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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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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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
2-22
Wastewater Response Protocol Toolbox
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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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2-23
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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.
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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 )
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Threat Warning
Initial Threat Evaluation
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Immediate Operational
Response Actions
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Site Characterization
and Sampling
Public Health
Response Actions
Sample Analysis
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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
Wastewater Response Protocol Toolbox
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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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3-3
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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
Wastewater Response Protocol Toolbox
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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
3-8
Wastewater Response Protocol Toolbox
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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
25 ml
25 ml
25 ml
50 strips
For sample dilution in the field
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
1 container
1 gallon
2
1
3
One per individual (minimum)
Nitrile or polyethylene, powder-free
One pair per individual (minimum)
One per individual (minimum)
For disposal of lab coat, gloves, etc.
For general use and first aid
For cleaning hands, sample containers, etc.
For decontamination if necessary
For use with rinse water or lab grade water
For general first aid
For working at night or in dark locations
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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
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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.
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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
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Threat Warning
Initial Threat Evaluation
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Public Health
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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.
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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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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
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•-.^ radioactivity? ,-''
Preform laboratory
screening analysis for
alpha, beta and gamma
radiation
Screening results ''T
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radionuclides not
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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
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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
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3.6 Remedial Design [[[ 6-5
3.7 Remedial Action [[[ 6-5
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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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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
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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
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affected
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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
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Response
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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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Date and time of contamination: -~~
Additional information:
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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:
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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:
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Summary of key information from external sources (provide detail in attachments as necessary):
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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
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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:
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Additional Site Information:
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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
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Are there sequential alarms (e.g., alarm on a gate and a hatch)? D Yes D No QJ
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Date and time of alarm(s):
Describe alarm(s):
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Is video surveillance available for the site of the security incident? Yes No
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// Yes, provide additional detail below
Date and time of video surveillance:
Describe surveillance:
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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_
Wastewater Response Protocol Toolbox
A4-3
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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:
Wastewater Response Protocol Toolbox A5-1
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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_
Wastewater Response Protocol Toolbox
A6-2
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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
Wastewater Response Protocol Toolbox A7-1
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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_
Wastewater Response Protocol Toolbox
A8-3
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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_
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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
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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
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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
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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
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10 Field Testing Results Form
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11 Sample Documentation Form
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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
Analysis
Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Received by: Date/time:
Dispatched by: Date/time: Received for Laboratory Date/time:
by:
Method of Sample Transport:
Shipper: Phone No.: Tracking No.:
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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.
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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:
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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
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Can any conclusions regarding the contaminant properties be made? (Place di
column)
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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
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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)
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In-house Information
Contact/ phone no.:
Internal database:
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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:
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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:
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Name of person completing form:
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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
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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:
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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:
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Name of person completing form:
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Print name:
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Signature: Date/Time: 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
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• — 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
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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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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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