointly if possible. The completed
form will be used to guide site characterization activities in the field; however, it may be
 necessary to revise the initial plan based on initial observations at the site. A form should be
 completed for each investigation site that will be characterized.

 THREAT WARNING INFORMATION
    Consult Module 2, Appendix 8.2 "Threat Evaluation Worksheet" for details about the
    threat.

 INVESTIGATION SITE
    Site Name: 	
     Type of facility:
       D Source water
       D Ground storage tank
          reservoir
       D Distribution main
       D Other      	
D Treatment plant
D Elevated storage tank

D Hydrant
D Pump station
D Finished water

D Service connection
    Address:
    Additional Site Information:
INITIAL HAZARD ASSESSMENT
    Are there any indicators of an explosive hazard?            D  Yes
       If "Yes," notify law enforcement and do not send a team to the site.
                                      D No
     Initial hazard categorization
       D Low hazard                            D Chemical hazard
       D Radiological hazard                     D Biological hazard
       If the initial hazard assessment indicates a chemical, radiological, or biological hazard
       (as described in Module 3, Section 4.1.3), then only teams trained to deal with such
       hazards should be sent to the site.
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SITE CHARACTERIZATION TEAM
    Name & Affiliation of Site Characterization Team Leader:
    Drinking water utility staff:
       D  Water quality specialist    Name:
       D  Security specialist         Name:
       D  Operations specialist      Name:
       D  Other	    Name:
    Representatives from other agencies:
       D   Local law enforcement    D Fire department
       D   US EPA                 D FBI
                          D HazMat
                          D Other
COMMUNICATION PROCEDURES
    Mode of communication:
       D  Phone
       D  Facsimile

    Reporting events:
       D  Upon arrival at site
       D  After site evaluation
       D  Other
D 2-way radio
D Other
D During approach
D After field testing
D Digital
D Site entry
D Site exit
FIELD SCREENING CHECKLIST












Parameter
Radiation
Chlorine residual
pH / conductivity
Cyanide
Volatile
chemicals
Chemical
weapons
Biotoxins
Pathogens



Screen
Both
Water
Water
Water
Safety
Both
Water
Water



Meter/Kit ID3











Check Date4











Reference Value











    1. List the parameters that will be evaluated as part of field screening (examples are listed).
    2. Screening may be conducted for safety, rapid water testing, or both.
    3. Report the unique identifier for the meter or kit used during screening.
    4. Report date of last calibration, expiration date, or date of last equipment check as
       appropriate.
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    5. List any reference value that would trigger a particular action, such as exiting the site.

SAMPLING CHECKLIST


















Analyte1
Standard VOCs
Semi-volatiles
Quartenary nitrogen
compounds
Cyanide
Carbamate pesticides
Metals/elements
Organometallic compounds
Cyanide
Radionuclides
Non-target VOCs
Non-target organic
compounds
Non-target inorganic
compounds
Immunoassays
Pathogens - culture
Pathogens - PCR
Water quality - bacteria
Water quality - chemistry
No.
Samples

















Sample Preservation2

















    1. List the parameters that will be sampled during site characterization (examples are
        listed).
    2. List preservatives and dechlorinating agents and indicate if they are to be added in the
        field.
EQUIPMENT CHECKLIST
    D Completed Site Characterization Plan
    D Emergency Water Sampling Kit (Table 3-1)
    D Reagents (if stored separately)
    D Laboratory grade water (5 gal)
    D Special equipment for the specific site
    D Other
D Additional documentation
D Field Testing Kit (Table 3-3)
D Bags of ice or freezer packs
D Rinse water (20 liters)
D Disposable camera
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SAMPLE HANDLING INSTRUCTIONS
    Sample delivery:
       D  Return samples to water utility
       D  Ship samples to specified location
       D  Deliver samples to specified recipient (e.g., laboratory, law enforcement, shipping co.,
          etc.)

       Name of recipient: 	

       Phone No.:                                     Fax No.:
      Delivery address:
    Sample storage and security:
      Describe any special precautions or instructions related to sample storage and security:
SIGNOFF
  Incident Commander (or designee responsible for developing Site Characterization Plan):
     Print name  	
     Signature   	   Date/Time: 	
  Site Characterization Team Leader:
     Print name
     Signature   	   Date/Time:
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8.2   Site Characterization Report Form

INSTRUCTIONS
Members of the site characterization team can use this form to record their observations at the
investigation site.  It also serves as a checklist for notifying incident command at key points
during the characterization. Additional checklists are included in this form for sample collection
and exiting the site.  The completed form can also be used as a component of the site
characterization report. A form should be completed for each investigation site that is
characterized

GENERAL INFORMATION
    Date: 	               Time arrived investigation at site:  	
    Name of Site Characterization Team Leader:
    Phone No.:  	             Fax No.:

LOCATION OF INVESTIGATION SITE
    Site Name:  	
    Type of facility:
       D  Source water               D  Treatment plant          D  Pump station
       D  Ground storage tank        D  Elevated storage tank     D  Finished water
          reservoir
       D  Distribution main           D  Hydrant                D  Service connection
       D  Other     	

    Address:
    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  None                     D Radiation               D Volatile chemicals
       D  HAZCAT                 D Chemical weapons      D Biological agents
       D  Other      	

       Report results of field safety screening in Appendix 8.3 "Field Testing Results
       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  None                     D Radiation              D Volatile chemicals
       D  HAZCAT                 D Chemical weapons      D Biological agents
       D  Other      	

       Report results of field safety screening in Appendix 8.3 "Field Testing Results
       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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                                MODULE 3: Site Characterization and Sampling Guide
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 None
   D Sulfur
   D Sweet/Fruity
  Describe unusual odor:
D Pungent
D Skunky
D New mown hay
  D  Irritating
  D  Bitter almond
  D  Other
Unusual Vehicles Found at the Site:
   D  Car/sedan                 D
   D  Flatbed truck              D
   D  Other
     SUV
     Construction vehicle
D Pickup truck
D None
  Describe vehicles (including make/model/year/color, license plate #, and logos or
  markings): 	
Signs of Tampering:
   D  None
   D  Open/damaged gates, doors, or windows
   D  Missing/damaged equipment
   D  Other 	
              D  Cut locks/fences
              D  Open/damaged access hatches
              D  Facility in disarray
   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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                                MODULE 3: Site Characterization and Sampling Guide
Unusual Equipment:
   D None                                 D Discarded PPE (e.g., gloves, masks)
   D Tools (e.g., wrenches, bolt cutters)       D Hardware (e.g., valves, pipe)
   D Lab equipment (e.g., beakers, tubing)     D Pumping equipment
   D Other 	

   Describe equipment: 	
Unusual Containers:
  Type of container:
     D None                    D  Drum/Barrel           D  Bottle/Jar
     D Plastic bag                D  Box/Bin               D  Pressurized cylinder
     D Test Tube                D  Bulk container          D  Other 	
  Condition of container:
     D Opened                  D New                  D  Damaged/leaking
     D Unopened                D Old                   D  Intact/dry

  Size of container:  	

  Describe labeling on container:  	
  Describe visible contents of container:
Rapid Field Testing of the Water
   D  None                        D Residual disinfectant  D pH / conductivity
   D  Cyanide                  D Radiation               D VOCs and SVOCs
   D  Pesticides                 D Biotoxins               D General toxicity
   D  Other      	

   Report results of rapid field testing of the water in Appendix 8.3 "Field Testing
   Results 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
                                  78                    Interim Final - December 2003

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                                    MODULE 3: Site Characterization and Sampling Guide
SAMPLING
    Time Sampling was Initiated / Completed:
    Implement Sampling Procedures Appropriate for the Hazard Conditions at the Site:
       D  Low hazard                            D Chemical hazard
       D  Radiological hazard                     D Biological hazard
    If the site is characterized as a chemical, radiological, or biological hazard (as described
    in Module 3, Section 4.1.3), 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 dechlorinating agents as specified.
       D  Carefully close sample containers and verify that they don't leak.
       D  Wipe the outside of sample containers with a mild bleach solution if there was any
          spillage.
       D  Place sample containers into a sealable plastic bag.
       D  Place samples into an appropriate,  rigid shipping container.
       D  Pack container with frozen ice packs.
       D  Complete "Sample Documentation Form" (Appendix 8.4).
       D  Complete "Chain of Custody Form" (Appendix 8.5).
       D  Secure shipping container with custody tape.
       D  Comply with any other sample security provisions required by participating agencies.
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                                     MODULE 3:  Site Characterization and Sampling Guide
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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                                                                                  MODULE 3: Site Characterization and Sampling Guide
8.3  Field Testing Results Form
Date of Field Testing: Site Name: Field Tester: Phone No.
Parameter




















Units




















Screen1




















Meter/Kit
ID2




















Testing Location3




















Testing
Time4




















Results5




















Ref. Value6




















1: Screening may be conducted for safety, rapid water testing, or both.
2: Report the unique identifier for the meter or kit used during screening.
3: Report the specific location where the field testing was conducted.
4: Report the specific time at which the test was performed.
5: Results of field testing should include replicate analysis where appropriate.
6. Results should be compared with a reference value, if available, to determine whether or not the levels detected pose a hazard.
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                                                                   MODULE 3: Site Characterization and Sampling Guide
8.4  Sample Documentation Form
Collection Date: Site Name: Sampler: Phone No.
Sample ID




















No.
Bottles




















Sampling
Time




















Sampling Location




















Sample Description




















Analysis




















Sample Additives1




















1: Report preservatives, dechlorinating agents, acid/base for pH adjustment, and any other sample additives.
                                      82
Interim Final - December 2003

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                                  MODULE 3: Site Characterization and Sampling Guide
8.5  Chain of Custody Form
Site Name:
Sampler Phone No.:
Sample ID


















Collection Date


















Relinquished by:
Relinquished by:
Relinquished by:
Relinquished by:
Relinquished by:
Sampler:
Signature:
No. Bottles


















Analysis


















Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Dispatched by: Date/time: Received for Laboratory by: Date/time:
Method of Sample Transport:
Shipper: Phone No.: Tracking No.:
                                    83
Interim Final - December 2003

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Office of Ground Water and Drinking Water
Water Security Division
EPA817-D-03-003
www.epa.gov/safewater/security
December 2003
Recycled/Recyclable  Printed with Vegetable Oil Based Inks on
   100% Postconsumer, Process Chlorine Free Recycled Paper

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