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

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                        Table of Contents - Module 3

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

                                             O
                                        Threat Warning
                                    Initial Threat Evaluation
(A

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

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1 Introduction

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

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



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

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

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

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

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

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

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

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

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

Following rapid field testing of the wastewater,
samples of the suspect wastewater should be
collected for potential laboratory analysis.
The purpose of sampling from a suspected
contamination site is to obtain and preserve a
sample of the wastewater at a particular time
and location so that it can be analyzed later
if necessary. The decision to send samples to
a laboratory for analysis should be based on
the outcome of the threat evaluation. If the
threat is determined  to be 'Credible,' then
samples should be immediately delivered to a
laboratory for analysis. On the other hand, if
the threat is determined to be 'Not Credible,'
then samples should be secured and stored
for a predetermined  period in the event that it
becomes necessary to analyze the samples at a
later time.

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

   • Which contaminants or contaminant
    classes will be analyzed for?
   • What type of samples will be collected
    (i.e., grab or composite)?
   • When and where will samples be
    collected?
   • Are any special  precautions necessary
    during sample collection?

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

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

EPA has recently published additional guidance
on sample collection entitled Sampling
Guidance for Unknown Contaminants
in Drinking Water (EPA-817-R-08-003,
November 2008) (see www.epa.gov/
watersecurity; search under Water Laboratory
Alliance). While this document is intended
for drinking water applications, it may also be
useful for wastewater sampling.
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          Table 3-1 presents an example of a sample collection kit, while Table 3-2 provides a detailed

          listing of the sample containers included in the kit. The sample collection kit described in this

          section is intended to illustrate the types of materials and supplies that might be useful during

          sampling activities. However, the design of a specific kit should be tailored to the needs and

          sampling objectives of the user.
Table 3-1: Example Design of an Emergency Wastewater Sample Collection Kit
Item Quantity Notes
Field Resources and Documentation
Field Guide
Health and safety plan
Sample labels
Sample documentation forms
Custody tape (or seals)
Chain of custody forms
Lab marker
2
2
48
24
2 rolls
24
2
Resource for field personnel
If required for the site
Waterproof (filled out in advance, if possible)
For recording sample information
Used on sample or shipping containers
For documenting sample custody
Waterproof, 1 red, 1 black
General Sampling Supplies
Sample containers
Device for grab sampling
10 liter HOPE container
Lab grade tape
Miscellaneous glassware
Collapsible cooler
Rigid shipping container
Table 3-2
1
4
3 rolls
N/A
1
1
For collecting samples
For sampling large water bodies
For collection of large volume water samples
For temporary labeling in the field
Beakers, graduated cylinders, spatula, etc.
For sample storage
For shipping by overnight service if needed
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Table 3-1 (cont.): Example Design of an Emergency Wastewater Sample Collection Kit
Item Quantity Notes
1 qt. zippered freezer bags
Thermometer
Paper towels
1 pack 100
2
2 rolls
For double bagging ice and sample
containers
For checking water temperature
Wiping wet containers and containing spills
Reagents (may need to be kept separate from the rest of the kit)
Laboratory grade water
6 Molar ACS grade hydrochloric acid (HCI)
6 Molar trace metal-grade nitric acid (HNO3)
10 Normal sodium hydroxide (NaOH)
pH paper in ranges from 0-4 and 10-14
5 liters
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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  If the threat is determined to be 'Credible,' then samples should be
           immediately delivered to a laboratory for analysis.
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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).
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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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