&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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Site Characterization
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Public Health
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Sample Analysis
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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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