&EPA
  United States
  Environmental Protection
  Agency
Wastewater Response Protocol
Toolbox:
Planning For and Responding To
Wastewater Contamination
Threats and Incidents
December 2011
Module 2:
Contamination Threat Management Guide

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                         Table of Contents - Module 2

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

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             Public Health

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                                    Remediation and Recovery
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1 Introduction

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

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

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

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

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

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

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

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

2.1 Roles and Responsibilities

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

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

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

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

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

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

2.2 Response and Consequence

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

Criteria for Response Decisions

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

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

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

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

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

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

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

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

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

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

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

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

3.1 Information from the Threat Warning

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

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

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

          Security Breach

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

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

                                 Direct Notification by Perpetrator

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

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

Notification by News Media

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

Unusual Wastewater Chemical
Characteristics

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

Degradation of Treatment Organisms

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

Public Complaints

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

Notification by Public Health Agencies

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

3.2 Additional Information

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

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

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

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

Site Characterization

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

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

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

Immediate Operational Responses

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

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

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

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

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

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

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

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

Previous Threats and Incidents

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

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

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

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

4.2 Response Actions Considered at
    the 'Credible' Stage

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

Sample Analysis

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

Continuation of Site Characterization
Activities

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

Law Enforcement Notification

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

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

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

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

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

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

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

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

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

Analytical Results

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

Additional Site Characterization Results

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

Information from External Sources

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

5.2 Response Actions Considered at
    the 'Confirmed' Stage

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

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

6 Contamination Threat
   Management Matrices

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

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

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





Information











Evaluation










Notifications







Response





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

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






• Notifications within
utility
Local law enforcement
agencies





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



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

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




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



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






Information












Evaluation










Notifications









Response








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







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






• Notifications within utility
Local law enforcement







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





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



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





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



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









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6.3   Direct Notification by Perpetrator

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






Information












Evaluation










Notifications










Response








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





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


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





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






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


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




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



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










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





Information











Evaluation










Notifications










Response









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




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




• Notifications within utility
• Wastewater permitting
agency






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







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




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


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



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











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6.5   Notification by News Media

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






Information












Evaluation










Notifications










Response








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







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




Notifications within utility
• Local law enforcement
Wastewater permitting
agency





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







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




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




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



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










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




Infomistion














Evaluation













Notifications










Response








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









• Notifications within utility








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







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


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

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

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









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










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6.7   Degradation of Treatment Organisms

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




Information









Evalustion










Notifications








Response






Extent of degradation
Time of degradation
• Additional signs of
contamination





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





• Notifications within
utility







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




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

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

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






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





Information












Evaluation











Notifications










Response











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







• Nolilicalions within utility








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









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





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

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



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






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













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6.9   Public Health Notification

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




Information











Evaluation











Notifications








Response




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


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




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




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




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

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




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



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


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                       Wastewater Response Protocol Toolbox
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.
 CS
 i_
          8 Appendices

          The following are examples of forms that may
          be used to facilitate the public health response:
 CD
            • Response Planning Matrix
            • Threat Evaluation Worksheet
 CD
            • 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.
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