c/EPA
Wastewater Response Protocol
  United States      T       _
  Environmental Protection  | \J\J | LJ(jX .
  Agency
             Planning For and Responding To
             Wastewater Contamination
             Threats and Incidents
             December 2011
             Module 6:
             Remediation and Recovery Guide

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                         Table of Contents - Module 6

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

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

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1 Introduction
This module presents guidance on the
remediation and recovery process that should
be applied when a wastewater contamination
incident has been confirmed. The target
audience for this module includes:

    Individuals who will be involved in
     characterization, risk assessment, and
     remedial response activities following a
     confirmed contamination  incident.

    Lead agency personnel and decision
     makers who will determine the need for
     long-term alternate sanitary services,
     select remedial technologies, determine
     when to return to normal  operations, and
     communicate with the public.

These individuals will probably include utility
personnel, regulators, public health officials,
and technical assistance providers.

The purpose of the remediation and recovery
process is to address extensive contamination
at levels that pose immediate and/or long-term
risks to human health and the environment.
The overall objective is to reduce or eliminate
the contaminant and return the wastewater
system to service as quickly as possible while
protecting public health and the environment
and minimizing disruption to normal life. The
remediation and recovery process is applicable
for decontamination of the contaminated
wastewater prior to safe disposal, as well as
to remediation of the wastewater collection
system, the treatment plant, and associated
facilities such as lift stations. While rapid
recovery of the system may be critical, it is
important to follow a systematic process that
is consistent with any applicable laws and
regulations, and establishes remedial goals
acceptable to all stakeholders, implements
the remedial process in an effective and
responsible manner, and demonstrates that the
remedial action was successful. This  module
describes some elements of such a systematic
process.
If it is determined that chemical, biological, or
radiochemical contaminants have entered the
public wastewater system it may be necessary
to protect utility employees from exposure
until the scope of the problem is defined
and remediation has been completed. These
actions may even need to take place prior to
the completion of the characterization process.
Some specific steps that might be taken to
protect employees in the interim include:

    Prevent personnel from entering manholes
    Prevent personnel from entering wet wells
    of pump  stations
    Suspend manual cleaning of bar screens
    and removal of grit
    Restrict access to trickling filters, aeration
    basins, and other treatment plant sites
    where aerosols might be generated
    Suspend manual handling of biosolids
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2 Roles and Responsibilities
  During Remediation and
  Recovery

The remediation and recovery process should
be implemented when a contamination
incident has been confirmed. For a 'Confirmed'
incident, an agency external to the utility may
assume the responsibility for coordinating
the response under the Incident Command
System (ICS). Whether a local, state, or federal
government exercises primary authority may
depend on the nature and size of the incident
and the resources needed for remediation
and recovery. State and local governments
have primary responsibility for consequence
management, including remediation and
recovery efforts. If the magnitude of the
remediation and recovery efforts exceeds
the capabilities and resources of state and
local government, and if federal interests are
involved, then the federal government may be
required to provide assistance.

3 Steps in Remediation and
  Recovery Process

It should be noted that the remediation and
recovery approach outlined in this module
is modeled, in part, on the EPA Superfund
remedial response program. There are nine
steps in the remediation and recovery program.
Each is described below.
3.1 Long-Term Alternate Sanitary
   Services

During the remedial process, long-term
alternate sanitary services may need to be
secured. The specific services required will
depend on the extent of contamination but
could include long-term alternate wastewater
collection, treatment, and disposal. Long-term
alternate services may be different from the
short-term services described in Module 5.
The need for long-term alternative services
will depend on the nature and severity of
the contamination event and the length of
time required to return the system to normal
operation. If utility  and local authorities do
not have the resources to provide long-term
alternate sanitation, assistance may be required
from mutual aid and assistance agreements
with other wastewater utilities (such as
WARNs), the state, or the federal government.
Alternative  services may include:

    Portable toilets
    Collection points for removal and disposal
    of 'gray water' (i.e., wash water that does
    not contain sanitary waste)
    Contracts with  hauling companies to assist
    in transferring unaffected wastewater

3.2 System Characterization/Feasibility
   Study

After a contamination incident has been
confirmed, additional information will be
required to support remediation/recovery
actions. This information and data can be
obtained via a System Characterization/
Feasibility Study. The study will provide a
detailed assessment of the nature and  extent
of contamination and preliminarily screen
candidate treatment options. Several planning
documents may be helpful for the system
characterization.
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System Characterization/Feasibility Study
Work Plan

The System Characterization/Feasibility
Study Work Plan documents information
collected and decisions made during the
systematic planning process, and describes
anticipated future tasks. It also serves as
a tool for assigning responsibilities and
setting the project's schedule and cost.
Appendix 15 provides a suggested outline
for the System Characterization/Feasibility
Study Work Plan.

Quality Assurance Project Plan

This is a critical planning document for
data collection for system characterization
because it documents all project activities
including Quality Assurance (QA) and
Quality Control (QC) procedures. See
Appendix 16 for a listing of the elements of
a Quality Assurance Project Plan.

Health and Safety Plan (HASP)

The HASP includes information regarding
personnel roles, lines of authority
and communication, site security and
control, and medical and emergency alert
procedures. The HASP should be developed
for the specifics of the incident so that staff
is aware of the common routes of exposure
at a site and is trained in the proper use of
safety equipment and protective clothing
and equipment. Safe areas should be
designated for washing, drinking, and
eating. A suggested format for a HASP is
given in Appendix 17.

3.3 Risk Assessment

Upon confirmation of a contamination
incident, the lead agency for consequence
management will quickly assess the risk posed
to on-site workers and the public. This rapid
risk assessment will help guide response
actions.

During the remedial response phase, additional
risk assessments may be required to:

   Evaluate risk reduction achieved by
    the operational response actions being
    conducted at that time
   Aid in establishing preliminary
    remediation goals
   Assess potential risk reduction from
    implementation of long-term remedial
    actions

3.4 Detailed Analysis of Alternatives for
   Remediation

This step involves the evaluation of various
remediation approaches available on the
basis of their effectiveness and technical
feasibility. In situations in which human
health and environmental risks are reduced to
acceptable levels through natural attenuation
or degradation of the contaminant, no remedial
actions may be required.

If remedial actions are required,  they may
include any of the following steps, or
combination of steps:
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    Containment of contaminated wastewater
    Treatment of contaminated wastewater
    Disposal of contaminated wastewater
    Rehabilitation of contaminated wastewater
    system components
    Restoration of the biological treatment
    process

Restoration of biological treatment may require
importing and  introducing organisms from
other processes within the plant (if unaffected)
or from other nearby treatment plants. Full
recovery of the biological community could
take weeks or months.

Possible technologies for cleanup of
contaminated wastewater include, but are not
limited to, the  following, which can  be used
alone or in combination:

    Chlorination
    Air stripping
    Granular activated carbon filtration
    Ultraviolet irradiation
    Ozonation

For the management of radioactive materials
entering POTWs that may impact wastewater/
stormwater management, guidance is provided
by the  Interagency Steering Committee on
Radiation Standards in the document ISCORS
Assessment of Radioactivity in Sewage
Sludge: Recommendations on Management
of Radioactive Materials in Sewage  Sludge
and Ash at Publicly Owned Treatment Works
(February 2005 - ISCORS Technical Report
2004-04; EPA  832-R-03-002B; DOE/EH-
668) that is available on the ISCORS website
under LIBRARY at http://www.iscors.org/pdf/
FinalRecommendations.pdf

Additionally, various  contaminated
components of the wastewater system may
need to be rehabilitated. These include the
infrastructure, such as system mains and
pumps, as well as the equipment used to
treat the wastewater at the plant. Possible
technologies and alternatives that can
be considered for the rehabilitation of
contaminated system components include:
    Disinfection
    System flushing
    Pigging and swabbing of system piping
    Air scouring
    Sand blasting
    Relining pipes
    Condemning portions of the collection
    and/or treatment system (e.g., in response
    to gross contamination such as from a
    radiological agent)
    Utilization of the current treatment plant
    with a new collection system
    Utilization of the current wastewater
    collection system with a new treatment
    plant

Remediation can be performed in stages with
emergency short-term remediation being
conducted to reduce dangerous levels of a
contaminant to a safer level. This can then be
followed by long-term, more comprehensive
cleanup  steps to remove any remaining low
levels of the contaminant(s). When assessing
remediation alternatives, the utility will need to
take into consideration any applicable laws and
regulations.

To learn more about available federal funding
for remediation/recovery from disasters
see http://water, epa.gov/infrastructure/
watersecurity.
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3.5 Remediation Technology Selection

To select the remediation technology, a
comparative analysis may be performed to
identify the advantages and disadvantages of
each technology. The criteria for technology
selection include, among others:

   Protection of human health
   Protection of the environment
   Compliance with applicable laws and
    regulations (e.g., the Clean Water Act)
   Feasibility of implementation
   Cost

3.6 Remedial  Design

After a final remedy is selected, remedial
design is the next step. This is an engineering
phase involving preparation of a series of
documents, specifications, and drawings that
detail the specific steps to be taken during
the remedial action. The lead agency will be
responsible for remedial design, assisted by
the wastewater utility (if not already the lead
agency) and other technical support staff.
Remediation should be designed to prevent
impacts on the remaining unaffected portions
of the wastewater system.

3.7 Remedial Action

This is the actual implementation of the chosen
remediation approach and includes both
treatment of contaminated wastewater and
rehabilitation of system components.

3.8 Post-Remediation Monitoring

After site actions are complete, monitoring of
the system must be conducted to ensure that
the remediation was effective.
3.9 Communication to Restore Public
    Confidence

During remediation activities, and prior to
return of the system to normal operations,
the utility and other agencies should conduct
outreach to the community to restore public
confidence in the wastewater system.

The degree to which remediation and recovery
follows the nine step model presented above
will depend on the nature and extent of the
contamination.  A small-scale incident might
not involve all of the steps. For example,
extensive system characterization may not
be required if the contamination is contained
through early operational responses and
is confined to a well-defined area. Each
remediation and recovery effort will be
unique and will be dictated by details of the
intentional or accidental contamination event.

4 Summary

Following confirmation of either an accidental
or intentional contamination event in a
wastewater system, steps must be taken to
remove the contamination and bring the system
back into full service. Depending on the nature
and extent of contamination, the wastewater
may have to be decontaminated prior to
disposal. The wastewater infrastructure (e.g.,
collection mains, pumps, and treatment plant)
may also have to be decontaminated. Module 6
of the Toolbox outlines a systematic approach,
based on EPAs Superfund experience,
for remediation and recovery of affected
wastewater systems.

Efforts are ongoing within the federal
government and research community to
develop specific technical solutions to
wastewater system decontamination needs.
When developed, this information may be
distributed through vehicles such as WCIT.
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          5 Appendices

          The following are examples of forms that
          may be used to facilitate the remediation and
          recovery process:
            Suggested Outline for System
            Characterization/Feasibility Study Work
            Plan
            Elements for a Quality Assurance Project
            Plan
            Elements of a  Health and Safety Plan
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          These forms can be found in the Appendices
          located at the end of the Toolbox.
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