r/EPA
  United States
  Environmental Protection
  Agency
Wastewater Response Protocol
Toolbox:
Planning For and Responding To
Wastewater Contamination
Threats and Incidents

December 2011

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Office of Water (Mailcode 4608T)
EPA817-B-09-001
December 2011
www.epa.gov/safewater                                Printed on Recycled Paper

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/Vote to Readers
The U.S. Environmental Protection Agency (EPA) prepared the
Wastewater Response Protocol Toolbox (WWRPTB) to assist utilities,
government agencies, and emergency responders in protecting
wastewater systems from contamination events. This document is
designed to be a preparedness tool but does not impose legally binding
requirements on EPA, states, or utilities. Additionally, the guidance
may or may not apply to a particular incident. EPA and state decision-
makers retain the discretion to adopt approaches on a case-by-case
basis that may differ from these guidelines. Any decisions regarding a
particular wastewater system should be made based on the applicable
statutes and regulations. Therefore, interested parties are free to raise
questions and objections about the appropriateness of the application
of this guide to a specific situation, and EPA will consider whether the
recommendations or interpretations in this guide are appropriate in that
situation based on the law and regulations which are not discussed in
this document.

EPA may modify this guide in the future.  To determine whether EPA
has modified this guide, or to obtain additional copies, visit EPA's
Water Security website at http://www.epa.gov/watersecurity.

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                               Table of Contents

Introduction	1
Overview of the Response Protocol Toolbox	3
Module 1: Wastewater Utility Planning Guide	1-1
Module 2: Contamination Threat Management Guide	2-1
Module 3: Site Characterization and Sampling Guide	3-1
Module 4: Analytical Guide	4-1
Module 5: Public Health and Environmental Impact Response Guide	5-1
Module 6: Remediation and Recovery Guide	6-1
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        Planning and Preparation
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            Threat Warning
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        Initial Threat Evaluation
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Introduction
In 2004, the United States Environmental
Protection Agency (EPA) published guidance
on planning for and responding to threats
and incidents of intentional contamination of
public drinking water supplies. This document
is entitled the Response Protocol Toolbox:
Planning for and Responding to Drinking
Water Contamination Threats and Incidents
(RPTB) (EPA-817-D-03-007, December 2003).
EPA prepared detailed guidance specifically for
the intentional contamination scenario because
of the scenario's potential for a rapid and direct
impact on public health. EPA subsequently
released a condensed version of the RPTB,
entitled the Water Security Handbook (EPA-
817-B-06-001, April 2006), to reach a wider
audience. While the shorter document does
not include all of the details examined in the
comprehensive version, it summarizes the
most essential information. Additionally, EPA
published the Response Guidelines (EPA-
817-D-04-001, August 2004), a condensed
document which includes forms and checklists
from the RPTB. The Response Guidelines is
an easy to use field document for responders
managing an ongoing contamination threat or
incident. All of these documents are available
at EPA's Water Security website www.epa.gov/
watersecurity.

Wastewater utilities are also potentially
targets of malevolent acts including
contamination. They may be a direct target
of intentional contamination, or an indirect
target by receiving water from a contaminated
drinking water system or wash water from
decontamination efforts directed toward
contaminated people, buildings, etc. The
document contained herein, the Wastewater
Response Protocol Toolbox (WWRPTB),
addresses the preparedness and response
needs for threats and contamination events
in wastewater systems. These events can
include contamination with toxicants as well as
infectious, flammable, explosive, or radioactive
substances. As an "all hazards" document,
the WWRPTB discusses the response to
accidental and negligent contamination events
in addition to its primary focus on intentional
contamination.

Rather than produce both an extended version
and a condensed version, an attempt has been
made with the WWRPTB to develop a mid-
sized document that contains some detailed
information but is still of a manageable size.
The Wastewater Response Protocol Toolbox
was developed as a collaborative effort
between EPA and the wastewater industry. The
following utilities and industry organizations
took part in this process:

   • Metropolitan Water Reclamation District
    of Greater Chicago

   • New York City Department of
    Environmental Protection

   • Pittsburgh Water and Sewer Authority
    (PWSA)

   • San Antonio Water System (SAWS)

   • Water Environment Federation

   • Water Environment Research Foundation
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          In addition, the following individuals assisted with the preparation of this document:


               • Jeffrey Brenner - Minnesota Department of Health


               • Leonard Casson - University of Pittsburgh School of Engineering


               • Homer Emery - San Antonio Water System


               • David Goldbloom-Helzner - United States Environmental Protection Agency


               • Nancy Love - Virginia Tech University


               • Matthew Magnuson - United States Environmental Protection Agency


               • Joshua Novikoff - United States Environmental Protection Agency


               • John Petito - New York City Department of Environmental Protection


               • Anthony Quintanilla - Metropolitan Water Reclamation District of Greater Chicago


               • Roy Ramani - Water Environment Research Foundation


               • David Soong - United States Environmental Protection Agency


               • Stanley States - Pittsburgh Water and Sewer Authority


               • James Sullivan - Water Environment Federation


               • Rebecca Trenholm - Southern Nevada Water Authority

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               • Richard Weisman - United States Environmental Protection Agency
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               • Dennis Wesolowski - United States Environmental Protection Agency
               • James Wheeler - United States Environmental Protection Agency
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               • John Whitler - United States Environmental Protection Agency


               • Lawrence Zintek - United States Environmental Protection Agency
                                  Wastewater Response Protocol Toolbox

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Overview of the
Response Protocol Toolbox

The format of the Wastewater Response
Protocol Toolbox is identical to that of its
drinking water counterpart. The guidance
document is composed of six interrelated
modules (Modules 1-6) in addition to this
introductory section.

   The six modules that constitute the
   Wastewater Response Protocol Toolbox are:
               <>EFA  Wastewater Response Protocol
                r™~,,, , Toolbox:
                     Planning For and Responding To
                     Waslewater Contamination
                     Threats and Incidents

                      Toolbox Module
                      1.  Wastewater Utility Planning Guide
                      2.  Contamination Threat Management Guide
                      3.  Site Characterization and Sampling Guide
                      4.  Analytical Guide
                      5.  Public Health and Environmental Impact Response Guide
                      6.  Remediation and Recovery Guide
   Module 2 is considered to be the hub
   of the Toolbox in that it describes the
   overall recommended management
   process for response to a  contamination
   threat.

The WWRPTB is designed to be a planning
tool. It is not intended to be a reference
document for use during an actual emergency
when decisions need to be made rapidly.
Rather, it should  be read ahead of time and
integrated into a utility's Emergency Response
Plan. The Toolbox is not prescriptive, but
consists of broad guidance that should be
adapted to local conditions. Furthermore,
the WWRPTB is not based on any statutory
authority and, therefore, contains no mandatory
requirements. Use of the Toolbox is voluntary.
It is merely provided as a tool to aid utilities in
planning for contamination threats and events.
The WWRPTB offers recommendations on the
following emergency response issues:

 • Who to notify
 • What actions to take
 • How to conduct a threat evaluation
 • How to safely collect and ship samples
 • How to analyze samples
 • Steps to recover from a contamination event
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&EPA
  United States
  Environmental Protection
  Agency
Wastewater Response Protocol
Toolbox:
Planning For and Responding To
Wastewater Contamination
Threats and Incidents
December 2011
Module 1:
Wastewater Utility Planning Guide

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                         Table of Contents - Module 1
1 Introduction	 1-1
2 Contamination Threats and Incidents	1-1
  2.1 Overview of Contamination Threats and Incidents	1-1
  2.2 Malevolent Acts	1-5
  2.3 Wastewater Systems as an Indirect Target	1-6
  2.4 Candidate Contaminants	1-6
3 Considerations in Responding to Contamination Threats	1-7
4 How to Prepare for a Contamination Threat or Incident	1-8
5 Summary	1-11
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1  Introduction

Module 1 is an overall guide to utility planning
for contamination threats and incidents
involving wastewater systems. The module
provides a brief discussion of the nature
of contamination events and describes the
planning activities that a utility may undertake
to prepare for a response. All stakeholders
involved in planning for or responding to a
contamination threat or incident should review
this module. This includes utilities, emergency
responders, regulators, and health agencies.
Modules 2 through 6 provide information that
expands on Module 1.

 Specific topics covered in Module 1 include:

  1. Introduction
  2. Contamination threats and incidents
  3. Considerations in responding to
    contamination threats
  4. How to prepare for a contamination
    threat or incident
2  Contamination Threats and
   Incidents

2.1 Overview of Contamination Threats
    and Incidents

A wastewater contamination threat occurs
when the introduction of an atypical
contaminant, or abnormal volumes of a
more common contaminant, is threatened or
suggested by initial evidence. A contamination
incident occurs when a contaminant has
actually been  added to a wastewater system.
An incident may be preceded by a threat, but
not always.
Intentional or accidental contamination threats
and incidents are of concern to wastewater
utilities due to the range of consequences that
may result. These include:

   • Injury, illness, or death among utility
    workers or the public if flammable or
    explosive substances are involved, or if
    harmful vapors or aerosols are released.

   • Disruption of system operations and
    interruption of the collection, treatment,
    and disposal of wastes. This could result,
    for example, from the introduction of
    toxic substances that inactivate the
    microbial community that is an essential
    component of secondary treatment.

   • Physical damage to the wastewater
    infrastructure. This may be caused by the
    introduction of flammable or explosive
    substances into the collection system
    or treatment plant. There could also be
    damage to streets, private property, and
    other utility infrastructure (drinking water,
    gas,  electric, etc.) located near the sewer
    system.
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   • Damage to the environment or
    downstream users of receiving waters
    such as drinking water treatment systems.
    This could occur if contaminants were
    not removed by the wastewater treatment
    process and  passed through the plant.

   • Significant costs incurred for
    decontamination or replacement of
    portions of the wastewater system. These
    costs could result from the introduction
    of long lasting and difficult to remove
    contaminants such as radionuclides or
    pathogenic bacterial spores.

   • Economic impact on the wastewater
    utility and the community associated with
    interruption  of sanitary services.

A key question is whether it is possible for
accidental or intentional contamination of
a wastewater system to result in serious
consequences. A  review of documented
incidents indicates that contamination events
have caused significant damage in the past.
Some of the events documented below were
accidental while  others were the result of
either negligent or malevolent acts. Several
major incidents have involved the introduction
of flammable or  explosive substances into
wastewater systems:
Akron, Ohio 1977. A deliberate, malevolent
injection of flammable substances resulted
in a series of sewer explosions. A police
investigation revealed that at least 3,000
gallons of petroleum naptha and isopropyl
alcohol had been discharged into the sewer
during the night by vandals at a strikebound
rubber plant. Officials believe that when the
material entered the wastewater collection
system it was too rich to ignite, but as it flowed
further through the system it became diluted to
explosive range and finally ignited 3.5 miles
from the point of introduction. Approximately
one mile of sewer line was damaged.
Remediation costs exceeded $10 million.

Louisville, Kentucky 1981. Around SAM
on February 13, 1981, two women going to
work at a hospital drove under an overpass
on Hill Street in Louisville. There was a large
explosion  and their car was hurled into the air
and onto its side. At the same time, a police
helicopter flying overhead observed a series
of explosions erupting along the streets of
the city. More than two  miles of streets were
pockmarked with craters where manholes had
been located. Several blocks of Hill  Street
had fallen into the collapsed 12 foot diameter
sewer line (Figure 1-1). Fortunately, no one
was seriously hurt, but homes and businesses
were extensively damaged and a number of
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  Figure 1-1. Louisville, KY explosion, February 13, 1981. (The Courier-Journal)
people had to be evacuated. The cause of
the explosions was traced to a soybean
processing plant where thousands of gallons
of the flammable solvent hexane had
accidentally spilled into the sanitary sewer.
The fumes were presumably ignited by a
spark from the car as it was being driven
under the overpass. It required 20 months to
repair the sewer lines,  and several additional
months to complete the street repairs.

Guadalajara, Mexico 1992. There was an
especially tragic accident in Guadalajara
in April 1992. Nine separate explosions
occurred, over a four hour period, in the
sewer collection system beneath the city's
downtown area. The explosions were caused
by gasoline accidentally leaking from
an underground pipeline into the sanitary
sewer. Local residents had complained for
several days about a strong gasoline odor
wafting up from the sewer drains. Officials
could not find the source of the problem, did
not order an evacuation, and called off their
investigation several hours before the series
of explosions began. The explosions killed
206 people, injured 1,460 persons, damaged
1,148 buildings, destroyed 250 businesses
and 500 vehicles, left 15,000 people
homeless, and forced the evacuation of a
total of 25,000 people. Seven miles of sewer
pipe were destroyed, some of which was
18 feet in diameter (Figure 1-2). A number
of victims were buried alive. Damages
exceeded $75 million United States dollars.
It was eventually concluded by investigators
that the ultimate cause of the explosions
was the installation of a drinking water
main, several years earlier, which leaked
onto the gasoline line lying underneath. The
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              Figure 1-2. Gasoline-sewer explosion, Guadalajara, Mexico, April 22, 1992.
                      Reprinted with permission from the Disaster Recovery Journal (Vol 5, #3).
          subsequent corrosion of the gasoline pipeline
          caused leakage of gasoline and allowed vapors
          to accumulate in the sanitary sewer system.
      A number of victims were
              buried alive.
  Damages exceeded $75 million
              U.S. dollars.
Conroe, Texas 1994. The owner of a
convenience store/gas station learned that his
8,000 gallon underground storage tank was
cracked and ground water was infiltrating
the tank. Rather than dispose of the diluted
gasoline properly, the business owner rented
a small pump and intentionally discharged
a mixture of approximately 5,000 gallons
of gasoline and 500 gallons of water onto
the street in front of his store. The gasoline/
water mixture entered both the sanitary and
storm water collection systems and essentially
formed a three-mile long pipe bomb.

Fortunately, there was no explosion. However,
several schools were evacuated the next day as
a precaution. The gasoline in the storm water
collection system flowed into a creek. Utility
officials were able to divert the gasoline in the
sanitary sewer collection system to a lagoon
to protect the wastewater treatment plant. The
perpetrator was prosecuted for violation of the
Clean Water Act.

Documented incidents have also occurred that
involved the introduction of toxicants into the
wastewater system:

Louisville, Kentucky 1977. Workers at a
municipal wastewater treatment plant reported
a strong chemical odor that was making them
ill. After more than a week of investigation
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it was determined that the odor was coming
from a mixture of hexachloropentadiene
and octachlorocyclopentene, two highly
toxic chemicals used in the manufacture of
pesticides. The mixture had been intentionally
discharged into a sewer system manhole by a
local chemical disposal company improperly
dumping industrial waste. The contaminated
sewage treatment plant had to be shut down
for a three month period during which time
100 million gallons per day of raw sewage was
released to the Ohio River.

Philadelphia, Pennsylvania 2006. Employees
at a suburban wastewater treatment plant
noticed fluctuations in the chlorine levels in the
plant's discharge. Shortly thereafter, a fish kill
was observed downstream of the plant. It was
subsequently determined that a pharmaceutical
company had inadvertently discharged to the
sanitary sewer approximately 25 gallons of
potassium thiocyanate. It is believed that the
cyanate compound combined with the chlorine
used to treat the wastewater plant discharge
and formed cyanogen chloride, a chemical
highly toxic to fish. The unexplained fish kill
forced drinking water officials to temporarily
close one of the City of Philadelphia's
downstream drinking water plant intakes as a
precaution.

In addition to the well publicized cases
described above, there are numerous
smaller scale incidents that have resulted
in contamination of wastewater systems
across the United States. For example, many
accidental discharges to sanitary or storm water
collection systems have occurred as a result
of spills from chemical tanker trucks involved
in highway accidents and railroad tank cars
involved in derailments.
2.2 Malevolent Acts

As illustrated by the deliberate introduction
of flammable substances into the Akron, Ohio
sewage collection system described above,
contaminants may be intentionally added to a
wastewater system as part of a malevolent act.
The intentional contamination could be carried
out by vandals as in the Akron incident. It is
also conceivable that domestic or international
terrorists could attack a municipal wastewater
system to harm people or property.
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Possible reasons why terrorists might target a
wastewater system include:

   • Wastewater systems are a major part of the
    infrastructure of this country.

   • Interference in the collection, treatment, or
    disposal of sanitary wastes would impact
    public health, disrupt daily life for the
    affected populations, result in significant
    economic losses, and negatively affect the
    environment.

   • Wastewater systems have many
    components, are spread out
    geographically,  and are therefore
    difficult to protect.

   • Wastewater systems, like drinking water
    systems, are  perceived to be associated
    with the government.

Although the focus of the WWRPTB is
contamination events, it should be noted
that wastewater systems, like drinking water
systems, are also potentially susceptible to other
types of deliberate attacks. These could include
physical assaults on facilities or staff, cyber
attacks, or the intentional release of hazardous
treatment chemicals like chlorine gas.

2.3 Wastewater Systems as an Indirect
    Target

Wastewater systems also could become the
indirect victim of an intentional act aimed at
another target in the  community. For example,
an intentional contamination of the public
drinking water supply would almost certainly
result in contaminants eventually flowing
into the wastewater collection and treatment
system. This could occur through normal
use of drinking water or remedial flushing of
the drinking water system. Similarly, should
people or buildings in the community become
contaminated as a result of a chemical,
biological, or radiological (CBR) attack,
spent wash water used in the decontamination
process may find its way into the municipal
wastewater collection and treatment system.
  Wastewater systems are a major
    part of the infrastructure of
             this country.
2.4 Candidate Contaminants

A candidate list of contaminants could include
various flammable, explosive, infectious,
toxic, and radioactive substances. If injected
or released into a sanitary or storm water
collection system, these contaminants
could cause injury or death to the public or
utility workers, damage to the wastewater
infrastructure and nearby property within
the community, damage to the biological
components of the wastewater treatment
process, and impacts on downstream water
users if the contaminants managed to pass
through the wastewater treatment plant.

To support emergency management of
wastewater and drinking water contamination
threats and incidents, EPA has developed a
resource for contaminant-specific information
for use by the drinking water and wastewater
sectors. The Water Contaminant Information
Tool (WCIT) is an Internet database that
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provides detailed information for potential
contaminants on key factors such as
contaminant toxicity and infectivity, chemical
characteristics, clinical symptoms of exposure,
drinking water and wastewater treatability,
and decontamination approaches among
others. Access to this database is available
to utilities, regulators,  health agencies, and
others by registration with EPA. Information
on registration procedures can be obtained at
http ://www. epa.gov/wcit.

3  Considerations in Responding
   to Contamination Threats

With the events of 9/11, continued threats
against the homeland,  and the realization that
drinking water and wastewater systems could
potentially become the targets of intentional
contamination, questions have arisen
concerning the role that utilities should play in
responding to threats or actual incidents.

One question that could reasonably be raised
by wastewater utilities is: "I'm just a utility -
why do I need to do anything at all?"
Wastewater utilities play an essential role in
the safe collection, treatment, and disposal
of sanitary wastes, industrial wastes, and
storm water. A growing number of utilities
are also processing reclaimed water for
use in irrigation, cooling, lake or  stream
augmentation, groundwater recharge, and
other non-potable uses. These functions
have obvious public health ramifications.
Wastewater utilities take their public health
responsibilities very seriously.  Either
accidental or intentional contamination of a
wastewater system with flammable, toxic,
infectious, or radioactive substances may pose
a risk to the health of the community, utility
employees, and the environment. Utilities may
be subject to legal and regulatory requirements
associated with the contamination. Utilities
should consider an effective response to a
contamination event as being part of their
mission.

   Presidential Policy Directive 8 is
   aimed at strengthening the security and
   resilience of the U.S. against threats that
   pose the greatest risk to the Nation (e.g.,
   terrorism, catastrophic natural  disasters).
   In the Directive, "response" refers to
   those capabilities that save lives, protect
   property and the environment, and meet
   basic human needs after an incident.
   The water sector plays an important role
   in response by providing safe drinking
   water and wastewater sanitation services.
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A second potential question among utilities is:
"What should I be doing to protect against
and respond to contamination threats?"

Specific actions to protect against and
respond to a contamination threat are
warranted, due to the public health and public
safety consequences of wastewater system
contamination, and need to be conducted
in accordance with applicable legal and
regulatory requirements. The wastewater
system should work with applicable local,
state, and federal agencies and emergency
officials to determine the appropriate actions.
This document can help a wastewater utility
evaluate issues involved in determining the
appropriate actions and integrate the relevant
information into documents such as utility
Emergency Response Plans.  Effective
planning will assist the wastewater utility to
conduct a careful evaluation of any threat and
take appropriate response actions based on that
evaluation.

 4  How to Prepare for a
    Contamination Threat or
    Incident

There are a number of steps that utilities can
take to prepare for contamination threats.
These include:

 • Use the WWRPTB to develop an updated
    Emergency Response Plan

    Utilities are encouraged to use the
    recommendations presented in this
    document that are appropriate for their
    local needs. Utilities should feel free
    to 'cut and paste' protocols, forms, and
    other information from the Toolbox and
    customize them for their own response
    plan. Again, use of the Toolbox is not
    mandatory.
Conduct a Vulnerability Assessment (VA)

 Under the Public Health and Bioterrorism
 Preparedness and Response Act of 2002,
 drinking water utilities serving more than
 3,300 persons were required to conduct a
 formal Vulnerability Assessment. While
 wastewater utilities were not mandated
 to conduct VAs, a wastewater  system can
 gain an enhanced perspective  on their
 risks and susceptibilities from this type
 of effort. A VA can be used to  define
 risks from both intentional and accidental
 contamination events as well as from
 natural disasters, accidents, and other
 intentional acts (e.g., physical  attacks,
 cyber attacks, and intentional release
 of harmful treatment chemicals such as
 gaseous chlorine).

 EPA and several wastewater industry
 organizations have produced vulnerability
 assessment and consequence analysis
 tools to assist wastewater systems in
 conducting their assessments.  These
 tools can be accessed from EPAs Water
 Security website at
 http ://www. epa.gov/watersecurity.

Know your wastewater system

 A detailed knowledge of the hydraulic and
 chemical characteristics of the wastewater
 collection and treatment system will
 assist utility officials in determining
 the credibility of suspicions that a
 contamination event has actually occurred.
 It will also help utility personnel predict
 which portions of the wastewater system
 may be compromised by an event.

 EPA has made available, free of charge, a
 security hydraulic model (SewerNet) that
 wastewater utilities can use to predict the
 transport and fate of contaminants in a
 wastewater collection system.
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• Include intentional and accidental
  contamination scenarios in your utility's
  Emergency Response Plan

   Even if the risk of a contamination event
   is not deemed to be particularly high when
   a utility conducted its VA, the potential
   consequences of such an incident may be
   serious enough to warrant contingency
   planning.

• Develop utility specific Response
  Guidelines for intentional  contamination

   Response Guidelines are condensed
   field guides for responding to specific
   emergencies. They should be action
   oriented, easy to use in the field under
   emergency conditions, and contain all the
   necessary forms and information. They are
   composed of written procedures, report
   forms, templates,  and checklists, examples
   of which can be found in Modules 2 thru 6
   oftheWWRPTB.

• Establish a structure for incident
  command

   Ideally this structure should be based on
   the Incident Command System (ICS)
   and the National Incident Management
   System (NEVIS). ICS is the system
   that has been adopted throughout the
   United States to manage emergencies
   ranging from natural disasters to terrorist
   events. NEVIS is a nationwide template
   that enables all government and non-
   government organizations to work
   together during an incident requiring the
   use of ICS. If the ICS structure is already
   being used as the model for emergency
   management  at the utility level, it will
   be much easier to coordinate the utility's
   response with the efforts of outside
   agencies should a situation expand in
  complexity. Utility personnel can access
  free, online ICS/NEVIS training courses
  through FEMA at http://training.fema.gov/
  is/crslist.asp. Also, EPA provides on-line
  and in-person ICS training targeted to
  water and wastewater utilities at http://
  water, epa.gov/infrastructure/watersecurity/
  emerplan/index.cfm.

Develop an information management
 strategy

  During a threatened or actual incident,
  information will be received from multiple
  sources including those performing
  site characterization, law enforcement
  agencies, and health officials. The
  effectiveness of incident response will
  be determined, in large part, by how
  effectively this volume of information
  is collected, analyzed, and disseminated
  within the utility, and between the utility
  and other responding agencies.
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• Establish a communication and
  notification strategy

   This includes timely and accurate
   notifications of personnel within the
   wastewater utility, the public, and
   other organizations such as emergency
   responders, regulators, health officials,
   neighboring wastewater utilities, and
   downstream drinking water plants in
   accordance with all regulations and
   requirements.

• Conduct training

   A well-written Emergency Response
   Plan may not be effectively executed if
   key players are not familiar with their
   roles and how they are expected to
   coordinate with other responders (e.g.,
   law enforcement, fire department, and
   health department). Training should begin
   with classroom instruction on utility
   Emergency Response Plans, guidance
   such as the WWRPTB, and the ICS. It
   should then progress to tabletop exercises
   and finally to field exercises so that the
   utility and outside response agencies can
   practice their interaction with each other.

   EPA's Tabletop Exercise Tool for Water
   Systems: Emergency Preparedness,
   Response, and Climate Resiliency (EPA-
   817-C-10-001, June 2010) allows utilities
   to conduct their own customized incident
   response training. The Tool can be
   obtained from the following website:
   www.epa.gov/watersecurity.

• Enhance physical security of the
  wastewater system

   While physical protection systems alone
   cannot guarantee security, enhancement of
   physical barriers through such measures

  as fences, intrusion detection systems,
  and closed-circuit TV surveillance is
  an important first step in improving the
  overall security of a wastewater system.

  The Water Infrastructure Security
  Enhancements (WISE) program has
  produced a guidance document to
  assist wastewater utilities in improving
  their physical security. The document
  is entitled Guidelines for the Physical
  Security of Wastewater/Stormwater
  Utilities (December 2006) and is available
  at:  http://www.cdph.ca.gov/certlic/
  drinkingwater/Documents/Security/WISE-
  PhaseSWastewaterStormwaterUtilityGuid
  elines.pdf

Establish a baseline monitoring program

  The ability to detect significant excursions
  from the normal chemical characteristics
  of wastewater within the collection
  system and through the various stages
  of treatment is an important means of
  determining whether a contamination
  event has actually occurred. Evaluating
  the significance of water quality
  excursions requires comparison with
  established baseline wastewater chemical
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    data. For example, what is the usual pH
    range for a utility's wastewater? What
    are the typical concentrations of various
    organic compounds in the wastewater
    (e.g., toluene or benzene)?

   Use and understand on-line monitoring

    While current online monitoring
    capabilities are limited, the technology is
    improving. Online monitoring of water
    quality is a means for detecting accidental
    and intentional contamination events.
    The resources to purchase, operate,
    and maintain monitoring systems will
    be enhanced if the monitoring can be
    used not only to bolster security, but
    also to provide multiple benefits such as
    improving the utility's process control and
    regulatory compliance.
   Participate in Mutual Aid Programs

    Drinking water and wastewater
    utilities, in conjunction with EPA,
    state regulatory agencies, and water
    industry organizations, have developed
    mutual aid and assistance agreements
    for almost all 50 states. This initiative,
    Water and Wastewater Agency Response
    Networks (WARNs), involves wastewater
    and drinking water utilities within a
    state signing a mutual aid agreement
    pledging to support other utilities during
    emergencies. Support can involve the
    sharing of personnel, equipment, and
    supplies. Additional information on the
    WARN initiative, including specific
    information about wastewater utilities in
    WARN, is available at http://water.epa.
    gov/infrastructure/watersecurity/index.
    cfm.
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5  Summary

A number of wastewater system contamination
events have occurred in this country and
elsewhere. Most of these have been accidental
but some have occurred intentionally. Several
of these have resulted in loss of life, injuries,
and significant damage to both wastewater
infrastructure as well as private property.
These incidents underscore the vulnerability
of wastewater systems to accidental or
intentional contamination. They also illustrate
the potential risk to public safety, public
health, private property, and the wastewater
infrastructure, as well as the large amounts of
time and money needed to repair the damage.
Wastewater utilities have a responsibility to
prepare for and respond to contamination
threats. A number of practical suggestions
have been offered in this module for steps that
wastewater systems can take to improve their
ability to manage contamination incidents.
Again, these are only general suggestions that
may be tailored to the needs and resources
of individual utilities consistent with any
applicable laws and regulations.
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&EPA
  United States
  Environmental Protection
  Agency
Wastewater Response Protocol
Toolbox:
Planning For and Responding To
Wastewater Contamination
Threats and Incidents
December 2011
Module 2:
Contamination Threat Management Guide

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                         Table of Contents - Module 2

1 Introduction	2-1
2 Overview of the Contamination Threat Management Process	2-2
  2.1 Roles and Responsibilities	2-2
  2.2 Response and Consequence	2-3
  2.3 Contamination Threat Management Decision and Response Tree	2-4
3 Stage I: 'Possible' Stage of Threat Management Process	2-4
3.1 Information from the Threat Warning	2-4
3.2 Additional Information	2-7
  3.3 Response Actions Considered at the 'Possible' Stage	2-8
                                                                                            on
4 Stage II: 'Credible' Stage of Threat Management Process	2-9
                                                                                            C
  4.1 Information Considered at the 'Credible' Stage	2-9
  4.2 Response Actions Considered at the 'Credible' Stage	2-10
5 Stage III: 'Confirmed' Stage of Threat Management Process	2-12
  5.1 Information Considered at the 'Confirmed' Stage	2-13
  5.2 Response Actions Considered at the 'Confirmed' Stage	2-13
6 Contamination Threat Management Matrices	2-14
                                                                                            +->
  6.1 Security Breach	2-15
  6.2 Witness Account	2-16
  6.3 Direct Notification by Perpetrator	2-17
  6.4 Notification by Law Enforcement	2-18
  6.5 Notification by News Media	2-19
  6.6 Unusual Water Quality	2-20
  6.7 Degradation of Treatment Organisms	2-21
  6.8 Public Complaints	2-22
  6.9 Public Health Notification	2-23
7 Summary	2-24
8 Appendices	2-24
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                                    Planning and Preparation
                            ion )
                                         Threat Warning
                                     Initial Threat Evaluation
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                                      Immediate Operational

                                        Response Actions
                                      Site Characterization

                                          and Sampling
             Public Health

           Response Actions
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                                           Is Incident

                                           Confirmed
                                    Remediation and Recovery
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1 Introduction

As discussed in Module 1, accidental and
intentional contamination events involving
wastewater systems have occurred in the past.
In some cases, such as Guadalajara, Mexico
in 1992, the results have been devastating
in terms of the impact on human lives and
property. Therefore, in the event of either
an accidental or intentional contamination
threat, there is a need to be able to evaluate the
credibility of the threat and identify appropriate
response actions. Also, because a large
number of people and a significant amount
of infrastructure and private property can be
exposed to a contaminant passing through a
collection and treatment system within just
a few hours, there is a need to evaluate and
respond in a short amount of time.

While it is desirable to have complete
information prior to making response
decisions, the reality is that this will almost
certainly not be the case when responding to
contamination threats. Typically, there will
not be time to conclusively determine whether
the wastewater has been contaminated or
definitively identify the contaminant prior
to making decisions to protect health and
property. However, it is also necessary to avoid
false alarms that would result in undue stress
on the public. Therefore, a delicate balance
must be achieved between actions taken to
protect public safety and property, and limiting
overreaction to a perceived threat.
Module 2, the Contamination Threat
Management Guide, provides a framework
for making decisions based on available,
yet incomplete, information in response to a
contamination threat. It represents the hub of
the WWRPTB. The objectives of this module
include:

   • Present a framework for evaluating a
    wastewater contamination threat and
    making appropriate decisions

   • Describe the type of information that may
    be used for conducting a threat evaluation

   • Describe the actions that might
    be implemented in response to a
    contamination threat (giving appropriate
    consideration to the potential
    consequences of an incident and the
    impacts that may result from the response
    actions)

Based on these objectives, Module 2 is divided
into the following sections:

   1. Introduction
   2. Overview of the Contamination Threat
     Management Process
   3. 'Possible' Stage of the Threat
     Management Process
   4. 'Credible' Stage of the Threat
     Management Process
   5. 'Confirmed' Stage of the Threat
     Management Process
   6. Contamination Threat Management
     Matrices
   7. Summary
   8. Appendices

Many of the concepts described in  Module
2 are similar to those for the Water Security
initiative, which addresses drinking water
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security. In particular, the Interim Guidance
on Developing Consequence Management
Plans for Drinking Water Utilities (CMP) (EPA
817-R-08-001, October 2008) provided for the
Water Security initiative addresses the various
stages of the threat management process
for drinking water (possible, credible, and
confirmed). See http://www.epa.gov/safewater/
watersecurity/pubs/guide_interim_cmp_wsi.
pdf for additional information about the CMP.
2 Overview of the Contamination
  Threat Management Process

2.1 Roles and Responsibilities

As discussed in Module 1, the Incident
Command System (ICS) is the national
model for managing emergencies, including
contamination threats, involving public
drinking water and wastewater systems.
   Organizations that may Assume Incident Command Responsibility During
   an Intentional Contamination Situation

   Wastewater Utility. May be responsible for incident command during the initial stages
   of an event since it will often be the first party to become aware of the threat warning.
   The utility will retain this responsibility, by default, unless/until another organization
   (with proper authority) assumes command. The Utility Incident Commander would prob-
   ably serve as overall Incident Commander while the utility maintains primary responsi-
   bility for managing the crisis.

   Local Fire Department/HazMat Team. May assume incident command if hazardous
   materials are involved.

   Wastewater Permitting Agency. May assume incident command, especially when a
   smaller utility lacks the resources to manage the threat.

   Public Health Agency (state or local). May assume incident command if the situation is
   a public health crisis.

   Local Law Enforcement. May assume incident command when criminal activity (ex-
   cluding federal crimes) is suspected.
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   FBI. Will assume incident command (of the criminal investigation) when there is a ter-
   rorism incident or a credible threat of terrorism. In this case, EPA's Criminal Investiga-
   tion Division (CID) will have a role in working with the FBI. If it is determined that a
   contamination threat or incident is not an act of terrorism, EPA's CID will typically be the
   lead federal agency for law enforcement in the response.
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Under this management system, incident
command has overall responsibility for
managing the crisis. The organization that
assumes responsibility for incident command
will vary with the nature and severity of the
situation. During the course of managing a
contamination threat, the individual designated
as Incident Commander may change as
different organizations assume responsibility
for managing the situation. In the event
of a more complex emergency, a Unified
Command may be set up in which the incident
command consists of representatives of the key
stakeholders with jurisdictional or functional
authority.
 The organization that assumes
    responsibility for incident
   command will vary with the
    nature and severity of the
              situation.
If an organization other than the wastewater
utility assumes incident command, the utility
will play a supporting role during the threat
management process. Regardless of which
organization is in charge of managing the
overall situation, the utility will always have a
responsibility for the wastewater system.

2.2 Response and Consequence

Response decisions regarding a wastewater
system contamination threat may have
consequences that significantly affect the
community. While the health and safety of
utility workers and the public will always be
the primary concern during a contamination
incident, it should be realized that the response
actions taken to deal with the threat may have
serious ramifications. For example, if the
decision is made to completely shut down a
municipal wastewater system due to concerns
over a contaminant, this would seriously
impact the public health of a community that
can no longer safely treat sanitary waste.
Additionally, any decision to bypass the
wastewater treatment plant must be consistent
with applicable laws and regulations including
40 CFR 122.41(m). This could seriously
impact the environment and downstream
water users when raw sewage containing
the contaminant is released untreated into a
receiving stream.

Criteria for Response Decisions

Response decisions concerning contamination
threats and incidents should be based on the
following three criteria:

   1. Is the contamination threat 'Possible,'
     'Credible,' or 'Confirmed?'

   2. What are the potential consequences of
    the contamination on human health and
     safety, the environment, the economy, and
    the wastewater infrastructure?

   3. What is the potential  impact of the
    response action on public health, the
    economy, and the environment?

A Response Planning Matrix is a tool that can
help officials weigh these three criteria when
making response decisions. The matrix is a
simple tabular summary that lists the three
levels of a threat evaluation, the potential
consequences of a threat (including the number
of people affected and health effects), and
potential response actions along with their
impacts on the public and the environment. A
blank Response  Planning Matrix  is included in
Appendix  1 at the end of the toolbox.
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2.3 Contamination Threat Management
    Decision and Response Tree

The overall threat management decision
process is summarized in Figure 2-1. The
remaining sections in this module describe the
various steps in this decision and response tree.

3 Stage I: 'Possible' Stage of
  Threat Management Process

A wastewater contamination threat is
characterized as 'Possible' if the circumstances
of the threat warning (threat warnings are
discussed in section 3.1) indicate that there
was an opportunity for contamination. This
is the lowest threshold determination in the
threat evaluation process and is the point at
which a decision is made regarding whether or
not to initiate an investigation. If the threat is
determined to be impossible, there is no need
to continue the threat evaluation or consider
any response actions. However, it is likely
that most contamination threats will meet
this relatively low threshold and thus warrant
investigation.

The target time period for determining
whether or not a contamination threat is
'Possible' is within one hour from the time
the  threat warning is received by the utility.
Given the potentially severe consequences of
failing to respond to an actual contamination
incident in a timely and appropriate manner,
it is important to determine whether or not
a threat is 'Possible' in this relatively short
time frame. The one hour target, however,
should be treated as a flexible goal since the
circumstances of a particular threat may dictate
a shorter or longer period.

As with all stages of the threat management
process, the Incident Commander usually
is responsible for determining whether or
not the contamination threat is 'Possible.' In
most cases, this determination will be made
by the utility Incident Commander, although
others may become involved in the initial
evaluation as appropriate. For example,
if the threat warning is reported by a law
enforcement agency, they would likely play
a role in determining whether or  not a threat
is 'Possible.' Also, the wastewater permitting
agency may need to be informed about all
threat warnings and may participate in this
initial stage of the threat evaluation. However,
given the short target time frame for the initial
evaluation, the utility Incident Commander
might make this determination, initiate an
investigation,  and initiate some preliminary
operational responses.

Relevant and timely information is key
to determining whether or not a threat is
'Possible' in the target time period. In most
cases, the information considered at this
stage will be derived directly from the threat
warning (e.g., nature of warning, location,
time of discovery, suspected time of incident,
and other details). Under some circumstances,
additional  information beyond the threat
warning may be considered. However, there
may not be sufficient time to do so in most
cases, and the determination regarding whether
or not the threat is 'Possible' will be based
primarily on details of the threat  warning.

A Threat Evaluation Worksheet is provided in
Appendix 2 to help organize the information
used throughout the threat evaluation,
beginning with a summary of information
about the threat warning itself.

3.1 Information from the Threat Warning

A threat warning is an unusual event,
observation, or discovery that indicates
the potential for intentional or accidental
contamination and suggests the need for
actions to address the concern. Threat warnings
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V
                             /
                             (THREAT:
                      Review contamination threat
                         warning information
                            X     x
                         . /  Is threat  N_
                          *\ possible? /
                          Investigate possible
                            contamination
                      Review investigation results

                         *        *»
                     /  Is threat  *»_
                      \^ credible? S
                        **.       ^^
                        Preform sample analysis
                               0
                      Review additional information
                               " *
,«••** Do results confirm **••
'*••», contamination? f»*
                                                            1
                                             ^
                                                                       Close investigation, return
                                                                        to normal operation, and
                                                                          document the threat.
                                                   Consider public
                                                   notification and
                                                    public health /
                                                   safety response
                                                               Is threat still
                                                                possible?
Revise operational response and
public health response as necessary
1 1

Revise sampling and
analysis plan and
continue threat evaluation
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                         Develop remediation
                          and recovery plan
Figure 2-1. Contamination Threat Management Decision Tree for Wastewater
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                                                  Security
                                                  Breach
                                    Public
                                    Health
                                 Notification
                                            Witness
                                            Account
                                                                        Notification
                                                                            by
                                                                        Perpetrator
      Public
   Complaints
                 \
/ Contamination \
\     Threat     ]
'•    Warning    /
                                                                     Notification
                                                                       by Law
                                                                    Enforcement
      Degradation
      of Treatment
      Organisms
                                          Unusual
                                        Waste water
                                         Chemicals
                                   Notification
                                       by
                                   News Media
Figure 2-2. Types of Threat Warnings
          may come from several sources both within
          and outside of the wastewater utility. Figure
          2-2 summarizes the most likely threat warnings
          that a wastewater utility may expect to receive.

          Security Breach

          A security breach is an unauthorized intrusion
          into a secured facility or the collection
          system that may be discovered through direct
          observation (for example, through an alarm,
          cut fence, or open manhole). A Security
          Incident Report Form is included in Appendix
          3 to assist in documenting the available
          information about a breach and support the
          threat evaluation.
                                 Witness Account

                                 A witness account is a threat warning from an
                                 individual who directly witnesses suspicious
                                 activity. A Witness Account Report Form is
                                 included in Appendix 4 to help document a
                                 witness account.

                                 Direct Notification by Perpetrator

                                 A threat may be made directly to the utility by a
                                 perpetrator, either verbally or in writing. Report
                                 forms for telephone and written threats are
                                 provided in Appendices 5 and 6, respectively.
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Notification by Law Enforcement

A utility may receive notification about a
contamination threat from a law enforcement
agency.

Notification by News Media

A contamination threat might be made to the
media, or the media may learn of an accidental
contamination before the utility is alerted.

Unusual Wastewater Chemical
Characteristics

Unusual wastewater chemical results could
come from on-line monitoring or routine grab
sampling indicating a possible contamination
event.

Degradation of Treatment Organisms

Should a contaminant enter the treatment plant
from the collection system, the first indication
of its presence could be a degradation in
the abundance or activity of microbes in the
secondary treatment process.

Public Complaints

Public or utility employee complaints about
unusual odors associated with the sewer
system (e.g., petroleum products or industrial
chemicals) may suggest the presence of a
contaminant. Wastewater system personnel
reporting unusual  health symptoms may also
indicate a threat.

Notification by Public Health Agencies

Notification from  health agencies or health
care providers that people are being negatively
affected by fumes emanating from domestic
sewer systems, catch basins, or the wastewater
treatment plant may suggest a contamination
event. A Public Health Information Report
Form included in Appendix 7 is intended
to organize information from public health
entities to support this evaluation.

3.2 Additional Information

Information extracted from details of the
threat warning is critical to determining
whether or not a contamination threat is
'Possible.' Different types of warnings will
have different levels of initial believability.
For example, widespread complaints of
solvent-like odors wafting up from sanitary
sewer manholes would have a higher degree
of initial believability than a report of unusual
wastewater chemistry based on changes in a
few general parameters (e.g., pH or alkalinity).
Some warnings may be judged so reliable that
the threat is deemed 'Credible' solely on the
basis of information about the threat warning,
while others may be almost instantly dismissed
as impossible.

Regardless of the nature and source of the threat
warning, it is critical that protocols be in place
to report the warning to the utility Incident
Commander as quickly as possible. Utilities
should develop communications procedures to
ensure that threat warnings can be rapidly and
accurately reported on a 24/7 basis.

While the threat warning will likely provide
the most immediate and relevant information,
several other resources might be considered
to help make the determination as to whether
a threat is 'Possible.' These may include:
internal information from utility staff that
are knowledgeable of the operation of the
wastewater system, information from the
utility's VA that is relevant to the current
situation, and real time water chemistry
data that might be used as an indicator of
wastewater contamination.
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3.3 Response Actions Considered at
    the 'Possible' Stage

Once a contamination threat has been deemed
'Possible,' relatively low level response
actions are appropriate since this is a very
early stage in the threat management process.
Two response actions that might be considered
at this stage include site characterization and
operational response.

Site Characterization

This is the process of collecting information
from the site of a suspected wastewater
contamination incident. This is a key activity
in the ongoing threat evaluation and is intended
to help determine whether or not the  'Possible'
threat is 'Credible.' Site characterization
includes the following activities:

  • Site investigation
  • Field safety screening
  • Rapid field testing of wastewater
  • Sample collection

Detailed procedures for conducting site
characterization are described in Module  3:
Site Characterization and Sampling Guide.

Immediate Operational Responses

These are actions intended to limit the potential
exposure of the public to the contaminant
and reduce the risk to private property, the
wastewater infrastructure, and the environment
while site characterization activities are
conducted. An example operational response
would be diverting the flow of untreated
wastewater to temporary storage, rather than
exposing the treatment process, until the nature
of the possible contamination event can be
better characterized. Emergency pretreatment
of the influent wastewater may also be
considered consistent with any applicable laws
and regulations. This may include the addition
of powdered activated carbon, a strong oxidant
such as chlorine or potassium permanganate,
or the addition of caustic to neutralize or
precipitate atoxic chemical.

If a flammable substance is in the collection
system, the utility, working with the fire
department, may attempt to remove the
substance using vacuum trucks and/or oil
spill remediation equipment.  If the flammable
substance is in the plant influent, the utility
may decide to turn off pumps to the treatment
basins and assist the fire department in
dispensing aqueous film forming foam.

The decision to implement these response
actions may need to be made very quickly for
the  actions to have their desired effect. For
example, in order for diversion and storage
of untreated wastewater to be effective, it
may need to be implemented as quickly as
feasible after a threat is deemed  'Possible.' To
facilitate  this, the utility Incident Commander
should be aware of the regulatory and legal
considerations that may apply to decisions, and
be empowered to implement  such response
actions at the  'Possible' stage. However, the
immediate response actions should then be
shared with utility management.
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If an operational response is not feasible, the
threat evaluation process should be accelerated
to determine whether or not the threat is
'Credible.'
4 Stage II: 'Credible' Stage of
  Threat Management Process

A wastewater contamination threat should
be considered to be 'Credible' if additional
information collected during the investigation
(initiated after the 'Possible' decision was
made) corroborates the threat warning, and
the cumulative information indicates that
contamination is likely. For example, if the
threat warning comes in the form of a security
breach and additional convincing signs of
contamination (e.g., abnormal wastewater
chemical values) are observed during site
characterization, the threat could be considered
'Credible.' While many warnings may result
in 'Possible' contamination threats, only a
small percentage of those 'Possible' threats are
expected to be elevated to the 'Credible' level.

It is important to move quickly from the
'Possible' stage to the next stage of the threat
management process to determine whether
or not the threat is 'Credible' and warrants an
elevated response. The target time period for
determining whether or not a contamination
threat is 'Credible' is within 2 to 8 hours from
the time that the threat was deemed 'Possible.'
The decision to elevate a threat from 'Possible'
to 'Credible' is significant since elevated
response actions may be necessary to protect
public health and safety. The elevated response
measures may fall outside of the authority
of the utility Incident Commander, and the
organizations that would be involved in
these response decisions would need to be
engaged in the threat evaluation process at this
stage. This might include wastewater utility
management, the regulatory agency, and the
public health agency. If there is a possibility
that the contamination event was deliberate,
law enforcement may also need to be involved.
The individual typically responsible for
determining that a contamination threat is
'Credible' is the Incident Commander, who
may not be the utility Incident Commander at
this point in the threat management process.
4.1 Information Considered at the
    'Credible' Stage

Many of the information resources used to
determine that a threat is 'Possible' may
also prove relevant at the 'Credible' stage.
It is important to view the investigation as
a continuum. Information collected through
the 'Possible' and 'Credible' stages of an
investigation should be evaluated in its
entirety.

Additional information that might be
considered to support the threat evaluation
and determine whether or not a contamination
threat is 'Credible' include site characterization
results, previous threats and incidents, and
information from external sources.
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Site Characterization Results

This includes observations from the site
investigation such as physical evidence (e.g.,
discarded equipment and containers) and
environmental indicators (e.g., dead animals,
dead vegetation, and unusual odors). This also
includes results from field safety screening and
rapid field testing of the wastewater. If it is
suspected that a contaminant may have already
entered the treatment plant, it may be useful to
examine archived samples  from a continuous
automatic sampling program if the utility
operates one.

Previous Threats and Incidents

Summary information derived from analysis of
previous incidents similar to the current threat
warning may be considered. This can include
incidents that have occurred at this utility as
well as incidents that have  occurred previously
in other parts of the country.
Information from External Sources

Information can also be obtained from
external sources to assist incident command
in determining whether a threat is 'Credible.'
Some potential external information sources
include:

  • Wastewater Permitting Agency
   •EPA
   • Water ISAC - (Water Information Sharing
    and Analysis Center) http://www.
    waterisac.org
   • NRC (National Response Center): Has
    experts trained to provide assistance in the
    case of a terrorist threat or incident. Also
    serves as a central point of contact for
    federal resources (1-800-424-8802).
   • Law Enforcement Agencies (from all
    levels of government)
   • FBI: The focus of the FBI's investigation
    will be the terrorism aspects of the threat.
    However, if the FBI determines that
    the event is 'Credible' from a terrorism
    perspective, the threat will likely also be
    considered 'Credible' from a utility and
    public health/safety perspective.
   • Neighboring Utilities and WARNs
   • Public Health Agencies
   •911 Call Centers
   • Homeland Security Warnings and Alerts

If a specific contaminant is suspected during
a threat, information about that contaminant
should be consulted to help establish the
'Credibility' and potential consequences of the
threat (e.g., toxicity and water solubility). A
resource for contaminant specific information
is EPA's Water Contaminant Information Tool
(WCIT) at http://www.epa.gov/wcit.

4.2 Response Actions Considered at
    the 'Credible' Stage

Once the decision has been made that the
threat of contamination is 'Credible,' the
response actions that are taken are designed to
minimize risk to public health/safety, private
property, the economy, infrastructure, and the
environment. The response is also aimed at
gathering additional information to ultimately
decide whether the contamination threat can be
'Confirmed.'
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The response actions taken at the 'Credible'
stage may have a greater impact on the public
than those taken at the 'Possible' stage. Four
response actions that may be considered at the
'Credible' stage, in conjunction with applicable
laws or regulations, include the following:

Sample Analysis

Once a threat has been deemed 'Credible,'
one of the first steps taken in an effort to
confirm a contamination incident should be
the analysis of samples that were collected
during site characterization. The recommended
analytical procedures for confirming the
presence of tentatively identified contaminants,
or analyzing wastewater samples for unknown
contaminants, are presented in Module 4:
Analytical Guide.

Continuation of Site Characterization
Activities

Once a threat is deemed 'Credible,' additional
site characterization and sampling activities
may be implemented in an attempt to confirm
a contamination incident. In cases where
a 'Credible' contamination threat is not
confirmed, the additional  site characterization
and sampling activities will help verify that
the wastewater has not been contaminated
and support the decision to return to normal
operations.

Law Enforcement Notification

If at this stage of the threat management
process it appears that an intentional act
may have been associated with the apparent
contamination event, law enforcement should
be contacted if they have not been contacted
previously.
Public Notification and Public Health/Safety
Response

As with the immediate operational response
actions taken following the decision that a
threat is 'Possible,' the goal of the public
health response actions taken after a threat
has been deemed 'Credible' is to minimize
risk to the population. However, the public
health response and safety actions at this stage
are elevated with respect to the impact on the
public. It is at this point that officials may need
to notify the public of the emergency under
existing laws or regulations or they may decide
to notify the public anyway in the absence of
a legal requirement to do so. For example, if
significant levels of flammable  or explosive
chemicals have entered the wastewater
collection system, either accidentally or due
to an intentional act, the nearby population
may be instructed to evacuate the area. If the
contaminant has entered the treatment plant,
plant personnel may be instructed to evacuate.
If the contaminant has passed through
the treatment plant, or the contaminated
wastewater has been released to the receiving
stream, downstream users, such as drinking
water treatment plants, should also be
contacted.

The Incident Commander (or Unified
Command) will typically make decisions
regarding  actions taken in response to
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a 'Credible' wastewater contamination
threat. Due to the elevated level of actions
considered at this stage, responsibility for
incident command may shift from the utility
Incident Commander to another individual
or organization. Additionally, at this point
local government may choose to activate their
Emergency Operations Center (EOC) to help
facilitate a coordinated response among the
participating agencies. Activation of the EOC
may be full or partial depending upon the
circumstances.

  The EOC is the physical location or
  headquarters in which the coordination
  of information and resources to support
  incident management takes place.  It is the
  support arm of the response effort. It is
  typically maintained by a community or
  jurisdiction (city, county, state) as  part of
  their emergency preparedness program.
  The EOC is usually located in a central,
  permanently established facility situated
  some distance from the incident. It is
  from this location that elected officials,
  top agency representatives, and EOC staff
  coordinate information and resources
  to support on-scene management of the
  incident which occurs at the Incident
  Command Post.

The Incident Command Post (ICP) is usually
where the Incident Commander or the Unified
Command, and their staff, are physically
located. The ICP is normally located as close
as possible to the site of the emergency. It is
from this location that incident command may
exercise tactical command and control over the
emergency response effort.

5 Stage III: 'Confirmed' Stage of
  Threat  Management Process

Confirmation represents the transition from
a contamination threat to a contamination
incident and requires definitive proof that the
wastewater has been contaminated. The most
reliable means of confirming a contamination
incident is through analytical confirmation
of the presence of a contaminant. However,
under some circumstances, it may be necessary
to confirm a  contamination incident in the
absence of definitive analytical data. This
is particularly true in cases where there are
challenges in collecting a representative
sample due to uncertainty about the point
of contaminant introduction, or due to a
significant amount of time having elapsed
between the  introduction of the contaminant
and receipt of the threat warning. In cases
where analytical confirmation is not possible, it
will be necessary to rely upon a preponderance
of evidence to confirm an incident. It may
take several  days to collect sufficient evidence
(analytical or non-analytical) to confirm a
contamination incident.

If the threat evaluation yields no conclusive
evidence of contamination, then there should
be a determination as to whether the threat still
appears to be credible. If it is still 'Credible,'
then additional investigation and analysis
are warranted. On the other hand, if incident
command decides that the threat is no longer
'Credible,' then the incident could be brought
to a close. However, the investigation at this
point will have to be sufficiently thorough to
demonstrate that the wastewater is  safe and the
system can be returned to normal operation.
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5.1 Information Considered at the
    'Confirmed' Stage

The types of information that might help
confirm a contamination incident include the
following:

Analytical Results

Positive identification of a contaminant
through sample analysis can confirm a
contamination incident and provide the basis
for making decisions about public health/safety
responses and remediation activities.

Additional Site Characterization Results

At the 'Confirmed' stage of the threat
management process, there will likely be
results from site characterization activities
performed at multiple locations. These results
should be reviewed collectively to explore any
potential trends in the data.

Information from External Sources

At this stage,  external resources can be
specifically targeted in light of the information
already collected. Information from these
resources may help to build the 'preponderance
of evidence' to confirm  an event in the absence
of laboratory identification of a contaminant.

5.2 Response Actions Considered at
    the 'Confirmed' Stage

Once a contamination incident has been
confirmed, it should be moved into full
response mode. At this point, depending on
the level of risk posed by the contamination
event, city, county, and/or state EOCs may
be activated in order to support an effective
and coordinated response (Figure 2-3).
Other organizations that may be actively
engaged in the response include: the
wastewater permitting agency, public health
officials, emergency response agencies, law
enforcement, and the WARN network. All of
the participating organizations will likely be
coordinated under existing incident command
structures designed to manage emergencies
at the local or state level. One agency will
likely be designated as a lead agency and be
responsible for incident command. In some
cases a Unified Command may established. If
federal agencies are involved in the response,
their roles are defined by the National
Response Framework
(http: //www. fema. gov/emergency/nrf/). In
any case, the utility will still have a role in the
implementation of full response actions.
Figure 2-3. Emergency Operations Center

Effective implementation of response
actions at this stage is enhanced by positive
identification of the contaminant and
knowledge of contaminant properties. In
particular, the appropriate public health
protection strategies, and selection of
treatment technologies, will depend on the
nature of the specific contaminant. It is vital
to perform a thorough investigation in order
to have confidence in any decisions about
response actions. This is especially true if
response actions are implemented on the basis
of a preponderance of evidence rather than
analytical confirmation.
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Once the incident has been confirmed, and
available information about the incident has
been analyzed, the public health response
measures already implemented should be
reassessed and revised if necessary. This might
include revisions to containment strategies or
public notifications. Once the immediate public
health crisis is under control, efforts will likely
focus on remediation and recovery.

6 Contamination Threat
   Management Matrices

Listed below is a series of Contamination
Threat Management Matrices. There is a
matrix (tabular summary) provided for each of
the nine threat warnings discussed in Section
3.1. Each matrix lists the following items at
each stage of the threat evaluation:
   • Information that should be considered in
    assessing the threat
   • Factors that should be considered in
    evaluating this information
   • Potential notifications
   • Possible response actions

While these matrices are generic, they can be
tailored to the needs of a specific utility and to
very specific incidents (e.g., security breach at
a particular wastewater facility).  The actions
in these matrices or additional actions may be
required by any laws or regulations that apply
to the situation. The customized Contamination
Threat Management Matrices could then be
used as an aid in development of a utility's
Emergency Response Plan and site specific
Response Guidelines.
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Security Breach

  Table 2-1: Recommendation for Threat Evaluation Stage - Security Breach
Possible Credible Confirmatory





Information











Evaluation










Notifications







Response





• Location of security
breach
Time of security breach
• Information from
alarms
Observations when
security breach was
discovered
• Additional details from
the threat \\arning

Was there an
opportunity for
contamination?
1 las normal operational
activity been ruled out?
• Have other "harmless"
causes been ruled out?






• Notifications within
utility
Local law enforcement
agencies





Isolate affected area
initiate site
characterization
• Estimate spread of
suspected contaminant
• Consult external
information sources



• Results of site
characterization at
location of security
breach
• Previous incidents
Real time wastevvater
chemical data from
location of breach
• Input from local law
enforcement

Do site characterization
results reveal signs of
contamination?
• Is this security breach
similar to previous
security incidents?
• Does other information
(e.g., wastevvater
chemical characteristics)
corroborate threat?
• Does law enforcement
consider this a credible
threat?
Wastewater primacy
agency
• State/local public health
agency
• FBI (if contamination
appears to be deliberate)




• Implement appropriate
public health/safety
protection measures
Consider steps to protect
wastewatcr system
(e.g., diversion of
contaminated
wastcwater) consistent
with applicable laws and
regulations
• Results of sample
analysis
Contaminant
information
• Results of site
characterization at
other investigation
sites
Input from permitting
agency and public
health agency
• Were unusual
contaminants delected
during analysis? Do
they pose a risk to the
public?
• Do site
characterization results
reveal signs of
contamination?
• Is contamination
indicated by a
"preponderance of
e\ idence?"
• Emergency response
agencies
National Response
Center
Other state and federal
assistance providers
WARN network
* Downstream users if
receiving stream was
contaminated
Characterize affected
area
Revise public health/
safety protection
measures as necessary
• Plan remediation
activities



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      6.2    Witness Account
              Table 2-2: Recommendation for Threat Evaluation Stage - Witness Account
Possible Credible Confirmatory






Information












Evaluation










Notifications









Response








• Location of the suspicious
activity
• Witness account of the
suspicious activity
• Additional details from the
threat warning







• Was there an opportunity
for contamination?
• Is (he witness reliable'.'
• Has normal operational
activity been ruled out?
• Have other "harmless"
causes been ruled out?






• Notifications within utility
Local law enforcement







Isolate affected area
• Initiate site
characterization
Estimate spread of
suspected contaminant
• Consult external
information sources
• Interview witness for
additional information





• Additional information
from the witness
• Results ot site
characterization at
location of suspicious
activity
• Previous incidents
* Real time wastewaler
chemical data from the
location of suspicious
activity'
• Input from local law
enforcement
• Do site characterization
results reveal signs of
contamination?
Is the suspicious aclivitj
similar to previous
security incidents?
• Does other information
(e.g., wastewater chemical
characteristics)
corroborate threat?
• Does law enforcement
consider this a credible
threat?
• Wastewaler permitting
agency
State/local public health
agency
FBI (if contamination
appears to be deliberate)



• Implement appropriate
public health/safety
protection measures
Consider steps to protect
wastewater system
(e.g., diversion of
contaminated wastcwaler)
consistent with
applicable laws and
regulations
• Analyze samples
• Perform site
characterization at
additional sites
• Results of sample analysis
• Contaminant information
• Results ol'site
characterization at other
investigation sites
Input from permitting
agency and public health
agency





• Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
• Do site characterization
results reveal signs of
contamination?
• Is contamination indicated
bv a "preponderance of
evidence?"



• Emergency response
agencies
• National Response Center
• Other state and federal
assistance providers
WARN network
• Downstream users if
receiving stream was
contaminated
Characterize affected area
• Review public health
protection measures as
necessary
• Plan remediation activities









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6.3   Direct Notification by Perpetrator

        Table 2-3: Recommendation for Threat Evaluation Stage - Direct Notification by Perpetrator
Possible Credible Confirmatory






Information












Evaluation










Notifications










Response








Transcript of phone (or
written) threat
1 he who. what, where.
when, and why of the
Ihreat
Additional details from the
threat warning
Vulnerability assessment





Is the threat feasible'.'
• Has the wastewater
already been
contaminated?
• Is the location known or
suspected1'
• Is the identity of the
perpetrator known or
suspected?
• 1 lave there been personnel
problems at the utility?


Notifications within utility
• Local law en Ibrcemem
• Wastewater permitting
agency





• Isolate affected area if
identified in the threat
Identify sites and initiate
site characterization
Consult external
information sources
• Gather information from
law enforcement
assessment






• Lavs enforcement
assessmenl
Primacy agency
assessment
• Previous threats at this
utility or other utilities
Results Of site
characterization at
selected investigation sites
Real time wasicwaier
chemical data
Reports from IS AC. RPA.
etc.
• Do site characterization
results reveal signs of
contamination?
• Does other information
( e.g. ,w as Lu water chemical
characteristics)
corroborate Ihreat?
• Does law enforcement
consider this a credible
threat?
Does tile permitting
agency consider this a
credible threat?
FBI
(ifcontamination appears
to be deliberate)
* Stale/local public health
agency
EPA Criminal
Investigation Division


* Implement appropriate
public health protection
measures
Consider steps to protect
wastewater system (e.g..
diversion of contaminated
wastewater) consistent
with applicable laws and
regulations
• Analyze samples
Perform site
characterization at
additional sites
• Estimate spread of
suspected contaminant
• FBI assessment
• Result:, of sample analysis
Contaminant information
• Results of site
characteri/ation at other
investigation sites
Input from permitting
agency and public health
agency




* Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
• Do site characterization
results reveal signs ol
contamination?
• K contamination indicaied
by a "preponderance of
evidence?"



Emergency response
agencies
• National Response Center
• Other state and federal
assistance providers
WARN network
• Downstream users if
receiving stream was
contaminated
• Characterize affected area
• Revise public health
protection measures as
necessary
• Plan remediation activities










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      6,4   Notification by Law Enforcement
              Table 2-4: Recommendation for Threat Evaluation Stage - Notification by Law Enforcement
Possible Credible Confirmatory





Information











Evaluation










Notifications










Response









Law enforcement report
The who, what, where,
when, and why of'lhe
threat
• Additional details from the
threat warning
• Vulnerability assessment




• 1 low did the threat
warning come to law
enforcement?
• Is the threat feasible?
• Has the wastewater
already been
contaminated?
Is a specific location
targeted?




• Notifications within utility
• Wastewater permitting
agency






Isolate affected area if
known
• Identify sites and initiate
site characterization
• Work with law
enforcement to a-sscis
lllreal credibility
Consult external
information sources







• Law enforcement
asses smenl
Previous security
incidents
• Results of site
characterization at
selected investigation sites
• Real lime wastewater
chemical data
Reports from 1SAC. EPA.
etc.
Do site characterization
results reveal signs of
contamination?
• Does other information
(e.g., wastewater chemical
characteristics)
corroborate threat?
Does law enforcement
consider this a credible
threat?
• Docs the permitting
agency consider this a
credible threat?
• FBI
(if contamination appears
to he deliberate)
• Slate/local public health
agency




• Implement appropriate
public health protection
measures
• Consider steps to protect
wastewater system
(e.g., diversion of
contaminated waslcwatcr)
consistent with
applicable laws and
regulations
• Analy/e samples
• Perform site
characterization at
additional sites
Estimate spread of
suspected contaminant
• FBI assessment
Results of sample analysis
• Contaminant information
• Results of site
characterization at other
investigation sites
Input from permitting
ngency and public health
agency


• Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
• Do site characterization
results reveal signs of
contamination?
Is contamination indicated
by a "preponderance of
evidence?"



• Emergency response
agencies
• National Response C'enter
• Other state and federal
assistance providers
WARN network
• Downstream users it"
receiving stream was
contaminated
• Characterize alTected area
Revise public health
protection measures as
necessary
• Plan remediation activities











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6.5   Notification by News Media

        Table 2-5: Recommendation for Threat Evaluation Stage - Notification by News Media
Possible Credible Confirmatory






Information












Evaluation










Notifications










Response








Details of media report
The who, what, where,
when and why ol'the threat
• Additional details from the
llircat warning
Vulnerability assessment







1 low did the threat
warning come to the
media?
• Is the threat feasible?
Mas the wastewaler
ul rcadv been
contaminated?
• Is a specific location
targeted?




Notifications within utility
• Local law enforcement
Wastewater permitting
agency





• Isolate a fleeted area it
known
• Identify sites and initiate
sile characterization
Contact news media for
additional details
• C onsult external
information sources







• Additional details from
media
• Law enforcement
assessment
• Previous securit)
incidents
• Results of site
characterization at
selected investigation sites
Real time wastcwater
chemical data
• Reports from ISAC. RPA,
etc.
• Do sile characterization
results reveal signs of
contamination','
• Does other information
(e.g., \vastewalerchemieal
characteristics)
corroborate threat?
Does law enforcement
consider this a credible
threat?
Does the permitting
agency consider this a
credible threat?
FBI
(ifcomamination appears
to be deliberate)
• Slate/local public health
agency




• Implement appropriate
public health protection
measures
Consider steps to protect
waste water system (e.g..
diversion of contaminated
wastcwater) consistent
with applicable laws and
regulations
Analyze samples
• Perform sile
characterization at
additional sites
• Lstimalc spread of
suspected contaminant
• FBI assessment
• Results of sample analysis
• Contaminant information
• Results of site
characterization at other
investigation sites
• Input from permitting
agency and public health
agency




* Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
Do site eharacleri/atitiii
results reveal signs ol
contamination?
• Is contamination indicaled
by a "preponderance of
evidence?"



Emergency response
agencies
• National Response Center
• Other stale and federal
assistance providers
WARN network
• Downstream users if
receiving stream vvas
contaminated
• Characterize affected area
Revise public health
protection measures as
necessary
• Plan remediation activities










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      6.6   Unusual Water Quality
              Table 2-6: Recommendation for Threat Evaluation Stage - Unusual Water Quality
Possible Credible Confirmatory




Infomistion














Evaluation













Notifications










Response








• Unusual wastewater
chemical data
• Baseline wastewater
chemical data
• Real time wastewater
chemical data
• Operational information
corresponding to the time
of the unusual water
quality
• Are the unusual
wastewater chemical
values significantly
different from an
established baseline?
• Could operational changes
be the cause?
• Arc there similar results at
other monitoring
locations?









• Notifications within utility








• Identify sites and initiate
site characterization
• Begin analysis of available
wastewater chemical data
Investigate any unusual
public complaints
• Consult external
information sources







• Results ofsite
characterization at
selected investigation sites
• Previous threat warnings
triggered by changes in
wastewater chemistry
• Contaminant information
• Public complaints


Do site characterization
results reveal signs of
contamination?
• Are these unusual data
substantially different
from previous episodes
involving changes in
wastcwaler chemistry?
Are the unusual
wastewaler chemical data
indicative of a specific
contaminant?
• Are the unusual
wastewater chemical
results clustered in a
specific area?
• Are there any unusual
public complaints in the
area? (e.g., odors)
Wastewater permitting
agency
Slate/local public health
agency
• Local law enforcement
• im
(if contamination appears
to be deliberate)

• Implement appropriate
public health protection
measures
• Consider steps to protect
waslewater system (e.g.,
diversion of contaminated
wastewater) consistent
with applicable laws and
regulations
* Analyze samples
• Perform site
characterization at
additional sites
• Estimate spread of
suspected contain inam
• Results of sample analysis
• Contamination
information
• Results of site
characterization at other
investigation sites
• Input from permitting
agency and public health
agency

• Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
• Do site characteri/ation
results reveal signs of
contamination?
• Is contamination indicated
by a "preponderance of
evidence?"









Emergency response
agencies
• National Response Center
• ( )lhcr slate and federal
assistance providers
• WARN network
« Downstream users if
receiving stream was
contaminated
• Characterize affected area
• Revise public health
protection measures as
necessary
« Plan remediation activities










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6.7   Degradation of Treatment Organisms

        Table 2-7: Recommendation for Threat Evaluation Stage - Degradation of Treatment Organisms
Possible Credible Confirmatory




Information









Evalustion










Notifications








Response






Extent of degradation
Time of degradation
• Additional signs of
contamination





• Was (here an
opportunity tor
contamination?
Has normal operational
activity been ruled out?
* Have other "harmless"
causes been ruled out?





• Notifications within
utility







• isolate affected area
• Initiate site
characterization
• F,stimate spread of
suspected contaminant
• Consult external
information source




• Results of site
characterisation at
location of suspected
contamination
Previous incidents
Real time waste water
chemical data
• Input from local law
enforcement

• Do site characterization
results reveal signs of
contamination?
Is this degradation of
treatment organisms
similar to previous
contamination
incidents?
• Does other in formation
(e.g., waslewater
chemistry) corroborate
threat?
• Wastewaler permitting
agency
• State/local public
health agency
• Local law enforcement
and FBI
(if contamination
appears to be
deliberate)

• Implement appropriate
public health/safety
protection measures
Consider steps to
protect wastewaier
system (e.g. diversion
of contaminated
wastewater)
consistent with
applicable laws and
regulations
• Results of sample
analysis
• Contaminant
information
Results of site
characterization at
other investigation sites
• Input from permitting
agency and public
health agency
• Were unusual
contaminants detected
during analysis? Do
they pose a risk to the
public?
• Do site characterisation
results reveal signs of
contamination?
• Is contamination
indicated by a
"preponderance of
evidence?"
• limergency response
agencies
• National Response
Center
• Other state and federal
assistance providers
WARN network
• Downstream users if
receiving stream was
contaminated
• Characterize affected
area
Revise public health
protection measures as
necessary






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      6.8   Public Complaints
              Table 2-8: Recommendation for Threat Evaluation Stage - Public Complaints
Possible Credible Confirmatory





Information












Evaluation











Notifications










Response











• Compilation of public
complaints, including
geographic distribution
(e.g., unusual odors
emanating from sewers)
• Recent waste water
chemical dala that may be
associated \vith complaints
• Operational information
corresponding to the time
of the unusual complaints
• Are the complaints
unusual?
• Could operational changes
be the cause?
* Are the complaints
clustered in a specific
urea?
• Are complaints from
habitual complainers'.'







• Nolilicalions within utility








Identify sites and initiate
site characterizations
• Begin analysis of available
waslewater chemical data
• Interview people in area
with high numbers of
complaints
• Consult external
information sources









• Results of site
characterization at
selected investigation sites
• Summitry of historic
public complaints
• Contaminant information





• Do site characterization
results reveal signs of
contamination?
• Are other people in the
area making similar
complaints?
• Are the unusual
complaints significantly
different from typical
complaints?
• Are the complaints
indicative of a specific
contaminant?
• Is there anything unusual
about the water quality in
the area?
• Waslewater permitting
agency
• Stale/local public health
agency
Local law enforcement
[;BI
(if contamination appears
to be deliberate)

• Estimate affected area and
isolate if possible
• Implement appropriate
public health/safety
protection measures
Consider steps to protect
wastewater system
(e.g., diversion of
contaminated wastewater)
consistent with
applicable laws and
regulations
• Analyze samples
• Perform site
characterization at
additional sites
• Estimate spread of
suspected contaminant
• Results ot sample analysis
Contaminant information
• Results of site
characterization at other
investigation sites
• Input from permitting
agency and public health
agency



• Were unusual
contaminants detected
during analysis? Do they
pose a risk to the public?
• Do site characterization
results reveal signs of
contamination?
Is contamination indicated
by a "preponderance of
evidence?"






• Emergency response
agencies
• National Response Center
• Other slate and federal
assistance providers
WARN network
• Downstream users if
receiving stream was
contaminated
• Characterize affected area
• Review public health
protection measures as
necessary
Plan remediation activities













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6.9   Public Health Notification

        Table 2-9: Recommendation for Threat Evaluation Stage - Public Health Notification
Possible Credible Confirmatory




Information











Evaluation











Notifications








Response




• Details of notification
from public health
sector
• Symptoms of health
effects and causative
agent, if known
• Contaminant
information


* Why is wastewater
under investigation as a
possible source?
Are the reported
symptoms consistent
with exposure to the
contaminant via
wastewater?
• If causative agent is
known, is it stable in
water?




• Notifications within
utility
• State/local public health
agency
• Wastewater permitting
agency




• Consult with public
health agency and
permitting agency
• Consult external
information sources




• Geographic distribution
of health effects
• Recent wastewater
chemical and
operational data
• Reports of public
complaints
• Contaminant
information

• Is the geographic
pattern of exposure
consistent with
exposure to
contaminated
wastewater?
• Is there a recent
occurrence of unusual
water quality data or
public complaints?
Does additional
in formation about the
potential contaminant
indicate wastewater as
a potential source?
• FBI
(if contamination
appears to be
deliberate)
Local and State law
enforcement agencies




• Estimate affected area
and isolate if possible
• Implement appropriate
public health/safety
protection measures
• Identify additional sites
and initiate site
characterization
• Analyze samples
• Results of site
characterization at
selected investigation
sites
• Results of sample
analysis
• Contaminant
information
• Law enforcement and/
or FBI assessment
• Has the public health
agency concluded that
wastewater is the cause
of the health effects?
• Did sample analysis
detect the causative
agent?
• Was another
contaminant detected
during sample analysis
that could be the cause
of the health effects?



• Emergency response
agencies
• National Response
Center
Other state and federal
assistance providers
WARN network
• Downstream users if
receiving stream was
contaminated
• Characterize affected
area
Revise public health/
safety protection
measures as necessary
• Plan remediation
activities


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          7 Summary

          Because of the potentially serious impacts of
          a wastewater contamination event on public
          safety/ health, private property, and wastewater
          infrastructure, contamination threats should
          be evaluated and managed in a timely and
          systematic manner. Improper management
          of a threat can lead to overreaction to a
          false alarm or underreaction to a dangerous
          situation. Module 2 of the WWRPTB presents
          recommendations to systematically process
          a suspicion of intentional or accidental
          contamination of a wastewater system. Utilities
          can use these suggestions for evaluating threats
          and responding accordingly when they prepare
          or upgrade their Emergency Response Plans
          and Response Guidelines.
 CS
 i_
          8 Appendices

          The following are examples of forms that may
          be used to facilitate the public health response:
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            • Response Planning Matrix
            • Threat Evaluation Worksheet
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            • Security Incident Report Form
            • Witness Account Report Form
            • Phone Threat Report Form
            • Written Threat Report Form
LU
            • Public Health Information Report Form

          These forms can be found in the Appendices
          located at the end of the Toolbox.
      2-24                        Wastewater Response Protocol Toolbox

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&EPA
   United States
   Environmental Protection
   Agency
Wastewater Response Protocol
Toolbox:
Planning For and Responding To
Wastewater Contamination
Threats and Incidents
December 2011
Module 3:
Site Characterization and Sampling Guide

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                        Table of Contents - Module 3

1 Introduction [[[ 3-1
2 Overview of Recommended Site Characterization Process [[[ 3-2
3 Safety and Personnel Protection [[[ 3-12
4 Roles and Responsibilities for Site Characterization [[[ 3-13
5 Summary [[[ 3-14
6 Appendices [[[ 3-14
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                                  ( Planning and Preparation )

                                             O
                                        Threat Warning
                                    Initial Threat Evaluation
(A

Immediate Operational
  Response Actions
                 i>
 Site Characterization
    and Sampling
              Public Health
            Response Actions
                                        Sample Analysis
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                            HI
                                          Is Incident
                                          Confirmed
                                   Remediation and Recovery
                              Wastewater Response Protocol Toolbox

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1 Introduction

Site characterization and sampling are
activities that should be initiated in response
to a 'Possible' contamination threat in order
to determine whether or not the threat is
'Credible.' Site characterization is the process
of collecting information concerning a
'Possible' contamination event. If a suspected
contamination site has been identified, it
will likely be designated as the primary
investigation site. Additional or secondary sites
may be identified to investigate the potential
spread, or source, of a suspected contaminant.
For example, this could include monitoring
of the influent pump station wet well at the
treatment plant headworks if contamination
is suspected in the wastewater collection
system. The results of site characterization are
critically important to the threat evaluation
process. Note that in some cases,  the evidence
or observations gathered during the site
characterization could be sufficient to elevate
the threat evaluation from 'Possible' to
'Credible' and even 'Confirmed.'

Module 3 describes recommended procedures
for carrying out the site characterization
activities. These procedures may be adapted
to a utility's specific needs consistent with any
applicable laws or regulations.
There are two broad phases of site
characterization: planning and implementation.
The Incident Commander is typically
responsible for planning while the Site
Characterization Team is typically
responsible for actually implementing the Site
Characterization Plan. This module provides
information for those involved in either the
planning or implementation phases of site
characterization. While the target audience
is primarily wastewater utility managers and
staff, other organizations may be involved
in site characterization. Therefore, this
module may also be useful for a variety
of first responders including police, fire,
HazMat responders, FBI and EPA criminal
investigators, National Guard Civil Support
Teams, and environmental response teams
from EPA and other government agencies.
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           2 Overview of Recommended Site Characterization Process
           Process Overview
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           The recommended site characterization process includes five stages. These are shown in the
           flowchart in Figure 3-1, and are described in the narrative that follows.
[THREAT:
                       Customize the
                   Site Characterization Plan
                          V
                     Approaching the Site
                          V
                                              Collect Samples
                                              Exiting the Site
                                                                       Initial evaluation
                                                                     Identify investigation site
                                            Characterize site hazards
Characterize the Site



                                                  Form Site
                                              Characterization Team
 Conduct field
safety screening
                                            Observe site conditions and
                                            determine signs of hazard
                                                 Repeat field
                                                safety screening
                                               Investigate site and
                                               evaluate hazards
                                                Conduct field
                                                water testing
                       Place samples In
                       secure storage
                                                  V
                     Ship samples to lab
           Figure 3-1. Site Characterization Process
        3-2
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Customize the Site Characterization Plan

A Site Characterization Plan should be
customized for a specific threat, from the
utility's generic Site Characterization Plan.
The generic Site Characterization Plan should
be developed as part of a utility's prior
preparation for responding to both intentional
and accidental contamination threats, and
should be designed to be adaptable to a
variety of situations. The generic plan may
contain information on pre-entry criteria
(i.e., under what circumstances a particular
team, such as a utility team, may execute the
site characterization), communications, team
organization and responsibilities, safety, field
testing details, sampling details, and a protocol
for exiting the site. The customized plan should
guide the team during site characterization
activities and be based on the specific
circumstances of the current threat warning.
The Site Characterization Team typically will
use the customized plan as the basis for their
activities at the investigation site. A template
for the development of a Site Characterization
Plan is provided in Appendix 8.

During the development of the customized
plan, it is important for the Incident
Commander to conduct an initial assessment
of site hazards, which is critical to the safety of
the Site Characterization Team.

The initial assessment of site hazards will
impact the makeup of the team. Under low
hazard conditions, a utility team may perform
site characterization. If there are obvious signs
of more hazardous conditions (radiological,
chemical, or biological contamination), then
teams trained in hazardous materials safety
and handling techniques (HazMat) may need
to conduct an initial hazard assessment and
clear the site for entry by utility personnel.
Alternatively, the HazMat team may decide
to perform all site characterization activities
themselves. The composition of the Site
Characterization Team should be consistent
with the role that  the utility has assumed
beforehand in threat/incident response.
Obvious signs of hazard 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 human intervention. In this
case, law enforcement may take over the site
investigation.
  Four hazard categories are considered in the context of site characterization:

  Low Hazard - no obvious signs of radiological, chemical, or biological contaminants
  present at the site (i.e., in the air or on surfaces). Contaminants that may be present are
  assumed to be dilute and confined to the wastewater.

  Radiological Hazard - presence of radiochemical isotopes or emitters tentatively identified,
  at the site, in the air or in the wastewater (i.e., through the use of field radiation detectors).

  Chemical Hazard - presence of highly toxic chemicals (e.g., chemical weapons or
  biotoxins) or volatile toxic industrial chemicals, tentatively identified at the site in the a
  in the wastewater, with a potential risk of exposure through dermal or inhalation routes

  Biological Hazard - presence of pathogens, tentatively identified at the site, with a potential
  risk of exposure through dermal or inhalation routes.
                                    air or
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            Figure 3-2 illustrates how information from recommended site characterization activities may be used
            to refine the hazard assessment, which in turn may influence the course of the site characterization.
                                                 /	\
                                                 (THREAT)

                                                 V
                                       Site Characterization Planning
                                       •Preform initial site hazard assessment
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                                  Approach site
                                  •Conduct field safety screening
                                  •Observe site for hazards
                               Report findings to Incident Command
                                       and access site
                                                                     Halt Site Characterization
                                                                      Contact law enforcement and
                                                                          HazMat responders
                              Characterization of site
                              •Conduct field safety screening
                              •Observe site for signs of hazard
                              •Conduct rapid field testing of wastewater
                                           IF
                                        Report findings to Incident Command
                                                and access site
                                                „'         »»
                                             f»* Approval to  »^
                                              **»» enter site? .*'
                                           Collect wastewater samples
                                                   Exit site
                                            Notify Incident Command
            Figure 3-2. Integration of site hazard assessment into site characterization process
3-4
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Approach the Site

Before entering the site, an initial assessment
of conditions and potential hazards should be
conducted at the site perimeter. As part of this
assessment, the Site Characterization Team,
upon arrival at the perimeter, should conduct
a field safety screening and observe site
conditions.

The purpose of the field safety screening
activities is to identify potential environmental
hazards that might pose a risk to the Site
Characterization Team. The screening may
include tests for radioactivity and atmospheric
screening for ambient combustible gases, toxic
gases, and volatile organic compounds (VOCs).
Flammable or explosive gases can be detected
using a Lower Explosive Limit (LEL) meter
and/or a combustible gas detector. Non-specific
VOCs can be detected with a Photoionization
Detector (PID) Total Organic Vapor Detector.
Specific VOCs can be detected and identified
with field portable gas chromatography (GC) or
gas chromatography-mass spectrometry (GC-
MS). The team should also conduct a visual
inspection of the site to detect signs of hazard
(e.g., dead animals, dead vegetation, discarded
equipment, gloves, and containers).

If the team detects signs of hazard, they should
stop their investigation and contact the Incident
Commander to report their findings. If no
immediate hazards are identified during the
approach to the site, the Incident Commander
will likely direct the team to enter the site and
perform the site characterization (Figure 3-3).

Observations made during the approach to
the site should be documented using a form
such as the Site Characterization Report Form
in Appendix 9. The results of the field safety
screening should be documented using a form
such as the Field Testing Results Form included
in Appendix 10.
Figure 3-3. Operator Using a Field Meter for
Site Characterization.

Characterize (Investigate) the Site

During this stage, the team should repeat
the field safety screening (at the site itself),
conduct a detailed visual investigation of
the site, and perform rapid field testing of
the wastewater that is suspected of being
contaminated. Rapid field testing may include
the collection of samples based on the process
outlined in the section below. Details observed
during the visual inspection of the site can also
be documented using the form in Appendix 9.

Rapid field testing of the wastewater 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 by laboratory testing.
   3. Determine if hazards tentatively identified
    in the wastewater require special handling
    precautions for sample collectors.
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The field testing performed on wastewater
should be based on the circumstances of
the specific threat and should be consistent
with the training and resources of the Site
Characterization Team. A core set of rapid
field tests includes measurement of pH,
conductivity, and radioactivity (including
alpha, beta, and gamma radiation). Abnormal
pH, conductivity, or radioactivity values may
indicate a problem.

In addition to the core tests, the Site
Characterization Team may conduct expanded
field testing of wastewater commensurate
with their training and resources (Figure 3-4).
Expanded field testing may include screening
for combustible gases in the headspace of a
wastewater sample using an LEL gas detector.
It may also include non-specific screening for
VOCs using a sample headspace total organic
vapor PID detector, or specific detection and
identification of VOCs using a portable GC/
MS.  Screening for gases in a manhole can
include measurements at two inches below the
lip and repeated measurements  after lowering
the probe to a point just above the wastewater
surface.  Toxicity screening may be conducted
using acute toxicity screening tests, and
biotoxins and pathogens may be detected using
Polymerase Chain Reaction (PCR) technology.
   It is important to note that negative rapid field test results are not a reason to forgo
   sample collection since field testing is limited in scope and can result in false negatives.
   This is especially true given the complicated analytical matrix presented by wastewater.
   It is also important to emphasize that any field detectors or kits used during an
   emergency should be evaluated and characterized with respect to performance, and a
   baseline established before an emergency for the monitored parameter. Use of detectors
   or equipment that have not been characterized may lead to greater uncertainty with
   respect to how to respond, especially if the tests produce false positive results.

Results of rapid field testing of the wastewater can be documented using the Field Testing
Results Form in Appendix 10.
                              Figure 3-4. Operator Conducts Field Testing at a Treatment Plant.
       3-6
                        Wastewater Response Protocol Toolbox

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Collect Samples

Following rapid field testing of the wastewater,
samples of the suspect wastewater should be
collected for potential laboratory analysis.
The purpose of sampling from a suspected
contamination site is to obtain and preserve a
sample of the wastewater at a particular time
and location so that it can be analyzed later
if necessary. The decision to send samples to
a laboratory for analysis should be based on
the outcome of the threat evaluation. If the
threat is determined  to be 'Credible,' then
samples should be immediately delivered to a
laboratory for analysis. 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.

In order to sample effectively, sampling
requirements should be considered during
the development of the customized Site
Characterization Plan.  Factors to consider
during the development of the sampling
approach include:

   • Which contaminants or contaminant
    classes will be analyzed for?
   • 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?

Under low hazard conditions, no special
sampling techniques may be necessary
beyond good safety practices as outlined later
in this module. If the site is characterized
as a radiological hazard during field safety
screening or the rapid field testing of
wastewater, then samples should be collected
for radiological analysis by personnel
trained and equipped to work at radioactive
contamination sites. If the site is characterized
as a chemical hazard, dilution of samples
collected for chemical analysis may be an
appropriate sampling strategy to reduce risk
during sample transport and analysis. Finally,
if the site is characterized as a biological
hazard, pathogen sampling may require the
collection of a large volume of wastewater for
subsequent concentration in the lab.

Critical information for each sample should be
documented. The same information captured
on the sample labels should be transferred to
a sample documentation form to serve as a
sample inventory. Appendix 11 contains an
example documentation form. Additionally,
sample custody should be closely tracked and
documented using a chain of custody form. See
Appendix 12 for an example of this form.

EPA has recently published additional guidance
on sample collection entitled Sampling
Guidance for Unknown Contaminants
in Drinking Water (EPA-817-R-08-003,
November 2008) (see www.epa.gov/
watersecurity; search under Water Laboratory
Alliance). While this document is intended
for drinking water applications, it may also be
useful for wastewater sampling.
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          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. The sample collection kit described in this

          section is intended to illustrate the types 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.
Table 3-1: Example Design of an Emergency Wastewater 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
Table 3-2
1
4
3 rolls
N/A
1
1
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
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Table 3-1 (cont.): Example Design of an Emergency Wastewater Sample Collection Kit
Item Quantity Notes
1 qt. zippered freezer bags
Thermometer
Paper towels
1 pack 100
2
2 rolls
For double bagging ice and sample
containers
For checking water temperature
Wiping wet containers and containing spills
Reagents (may need to be kept separate from the rest of the kit)
Laboratory grade water
6 Molar ACS grade hydrochloric acid (HCI)
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
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25 ml
25 ml
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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 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
1 box
2 pairs
2
4
20 liters
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1 gallon
2
1
3
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One per individual (minimum)
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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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    Exit the Site
    
    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,
    collected all equipment and samples, and re-
    secured the site (e.g., locked doors, hatches,
    and gates).
    
    If the site is considered to be a hazardous site,
    special procedures for exiting the site may be
    required by HazMat officials. 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 may be responsible
    for collecting and preserving any physical
    evidence (such as empty containers, or
    discarded equipment).
    
    The site characterization activities presented
    in this module range from relatively simple
    activities, such as visual inspection of the site,
    to complex activities, such as field testing of
    the air, environmental surfaces, and wastewater
    for unusual contaminants. The wastewater
    utility should decide in advance the extent
    of site characterization activities that they
    will perform within their own organization
    and those that would be provided by external
    organizations. For example, a utility may
    choose to develop a capability for performing
    the visual inspection and core field testing
    at low hazard sites. The utility may make
    arrangements with HazMat responders to
    provide support during the characterization of
    potentially more hazardous sites. The utility
    may also arrange with a contract lab to provide
    sample kits and sample containers.  It is critical
    that the utility plan ahead of time 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 capabilities. Tabletop and
    operational-based drills and exercises provide
    training opportunities to improve coordination
    between the utility and response agencies.
    
    3 Safety and  Personnel Protection
    
    Proper safety practices are essential for
    minimizing risks 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 with applicable laws and
    regulations including work safety regulations
    under the Occupational Safety and Health
    Administration. These include OSHA
    1910.120 (http://www.osha.gov), which deals
    with hazardous substances.
    
    Basic good safety practices  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).
          3-12
                             Wastewater Response Protocol Toolbox
    

    -------
    The appropriate level of personal
    protection necessary to safely perform site
    characterization activities will depend on
    the assessment of site hazards that might
    pose a risk to the Site Characterization
    Team. Site hazard assessment is conducted
    during the development of the customized
    Site Characterization Plan and continues
    throughout the period of time that the team
    occupies the investigation site. Two general
    scenarios are 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 will
    not present a significant hazard and basic
    equipment and training will be sufficient to
    conduct site  characterization activities safely.
    This would typically be the  case for a routine
    security breach such as an open manhole cover.
    Under these  conditions it  may be reasonable
    to presume that any contaminants that might
    be present are confined to the wastewater and
    are present at dilute concentrations. Risk to
    personnel may be minimized through the use
    of good safety practices, including:
    
       • Do not eat, drink, or smoke at the site
       • Do not smell wastewater samples
       • Use basic personal protective equipment -
         • Splash proof goggles
         • Disposable gloves
         • Disposable foot covers
         • Disposable lab coat
       • Avoid skin contact with wastewater
       • Fill sample containers slowly to avoid
        volatilization or aerosolization of
        contaminants
       • Minimize time that personnel are on site
    In other cases obvious signs of hazards may
    be observed at the time the threat is discovered
    or during the approach to the site. Under
    these conditions, only personnel with proper
    equipment and training (e.g., HazMat teams)
    should enter the site.
    
    4  Roles and  Responsibilities for
    Site Characterization
    
    The Incident Commander, Operations
    Section Chief and the site characterization
    Team Leader are key personnel in site
    characterization.  The Incident Commander
    should have overall responsibility for
    managing 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. The Operations Section Chief is
    responsible for all field activities and serves as
    the liaison between the Incident Commander
    and the Site Characterization Team Leader.
    The Site Characterization Team Leader
    should be responsible for implementing the
    Site Characterization Plan in the field and
    supervising site characterization personnel.
    
    Depending on the nature of the contamination
    threat, other agencies and organizations
    may be involved or assume responsibility
    during planning and implementation of site
    characterization activities. Some of these
    organizations and roles are described below.
    
    Wastewater Utility
    
    The utility may provide the Incident
    Commander unless another organization is so
    designated to provide that role.
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    HazMat Response Teams
    
    In coordination with utility staff, these HazMat
    Teams may assume responsibility for oversight
    of site characterization activities in situations
    where hazardous materials are suspected.
    
    Technical Assistance Providers
    
    The wastewater primacy agency, EPA
    hazardous material responders, or other
    specially trained response teams may be
    consulted for technical assistance and in some
    cases be requested to take responsibility for
    planning, oversight, and implementation of site
    characterization activities.
    
    Laboratories
    
    Laboratories are responsible for timely
    analysis of samples collected by the Site
    Characterization Team in response to a
    contamination threat.
    
    Local Law Enforcement Agencies
    
    These agencies may assume responsibility
    for incident command in situations where
    criminal activity, excluding a federal crime, is
    suspected.
    
    FBI
    
    The FBI is expected to assume incident
    command for the investigation aspects of the
    situation when terrorism is suspected. If the
    FBI becomes involved they would likely make
    the credibility determination.
    
    EPA
    
    The EPA may provide technical advice for site
    characterization or other components of the
    Threat Management process, and may provide
    personnel for site characterization if requested
    by a state regulatory agency. In cases where a
    contamination threat or incident is not an act
    of terrorism, EPA's CID will typically be the
    lead federal agency for law enforcement in the
    response.
    
    5 Summary
    
    Once the determination has been made that
    a contamination event is 'Possible,' it is
    appropriate to conduct a site characterization to
    help determine whether the threat is 'Credible.'
    Site characterization is the investigation of
    the suspected site of contamination as well as
    other locations where contaminants may have
    spread or originated.  Site characterization
    should be carried out systematically and
    involves customization of a general Site
    Characterization Plan followed by the actual
    investigation. The investigation includes
    physical inspection of the site, field safety
    screening of the environment, rapid testing
    of the suspect wastewater, and sample
    collection. While it is important to conduct
    a thorough investigation of the  site and
    collect representative samples, it is also
    important to minimize the risk faced  by the
    Site Characterization  Team. Module 3: Site
    Characterization and Sampling Guide suggests
    a protocol to accomplish all of these goals.
    
    6 Appendices
    
    The following are examples of forms that may
    be used to facilitate the public health response:
       • Site Characterization Plan Template
       • Site Characterization Report Form
       • Field Testing Results Form
       • Sample Documentation Form
       • Chain of Custody Form
    
    These forms can be found in the Appendices
    located at the end of the Toolbox.
          3-14
                            Wastewater Response Protocol Toolbox
    

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    &EPA
      United States
      Environmental Protection
      Agency
    Wastewater Response Protocol
    Toolbox:
    Planning For and Responding To
    Wastewater Contamination
    Threats and Incidents
    December 2011
    Module 4:
    Analytical Guide
    

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                             Table of Contents - Module 4
    
    1 Introduction	 4-1
      1.1 Objectives of this Module	4-1
    2 Current Laboratory Infrastructure in U.S	4-1
      2.1 Environmental Chemistry Labs	4-3
      2.2 Radiochemistry Labs	4-4
      2.3 BiotoxinLabs	4-4
      2.4 Chemical Warfare Labs	4-4
      2.5 Microbiological Laboratories	4-4
    3 Health and Safety	4-5
    4 Analytical Approach for Unidentified Contaminants in Wastewater	4-7
    5 Basic Screening for Organic and Inorganic Chemicals Using Standard Methods 	4-9
    6 Expanded Screening for Chemicals	4-15
      6.1 Expanded Screening for Organic Compounds - Sample Preparation Techniques	4-16
      6.2 Expanded Screening for Organic Compounds - Detection Methods	4-17
      6.3 Expanded Screening for Inorganic Chemicals	4-19
                                                                                               T3
      6.4 Expanded Screening for Cyanides	4-21
      6.5 Expanded Screening for Biotoxins	4-21
      6.6 Expanded Screening for Chemical Weapons	4-21
      6.7 Basic and Expanded Screening for Radionuclides	4-22
                                                                                                ^^>
    7 Additional Recommendations for Chemical Screening of Wastewater Samples	4-24
                                                                                                C
    8 Screening for Microbiologicals Including Unknowns	4-25
    9 Forensic Implications of Sample Collection and Analysis	4-26
    10 Data Analysis and Reporting	4-26
    11 Summary	4-27
                                                                                               o
                            Wastewater Response Protocol Toolbox
    

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      WA
    
                                         Planning and Preparat
                                ion )
                                              Threat Warning
                                          Initial Threat Evaluation
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             Immediate Operational
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                                           Site Characterization
                                              and Sampling
                                               Public Health
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                                        Remediation and Recovery
                                    Wastewater Response Protocol Toolbox
    

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    1 Introduction
    
    1.1 Objectives of this Module
    
    The primary intended users of this module
    include laboratory personnel and planners
    who would provide analytical support
    to a wastewater utility in the event of a
    contamination threat. This module is intended
    to be a planning tool for labs rather than
    a how-to manual for use during an actual
    incident. As part of planning for such an
    incident, laboratories may want to prepare a
    detailed 'Laboratory Guide' specific to their
    needs and capabilities. Also, laboratories may
    want to consider how they coordinate with
    networks of other laboratories so as to provide
    added capability and capacity.
    
    The objectives of this module include:
    
      1. Describing how laboratories can
        respond to contamination events.
      2. Describing special laboratory
        considerations for handling and
        processing emergency wastewater
        samples suspected of contamination
        with a harmful substance.
      3. Presenting model approaches and
        procedures for analysis of wastewater
        samples suspected of contamination
        with a known or unknown substance.
        These analytical approaches are
        intended to take advantage of existing
        methodologies and infrastructures.
      4. Encouraging planners to develop a
        site-specific analytical approach and
        Laboratory Guide that conforms to
        the general principles of the model
        approaches presented in this module.
    Roles of Laboratories in Response to
    Contamination Threats
    
    While utility labs, especially at larger utilities,
    may become quite involved with preliminary
    screening and preliminary analysis of samples
    from suspected contamination events, most
    will not be able to implement all of the
    analytical protocols described in Module 4.
    Federal, state, and commercial labs may be
    called upon to provide more sophisticated, in-
    depth analyses.
    
    2 Current Laboratory
       Infrastructure in U.S.
    
    The analytical approach described in this
    module was developed under the assumption
    that it would be implemented using the
    existing laboratory infrastructure in this
    country. EPA established the Environmental
    Response Laboratory Network (ERLN) to
    assist in addressing chemical, biological, and
    radiological threats during nationally significant
    incidents. The Water Laboratory Alliance
    (WLA), which launched in October 2009,  is the
    water component of the ERLN and provides the
    Water Sector (drinking water and wastewater
    systems) with an integrated nationwide network
    of laboratories. The WLA provides additional
    analytical capability and capacity to an event
    involving intentional and unintentional water
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       contamination involving chemical, biological
       and radiochemical contaminants. For more
       information, visit http://www.epa.gov/erln/
       water.html.
    
       Also, the WLA has a Water Laboratory
       Alliance - Response Plan (WLA-RP) (EPA
       817-R-10-002, November 2010) that outlines
       the processes and procedures for a coordinated
       laboratory response to water contamination
       incidents that may require more analytical
       laboratory capability and capacity than a
       typical laboratory can provide. It addresses
       analytical demand during the emergency
       response, remediation, and recovery phases of
       a natural disaster, accident, or terrorist incident
       affecting the water sector, (http://water.epa.
       gov/infrastructure/watersecurity/wla/upload/
       WLAResponsPlan_November2010.pdf)
    
       EPA has constructed a Laboratory
       Compendium to assist utilities and other
       responders in locating appropriate labs
                         for analysis of contaminants during a
                         contamination incident. The Laboratory
                         Compendium is a database of laboratory
                         capabilities for environmental analysis in
                         water, air, soil, sediment, and other media.
                         Instructions on acquiring access to the
                         Laboratory Compendium are available at
                         the following website: http://www.epa.gov/
                         compendium.
    
                         The ERLN is also part of a larger federal
                         network of laboratories called the  Integrated
                         Consortium of Laboratory Networks (ICLN).
                         The Department of Homeland Security
                         established the ICLN to coordinate laboratory
                         networks to respond to acts of terrorism and
                         other major incidents. ICLN is composed of
                         networks of Federal laboratories from U.S.
                         Department of Agriculture, Department of
                         Health and Human Services (Centers for
                         Disease Control and Prevention, Food and
                         Drug Administration), Department of Defense,
                         and the Environmental Protection  Agency.
          Analytical Goals
    
          In responding to contamination incidents (intentional or unintentional), keep in mind the
          following analytical goals or points:
    
             • Protect laboratory personnel and provide timely, accurate results.
             • Confirm or rule out the presence of significantly elevated levels of certain types or
              classes of contaminants.
             • Check for the presence of additional  contaminants, not just one.
             • Report accurate results and not misidentify an instrumental response, which could
              lead to a false positive result.
             • Focus on harmful contaminants including radionuclides, biotoxins, pathogens, and
              high concentrations of industrial chemicals.
             • Consider background concentrations of a contaminant in a specific location when
              analyzing the data from wastewater samples.
    4-2
    Wastewater Response Protocol Toolbox
    

    -------
    The networks of laboratories analyze clinical
    and environmental samples for chemical,
    biological, and radiological analytes associated
    with terrorist as well as natural events.
    
    It is likely that most emergency wastewater
    samples will be sent for analysis on the basis
    of a probable contamination threat. Samples
                         laboratory support for 'credible' incidents, and
                         specialty laboratories likely would be called
                         into service for 'confirmed' incidents.
    
                         Figure 4-1 and the narrative below summarize
                         the typical laboratory infrastructure, as
                         it currently exists, for the analysis of
                         environmental samples.
                        Chemical Analysis
                                       Biological Analysis
         Radiochemical
             Labs
     Environmental
    Chemistry Labs
     Environmental
    Microbiology Labs
                          Chemical
                          Weapons
                          Biotoxins
      Figure 4-1. Types of Laboratories for Analysis of Environmental Samples.
    sent to a laboratory as a result of a probable
    contamination threat should be treated as if
    they contain a potentially harmful  substance.
    However, the site characterization  process,
    along with the threat evaluation process,
    should result in most highly hazardous
    samples being screened before they reach the
    laboratory. Some organizations have an "All
    Hazards Receipt Facility" (AHRF) which is
    activated to screen unknown samples before
    those  samples are sent to a laboratory. From
    a safety standpoint, it is important  for a
    laboratory to realize that it will not be expected
    to determine every potential contaminant. For
    instance, utility laboratories typically may
    expect to receive samples from 'possible'
    incidents. The utility labs may need additional
                         2.1 Environmental Chemistry Labs
    
                         This group includes many EPA, state, utility,
                         and commercial water analysis labs. Most
                         environmental chemistry labs are set up to
                         perform analysis of wastewater samples for
                         compliance with the  Clean Water Act and/or
                         the Resource Conservation and Recovery Act,
                         as well as some state and local regulations.
                         Because these laboratories are typically
                         certified to utilize regulatory compliance
                         methods, unless the lab tests for a particular
                         analyte on a routine basis, they may not
                         necessarily be able to utilize a method for a
                         specific contaminant without advance notice.
    
    
    
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    There are also a number of research
    laboratories within the government and
    academic sectors that may be available on a
    limited basis. These labs may be equipped with
    advanced instrumentation and highly trained
    analysts who can implement exploratory
    techniques.
    
    2.2 Radiochemistry Labs
    
    If a radioactive contaminant is suspected,
    analysis should be performed by a laboratory
    specifically equipped to handle such material
    and analyze for a range of radionuclides.
    EPA, Department of Energy (DOE), states,
    and some commercial firms have labs
    specifically dedicated to the analysis of
    radioactive material. Information concerning
    EPA's radiological emergency response and
    laboratory services is available at http://
    www.epa.gov/radiation/emergency-response-
    overview.html. Another source of support
    is the Federal Radiological Monitoring and
    Assessment Center (FRMAC) operated by the
    Department of Energy:
     http: //www. nv. doe. gov/national security/
    homelandsecurity/frmac/.
    
    2.3 Biotoxin Labs
    
    Currently, few laboratories are set up
    specifically for the analysis of biotoxins. There
    are a number of laboratories in government
    and academia that perform biotoxin analysis,
    usually for matrices other than wastewater
    (e.g., seafood and agricultural products). It is
    possible that some biotoxin analyses could
    be performed in qualified environmental
    chemistry labs using techniques such as gas
    chromatography-mass spectrometry (GC/
    MS), high performance liquid chromatography
    (HPLC), immunoassay, and possibly liquid
    chromatography-mass spectrometry (LC/
    MS). However, this capability is not currently
    widespread.
    2.4 Chemical Warfare Labs
    
    Chemical Weapons are those weapons that the
    Chemical Weapons Convention (CWC) has
    placed on a list known as Schedule 1. These
    are toxic chemicals with few or no legitimate
    uses other than for military purposes. There are
    only a handful of laboratories in the U.S. that
    are qualified and permitted to perform analysis
    for Schedule 1 chemical weapons material.
    Among other qualifications, these labs possess
    appropriate analytical instrumentation, are
    supplied with analytical standards of Schedule
    1 chemical weapons material, and have
    implemented necessary  safety measures. Some
    of these labs can only be accessed via certain
    federal agencies such as the FBI and include
    the U.S. Army Edgewood Laboratory and the
    Lawrence Livermore National Laboratories.
    EPA is developing capability and capacity to
    analyze environmental samples potentially
    contaminated with chemical warfare agents
    and degradents at seven fixed laboratories and
    two mobile laboratories.
    
    2.5 Microbiological Laboratories
    
    The analysis of waterborne pathogens will
    likely be performed by an environmental
    microbiology lab. Environmental microbiology
    laboratories (including those of EPA, state
    environmental agencies, utilities, and the
    commercial sector) routinely analyze water
    samples for indicators of fecal contamination
    (e.g., fecal coliform bacteria, total coliform
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    bacteria, and E. coif). An analytical limitation
    is that specific culture analyses for waterborne
    pathogens such as Salmonella spp. and
    Shigella spp. are not routinely performed in
    most environmental microbiology laboratories.
    In the event that a contamination threat or
    event involves select agents such as Bacillus
    anthracis, Brucella spp., Yersiniapestis,
    Francisella tularensis, and C.  botulinum
    toxins, among others, samples would probably
    be transported by federal authorities to a lab
    within the Centers for Disease Control and
    Prevention Laboratory Response Network.
    
    As discussed later in this module, the presence
    of microbiological pathogens in wastewater
    typically does not constitute the same health
    risk as when these pathogens are found in
    drinking water. Therefore, there may not be the
    same need to  analyze potentially contaminated
    wastewaters for harmful microbes as there is
    for chemical contaminants.
    3 Health and Safety
    
    It is important to realize that details important
    for laboratory safety are integrated into
    the Threat Evaluation (Module 2) and Site
    Characterization (Module 3) processes even
    though they occur outside of the laboratory
    setting. The threat evaluation and site
    characterization processes help to define
    the hazard conditions at the site of sample
    collection, identify who should collect the
    samples and determine which laboratories
    should analyze them.
    
    The following are some important
    considerations for the safety of personnel who
    will be processing laboratory samples that
    may contain unknown, possibly dangerous
    substances.
    
    Currently, laboratories should have a plan
    in place to ensure worker safety. Some
    laboratories may wish to treat certain
    emergency wastewater samples as hazardous
    material, whether they be chemical, biological,
    or radiochemical in nature. They may also
    decide to develop a specific health and safety
    plan (HASP) to address this potential risk,
    although there is currently no requirement to
    do so in most cases.
    
    Laboratory personnel involved in the handling
    and analysis of wastewater samples should
    have appropriate current safety training
    that will allow them to adhere to applicable
    regulations. Laboratories may wish to explore
    some of the measures contained in regulations
    for the handling of hazardous materials, such
    as OSHA 1910.120 (http://www.osha.gov/
    pi s/oshaweb/owadi sp. show_document?p_
    table=standards&p_id=9707).
    
    Additionally, there is health and safety
    suggestions contained in various government
    publications including Biosafety in
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    Figure 4-2. Lab Personnel Using a Protective
    Lab Hood.
    Microbiological and Biomedical Laboratories,
    5th Edition. National Center for Infectious
    Diseases, Centers for Disease Control and
    Prevention, Office of Health and Safety, 2009.
    http://www.cdc.gov/biosafety/publications/
    bmblS.
    
    Analysis of potentially hazardous samples
    during an emergency situation may require
    additional personal protective equipment (PPE)
    above that normally used in the laboratory.
    These PPE requirements should be determined
    during the creation of the site-specific HASP.
    These may include, among others, the use of
    butyl gloves and full face shields especially
    during pouring and splitting of non-volatile
    samples.
    
    Appropriate hoods (Figure 4-2) and other
    physical control measures should always be
    utilized when handling samples containing
    potentially hazardous unknown contaminants.
    The laboratory should also be outfitted with
    safety equipment such as eyewashes, safety
    showers, spill  containment devices, and
    first aid kits. The laboratory should be fully
    informed about the sample collection and site
    investigation procedures, including any field
    safety screening and rapid field testing results.
    However, to reduce risks associated with
    potential, undetected hazards, laboratories may
    wish to screen the sample for various hazards
    upon receipt at the laboratory, regardless of the
    reported field safety screening results.
    The water solubility of potential contaminants
    sometimes contributes to their safe handling.
    Steps should be taken to avoid volatilizing or
    aerosolizing wastewater samples, which would
    then increase the inhalation risk. Accordingly,
    separatory funnel liquid-liquid extractions,
    which may release aerosols when vented, are
    not recommended unless laboratories utilize
    appropriate hoods or other precautions.
    
    Dilution of a hazardous wastewater sample
    with laboratory-grade water helps reduce risks
    associated with handling of the sample and its
    analysis for chemical contaminants. Dilution,
    however, may  interfere with the ability to
    detect and quantify contaminants.  If dilution
    is desired, 'log dilutions' may be utilized. For
    instance, a 1/1000 dilution may be analyzed
    first, followed  by a 1/100 dilution  if nothing
    is detected in the highest dilution.  These  can
    be followed by a 1/10 dilution, and finally the
    undiluted sample.
                                                            Like dilution, reducing the volumes of sample
                                                            handled may help minimize exposure for both
                                                            chemical and biological contaminants. Certain
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    analytical techniques involve using smaller
    sample volumes. For example, micro-liquid
    extraction utilizes only about 40 ml compared
    with large volume extractions which utilize
    1L or more. Selecting analytical approaches
    requiring smaller volumes of sample may
    help to limit risk to lab personnel dealing with
    suspect samples.
    Approaches to limiting the potential exposure
    to unknown pathogens prior to chemical
    analysis may be to irradiate (UV or gamma), or
    pasteurize, the samples. Currently there is no
    general consensus on proper use of irradiation
    to reduce risk associated with sample handling
    and analysis while maintaining the integrity
    of the sample and analysis. Therefore, these
    techniques for reducing pathogen exposure are
    not validated methods and are experimental
    at best. However, they could be utilized by
    the laboratory, on portions of the sample, as
    an exploratory technique. It should be noted
    that UV sterilization or heat  sterilization may
    also alter the identity or quantity of some
    chemicals.
    4 Analytical Approach for
      Unidentified  Contaminants in
      Wastewater
    
    In the case of a complete unknown, the
    problem of identifying and quantifying a
    specific contaminant presents a significant
    challenge. The difficulty arises from the large
    number of potential contaminants of concern,
    and the impracticality of screening for all of
    them. To address this issue, EPA recommends
    using an analytical  approach for unknowns that
    is based on contaminant classes derived from
    a prioritization of chemicals and pathogens of
    concern if present in a wastewater system.
    
    The recommended  analytical approach
    for unknown contaminants in wastewater
    presented in this module is comprehensive
    for selected priority contaminants and
    provides coverage for hundreds of additional
    contaminants. The following assumptions and
    principles were used in the development of this
    approach:
    
      • Selection of target analytes was based
        on an assessment of contaminants likely
        to pose a threat to public health, public
        safety, utility employee health and safety,
        property, utility operations/infrastructure,
        and the environment.
    
      • Existing laboratory infrastructure and
        analytical methods were utilized.
    
      • Analytical procedures are tiered, with a
        progression from field safety screening
        and rapid field testing, through laboratory
        screening, to confirmatory analysis.
    
      • Samples that cannot receive confirmatory
        analysis in the lab performing the
        initial testing are subsequently referred
        to laboratories that can perform a
        confirmatory analysis.
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       • The entire approach relies on the
        systematic elimination of potential
        contaminants, both to ensure the safety
        of sampling and laboratory personnel and
        to aid in identification of the unknown
        contaminant.
    
    It is also important to realize that identification
    of unknown contaminants in wastewater
    samples is not an exact science. This is
    especially true given the difficult analytical
    matrix presented by  wastewater. There is no
    guarantee that any combination of technology
    will always yield successful identification of
    unknown contaminants.
    
    It should be emphasized that Module 4 is
    not intended to represent a prescriptive how-
    to laboratory manual. Rather, this model
    screening procedure is intended to be a
    recommended planning tool for laboratories to
    formulate a Laboratory Guide specific to their
    own needs and capabilities. The Laboratory
    Guide for the lab dealing with emergency
    samples is similar to the Emergency Response
    Plan prepared by the utility in that both can be
    based extensively on information presented
    in the EPA Wastewater Response Protocol
    Toolbox, but both should still be customized to
    local needs and resources.
    Also, the Water Laboratory Alliance -
    Response Plan (WLA-RP) provides a
    structure to coordinate laboratory capability
    and capacity to prevent duplication of effort,
    maximize efficiencies and effectiveness,
    improve communication, and increase
    analytical support. Laboratories are encouraged
    to increase awareness of the WLA-RP through
    notification and discussion with the state
    drinking water programs and emergency
    management agencies.
    
    Additionally, EPA has recently published
    additional guidance on sample collection
    entitled Sampling Guidance for Unknown
    Contaminants in Drinking Water (EPA 817-
    R-08-003, November 2008) (see www.
    epa.gov/watersecurity; search under Water
    Laboratory Alliance). The guidance integrates
    recommendations for pathogen, toxin,
    chemical, and radiochemical sample collection,
    preservation, and transport procedures to
    support multiple analytical approaches for
    the detection and identification of potential
    contaminants in drinking water.
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    5 Basic Screening for Organic
      and Inorganic Chemicals Using
      Standard Methods
    
    The recommended chemical screen integrates
    a number of analytical techniques to cover
    abroad range of chemical classes. These
    techniques include not only wet chemistry and
    instrumental analysis, with which laboratories
    are typically familiar, but also hand-held
    equipment and commercially available test
    kits, such as those based on immunoassays.
    
    The overall screening approach for unknown
    chemicals is broken into two parts, the
    basic screen (Section 5) and the expanded
    screen (Section 6). The basic screen utilizes
    established (standardized) analytical methods
    for the  analysis of contaminants in wastewater.
    The WLA-RP also has a section on Basic
    Field/Safety Screening to assist laboratories
    in procedures for dealing with unidentified
    contaminants. Typically, these methods are
    produced as a standard by a recognized method
    development organization and contain steps
    to defensibly confirm the presence and/or
    quantity of specific contaminants. Table 4-1
    lists several sources of standard methods.
    
    Standardized methods may be selected from
    an appropriate method database, such as
    the Water Contaminant Information Tool
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    i
      Table 4-1: Sources of Standardized Methods
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                        Name
                 Water Contaminant
                 Information Tool
                 (worn
                  EPA SW-846 methods
                  40 CFR Parts 136 and
                  141
       National
       Environmental
       Method Index
       (NEMI)
                                 Description
                           Contains methods compiled
                           from a number of sources.
                           May be consulted first.
                           Compendium of analytical
                           and sampling methods that
                           have been evaluated and
                           approved for use in
                           complying with RCRA
                           regulations.
                           Promulgated list of
                           defensible methods widely
                           accepted in the analytical
                           community for water and
                           wastewater.
    On-line database containing
    chemical, microbiological,
    biological, toxicity, and
    physical methods for
    comparison.
                              Publisher
                            US EPA Office
                            of Water
                            US EPA Office
                            of Solid Waste
                            US EPA Office
                            of Resource
                            Conservation
                            and Recovery
                            and US EPA
                            Office of Water
                                                              US Geological
                                                              Survey and
                                                              US EPA
          How to obtain
    http //www.epa.gov/wcit
    http://www.epa.gov/
    epaoswer/hazwaste/test/
    main.htm
    http://ecfr.gpoaccess.gov
    www nemi.gov
    (WCIT) (http://www.epa.gov/wcit/). The
    National Environmental Methods - Index
    (NEMI) contains methods compiled from
    many sources. These methods are reviewed
    and selected by the National Methods and
    Data Comparability Board (http://acwi.gov/
    methods/). Some of these methods are EPA
    wastewater methods, some are EPA SW-846
    methods (Test Methods for Evaluating Solid
    Waste, Physical/Chemical Methods), and
    others were developed by USGS or DOE for
    their environmental monitoring programs.
    
    Also, EPA's National Homeland Security
    Research Center's Standardized Analytical
    Methods for Environmental Restoration
    Following Homeland Security Events (SAM)
    (EPA600-R-10-122, October 2010) (www.epa.
                          gov/sam/) identifies analytical methods to be
                          used by laboratories tasked with performing
                          analyses of environmental samples following a
                          homeland security event.
    
                          The basic screen is designed to capture many
                          of the chemical contaminants of concern
                          using a relatively small number of well-
                          defined, standardized analytical techniques
                          (Figure 4-3). The techniques chosen for basic
                          screening analysis are summarized in Table
                          4-2.
    
                          If the methods in this table are performed, then
                          the basic screen may cover a large percentage
                          of the priority chemical contaminants.
                          Furthermore, many other contaminants of
                          concern, but of lower priority, may be screened
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      Table 4-2: Suggested Analytical Techniques for Performing the Basic Screen, Arranged by
      Chemical Class
    Chemical . T EPA Method ^lef" ^ te* Analyte
    (general class) Analytical Technique (SW846) Act Method Ust
    4U wrK ran 1 Jb
    Volatiles (organic)
    Semivolatiles (organic,
    includes many
    pesticides)
    Trace metals (inorganic)
    Total mercury
    (inorganic, includes
    organomercury
    compounds)
    Cyanides
    Radionuclides
    
    Purge-and-trap PID/ELCD
    Purge-and-trap GC/MS
    Solid-phase extraction GC/
    MS
    ICP-AES, ICP-MS,
    graphite furnace AA
    Cold vapor AA
    
    Wet chemistry
    Gross alpha, gross beta,
    gross gamma
    802 1B
    8260B
    8270D
    3535A
    6010
    6020A
    7010
    747 1B
    
    901 2 A
    7110B
    
    601
    602
    624
    625
    200.7
    200.8
    200.9
    245.1
    245.2
    
    335.4
    900.0
    
    A
    B
    C
    D
    
    E
    F
    
    for as well. To increase confidence
    in the results, only validated
    methods should be used for the
    basic screen (e.g., SW-846 or
    comparable methods). Table 4-3
    below lists contaminants that may
    be detected by the basic screen
    standardized methods listed in
    Table 4-2.
    
                                     Figure 4-3. Lab Personnel Using an Analytical Approach
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                Table 4-3: Analyte Lists Corresponding to Table 4-2
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    1 1,1,2-TetrachlorQethane
    1.1.1-Tnchloroethane
    1 . 1 .2,2-Tetrachloroethane
    1,1 ,2-Trichloroethane
    1,1-Dichloroethane
    1,1-Oichloroethene
    1 ,1-Dichloropropene
    1 ,2,3-Trichlorobenzene
    1,2,3-Trichloropropane
    1 ,2,4-TrichIorobenzene
    1,2,4-Trimethylben2ene
    1 ,2-Dibrorno-3-chtoropropane
    1 ,2"Dibromoeth3ne
    1 ,2-Dichlorobenzene
    1 ,2-Dichloroethane
    1 ,2-Dichloropfopane
    1 ,3,5-Trimethylbenzene
    1.3-Oichlorobenzene
    1,3-Dichloropropane
    1 ,4-Oichlorobenzene
    2.2-Dichloro propane
    2-Chlorotoluene
    2- Nitro propane
    4-CWorotoluene
    Acrylonilrile
    Ally I chloride
    Benzene
    Bromo benzene
    Bromochlorome thane
    2.2'.3,3',4,4',6-Heptachlorob!phenyl
    2,2',3,3'14,5l,616'-OctachlorobJphenyl
    2,2' 3'.4,6-Pentachlorobiphenyl
    2,2'.4,4',5,6!-Hexachlorobiphenyl
    2,2',4,4'-Tetrachloroblphenyl
    2,3-Dichlorobiphenyl
    2,4,5-Trichlorobiphenyl
    2,4-Dirritfotoluene
    2,6-Dinitrotoluene
    2-Chlorobiphenyl
    a-8HC
    Acenaphthylene
    a-Chlordane
    Alachlor
    Aldrin
    Anthracene
    Atrazine
    Azinphos methyl
    b-BHC
    Benz(a ) a nth ra cene
    Benzo(a)pyfene
    Benzo(b)fluoranthene
    Benzo(g,h,i)perylene
    Benzo(k)fluofanthene
    bis(2-Ethylhexyl)adipate
    bis(2-Ethylhexyl)phthalate
    Bolster
    
    
    Arsenic
    Cadmium
    Chromium
    Cobalt
    Copper
    Lead
    Mercury
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Mercury
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Free
    cyanide
    (see
    method)
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Cesium-
    137
    Indium-
    192
    Cobalt-60
    Strontium-
    90
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
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    Table 4-3 (cont.): Analyte Lists Corresponding to Table 4-2
    Bromodichtaromethane
    Bromoform
    Bromomethane
    Butyl chloride
    Carbon disulfide
    Carbon tetrachloride
    Chloroacetonitrile
    Chlorobenzene
    Chloroethane
    Chloroform
    Chloromethane
    Cis- 1 ,2-Dichtoroethene
    Cis-1,3-Dichloropropene
    Dibrornochtoromethane
    Dibromomethane
    Dichlorodifluoromethane
    Di ethyl elder
    Ethyl methaerylate
    Ethy tbenzene
    Hexachlorobutadiene
    Hexachloroelhane
    Isopropylbenzene
    Methacrylonitrile
    Melhanol (solvent)
    Methyt acryiate
    Methyl methacrylate
    Methyl tert-butyl ether
    Methylene chloride
    m-Xylene
    Naphthalene
    n-Butylbenzene
    Nitrobenzene
    n-Propylbenzerie
    Butachlor
    Butylbenzylphthalate
    Chlorobenzilate
    Chloroneb
    Ctilorothalonil
    Chlorpyrifos
    Chrysene
    cis-Permethrin
    Coumaphos
    Cyanazine
    Dacthal
    d-8HC
    Demeton (mixed isomers)
    Diazinon
    Dibenz(a , h)anthracene
    Dtchtorvos
    Dieldrin
    Diethyl phthalate
    Dimethyl phthalate
    Di-n-butyl phthalate
    Disulfoton
    Endosulfan I
    Endosulfao II
    Endosulfan sulfate
    Endrin
    Endrin aldehyde
    Elhoprop
    Etridiazole
    Fensulfothion
    Perth ion
    Fluorene
    g-BHC
    g-Chlordane
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              Table 4-3 (cont.): Analyte Lists Corresponding to Table 4-2
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    o-Xylene
    Pentachloroethane
    p-lsopropy (toluene
    Propionitrile
    p-Xylene
    sec-Butylbenzene
    Styrene
    tert-Butylbenzene
    Tetrachloroethene
    Tetrahydrofuran
    Toluene
    trans-1 ,2-Dichloroethene
    trans-1 ,3-Dichloropropene
    trans-1 ,4-Dichloro-2-butene
    Trichloroethene
    Trichlorofluoromethane
    Vinyl chloride
    
    
    
    
    
    
    
    
    
    
    Heptachlor
    Heptachlor epoxide
    (Isomer B)
    Hexachlorobenzene
    Hexachlorocycbpentadiene
    lndeno{1 ,2,3-cd)pyrene
    Lindane
    Merphos
    Methoxychlor
    Methyl parathion
    Metolachlor
    Metribuzin
    Mevinphos
    Mated
    p,p'-DDD
    p,p'-DDE
    p,p'-DDT
    Pentachlorophenol
    Phenanthrene
    Phorate
    Propachlor
    Pyrene
    Ronnel
    Simazine
    Stirophos
    Tokuthion
    trans-Nonachlor
    Trichloronate
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    6 Expanded Screening for
      Chemicals
    
    The purpose of the expanded screen is to
    capture chemical contaminants not picked
    up by the basic screen. The expanded screen
    may also more rapidly detect some analytes
    covered by the basic screen. The expanded
    screen should be sufficiently broad to permit
    the analyst to screen for many possible
    contaminants.
    
    In practice, the expanded screen can be used in
    addition to the basic screen, because the results
    of the basic screen may provide a springboard
    to guide the selection of techniques for the
    expanded screen. For example, many of
    the techniques in the basic screen rely on
    chromatography and/or mass spectrometry, so
    the data should be capable of being evaluated
    for the presence of not only target analytes,
    but also other compounds. Combining
    observations from multiple basic screening
    techniques may also be helpful.
    
    Alternatively, some laboratories may choose
    to utilize only the expanded screen, comprised
    of potentially sensitive techniques, including
    those summarized in Table 4-4. In the latter
    case, preliminary results can be cautiously
    used to make response decisions, but should
    be followed up with confirmatory analysis
    because screening techniques, including
    some listed in Table 4-4, are not necessarily
    definitive. Some details regarding utilization
    of the expanded screening techniques are
    included below to help guide the reader in the
    selection of appropriate techniques relative to
    wastewater analysis.
    Table 4-4: Expanded Screening for Contaminants (Arranged by Class of Contaminant)
    Contaminant Type Expanded Screening Technique
    Organic
    Inorganic
    Cyanides
    Biotoxin
    Radiological
    Chemical Warfare Agents
    GC, GC/MS, HPLC, LC/MS, Immunoassay test kits
    1C, AA, ICP, ICP-MS
    Wet chemistry
    Immunoassay test kits, GC/MS, HPLC, and LC/MS
    Handheld equipment
    GC/MS with direct injection, purge & trap, and SPE/SPME,
    test kits, handheld equipment
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    6.1 Expanded Screening for Organic
       Compounds - Sample Preparation
       Techniques
    
    Organic analyses utilized in this approach
    are comprised of some combination of the
    following three steps: 1) extraction or recovery
    of the contaminant from the wastewater
    matrix; 2) separation of the compounds
    through gas chromatography or liquid
    chromatography; and/or 3) detection and
    identification of the analyte. Preparatory and
    extraction techniques for organic constituents
    should be broad enough to recover a variety of
    compound classes (e.g., a range of hydrophilic
    properties and molecular weights). A variety
    of techniques are used for detection of organic
    constituents.
    
    Regardless of the detector system employed,
    there are a number of widely used sample
    preparation techniques. These include the
    following:
    
    Large Volume Liquid/Liquid Extraction
    (LLE)
    
    This technique (SW846-Method 35IOC) is not
    advisable for aerosolizable samples because it
    requires the use of separately funnels that may
    release aerosols when vented. The generation
    of these aerosols may represent a larger health
    hazard than other techniques, unless labs take
    precautions such as appropriate hoods.
    
    Direct Aqueous Injection
    
    Although a powerful analytical technique, the
    use of direct aqueous injection of wastewater
    samples into a GC may present technical
    difficulties in chromatographic separation and
    could reduce the lifetime of the GC column
    and the detector (Figure 4-4). While the high
    concentrations of contaminants that might be
    present during an emergency incident may
                                                          cause the use of direct injection of wastewater
                                                          samples to prove valuable, particularly
                                                          for initial and rapid screening of analytes,
                                                          the analytical system should be carefully
                                                          monitored for loss of performance. For all but
                                                          a few analytes, confirmatory analyses may be
                                                          required.
    Figure 4-4. Lab Personnel Using Syringe to
    Inject GC.
    
    Micro Liquid-Liquid Extraction
    (micro-LLE)
    
    Liquid micro extraction involves the use
    of small volumes of solvent (e.g., 2 ml) to
    extract analytes from  a small volume (e.g., 40
    ml) of water. For the high concentrations of
    contaminants that may be present during an
    emergency incident, the use of micro-LLE of
    aqueous samples with a suitable solvent, such
    as methylene chloride, could prove particularly
    valuable for initial and rapid screening of
    analytes. The extraction could be immediately
    followed by GC/MS analysis which can
    provide qualitative identification. However,
    micro-LLE may not provide adequate detection
    limits for lower concentrations which may
    occur at the tailing edge of a contaminant slug.
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    Continuous Liquid-Liquid Extraction
    (Cont LLE)
    
    This technique, as described in SW846-
    Method 3520C, may be used for the isolation
    and concentration of water insoluble and
    slightly soluble organics. Its use can result in
    excellent detection limits, although analysis
    times can be long.
    
    Solid-Phase Extraction (SPE)
    
    Solid-phase extraction, sometimes referred
    to as liquid-solid extraction (SW846-Method
    3 53 5 A), is one of the techniques for basic
    screening analysis. Like micro-LLE, SPE
    extracts many contaminants, but can achieve
    larger concentration factors compared with
    the former technique. CIS adsorbents are
    commonly used. Many other adsorbents can
    also be employed to extract contaminants not
    amenable to CIS adsorbents. Different elution
    solvents can be used. A safety advantage
    associated with SPE is that it produces few
    aerosols.
    
    Solid-Phase Microextraction (SPME)
    
    SPME involves the use of a fiber coated with
    sorbent material. The sorbent coated fiber is
    exposed to either the aqueous sample or the
    headspace from the sample, and the analytes
    then adsorb to the coating on the fiber. After
    exposure to the sample, the fiber is introduced
    into the detection system (i.e., GC or HPLC).
    For example, after exposure  to the sample,
    the SPME fiber is inserted into the injector of
    a GC, and contaminants are released to the
    column by thermal desorption. As with micro-
    LLE, another quick screen, the detection limits
    achievable via the use of SPME may only be
    useful in the case of elevated contaminant
    concentrations. Like SPE, SPME should
    produce few aerosols.
    Headspace Collection
    
    The headspace above an aqueous sample may
    be injected into a GC (SW846-Method 3810).
    Commercially available equipment, interfaced
    with the GC, is designed to facilitate this
    analysis.
    
    Flow Injection
    
    In flow injection, an aqueous sample or sample
    extract is injected directly into an LC/MS in
    such a manner that it bypasses the LC column.
    Thus the analytes are not chromatographically
    separated, but the technique can prove useful
    if high concentrations of a single analyte are
    present, or if sample preparation is employed
    that is selective for particular analytes.
    
    6.2 Expanded Screening for Organic
       Compounds -  Detection Methods
    
    In addition to the sample preparation
    techniques described above, there  are a number
    of detection methods available for organic
    chemical contaminants:
    
    Gas Chromatography with Electron Impact
    lonization Mass Spectrometry
    
    The subsequent analysis of contaminants
    extracted from wastewater may be conducted
    by the use of GC/MS. When the mass
    spectrometry  is performed using electron
    impact ionization, eluting peaks show
    distinctive fragmentation patterns, which may
    be used in identification, particularly through
    the use of a variety of computerized tools
    for library matching to ionization patterns
    of known compounds. Usually, the program
    performs a spectral search using a user-defined
    library (such as National Institute of Standards
    and Technology - NIST, EPA, Wiley, etc.) and
    will report the compound with the best spectral
    match as the tentatively identified  compound
    with an estimated concentration.
    
    
    
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    It is desirable to examine the peaks for more
    than just the analytes for which the instrument
    is calibrated. The analyst may utilize a
    threshold for examining unidentified peaks that
    exceed 10% (height threshold) of the internal
    standard.
    
    Multidetector GC in Screening Mode
    
    A multidetector GC is utilized for specific
    analytes as an alternative, and sometimes
    complement, to a mass spectrometer. The
    intent of using multidetector GC in the analysis
    of unknowns is primarily as a screening
    tool. There are more than a dozen detectors
    available including electron capture, infrared,
    flame ionization, nitrogen-phosphorous
    specific, thermal conductivity, etc. Various GC
    detectors respond to contaminants in different
    ways, and the evaluation of all the data from
    the various detectors increases the selectivity,
    and sometimes the  sensitivity, of the analysis.
    For example, flame ionization detectors
    respond to a wide variety of contaminants,
    but typically with low sensitivity. On the
    other hand, electron capture detectors are
    more sensitive and  react more specifically to
    halogenated compounds. The detectors may
    be used in series with one GC, or in parallel
    through the use of multiple GCs.
    High Performance Liquid Chromatography-
    Ultraviolet (UV) Detector
    
    Analogous to multidetector GC, HPLC with
    UV detection can be used to determine if
    organic compounds not amenable to GC
    procedures (e.g., non-volatiles or thermally
    unstable compounds) are present in amounts
    greater than background. Calibration and
    quality control samples should be included
    to provide accurate analysis. Analytical
    confirmation may be necessary using
    established techniques such as GC/MS,
    although derivatization of the compounds may
    be necessary to make them amenable to GC/
    MS analysis.
    
    High Performance Liquid Chromatography-
    Mass Spectrometry (LC/MS)
    
    Many polar hydrophilic compounds cannot
    be easily extracted from an aqueous sample.
    Additionally, there are contaminants of large
    molecular weight (e.g., biotoxins) or thermally
    unstable compounds that are not amenable to
    GC analysis but can sometimes be analyzed
    by LC/MS. Direct aqueous injection HPLC
    allows analysis of a sample without extraction
    or concentration. SPME and SPE (and other
    extraction procedures) may be utilized for
    compounds that can be extracted. Identification
    of unknowns can be performed but there are no
    standardized mass spectral libraries, as in GC/
    MS. Analyst interpretation can help identify
    possible compound fragments and structure.
    
    More than a decade after its
    commercialization, LC/MS is not commonly
    used for water analysis, although it has proved
    extremely useful for analysis of target  analytes
    in other industries. Nonetheless, LC/MS can
    be an added tool in an expanded screen for
    unknown chemicals in specific cases, and may
    be useful for certain classes of pesticides, such
    as carbamates.
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    Tandem Mass Spectrometry (MS/MS)
    
    Both GC and HPLC may be used in
    conjunction with tandem mass spectrometry,
    also known as MS/MS. Different MS/MS
    instruments operate under different principles
    to achieve similar results, but essentially
    can be considered to be like two mass
    spectrometers connected by a collision cell.
    The first mass spectrometer separates ionized
    molecules, which are broken apart in the
    collision cell, and the resulting fragments are
    separated in the second mass spectrometer.
    This produces a great deal of information that
    can be used to identify the original molecules,
    but does not necessarily produce searchable
    libraries. MS/MS is not as widely available as
    MS and requires a high degree of skill.
    
    High Resolution Mass Spectrometry
    (HRMS)
    
    GC or HPLC, combined with a high resolution
    mass spectrometer, may provide exact mass
    data of an  eluting compound, allowing for
    calculation of elemental composition of
    both molecular and fragmentation ions. This
    information is useful in the identification of
    unknown organic compounds, especially when
    the result of mass spectral library research
    is not conclusive or when the standard of
    a tentatively identified  compound is not
    available.  Careful quality control procedures
    are required, and the technique is not always
    definitive, especially for unknown compounds,
    because many compounds produce fragments
    with the same exact masses.
    
    Immunoassays
    
    There are a number of immunoassay test
    kits available for organic chemicals, such as
    pesticides  and biotoxins. These may be useful
    for screening a sample for specific unknowns
    in the field or in the laboratory. These kits may
    be used for speed or if instrumental methods
    are not available in the lab. However, use of
    these kits requires that the goals of the analysis
    be planned because some kits are slower
    than the instruments, especially if analytical
    confirmation time is considered. Also,
    appropriate training is necessary in the use
    of these tests. Laboratories should be aware
    of the kits' reliability and levels of detection
    before using them. It is important to note that
    most of these test kits are not recognized by
    any standard setting organization. Not all of
    these products have been studied in detail
    as to their efficacy for wastewater, which
    may contain interfering and/or cross reacting
    substances. These problems can lead to false
    positive and false negative results. In general,
    a positive  or negative result from one of these
    test kits should be considered tentative and be
    confirmed through more  rigorous laboratory
    analysis.
    6.3 Expanded Screening for Inorganic
       Chemicals
    
    The inorganic analyses include several
    analytical techniques: classical wet chemistry;
    instrumental techniques such as inductively
    coupled plasma mass spectrometry (ICP-
    MS), inductively coupled plasma atomic
    emission spectrometry (ICP-AES), and atomic
    absorption (AA) spectrometry for trace metals;
    and ion chromatography for anionic and
    cationic contaminants.
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    Like the determination of organic chemicals,
    there are a number of preparation steps that
    are required for the analysis of inorganic
    chemicals. These vary with the methodology
    being employed.   To select a sample
    preparation approach, it may be useful to refer
    to relevant standardized methods. For instance,
    if the goal is to look for trace metals not listed
    in a particular method, it may be useful to refer
    to a method in which a wastewater sample
    of similar composition to the one in question
    is prepared for metal analysis. This is not an
    exact process, and some metals have certain
    characteristics that may cause them to not be
    amenable to a preparation technique applicable
    to another. For example, a digestion method
    for nickel may not be suitable for mercury
    analysis. Following preparation,  the samples
    can be analyzed by a number of techniques,
    described below:
    
    ICP-AES or ICP-MS in Semiquantitative
    Mode
    
    Analogous to multi-detector GC  and UPLC
    with UV detection, the ICP-AES and ICP-MS
    methods (CWA Methods 200.7 and 200.8) can
    also be expanded to provide a broad screening
    approach to identifying unknown trace metals.
    Under the semiquantitative mode, the ICP-MS
    instrument, operated in scanning mode, may be
    capable of providing semiquantitative results
    for more than 60 elements including major
    atomic cations, metals, semi-metals, rare earth
    elements and selected radionuclides (uranium
    and thorium). (Note: radioactive materials
    should be handled by a specialized laboratory).
    
    Ion Chromatography
    
    Ion chromatography forms the basis of several
    EPA methods to determine ions of regulatory
    interest (e.g., CWAMethod 300.1). By the
    correct choice of operating conditions and ion
    chromatography columns, determination of
                                                           many different types of ions have appeared in
                                                           the literature.
    Wet Chemistry
    
    Wet chemistry forms the basis of many types
    of chemical test kits. The chemistry and
    detectors for test kits approved for compliance
    monitoring are traceable to EPA methods.
    Wet chemistry techniques, through the use
    of autoanalyzers, form the basis of many
    types of chemical analysis for environmental
    and clinical applications. Manufacturers
    of these devices often provide full detailed
    methodology for defensible application of wet
    chemistry to a variety of analytes. Titrimetric
    methods are also available to analyze
    background water quality parameters such as
    alkalinity.
    
    Ion Selective Electrodes (ISE)
    
    Ion selective electrodes (ISE, also known
    as electrochemical probes)  can be utilized
    to analyze for some background wastewater
    quality parameters. A simple example of
    an ISE is the familiar pH probe for the
    hydrogen ion. Other ISEs are available for a
    variety of ions and may be  considered (e.g.,
    ammonia, calcium, chloride, fluoride, nitrate,
    potassium, silver, sodium, and sulfide). Some
    parameters that can be monitored by ISEs
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    may be useful in characterizing the extent of
    contamination or verifying the credibility of a
    contamination threat as part of the rapid field
    testing of wastewater procedure during site
    characterization.
    
    6.4 Expanded Screening for Cyanides
    
    Free cyanide concentration, measured without
    distillation, is useful in detecting acutely
    toxic cyanide. Therefore, distillation is not
    used in the rapid field tests for cyanide or for
    safety screening upon the receipt of samples
    in the laboratory. Distillation is required for
    determination of total cyanide concentration
    and is the most  conservative approach with
    respect to public health concerns.  Distillation
    may be applicable for expanded cyanide
    screening.
    6.5 Expanded Screening for Biotoxins
    
    Some biotoxins have been monitored routinely
    for quite a while, particularly in conjunction
    with naturally occurring outbreaks of biotoxins
    in marine environments. There are hundreds
    of biotoxins from dozens of different plant and
    animal species. Analysis of some biotoxins
    may be supported by the CDC Laboratory
    Response Network (LRN) laboratories. The
    LRN may utilize immunoassays for screening
    for botulinum toxin, ricin, and some other
    biotoxins.
    Immunoassay kits are commercially available
    for a number of biotoxins. It is important to
    note that most of these kits are not recognized
    by any standard setting organization, and
    potential interferences and/or cross reacting
    substances in wastewater are not well studied.
    Because these tests are susceptible to false
    positive and negative results, a positive or
    negative result should be considered tentative
    and should be confirmed through a more
    rigorous laboratory analysis. Confirmatory
    analyses usually involve GC/MS, LC, or LC/
    MS. Because biotoxins tend to be very water
    soluble, LC/MS may be particularly useful for
    biotoxin analysis, although specialized sample
    preparation techniques may be required. The
    skill of the analyst is critical for this technique
    to be used effectively.
    
    6.6 Expanded Screening for Chemical
        Weapons
    
    The term chemical weapons refers to the
    substances that appear on Schedule 1 of the
    Chemical Weapons Convention.  The Schedule
    1 agents are extremely hazardous to handle
    and most environmental  chemistry laboratories
    do not have the facilities or the procedures in
    place to handle these agents. In addition, most
    of the agents are not available commercially to
    prepare analytical standards for quantification.
    The chemical weapons agents will need
    to be analyzed by special laboratories for
    confirmatory analysis.
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    In the unlikely event that an environmental
    chemistry laboratory receives a sample
    containing a chemical weapon, screening
    techniques can be used to detect the presence
    of the agents in wastewater. In addition, the
    laboratory should notify appropriate ICS
    personnel. The best analytical approach may
    be to utilize the preparatory procedures for
    organic chemical analysis described above
    (direct injection, micro-LLE, SPE, SPME)
    followed by  GC/MS for identification. This
    approach may only be able to determine the
    presence, not concentration, of the agent
    because an analytical standard would not
    be available. The standard electron impact
    mass spectral libraries frequently contain
    mass spectra of these compounds and can be
    used for tentative identification. As an aid to
    increasing confidence in chemical warfare
    agents' GC/MS library matches, the NIST
    has developed the Automated Mass Spectral
    Deconvolution and Identification System
    (AMDIS) (http://chemdata.nist.gov/mass-spc/
    amdis/).
    In the unlikely event that chemical weapons
    agents are present, the expanded screen for
    organic chemicals is procedurally designed to
    reduce risk to personnel handling the sample,
    namely through reduction of aerosols. As
    with any organic chemical, an additional
    way to reduce risk would be through sample
    dilution. The laboratory may first start with
    the  most dilute sample (1/1,000) and if
    nothing is detected may proceed to analyze
    the  next dilution (1/100), followed by the 1/10
    dilution, and lastly the undiluted sample. If
    the laboratory proceeds through the undiluted
    sample and nothing is detected, it may be that
    the sample is a non-detect for the chemical
    weapon that would be captured by the screen.
    If chemical weapons agents are identified
    in the screen, proper notifications should
    be made to the Incident Commander or
    appropriate official within the ICS structure.
    Also notify law enforcement who may be able
    to gain access to laboratory resources that can
    confirm the presence of the chemical weapons
    agent. EPA is developing the capability and
    capacity at seven fixed laboratories and two
    mobile laboratories to analyze environmental
    samples potentially contaminated with
    chemical warfare agents and degradents. Other
    notifications may be required by applicable
    laws and regulations.
    
    6.7 Basic and Expanded Screening for
        Radionuclides
    
    Screening for radionuclides is somewhat
    different than screening for other chemical
    contaminants since radionuclides can be
    characterized by both the type of radiation they
    emit as well as their exact chemical identity.
    Accordingly, initial screening for radionuclides
    may involve measurement of gross
    radioactivity. However, any initial screening
    that indicates the presence of a radionuclide
    should be followed by analytical confirmation
    of the chemical identity. A schematic for
    radionuclide screening is shown in Figure 4-5.
    The results of field testing for radioactivity
    should be compared to background levels to
    determine whether the site may have been
    contaminated with radioactive material.
    
    The analysis for gross alpha and beta radiation
    may be conducted as a screening method for
    alpha and beta particle activities in wastewater
    and used to determine if specific radiological
    analyses are needed. Preliminary analysis can
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                          •THREAT;
                       Preform Field Testing
                        for Radioactivity
                      r             *»
                   <-'" Field test positive for~
                     *••.__ radioactivity? __,.*'
       Does lab policy **»v
     require screening for
    •-.^ radioactivity? ,-''
                       Preform laboratory
                      screening analysis for
                      alpha, beta and gamma
                           radiation
                        Screening results ''T
                           positive?  j.-''
                                                                      V
               Additional analysis for
                 radionuclides not
                    required
                      Preform analysis for
                     specific radionuclides
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                Figure 4-5: Protocol for Basic Radionuclide Screening
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    first be conducted in the field using appropriate
    field portable or hand-held devices, but may
    be verified in the laboratory. As part of their
    safety plan, laboratories may wish to screen
    samples upon arrival for gamma radiation
    using appropriate technologies such as hand
    held detectors.
    
    If the presence of radioactive material is
    indicated by the initial screening, specific
    radioisotopes may be determined by
    radiochemical specific procedures, using
    techniques with which radiation labs are
    already familiar. These procedures often
    involve separation of the radionuclide from
    the sample by precipitation techniques, and
    subsequent determination by a gas flow
    proportional counting system or scintillation
    detector system for alpha and beta emitters
    and an appropriate gamma detector for gamma
    emitters. For example, strontium-89 and
    strontium-90 can be precipitated as carbonates
    from the sample. Additional precipitation steps
    allow separation from other radionuclides and
    interferences.
    
    Due to the unique nature of radionuclide
    analysis, some laboratories have developed in-
    house procedures for radionuclide analysis that
    make use of their special skills and capabilities
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        to enhance the speed of analysis, especially
        since some standardized methods are not
        rapid methods. For example, one standardized
        method for radioactive strontium in water
        recommends a two-week in-growth period
        for obtaining the yttrium isotope from the
        purified strontium. Modification of the method
        produces much faster results. Reduction
        in analysis time could be accomplished by
        measuring the total amount of an element's
        radionuclide, not the isotopic distribution.
        Also, for some isotopes, faster results may be
        obtained by simply reducing the volume of
        water processed.
    
        It must be emphasized that radiochemical
        analysis should be performed only by licensed,
        specialty laboratories, and the need for such
        analysis should be indicated by the field
        screening equipment for alpha, beta, and
        gamma emitters, or other specifics of the
        incident, such as threats.
    
        As described above, the basic screen  is
        rather comprehensive because it requires
        identification of the  specific radionuclide if
        indicated by the screens for gross alpha, beta,
        and gamma radiation. Therefore, the expanded
        screen is designed to capture radionuclides that
        do not fall into the energy range of the gross
        radionuclide screen for gross alpha and beta.
        Fortunately, these radionuclides have specific
        standardized methods designed for their
        analysis, and radionuclide labs may also have
        additional reliable methods at their disposal for
        their analysis.
    
        Two other techniques that may be particularly
        useful for radionuclide analysis are gamma
        spectroscopy, which can directly identify the
        gamma emitting radionuclide, and inductively
        coupled plasma mass spectrometry (ICP-MS).
        Principal considerations in the use of both of
        these techniques include detection limits and
        availability of instrumentation.
                        7 Additional Recommendations
                           for Chemical Screening of
                           Wastewater Samples
    
                        Unlike drinking water analysis, wastewater
                        analysis is complicated by the high solids
                        content of samples. This is especially true for
                        raw sewage as well as primary effluent and
                        mixed liquor from the wastewater treatment
                        process. Solids residue is much less of a factor
                        in secondary or tertiary effluent from the
                        treatment chain.
    
                        The following practical observations and
                        suggestions may help to overcome the
                        analytical challenges posed by the difficult
                        wastewater matrix:
    
                           • The purge and trap extraction/
                            concentration method can be utilized
                            without modification to introduce volatile
                            organic compounds into a GC or GC/MS.
                            Because the sample itself does not come
                            into contact with the sensitive components
                            of the analytical system, there should be
                            no fouling potential for the GC or GC/MS
                            even when raw sewage, primary effluent,
                            or mixed liquor samples are  analyzed.
    
                           • Solid phase extraction can be used directly
                            on secondary or tertiary effluent samples.
                            The extract can then be analyzed by GC,
                            GC/MS, or other appropriate techniques.
    
                           • When screening raw sewage, mixed
                            liquor, and primary effluent samples, the
                            samples can be filtered through a 0.45um
                            membrane filter to remove residue. The
                            filtrate can then be extracted by solid
                            phase extraction and the extract analyzed
                            by HPLC, GC, GC/MS, or other methods.
    
                           • The filter retentate from the step above can
                            also be digested via Soxhlet  extraction
                            using SW-846 methods 3540C or 3541. If
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        necessary, the extract can subsequently be
        purified using a gel-permeation clean-up
        method such as SW-846 method 3640A.
        The product of this preparatory step can
        then be analyzed using GC, GC/MS, or
        other techniques.
    
    8 Screening for Microbiologicals
       Including Unknowns
    
    Wastewater typically contains large numbers of
    viruses, bacteria, and protozoans.  Additional
    microbes are seeded into wastewater during
    the secondary treatment process, and are
    encouraged to multiply to assist in the
    breakdown of organic matter and nutrients.
    Even finished effluent from wastewater
    treatment plants may contain significant
    numbers of microorganisms. The chlorination
    or UV light treatment that occurs at the
    end of the wastewater treatment process is
    intended to control  pathogens and reduce
    microbial numbers, but does not produce
    sterile water. Furthermore, the likely routes
    of exposure of utility workers or the general
    public to microbes that may have been added
    to wastewater accidentally or intentionally is
    through inhalation of aerosols and perhaps
    limited dermal contact, as opposed to
    ingestion. Consequently, there is much less
    emphasis placed on screening for microbial
    contaminants in wastewater during a suspected
    contamination event compared to a drinking
    water contamination incident.
    Possible exceptions may include microbes such
    as the anthrax bacterium, Bacillus anthracis,
    whose spores could pose an inhalation risk
    if they ended up in the wastewater system.
    Various parts of the wastewater collection and
    treatment systems generate aerosols that may
    potentially impact health via the inhalation
    route. Still another situation where the need
    may arise to analyze wastewater for the
    presence of microbial contaminants might be
    if the decision is made by officials to discharge
    to or bypass the wastewater treatment plant,
    following an intentional or unintentional
    biological contamination incident, allowing
    elevated numbers of potentially harmful
    microbial contaminants to enter natural
    waterways if such discharge or bypass is
    not otherwise prohibited by CWA Section
    301(f), 40 CFR 122.41(m), or another law or
    regulation.
    
    Analysis of wastewater for specific bacterial,
    viral, or protozoal contaminants is complicated
    by high
    background levels
    of microbes
    in wastewater.
    Additionally,
    efforts to
    concentrate
    wastewater
    samples for
    microbial analysis are complicated by the high
    solids content of wastewater.
    
    For all of these reasons, an extensive screening
    procedure is not recommended at this time
    for microbes in wastewater following a
    contamination threat or incident. Should the
    need for detailed microbial analysis arise, an
    attempt may be made to screen wastewater
    samples using molecular techniques (e.g.,
    Polmerase Chain Reaction - PCR) or
    traditional culture methods. In the event that
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    select biological agents (such as anthrax spores
    or the biotoxins ricin or botulinum toxin) are
    believed to be involved in a contamination
    incident, samples may be analyzed by the
    Centers for Disease Control and Prevention's
    laboratory since they are authorized to work
    with these microbes.
    
    9 Forensic Implications of Sample
      Collection and Analysis
    
    It is important to note that if a contamination
    event in wastewater is the result of an
    intentional or accidental release, there will
    likely be legal ramifications. Any  samples
    collected and analysis conducted during the
    incident response may ultimately be used for
    evidentiary purposes. Therefore, sampling
    and analytical procedures  should be accorded
    greater attention to detail.
    
    10  Data Analysis and Reporting
    
    The responsibility of the laboratory during an
    emergency does not end with sample analysis.
    At a minimum, the lab should report the
    results in a timely manner to the recipients
    designated by incident command. Additionally,
    the laboratory may be asked to assist in
    the analysis and interpretation of the data.
    The  Water Laboratory Alliance - Response
    Plan has suggestions for the maintenance
    and reporting of data. The following are
    some general guidelines for the analysis and
    reporting of results:
    
       • The laboratory and the client (e.g., the
        Utility Incident Commander or the overall
        Incident Commander) should agree on the
        format and content of the report before
        data are released by the lab. In general, the
        report should be thorough enough so that
        all information is available. However, if
        too much detailed information is reported,
        the laboratory may confuse the client.
    
       • During a suspected contamination
        incident, it is important that all
        relevant information be managed
        through incident command. Therefore,
        analytical results should be reported
        only to those individuals designated by
        incident command, and it will be their
        responsibility to subsequently inform
        other stakeholders.
        In a crisis situation, the laboratory may
        be asked to provide tentative results
        (sometimes called a rolling report) prior
        to complete data review and confirmation.
        In this case the lab  may need to provide
        appropriate caveats regarding the validity
        of the data at that stage of the analysis.
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       • The laboratory should remain available
        to assist in the analysis and interpretation
        of both preliminary and final results. The
        laboratory staff has a unique perspective
        regarding the reliability of the methods
        and interpretation of results.
    
    11 Summary
    
    The response to the threat of an intentional or
    accidental contamination event in wastewater
    often necessitates sample collection and
    analysis. The analytical response  will
    begin at a fairly basic level with rapid
    testing of wastewater in the field during the
    site characterization process. Should the
    contamination threat be deemed 'Credible',
    definitive analyses will need to be conducted
    in one or more laboratories. An important
    challenge to labs analyzing  such samples is the
    potential risk to personnel handling samples
    which may contain potentially hazardous
    substances. Another challenge is accurately
    detecting, identifying, and quantifying one or
    more contaminants from the array of thousands
    of chemical, microbes, and radionuclides that
    could accidentally or intentionally end up in  a
    wastewater collection or treatment system.
    Module 4 discusses safety procedures that
    should be employed to protect the analysts.
    It also recommends general approaches
    that could be used to begin the process of
    eliminating possible contaminants and target
    the agent that is actually present. In the case
    of many contaminants, a variety of both
    standardized and exploratory techniques may
    need to be utilized.
    
    The Module emphasizes the need for utility,
    government, and commercial laboratories to
    prepare their own Laboratory Guides, follow
    emergency procedures contained in the Water
    Laboratory Alliance -Response Plan, and
    prepare site-specific analytical approaches
    based on the recommendations provided in the
    Wastewater Response Protocol Toolbox.
    
    
    
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    &EPA
      United States
      Environmental Protection
      Agency
    Wastewater Response Protocol
    Toolbox:
    Planning For and Responding To
    Wastewater Contamination
    Threats and Incidents
    December 2011
    Module 5:
    Public Health and Environmental Impact
    Response Guide
    

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                             Table of Contents - Module 5
    
    1 Introduction	 5-1
    2 Plan the Public Health/Environmental Response (Pre-threat Phase)	5-1
    3 Determine the Public Health Consequences and Environmental Impacts Resulting
      from the Contamination Event (Post-threat Phase) 	5-3
    4 Implement Appropriate Operational Responses (Post-threat Phase)	5-4
    5 Implement the Public Notification Strategy (Post-threat Phase)	5-5
    6 Make Available Short Term Alternate Sanitary Services (Post-threat Phase)	5-6
    7 Summary	5-7
    8 Appendices	5-7
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                                        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
                                 
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    1 Introduction
    
    Module 5 provides guidance for the public
    health and environmental protection response
    to a wastewater contamination threat or
    incident. The response is one component of
    the overall threat management process which
    is described in Module 2, the Contamination
    Threat Management Guide. This response
    includes those actions taken by utilities, health
    entities, and regulatory agencies to decrease
    the public health  and safety consequences, as
    well as negative effects on the environment,
    which may result from a contamination threat
    or incident. Public health and environmental
    responders in this context include the utility,
    local and state health and environmental
    departments, the  EPA, and the Centers for
    Disease Control and Prevention because
    they may all  be involved in choosing and
    implementing the public health/environmental
    response actions  taken during a contamination
    incident.
    
    The public health and environmental
    protection response consists of the five
    actions listed below:
    Action taken before a threat occurs
      • Plan the public health and environmental
        response
    Actions taken after a threat occurs
      • Determine the public health and
        environmental consequences resulting
        from this particular wastewater
        contamination incident
      • Implement appropriate operational
        responses
      • Implement public notification
      • If necessary,  make available short term
        alternate sanitary services
    2 Plan the Public Health/
      Environmental  Response
      (Pre-threat Phase)
    
    The public health/environmental response
    should be planned and coordinated between
    utilities, public health agencies, and
    environmental regulatory agencies before a
    threat occurs. Utilities document their planning
    when preparing their Emergency Response
    Plan (ERP). State and local health agencies
    typically develop a Public Health Response
    Plan that covers responses to all types of public
    health emergencies (including but not limited
    to water emergencies). Regulatory agencies
    have developed extensive environmental
    protection plans to be used in response to a
    variety of contingencies. In their planning,
    utilities, health agencies, and regulatory
    agencies should address several issues as they
    relate to a response in the event of a threatened
    or actual contamination event in a wastewater
    system.
    
    First, during the planning phase, the roles
    and responsibilities of the agencies involved
    in public health and environmental impact
    response should be identified. At this point, the
    utility should define its intended role in future
    public health/environmental impact responses.
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              Secondly, an effort should be made to integrate
              public health and environmental protection
              agency planning into the utility's ERP. The
              utility should investigate how the public
              health response plans of local and State health
              departments, and the environmental protection
              plans of regulatory agencies, address
              wastewater contamination incidents. They
              should then integrate appropriate portions of
              these plans into the utility ERP.
              The utility should also develop a
              communications strategy. Rapid and reliable
              communications are crucial to ensuring a
              prompt and coordinated public health and
              environmental response. Plans  should be made,
              prior to an incident, that describe who should
              be notified, when and how they should be
              notified, and what types of information they
              should be given consistent with any applicable
              laws and regulations. A backup communication
              and notification system should be put into
              place in the event that phone networks are
              not functioning. Those notified may include
              emergency responders,  government and non-
              governmental agencies, critical customers
              such as hospitals, and the public. Especially
              important is two-way communication
              between wastewater utilities and public health
              agencies. The Incident Commander (who
              may or may not be from the utility) should
              report contamination threats to the public
              health agency so that physicians and hospitals
                                                           can be on alert to report potential signs and
                                                           symptoms to the health department. Similarly,
                                                           public health agencies should communicate
                                                           with wastewater utilities regarding unusual
                                                           symptoms being reported by the medical
                                                           community that may have a connection to
                                                           wastewater.
    
                                                           Finally, prior to a threat being received, the
                                                           involved organizations should develop plans
                                                           for operational and public health responses
                                                           to be taken during a threat or incident. The
                                                           operational steps should be designed to
                                                           minimize the impact of a contamination event
                                                           on public health  and the environment. The plan
                                                           should identify the agency or organization that
                                                           is responsible for carrying out the action(s), as
                                                           well as the circumstances under which certain
                                                           actions are to be taken. The organizations
                                                           should also assess the feasibility and potential
                                                           effectiveness of these operational steps. At the
                                                           same time these  agencies should determine the
                                                           potential impacts of specific  response actions
                                                           on the community.
                                                           It is during the planning phase that gaps in
                                                           operating procedures, technical capabilities,
                                                           and communications should be identified
                                                           and addressed. As with all response plans,
                                                           regularly exercising the public health/
                                                           environmental impact plan is critical to
                                                           effective implementation during an emergency.
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    Exercises should involve not only the utility
    but also health agencies, regulatory agencies,
    and public safety response agencies.
    
    The remaining four actions, described
    below, should be taken following the utility
    becoming aware of an accidental or intentional
    contamination threat. These actions may
    be taken individually, or in combination, at
    any point throughout the threat management
    process. However some actions may be
    required to be taken at specified times.
    3 Determine the Public
      Health Consequences and
      Environmental Impacts
      Resulting from the
      Contamination Event
      (Post-threat Phase)
    
    Once the possible identity of the contaminant
    (or contaminants) has been determined, the
    utility and other responders should obtain
    information on the properties and potential
    health and safety consequences of the
    contaminant, as well as possible impacts on
    the environment and wastewater operations.
    This information will help inform response
    decisions.  Some public health/public safety
    factors of concern include the acute and
    chronic health effects of human exposure to the
    contaminant, exposure routes of concern (e.g.,
    inhalation or dermal contact), contaminant
    concentrations that are toxic or infective, and
    the flammability of vapors. Environmental
    factors of concern include the stability of the
    contaminant in water and the potential impact
    of the contaminant on living organisms in the
    receiving waters as well as on downstream
    users of the receiving waters (e.g., drinking
    water utilities). Operational concerns include
    the ability of wastewater treatment processes to
    remove or inactivate the contaminant, as well
    as the contaminant's potential to damage the
    biological treatment process in  the wastewater
    plant.
    A good source for information on properties,
    health effects, and environmental impacts
    of a variety of chemical, biological, and
    radiological contaminants of concern for
    drinking water and wastewater is EPA's Water
    Contaminant Information Tool (WCIT).
    For these contaminants, WCIT provides
    information about relevant topics such as
    chemical or pathogen properties, medical
    aspects, toxicity, as well as decontamination
    methods for wastewater infrastructure and the
    effect of wastewater treatment processes on
    contamination concentrations. Access to this
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    secure, web-accessible database is available
    to water utilities, regulators, health agencies,
    and others free of charge. However, prior
    registration is required. Additional information
    on WCIT is available at http://www.epa.gov/
    wcit.
    
    Another factor relevant to determining the
    consequences of a contamination event
    is assessment of the actual spread of the
    contaminant in the wastewater system.
    This assessment can be accomplished using
    manual methods which are  simply based on
    the utility's knowledge of flow patterns in the
    collection system. The assessment can also be
    conducted through the use of hydraulic models
    such as EPA's SewerNet.
    
    SewerNet is an integrated, GIS-based
    simulation model for consequence assessment
    of sanitary and storm water collection
    systems affected by contamination events.
    It can be applied to any storm, sanitary, or
    combined sewer system. The model is capable
    of predicting the routing of contaminated
    storm water and/or sanitary flow through the
    sewer network, from points of collection to
    treatment facilities or direct discharge points.
    It can account for chemical transformations
    and losses that might occur during transport,
    such as volatilization or adsorption onto pipe
    walls, and can analyze the consequences of a
    variety of contamination scenarios. Additional
    information on SewerNet is available at the
    following website:
    http://eh2o.saic.com/iwqss.
    
    The Contaminant Characterization and
    Transport Worksheet (Appendix 13) is a form
    that could be used to help organize information
    that will lead to the identification of the
    contaminant. It can also facilitate decisions
    on appropriate operational responses and
    provide more accurate information for public
    notification.
    
    4 Implement Appropriate
      Operational  Responses
      (Post-threat Phase)
    
    Certain operational responses, identified during
    the pre-threat phase planning process, may
    be implemented in response to a 'Possible'
    or 'Credible' contamination threat. The
    objectives of operational response actions
    should be to minimize exposure of the
    public and wastewater system employees
    to the contaminated wastewater, decrease
    the negative impact on the environment,
    lessen the potential impact on the wastewater
    infrastructure, and provide additional time to
    evaluate whether or not the threat is 'Credible'
    or 'Confirmed.' Some operational responses
    include the following and can be implemented
    if consistent with applicable laws and
    regulations:
    
      • Isolate and store contaminated wastewater
        (e.g., in backup storage basins or tanks, if
        available).
      • Slow the influent flow of wastewater
        into the treatment plant to permit more
        extensive treatment.
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       • Isolate redundant unit wastewater
        treatment processes, if available, to
        prevent the contaminant from damaging
        the entire treatment process.
       • Increase disinfectant concentrations to
        reduce the passage of infectious pathogens
        through the treatment plant and into the
        environment
    
    Because some of these actions could violate
    permit conditions or the Clean Water Act,
    these actions should only be taken after
    consultation with the regulatory agency. If
    the utility is considering a bypass, the utility
    should note that the conditions for a bypass
    are described in 40 CFR 122.41(m). If the
    permittee knows in advance of the need for a
    bypass, it shall submit prior notice at least ten
    days before the date of the bypass, if possible.
    In the case of an unanticipated bypass, the
    permittee shall submit on 24 hour notice if the
    following conditions are met: (A) bypass was
    unavoidable to prevent loss of life, personal
    injury, or severe property damage; (B) there
    were no feasible alternatives to the bypass, and
    (C) the permittee submitted notices as required
    under paragraph (m)(3) of this section. CWA
    Section 301(f) governs the discharge of any
    radiological, chemical, or biological warfare
    agent, any high-level radioactive waste, or any
    medical waste, into the navigable waters. The
    cost of restoring the contaminated plant versus
    the environmental and economic damage to
    the watershed must be carefully considered. In
    addition, downstream drinking water treatment
    plants should be notified since this could
    impact their ability to provide safe drinking
    water to the public.
    
    The Public Health Response Action Worksheet
    in Appendix 14 can be utilized to organize
    information to aid in the evaluation of
    containment options, issuance  of public
    notification, and provision of alternate sanitary
    services.
    5 Implement the Public
      Notification Strategy
      (Post-threat Phase)
    
    Public notification will be a key component of
    an effective response to a 'Credible' threat or
    'Confirmed' incident. It may also be required
    by applicable laws and regulations.  Public
    notification may be needed to reduce or
    mitigate exposure to a contaminant and prevent
    panic. In the case of a 'Credible' contamination
    threat, if time allows, the utility should consult
    with the wastewater primacy agency, and the
    public health agency, to determine whether or
    not the situation warrants public notification.
    
    Once the decision has been made to notify
    the public, it is important to evaluate the type
    of information that should be delivered to
    the public. Any available information about
    the suspected contaminant will support the
    process of developing a notification message.
    If the identity of the contaminant is known
    with a sufficient degree of confidence as a
    result of the threat evaluation, then the public
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    notification may be crafted to deal with the
    specific risks to public health and safety posed
    by the contaminant. At a minimum generally,
    the public notification could include:
    
       • Description of the contaminant
       • How the contaminant was introduced into
        the wastewater system
       • Geographical extent of the affected area
       • Potential risks to which the public may
        be exposed (e.g., explosive fumes and/or
        toxic vapors)
       • Protective actions the public should take
        (e.g., evacuation)
       • Actions being taken by authorities to
        control the situation
       • Reassurance that the public will be kept
        informed
    
    In an extreme situation, it may become
    necessary to advise the public not to flush
    toilets (Do Not Flush order). This could occur,
    for example, if the drinking water supply had
    become contaminated with substances that
    present an inhalation risk if aerosolized or
    volatilized.  In this situation, the public would
    probably also receive a Do Not Use order for
    the drinking water system. In the event that it
    becomes necessary to communicate with the
    public concerning a contamination  event in
    the wastewater system, the communication
    will most likely occur through the media
    (TV, radio, newspapers). Methods such as
    email notices, reverse 911, and door-to-door
    notifications may also be used. To facilitate this
    communication, and maintain the credibility
    of the utility, as well as public health and
    regulatory agencies, it is important to maintain
    a communications plan, try to establish a
    working relationship with the local media
    prior to an event, and deal with the media in a
    forthright manner.
    
    6 Make Available Short Term
      Alternate Sanitary Services
      (Post-threat Phase)
    
    In the event that the wastewater collection
    system, or a portion of it, is temporarily not
    usable, the response will have to include
    provision of alternate sanitation options. A
    similar situation occurred in the past when
    portions of the wastewater collection system
    were destroyed by explosions in Akron, Ohio
    (1977) and Louisville, Kentucky (1981) as
    described in Module 1 of the Toolbox. Options
    for temporary sanitary facilities may include
    deployment and maintenance of portable
    toilets, home waste treatment devices, or
    packaged systems.
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    The wastewater utility and local authorities
    may or may not have the resources to provide
    alternate sanitation facilities. In the event
    that local resources are overwhelmed,  state
    and federal agencies may need to provide
    assistance.
    
    7 Summary
    
    The public health and environmental response
    to an intentional or accidental wastewater
    contamination event includes the actions taken
    to control the public health/safety, property/
    infrastructure damage, and environmental
    consequences resulting from biological,
    chemical or radiological  contaminants.
    
    The utility should plan the response with
    other organizations prior to receipt of a threat.
    This includes identification of the roles and
    responsibilities of agencies involved in the
    response, development of a communication
    strategy, and evaluation of the feasibility of
    various  operational responses.
    
    Once the utility and other responders
    become aware of a contamination threat,
    they should determine the public health and
    environmental consequences resulting from
    the contamination, implement operational
    responses, notify the public, and if necessary,
    provide alternate sanitary services.
    
    Much of the success of the public health and
    environmental response depends on adequate
    pre-planning and effective communications
    among all the response organizations involved.
    8 Appendices
    
    The following are examples of forms that may
    be used to facilitate the public health response:
       • Contaminant Characterization and
        Transport Worksheet
       • Public Health Response Action Worksheet
    These forms can be found in the Appendices
    located at the end  of the Toolbox.
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    c/EPA
    Wastewater Response Protocol
      United States      T   • •   _
      Environmental Protection  | \J\J | LJ(jX .
      Agency
                 Planning For and Responding To
                 Wastewater Contamination
                 Threats and Incidents
                 December 2011
                 Module 6:
                 Remediation and Recovery Guide
    

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                             Table of Contents - Module 6
    
    1 Introduction [[[ 6-1
    2 Roles and Responsibilities During Remediation and Recovery ............................................... 6-2
    3 Steps in Remediation and Recovery Process [[[ 6-2
      3.1 Long-Term Alternate Sanitary Services [[[ 6-2
      3.2 System Characterization/Feasibility Study [[[ 6-2
      3.3 Risk Assessment [[[ 6-3
      3.4 Detailed Analysis of Alternatives for Remediation [[[ 6-3
      3.5 Remediation Technology Selection [[[ 6-5
                                                                                               ~O
      3.6 Remedial Design [[[ 6-5
      3.7 Remedial Action [[[ 6-5
    

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                                              Threat Warning
                                         Initial Threat Evaluation
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                                            Response Actions
                                           Site Characterization
                                              and Sampling
                  Public Health
                Response Actions
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                                               Confirmed
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    1 Introduction
    This module presents guidance on the
    remediation and recovery process that should
    be applied when a wastewater contamination
    incident has been confirmed. The target
    audience for this module includes:
    
       • Individuals who will be involved in
         characterization, risk assessment, and
         remedial response activities following a
         confirmed contamination  incident.
    
       • Lead agency personnel and decision
         makers who will determine the need for
         long-term alternate sanitary services,
         select remedial technologies, determine
         when to return to normal  operations, and
         communicate with the public.
    
    These individuals will probably include utility
    personnel, regulators, public health officials,
    and technical assistance providers.
    
    The purpose of the remediation and recovery
    process is to address extensive contamination
    at levels that pose immediate and/or long-term
    risks to human health and the environment.
    The overall objective is to reduce or eliminate
    the contaminant and return the wastewater
    system to service as quickly as possible while
    protecting public health and the environment
    and minimizing disruption to normal life. The
    remediation and recovery process is applicable
    for decontamination of the contaminated
    wastewater prior to safe disposal, as well as
    to remediation of the wastewater collection
    system, the treatment plant, and associated
    facilities such as lift stations. While rapid
    recovery of the system may be critical, it is
    important to follow a systematic process that
    is consistent with any applicable laws and
    regulations, and establishes remedial goals
    acceptable to all stakeholders, implements
    the remedial process in an effective and
    responsible manner, and demonstrates that the
    remedial action was successful. This  module
    describes some elements of such a systematic
    process.
    If it is determined that chemical, biological, or
    radiochemical contaminants have entered the
    public wastewater system it may be necessary
    to protect utility employees from exposure
    until the scope of the problem is defined
    and remediation has been completed. These
    actions may even need to take place prior to
    the completion of the characterization process.
    Some specific steps that might be taken to
    protect employees in the interim include:
    
       • Prevent personnel from entering manholes
       • Prevent personnel from entering wet wells
        of pump  stations
       • Suspend manual cleaning of bar screens
        and removal of grit
       • Restrict access to trickling filters, aeration
        basins, and other treatment plant sites
        where aerosols might be generated
       • Suspend manual handling of biosolids
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    2 Roles and Responsibilities
      During Remediation and
      Recovery
    
    The remediation and recovery process should
    be implemented when a contamination
    incident has been confirmed. For a 'Confirmed'
    incident, an agency external to the utility may
    assume the responsibility for coordinating
    the response under the Incident Command
    System (ICS). Whether a local, state, or federal
    government exercises primary authority may
    depend on the nature and size of the incident
    and the resources needed for remediation
    and recovery. State and local governments
    have primary responsibility for consequence
    management, including remediation and
    recovery efforts. If the magnitude of the
    remediation and recovery efforts exceeds
    the capabilities and resources of state and
    local government, and if federal interests are
    involved, then the federal government may be
    required to provide assistance.
    
    3 Steps in Remediation and
      Recovery Process
    
    It should be noted that the remediation and
    recovery approach outlined in this module
    is modeled, in part, on the EPA Superfund
    remedial response program. There are nine
    steps in the remediation and recovery program.
    Each is described below.
    3.1 Long-Term Alternate Sanitary
       Services
    
    During the remedial process, long-term
    alternate sanitary services may need to be
    secured. The specific services required will
    depend on the extent of contamination but
    could include long-term alternate wastewater
    collection, treatment, and disposal. Long-term
    alternate services may be different from the
    short-term services described in Module 5.
    The need for long-term alternative services
    will depend on the nature and severity of
    the contamination event and the length of
    time required to return the system to normal
    operation. If utility  and local authorities do
    not have the resources to provide long-term
    alternate sanitation, assistance may be required
    from mutual aid and assistance agreements
    with other wastewater utilities (such as
    WARNs), the state, or the federal government.
    Alternative  services may include:
    
       • Portable toilets
       • Collection points for removal and disposal
        of 'gray water' (i.e., wash water that does
        not contain sanitary waste)
       • Contracts with  hauling companies to assist
        in transferring unaffected wastewater
    
    3.2 System Characterization/Feasibility
       Study
    
    After a contamination incident has been
    confirmed, additional information will be
    required to support remediation/recovery
    actions. This information and data can be
    obtained via a System Characterization/
    Feasibility Study. The study will provide a
    detailed assessment of the nature and  extent
    of contamination and preliminarily screen
    candidate treatment options. Several planning
    documents may be helpful for the system
    characterization.
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    System Characterization/Feasibility Study
    Work Plan
    
    The System Characterization/Feasibility
    Study Work Plan documents information
    collected and decisions made during the
    systematic planning process, and describes
    anticipated future tasks. It also serves as
    a tool for assigning responsibilities and
    setting the project's schedule and cost.
    Appendix 15 provides a suggested outline
    for the System Characterization/Feasibility
    Study Work Plan.
    
    Quality Assurance Project Plan
    
    This is a critical planning document for
    data collection for system characterization
    because it documents all project activities
    including Quality Assurance (QA) and
    Quality Control (QC) procedures. See
    Appendix 16 for a listing of the elements of
    a Quality Assurance Project Plan.
    
    Health and Safety Plan (HASP)
    
    The HASP includes information regarding
    personnel roles, lines of authority
    and communication, site security and
    control, and medical and emergency alert
    procedures. The HASP should be developed
    for the specifics of the incident so that staff
    is aware of the common routes of exposure
    at a site and is trained in the proper use of
    safety equipment and protective clothing
    and equipment. Safe areas should be
    designated for washing, drinking, and
    eating. A suggested format for a HASP is
    given in Appendix 17.
    
    3.3 Risk Assessment
    
    Upon confirmation of a contamination
    incident, the lead agency for consequence
    management will quickly assess the risk posed
    to on-site workers and the public. This rapid
    risk assessment will help guide response
    actions.
    
    During the remedial response phase, additional
    risk assessments may be required to:
    
      • Evaluate risk reduction achieved by
        the operational response actions being
        conducted at that time
      • Aid in establishing preliminary
        remediation goals
      • Assess potential risk reduction from
        implementation of long-term remedial
        actions
    
    3.4 Detailed Analysis of Alternatives for
       Remediation
    
    This step involves the evaluation of various
    remediation approaches available on the
    basis of their effectiveness and technical
    feasibility. In situations in which human
    health and environmental risks are reduced to
    acceptable levels through natural attenuation
    or degradation of the contaminant, no remedial
    actions may be required.
    
    If remedial actions are required,  they may
    include any of the following steps, or
    combination of steps:
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       • Containment of contaminated wastewater
       • Treatment of contaminated wastewater
       • Disposal of contaminated wastewater
       • Rehabilitation of contaminated wastewater
        system components
       • Restoration of the biological treatment
        process
    
    Restoration of biological treatment may require
    importing and  introducing organisms from
    other processes within the plant (if unaffected)
    or from other nearby treatment plants. Full
    recovery of the biological community could
    take weeks or months.
    
    Possible technologies for cleanup of
    contaminated wastewater include, but are not
    limited to, the  following, which can  be used
    alone or in combination:
    
       • Chlorination
       • Air stripping
       • Granular activated carbon filtration
       • Ultraviolet irradiation
       • Ozonation
    
    For the management of radioactive materials
    entering POTWs that may impact wastewater/
    stormwater management, guidance is provided
    by the  Interagency Steering Committee on
    Radiation Standards in the document ISCORS
    Assessment of Radioactivity in Sewage
    Sludge: Recommendations on Management
    of Radioactive Materials in Sewage  Sludge
    and Ash at Publicly Owned Treatment Works
    (February 2005 - ISCORS Technical Report
    2004-04; EPA  832-R-03-002B; DOE/EH-
    668) that is available on the ISCORS website
    under LIBRARY at http://www.iscors.org/pdf/
    FinalRecommendations.pdf
    
    Additionally, various  contaminated
    components of the wastewater system may
    need to be rehabilitated. These include the
    infrastructure, such as system mains and
    pumps, as well as the equipment used to
    treat the wastewater at the plant. Possible
    technologies and alternatives that can
    be considered for the rehabilitation of
    contaminated system components include:
       • Disinfection
       • System flushing
       • Pigging and swabbing of system piping
       • Air scouring
       • Sand blasting
       • Relining pipes
       • Condemning portions of the collection
        and/or treatment system (e.g., in response
        to gross contamination such as from a
        radiological agent)
       • Utilization of the current treatment plant
        with a new collection system
       • Utilization of the current wastewater
        collection system with a new treatment
        plant
    
    Remediation can be performed in stages with
    emergency short-term remediation being
    conducted to reduce dangerous levels of a
    contaminant to a safer level. This can then be
    followed by long-term, more comprehensive
    cleanup  steps to remove any remaining low
    levels of the contaminant(s). When assessing
    remediation alternatives, the utility will need to
    take into consideration any applicable laws and
    regulations.
    
    To learn more about available federal funding
    for remediation/recovery from disasters
    see http://water, epa.gov/infrastructure/
    watersecurity.
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    3.5 Remediation Technology Selection
    
    To select the remediation technology, a
    comparative analysis may be performed to
    identify the advantages and disadvantages of
    each technology. The criteria for technology
    selection include, among others:
    
      • Protection of human health
      • Protection of the environment
      • Compliance with applicable laws and
        regulations (e.g., the Clean Water Act)
      • Feasibility of implementation
      • Cost
    
    3.6 Remedial  Design
    
    After a final remedy is selected, remedial
    design is the next step. This is an engineering
    phase involving preparation of a series of
    documents, specifications, and drawings that
    detail the specific steps to be taken during
    the remedial action. The lead agency will be
    responsible for remedial design, assisted by
    the wastewater utility (if not already the lead
    agency) and other technical support staff.
    Remediation should be designed to prevent
    impacts on the remaining unaffected portions
    of the wastewater system.
    
    3.7 Remedial Action
    
    This is the actual implementation of the chosen
    remediation approach and includes both
    treatment of contaminated wastewater and
    rehabilitation of system components.
    
    3.8 Post-Remediation Monitoring
    
    After site actions are complete, monitoring of
    the system must be conducted to ensure that
    the remediation was effective.
    3.9 Communication to Restore Public
        Confidence
    
    During remediation activities, and prior to
    return of the system to normal operations,
    the utility and other agencies should conduct
    outreach to the community to restore public
    confidence in the wastewater system.
    
    The degree to which remediation and recovery
    follows the nine step model presented above
    will depend on the nature and extent of the
    contamination.  A small-scale incident might
    not involve all of the steps. For example,
    extensive system characterization may not
    be required if the contamination is contained
    through early operational responses and
    is confined to a well-defined area. Each
    remediation and recovery effort will be
    unique and will be dictated by details of the
    intentional or accidental contamination event.
    
    4 Summary
    
    Following confirmation of either an accidental
    or intentional contamination event in a
    wastewater system, steps must be taken to
    remove the contamination and bring the system
    back into full service. Depending on the nature
    and extent of contamination, the wastewater
    may have to be decontaminated prior to
    disposal. The wastewater infrastructure (e.g.,
    collection mains, pumps, and treatment plant)
    may also have to be decontaminated. Module 6
    of the Toolbox outlines a systematic approach,
    based on EPAs Superfund experience,
    for remediation and recovery of affected
    wastewater systems.
    
    Efforts are ongoing within the federal
    government and research community to
    develop specific technical solutions to
    wastewater system decontamination needs.
    When developed, this information may be
    distributed through vehicles such as WCIT.
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              5 Appendices
    
              The following are examples of forms that
              may be used to facilitate the remediation and
              recovery process:
               • Suggested Outline for System
                Characterization/Feasibility Study Work
                Plan
               • Elements for a Quality Assurance Project
                Plan
               • Elements of a  Health and Safety Plan
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              These forms can be found in the Appendices
              located at the end of the Toolbox.
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    &EPA
      United States
      Environmental Protection
      Agency
    Wastewater Response Protocol
    Toolbox:
    Planning For and Responding To
    Wastewater Contamination
    Threats and Incidents
    December 2011
    Appendices
    

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                                        Threat Warning
                                    Initial Threat Evaluation
                                           Is Threat
                                           Possible
    Immediate Operational
    
      Response Actions
                                            i>
                                     Site Characterization
    
                                         and Sampling
                                           Is Threat
                                           Credible
                                         Public Health
                                       Response Actions
                                       Sample Analysis
                                          Is Incident
                                          Confirmed
                                   Remediation and Recovery
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                           Table of Contents - Appendices
    
    Module 2 Forms
    1 Response Planning Matrix	Al
    2 Threat Evaluation Worksheet	A2
    3 Security Incident Report Form	A3
    4 Witness Account Report Form	A4
    5 Phone Threat Report Form	A5
    6 Written Threat Report Form	A6
    7 Public Health Information Report Form	A7
    Module 3 Forms
    8 Site Characterization Plan Template	A8
    9 Site Characterization Report Form	A9
    10 Field Testing  Results Form	AID
    11 Sample Documentation Form	All
    12 Chain of Custody Form	A12
    Module 5 Forms
    13 Contaminant Characterization and Transport Worksheet	A13
    14 Public Health Response Action Worksheet	A14
    Module 6 Forms
    15 Suggested Outline for System Characterization/Feasibility Study Work Plan	A15
    16 Elements for a Quality Assurance Project Plan	A16
    17 Elements of a Health and Safety Plan	A17
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         1 Response Planning Matrix
    Incident
    Crmfibttlty
    Possible
    Credible
    Confirmed
    Ctaiseqtttsncex
    ^people
    affected
    10's
    100's
    KQOO'B
    10*s
    LOO's
    UOOO's
    10*s
    100's
    LOOO's
    Health
    Impact
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Sex-ere
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Minor
    Moderate
    Severe
    Other
    Coa.iidertiiiimz
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Response
    Possible Actions
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Andfipaied Impacts
    ort the public.
    iitfrayrnit-mn.'.
    property tint!
    environment
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
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     2 Threat Evaluation Worksheet
    
     INSTRUCTIONS
    
     The purpose of this worksheet is to help organize information about a contamination threat
     warning that would be used during the Threat Evaluation Process. The individual responsible for
     conducting the Threat Evaluation (e.g., the Utility Incident Commander) should complete this
     worksheet.  The worksheet is generic to accommodate information from different types of threat
     warnings; thus, there will likely be information that is unavailable or not immediately available.
     Other forms in the Appendices are provided to augment the information in this worksheet.
    
    
    Threat Warning Information
    
              Date/Time threat warning discovered: 	
              Name of person who discovered threat warning:	
    
              Type of threat warning:
               D  Security breach   D  Witness account    D  Phone threat
               D  Written threat    D  Law enforcement   D  Public health notification
               D  News media      D  Public complaints
               D  Degradation of treatment organisms
               D  Unusual wastewater chemical characteristics
               D  Other:	
    
    
              Identity of the contaminant:          D Known     D Suspected    D Unknown
    
                If known or suspected, provide additional detail below
               D  Chemical           D  Biological            D  Radiological
    
               Describe:
              Time of contamination:       D Known    D Estimated     D Unknown
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                If known or suspected, provide additional detail below                                                        QJ
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              Date and time of contamination:	            -~~
    
              Additional information:	
                                                                                                          Q_
                                                                                                          Q_
              Mode of contamination:       D Known    D Suspected     D Unknown
                If known or suspected, provide additional detail below
    
              Method of addition:     D Single dose     D Over time     D Other	
    
              Amount of material:	
              Additional information:
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                  Site of contamination:           D Known     D Suspected    D Unknown
    
                     If known or suspected, provide additional detail below
                     Number of sites:
                     Provide the following information for each site.
                     Site #1
                     Site Name:
                     Type of facility:
                     D  Manhole              D  Treatment plant               D  Pump station
                     D  Catch basin            D  Collection main               D  Building drain
                     D  Other:	
                     Address:	
                     Additional site information:
                     Site #2
                     Site Name:
                     Type of facility:
                     d  Manhole              D  Treatment plant               D  Pump station
                     D  Catch basin            D  Collection main               D  Building drain
                     D  Other:	
                     Address:	
    
    
                     Additional site information:
    CO               Site #3
    CD
    O               Site Name:
                     Type of facility:
                     Q  Manhole              D  Treatment plant               D  Pump station
                     D  Catch basin            D  Collection main               D  Building drain
                     D  Other:	
                     Address:	
                     Additional site information:
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    Additional Information
            Has there been a breach of security at the suspected site?                  D Yes          D No
               // "Yes, " review the completed 'Security Incident Report'
            Are there any witness accounts of the suspected incident?                  D Yes          D No
               // "Yes, " review the completed 'Witness Account Report'
            Was the threat made verbally over the phone?                            D Yes          D No
               // "Yes, " review the completed 'Phone Threat Report'
            Was a written threat received?                                           D Yes          D No
               // "Yes, " review the completed 'Security Incident Report'
            Are there unusual wastewater chemical data or public complaints?          D Yes          D No
            Are there unusual symptoms or disease in the population?                  D Yes          D No
               // "Yes, " review the completed 'Public Health Report'
            Is a 'Site Characterization Report' available?                               D Yes          D No
               // "Yes, " review the completed 'Site Characterization Report' (Module 3)
            Are results of sample analysis available?                                  D Yes          D No
               // "Yes, " review the analytical results report, including appropriate QA/QC data
            Is a 'Contamination Identification Report' available?                        D Yes          D No
               // "Yes, " review the completed 'Contaminant Characterization and Transport Worksheet' (Module 5)
            Is there relevant information available from external resources?            D Yes          D No
               Check all that apply
               d   Local law enforcement      d   FBI                          d  Primacy agency
               Ll   Public health agency        D   Hospitals/911 call centers    D  US EPA/Water ISAC
               D   Media reports              d   Homeland Security alerts     d  Neighboring utilities
               HI   WARNs                   D  Other:	
                                                                                                                     CD
            Point of contact:	
                                                                                                                     T3
            	           C
                                                                                                                     CD
            Summary of key information from external sources (provide detail in attachments as necessary):
                                                                                                                     Q_
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              Threat Evaluation
    
                  Has normal activity been investigated as the cause of the threat warning?   D Yes  D No
                      Normal activities to consider
                      D Utility staff inspections             D Routine wastewater sampling
                      n Construction or maintenance       n Contractor activity
                      D Operational changes               D Wastewater chemical changes with a known cause
                      D Other:  	
    
                  Is the threat'possible'?     D Yes         Q No
                      Summarize the basis for this determination:	
                     Response to a 'possible' threat:
                     D None                            D Site characterization       D  Isolation/containment
                     D Increased monitoring/security      D Other: 	
                  Is the threat'credible'?     Q Yes         Q No
                     Summarize the basis for this determination:
                     Response to a 'credible' threat:
                     D Sample analysis            D Site characterization  D Isolation/containment
                     n Partial EOC activation       n Public notification    n Law Enforcement Notification
                     D Other:	
    
                  Has a contamination incident been confirmed?     D Yes         D No
                     Summarize the basis for this determination:
                     Response to a confirmed incident:
                      D Sample analysis            D Site characterization D Isolation/containment
    O
                      n Full EOC activation          n Public notification   n Provide alternate sanitary services
                      D Initiate remediation and recovery                 D Law Enforcement Notification
                      D Other:  	
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           How do other organizations characterize the threat?
    Organization
    D Local law
    enforcement
    D FBI
    D Public health
    agency
    D Wastewater
    permitting
    agency
    D Other
    D Other
    Evaluation
    D Possible
    D Credible
    D Confirmed
    D Possible
    D Credible
    D Confirmed
    D Possible
    D Credible
    D Confirmed
    D Possible
    D Credible
    D Confirmed
    D Possible
    D Credible
    D Confirmed
    D Possible
    D Credible
    D Confirmed
    Comment
    
    
    
    
    
    
    Sign off
           Name of person responsible for threat evaluation:
    
    
           Print name:
           Signature:
    _Date/Time:
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                3     Security Incident Report Form
    
                INSTRUCTIONS
                The purpose of this form is to help organize information about a security incident, typically a security
                breach, which may be related to a wastewater contamination threat.  The individual who discovered the
                security incident, such as a security supervisor, the Utility Incident Commander, or another designated
                individual may complete this form. This form is intended to summarize information about a security
                breach that may be relevant to the threat evaluation process.  This form should be completed for each
                location where a security incident was discovered.
    
                Discovery of Security Incident
                    Date/Time security incident discovered: 	
                    Name of person who discovered security incident: 	
                    Mode of discovery:
                       rj Alarm (building)         fj Alarm (gate/fence)           fj  Alarm (access hatch)
                       D Video surveillance       D Utility staff discovery         D  Citizen discovery
                       D Suspect confession      D Law enforcement discovery
                       D Other:	
                    Did anyone observe the security incident as it occurred?          D Yes      D No
                       If "Yes", complete the 'Witness Account Report'
    
                Site Description
                    Site Name: 	
                    Type of facility
                           rj  Manhole                rj Treatment plant           rj Pump station
                           n  Catch basin              n Collection main            n Building drain
                           n  Other:	
                    Address:	
    
     CO
                    Additional Site Information:	
     O
    T3
     C
     CD         Background Information
     o
                    Have the following "normal activities" been investigated as potential causes of the security
                    incident?
                    D  Alarms with known and  harmless causes     D Utility staff inspections
                    n  Routine wastewater sampling               D Construction or maintenance
                    D  Contractor activity                         D Other:	
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           Was this site recently visited prior to the security incident?             D Yes         D No
    
              // 'Yes, 'provide additional detail below
    
              Date and time of previous visit:	
              Name of individual who visited the site:
    
              Additional information:	
            Has this location been the site of previous security incidents?           D Yes         D No
    
              \f 'Yes, 'provide additional detail below
    
              Date and time of most recent security incident:	
    
              Description of incident:	
              What were the results of the threat evaluation for this incident?
    
                   D 'Possible'           D  'Credible'           D 'Confirmed'
    
            Have security incidents occurred at other locations recently?           D Yes         D No
    
              // 'Yes,' complete additional 'Security Incident Reports' for each site
    
              Name of 1st additional site:	
    
              Name of 2nd additional site:	
    
              Name of 3rd additional site:
    Security Incident Details
    
           Was there an alarm(s) associated with the security incident?           D Yes     D No
    
              // 'Yes,'provide additional information below
                                                                                                              CO
              Are there sequential alarms (e.g., alarm on a gate and a hatch)?      D Yes     D No               QJ
                                                                                                              U
              Date and time of alarm(s):	
    
              Describe alarm(s):	
                                                                                                              CD-
           Is video surveillance available for the site of the security incident?      Yes            No
                                                                                                             <
              // Yes, provide additional detail below
    
              Date and time of video surveillance:	
    
              Describe surveillance:	
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    Q_
    Q_
                     Unusual equipment found at the site and time of discovery of the security incident:
                        d  Discarded PPE (e.g., gloves and masks)    d  Empty containers (e.g., bottles, drums)
                        D  Tools (e.g., wrenches, bolt cutters)        D  Hardware (e.g., valves, pipe)
                        D  Lab equipment (e.g., beakers, tubing)     D  Pumps or hoses
                        D  None                                  D  Other:	
                        Describe equipment:	
    
    
                     Unusual vehicles found at the site and time of discovery of the security incident:
                        D  Car/sedan              D  SUV                    D  Pickup truck
                        D  Flatbed truck            D  Construction vehicle      D  None
                        D  Other: 	
                        Describe vehicles (including make/model/year/color/license plate #, logos, or markings):
    
    
                     Signs of tampering at the site and time of discovery of the security incident:
                        d  Cut locks/fences                       d  Open/damaged gates, doors, or windows
                        D  Open/damaged access hatches           D  Missing/damaged equipment
                        D  Facility in disarray                      D  None
                        D  Other: 	
                        Are there signs of sequential intrusion (e.g., locks removed from a gate and hatch)?
                                                                                     D Yes      D No
                        Describe signs of tampering:	
                     Signs of hazard at the site and time of discovery of the security incident:
                        d  Unexplained or unusual odors              d  Unexplained dead animals
                        D  Unexplained dead or stressed vegetation    D  Unexplained liquids
                        D  Unexplained clouds or vapors              D  None
                        D  Other:	
    O                  Describe signs of hazard:
              Signoff
                     Name of person responsible for documenting the security incident:
                     Print name:
                     Signature:	Date/Time:
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    4     Witness Account Report Form
    INSTRUCTIONS
    The purpose of this form is to document the observations of a witness to activities that might be
    considered an incident warning. The individual interviewing the witness, or potentially the witness,
    should complete this form. This may be the Utility Incident Commander or an individual designated by
    incident command to perform the interview. If law enforcement is conducting the interview (which may
    often be the case),  then this form may serve as a prompt for "utility relevant information " that should be
    pursued during the interview.  This form is intended to consolidate the details of the witness account that
    may be relevant to the threat evaluation process.  This form should be completed for each witness that is
    interviewed.
    
    Basic Information
        Date/Time of Interview: 	
        Name of person interviewing witness: 	
        Witness contact information: 	
           Full Name: 	
           Address: 	
           Daytime phone: 	
           Evening phone:  	
           E-mail address:  	
         Reason the witness was in the vicinity of the suspicious activity:
    Witness Account
         Date/Time of activity: 	
         Location of activity:
           Site name: 	
           Type of facility
           D Manhole                D Treatment plant                D Pump station              ~O
                                                                                                    C
           D Catch basin              D Collection main                 D Building drain               QJ
                                                                                                    Q_
           D Other: 	
                                                                                                   <
         Address:
        Additional site information:
                          Wastewater Response Protocol Toolbox                        A4-1
    

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                     Type of activity
                         D  Trespassing
                         D  Theft
                         D  Other: 	
                   D  Vandalism
                   D  Tampering
                        Additional description of the activity:
      D  Breaking and entering
      D  Surveillance
    
    Q_
    Q_
                      Description of suspects
    
                        Were suspects present at the site?
    
                        How many suspects were present?
                            DYes
    D No
    Describe each suspect's appearance:
    Suspect #
    1
    2
    3
    4
    5
    6
    Sex
    
    
    
    
    
    
    Race
    
    
    
    
    
    
    Hair Color
    
    
    
    
    
    
    Clothing
    
    
    
    
    
    
    Voice
    
    
    
    
    
    
                     Were any of the suspects wearing uniforms?
    
                        If 'Yes/ describe the uniform(s):	
                                   DYes
           D No
                        Describe any other unusual characteristics of the suspects:
                        Did any of the suspects notice the witness?
    
                        If 'Yes/ how did they respond?	
                                   DYes
           D No
         A4-2
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    Vehicles at the site
    
      Were vehicles present at the site?            D Yes
    
      Did the vehicles appear to belong to the suspects?
    
      How many vehicles were present?	
    
      Describe each vehicle:
    D No
    
    DYes
                                                                             D No
    Vehicle #
    1
    2
    3
    4
    5
    6
    Type
    
    
    
    
    
    
    Color
    
    
    
    
    
    
    Make
    
    
    
    
    
    
    Model
    
    
    
    
    
    
    License Plate
    
    
    
    
    
    
      Were there any logos or distinguishing marks on the vehicles?
      If 'Yes/ describe:	
           DYes
                                                                                    D No
       Provide any additional detail about the vehicles and how they were used (if at all):
    Equipment at the site
      Was any unusual equipment present at the site?
      d  Explosive or incendiary devices
      D  PPE (e.g., gloves, masks)
      D  Tools (e.g., wrenches, bolt cutters)
      D  Lab equipment (e.g., beakers, tubing)
      D  Other: 	
    D Yes
                                                                             D No
                                                  d  Firearms
                                                  D  Containers (e.g., bottles, drums)
                                                  D  Hardware (e.g., valves, pipe, hoses)
                                                  D  Pumps and related equipment
       Describe equipment and how it was being used by the suspects (if at all):
                                                                                                             U
                                                  Q_
                                                  Q_
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                      Unusual conditions at the site
    
    
                        Were there any unusual conditions at the site?               d Yes         d No
    
    
                        D  Explosions or fires             d  Fogs or vapors         d  Unusual odors
    
    
                        d  Dead/stressed vegetation      d  Dead animals          d  Unusual noises
    
    
                        d  Other:
    Describe the site
    conditions:
    
    
    
                      Additional observations
    
    
                        Describe any additional details from the witness account:
               Signoff
    
    
                      Name of interviewer:
    
    
                      Print name:
    CD
    (_)                Signature:	Date/Time:
                      Name of witness:
    
    Q_
                      Print name:
                      Signature:	Date/Time:
         A4-4                          Wastewater Response Protocol Toolbox
    

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    5      Phone Threat Report Form
    
    INSTRUCTIONS
    This form is intended to be used by utility staff that regularly answer phone calls from the public (e.g., call
    center operators).  The purpose of this form is to help these staff capture as much information as possible
    from a threatening phone call while the caller is on the line. It is important that the operator keep the
    caller on the line as long as possible in order to collect the information.  Since this form will be used
    during the call, it is important that operators become familiar with the content of the form.  The sections
    of the form are organized with the information that should be collected during the call at the beginning of
    the form (i.e., Basic Call Information and Details of Threat) and information that can be completed
    immediately following the call at the end of the form (i.e., the description of the caller).  The information
    collected on this form will be critical to the threat evaluation process.
    
    Basic Information
         Name of person receiving the call: 	
         Date phone call received: 	   Time phone call received:
    
         Time phone call ended: 	   Duration of call: 	
        Originating number: 	   Originating name:
           If the number/name is not displayed on the caller ID, press *57 (or call trace) at the end of the call
           and inform law enforcement that the phone company may have trace information.
    
         Is the connection clear?     D Yes           D No
    
         Could the call be from a wireless phone?       D Yes       D No
    
    Details of Threat
    
         Has the wastewater system already been contaminated?    D Yes       D No
    
           Date and time of contaminant introduction known?      D Yes       D No
    
                  Date and time if known: 	
    
         Location of contaminant introduction known?              D Yes       D No
    
           Site name:
    Type of facility
    D Manhole D Treatment plant
    D Catch basin D Collection main
    
    D Other:
    
    Address:
    
    D Pump station
    D Building drain
    •a
    c
    CD
    a_
    Q_
        Additional site information:
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                     Name or type of contaminant known?
                       Type of contaminant
                       D  Chemical                 D  Biological
                       Specific contaminant name/description:	
                                               DYes
    D No
                                                             D  Radiological
                     Mode of contaminant introduction known?
                        Method of addition:         D Single dose
                        Amount of material:	
                                                     D Yes          D No
                                                     DOver time      D Other
                       Additional information:
                     Motive for contamination known?           Q Yes          QNo
                     D  Retaliation/revenge            D  Political cause            D  Religious doctrine
                     D  Other:	
                     Describe motivation:	
    
    Q_
    Q_
              Caller Information
                     Basic information
                       Stated name: _
                       Affiliation:
                        Phone number:
      Location/address:	
    Caller's voice
      Did the voice sound disguised or altered?         D Yes
      Did the call sound like a recording?              D Yes
      Did the voice sound              D Male       D Female
      Did the voice sound familiar?                   D Yes
          If 'Yes/ who did it sound like?	
      Did the caller have an accent?                   D Yes
          If 'Yes/ what did it sound like?	
                                                                                    D No
                                                                                    D No
                                                                                    D Young   D Old
                                                                                    D No
                                                                                    D No
         A5-2
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    How did the caller sound or speak?
    D Educated
    D Irrational
    D Reading a script
    What was the caller's tone
    D Calm D
    D Excited D
    D Slow D
    D Soft D
    D Laughing D
    D Deep D
    D Other:
    d Well spoken
    D Obscene
    D Other:
    of voice?
    Angry d Lisping
    Nervous D Sincere
    Rapid D Normal
    Loud D Nasal
    Crying D Clear
    High D Raspy
    
    D Illiterate
    D Incoherent
    
    
    d Stuttering/broken
    D Insincere
    D Slurred
    D Clearing throat
    D Deep breathing
    D Cracking
    
    Were there background noises coming from the caller's end?
    L~H Silence
    D Voices
    D Children
    D Animals
    D Factory sounds
    D Office sounds
    D Music
    D Traffic/street sounds
    D Airplanes
    D Trains
    D Ships or large boats
    D Other:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    Describe:
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Signoff
           Name of call recipient:
    
           Print name:	
           Signature:
           Name of person completing form (if different from call recipient):
    
           Print name:
    _Date/Time:
     U
    
    '-a
    
    
     Q_
     Q_
           Signature:
    _Date/Time:
                             Wastewater Response Protocol Toolbox
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    Q_
    Q_
            6      Written Threat Report Form
            INSTRUCTIONS
            The purpose of this form is to summarize significant information from a written threat received by a wastewater
            utility. This form should be completed by the Utility Incident Commander or an individual designated by
            incident command to evaluate the written threat. The summary information provided in this form is intended to
            support the threat evaluation process; however, the completed form is not a substitute for the complete written
            threat, which may contain additional, significant details.
            The written threat itself (e.g., the note, letter, e-mail message, etc.) may be considered evidence and thus
            should be minimally handled (or not handled at all) and placed into a clean plastic bag to preserve any
            forensic evidence.
            Safety
    
            A suspicious letter or package could pose a threat in and of itself, so caution should be exercised if
            such packages are received. The US Postal Service has issued guidance when dealing with
            suspicious packages which can be found here: http://about.usps.com/posters/pos84.pdf
    
            Threat Notification
    
                    Name of  person receiving the written threat: 	
                    Person(s) to whom threat was addressed: 	
                    Date threat received: 	      Time threat received: 	
    
                    How was the written threat received?
    
                      D US Postal Service          D Delivery service              D Courier
                      D Fax                     D E-mail                       D Hand-delivered
                      D Other:
                      If mailed, is the return address listed?                D Yes          D No
                      If mailed, what is the date and location of the postmark? 	
    to
                      If delivered, what was the service used (list any tracking numbers)?
                      If faxed, what is the number of the sending fax?
                      If e-mailed, what is the e-mail address of the sender?
                      If hand-delivered, who delivered the message?
       A6-1                            Wastewater Response Protocol Toolbox
    

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    Details of Threat
           Has the wastewater system already been contaminated?       D Yes      D No
           Date and time of contaminant introduction known?           D Yes      D No
                  Date and time if known:
           Location of contaminant introduction known?
                  Site name: 	
                         DYes
             D No
           Type of facility
                  D Manhole
                  D Catch basin
                  D Other:
           Address:  	
    e D Treatment plant
    asin D Collection main
    D Pump station
    D Building drain
           Additional site information:
           Name or type of contaminant known?          D Yes
              Type of contaminant
              D Chemical                   D Biological
              Specific contaminant name/description: 	
                           D No
                              D  Radiological
           Mode of contaminant introduction known?
              Method of addition:        D Single dose
              Amount of material:	
              Additional information:	
           Motive for contamination known?
           D Retaliation/revenge
           D Other: 	
                   DYes
                   D Overtime
           D No
                  D other
            DYes
    D Political cause
    D No
           D  Religious doctrine
           D Describe motivation:
    
                                                                                                                 Q_
                                                                                                                 Q_
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               Note Characteristics
                      Perpetrator information:
                        Stated name:	
                        Affiliation:
                        Phone number:
                        Location/address:.
                      Condition of paper/envelope:
                        d  Marked personal
                        D  Neatly typed or written
                        D  Crumpled or wadded up
                        D  Other:	
    How was the note prepared?
      D  Handwritten in print
      D  Machine typed
      D  Other:	
    Language:
      D  Clear English
      D  Another language:	
      D  Mixed languages:	
    Writing style:
      d  Educated
      D  Uneducated
      D  Use of slang
      D  Other:	
    Writing tone:
      D  Clear
      D  Cond
      D  Agitated
      D  Other:
                   d  Marked confidential
                   D  Clean
                   D  Soiled/stained
                                                               d Properly addressed
                                                               D Corrected or marked-up
                                                               D Torn/tattered
                                                     D  Handwritten in script       D  Computer typed
                                                     D  Spliced (e.g., from other typed material)
                                                                  D  Poor English
                                                     d   Proper grammar
                                                     D   Poor grammar/spelling
                                                     D   Obscene
                                             D   Logical
                                             D   Incoherent
    D Direct
    ;cending D Accusatory
    id D Nervous
    D Sincere
    D Angry
    D Irrational
    
    Q_
    Q_
               Signoff
                      Name of individual who received the threat:
                      Print name:
                      Signature:
                                       Date/Time:
                      Name of person completing form (if different from written threat recipient):
                      Print name:
                      Signature:.
                                       Date/Time:
         A6-3
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     7      Public Health Information Report Form
    
     INSTRUCTIONS
    
     The purpose of this form is to summarize significant information about a public health
    episode that could be linked to contaminated wastewater.  This form should be completed by
    the Utility Incident Commander or an individual designated by incident command.  The
    information compiled in this form is intended to support the threat evaluation process.
     In the case of a threat warning due to a report from public health, it is likely that the public
    health agency will assume incident command during the investigation.  The wastewater
    utility will likely play a support role during the investigation, specifically to help determine
    whether or not wastewater might be the cause.
    
    
     PUBLIC HEALTH NOTIFICATION
    
            Date and Time of notification: 	             	
           Name of person who received the notification:
           Contact information for individual providing the notification
    
           Full Name: 	
           Title:
           Organization:
           Address:
            Day-time phone:
    
            Evening phone:
            Fax Number: 	
            E-mail address:
           Why is this person contacting the wastewater utility?
           Has the state or local public health agency been notified?     D Yes          D No
    
              If "No," the appropriate public health official should be immediately notified.
    
     DESCRIPTION OF PUBLIC HEALTH EPISODE
           Nature of public health episode:
    
              D Unusual disease (mild)   D Unusual disease (severe)         D Death
              D Other: 	
                                                                                                  Q_
           Symptoms:
    D Diarrhea
    D Fever
    D Other:
    D Vomiting/nausea
    D Headache
    D Flu-like symptoms
    D Breathing difficulty
              Describe symptoms:
           Causative Agent: D Known   D Suspected                     D Unknown
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                     If known or suspected, provide additional detail below
    
                     D Chemical             D  Biological                 D Radiological
    
                     Describe 	
    
    
                     Estimate of time between exposure and onset of symptoms:  	
                  Exposed Individuals:
                     Location where exposure is thought to have occurred
                        D  Residence                D Work                      D  School
    
                        D  Other: 	
    
                        Additional notes on location of exposure:  	
                        Collect addresses for specific locations where exposure is thought to have occurred.
    
                   Is the pattern of exposure clustered in a specific area?       D Yes        D  No
    
                   Extent of area
                        D Single building            D Complex (several buildings)   D City block
                        D Neighborhood            D Cluster of neighborhoods     D Large section of city
                        D Other: 	
    
                        Additional notes on extent of area: 	
                     Do the exposed individuals represent a disproportionate number of:
                        D  Immune compromised       D Elderly                     D  Children
                        D  Infants                    D Pregnant women            D  Women
                        D  Other:
                        D  None, no specific groups dominate the makeup of exposed individuals
    
              EVALUATION OF LINK TO WASTEWATER
                Were there any public complaints within the affected area?              D Yes        D No
    
                Were there any unusual wastewater chemical data within the affected area? D Yes       D No
    to
    Q)          Were there any process upsets or operational changes?                 D Yes        D No
    O
                Was there any construction/maintenance within the affected area?       D Yes        D No
    
                Were there any security incidents within the affected area?              D Yes        D No
    
    Q_
    Q_
    
              SIGNOFF
    
                Name of person completing form:
    
                   Print name  	
                   Signature   	   Date/Time:
         A7-2                         Wastewater Response Protocol Toolbox
    

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    8      Site Characterization Plan Template
    
    
    INSTRUCTIONS
    This form is intended to support the development of a customized site characterization plan developed
    in response to a specific wastewater 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
    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, "Threat Evaluation Worksheet" for details about the threat.
    
    Investigation Site
         Site  Name: 	
        Type of facility:
           D Manhole                    D Treatment plant           D  Pump station
           D Catch basin                  D Collection main            D  Building drain
           D Other:	
        Address:	
    
    
        Additional Site Information:
    Initial Hazard Assessment
        Are there any indicators of an explosive hazard?         D Yes         D No
           // "Yes," notify law enforcement and do not send a team to the site.
        Initial hazard categorization
           D Low hazard                               D Chemical hazard
           D Radiological hazard                         D Biological hazard                                £O
           // the initial hazard assessment indicates a chemical, radiological, or biological hazard, then only teams
           trained to deal with such hazards should be sent to the site.
                                                                                                        C
     Site Characterization Team
        Name & Affiliation of Site Characterization Team Leader:	
        	           <
    
        Wastewater utility staff:
           rj Wastewater security specialist     Name:	
           D General security specialist         Name:	
           D Operations specialist              Name:	
           D Other                           Name:	
                             Wastewater Response Protocol Toolbox                        A8-1
    

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                     Representatives from other agencies:
                       0   Local law enforcement       fj  Fire department
                            us EPA                      FBI
                                           D HazMat
                                           rj Other
                 Communication Procedures
                     Mode of communication:
                       [J Phone
                       D Facsimile
                  [J 2-way radio
                  D Other:
    D Digital
    
    Q_
    Q_
                     Reporting events:
                       [J Upon arrival at site
                       fj After site evaluation
                       rj Other: 	
                  [J During approach
                  fj After field testing
    [J Site entry
    fj Site exit
                 Field Screening Checklist for Worker Safety and Rapid Wastewater Testing
    ./
    
    
    
    
    
    
    
    
    Parameter1
    Radiation
    pH /conductivity
    Cyanide
    Combustible gases
    Volatile chemicals
    Metals
    
    
    Screen2
    Both Safety and
    Wastewater
    Wastewater
    Wastewater
    Both Safety and
    Wastewater
    Both Safety and
    Wastewater
    Wastewater
    
    
    Meter/Kit ID3
    
    
    
    
    
    
    
    
    Check Date4
    
    
    
    
    
    
    
    
    Reference
    Values
    
    
    
    
    
    
    
    
    1List the parameters that will be evaluated as part of field screening (examples are listed).
    Screening may be conducted for safety, rapid wastewater testing, or both.
    3Report the unique identifier for the meter or kit used during screening.
    4Report date of last calibration, expiration date, or date of last equipment check as appropriate.
    5List any reference value that would trigger a particular action, such as exiting the site.
         A8-2
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    Sampling Checklist
    ^
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Analyte1
    Standard VOCs
    Semi-volatiles
    Quaternary nitrogen compounds
    Cyanide
    Carbamate pesticides
    Metals/elements
    Organometallic compounds
    Radionuclides
    Non-target VOCs
    Non-target organic compounds
    Non-target inorganic compounds
    Immunoassays
    Pathogens- PCR
    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 indicate if they are to be added in the field.
    Equipment Checklist
     D Completed Site Characterization Plan
     D Emergency Wastewater 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
    D  Bags of ice or freezer packs
    D  Rinse water (20 liters)
    D  Disposable camera
     U
    '-a
     Q_
     Q_
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                Sample Handling Instructions
    
                    Sample delivery:
    
                       D  Return samples to wastewater 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:  	             Fax: 	
    
    
                       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:
     to
     Q)             Signature:                                          Date/Time:
     o                       	
    
    '-a
    
    
     o_
     Q_
          A8-4                          Wastewater Response Protocol Toolbox
    

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    9      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 sited that is characterized.
    
    General Information
         Date: 	      Time arrived at investigation site: 	
         Name of Site Characterization Team Leader: 	
         Phone: 	       Fax:
    
    
    Location of Investigation Site
         Site Name: 	
        Type of facility:
           D Manhole                    D Treatment plant           D Pump station
           D Catch basin                  D Collection main            D Building drain
           n Other:	
        Address:	
        Weather conditions at site:
        Additional Site Information:
    Approach to Site
        Time of approach to site:
         Initial Field Safety Screening (as listed in the "Site Characterization Plan"):                                    ^
           n None                        n Radiation                  n Volatile chemicals
           D HazCat                       D Chemical Weapons          Q Biological agents
           D Other:	   C
                                                                                                           CD
         Report results of field safety screening in Appendix 10 "Field Testing Results Form."
                                                                                                           Q_
         If any field safety screening result is above the corresponding reference value, immediately notify incident      ^
    
         command and do not proceed further into the site.
                               Wastewater Response Protocol Toolbox                         A9-1
    

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                   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 10 "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.
                   Signs of Hazard:
                       d  None                                    d  Unexplained dead animals
                       d  Unexplained dead or stressed vegetation     d  Unexplained clouds or vapors
    CO
                       d  Unexplained liquids                        d  Other:	
    O
                   Describe signs of hazard:
    Q_
    Q_
         A9-2                          Wastewater Response Protocol Toolbox
    

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    Unexplained or Unusual Odors:
    D
    D
    D
    None d Pungent
    Sulfur d Skunky
    Petroleum D Other:
    D Irritating
    D Bitter almond
    
    Describe unusual odor:
    
    
    
    
    Unusual Vehicles Found at the Site:
       d  Car/sedan                D  SUV                     D  Pickup truck
       d  Flatbed truck             D  Construction vehicle      D  None
       D  Other:	
      Describe vehicle(s) (include make/model/year/color, license plate #, and logos or markings):
    
    
    Signs of Tampering:
       d  None                                      d  Cut locks/fences
       d  Open/damaged gates, doors, or windows      d  Open manholes
       d  Missing/damaged equipment                 d  Facility in disarray
       d  Other:	
    Signs of sequential intrusion (e.g., locks removed from a gate and hatch)?     d Yes         d No
      Describe signs of tampering:	
    Unusual Equipment:
       d  None                                 d  Discarded PPE (e.g., gloves, masks)
       d  Tools (e.g., wrenches, bolt cutters)       d  Hardware (e.g., valves, pipes)
       d  Lab equipment (e.g., beakers, tubing)     d  Pumping equipment
       d  Other:	
       Describe equipment:	
     U
    '-a
     Q_
    <
                         Wastewater Response Protocol Toolbox                        A9-3
    

    -------
    Q_
    Q_
               Unusual Containers:
                  Type of container:
                     D None
                     n Plastic bag
                     n Test tube
                     D Other:	
                  Condition of container:
                     n Opened
                     D Unopened
                  Size of container: 	
            D Drum/barrel
            n Box/bin
            n Bulk container
    D Bottle/jar
    n Pressurized cylinder
            n New
            D Old
    n Damaged/leaking
    D Intact/dry
                  Describe labeling on container:
                  Describe visible contents of container:
    
               Rapid Field Testing of Wastewater
                     D None
                     D Cyanide
                     D Pesticides
                     D Other:
            D Residual disinfectant
            D Radiation
            D Biotoxins
    D pH/conductivity
    D VOCs and SVOCs
    D General toxicity
               Report results of rapid field testing in Appendix 10 "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
         A9-4
    Wastewater Response Protocol Toolbox
    

    -------
    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
         // the site is characterized as a chemical, radiological, or biological hazard, then special sampling
         and safety procedures should be followed.
         Safety Checklist:
           D Do not eat, drink, or smoke at the site.
           D Do not taste or smell the wastewater samples.
           D Follow all steps/procedures in HASP.
           D Do use the general PPE included in the emergency wastewater sampling kit.
           D Avoid all contact with the wastewater, 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 as specified.
           D Carefully close sample containers and verify that  they do not leak.
           D Wipe the outside of sample containers with a mild bleach solution if there was any spillage.
           D Place sample containers into a sealable plastic bag.
                                                                                                         CO
           D Place samples into an appropriate, rigid shipping  container.                                       QJ
                                                                                                         U
           D Pack container with frozen ice packs, as appropriate.
           D Complete "Sample Documentation Form"  (Appendix 11)
           D Complete "Chain of Custody Form" (Appendix 12)
                                                                                                         <<
           D Secure shipping container with custody tape.
           d Comply with any other sample security provisions required by participating agencies.
                              Wastewater Response Protocol Toolbox                         A9-5
    

    -------
          Exiting the Site
              Time of Site Exit:
    
    Q_
    Q_
              Site Exit Checklist:
                 n 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.
                 n 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.
                 n Contact Incident Commander (1C)  and inform the 1C that the team is leaving the site
               Signoff
    
               Site Characterization Team Leader:
                    Print Name: 	
    
                    Signature: 	        Date/Time:
         A9-6                          Wastewater Response Protocol Toolbox
    

    -------
       10   Field Testing Results Form
    
    
    
    
    
    
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    A10
    Wastewater Response Protocol Toolbox
    

    -------
           11   Sample Documentation Form
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        A11
    Wastewater Response Protocol Toolbox
    

    -------
    12   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
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
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    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 Date/time:
    by:
    Method of Sample Transport:
    Shipper: Phone No.: Tracking No.:
                                                                               o
                                                                               Q_
                                                                               Q_
                       Wastewater Response Protocol Toolbox
    A12
    

    -------
              13    Contaminant Characterization and Transport Worksheet
    
    
              INSTRUCTIONS
              The purpose of this worksheet is to help organize information that will lead to the identification of the
              contaminant to facilitate decisions on appropriate operational responses and provide more accurate
              information for public communication/notification. Contaminant identification will most likely first be a
              presumptive identification followed by more lengthy procedures for verification. While validated analytical
              results are typically the most reliable means of contaminant identification, other information collected
              during the threat evaluation and site characterization may provide valuable insight regarding the identity of
              the contaminant.
    
              Site Characterization/Threat Evaluation Summary
              Describe the contaminant's odor,  if applicable. (Note: For safety reasons, it is recommended that you not
              intentionally smell samples.)
              What was the physical form of the contaminant?
                     D  Solid                        D  Liquid                     D Gas
                     D  Slurry                       D  Powder                   D Granules
                     D  Other:	
              What color was the contaminant?
              Summarize additional information obtained during site characterization/threat warning that is relevant
              to contaminant identification.
              Summarize the on-line monitoring data, public complaints, or witness accounts that are relevant to
              contaminant identification.
              Describe any other characteristics of the contaminant not mentioned above.
    to
              Field Analysis Summary
              Summarize the results of the field analysis for the following parameters:
              Radiation: _
              Chlorine residual: _
              pH conductivity: _
              Cyanide:
              Volatile chemicals:
              Chemical weapons:.
              Biotoxins:
              Pathogens_
              Other:	
         A13-1                         Wastewater Response Protocol Toolbox
    

    -------
    Has death or disease in the population been reported?
    Type/symptoms:	
                                     DYes
                           D No   D Unknown
    Is there information on unusual sales of pharmaceutical supplies? .
    Number of people affected: 	
    Number of fatalities: 	
    Location/area affected:
    Was an epidemiological investigation conducted?
    Results:
                                   DYes
                           D No   D Unknown
    Was a clinical investigation conducted?
    Results: 	
                                   DYes
                           D No   D Unknown
    Is the contaminant acutely toxic and what are the acute effects? DYes
    Describe: 	
                                                DNo    D Unknown
    Laboratory Analysis Summary
    Unusual analytical results:	
    Reporting units:	
    Analytical method:
    Minimum reporting level:
    Precision (relative standard deviation):
    QA/QC (e.g., recovery of matrix spikes, standard checks, etc.):
    Summarize additional information obtained during laboratory analysis that is relevant to
    contaminant identification.
    Contaminant Characteristics
    What is the class of the contaminant?
     D Biological
     D Unknown:
    D Chemical
    D Radiological
    
                                                                                Q_
                                                                                Q_
                             Wastewater Response Protocol Toolbox
                                                                       A13-2
    

    -------
             Can any conclusions regarding the contaminant properties be made? (Place di
             column)
                                                  ji idtt
    
    
    Is the contaminant susceptible to
    disinfection or chemical oxidation?
    Does the contaminant hydrolyze
    into less toxic products?
    Does the contaminant hydrolyze
    into more toxic products?
    Does the contaminant react at
    certain pH's?
    Is the contaminant water soluble?
    Does the contaminant have a
    discernable odor or color? (Note:
    For safety reasons you should not
    intentionally smell samples.)
    Is the contaminant volatile or semi-
    volatile?
    Does the contaminant impact the
    pH?
    Does the contaminant impact
    conductivity?
    Does the contaminant impact other
    wastewater chemical parameters?
    Does the contaminant react with
    certain disinfectants (i.e., chlorine,
    chloramines, etc.)?
    What is the contaminant's half-life?
    Yes
    
    
    
    
    
    
    
    
    
    
    
    
    No
    
    
    
    
    
    
    
    
    
    
    
    
    Unknown
    
    
    
    
    
    
    
    
    
    
    
    
    Comment/Additional Information
    
    
    
    
    
    
    
    
    
    
    
    
             Contaminant Public Health Effect Information
             What are the primary routes of exposure?
             D Inhalation           D Dermal contact         D Ingestion
             What are the acute health effects for the exposure routes identified?
                                                D Unknown
    Q_
    Q_
             What is the contaminant's LD50/ID50 for these routes of exposure?
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    What is the length of time to first onset of symptoms after exposure?
    What are the chronic health effects associated with exposure to the contaminant?
    Does the contaminant have the potential for secondary transmission?
    D Yes                          D No                          D Unknown
    Describe: 	
    Is an approach available to prevent undesirable health effects from the contaminant?
    D Yes                          D No                           D Unknown
    Describe: 	
    Are there treatments available for individuals exposed to the contaminant?
    D Yes                          D No                          D Unknown
    Describe: 	
    Are health standards for the contaminant available?
    D Yes                          D No                           D Unknown
    Describe: 	
    By which exposure routes?
    D Dermal                D Inhalation              D Ocular                D Ingestion
    List the levels for each exposure route.
    Access to Contaminant Information (Effects and Properties)
                                                                                                              U
    In-house Information
    Contact/ phone no.:	
    Internal database:
                                                                                                              Q_
                       	     Q_
    Public Health Officials
    Contact/phone no.:_
    Website/database:
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              Resources
                  D  US EPA Water contaminant information tool (WCIT), at http://www.epa.gov/wcit.
                  D  US EPA Water Health and Economic Analysis Tool (WHEAT), at
                     http://water.epa.gov/infrastructure/watersecurity/techtools/wheat.cfm
                  D  US EPA's List of Drinking Water Contaminants & MCLs:
                     http://www.epa.gov/safewater/mcl.htmltfmcls.
                  D  Agency for Toxic Substances and Disease Registry (ATSDR): www.atsdr.cdc.gov.
                  D  CDC Emergency Preparedness and Response: www.bt.cdc.gov.
                  D  Recognizing Waterborne Disease and the Health Effects of Water Pollution: A Physician On-line
                     Reference Guide: www.waterhealthconnection.org.
                  D  Physician Preparedness for Acts of Water Terrorism:
                     www.waterhealthconnection.org/bt/index.asp.
                  D  Registry of Toxic Effects of Chemical Substances (RTECS): www.cdc.gov/niosh/rtecs.html.
                  D  Risk Assessment Information System (RAIS), which contains information taken from US EPA's
                     Integrated Risk Information System (IRIS), the Health Effects Assessment Summary Tables
                     (HEAST-rad HEAST-nonrad), US EPA Peer Reviewed Toxicity Values (PRTVs) Database, and other
                     information sources: http://www.epa.gov/risk assessment/.
                  D  United States Army Medical Research Institute of Infectious Diseases (USAMRIID) Medical
                     Management of Biological Casualties Handbook:
                     http://www.usamriid.army.mil/education/bluebook.html.
                  D  WHO: www.who.int/search/en/.
                  D  WHO's Public Health Response to Biological and Chemical Weapons (2004):
                     www.who.int/csr/delibepidemics/biochemguide/en/index.html.
    
    
              Contaminant Transport
              Summarize what is known regarding the location of contaminant introduction:
    to
    0        How much material was used:	[Ibs, tons, gals, etc.)
              How was it added?            D Single dose         D Overtime     D   Unknown
              Time period of suspected contaminant introduction:  	
              Elapsed time: 	
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    Method of estimating the spread:
    D Manual calculations            D Hydraulic model    D Water flow analysis
    D GIS                           D Field analysis       D Areas of public complaints
    D Areas of people with health-related symptoms
    D Other: 	
    Estimate the contaminated area: 	
    Estimate the population affected:	
    Identify any customers with special needs that are within the affected area.
    fj Critical Care Facilities
        D Hospitals                                    D Clinics
        D Nursing Homes                               D Dialysis Centers
        D  Other: 	
    D Schools
    D Day Care Facilities
    D Businesses
        D Food and Beverage Manufacturers             D Commercial Ice Manufacturers
        D Restaurants                                  D Agricultural Operations
        D Power Generation Facilities
        D Other:
    Signoff                                                                                           ^
                                                                                                       CD
    Name of person completing form:	
                                                                                                      ~O
    Print name:	
                                                                                                       Q_
    Signature:	       Date/Time: 	          ~r
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                14     Public Health Response Action Worksheet
    
                INSTRUCTIONS
                The purpose of this form is to help organize information to aid in the evaluation of containment and public
                notification options. The objectives of public health response actions (operational and public notification) are to
                prevent or limit public exposure to potentially contaminated wastewater by either restricting further transport of the
                contaminant through the wastewater system or restricting use of the system through public notification. This
                worksheet assumes that the "Contaminant Characterization and Transport Worksheet" in Appendix 13 has been
                completed to the extent possible.
    
                Assessment of Public Health Impact
                 Identity of the contaminant:          D Suspected         D  Known            D Unknown
                 Describe:	
                 Contaminant properties (if  known):
                       Route of exposure:
                       D Dermal       D  Inhalation      D  Ingestion     D  Other:	
                       Toxic or infectious dose (LD5o/ID5o) by these routes of exposure:	
                       Symptoms of exposure to high dose:	
                       Symptoms of exposure to low dose:	
                       Other:
                Evaluation of Containment Options
                 Describe the location and extent of the contaminated area: _
                 Containment options:
                 D Valve closures               D Reverse flow conditions       D By-pass
                 D Isolate zone(s)
                 D Other: 	
                 Critical equipment within contaminated area:
                 d System equipment            d Zones                     d Pump stations
                 D Other:	
                 Customers with special needs within contaminated area:
                 d Critical Care Facilities
                    D Hospitals                                D Clinics
                    D Nursing Homes                           D Dialysis Centers
                    D Other: _
    t^          D Schools
                 D Day Care Facilities
                 D Businesses
                    D Food and Beverage Manufacturers             D Commercial Ice Manufacturers
                    D Restaurants                              D Agricultural Operations
                    D Power Generation Facilities
                       other:
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    Effectiveness of containment options:
    D Complete contaminant isolation
    D Unknown
    D Other:
                    D Reduction in spread of contaminant
    Is containment expected to provide adequate public health protection?
           D Yes         D No         D Unknown
    Timeline for implementation of containment options:
    Containment procedures to begin:	
    Containment procedures to end:	
    Evaluation of Public Notification Options
    Is public notification necessary and/or required by any applicable laws or regulations?    D Yes  D No
    Collaboration Agencies   (identified in Public Health Response Plan and Utility's ERP)
     D Public health agencies
     D Hospitals/clinics
     D Regional Poison Control Center
     D Other:	
     D Police departments
     D Laboratories
    D Fire departments
    D Wastewater permitting agency
    Type of notification (follow steps shown):
       - Is the contaminant known?                       D Yes    D No
       - Is there a risk of explosion?                       D Yes    D No
                                           If "Yes," consider an evacuation notice.
          Is there a risk of dermal or inhalation exposure?   D Yes    D No       D Unknown
                                                   If "Yes" or "Unknown," consider an evacuation notice.
    Content of Public Notification
    D Has the contamination event been confirmed?
    D Is the contaminant known?
    D If "Yes," identity of the contaminant:	
    D Characteristics of the contaminant:	
    D Restrictions on use:	
    D Inhalation exposure
    D Exposure symptoms:	
    D Medical treatments:	
                     D Yes    D No
                     D Yes    D No
    D Dermal exposure
                                                                         U
                                                                         '-a
                                                                         Q_
                                                                         Q_
    D Transmission mode (if biological):
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                 Duration of restriction:
              D Alternate sanitary services:
              D Additional instructions to consumers: _
              D Other information about the incident:
              HI Other:
              Notification to customers with special needs:
              D Critical Care Facilities
                  D Hospitals
                  D Nursing Homes
                  D Other:	
              D Schools
              D Day Care Facilities
              D Businesses
                  D Food and Beverage Manufacturers
                  D Restaurants
                  D Power Generation Facilities
                  D Other:	
                                       D Clinics
                                       D Dialysis Centers
                                       D Commercial Ice Manufacturers
                                       D Agricultural Operations
              Are there subpopulations that will be affected at a greater rate than general population?
              D Yes                D No             D Unknown
              Describe:	
    
    Q_
    Q_
              Notification to consecutive system:
              D Yes                D No             D Not Applicable
              Method of dissemination (check all that apply):
    D     Broadcast media (radio and television)
    n     Web site
    D     Newspaper
    n     Newsletters (wastewater utility/partner)
    D     Broadcast phone messages
    n     Posting in conspicuous locations
    D     Hand delivery
    n     Town hall meetings
    n     Auto dialer system
    D     Other
                                D
                                D
                                D
                                D
                                D
                                D
                                D
                                D
                                D
    Government access channels
    Listserve email
    Letters by mail
    Phone banks
    Broadcast faxes
    Mass distribution through partners
    Door-to-door canvassing
    Conference calls
    Reverse 911
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    Notification/restriction timeline:
    Notification/restriction to begin:
    Notification/restriction to end:	
    Alternate Sanitation Services
    Are alternate sanitation services needed?             D Yes        D No
    Where can customers obtain the alternate sanitary services (e.g., locations for portable toilets)?
    Which customers with special needs should be notified of the alternate sanitary services?
    D Critical Care Facilities
        D Hospitals                                              D Clinics
        QNursing Homes                                         D Dialysis Centers
        D  Other:	
    D Schools
    D Day Care Facilities
    D Businesses
        D Food and Beverage Manufacturers                        D Commercial Ice Manufacturers
        D Restaurants                                            D Agricultural Operations
        D Power Generation Facilities
        D Other:
    Signoff                                                                                                       ^
                                                                                                                   CD
    Name of person completing form:	
                                                                                                                  ^
    Print name: 	
                                                                                                                   CD
    Signature:	      Date/Time: 	                      Q-
                                                                                                                   Q_
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              15   Suggested Outline for System Characterization/Feasibility Study
                    Work Plan
              I.  Executive Summary
              II. Introduction
              III. System Description and Environmental Setting
              IV. Initial Evaluation and Results of Site Characterization
                 A. Contaminants present, volume of wastewater and media affected
                 B. Potential pathways of contaminant migration/preliminary assessment of public health and
                    environmental impacts
                 C. Preliminary identification of candidate response objectives and remedial response action
                    alternatives
              V. Work Plan Rationale
                 A. Data quality objectives
                 B. Work plan approach
              VI. Tasks
                 A. Project Planning
                 B. Community Relations/Public Communication
                 C. Field Investigations
                 D. Sample Analysis/Validation
                 E. Data Evaluation
                 F. Risk Assessment
                 G. Evaluation of Remedial Alternatives
                 H. Treatability Studies
                 I.  Reports
     CJ
    • —        VII. Costs and Key Assumptions
              VIII. Schedule
              IX. Project Management
                 A. Staffing
                 B. Coordination
              X. References
              XI. Appendices
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    16   Elements for a Quality Assurance Project Plan
    I.  Project Management
       A. Title and Approval Sheet
       B. Table of Contents
       C. Distribution List
       D. Project/Task Organization
       E. Problem Definition and Background
       F. Project/Task Description
       G. Quality Objectives and Criteria
       H.  Special Training/Certifications
       I.  Documentation and Records
    II. Data Generation and Acquisition
       A. Sampling Process Design (Experimental Design)
       B. Sampling Methods
       C. Sample Handling and Custody
       D. Analytical Methods
       E. Quality Control
       F. Instrument/Equipment Testing
       G. Inspection and Maintenance
       H. Instrument/Equipment Calibration and Frequency
       I.  Inspection/Acceptance of Supplies and Consumables
       J.  Non-direct Measurements
       K. Data Management
                                                                                            ~O
    III. Assessment and Oversight
       A. Assessments and Response Actions
       B. Reports to Management
    IV. Data Validation and Usability
       A.     Data   Review,   Verification,   and
       Validation
       B. Verification and Validation Methods
       C. Reconciliation with User Requirements
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    Q_
    Q_
                17    Elements of a Health and Safety Plan
                I.  The name of a site health and safety officer and the names of key personnel and alternates
                   responsible for site safety and health
                II. Health and safety risk analysis for existing site conditions, and for each site task and operation
                III. Employee training assignments
                IV. Description of personal protective equipment to be used by employees for each of the site
                   tasks and operations being conducted
                V. Medical surveillance requirements
                VI. Description of the frequency and types of air monitoring, personnel monitoring, and
                   environmental sampling techniques and instrumentation to be used
                VII. Site control measures
                VIII. Decontamination procedures
                IX. Standard operating procedures for the site
                X. Contingency plan that meets the requirements of 29 CFR 1910.120(1) (1) and (I) (2)
                XI. Entry procedures for confined spaces
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