&EPA
United States
Environmental Protection
Agency
Water Laboratory Alliance
Response Plan
November 2010
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Office of Water
EPA 817-R-10-002
www.epa.gov/safewater
November 2010
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| WASHINGTON, D.C. 20460
OFFICE OF
WATER
Dear Colleague,
I am writing to announce the release of the final Water Laboratory Alliance Response Plan
(WLA-RP). The Water Laboratory Alliance Response Plan is based on the common elements of the
Regional Laboratory Response Plans, which were developed by EPA in collaboration with state
environmental and public health laboratories, drinking water utility laboratories, emergency responders,
and other state and federal agencies. The Water Laboratory Alliance Response Plan incorporates lessons
learned from 11 functional exercises conducted in 2008 and the Region 1 and 2 Full-Scale Laboratory
Response Exercise conducted in 2009.
The Water Laboratory Alliance Response Plan provides processes and procedures for
coordinated laboratory response to water contamination incidents that may require additional analytical
support and a broader response than a typical laboratory can provide. This plan is designed to work within
existing Incident Command System (ICS) structures and procedures to facilitate emergency laboratory
support to water contamination events. The Water Laboratory Alliance Response Plan is intended for use
in small incidents requiring support from a single laboratory to multi-regional incidents supported by
many laboratories.
The Water Laboratory Alliance Response Plan can be found in electronic format on the EPA
website at: http://ctpub.epa.gov/safewater/watersecurity/wla.cfm under Tools. If additional information is
needed, please contact Adrian Hanley by email: WLAfojepa.gov or by phone: 202-564-1564.
David Travers, Director
Water Security Division
Internet Address (URL) http://www.epa.gov
Recycled/Recyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
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Disclaimer
The U.S. Environmental Protection Agency (EPA) prepared this plan to help laboratories, water utilities,
emergency responders, and other local, state, and federal agencies work together to coordinate response to
drinking water contamination incidents. This document does not impose legally binding requirements on
EPA, laboratories, states, tribes, or the regulated water community. Rather, this plan may be used as
needed to coordinate laboratory support for water contamination incidents. EPA may review and update
this plan, as needed, to address procedure and policy changes and other evolving needs of the Water
Sector. To determine whether EPA has revised this plan or to obtain additional copies, contact Adrian
Hanley at WLA@epa.gov.
Any mention of trade names, companies, products, or services in this plan does not constitute an
endorsement by EPA or any non-federal entity, its products, or its services.
Acknowledgments
The U.S. Environmental Protection Agency's (EPA) Office of Water would like to recognize the
following individuals for their support in the development of this document:
Office of Water
Adrian Hanley
Latisha Mapp
Patricia Tidwell-Shelton
Rosemary Workman
Office of Emergency Management
Allan Antley - Retired
Michelle Burgess
Schatzi Fitz-James
Terry Smith
Office of the Science Advisor
Anand Mudambi
EPA Regions
Linda Anderson-Carnahan - Region 10
Dale Bates - Region 7
Gary Bennett - Region 4
Brenda Bettencourt - Region 9
John Bourbon - Region 2
Cynthia Caporale - Region 3
Gerald Dodo - Region 10
Robert Maxfield - Region 1
Rick McMillin - Region 6
Tony Medrano - Region 8 Retired
Cynthia Metzger - Region 3
David Neleigh - Region 6
Deborah Szaro - Region 2
Ernest Waterman - Region 1
Dennis Wesolowski - Region 5
Parti-Kay Wisniewski - Region 3
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Table of Contents
CHANGE CONTROL Ill
EXECUTIVE SUMMARY IV
SECTION 1.0 INTRODUCTION 1
1.1 SCOPE 1
1.2 PURPOSE 2
1.3 APPLICATION 2
1.4 RELATIONSHIP OF THE EPA WATER LABORATORY ALLIANCE (WLA) AND THE ENVIRONMENTAL
RESPONSE LABORATORY NETWORK (ERLN) 2
SECTION 2.0 LABORATORY RESPONSE PLAN ELEMENTS 4
2.1 LAWS AND AUTHORITIES 4
2.2 MINIMUM QUALIFICATIONS FOR PARTICIPATION AND EXPECTATIONS 5
2.3 RESOURCE MANAGEMENT 5
2.4 PLANNING 5
2.5 DIRECTION, CONTROL, AND COORDINATION 6
2.5.1 Roles 6
2.5.2 Responsibilities 7
2.5.3 Incident Command System (ICS) 9
2.5.4 Transfer of Responsibilities 10
2.5.5 Multi-Regional Incident Coordination 11
2.5.6 Data Ownership 11
2.6 QUALITY ASSURANCE PROJECT PLANS (QAPPs) 11
2.7 COMMUNICATIONS AND NOTIFICATION 11
2.7.1 Communications Logistics 12
2.8 HEALTH AND SAFETY 13
SECTION 3.0 OPERATIONS AND PROCEDURES 14
3.1 SAMPLING 14
3.2 SAMPLE BROKERAGE, TRACKING, AND TRANSPORT 15
3.2.1 Sample Brokerage 16
3.2.2 Sample Tracking 17
3.2.3 Sample Transport 17
3.3 ANALYSIS 18
3.3.1 Basic Field/Safety Screening 19
3.3.2 Rapid Laboratory Analyses 20
3.3.3 Confirmatory Analyses 20
3.3.4 Sample Disposal 21
3.3.5 Quality Assurance/Quality Control 21
3.4 INTERNAL DATA REVIEW 22
3.5 DATA REPORTING 23
3.6 SECURE DATA TRANSFER AND STORAGE 23
3.7 ANALYTICAL DATA VALIDATION 23
3.8 DATA INTERPRETATION 25
3.9 RECORD KEEPING 25
3.10 TRAINING 25
3.11 EXERCISES, EVALUATIONS, AND CORRECTIVE ACTIONS 26
3.12 FINANCE AND ADMINISTRATION 26
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List of Appendices
Appendix A List of Acronyms
Appendix B Checklist and Quick Reference Guide for PRL and MSL Response
Appendix C Help Sheet for Requesting Analytical Support during Water Emergency Response
Appendix D Incident Communications Tracking Form for Laboratories
Appendix E Data Elements for Electronic Transmission
Appendix F Field Testing Results Form
Appendix G Example Chain of Custody Form
Appendix H Minimum Chain of Custody Data Elements
Appendix I Guidelines for Handling Criminal Investigation Samples
Appendix J Close-out Action Checklist
Appendix K Recommendations for Water Laboratory Alliance Response Plan Practice
Appendix L Suggested Emergency Water Sample Collection Kit
Appendix M Standardized Analytical Methods for Environmental Restoration Following
Homeland Security Events (SAM)
Appendix N Short Form Quality Assurance Project Plan Template
Appendix O Structure of the Incident Command System
Appendix P Reimbursement Tips for Emergency Laboratory Support
Appendix Q References and Resources
Appendix R Regional Laboratory Contact Information
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Change Control
Section
Change
Changes Made By Date
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in
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Executive Summary
The goal of Environmental Protection Agency's (EPA) Water Laboratory Alliance (WLA) is to provide
the water sector with an integrated nationwide network of laboratories with the analytical capabilities and
capacity to support monitoring and surveillance, response, and remediation of intentional and
unintentional water contamination events involving chemical, biological, and radiochemical
contaminants. The WLA is the water component of the EPA's Environmental Response Laboratory
Network (ERLN). The ERLN is a network of laboratories which provides analytical capability and
capacity for the above contaminants in all environmental matrices.
The Water Laboratory Alliance Response Plan (WLA-RP) provides processes and procedures for
coordinated laboratory response to water contamination incidents that may require additional analytical
support and a broader response than atypical laboratory can provide. The WLA-RP is designed to work
within existing Incident Command System (ICS) structures and procedures. This plan may be adopted by
the EPA regions to replace their existing Regional Laboratory Response Plans (RLRPs). These RLRPs
were developed for each region in cooperation with drinking water utilities, state public health
laboratories, state environmental laboratories, emergency response personnel, and other experts.
Functional Exercises were conducted in 2008 to test each of the RLRPs; the lessons learned from the
Functional Exercises and the common elements of the RLRPs provided the basis for development of this
WLA-RP. The WLA-RP provides a consistent, national approach to coordinated laboratory response to
water contamination events and eliminates the need to maintain separate RLRPs. The WLA-RP is
intended for use in small incidents requiring support from a single laboratory to multi-regional incidents
supported by many laboratories.
During a natural disaster, terrorist event, or accident affecting the water sector, a large number of
environmental samples will be generated, likely overwhelming the capacity and/or capability of any
individual laboratory to provide sufficient analytical support. This plan does not obligate laboratories to
provide support in such an event, but rather provides a consistent approach to how water utility, state, and
EPA regional laboratories should work together to meet the need for analytical support. This plan should
not be construed to supplant or subordinate existing legal authorities, but rather should be used as needed
to coordinate laboratory support for water contamination incidents.
Note: The WLA-RP is a living document and will be reviewed and updated as needed to address
procedure and policy changes and other evolving needs of the water sector.
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Section 1.0 Introduction
1.1 Scope
The Water Laboratory Alliance Response Plan (WLA-RP) addresses water contamination incidents that,
due to their suspected cause or size, may require additional analytical support and a broader response than
a typical utility, state, or federal laboratory can provide. The WLA-RP is intended for use in responses on
a regional and multi-regional scale. The guidance and procedures discussed in the WLA-RP are also
applicable to smaller multi-laboratory responses, and many aspects of the plan regarding sample analysis,
sample tracking, data review and data transfer can also be applied to single-laboratory responses.
A laboratory's participation in a specific incident is at the discretion of the individual laboratory's
management and will normally require consultation with higher level management in the parent
organization before the laboratory can commit to providing analytical support. The WLA-RP addresses
actions to be taken by the responding laboratories early in an incident. Once an Incident Command
System (ICS) is mobilized, the plans and operations of the ICS may supplant those in this WLA-RP.
Although overall coordination during an incident response will be directed by the appropriate party (e.g.,
Laboratory Coordinator under the Environmental Unit) as part of the ICS, the WLA-RP procedures may
still be used to coordinate laboratory support under the direction of the ICS.
ICS is a flexible and scalable system driven by the tactical needs of an incident. It provides a common
structure and terminology that facilitates the integration and coordination of multiple agencies while still
maintaining a chain of command. ICS also provides pre-designated leadership positions, specific span of
control, and well-understood assigned responsibilities. For more information, please refer to the EPA
Incident Management Handbook (2007 edition) or the Federal Emergency Management Agency (FEMA)
training site at: http://www.fema.gov/about/training/index.shtm. Appendix O provides general
information on the ICS.
If a contamination event occurs that is beyond the analytical capability or capacity of the initial
responding laboratory, the WLA-RP may be used for a coordinated multi-laboratory response. The WLA-
RP provides procedures for a coordinated response to water contamination incidents that threaten public
health and safety. This plan assumes that samples are analyzed to identify unknown contaminants, and to
determine the extent of contamination, the success of remediation efforts, and when the system can be
returned to service. Samples may also be collected and analyzed as part of a criminal investigation.
Support that may be provided under the plan includes:
Analyses
Consulting
Data review, reporting, transmission, and exchange
Reagent exchange
Sample storage and brokerage
Training
Coordination / communications with other entities
Assumption of other support laboratories normal workload
Staff exchange (laboratories should be aware that legal issues, such as overtime and liability
regulations, may limit this support)
Recommended roles and responsibilities of laboratories during a response are described in this
WLA-RP. However, these designations are not intended to supersede those dictated by state,
agency, or department statutory authorities.
For example, this plan does not supersede reporting and other notification requirements already in
place between water utilities and state primacy agencies.
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This plan is not intended to pose additional requirements or burdens on the participating
laboratories, but to establish an approach for coordination during an event and increase
consistency to the extent practical across existing capabilities and procedures. It is recommended
that the guidelines provided in this document be followed for all responses. For some larger scale
incidents (e.g., incidents where WLA member laboratories are providing support under contract to
EPA), laboratories may be required to follow the procedures included in the WLA-RP, especially
for evidentiary chain of custody (see Section 3.2.2) and data reporting (see Section 3.5).
1.2 Purpose
The purpose of the WLA-RP is to establish a comprehensive, national approach to laboratory response
across a spectrum of activities including preparedness, response, remediation, and recovery for water-
related incidents. The WLA-RP provides federal, state environmental, state public health and water utility
laboratories with a laboratory structure for a systematic, coordinated response to a water contamination
incident. Implementation and maintenance of this plan also may identify capability gaps and opportunities
for revision of existing standard operating procedures (SOPs) and emergency plans.
This plan is intended to support and coexist with other laboratory coordinating programs, such as the
Centers for Disease Control and Prevention's (CDC) Laboratory Response Network (LRN), the Food and
Drug Administration's (FDA) Food Emergency Response Network (FERN), the United States
Department of Agriculture's (USDA) National Animal Health Laboratory Network (NAHLN) and the
EPA's Environmental Response Laboratory Network (ERLN). Additional information on these laboratory
networks can be found in Appendix Q.
1.3 Application
The WLA-RP applies to the local, state, and EPA regional laboratories that may be requested to provide
assistance or conduct analyses in actual or suspected water contamination incidents. This includes the
laboratories and utilities which participated in the development and review of the Regional Laboratory
Response Plans (RLRPs) for each region.
Water contamination incidents may require a coordinated response by an appropriate combination of
utility, local, state, and federal laboratories. This plan can expand a laboratory's existing response
network through notification of the drinking water programs and emergency management agencies. The
following parties should be notified of this plan during routine communications with the laboratory:
State and federal drinking water programs
State and federal emergency response programs
State emergency management agencies
Agency management
1.4 Relationship of the EPA Water Laboratory Alliance (WLA) and the Environmental
Response Laboratory Network (ERLN)
EPA is developing the ERLN to address analytical capability and capacity for response to environmental
contamination events. The ERLN will be coordinated with other national laboratory networks through the
Integrated Consortium of Laboratory Networks (ICLN). The ERLN will have the capacity to analyze
samples for chemical, biological, and radiological agents in all environmental matrices; will include
federal, state, and private sector laboratories; and will incorporate many of the network infrastructure
elements (e.g., laboratory types, proficiency testing, standardized methods) found in the CDC's LRN and
FDA's FERN. The WLA is part of the ERLN and provides support and coordination for analyses of water
matrices. Figure 1 depicts the relationship of the WLA within the ERLN.
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The WLA-RP provides recommended procedures to coordinate local, state, and federal laboratory efforts
to meet analytical needs that may result from an incident. The creation and implementation of the WLA-
RP will serve as groundwork for the development of the WLA and ERLN, by providing a testing ground
to address issues such as sample brokerage, analytical method selection, secure data transfer, and legal
authority.
Environmental Response Laboratory Network (ERLN)
'Coordinated by the EPA Office of Water
Figure 1. Relationship of the WLA to the ERLN
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Section 2.0 Laboratory Response Plan Elements
This section of the WLA-RP addresses the following elements:
Laws and Authorities (Section 2.1)
Minimum Qualifications for Participation and Expectations (Section 2.2)
Resource Management (Section 2.3)
Planning (Section 2.4)
Direction, Control, and Coordination (Section 2.5)
Quality Assurance Project Plans (Section 2.6)
Communications and Notification (Section 2.7)
Health and Safety (Section 2.8)
The general procedures below apply to laboratory support during emergency response, remediation, and
recovery. However, the applicability of any particular element of the plan will be dictated by the specifics
of the incident.
2.1 Laws and Authorities
On January 30, 2004, the President signed Homeland Security Presidential Directive (HSPD) 9, Defense
of United States Agriculture and Food, which directs EPA to develop comprehensive surveillance and
monitoring systems for water quality, as well as nationwide laboratory networks for water quality that
integrate existing state and federal laboratory resources. HSPD-9 recognizes that surveillance efforts and
laboratory support must be coordinated with the states and the nation's 56,000 community water systems,
and this Directive forms the basis for the development of the WLA-RP. In addition, the National Strategy
for Homeland Security and HSPD-10 assign EPA responsibility for building laboratory diagnostic surge
capacity for environmental samples during crises.
Laboratories providing support under the WLA-RP must comply with all applicable state and local laws
and authorities. Federal and state legislations, regulations, codes, and authorities relevant to this WLA-RP
will be reviewed by EPA when the WLA-RP is updated as part of the biennial review process.
The WLA-RP is intended to comply with applicable legislation, regulations, directives, and policies.
Applicable federal authorities include Section 103 of the Clean Air Act, 42 U.S.C. 7403, Section 104 of
the Clean Water Act, 33 U.S.C. 1254, Section 8001 of the Solid Waste Disposal Act, 42 U.S.C. 6981,
Sections 101(8), 104(a) and 104(b) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), U.S.C. 9601, the Safe Drinking Water Act, 42 U.S.C. 300f and the Oil
Pollution Act of 1990. These statutes provide EPA with authority to undertake cooperative efforts with
states to promote the coordination and acceleration of research, studies, and other activities relating to the
causes, effects, extent, prevention, reduction, and elimination of pollution (with the exception of CERLA
which covers response authorities).
Under the National Response Framework, EPA has a co-lead role with the Coast Guard for Emergency
Support Function (ESF) #10, which specifies the federal response to an actual or potential release of oil or
hazardous materials, including certain chemical, biological, and radioactive substances considered
weapons of mass destruction. In addition, EPA is designated as a support agency to the U.S. Army Corps
of Engineers for water infrastructure and safety under ESF #3, which applies to all types of national
incidents, including, but not limited to, natural and human caused disasters.
The National Contingency Plan (NCP), in support of the Oil Pollution Act of 1990, established response
roles, responsibilities and coordination procedures in response to major discharges of oil or hazardous
materials. A key role in the plan is that of the National Response Team (NRT), of which EPA serves as
the lead, and describes its roles and responsibilities including planning and coordinating responses to
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major discharges of oil or hazardous waste, providing guidance to Regional Response Teams,
coordinating a national program of preparedness planning and response, and facilitating research to
improve response.
2.2 Minimum Qualifications for Participation and Expectations
To demonstrate capabilities, the plan relies on existing programs that laboratories currently participate in,
such as the National Environmental Laboratory Accreditation Program (NELAP), the LRN, the EPA
Drinking Water Certification Program, American Association of Laboratory Accreditation Program
(A2LA), and the Regional Quality Assurance programs. These programs provide indication and
verification of a laboratory's capabilities though their own program requirements. Requirements for
laboratory certification will vary from state to state. Decisions regarding the requirements for laboratory
support will be incident-specific and will be made by the Analytical Services Requester (ASR) or other
responsible party. Laboratories are not required to be members of the WLA or the ERLN in order to
provide support during an incident. However, if ERLN/WLA member laboratories are called upon to
provide support to an incident under contract to EPA, the member laboratories must meet the
requirements of the appropriate program.
Laboratories are expected to provide the basic support necessary to implement and regularly review the
plan. Additionally, laboratories should register for access to EPA's Compendium of Environmental
Testing Laboratories (CETL or EPA Lab Compendium) database (www.epa.gov/compendium) and
update their laboratories' capabilities as well as other essential information (e.g., contacts, telephone
numbers, etc.) on a regular basis.
2.3 Resource Management
This plan is based on use of laboratories' current personnel, equipment, and supplies that are normally
used in day-to-day operations to accomplish current program missions and mandates. Laboratories will
follow their existing procedures regarding resource inventory (e.g., reagents, disposables, standards) and
are not required to maintain any non-routine stock for emergency use. If a lack of standards or reagents
will create an issue, the laboratory should contact the Primary Responding Laboratory (PRL) or ASR to
inform them.
Incidents may necessitate the use or provision of emergency response sampling kits. An example sample
collection kit is provided in Appendix L for reference. However, laboratories are not required to supply
emergency sampling kits.
Laboratories may require access to calibration materials or standards for analyses they do not perform
routinely. In addition, laboratories may need additional testing supplies and reagents once their existing
supplies are exhausted. Laboratories should address this resource issue using one or more of the following
mechanisms:
Sharing existing inventory information to aid in rapidly locating materials during an emergency
Working with the state or EPA regional laboratories to procure materials
Developing relationships with other laboratory networks (e.g., ERLN), academic institutions, or
commercial organizations that have large reagent inventories
Entering into a commercial contract with a supplier
2.4 Planning
The WLA-RP addresses analytical demand during the emergency response, remediation, and recovery
phases of a natural disaster, accident, or terrorist incident affecting the water sector. Coordination of
likely activities through the WLA-RP can prevent duplication of effort, maximize efficiencies and
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effectiveness, improve communication, and increase analytical support. Laboratories are encouraged to
increase awareness of the WLA-RP through notification and discussion with the state drinking water
programs and emergency management agencies.
A review of this plan will be performed every two years and updates to the plan will be made as necessary
to ensure that it meets the needs of the water sector. The EPA Water Security Division (WSD) will be
responsible for leading the review of the plan and updating the plan as needed. All changes made to the
plan will be tracked in the change control table at the beginning of this plan. To access the current version
of the plan, laboratories should go to the WLA Web page at:
http://cfpub.epa.gov/safewater/watersecurity/wla.cfm. The plan review should include consideration of
the following:
Lessons learned from recent incidents and exercises
Regulatory changes
New potential hazards or changes in existing potential hazards
Major resource or organizational structure changes
Infrastructure or laboratory guidance changes
Funding or budget-level changes
Changes in other laboratory organizations (e.g., LRN, FERN, etc.)
Changes in documents and Web resources cited in the plan
Changes in address and contact information for participating laboratories
2.5 Direction, Control, and Coordination
Direction, control, and coordination of collaborative laboratory support under this plan follow ICS and
include the designation of a Primary Responding Laboratory (PRL) and Mutual Support Laboratory(ies)
(MSLs) as the line of support and coordination. The PRL is the laboratory that first agrees to provide
analytical support for a water contamination event when asked by the ASR. However, if the laboratory
that first provides initial support is not qualified to serve as the PRL, this role may be transitioned to
another laboratory (see Section 2.5.3). The ASR may be the first responder (e.g., police officer), Hazmat
team leader, state drinking water agency, or utility manager. Although the "selection" of an ASR is
outside the scope of this plan, laboratories should work with the requester to ensure that proper channels
and notifications have been followed prior to request and engagement of laboratory support. If the PRL
does not have the capability and/or capacity to fully address the analytical needs presented by the water
contamination incident, the PRL in consultation with the ASR will contact other laboratories for
assistance. The PRL should get the ASR approval before engaging any laboratories to act as MSLs. Those
laboratories agreeing to provide assistance are referred to as MSLs. The PRL will direct sample
brokerage, coordination of analytical issues and quality assurance (QA) requirements, and routing of
MSL results to the ASR. The PRL will interface directly with all MSLs and the ASR.
An ICS should be implemented for all emergency response incidents. The WLA-RP is designed to
function under the ICS structure, which is a standardized system used to organize all of the management
functions necessary to respond to an emergency (the ICS is described in more detail in Appendix O).
2.5.1 Roles
Coordination of laboratory support under this WLA-RP in response to a water contamination incident
involves the following roles:
Analytical Services Requester (ASR) - This is the primary point of contact who requests
analytical assistance for a water contamination incident from a laboratory. The ASR may be a
first responder (e.g., police officer), Hazmat team leader, utility manager, state regulatory
authority affected by the incident, or a state drinking water agency. As the ICS sections are put in
place, the responsibilities of the ASR may be absorbed by the Environmental Unit (EU) under the
planning or operations sections of the ICS. Existing Emergency Operations Centers (EOCs) and
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Multi-Agency Coordination Systems (MACS) may also play a role in identification and
coordination of resources for laboratory emergency response.
Primary Responding Laboratory (PRL) - The initial laboratory contacted by the ASRthat
agrees to provide support.
Mutual Support Laboratory (MSL) - Laboratory that may be engaged by the PRL, should the
PRL's resources be insufficient at any point in the process to meet the analytical needs of the
incident.
2.5.2 Responsibilities
The ASRhas the following responsibilities:
Contact the laboratory that will serve as the PRL and that will provide analytical services for the
incident. The ASR should provide information to the PRL on the incident including site
characterizations, potential hazards, and any field screening information.
Act as the primary decision maker concerning the type, quality, and timeliness of the analytical
data required for the response. The ASR may consult with the PRL regarding the various
analytical options available to provide the type of data requested.
Direct sample collection and distribution to the PRL and MSL(s) as appropriate. Communicate
any information from the support laboratories to the samplers regarding requirements for sample
volumes, preservation, shipping and storage, need for personal protective equipment, etc.
Coordinate with other organizations that may have information relevant to the incident, such as
clinical laboratories and public health departments, and ensure that this information is
communicated to the PRL.
Inform the PRL of requirements for data turnaround, data format, sample and record retention,
and sample storage.
The PRL has the following responsibilities:
In consultation with the ASR, develop an initial analytical strategy based on Section 3.3.
Depending on the information available from the ASR, the PRL may involve other laboratories in
developing the strategy. [See the Response Protocol Toolbox - Module 4 for additional
information: http://www.epa.gov/safewater/watersecurity/pubs/guide_response_module4.pdf]
Provide coordination and follow direction from ICS.
Provide sample collection staff to the ASR (if appropriately trained staff are available), or
guidance and information regarding collection, preservation, and shipment of samples. The PRL
should provide the ASR or sample collection staff with specifications regarding minimum field
data elements, sample container and preservation guidance, sample shipping conditions, need for
personal protective equipment, and cautions regarding potential release of data in response to
Freedom of Information Act (FOIA) requests or other legal authorities.
As needed, identify and engage laboratories as approved by the ASR with appropriate expertise to
function as MSLs in order to meet the analytical demands of the particular phase of the incident.
For example, for potential biological contamination, LRN laboratories may be engaged during the
triage phase to perform pathogen analyses. During the remedial investigation phase, several
MSLs may be needed to provide adequate capacity to determine the extent of contamination by a
particular agent. MSL support to an incident could also include expert advice on selection of
appropriate methodology and peer review of data, in addition to analysis of samples. The PRL
may elect to use other assets, such as commercial laboratories, if the circumstances of the
response effort require this approach. The PRL may use the CETL or other federal, regional,
state, or local resources to identify laboratories that have the capabilities to provide support.
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Act as a communications conduit between MSLs and the ASR as the situation develops and
samples are collected. In this capacity, the PRL sample coordinator ensures that samples and field
data are appropriately routed to the correct laboratory (sample brokerage is discussed further in
Section 3.2.1) and that the laboratory has the necessary information to correctly analyze those
samples as soon as possible. Frequent and complete exchange of communication is key to
ensuring a coordinated response (see Section 2.7). The ASR may request that the MSLs provide
data directly to the ASR, rather than routing it through the PRL.
Coordinate collection and compilation of data from MSLs and report back to the ASR.
Depending on the phase of an event, reports may be sent to the ASR as data from the PRL and/or
MSL(s) become available. The PRL may also be responsible for consolidating and performing
basic quality checks on MSL data prior to forwarding the data on to the ASR (discussed further in
Section 3.5). The MSLs may provide data compilation and data review. The PRL is also
responsible for obtaining special instructions from the ASR regarding data release and records
maintenance, retention, and destruction. The ASR should be advised that various state
laboratories may function under different FOIA requirements.
In addition, the PRL may provide analytical support. This support would typically be during the
initial phases of the response when rapid identification of the unknown is required, but may also
include the remedial phase.
Additional support may include:
o Analysis
o Consulting
o Data review, reporting, and exchange
o Reagent exchange
o Sample storage
o Training
MSLs have the following responsibilities:
Follow direction from the ASR/IC or other ICS authority (e.g., EU Laboratory Coordinator)
Rapidly assess available resources and provide timely realistic assessment of available support
Meet commitments to the PRL (e.g., analyses, data review, sample storage)
Consult with PRL as changes occur and analytical information becomes available
Support provided may include:
o Sample collection
o Analyses
o Consulting
o Quality control
o Data review
o Reagent exchange
o Sample storage
o Training
o Staff exchange
In addition to providing analytical support directly related to the incident, MSLs may provide support by
assuming part of the PRL or other MSLs normal workload to create capacity at those laboratories to
provide direct incident support.
Laboratories may refer to the Checklist and Quick Reference Guide for Providing Laboratory Support
during a Drinking Water Emergency Response for high-level guidance on laboratory support activities
and references to appropriate sections of this plan for further information (Appendix B).
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2.5.3 Incident Command System (ICS)
For smaller-scale incidents and the early stages of a larger incident, management functions might be
handled by one person, the incident commander (1C). In this case, the 1C will serve as the ASR. The ASR
or 1C will serve until the requirements of the event move beyond the scope of their expertise (e.g., scale of
incident escalates, contamination is confirmed, or remediation and recovery begins), at which time the
role of the ASR or 1C will be transferred to another individual or organization, as appropriate for the
situation (e.g., for hazardous materials incidents or oil spills, the role of the ASR or 1C may transition to
an EPA On-scene Coordinator (OSC)).
As the incident develops and operational requirements warrant, the ICS may be expanded to address the
scope and size of the event and provide the 1C with supporting staff according to a standardized, well-
understood management structure. If the incident is of sufficient complexity, the 1C may activate an EU
within the planning section of the ICS to facilitate environmental data management, monitoring,
sampling, analyses and assessment, which would include the efforts by the laboratories. A list of the EU
personnel involved in coordinating the laboratory response to a water contamination incident and the
highlights of their duties are provided as follows:
Laboratory Coordinator: identify and reach out to available laboratory resources, set priorities
for laboratory analyses, and coordinate laboratory resources with other agencies
Analytical Coordinator: schedule environmental sample analyses, maintain laboratory contacts,
monitor and review sample and data chain-of-custody, and provide analytical reports to the 1C
andEU
Quality Assurance Coordinator: review and approve quality assurance project plans (QAPPs)
and standard operating procedures (SOPs), supervise data review and validation, and resolve QA
issues
Sampling and Monitoring Plan Coordinator: develop and review the sampling plans, sampling
procedures, and QAPP
The EU roles listed above may be played by a single person or multiple people, depending on the
complexity and demands of the incident. In addition to the EU roles listed above, there may be other EU
personnel involved with the laboratory response to a water contamination incident. For a complete list of
EU personnel and descriptions of their responsibilities, please refer to the EPA Incident Management
Handbook (2007 edition).
After the EU is implemented, the ICS may continue to use the structure and roles set up by the WLA-RP
for coordination of laboratory support. The PRL may interface directly with the appropriate personnel
under the EU, or the EU may replace the PRL coordination / sample brokering role and coordinate
directly with all laboratories providing support to the incident. In this case, the PRL could continue to
provide analytical services as a support laboratory. A schematic of the relationship of the ASR, PRL, and
MSLs, and how this may be integrated into an expanded ICS, is provided in Figure 2.
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Expanded Coordination
Structure
Command
Incident Commander (1C)
Initial Coordination
Structure
ASR
(1C)
Planning
I
Operations
1 1
Logistics
V )
Finance
Transfer of Coordination
Responsibilities
Environmental Unit
Figure 2. General Relationship of Laboratory Response Participants
2.5.4 Transfer of Responsibilities
Depending on the evolution of the response to an incident, the PRL may determine that transferring this
responsibility to another laboratory or functional position within an ICS EU is appropriate. This may be
necessary if the scope and scale of the incident exceeds the resources and capabilities of the PRL (e.g.,
personnel issues, instrumentation problems, sample capacity exceeded), or the PRL's operations are
impacted by the incident. If this transfer is necessary, the PRL will coordinate with the MSL(s) to identify
the issues, responsibilities, and materials that would need to be addressed to implement this change.
Actions that will need to be taken by the PRL when transferring its role to a new laboratory include:
Coordinating with ICS
Notifying the ASR of the need to transfer the PRL role
Providing necessary background information about the incident to the new PRL using the Help
Sheet for Requesting Analytical Support during Water Emergency Response (Appendix C)
Notifying the MSLs of the change in PRL
Completing any ongoing sample analyses
Arranging for any remaining samples to be transferred to another laboratory, as appropriate
Providing all data generated in support of the event to the new PRL
Similar to the PRL, an MSL may decide that it can no longer provide support to an incident. The MSL
should inform the PRL or functional position within the ICS EU if support can no longer be provided.
The PRL should work with the MSL to ensure that all necessary information is provided to a new
laboratory that is taking over the MSL role, and that any remaining samples are transferred to the new
laboratory. The MSL should complete any ongoing sample analyses and report any data already generated
to the PRL. If the MSL is a subcontractor to the PRL, the PRL will be responsible for enforcing
contractual requirements and determining if transfer of responsibilities to a new MSL is necessary.
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2.5.5 Multi-Regional Incident Coordination
For larger incidents or incidents that require specialized laboratory capabilities (e.g., analysis of chemical
warfare agents), it may be necessary to request assistance from government laboratories outside of the
EPA region where the incident initially occurred. In this case, the following procedure should be used:
1. The ASR/EU/PRL contacts their EPA Regional Laboratory Director regarding the need for assistance
from other EPA Regions.
2. The EPA Regional Laboratory Director would then contact their counterpart(s) in another EPA
region(s) to request assistance.
3. The assisting EPA Regional Laboratory Director may provide direct support (e.g., analyses performed
at the Regional Laboratory) or request assistance from other laboratories located in their region.
4. The EPA Regional Laboratory Directors from the requesting and assisting regions should come to an
agreement regarding how laboratory support from the assisting region will be coordinated.
Note: commercial laboratories outside the region can be contacted by the ASR/PRL/EU directly or use
the procedure outlined above.
2.5.6 Data Ownership
Generally, the ASR will be the owner of the data generated by laboratories participating in a response
under the WLA-RP. Data will be released to the ASR through the PRL, in accordance with the analytical
laboratory's existing policies and procedures governing data reporting (e.g., provision of original data or
copies of the data). Laboratories participating in the WLA-RP will not release data to anyone other than
the PRL or ASR, unless there are specific circumstances requiring the laboratory to do so. Circumstances
that may require the laboratory to release data may include FOIA requests and state mandates. Any
information shared with laboratory management should not be released to parties outside the laboratories.
2.6 Quality Assurance Project Plans (QAPPs)
The QAPP is a document that describes specific analytical considerations that need to be addressed in the
event that there is an emergency drinking water response. QAPPs typically include information on the
background of the project, scope and application, project organization (which lists all key personnel,
sampling, and analytical specifications), Quality Assurance (QA)/Quality Control (QC) checks, and
method verification. Since the laboratory performs a support service, it is not responsible for writing the
QAPP. However, the laboratory can be an important resource for analytical information during
development of the QAPP. Laboratories should be aware that although a general or generic QAPP may be
used during the initial phases of an emergency response, a more complex one will likely be necessary
during recovery and remediation. Laboratories are advised to request a copy of the QAPP if one has been
developed. The ICS EU QA coordinator is responsible for reviewing and approving the QAPP. A
template for a Short Form Quality Assurance Project Plan is included in Appendix N.
2.7 Communications and Notification
Communications should follow the ASR/PRL/MSL structure described in Section 2.5. Laboratories
should maintain a list of primary through tertiary contacts, including a duty or 24-hour line, if available,
and physical (delivery) and Web site addresses. This information should be updated in the CETL
quarterly.
Communication among the laboratories will generally be limited to the primary point of contact (POC).
The participants of this plan acknowledge that discussions about the analytical strategy will be
documented in writing. In the event that the primary POC becomes unavailable at the PRL or MSLs,
laboratories need to coordinate internally to ensure that back-up contacts are kept informed throughout the
lifecycle of the event to avoid lapses in ongoing, rapid support.
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Laboratories should note that the PRL POC may require routine updates or conference calls amongst the
laboratories if the response continues for a prolonged period. This communication may include a planning
call with the MSL(s) to prepare for any conference calls with the ASR or applicable EOC, and a call
afterwards to update the MSL(s). The PRL and MSL(s) should communicate health and safety issues as
soon as preliminary data become available. It is good practice to document the issues that were discussed
and follow up with an email summary of the information (see Section 2.7.1).
If samples are law enforcement sensitive, this information needs to be communicated to all involved
parties at the beginning of the event. The samplers will need to use appropriate techniques, including
sample custody tape, if required, and enhanced internal chain-of-custody documentation. The PRL should
ask the MSL if it will be able to provide enhanced, internal, laboratory chain-of-custody tracking. For
more information on internal laboratory chain-of-custody requirements for potential or actual
criminal investigation samples, see Appendix I.
Decisions should be made at the beginning of an incident regarding how communications with parties that
are outside of the laboratory support structure will be handled. In general, these communications will be
routed through the ASR/PRL/MSL notification and reporting structure, and information should not be
provided by the laboratories to outside parties. Laboratories may need to communicate with other
organizations during an incident response to make necessary notifications and share information. These
organizations will vary between incidents, but may include:
Hospitals and clinical laboratories
Local and state public health agencies
State drinking water agencies
Local, state, and federal law enforcement
The Department of Homeland Security
Neighboring water systems
In many situations, an 1C may appoint a designated public information officer (PIO) responsible
for all communications with the press and public. Each laboratory must follow their own local,
state and federal guidelines for communications with the press and the public. There also may be a
Liaison Officer (LNO) that is responsible for coordinating with other agencies and organizations
providing support to an incident.
In some cases, communications may occur outside the structure chosen by the ASR. Although
laboratories acknowledge that such communications may need to occur, laboratories should always notify
the PRL and/or the ASR beforehand. Exceptions to the communication structure include:
FOIA requests or "sunshine" laws
Program requirements (e.g., LRN)
Management requests
Political pressure (e.g., governor)
Law enforcement (in some circumstances)
Laboratories may use the following forms (or similar forms currently used by the laboratory) to aid in
communications during an incident:
Checklist and Quick Reference Guide for PRL and MSL Response during a Water Emergency
(Appendix B)
Help Sheet for Requesting Analytical Support during Water Emergency Response (Appendix C)
2.7.1 Communications Logistics
Laboratories participating in a response should establish procedures for how emergency calls and calls to
the POC for the incident will be handled, how they will be forwarded, and how after-hours calls will be
addressed. The laboratory should establish procedures for transferring authority within the laboratory
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during the incident to ensure that they can continue to provide efficient incident support. These
procedures should include notification to the ASR or PRL that the laboratory's POC has changed.
Responding laboratories should consider setting up a laboratory specific command center during the
response that will serve as their headquarters for managing the incident. Ideally, the command center will
have multiple phone lines with voice mail, computer access, and a fax machine. The command center
should be staffed by the following, as needed:
Laboratory's POC
Back-up POC
Clerical/phone support
Quality Assurance Officer (QAO)
Information Technology Support
PIO
See the Command Center and Ongoing Communications section of Appendix B for activities coordinated
by the Command Center.
The Help Sheet for Requesting Analytical Support during Water Emergency Response (Appendix C) and
the Incident Communications Tracking Form for Laboratories (Appendix D) may be used by the
laboratories to facilitate the communication of information necessary for a laboratory to provide support
during a drinking water contamination incident. This help sheet is divided into two parts: the first part is
for documenting communication between the ASR and the PRL, and the second part is for documenting
communication between the PRL and MSLs. These forms can be completed electronically, and
laboratories may wish to send the completed help sheet to the appropriate MSLs (via a secure means) to
ensure that the laboratories have all needed information. In addition to using the help sheets, other
activities the laboratories should undertake to ensure efficient communication during a response could
include:
Maintain communication logs to document all communication related to the incident
Email follow-up after phone conversations/conference calls to document information that was
provided, decisions that were made, and any follow-up action items
Confirm receipt of data sent electronically through a follow-up secure fax, email, or phone call
Provide written status reports or daily briefings to keep all the participants in a response informed
Designate a single person in charge that handles all information coming into and out of the
laboratory
Maintain a designated phone line and have someone to man the line at all times
Consider establishing a secure portal for posting and transfer of data and other incident-related
information
2.8 Health and Safety
During an event which requires activation of the WLA-RP system, samples may be collected that are of
unknown contamination type, and are the results of an intentional contamination activity. The ASR and
PRL should provide all information available regarding potential sample hazards to the support
laboratories receiving samples. Laboratories may elect to reject samples suspected of containing
contaminants which may be hazardous to laboratory personnel. If a laboratory chooses to accept samples,
the laboratory management and personnel should be familiar with the protective measures required if a
sample is considered an unknown and/or law-enforcement sensitive. For unknowns, elevated levels of
personal protective equipment (PPE) should be worn by field and laboratory teams that come in contact
with the sample.
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Section 3.0 Operations and Procedures
This section of the plan addresses the following:
Sampling (Section 3.1)
Sample Brokerage, Tracking, and Transport (Section 3.2)
Analysis (Section 3.3)
Internal Data Review (Section 3.4)
Data Reporting (Section 3.5)
Secure Data Transfer and Storage (Section 3.6)
Analytical Data Validation (Section 3.7)
Data Interpretation (Section 3.8)
Record Keeping (Section 3.9)
Training (Section 3.10)
Exercises, Evaluation, and Corrective Actions (Section 3.11)
Finance and Administration (Section 3.12)
Laboratories should be familiar with all procedures detailed in the WLA-RP, and maintain appropriate
SOPs and good laboratory practices to perform these actions.
3.1 Sampling
During the early stages of an event, upon initial contact by the ASR, the PRL may be responsible for
gathering critical information pertaining to the nature of the samples to be collected. At this time, the PRL
may also provide guidance to the ASR, or directly to field personnel on sampling requirements (e.g.,
containers, holding times and conditions, chain of custody, health and safety considerations for sample
collection, etc.) and development of a sampling plan. Laboratories should follow their existing procedures
for sample security and integrity unless otherwise instructed. Laboratories may utilize the Help Sheet for
Requesting Analytical Support during Water Emergency Response (Appendix C) to ensure that the
critical questions are asked and that necessary information is recorded. Laboratories should also
communicate with samplers to discuss the number of samples required, prioritize samples, and alert the
member laboratories.
Depending on the information available regarding the nature of the incident, the PRL may contact other
laboratories before providing specific sampling guidance. Analytical methods sometimes have specific
sample preservation requirements; therefore, it is good practice to confirm what methods are being used
and to convey method-specific preservation requirements to the samplers. If the ASR elects to follow the
standard PRL/MSL scheme, the PRL is also responsible for passing along the critical information
provided by the ASR regarding the nature of the samples to any MSLs that will assist with the analyses.
Laboratories should aim for real-time, constant communications between all parties involved in response.
In supporting sample collection, laboratories may also utilize the following resources:
USEPA, Response Protocol Toolbox (RPTB) EPA 817-D-03-001 to 007, December 2003
provides guidance on sampling and related safety issues
(http://cfpub.epa.gov/safewater/watersecurity/home.cfm?program_id=8#response_toolbox)
USEPA, Sampling Guidance for Unknown Contaminants in Drinking Water; EPA 817-R-08-003,
November 2008.
http://www.epa.gov/safewater/watersecurity/pubs/guide watersecurity samplingforunknown.pdf
NEWWA Sampling Guide for First Responders to Drinking Water Contamination Threats and
Incidents; November 2008. (http://www.newwa.org/Links/Research Orgs.htm)
Appendix F: Example Field Testing Results Form
Standardized Analytical Methods for Environmental Restoration following Homeland Security
Events (SAM) companion documents (http ://www.epa.gov/sam/). These documents provide
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method-specific sampling guidance regarding containers, preservation, holding time, and
shipping, as well as evaluating site information for EPA priority contaminants. For more
information, see Appendix M.
3.2 Sample Brokerage, Tracking, and Transport
Based on the initial field/safety screening and field investigation information available, the ASR will
contact a laboratory to serve as the PRL, according to the procedures described in Section 2.5. If the PRL
is unable to perform all of the necessary analyses, the PRL and the ASR will work to contact candidate
MSLs to determine whether they have the capability and capacity to accept samples. Before agreeing to
provide support, a laboratory should consider the following:
Capability
Capacity
Data turnaround
Management approval
Nature of threat
Level of analysis (i.e., screening or confirmatory analysis)
Proficiency or certification (if available for the contaminant of concern)
Availability of funding and/or vehicle for reimbursement
Required level of internal chain of custody
Special conditions (e.g., data ownership)
Number of samples
Duration of support
Estimated concentration
Data quality objectives (end-use)
Availability of supplies
Acceptance or rejection of samples will be based on individual samples (i.e., a laboratory can accept or
reject samples at any time during the lifetime of the event). A laboratory's participation in a specific
incident is at the discretion of the individual laboratory's management and may require consultation with
higher level management in the parent organization before the laboratory agrees to provide analytical
support. If samples are collected, shipped, and/or preserved in a manner that may affect sample integrity,
the PRL should notify the ASR as soon as possible. The laboratory should discuss with the ASR the use
of the data and possible impacts of sample integrity issues on the validity of any data generated.
Consideration of possible impacts on data quality should be weighed against the monitoring objectives
(e.g., the need to obtain rapid preliminary identification of the contaminant) before making a decision to
accept or reject samples. Any results generated from analysis of samples with shipping or preservation
issues should be appropriately qualified. Although sample acceptance (or rejection) is ultimately the
laboratory director's or higher level management's prerogative, laboratories should consider the following
before accepting samples:
Sample integrity (i.e., condition)
Sample packaging and preservation
Sample volume
Chain of custody provided
Minimum documentation provided
Potential sample hazards
Field/Safety screening results (e.g., radiation, explosives)
Law enforcement involvement or requirements
Special instructions from the ASR
Availability of additional, identical samples (splits)
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3.2.1 Sample Brokerage
Based on the information from field/safety screening and field investigation, the ASR will distribute
samples as directed by the PRL to the laboratories providing assistance (the PRL and MSLs, if
necessary). Accepting samples does not obligate a laboratory to provide support throughout the life cycle
of an incident. Laboratories will need to consider the rate at which samples will arrive so they can
accommodate holding time or needed response time. Information on the number, type, and volume of
samples and the required data turnaround times should be recorded in a laboratory notebook or the Form
Requesting Analytical Support during a Water Emergency Response (Appendix C). In the event that an
MSL determines it can no longer provide analytical support, the MSL manager or designee should contact
the PRL to request that sample shipment be stopped. If samples are in route to the MSL, a mutually
agreeable plan to ship samples to the PRL, ASR, or another MSL will be developed. If samples are
received, but the laboratory subsequently determines it does not have the required capabilities for
analysis, the samples will be rerouted by the PRL or ASR. Note: This plan assumes that most laboratories
are participating on a voluntary basis. Laboratories participating under a contract may not be able to
refuse samples, depending on the terms of their contract.
The following items should be considered during sample brokerage:
Hazard. This plan is designed to cover only water samples, and is not intended for hazardous
materials or other types of sample matrices. During certain serious situations (e.g., time-sensitive
public health issues), decisions will be made at a local, state, or federal level regarding how true
unknowns will be handled. Water samples with true unknown contaminants will only be shipped
to those laboratories with the capability to accept and assess unknown contaminants. Laboratories
should consult EPA's CETL to determine all-hazard receipt laboratories and their capability to
analyze unknowns. Laboratories with such capability should be advised of the unknown nature
prior to sample shipment and agree to accept the samples. Some resources are available (Civil
Support Team (CST) and OSC) to perform field screening in order to determine the nature of the
contaminant prior to sample shipment. Note: Field screening that can be provided by CSTs is
very limited.
Matrix. Laboratories should have procedures for properly separating a contaminant from its
matrix. Prepared samples may be sent to another laboratory for analysis, if the laboratory that has
separated the contaminant from its matrix (e.g., concentrated or extracted) does not have
procedures to complete an analysis. Laboratories should be aware of the impact this may have on
data quality.
Contaminant type. Laboratories should be able to perform appropriate methods for the
contaminant or contaminant type tentatively characterized and/or identified during field
investigation and screening. In addition, certain contaminants (e.g., select biological agents and
chemical warfare agents) can only be handled by laboratories with appropriate containment and
methods.
Level of contamination. If contamination levels are high, rapid qualitative and quantitative
methods may be appropriate for use. For trace level contamination, more sensitive methods may
be required. Contaminant levels may be unknown when samples are first analyzed, so the PRL
and MSL(s) should agree upon screening and/or confirmatory methods to use.
In-house capacity. The PRL should contact MSLs during the brokerage process to ensure that
their stated capabilities and capacities are true at the given moment (e.g., that all instrumentation
personnel, and (secure) storage are available). During this process, laboratories will need to
consider prioritization of existing and incoming samples requiring analysis (with consideration of
sample aging, equipment recalibration, and other issues). Laboratories may also need to ship
extracts and/or digestates in certain situations, and should be aware of the possible repercussions
on related QC.
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3.2.2 Sample Tracking
A chain-of-custody form should be initiated at sample collection. The PRL should establish a standard
format for sample identification that can be used for sample tracking, and this format should be conveyed
to the samplers and the MSLs. Once samples are relinquished by the field investigation team and received
at the laboratory, normal laboratory procedures should be followed regarding chain-of-custody, unless
other procedures are necessary (e.g., evidentiary chain-of-custody). This chain-of-custody form should
follow the sample throughout the process and include information describing when the sample was
collected, who has handled the sample, and who was in possession of the sample. If samples are received
at the laboratory, but not listed on the chain-of-custody, laboratories will contact the sampler to obtain the
additional information and will document the additional sample(s) through normal laboratory procedures
(e.g., complete a non-conformance document and file accordingly). Existing chain-of-custody forms will
be used; however, laboratories should ensure that the chain-of-custody form provided with samples
includes the minimum elements necessary through use of the Help Sheet for Requesting Analytical
Support during Water Emergency Response in Appendix C. An example chain-of-custody form is
provided in Appendix G and a list of minimum data elements is provided in Appendix H.
If samples need to be handled as law enforcement sensitive, the ASR needs to notify laboratories prior to
shipping. To ensure that data is protected for evidentiary purposes, it is important that laboratories know
or are informed of what is required of the laboratory by law enforcement groups. This may include
ensuring that custody tape is intact on sample containers and/or coolers, that the sample is tracked on the
chain-of-custody form more closely throughout the sampling and analysis stage, and that the results may
need to be shared with law enforcement entities. Good communication with appropriate individuals or
organizations will ensure that all necessary criteria are met during an event. Additional guidance on
handling criminal investigation samples is provided in Appendix I. WLA and ERLN member laboratories
providing support to an incident under contract to EPA may be required to follow the guidelines on
handling criminal investigation samples specified in Appendix I. This may also be a requirement for
laboratories providing support to the incident under other contract mechanisms, depending on the
specifics of the contract.
Laboratories should follow their existing procedures, unless otherwise requested, for intra-laboratory
sample transfers, and for identifying and tracking split samples created after sample receipt at the
laboratory.
Once a sample has been received by a laboratory, that laboratory may use its own internal tracking
procedures, provided the sample can be tracked back to the original sample received and identified by the
provided chain-of-custody. Procedures within a given laboratory may include secure sample storage and
sample and extract log-in/log-out forms to document the chain-of-custody, rather than a single form.
Should a responding laboratory ship a split sample, extract, or digestate to facilitate additional analysis at
another laboratory, it is essential that each aliquot be uniquely identified (coded) and that the chain-of-
custody form reflecting this split of the original field sample accompany it.
3.2.3 Sample Transport
Although it is not expected that the PRL or MSLs will need to ship samples (this is the responsibility of
the ASR), the PRL may need to advise the ASR on sample transport issues or ship samples to MSLs if the
PRL cannot analyze samples. As such, all laboratories should have personnel trained in shipping
regulations. Personnel in charge of transporting samples from the site to the PRL and/or MSLs must
ensure that sample packaging is in compliance with U.S. Department of Transportation (DOT) and, if
applicable, International Air Transport Association (IATA) regulations regarding the transfer of
hazardous substances and environmental samples. These regulations, CFR49 Parts 171 through 180 for
DOT and the Dangerous Goods Regulations (DGR) for IATA, provide specific details regarding proper
marking, labeling, use of placards, and packaging and shipment of hazardous materials, substances and
wastes, as well as regulatory exceptions. The PRL will also advise the ASR to follow any state
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regulations governing these activities. The state drinking water agencies may also be able to provide
advice and assistance with sample shipping.
The PRL can refer the ASR to information regarding the appropriate labeling and packaging of sample
transport containers at: http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&sid=5bOf467f91a98f9cf6833dbda89429af&rgn=div6&view=text&node=49:2.1.1.3.7.2&idno
=49 (This link contains Hazmat tables.) Additional information on transport procedures and training will
eventually be available in the companion documents to the EPA National Homeland Security Research
Center's (NHSRC) Standardized Analytical Methods for Environmental Restoration following Homeland
Security Events (SAM). Laboratories are strongly encouraged to take courses on Dangerous Goods
Regulations and Shipping Guidelines for Infectious Substances (if analyzing or shipping biological
samples). Information on courses available through IATA can be found at
http: //www. iata. org/training/cargo/.
3.3 Analysis
Before samples are transported to laboratories from the sampling site, the PRL will need to work with
MSLs and the ASR to revise or develop an analytical approach, including QC requirements and internal
custody, if required. Unless the ASR and/or PRL requests that the MSL follow project-specific sample
preparation, analysis, quality control, data reporting and/or verification procedures, the MSL will utilize
its in-house SOPs. It is the responsibility of the ASR and PRL to advise the MSL of any special
analytical, quality control, or reporting procedures.
The analytical approach may be divided into three stages: Basic Field/Safety Screening (Section 3.3.1),
Rapid Laboratory Analyses (Section 3.3.2), and Confirmatory Analyses (Section 3.3.3). Depending on the
nature of the contamination incident and available resources, the laboratory analyses may occur at one or
more laboratories. The analytical approach is anticipated to change as the incident progresses. During the
initial phases of the incident, the focus will likely be on obtaining results as soon as possible. Rapid
laboratory methods will be favored, and reducing QC to decrease data turnaround times may be
acceptable. (See Section 3.3.5 for additional guidance on appropriate QC). As the incident progresses to
remediation and recovery, the focus of analysis will change. Confirmatory analyses performed using a
consistent approach by qualified laboratories performing full QC will be needed. When developing the
analytical approach, the requester should be sure to convey the objectives of the monitoring (e.g., initial
contaminant detection, determining if clean-up goals have been met) and data turnaround times to the
supporting laboratories in order that appropriate methods can be selected. Based on this information, the
PRL should work with the ASR to develop an agreed-upon analytical approach.
Laboratories should consider what steps can be taken to reduce data turnaround times, in addition to use
of rapid methods and performing abbreviated QC. Laboratories that have already begun sample
processing, but cannot complete all necessary analyses, may wish to ship processed samples (e.g., sample
extracts, biological isolates) to an MSL for additional analyses. If processed samples are shipped to
another laboratory for analysis, this should be documented on the accompanying chain-of-custody form
and any impacts on data quality (e.g., holding time violations) should be documented. Laboratories may
also prepare standards and calibrate instruments ahead of time to allow sample processing to begin as
soon as samples arrive at the laboratory, provided that enough information about the contaminant and
contaminant concentrations is known.
Screening analyses do not require the use of a particular procedure; however, there are available
procedures for performing screening analyses, such as the All-Hazard Receipt Facility (AHRF) protocol,
which should be leveraged by laboratories. Contaminants that may be accidentally or intentionally
introduced into drinking water may not fall within the suite of analytes that environmental laboratories
typically monitor in drinking water. Environmental laboratories should work with other divisions of their
laboratory (e.g., public health division) to utilize their full capability to perform analysis for non-routine
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contaminants (especially biological contaminants), including use of mass spectral library searches to
tentatively identify unknown peaks when using GC/MS and LC/MS. For example, the environmental
section may filter and culture biological samples and then provide the isolates to their clinical laboratory
for identification.
As analyses are completed at the PRL or MSL laboratories, the PRL should coordinate the review and
reporting of results to the ASR (Section 3.6).
3.3.1 Basic Field/Safety Screening
The earliest stage of analysis is Basic Field/Safety Screening. The purpose of this stage is to provide
additional credible information for sample threat assessment; screen for high risk radioactive and
chemical warfare agents to protect laboratory personnel and facilities; and to tentatively identify potential
contaminants. This screen may occur in the field or at an AHRF, and may include the target parameters,
screening techniques, and methods listed in Table 3-1. The EPA CETL and other local or regional
resources should be consulted to identify a laboratory with the capability to analyze the samples or to
perform analysis of unknowns. If no AHRF is available, the WLA-RP team may need to work to identify
other laboratories that can accept the samples for screening and analysis.
It is always incumbent upon the receiving laboratory to review Basic Field/Safety Screening data to
assess the hazard a sample may present before the sample is shipped. This information should be
conveyed to the laboratory receiving the samples as soon as it is available, and a copy of the field
screening information should be shipped with the samples. Samplers should list the PPE used by the field
samplers on the chain-of-custody form. If field screening is inadequate, incomplete, or otherwise
compromised, the laboratory may require additional screening before acceptance.
Safety screening at the laboratory is termed triage and is conducted in an AHRF, or equivalent high-
hazard laboratory area. If a laboratory does not have AHRF capability, the laboratory should consider
their ability to handle the samples and any field screening and threat information before deciding whether
to accept the samples. No screening techniques for biological agents in drinking water are currently
identified in SAM; and as such, true unknown samples should be treated as if they are biologically active
if available information suggests that they may pose such a threat. The field screener will communicate
results and characterization to the laboratory as presumptive. Samples can be rejected by the laboratory
manager or senior staff if accepting the samples could put the laboratory at risk for liability (e.g., health
and safety issues, equipment loss). Resources are expected to be available (CST, OSC) during these
situations to perform field screening.
Table 3-1. Basic Field/Safety Screening1
Target Parameter
Radiochemical
Free Cyanide
pH/conductivity/ORP
Chlorine residual
Volatile chemicals
VOC(PID), CO, H2S, O2
Chemical Warfare Agents
Example Field Instruments or Kits
Ludlum Model 2241 -3K
Hach Model DR890
Myron Ultrameter6P
Hach Model DR890 Colorimeter
Photo ionization detector (PID) (e.g.
ppbRAE)
MultiRAE
M272 Water Testing Kit
The information in this table was developed by the Office of Water in support of the Water Security Initiative pilot.
In addition to field screening data, any available information on threat credibility should be
communicated to the laboratory for sample threat assessment. A credible threat may be indicated by the
following:
Unauthorized individuals present at the site
Signs of tampering or unusual containers
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Fire or other obvious hazard
Signs of a potential explosive hazard (e.g., devices with exposed wires)
Signs of a potential chemical hazard (e.g., dead animals, dead or stressed vegetation, unusual
fogs, unusual odors)
Unusual and unexplained equipment at the site
Notification that a person or group has made threats to contaminate a water supply (or other
target)
Other signs of immediate hazard
3.3.2 Rapid Laboratory A nalyses
The ASRmay request that laboratories perform rapid analyses for time sensitive situations. This would
normally be during the initial phases of an investigation during which public health concerns are
paramount. Rapid analysis may be used as an initial screening tool. Examples of rapid laboratory analyses
include 'shake and shoot' sample preparation for extractable organics, headspace procedures for volatile
organic analytes (VOAs), immunoassays for various classes of compounds, and real-time polymerase
chain reaction (PCR) technology methods for biological agents. Until EPA provides national guidance on
the use of rapid analytical procedures, laboratories should follow their existing procedures regarding the
use of rapid laboratory analyses. Many of these analytical approaches are in common use for other
programs where rapid, indicative techniques may be suitable for producing data for real-time decision-
making. For information on NHSRC's development of rapid laboratory analyses (companion document to
SAM), see Appendix M.
Because some of these tests may not be fully validated "standard" methods and/or may not provide highly
accurate quantification of the contaminants in question, laboratories are urged to develop internal QA/QC
data to support their use of the procedures and to always report data as "Preliminary Data Pending
Confirmation" (see Section 3.4 for more information on the release of preliminary data). Response
laboratories should document the QC performed for rapid laboratory analyses, as well as any limitations
to the data. The EPA Response Protocol Toolbox, Module 4, has additional guidance on basic analytical
screening of drinking water samples for general unknowns
(http://cfpub.epa.gov/safewater/watersecuritv/home.cfm7program id=8).
3.3.3 Confirmatory Analyses
Confirmatory methods are used to verify the results of rapid laboratory analyses (if those methods have
been employed). For some analytes, the confirmatory method may be sufficiently expedient with full QC
procedures to obviate the need for a rapid laboratory analysis, and in some cases may be the only method
available for a particular analyte. The methods performed by the support laboratories will depend on the
phase of the incident (initial rapid response vs. remediation and recovery) and the capability of the
laboratories providing the support. During the response and remediation phase of an event, there is a
greater need for consistent and reliable data generation.
To ensure comparability of results, the ASR or PRL should work together to select the appropriate
methods to meet the monitoring objective. A list of potential method options, in descending order of
preference, is as follows:
1. SAM 5.0 (See Appendix M for more information)
2. EPA Certified Drinking Water Methods
3. Other applicable EPA methods (e.g., SW-846 or 40CFR136 methods)
4. Other methods performed by the laboratories (such as Standard Methods or ASTM)
NHSRC has recently published SAM 5.0, which identifies preferred confirmatory methods. See Appendix
M for additional information on SAM and Standard Analytical Protocols (SAPs). However, the methods
contained in SAM:
Do not include structured step-by-step methods for all analytes,
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Have not been validated for all analytes, and
Many are not specifically applicable to EPA's Drinking Water Program.
Confirmatory methods should be performed by competent, experienced laboratories. It is expected that
laboratories will have established SOPs for all of their confirmatory methods, and that those methods will
require extensive QC samples/analyses to verify and document the quality of the data, including new
analytes added for identification of unknowns. Any laboratory that is accredited under NELAP (National
Environmental Laboratory Accreditation Program) or A2LA, using NELAC (National Environmental
Laboratory Accreditation Conference) standards or certified under EPA's Drinking Water Certification
Program (or an equivalent state or regional program) should be deemed capable of performing
confirmatory methods for which it has been accredited. This includes using the accredited method to
identify contaminants that are not included in the laboratory's certification/accreditation. Requirements
for certification may vary from state to state. Decisions regarding the requirements for laboratory support
will be incident specific and will be made by the ASR or other responsible party.
In the instance where all federal, state, and municipal laboratories cannot accept samples, the PRL should
contact the appropriate ICS resource to identify non-governmental or commercial laboratories that might
be capable of performing those chemical or biological analyses. The qualifications and performance of
those laboratories should be evaluated by the PRL or ICS designee prior to use.
3.3.4 Sample Disposal
Disposal of samples should adhere to requester (e.g., ASR) direction. Law enforcement may have forensic
needs that, depending on the nature of the incident, may require laboratories to retain samples as
evidence. Alternatively, the ASR may request that samples be returned to the ASR for disposal during
remediation and recovery. Procedures for sample disposal should be decided upon when a laboratory is
first contacted to provide support, if possible. Samples may also be returned to the ASR as a precondition
for sample acceptance by the support laboratories. Sample disposal should not occur until the contaminant
and concentration is identified. Samples may require autoclaving or other processing (e.g., neutralization,
precipitation, or phase separation) prior to disposal.
If disposal is to take place at the testing laboratory through normal procedures, consultation with the
responsible Hazardous Waste Coordinator (for chemical agents) or Emergency Medical Services
Coordinator (for biological agents) may be required, due to the possibility of introducing a broader range
of contaminants into a laboratory's waste stream than may be associated with its normal operations.
3.3.5 Quality Assurance/Quality Control
QC pertains to sample collection, sample analysis, and data reporting. Although sample collection is not
under laboratory control, QC during this step is an important consideration during interpretation of
analytical results. Laboratories should request sample QC information during preliminary discussions
with the ASR.
The level or amount of QC necessary depends on the data quality objectives of the activity, which should
be decided by the ASR based on discussion between the ASR and the PRL prior to sample analysis (and
preferably prior to sample collection). Reduced levels of QC might be acceptable when rapid data
turnaround and initial detection are the goals. When quantitative results are needed to confirm that
remediation efforts are successful or the system can be returned to service, more extensive QC will be
required. All relevant QC should be performed and documented as agreed by the PRL and MSL, unless
unique circumstances prevent the QC. If it becomes necessary to reduce or alter the agreed-upon QC
procedures, the PRL and ASR should be notified as soon as possible.
Method QA/QC requirements should be followed, depending on the monitoring objectives, and if time
allows. The following is the minimum recommended QC that should be performed for rapid and
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confirmatory methods (confirmatory methods may require additional QC depending on use of the data
and the requirements of the method) to verify that the method is performing acceptably:
Chemical analytes
Method blank
Analytical duplicates/replicates
Calibration verification
Laboratory Control Sample (LCS) or Laboratory Fortified Blank (LFB)
Radiochemical analytes
Calibration check
Background check
Duplicate
Blank
Biological analytes
Positive control
Negative control
Blank
Member laboratories should be prepared with calibrated instruments, appropriate standards, method-
specific standard analytical procedures, and qualified and trained technicians. Laboratories should also be
capable of providing rapid turnaround of sample analyses and data reporting if agreeing to accept samples
for rapid analysis. The ASR should work with the support laboratories to determine if they have sufficient
capabilities to provide the required analytical support. MSLs should provide all QC data to the PRL, in
addition to a narrative description of observations, tentative identifications, and QC deviations.
3.4 Internal Data Review
During response to a contamination incident, concerns for public health may decrease the time period
available for initial laboratory analyses and corresponding data review. If a PRL is required by the ASR to
provide data that have not undergone adequate internal verification, but the analysis has been completed,
the laboratory will label results as "Preliminary Data Pending Confirmation," with the understanding that
confirmed data will follow as soon as they are available. MSLs should report preliminary data to the PRL
only. Ideally, preliminary data would only be released by the laboratory performing the analyses during
the initial phases of an incident. These results should be accompanied by documentation of the level of
QA/QC performed.
Throughout the analytical process, frequent communication between the PRL and the ASR and between
the PRL and the MSL(s) is necessary to clarify and negotiate the timeframe required for preliminary and
confirmed data. These discussions should include specific expectations on the level of data verification
that will occur within the given timeframe.
During the data review process, each laboratory should follow their existing procedures for QA data
review and specific laboratory roles for data approval. The overall data generation and reporting process
may entail the following steps:
1. Data generation
2. Data reduction
3. Raw data package generation
4. Analyst review
5. Peer review
6. Final data package generation
7. QA review
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8. Sign off by laboratory manager with a statement that analysis has been performed using the
proper methodology and proper QA
9. Data release
In addition to the requirements described above, laboratories should ensure the following before reporting
results:
If possible, confirm the presence of contaminants using standardized methods
Provide appropriate caveats to the validity of data, including any QA/QC issues that may have
been observed
Maintain documentation of all communications and chain-of-custody
Report results only to designated authority (MSLs to the PRL; PRL to the ASR)
3.5 Data Reporting
Under the WLA-RP, multiple laboratories may provide analytical support during a drinking water
emergency. It is highly recommended that laboratories submit analytical results via an electronic
spreadsheet (Excel or other appropriate format) using the columns given in Appendix E. WLA and ERLN
member laboratories providing support to an incident under contract to EPA may be required to submit
results using the format specified in Appendix E. This may also be a requirement for laboratories
providing support to the incident under other contract mechanisms, depending on the specifics of the
contract. Laboratories may also need to submit additional data (in hardcopy or electronic format) in order
for the ASR/PRL to perform a stage 2 validation. The hardcopy or electronic format for these additional
data will need to be agreed upon by the ASR and the PRL.
Laboratories may share data by the following means: submitted via email, posted to a secure Web site, or
a hard copy submitted via facsimile (fax). Laboratories also acknowledge that results may be reported via
telephone, with a full written report provided as a follow up.
For the purposes of the WLA-RP, the ASR owns the data. See Section 2.7 for outside factors that may
require the laboratory to release data to parties other than the ASR or PRL. In these cases, the laboratory
should notify the ASR prior to release if possible.
3.6 Secure Data Transfer and Storage
Laboratories will exchange data through the agreed upon method designated by the ASR [e.g., file
transfer protocol (FTP), secure fax, secure email, hand deliver, etc.]. However, on an incident-specific
basis, a different method of data exchange may be requested. Data transfer should balance security needs
with the need to rapidly transmit data to support an emergency response. In all cases, the PRL should
discuss data transfer requirements with the MSL(s) prior to sample analysis. Likewise, the PRL should
discuss data transfer requirements with the ASR prior to data exchange. In the long-term, laboratories
may adopt a standard data format that is compatible across the Laboratory Information Management
Systems (LIMS) of different laboratories.
3.7 Analytical Data Validation
Based on discussions with the ASR, the PRL may be asked to consolidate and validate analytical data
quality aspects of results reported by the MSLs. Alternatively, if the ASR is directly interfacing with all
laboratories, the ASR or a designee may perform this function for data received from all laboratories. The
ASR or PRL should inform the laboratories prior to the beginning of analysis of what data the laboratory
will be required to submit for data validation. The following information should be checked by the
responsible party (also known as stage 2a validation) as applicable to chemical, radiochemical, and
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biological analyses (for more information see: http://www.epa.gov/superfund/policy/pdfs/EPA-540-R-08-
005.pdf):
(1) Documentation identifies the laboratory receiving and conducting analyses, and includes
documentation for all samples submitted by the project or requester for analysis.
(2) Requested methods (handling, processing, preparation, cleanup, and analysis) are performed.
(3) Requested target analyte results are reported along with the original laboratory data qualifiers and
data qualifier definitions for each reported result (and the uncertainty of each result and clear
indication of the type of uncertainty reported, if required, e.g., for radiochemical analyses).
(4) Requested target analyte result units are reported (along with their associated uncertainty units, if
required, e.g., for radiochemical analyses).
(5) Requested reporting limits for all samples are present, and results at and below the requested
(required) reporting limits are clearly identified (including sample detection limits if required).
(6) Sampling dates (including times if needed), date and time of laboratory receipt of samples, and
sample conditions upon receipt at the laboratory (including preservation, pH and temperature) are
documented.
(7) For radiochemical analyses, the sample-specific critical values (sometimes called "critical level,"
"decision level" or "detection threshold") and sample-specific minimum detectable value, activity
or concentration for all samples are reported and results at and below the requested (required)
critical values are clearly identified.
(8) For radiochemical analyses, the chemical yield (if applicable to the method) and reference date
and time (especially for short-lived isotopes) is reported for all samples (as appropriate).
(9) Method dates (including dates, times and duration of analysis for radiation counting
measurements and other methods if needed) for handling (e.g., Toxicity Characteristic Leaching
Procedure), processing, preparation, cleanup and analysis are present as appropriate.
(10) Sample-related QC data and QC acceptance criteria (e.g., method blanks, surrogate recoveries,
deuterated monitoring compounds (DMC) recoveries, laboratory control sample (LCS)
recoveries, duplicate analyses, matrix spike and matrix spike duplicate recoveries, serial dilutions,
post digestion spikes, standard reference materials) are provided and linked to the reported field
samples (including the field quality control samples, such as trip and equipment blanks).
(11) Requested spike analytes or compounds (e.g., surrogate, DMCs, LCS spikes, post digestion
spikes, matrix spikes and matrix spike duplicates) have been added as appropriate.
(12) Sample holding times (from sampling date to preparation and preparation to analysis) are
evaluated.
(13) Method QC (e.g., Frequency of QC samples, QC sample criteria) are evaluated.
(14) Raw data are provided for biological analyses (to confirm or recalculate results).
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3.8 Data Interpretation
During an incident, the PRL (or an MSL) may be requested to interpret the results for the ASR. However,
data use is not the responsibility of the laboratory and is beyond the scope of the WLA-RP. If laboratories
are called upon to provide such information, they should refer the ASR to resources available to aid the
ASR in interpreting data (e.g., epidemiologists, toxicologists, EPA's Red Team, Water Contaminant
Information Tool (http://water.epa.gov/scitech/datait/databases/wcit/index.cfm).
3.9 Record Keeping
Laboratories should maintain all records and data needed for a third party to verify and reconstruct
analytical results. Laboratories will inform the ASR and PRL that they will follow their existing
procedures, if specific guidance is not provided. These procedures include what records must be
maintained (e.g., incident logs, chain-of-custody, LIMS reports, sample and analytical records), the
timeframe for retention, and requirements for record destruction. However, record retention must occur as
required by law, unless otherwise directed. Laboratories should contact the ASR or responsible party,
when possible, before disposing of hard copy documents. EPA and/or state regulations may require that
original hard copy records remain at the laboratory; if a request is made for the originals, the laboratory
will inform the requester that only copies can be provided. Laboratories should also follow existing
procedures for criminal evidence requirements, unless the ASR indicates that specific requirements need
to be met when first contacting the PRL.
Laboratories participating in an emergency response should be aware that not all records may be exempt
from FOIA or other legal authorities (see Section 2.7). When necessary, the PRL should direct the MSLs
on how to respond to such requests, based on the guidance provided by the ASR when analytical support
is first requested.
3.10 Training
The objective of training is to create awareness and enhance the skills required to plan and execute
analytical support for a drinking water emergency. A basic assumption of this plan is that laboratories are
familiar with, and proficient in, the analytical methods they agree to perform as part of the WLA-RP.
From this perspective, it is anticipated that no additional training in new methods will be required.
However, laboratories should ensure that all personnel have received appropriate and documented
training to carry out the role of PRL or MSL. Training and familiarity with the WLA-RP are important.
Laboratories need staff trained in IATA and DOT shipping regulations and the LIMS. In addition, the
primary through tertiary contacts for each laboratory should have at least 100- and 200-level ICS training.
For more information refer to the FEMA training site at: http://training.fema.gov/IS/crslist.asp. Other
personnel that may be involved in coordination during a response are recommended to receive training in
ICS.
Laboratories should consider training in new methods as they become available [e.g., Clean Water Act
(CWA) methods], if they are considering implementing these methods. Additional training opportunities
from the Association of Public Health Laboratories' (APHL) National Laboratory Training Network
(NLTN) should be leveraged, when available. Training in data formats (e.g., Staged Electronic Data
Deliverable (SEDD) 2a) or data management tools (such as Scribe) may occur on a lab-specific basis.
Annual laboratory meetings may be leveraged as an opportunity for centralized training on an ad hoc
basis. Training records should be maintained for all current personnel.
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3.11 Exercises, Evaluations, and Corrective Actions
At the minimum, a review of the WLA-RP will occur once every two years and will be coordinated by
EPA WSD. At this time, no set frequency will be established for exercises to test the WLA-RP. However,
laboratories should take advantage of opportunities to test the WLA-RP (e.g., WSD-sponsored table-top
and functional exercises, state exercises, etc.). In addition to participating in table-top and functional
exercises, there are activities (e.g., practicing data transfer) that laboratories can undertake individually or
in small groups to practice and prepare for participation in a response (See Appendix K). Some exercises
may only involve certain portions of the plan (e.g., data exchange).
After completion of an exercise or an actual response, an assessment will occur to review the exercise or
incident outcomes, identify program shortfalls, and recommend necessary corrective actions. To aid in the
development of the assessment, an example Close-out Action Checklist has been included in Appendix J.
The issues identified will be documented in an After-Action Report. When an assessment is initiated as a
result of a water contamination incident, EPA will coordinate with participating laboratories to conduct
the review and will lead the effort to develop a report. Laboratory-specific changes will be made by those
laboratories according to their procedures.
The WLA-RP may be updated based on the After-Action Report corrective items. Documentation of the
entire corrective action process should be maintained to ensure a clear understanding and effective
resolution of current and future deficiencies. All changes made to the WLA-RP must be noted in the
Change Control table at the beginning of this plan. Development of future exercises should account for
these changes, and should be designed to test whether the underlying issues have been resolved.
Note: Appropriate corrective actions may not be taken due to budgetary constraints or will be deferred as
a part of the long-range capital project. However, temporary actions may be adopted in the interim until
funds are provided to implement the desired option.
3.12 Finance and Administration
This plan does not establish mechanisms for laboratories that provide support to receive financial
assistance to offset costs incurred during an emergency response under this plan. This plan does not
obligate additional expenditures by any laboratory, as all laboratories have the ability to decline to
provide support for any reason. The following resources outside of the WLA-RP may be used for
assistance with cost reimbursement:
Emergency Management Assistance Compact (EMAC) (state to state): www.emacweb.org
Stafford Act (including ESF #3 and #10): www.fema.gov/government/grant/pa/reference.shtm
State and tribal assistance grants (STAG): www.epa.gov/compliance/state/grants/
Inter-agency grants or agreements
OSC funding mechanisms
Purchase orders
Commodities workgroup agreement amongst regional lab chiefs
Mutual Aid Agreements (e.g., Water/Wastewater Agency Response Network (WARN):
www .national warn .org)
When the potential exists for reimbursement, laboratories must maintain records of expenditures
associated with analytical support of an event, including the tracking of all personnel engaged in incident
activities, costs related to regular or overtime work, reagents, acquisition of equipment, overflow
laboratory costs (i.e., the cost of contracting laboratories to cover routine support), courier/transport costs
for samples, data reproduction, and storage and disposal of samples and/or records. Specific expenditures
to track will vary based on the situation. When reimbursement is possible under the Stafford Act,
laboratories should note that the project plan will explicitly list all expenditures that are available for
reimbursement. See Appendix P for Reimbursement Tips for Emergency Laboratory Support.
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Additional considerations may need to be made for fee-for-service laboratories based on their operational
constraints. Whether one of these laboratories can perform analyses will be determined on an incident-
specific basis.
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Appendix A List of Acronyms
A2LA American Association of Laboratory Accreditation
ADR Automated Data Review
AHRF All-Hazard Receipt Facility
APHA American Public Health Association
APHL Association of Public Health Laboratories
ASR Analytical Services Requester
ASTM American Society for Testing and Materials
AWWA American Water Works Association
CBR Chemical, Biological, and Radiochemical
CDC Centers for Disease Control and Prevention
CDX Central Data Exchange
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CETL Compendium of Environmental Testing Laboratories
CFR Code of Federal Regulations
CST Civil Support Team (Army National Guard)
CWA Clean Water Act
DGR Dangerous Goods Regulations
DMC Deuterated Monitoring Compound
DOT U.S. Department of Transportation
EDD Electronic Data Deliverable
EMAC Emergency Management Assistance Compact
EOC Emergency Operations Center
EPA U.S. Environmental Protection Agency
ERLN Environmental Response Laboratory Network
ERP Emergency Response Plans
ESF Emergency Support Function
EU Environmental Unit
FDA U.S. Food and Drug Administration
FEMA Federal Emergency Management Agency
FERN Food Emergency Response Network
FOIA Freedom of Information Act
FOSC Federal On-Scene Coordinator
FTP File Transfer Protocol
HMIC Hazardous Materials Information Center
HMR Hazardous Materials Regulations
HSPD Homeland Security Presidential Directive
IATA International Air Transport Association
1C Incident Commander
ICAO International Civil Aviation Organization
ICLN Integrated Consortium of Laboratory Networks
ICS Incident Command System
IT Information Technology
LCS Laboratory Control Sample
LFB Laboratory Fortified Blank
LIMS Laboratory Information Management Systems
LNO Liaison Officer
LRN Laboratory Response Network
MACS Multi-agency Coordination System
MSL Mutual Support Laboratory
NAHLN National Animal Health Laboratory Network
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NCP National Contingency Plan
NELAC National Environmental Laboratory Accreditation Conference
NELAP National Environmental Laboratory Accreditation Program
NEMI-CBR National Environmental Methods Index for Chemical, Biological, and Radiological
Contaminants
NHSRC National Homeland Security Research Center
NLTN National Laboratory Training Network
NRT National Response Team
NEWWA New England Water Works Association
OSC On-Scene Coordinator
PCR Polymerase Chain Reaction
PHMSA Pipeline and Hazardous Materials Safety Administration
PID Photo lonization Detector
PIO Public Information Officer
POC Point of contact
PPE Personal Protective Equipment
PRL Primary Responding Laboratory
QA Quality Assurance
QAPP Quality Assurance Project Plan
QC Quality Control
RLRP Regional Laboratory Response Plans
RPTB Response Protocol Toolbox
SAM Standardized Analytical Methods
SAP Standard Analytical Protocol
SEDD Staged Electronic Data Deliverable
SOP Standard Operating Procedure
STAG State and Tribal Assistance Grants
USC United States Code
USDA United States Department of Agriculture
VOA Volatile Organic Analytes
VOC Volatile Organic Compound
WARN Water/Wastewater Agency Response Network
WCIT Water Contaminant Information Tool
WEF Water Environment Federation
WLA Water Laboratory Alliance
WLA-RP Water Laboratory Alliance Response Plan
WSD Water Security Division
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Appendix B Checklist and Quick Reference Guide for PRL and
MSL Response during a Water Emergency
Purpose: This sheet should be used as a checklist and quick reference guide for laboratories supporting
an incident. References to appropriate sections of the Water Laboratory Alliance Response Plan (WLA-
RP) are provided in each section of this sheet.
INITIAL SUPPORT REQUEST
When the initial call comes in from the Analytical Services Requester (ASR) or Primary Responding
Laboratory (PRL) use the Help Sheet for Requesting Analytical Support during Water Emergency
Response (Appendix C) to collect the following:
H ASR contact information
D Site Characterization Information
D Field Screening Results (Basic Field/Safety Screening: Section 3.3.1 and Field Testing Results
Form: Appendix F)
D Information on types and number of samples
D Analyses required
D Data turnaround times and reporting requirements
D Sample disposal information
AGREEING TO PROVIDE SUPPORT
Prior to agreeing to provide support, the laboratory should consider the following (Sample Brokerage,
Tracking, and Transport: Section 3.2):
H Capability
D Capacity
D Data turnaround requirements
D Nature of the threat
D Required proficiencies and certifications
D Internal chain-of-custody requirements
D Management approval
D Funding
D Other special conditions
COMMAND CENTER AND ONGOING COMMUNICATIONS
Responding laboratories should take steps to ensure efficient communication during an incident
(Communications Logistics: Section 2.7.1)
H Set up a command center with multiple phone lines and computer and fax access
D Set up procedures for handling incident phone calls
D Designate points-of-contact and procedures for transferring information during shift changes
D Log all communications with the ASR and/or PRL
D Follow-up verbal conversations with emails to confirm information and document decisions
D Provide a daily status report and/or set up daily briefings with all participants
D Post Public Information Officer (PIO) contact information for any external inquiries
COMMAND CENTER STAFF
Responding Laboratories should have the appropriate staff available to respond to an incident
(Communications Logistics: Section 2.7.1)
H Set up a command center with multiple phone lines and computer and fax access
D Set up procedures for handling incident phone calls
D Designate points-of-contact and procedures for transferring information during shift changes
D Log all communications with the ASR and/or PRL
D Follow-up verbal conversations with emails to confirm information and document decisions
D Provide a daily status report and/or set up daily briefings with all participants
D Post Public Information Officer (PIO) contact information for any external inquiries
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IDENTIFY AND RECRUIT ADDITIONAL SUPPORT LABORATORIES (PRL ONLY)
If the PRL does not have the capability and/or capacity to fully address the analytical needs of the
incident, then it may be necessary to bring in additional laboratory support (Direction, Control, and
Coordination: Section 2.5).
H Determine that additional support is required
D Identify appropriate support laboratories (Roles: Section 2.5.1)
D Contact the laboratories to provide support
D Provide background information on the incident and available analytical results
SAMPLE BROKERAGE AND SAMPLE TRACKING
Section 3.2.1: Sample Brokerage, Section 3.2.2: Sample Tracking, and Appendix G: Example Chain-of-
Custody Form:
H Obtain sample tracking numbers
D Confirm that samples arrived in acceptable condition
D Confirm that appropriate chain-of-custody was received with samples
D Determine requirements for internal sample tracking
SAMPLE ANALYSIS
The ASR and PRL should consider the following when determining an analytical strategy (Analysis:
Section 3.3):
H Objectives of the monitoring (identification of contaminant vs. remediation and recovery)
D Data turnaround times
D Type of method: Rapid or Confirmatory (Rapid Laboratory Analysis: Section 3.3.2, and
Confirmatory Analysis: Section 3.3.3)
D Information regarding the type of contaminant
D Laboratory capabilities
D Level of Quality Control (QC) required (Quality Assurance/Quality Control: Section 3.3.5)
DATA REVIEW AND VALIDATION
Internal Data Review: Section 3.4 and Data Reporting: Section 3.5
H Mark data that has not undergone a complete review as "Preliminary Data Pending
Confirmation"
D Complete internal data review prior to releasing confirmatory data
D Determine if additional data validation is needed by PRL or ASR
DATA REPORTING
Document requirements for Data Reporting (Section 3.5) in the Help Sheet (Appendix C)
H Use the data reporting template (Appendix E)
D Confirm receipt of data submitted electronically
SAMPLE AND RECORDS RETENTION
Laboratories should follow their existing procedures regarding the following in the absence of alternative
guidance or specific instructions. Document requirements in the Help Sheet (Appendix C)
H Sample retention and disposal (Sample Disposal: Section 3.3.4)
D Data/records retention (Record Keeping: Section 3.9)
COMMUNICATIONS WITH THE MEDIA AND OTHER OUTSIDE PARTIES
Generally, communication with parties not directly involved in the response should be handled through
the ASR/PRL/MSL chain-of-command. Procedures for routing requests and providing information should
be established at the beginning of a response (Communications and Notification: Section 2.7).
H Establish procedures for handling requests for information
D Be aware of potential exceptions to communication structure (e.g., FOIA)
D Log all communication requests received and report to appropriate contact
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy 8-2
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Appendix C Help Sheet for Requesting Analytical Support during an
Emergency Response
Purpose: This sheet is designed to help discussions between the Analytical Services Requester (ASR) and the
laboratory. The ASR may be either the Incident Commander/representative or the Primary Responding Laboratory
(PRL). The Laboratory may be either the PRL or a Mutual Support Laboratory. The Laboratory should use this help
sheet to ensure that all critical information is exchanged. The information should be recorded in a logbook or notebook
dedicated to the incident, the laboratory's standard forms, or the forms that follow.
For each analytical request, to the extent practical, the ASR should record any information provided in writing
and send to the laboratory, e.q., via fax, e-mail, etc.
COMMUNICATION INFORMATION
During the initial call with a requestor, record the following information:
H Date and time of the call
D Incident primary point-of-contact (POC)
D POC phone number, cell number, fax number, and email address
D Other relevant contact information
SITE CHARACTERIZATION INFORMATION
Ensure that the following information is documented with the sample paperwork shipped to the laboratory:
H General background of the incident
D Available field data - environmental and clinical
D Specific hazards associated with the site
D Samples collected from the site
GENERAL INFORMATION FOR LAB SERVICE REQUESTERS
Record the following information regarding the analytical request:
H Analytes of interest
D Matrix
D Analytical method(s) preferred
D Number of samples
D Reporting limit(s)
D Background levels (if data is available)
D Quantitative (standard QC or reduced QC) or semi-quantitative/screening (estimated; presence/absence)
D Data validation (preliminary or full validation)
D Turn around time
Review/Confirm sample volume, container and preservation requirements with requester.
CHAIN OF CUSTODY REQUIREMENTS
Determine requirements for chain of custody:
H Routine chain of custody or law enforcement sensitive?
D Internal chain of custody required (if law enforcement sensitive)?
D Other special conditions or instructions
SAMPLE SHIPMENTS
Inform the requestor of the laboratory's shipping address and record the following:
H Transport method
D Tracking numbers (if applicable)
D Arrival date/time at laboratory
D Other special conditions/instructions
DATA REPORTING AND RECORDS RETENTION
Laboratories will follow their existing procedures regarding the following in the absence of alternative guidance or
specific instructions and record the following:
H Who receives a copy of the report
D Data format needed (e.g., Excel Spreadsheet, Specific EDO, etc.)
D Method of transmission (e.g., electronic or hard copy)
The laboratory should verify that their standard sample and record retention is adequate.
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
C-l
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Appendix C Form Part 1: Requesting Analytical Support during Water
Emergency Response (ASR^> PRL)
Purpose: This sheet is designed to help discussions between the Analytical Services Requester (ASR) and the Primary
Responding Laboratory (PRL). Potential PRLs should use this help sheet to ensure that all critical information is
exchanged. The PRL can recruit Mutual Support Laboratories to perform the work which they cannot do, so the PRL needs
to record all of the required analytical work reqardless of whether the PRL can perform the work in house.
COMMUNICATION INFORMATION
Date of initial call:
Time of initial call:
Who is in charge of the incident (Analytical Services Requester (ASR) or Incident Commander(IC))?
ASR/IC name:
ASR/IC phone number:
ASR/IC cell number:
ASR/IC fax number:
ASR/IC email address:
Other contacts (utilities, labs, public health, law enforcement, etc.):
EPA/Public Information Officer (PIO) contact:
SITE CHARACTERIZATION INFORMATION
Ensure that this information is documented with the sample paperwork shipped to the laboratory:
Nature of threat:
How was the threat determined (who, what, when):
Threat investigation status, circle one: a) possible b) credible c) confirmed d) other - list here:
Incident information:
Has distribution system been shut down? a) yes b) no c) don't know
Is this incident law enforcement sensitive?
a) yes b) no c) don't know
Who has been contacted?
Any known exposure risks: a) contact b) inhalation c) ingestion d) other - specify:
Results of field safety screening (if applicable, see Field Screening Results Table):
Any known illnesses or injuries related to the incident:
Clinical data/results:
Additional information required for sample acceptance:
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
C-2
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GENERAL INFORMATION FOR LAB SERVICE REQUESTERS
The table below should be filled out to document the sample analyses requested. If samples have not already been
collected, the completed table can be provided to the samplers to provide guidance on sample volumes, preservation,
sample containers, etc.
Requested Analyses
Method
# Samples
Sample
Volume
Container
Preservation
Storage and
Shipping
Conditions
Standard or
Rapid
Analysis
QC Level
Sample disposal instructions:
Other special conditions or instructions:
Relevant background levels from matrix:
Drinking water treatment chemicals:
Prioritization of specific samples:
CHAIN OF CUSTODY REQUIREMENTS
Will routine chain of custody be sufficient or is the event law enforcement sensitive?
If law enforcement sensitive, will internal laboratory chain of custody be required?
Other special conditions or instructions:
SAMPLE SHIPMENTS
Transport method (courier, overnight shipping):
Tracking number(s):
When will the samples arrive at the lab?
Other special conditions or instructions:
DATA REPORTING AND RECORDS RETENTION
Laboratories will follow their existing procedures regarding the following in the absence of alternative guidance or specific
instructions:
Data turnaround for preliminary results (if needed):
Data turnaround time for final results:
Data format:
Method of data transmission:
Contact to report results to:
How will the laboratory be reimbursed?
Will routine sample and record retention be adequate?
How to respond to Freedom of Information Act (FOIA), state information access laws, or law enforcement requests?
Other special considerations:
ADDITIONAL INFORMATION OR COMMENTS
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
C-3
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Appendix C Form Part 2: Requesting Analytical Support during Water
Emergency Response (PRL^> MSL)
Purpose: This sheet is designed to help discussions between the PRL and the Mutual Support Laboratory (MSL).
Potential MSLs should use this help sheet to ensure that all critical information is exchanged. The methods, matrices, and
number of samples are discussed first to determine whether the MSL will be able to assist the PRL. If the MSL is not in a
position to help the PRL then the discussion does not need to continue, and the PRL should call another potential MSL.
GENERAL INFORMATION FOR LAB SERVICE REQUESTERS
The table below should be filled out to document the sample analyses requested. If samples have not already been
collected, the completed table can be provided to the samplers to provide guidance on sample volumes, preservation,
sample containers, etc.
Requested Analyses
Method/Analyte
# Samples
Matrix
Sample
Volume
Container
Preservation
Storage and
Shipping
Conditions
Standard or
Rapid
Analysis
QC
Level
Relevant background levels of matrix:
Known water treatment chemicals:
Sample disposal instructions:
Prioritization of specific samples:
Other special instructions:
Date of initial call:
COMMUNICATION INFORMATION
Time of initial call:
Who is in charge of the incident (Analytical Services Requester (ASR) or Incident Commander(IC)?
ASR/IC name:
ASR/IC phone number:
ASR/IC cell number:
ASR/IC fax number:
ASR/IC email address:
PRL point-of-contact name:
PRL phone number:
PRL cell number:
PRL fax number:
PRL email address:
Other contacts (utilities, labs, public health, law enforcement, etc.):
EPA/Public Information Officer (PIO) contact:
SITE CHARACTERIZATION INFORMATION
Ensure that this information is documented with the sample paperwork shipped to the laboratory:
Nature of threat:
How was the threat determined (who, what, when):
Threat investigation status, circle one: a) possible b) credible c) confirmed d) other - list here:
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
C-4
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Incident information:
Has distribution system been shut down?
a) yes b) no c) don't know
Is this incident law enforcement sensitive?
a) yes b) no c) don't know
Any known exposure risks: a) contact b) inhalation c) ingestion d) other - specify:
Any known illnesses or injuries related to the incident:
Clinical data/results:
Results of field safety screening (if applicable, see Field Screening Results Table):
Results from other laboratories (if applicable, types of analytes tested, positive/negative results):
Additional information required for sample acceptance:
CHAIN OF CUSTODY REQUIREMENTS
Will routine chain of custody be sufficient or is the event law enforcement sensitive?
If law enforcement sensitive, will internal laboratory chain of custody be required?
Other special conditions or instructions:
SAMPLE SHIPMENTS
Laboratory shipping address:
Transport method (courier, overnight shipping):
Tracking number(s):
When will the samples arrive at the lab?
Other special conditions or instructions:
DATA REPORTING AND RECORDS RETENTION
Laboratories will follow their existing procedures regarding the following in the absence of alternative guidance or specific
instructions:
Data turnaround for electronic and/or hardcopy results:
Data turnaround time for verbal results, if applicable:
Data format:
Method of data transmission:
Contact to report results to:
How will the laboratory be reimbursed?
Will routine sample and record retention be adequate?
How to respond to Freedom of Information Act (FOIA), state information access laws, or law enforcement requests?
Other special considerations:
ADDITIONAL INFORMATION OR COMMENTS
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
C-5
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Appendix D Incident Communications Tracking Form for Laboratories
INSTRUCTIONS
This form is intended to be used by a responding laboratory to capture drinking water incident field information relevant to
the laboratory response activity. A form should be completed for each investigation and expanded as necessary to fully
document all information received from the field for each batch of samples received. If field data has been collected and
reported on other forms, those form can be attached and referred to on this incident tracking form.
Incident Report to Laboratory
Site Name:
Date:
Time:
Reported By:
Contact Cell Number:
Type of facility:
D Source water D Treatment plant D Pump station
D Ground storage tank D Elevated storage tank D Finished water reservoir
D Distribution main D Hydrant D Service connection
D Other
Address:
Additional Site Incident Information:
INITIAL HAZARD ASSESSMENT
Initial hazard categorization
D Low hazard D Chemical hazard
D Radiological hazard D Biological hazard
D Unknown
If the initial hazard assessment indicates a chemical, radiological, or biological hazard (as described in
RPTB Module 3, Section 4.1.3), then only teams trained to deal with such hazards should be sent to the
site.
SITE CHARACTERIZATION TEAM
Name & Affiliation of Site Characterization/Sampling Team Leader:
Contact Information:
Other Site Contacts
Organization Name:
Organization Name:
Organization Name:
Organization Name:
Representatives from other agencies:
D Local law enforcement D Fire department D HazMat
D US EPA D FBI D Other
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy D-l
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COMMUNICATION PROCEDURES
Mode of communication:
D Phone
D Facsimile
Reporting events:
D Upon arrival at site
D After site evaluation
D Other
D 2-way radio
D Other
D Digital
D
D
During approach
After field testing
D Site entry
D Site exit
VERBAL FIELD SAFETY SCREENING INFORMATION (Written report to be included with COC and samples)
Parameter1
Radiation
Chlorine residual
pH / conductivity
Cyanide
Volatile chemicals
Chemical weapons
Biotoxins
Pathogens
Screen^
Both
Water
Water
Water
Safety
Both
Water
Water
Instrument
Result
Comments
1. List the parameters that will be evaluated as part of field screening (examples are listed).
2. Screening may be conducted for safety, rapid water testing, or both.
Name of Field Screen Tech
Cell Phone Number
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
D-2
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SAMPLES Taken and Lab Destination
Analyte
Standard VOCs
Semi-volatiles
Quartenary nitrogen
compounds
Cyanide
Carbamate pesticides
Metals/elements
Organometallic
compounds
Cyanide
Radionuclides
Non-target VOCs
Non-target organic
compounds
Non-target inorganic
compounds
Immunoassays
Pathogens - culture
Pathogens - PCR
Water quality - bacteria
Water quality -
chemistry
No.
Samples
Preservation
Destination
Laboratory(s)
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
D-3
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Appendix E Data Elements for Electronic Transmission
Note: Data reporting requirements will evolve as ERLN/WLA reporting systems are developed and implemented.
The electronic data deliverable (EDD) must arrive in a spreadsheet composed of the following data elements. Each
element shall be a column, which is to be populated. Some of the columns, such as LabName, will be very repetitive.
Each row shall contain the results for one analyte or parameter. QC data, such as surrogate and spiked sample results
are reported as analytes.
This "Bio " column indicates which fields are required for population when reporting results for biological analyses.
Data
Element
#
1
2
3
4
5
6
7
8
9
Data Element
Name
LabName
ClientSamplelD
LabSamplelD
PreparationBatch
LocationID
CollectedDate
CollectedEndDate
MatrixlD
MethodID
Definition
Descriptive name for
the laboratory
performing this
analysis
A client-defined
identifier for a sample
A laboratory-defined
identifier for a sample
that uniquely identifies
a single sample that is
subjected to an
analysis
A laboratory-defined
identifier for a batch of
aliquots that are
prepared together for
analysis by one
method. Together can
imply similarity of time,
place, and manner of
preparation.
Identifier for the
sampling location at a
site
Date (and time, if
required) the sample
was collected. If
collected over a range
of dates, this is the
start date.
If the sample was
collected over a range
of dates (and times, if
required), the end of
the collection period.
A more specific
description of the
sample matrix or
media
The published
reference code for the
method used by the
laboratory to analyze
the sample
Comment
This should be reported
exactly as it is seen on
the chain of custody form.
Use a unique ID for each
method and preparation
batch.
This information may be
present on the chain of
custody form.
This field would not need
to be populated for grab
samples.
Bio
Y
Y
Y
Y
Y
Y
Y
Y
Y
Format
Alphanumeric
Alphanumeric
Alphanumeric
The following ISO 8601 format
is recommended:
YYYY-MM-
DDThh:mm:ss.sTZD
These are listed in the SEDD
5.2 Valid Value List located at:
http://www.epa.gov/superfund/
prog rams/clp/seddspec52. htm
These are listed in the SEDD
5.2 Valid Value List located at:
http://www.epa.gov/superfund/
prog rams/clp/seddspec52. htm.
The list will be updated
periodically to include SAM
and other appropriate
methods.
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
E-l
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10
11
12
13
14
15
16
17
18
LabMethodID
PreparedDate
AnalyzedDate
CASRegistryNumber
AnalyteName
LabAnalytelD
Result
ResultUnits
LabQualifier
A laboratory-defined
code for the method
used by the laboratory
to analyze the sample
Date and time of
sample preparation.
Preparation is used
generally to include
method specific
techniques such as
extraction, digestion,
and separation. If
prepared over a range
of dates, this is the
start date.
The date (and time, if
required) of analysis of
an aliquot. If analyzed
over a range of dates,
this is the start date.
The Chemical Abstract
Service number for the
analyte
The published
reference name for the
analyte
A laboratory-defined
identifier for an analyte
Reportable final result
for the analyte
Units for Result
A laboratory-assigned
string of result
qualifiers (usually a
single character for
each qualifier), based
on client or laboratory-
defined rules and
values
Enables users to
determine holding time
based on when samples
were prepared, as well as
when samples were
analyzed.
This field is almost
always numerical, unless
the analysis is qualitative
(i.e., detect/nondetect).
Ensure that
ResultUncertainty is
expressed in same
ResultUnit as the Result.
N
Y
Y
N
Y
N
v
1
Y
Y
The following format is
recommended: YYYY-MM-
DDThh:mm:ss.sTZD
The following format is
recommended: YYYY-MM-
DDThh:mm:ss.sTZD
Alphanumeric/text
Recommend using the EPA
Registry Name from EPA's
Substance Registry System
located at:
httpV/iaspub.epa.gov/sorJnternet/r
egistry/substreg/home/overview/ho
me. do
IEEE/ASTM SI 10 -2002-
American National Standard for
Use of the International System of
Units (SI) : the Modern Metric
System. These are listed in the
SEDD 5.2 Valid Value List located
at
http://www.epa.gov/superfund/pro
qrams/clp/seddspec52.htm
In order to stay consistent from
one deliverable to another, the
only qualifiers that will be used are
"U", "J", and "UJ". "U" indicates
that the analyte was analyzed for
but not detected. "J" indicates an
estimated value. The "J" qualifier
is used when a QC parameter
indicates that the reported quantity
could be inaccurate, or when the
data indicates the presence of an
analyte that meets the
identification criteria but the result
is less than the sample
quantitation limit but greater than
zero. The "UJ" qualifier indicates
that the analyte was analyzed for
but not detected, and a QC
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
E-2
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19
20
21
22
23
24
25
26
27
ResultUncertainty
UncertaintyCoverag
eFactor
ResultBasis
ReportingLimit
ReportingLimitUnits
ReportingLimitType
AnalyteType
ExpectedResult
ExpectedResultUnits
Calculated Uncertainty
associated with the
Result
Numerical factor by
which the combined
standard uncertainty is
multiplied to obtain the
reported uncertainty
The basis upon which
the final results were
calculated
Reporting limit for the
analyte being
measured. Reporting
limits are defined in
terms of a number
below which data is
reported as not
detected.
Units for
ReportingLimit.
One of a list of client-
defined acronyms that
specify the type of
reporting limit.
A client-defined
identifier that identifies
the type of analyte
reported
The expected final
result of an analyte
that has been spiked
into an aliquot at any
time during the
analysis process or
the true value of an
analyte in the sample
analyzed.
Units associated with
expected result.
For Radiochemical
Analysis only at this time.
Ensure that
ResultUncertainty is
expressed in same
Result Unit as the Result.
Radiochemical Analysis
Element -typically
between 2 and 3, but
may be 1 if the CSU itself
is reported.
Should be the same as
ResultUnits
Enables user to calculate
recoveries for surrogates,
spikes, Pes, duplicates,
etc.
N
N
N
N
N
N
N
Y
Y
parameter indicates that the
reporting limit could be inaccurate.
Numeric
Numeric
"Dry" or "Wet" for samples with a
solid matrix, and "Total" or
"Dissolved" for samples with an
aqueous matrix.
Use the same format as the
ResultUnits.
Specifies the type of reporting limit
for the analysis, i.e., MDL, PQL,
CRQL, MDC, MDA
This field is used to distinguish
spiked analytes from sample
results (e.g., Target, Spike, TIC,
Surrogate, or Internal Standard).
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
E-3
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28
29
QCType
Comment
The client-defined
term used to define
the specific type of QC
sample being
analyzed
A free-form comment
field.
Currently the SEDD 5. 2
Valid Value List located
at
http://vwvw.epa.qov/super
fund/proqrams/clp/sedds
pec52.htm
contains some, but not
all, of the EPA Office of
Water QC sample types.
Y
Y
This field describes the QC
sample used to generate results
the lab inserts into the EDO (e.g.,
Laboratory_Fortified_Blank). It
should be populated with the QC
sample types listed in the SEDD
valid value list (SEDD Appendix
B).
The comment field can not contain
any commas or semi-colons, in
case the electronic deliverable is
converted into a comma delimited
or semi-colon delimited file.
Insert NA for any element not applicable, (e.g. CAS # for unnumbered radiochemical analytes).
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
E-4
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Appendix F Field Testing Results Form
Date of Field Testing: Site/Incident Name: Field Tester: Phone No.
Parameter
Units
Screen1
Meter/Kit
ID2
Testing Location3
Testing Time4
Results5
Ref. Value6
Screening may be conducted for safety, rapid water testing, or both
' Report the unique identifier for the meter or kit used during screening
' Report the specific location where the field testing was conducted
' Report the specific time at which the test was performed
' Results of field testing should include replicate analysis where appropriate
' Results should be compared with a reference value, if available, to determine whether or not the levels detected pose a hazard
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
F-l
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Appendix G Example of a Chain-of-Custody Form
Chain of Custody Form
Site Name:
Sample Owner/Collector:
Contact Information:
Signature
Sample ID
Collection
Date/Time (24 h)
Sample Location
Sample Type
(Matrix)
Grab/
Composite
Preservative(s)
No./Type
of Bottles
Comments
Matrix: DW = Drinking Water, RW = Reservoir Water, UW=Untreated Water, SD = Sediment, SL = Sludge, SO = Soil, SM = Misc. Solid Material
Relinquished By: Received by: | Date/Time:
Relinquished By:
Received by:
Date/Time:
Relinquished By:
Received by:
Date/Time:
Relinquished By:
Received by:
Date/Time:
Relinquished By:
Received by:
Date/Time:
Dispatched by:
Date/Time:
Received by:
Date/Time:
Method of Sample Transport
Shipper:
Phone No.
Shipper's Tracking No.
Attach additional pages as required.
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
G-l
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Appendix H Minimum and Optional Chain-of-Custody
Data Elements
Note: The collection of data elements listed below is based on the input received on the February 11,
2009, draft WLA Response Plan. The names of the data elements included on your laboratory's chain-of-
custody (COC) form do not have to match the names listed below. The names given below under
"Minimum COC Data Elements" are to be compared with what is on your form for ensuring that all
information covered by the proposed minimum data elements is captured by your form. This is being
done in order to ensure that any COC form used during incident response conveys the same minimum
information to the laboratory.
The minimum data elements for COC forms given below are still being discussed and may change based
on further input received from you.
A. Project/Site Information
Minimum COC Data Elements for each Project/Site
1. SitelD/Incident ID
2. SiteName
3. ProjectID
4. ProjectName
5. Site/Incident Description
6. Site/Sampler Contact Information (name, affiliation, phone number)
7. Site/Incident Data Coordinator Contact Information (name, affiliation, phone number)
8. General comments on this shipment
Optional COC Data Elements for each Project/Site
9. AnalyticalRequestID (A client-defined identifier for the paperwork that authorizes the analyses of
specific samples by listed methods.)
10. ClientID - unique ID for the client
11. ClientName - name of the client
12. CoolerlD - unique ID for a sample cooler
13. Custody ID - unique ID for the COC form
14. RequesterlD - ID for person requesting analysis
15. RequesterName - name of person requesting analysis
16. ShippingBatch - unique ID for samples shipped together
17. SamplingBatch - unique ID for samples collected together
B. Sample Information
Minimum COC Data Elements for each Sample
18. ClientSamplelD - Sample ID as given in the field
19. CollectedDate - the date and time the sample was collected. If collected over a period of time, this is
the start date and time.
20. CollectedEndDate - the date and time of the end of the sample collection period.
21. LocationID - location ID as given in the field
22. LocationName - name of the location where samples were collected
23. MatrixID - a more specific description of the sample matrix, e.g., drinking water
24. MatrixMedium - a general description of the sample matrix, e.g., aqueous
25. Sample Type (Grab or Composite)
26. Preservatives and/or dechlorination agents added in field (e.g., nitric acid, sodium thiosulfate)
27. Bottles and BottleType: Number and type of bottles/sample containers
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy H-l
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28. ClientMethodID & ClientMethodName: Test code and Test names requested on sample
29. Additional comments regarding specific sample
Optional COC Data Elements for each Sample
30. Filtered - Yes or No (Indicates whether or not the sample as received by the laboratory was field
filtered.)
31. Quarantine - Yes or No (Indicates whether or not the sample as received by the laboratory is to be
quarantined.)
32. SampleAmount - the amount (weight or volume) as received by the laboratory
33. SampleAmountUnits - units for sample amount
34. Sample Disposal Information
C. Shipping Information (Minimum COC Data Elements)
35. Signature blocks designating who shipped samples (dates and times)
36. Mode of shipment (e.g., Fedex, courier, hand delivery)
37. Shipping contact information
38. Date shipped
39. Sample shipping tracking number
D. Sample Receipt Information (Minimum COC Data Elements)
40. LabReceiptDate - The date (and time, if required) that the sample was received in the laboratory.
41. Block to record comments from Receiving Laboratory (e.g., preservative checks, sample condition)
42. Signature block designating who relinquished samples to the laboratory (dates and times)
43. Signature block designating who received samples at the laboratory (dates and times)
E. Field Measurements (Optional Data Elements)
44. CharacteristicType (e.g., pH, dissolved oxygen, residual chlorine)
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy H-2
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Appendix I Guidelines for Handling Criminal Investigation
Samples
Introduction
Samples analyzed as part of a response to a suspected or known water contamination incident may
become part of a criminal investigation. Thorough sample custody and recordkeeping procedures
implemented by the laboratory analyzing these criminal investigation samples are necessary to ensure that
the samples and analytical results will withstand the high burden required by the criminal justice system.
Laboratories must have procedures in place that prevent samples from being altered in any way while
providing confirmation that they were not in fact altered. Guidelines for handling criminal investigation
samples are provided below.
Sample Receipt and Acceptance
Completed chain-of-custody forms should accompany samples that are part of a criminal
investigation.
Samples should arrive in a cooler or other container sealed with custody tape at a minimum and may
also be padlocked.
If samples arrive without appropriate chain-of-custody, custody tape, or locks, the investigating
authority should be notified immediately.
Digital pictures should be taken of samples upon sample receipt. USEPA Guidelines for digital
imaging technology for investigations can be found at:
http://epa.gov/oecaerth/resources/policies/monitoring/digitalcameraguide.pdf In addition, the
Scientific Working Group on Imaging Technology (SWGIT) provides recommendations for
capturing, storing and archiving digital imagery http://www.theiai.org/guidelines/swgit/index.php.
Sample Custody
All analysts and sample custodians with access to the original samples are potential witnesses that
may be called to testify in court as to how the samples were stored, handled, and tampering was
prevented nor evident at any time.
Samples should remain in custody throughout sample receipt, analysis, and disposal. Samples are in
formal custody if they are in:
o Someone's physical possession
o Direct view after being in physical possession
o Locked location so that tampering cannot occur
o Secure area, restricted to authorized personnel only
Samples should be tracked from receipt through report issuance and disposal, preferably using the
Laboratory Information Management System (LIMS).
It is recommended that site identification or location information about the samples not be entered in
LIMS. The investigation authority should assign a case number that can be used for sample tracking.
Only one sample custodian should handle criminal investigation samples. The role of the sample
custodian is to control access to the samples while they are in the custody of the laboratory.
Samples should be stored in a locked cooler or other locked area. Access to the cooler should be
limited to the sample custodian. If an analyst needs access to the samples, they should sign out the
samples from the sample custodian.
Analysis of samples should be limited to one analyst per analysis, if possible. If a second analyst
needs to relieve the original analyst, a note with the date, times, and signatures should be included in
the sample file.
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Samples should be locked in storage if the analyst leaves the room where analysis is being performed.
Analysts should sign out a key from the sample custodian for the storage area where samples will be
stored during sample analysis.
Custody applies to the original samples and containers. If all of the sample is used, the original
container must be maintained as an item of evidence under custody. If all of a sample is used, any
extracts or digests must then be kept under custody as if they were original. Extracts that have no
original sample remaining should be supervised at all times.
When aliquots are removed from the original sample, the remaining original sample should be
returned to the sample custodian for safe keeping.
Samples must be retained until written permission for disposal is received from the investigating
authority.
Sample Analysis
Through discussions with the investigating authority, the laboratory needs to ensure that all analyses
needed to cover the elements of the crime have been conducted.
Analyst, date of analysis, and LIMS sample ID should be on every page of the analytical data
package, including bench sheets, instrument printouts, and narratives.
If there are any flags associated with the data, a complete explanation of the circumstances and
corrective actions attempted should be included in the data file.
Samples associated with a criminal investigation should not be combined in a batch or analytical run
with any other samples not associated with the criminal investigation.
All analysts are potential witnesses who may be required to defend the accuracy of their work in
court.
Quality Control (QC)
Samples being analyzed for the purposes of criminal investigation only (i.e., results will not be used
as part of response or recovery decisions) should be analyzed using complete method QC. If samples
are being analyzed to make response or other decisions, sample QC should be appropriate for the
monitoring objectives. QC should also be sufficient to allow the analyst to make an estimate of the
uncertainty of the data, if necessary.
Reporting
Data should be reviewed by the analytical laboratory according to the laboratory's documented
procedures prior to release to the investigating authority.
All data should be kept in locked storage when the laboratory is closed.
The laboratory's LIMS should be set up to create an audit trail that can be used to confirm that no one
has changed any values.
The laboratory should agree with the investigating authority regarding the appropriate route for data
transmission.
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy 1-2
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Appendix J Close-out Action Checklist
Plan Elements and Procedures
Laws and Authorities
Minimum Qualifications for Participation
Resource Management
Form of Commitment to this Plan
Planning
Direction, Control, and Coordination
Roles
Quality Assurance Project Plans (QAPPs)
Communications and Notification
Health and Safety
Sampling
Sample Brokerage, Tracking, and Transport
Sample Brokerage
Sample Tracking
Sample Transport
Analysis
Problem
Issue?
Description of Issue
After-Action Plan Solutions
Final - November 2010
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Plan Elements and Procedures
Basic Field/Safety Screening
Rapid Laboratory Analysis
Confirmatory Analysis
Sample Disposal
QA/QC
Data Verification
Data Reporting and Validation
Secure Data Transfer and Storage
Record Keeping
Training
Exercises, Evaluations, and Corrective Actions
Finance and Administration
Other
Problem
Issue?
Description of Issue
After-Action Plan Solutions
Final - November 2010
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Appendix K Recommendations for Laboratory Practice of the
Water Laboratory Alliance Response Plan
Purpose
The Water Laboratory Alliance (WLA) Response Plan (WLA-RP) for drinking water is intended as a
guideline for joint laboratory response to an actual or suspected drinking water contamination event due
to a natural disaster or terrorist event. During such an event, a large number of environmental samples
may be generated, likely overwhelming the capacity and/or capability of any individual laboratory to
provide sufficient analytical support. The WLA-RP addresses this situation by providing a blueprint for
how EPA National, Regional, drinking water utility, and state laboratories can work together to meet
analytical needs during an event.
The EPA Water Security Division conducted table top exercises and functional exercises of the Regional
Laboratory Response Plans (RLRP) during 2008. Multi-regional exercises of the WLA-RP were started in
2009 and will be conducted on an ongoing basis. In addition to participation in these activities,
laboratories may wish to practice aspects of the WLA-RP on their own or in conjunction with other
laboratories to prepare for implementation of the WLA-RP during an actual event.
Laboratory practice of aspects of the WLA-RP prior to participation in a drinking water contamination
response provides the following benefits to the participating laboratories, as well as the drinking water
community:
An increase in member laboratories' familiarity with the WLA-RP;
Opportunities to identify issues that can be resolved ahead of time and increase overall
preparedness;
A reduction in the time needed by laboratories to determine the appropriate procedures during an
event resulting in decreased response time;
Increased communication and collaboration with other laboratories within the WLA WLA-RP
network.
Recommendations for Practice of the WLA-RP:
Laboratories should practice different aspects of the WLA-RP in order to prepare for participation in a
response to a drinking water contamination incident. Some of these activities can be performed
independently by the laboratory, and others should be performed in conjunction with other laboratories to
test communication and data exchange. Your laboratory may have already performed some of these
activities.
Independent Laboratory Activities:
1. Review the WLA-RP
Review the WLA-RP on a regular basis.
If your contact information is out of date, provide updated contact information to those in your
region.
Identify roles and responsibilities for your staff should your laboratory become involved in a
response.
Evaluate the WLA-RP against your laboratory's standard operating procedures (SOPs) and
determine if procedures need to be updated or added such as those listed below:
Method QC activities that could be dropped to minimize turnaround times
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy K-l
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Requirements related to sample tracking and retention in law enforcement cases
Minimum data review prior to sample release.
2. Practice Creating Data Files
Coordinate with your laboratory's LIMS manager to create flat files or Excel spreadsheets for
samples analyzed in-house; ideally these files will meet most of the recommendations in the
WLA-RP. Laboratories analyzing both chemical and biological samples should practice
generating data files for both types of analyses.
3. Become Familiar with the EPA Compendium of Environmental Testing Laboratories (CETL) -
http://www.epa.gov/compendium
The EPA CETL is a Web-based system that can be used to identify laboratory analytical
capabilities and capacities based on categories of threat agents or analytes.
If you don't currently have access, register at http://www.epa.gov/compendium.
Logon using your username and password; contact the helpdesk at 703-818-4200 if needed.
Go to 'Manage' and view your laboratory's contact information and capabilities; update this
information if needed.
Using the search function, identify five laboratories in your region that have the capability to
analyze samples for total organic carbon.
Logon to the system at least once every three months to ensure your username and password are
active and that your laboratory's information is up to date.
4. Confirm Access to Water Contaminant Information Tool (WCIT) -
WCIT is a secure, Web-based system that provides contaminant data that may be used in
planning for or responding to a drinking water contamination incident. This includes information
on available methods for chemical, biological, and radiochemical contaminants (formerly
available in the National Environmental Methods Index for Chemical, Biological, and
Radiological Methods [NEMI-CBR]) that allows users to compare method performance, speed,
and relative cost for response to both intentional and accidental contamination events
(http: //water, epa. gov/scitech/datait/database s/wcit/index. cfm).
If you do not currently have access, register at https://cdx.epa.gov/warning.asp.
Logon using your username and password. Contact the CDX Helpdesk at 1-888-890-1995, if
needed.
Practice using the 'Search' feature to find contaminants by name, synonym or "free search."
Select one of the contaminants returned by your search; select the field and analytical methods for
the contaminant.
Logon to the system at least once every three months to ensure your username and password are
active.
5. Receive Incident Command System (ICS) Training - http://training.fema.gov/IS/crslist.asp
This is the website for Independent Study courses offered by FEMA.
Laboratory managers and other laboratory personnel that may be directly involved in managing a
response should take the course: Introduction to Incident Command System, I-100.
6. Receive Training for International Air Transport Association (IATA) and Department of
Transportation (DOT) Transportation Regulations for Sample Shipment -
http: //www. iata. org/training/cargo/
IATA training focuses on regulations for shipping dangerous goods.
At least one person at each laboratory should be trained to ship dangerous goods according to
IATA and DOT regulations.
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy K-2
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Courses should be taken on Dangerous Goods Regulations and Shipping Guidelines for Infectious
Substances (if analyzing or shipping biological samples).
The laboratory should have the appropriate materials for packing and shipping samples according
to IATA regulations, if applicable.
Activities to Coordinate with other Laboratories:
1. Laboratory Communication
Role-play with other laboratories to practice communication between laboratories during a
response. Take turns being the Primary Responding Laboratory (PRL) and Mutual Support
Laboratory (MSL).
Use the Help Sheet for Requesting Analytical Support during Water Emergency Response to
practice collecting information about an 'incident' including analyses required, method QC to
perform, data review and reporting requirements, etc.
2. Data Exchange
Practice exchanging data with other laboratories through the various mechanisms that data
exchange may occur during an incident (e.g., fax, phone, email, etc.)
Exchange flat files that comply with the recommendations of the WLA-RP.
Attempt to compile data files from your laboratory with data files from other laboratories.
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy K-3
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Appendix L Suggested Emergency Water Sample Collection Kit
Table L-1. Example Emergency Water 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
Disposable camera
2
2
2 times the
number of
bottles
24
2 rolls
24
2
1
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
Waterproof or water resistant
General Sampling Supplies
Sample containers
Device for grab sampling
10 liter HOPE container
Lab grade tape
Miscellaneous glassware
Collapsible cooler
Rigid shipping container
1 qt. zippered freezer bags
Thermometer
Paper towels
Table L-2, L-3,
and L-4
1
4
3 rolls
N/A
1 or more
1 or more
1 pack 100
2
2 rolls
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.
For double bagging ice and sample containers
For checking water temperature
Wiping wet containers and containing spills
Pathogen Sampling Supplies
Tubing and clamp
Stopwatch & graduated cylinder
Ultrafiltration or membrane filtration
apparatus
1
1
1
For sample tap flushing, etc.
For measuring flow rate
For concentrating biological (pathogen and toxin)
samples
Reagents (may need to be kept separate from the rest of the kit)
Laboratory grade water
Sodium thiosulfate crystals
Ascorbic acid
Sodium sulfite crystals
Potassium dihydrogen citrate
6 Molar ACS grade hydrochloric acid
(HCI)
6 Molar trace metal-grade nitric acid
(HNO3)
10 Normal Sodium hydroxide (NaOH)
Sulfuric Acid (H2SO4)
pH paper in ranges from 0-4 and 10 -
14
5 liters
100 grams
100 grams
100 grams
100 grams
25 mL
25 mL
25 mL
25 mL
50 strips
For sample dilution in the field
For water sample dechlorination
For water sample dechlorination
For water sample dechlorination
For carbamate preservation
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
In dropper bottle for preservation of samples for pesticide
preservation
For checking the 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
Squirt bottle
2
1 box per size
(S, M, L, XL)
2 pairs
2
4
20 liters
1 container
2
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 use with rinse water or lab grade water
Final - November 2010
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Item
First aid kit
Flashlight/headlamp
Quantity
1
3
Notes
For general first aid
For working at night or in dark locations
Table L-2. Chemical Sample Collection Kit Guidelines
Contaminant
Class/Type
Volatiles
(Methods 502.2,
8021 B, 524.2,
8260B)
Carbamate
Pesticides
(Methods 531.1,
531.2)
Unknown organics
(volatile)
Metals/ Elements
(Methods 200.7,
200.8, 200.9)
Organometallic
compounds
Toxicity
Cyanide
(Methods 335.2,
335.3, 335.4)
Quaternary
nitrogen
compounds
(Method 549.2)
Semi-volatiles
(Methods 525.2,
8270D/3535A)
Container
Volume and
Type
40 ml_, Glass
w/ Teflon faced
septa
40 ml_, Glass
w/ Teflon faced
septa
40 ml_, Glass
w/ Teflon faced
septa
125 ml_, Plastic
(i.e., HPDE)
125 ml_, Plastic
(i.e., HPDE)
125 ml_, Glass
1 L, Plastic
1 L, Amber
PVCor
silanized glass
1 L, Amber w/
Teflon-lined
screw caps
No. of
Containers
5
4
5
2
2
2
2
4
4
Disinfection
Reducing
Agent
Ascorbic acid
(0.25-0.5 g)
Sodium
thiosulfate
(12.5 mg)
None
None
None
Consult
manufacturer'
s instructions
Ascorbic acid
(0.06 g)
Sodium
Thiosulfate
(100 mg)
Sodium sulfite
(40 - 50 mg)
Preservative
1:1 HCLtopH
<2
stored <4°C
Potassium
dihydrogen
citrate; adjust
sample pH to
-3.8
stored <4°C
None - mark
samples not
preserved
stored <4°C
Trace metal
grade nitric acid
to pH <2
Nitric acid to pH
<2
Consult
manufacturer's
instructions
Sodium
hydroxide to pH
>12
stored <4°C
Sulfuric acid to
pH<2
stored <4°C
BMHCIto
PH<2
stored <4°C
Holding Time
14 days
28 days
7 days
6 months
30 days
Consult
manufacturer's
instructions
14 days
14 Days
7 days to
extraction,
28 days to
analysis
Analytical
Technique
P&T - GC/MS
P&T-
GC/PID/ELCD
HPLC-fluorescence
P&T - GC/MS
ICP-MS
ICP-AES
AA
AA- cold vapor
manual
AA- cold vapor
automated
Rapid toxicity assay
(several vendors)
Titrimetric
Spectrophotometric
SPEHPLC-UV
SPE GC/MS
Final - November 2010
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L-2
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Contaminant
Class/Type
Unknown organics
(general)
Unknown
inorganics
Water quality:
Chemistry
Container
Volume and
Type
1 L, Amber
glass
1 L, Plastic
1 L, Plastic or
Glass
No. of
Containers
4
2
1
Disinfection
Reducing
Agent
None
None
None
Preservative
None - mark
samples not
preserved
stored <4°C
None - mark
samples not
preserved
None - mark
samples not
preserved
Holding Time
7 days to
extraction,
28 days to
analysis
28 days
Immediate to
14 days
Analytical
Technique
Prep: SPE, SPME,
micro LLE, direct
aqueous injection,
headspace
Analysis: GC/MS,
GC, HPLC, LC-MS
ICP-MS
Conductivity, pH,
alkalinity, hardness,
turbidity
Table L-3. Biological (Pathogens and Toxins) Sample Collection Kit Guidelines
Contaminant
Class/Type
Biological
Fecal conforms, £.
CO//
Biological
(pathogens and
toxins)
Bacterial Pathogens
Container
Volume and
Type
125mLto250
ml_, Plastic
10 to 100 L,
Plastic
1 to 2 L, Plastic
Sample
Concentration
Volume
None
250 to 500 ml_
(ultrafiltration)
2-4 mL
(membrane
filtration)
Disinfection
Reducing
Agent
Sodium
thiosulfate
(0.05% final)
Sodium
thiosulfate
(0.05% final)
Sodium
thiosulfate
(0.05% final)
Preservative
< 4°C + 2°C,
do not freeze
Sample
concentrate
< 10°C, do not
freeze
Sample
concentrate
< 10°C, do not
freeze
Holding Time
24 - 30 hours
TBD
TBD
Analytical Technique
(or Instrumentation)
Culture Methods
(multiple-tube
fermentation/
membrane filtration)
PCR and
immunoassay
PCR and
immunoassay
Table L-4. Radiochemical Collection Guidelines
Contaminant
Class/Type
Radiochemical
Container
Volume and
Type
1, 5-L
cubitainer or
4, 1-L plastic
containers
Number of
Containers
2
Disinfection
Reducing
Agent
None
Preservative
Trace metal
grade nitric
acid to pH <2
Holding
Time
6 months
Analytical Technique
(or Instrumentation)
Gross alpha, gross beta,
gamma isotopes, specific
radionuclides
Final - November 2010
For Official Use Only - Do Not Cite, Circulate, or Copy
L-3
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Appendix M Standardized Analytical Methods for Environmental
Restoration Following Homeland Security Events (SAM)
To expedite and standardize identification and measurement of contaminants in environmental samples across
multiple laboratories following a homeland security related incident, EPA's National Homeland Security
Research Center (NHSRC) is compiling and maintaining a list of laboratory analytical methods for priority
contaminants relevant to homeland security (the SAM document). The methods will be used by environmental
laboratories identifying and measuring chemical, radiochemical, pathogen, and biotoxin contaminants in
environmental samples associated with remediation activities following a contamination incident. By
standardizing the methods across laboratories, SAM potentially shortens critical decision times in national
emergencies by reducing confusion associated with interpreting analytical results. SAM facilitates the analysis of
large numbers of environmental samples, greatly improves the process of validating and analyzing sample data,
and improves evaluating the effectiveness of decontamination efforts. Thus far, SAM lists procedures to identify
and measure 135 priority chemical contaminants, 22 radionuclides, 32 pathogens, and 18 biotoxins that may be a
concern following a homeland security incident.
SAM is the product of an NHSRC-sponsored workgroup, with support from multiple agencies, including, but not
limited to the U.S. Centers for Disease Control and Prevention (CDC), Department of Homeland Security (DHS),
and the Department of Defense. The fifth revision to this methods compendium (SAM 5.0) was published in
September 2009. The latest revision to SAM includes input from DHS, the National Institutes of Occupational
Safety and Health, CDC, the Food and Drug Administration, and numerous EPA offices. The latest revision of
SAM can be found on the SAM Web site (www.epa.gov/sam), which was first developed in 2007 by NHSRC to
allow users and other stakeholders to search for specific needs. The SAM Web site is updated with each revision
of the document to reflect the most recent information and allows users to submit questions and comments
regarding the information.
Standard Analytical Protocols (SAPs)
NHSRC is developing and validating Standard Analytical Protocols (SAPs) based on the methods listed in the
SAM document, where further development and verification are necessary to address the specific analytes and
environmental sample types listed in SAM. SAPs are being tested, verified, and validated in single- and multi-
laboratory studies. Once validation is complete, data regarding specific method performance and data quality
objectives will be available. Verification or validation of 10 chemistry SAPs and 2 pathogen SAPs has been
initiated. These SAPs include: gas chromatography/mass spectrometry (GC/MS) for chemical warfare agents,
chemical warfare agent degradation products, semi-volatile organic compounds, and volatile compounds; high
performance liquid chromatography (HPLC) tandem MS for carbamates, thiodiglycol, ethanolamines, and
organophosphates; inductively coupled plasma (ICP) for metal-containing compounds; ion chromatography (1C)
for inorganic anions; and culture technique for Escherichia coll O157:H7 and Salmonella Typhi.
SAM Companion Documents
As companions to SAM, NHSRC is also developing several documents that are intended to standardize
procedures used to collect and screen samples prior to full confirmatory analysis in the laboratories. These
documents will provide information needed to (1) collect, package, and ship environmental samples to be
analyzed using the analytical methods listed in SAM, (2) screen field conditions for the presence of SAM target
analytes or related compounds, and (3) provide rapid preliminary analyses for laboratory identification of SAM
target analytes or related compounds, prior to confirmatory analysis. NHSRC also is preparing a sample disposal
document that provides guidelines regarding disposal of samples containing the SAM analytes. These documents
are currently under various stages of development and review, and involve the multi-agency workgroups involved
in development of SAM. It is anticipated that the first three SAM companion documents will be available during
the Summer/Fall of 2010.
Final - November 2010 For Official Use Only - Do Not Cite, Circulate, or Copy M-1
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Appendix N
Short Form Quality Assurance Project Plan (QAPP)
Template for Emergency Response Laboratory
Services for Drinking Water Incidents
Project Title and Participants
Project Name:
Date:
Lead Agency:
Other Agencies:
B
Distribution List, Roles, and Approvals
Include names, organizations, roles, and telephone numbers of those individuals receiving copies of this
QAPP. The Incident Commander/Analytical Services Requester, QA Officer, and Laboratory Manager(s)
must sign on the lines below their names, signifying their approval of the document. Other recipients of
the plan do not sign the document, but receive copies. (Add more rows to the table, or attach additional
pages, as needed.)
Name
Organization
Role
Incident Commander/
Analytical Services
Requester
QA Officer
Laboratory Manager
Laboratory Manager
Telephone Number/
e-mail
C Problem Definition
In the sections below, provide a brief description of the problem or the nature of the emergency response
situation and describe how the data will be used (i.e., assess immediate threat to the water supply). Use
tasking material provided by the Project Manager/OSC/Incident Commander, as appropriate.
Cl Problem Statement
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C2
Intended Use of Data
D
Response Timetable
In emergency response situations, it is critical that everyone involved understand the timeframes for
response actions so that they can provide the needed data in time to make meaningful decisions. (Getting
"perfect" data two days after the decision needs to be made is not helpful). Use the table below to
describe the major activities that must take place and the dates and times by which they must occur. Use
local time, or specify a time zone for each entry. (Add more rows to the table, as needed.)
Activity
Date and Time for Completion
E Parameters of Interest and Measurement Quality Objectives
El Matrices, parameters, and measurement type
Use the table below to identity the matrices, parameters (contaminants) of interest, and identify the nature
of the measurements to be made. Parameters may be listed as broad classes of analytes (e.g., semivolatile
organics) or specific suspected threats (e.g., kerosene), based on available information. If specific
methods are to be employed, list them in the column that represents their capabilities (screening,
semiquantitative, or quantitative), or simply mark the cell that corresponds to the type of measurement
requested. (Add more rows to the table, as needed.)
Matrix
Parameter
Type of Measurement or Specific Method Required
Screening?
Semiquantitative?
Quantitative?*
*Mark the cell only; fill out the following table
Final - November 2010
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N-2
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Matrix
Parameter
Quantitative Analysis
Project's
Quantitation
Limit**
Precision
Require-
ment**
Accuracy
Require-
ment**
Selected
Method
Lab's
Method
Detection
Limit
**Consult project/client provided documentation
E2 Representativeness
Use this section to briefly describe how subsamples taken from sample containers are representative of
the entire sample.
E3 Comparability
Use this section to identify any requirements for comparability of the results to data from other sources,
including action limits, regulatory limits, health-based limits, or other measures used to judge the success
of the project. For example, what units of measure are to be used (|o,g/L?, CFU/mL?, etc.) What value (if
any) will "non-detects" be given for subsequent statistical analysis (e.g., zero, the MDL, treated as
outliers)? What rounding rules and levels of significant figures are needed for calculations and reporting?
If specific methods must be employed, list them here, as well as in Section El above.
E4 Completeness
Completeness is a measure of the number of valid measurements made as a percentage of samples
collected. Use the table below to estimate the numbers of samples to be collected and analyzed for each
parameter and to define the level of completeness required. The level of completeness may vary for each
project, in that even one positive result may provide enough information to take action in some instances.
(Add more rows to the table, as needed.)
Parameter
# Samples Anticipated
# Valid Results Required
Completeness (%)
F Sample Collection, Handling, and Transport Procedures
Use the section below to describe how samples will be collected, by whom, and how they will be handled
and transported by the laboratory(ies). Identify any required sampling equipment and procedures
consistent with the discussion in Section E2.
Final - November 2010
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G Training and Certification Requirements
Use the section below to identify any training or certification requirements required for participants in the
project (both organizations and individuals). Such requirements should be specific to the project and do
not include routine training provided to all employees (e.g., ethics training or timekeeping training).
H Documentation and Records
Use the section below to briefly describe the documentation and other records that must be produced
during the sample collection and analysis processes. If chain of custody is required, state that here.
When describing analytical raw data, cite the analytical technique where practical (e.g., GC/MS raw data,
including mass spectra and quantitation reports) as a means of describing the information. Indicate if
there are requirements for electronic data versus hard copy. Specify the locations in which documentation
and records will be retained, for what period, and by whom.
I Quality Control Requirements
The nature of emergency response situations changes the focus of many quality control operations,
primarily because there may not be time to take corrective actions when QC acceptance criteria are not
met (e.g., samples with poor surrogate recoveries may not be able to be rerun in time). Therefore, the
focus of these QC operations may shift to identifying those critical aspects of the sampling, analysis, and
data evaluation processes that must be considered, and establishing minimum requirements for each
critical operation.
Use the three subsections below to identify all critical QC operations and checks for the sampling,
analysis, and data evaluation processes. Where possible, establish minimum acceptance criteria, rather
than acceptance windows (e.g., state that surrogate recovery must be at least 10%, rather than giving a
range like 70-130%), based on your assessment of the importance of each QC check and its impact on the
decision to be made (e.g., what risk of a decision error can you accept?).
II Laboratory QC Checks
12 Data Evaluation Checks
J Instrument/Equipment Testing, Inspection, and Maintenance Requirements
Use the table below to identify the testing, inspection, and maintenance requirements associated with any
of the laboratory equipment and instrumentation. List the equipment type (or name), the type of testing,
inspection, and maintenance, and the required frequency. (Add more rows to the table, as needed). These
requirements may be met through a laboratory's current quality systems as required by drinking water
certification and method implementation in its state.
Equipment Type (or name)
Type of Testing, Inspection,
and Maintenance
Required Frequency
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K Calibration Requirements
Use the table below to identify the requirements for calibration any analytical instruments used in the
laboratory. Describe the type of calibration (e.g., single-point) and the required frequency, whether
during the project (e.g., daily, before each use) or overall (e.g., annually). These requirements may be
met through a laboratory's current quality systems as required by drinking water certification and method
implementation in its state.
Instrument
Type of Calibration
Frequency
L Inspection and Acceptance Requirements
Use this section to identify any inspection and acceptance requirements for supplies, reagents, or
equipment that are critical to the successful completion of the emergency response, whether purchased or
created in house. For example, identify those laboratory testing reagents that must be freshly prepared
each day. If sampling equipment must be prepared in advance using specific procedures, describe the
process for ensuring that such equipment is available and readily identifiable to field personnel. These
requirements may be met through a laboratory's current quality systems as required by drinking water
certification and method implementation in its state.
M Assessment and Response Actions
Use the section below to briefly describe how the results will be used to assess the situation and determine
appropriate responses. The details should be consistent with the statement of the problem in Section C,
the description of the parameters of interest and any associated limits in Section E, and QC requirements
in Section I. Where practical, identify the person or persons making each assessment and those
responsible for the responses, by name, organization, and role.
N Data Review, Validation, and Verification
In the context of this plan, data review refers to the process by which the person or organization
generating primary data ensures that the results are correct and accurately represent what took place.
"Self-inspection" is another term that has been used for this process. Data validation refers to those
procedures used by an independent party to assess the validity of the results. The independent party may
be another participant in the project (i.e., not part of the laboratory that generated the results), or an
outside party whose sole responsibility is to validate the data. Data verification refers to the steps taken to
ensure that the quality (or limitations) of any secondary data used in the project (secondary data being
data which were not generated as part of the project, but taken from other sources, including literature,
other projects, etc.).
The extent to which these review, validation, and verifications processes can be accomplished in an
emergency response situation will vary. Some steps may be taken as the primary data are generated (e.g.,
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some level of self-inspection by the laboratory staff), while others may be carried out retrospectively
(after the project decisions have been made) as support for the overall project.
Use the section below to describe any procedures used to review data, validate results, and verify results,
identifying the person or persons responsible for each process by name, organization, and role. Clearly
indicate those procedures that will be carried out during the project and those that will be carried out later.
O Reports
Use this section to describe any anticipated reports or summaries of project activities. For reports of
results that are needed to make decisions, identify the recipient (e.g., the project manager or on-scene
coordinator), how the information will be transmitted (e.g., by telephone, facsimile, or email), and the
timeframe. For summaries of project activities, or final reports, identify the persons or organizations
responsible for generating each report, the intended audience, and any project personnel responsible for
reviewing and approving the reports
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Appendix O Structure of the Incident Command System
In 2003, the President issued Homeland Security Presidential Directive (HSPD) 5 that directed the Secretary of
the Department of Homeland Security (DHS) to develop the National Incident Management System (NIMS)
Incident Command System (ICS). NIMS provides a consistent framework for federal, state, and local
governments, and private sector and nongovernmental organizations to work together to plan, prepare, respond,
and recover from domestic incidents, including catastrophic terrorism acts. HSPD 5 also directed the Secretary of
DHS to develop the National Response Plan (now the National Response Framework) to integrate federal
government domestic planning, preparedness, response and recovery (addressing all hazards) into a single plan.
The WLA-RP uses the NIMS framework as a mechanism to provide guidance and direction for federal support to
state, local, and tribal incident managers.
ICS is a flexible and scalable system driven by the tactical needs of the responders at the scene. It provides a
common structure and terminology that facilitates the integration of multiple agencies while still maintaining a
coherent chain of command. ICS also provides standardized training, pre-designated leadership positions,
specific span of control, and well-understood assigned responsibilities. This approach will provide consistency in
addressing key aspects of a response such as organizational elements and lines of communication. The system is
built around five major response management functional areas: Command, Planning, Operations, Logistics, and
Finance. These functional areas may be further subdivided depending on the situation and its complexity.
An Incident Commander (1C) typically handles the command function and is responsible for overall management
of the incident. The command function normally includes a Public Information Officer (PIO), a Liaison Officer,
and a Safety Officer. The PIO is responsible for developing and releasing, when approved, information regarding
the incident to the press and public. Only one PIO exists per incident command. A Liaison Officer may exist in
multi-jurisdictional incidents or where several agencies are involved, and serves as the point of contact for
personnel assigned to the incident by assisting or cooperating with agencies. The Safety Officer is responsible for
safely conducting all operations of the incident command, and develops and recommends measures for ensuring
personnel safety and for assessing hazardous situations.
The remaining response management functional areas are known as general staff. Their responsibilities include:
Operations Section - Management of all operations directly applicable to the primary mission. This
section activates and supervises organizational elements in accordance with an Incident Action Plan (IAP)
and directs its execution. It also requests and releases resources and makes changes to the IAP as
necessary.
Planning Section - Collection, evaluation, dissemination, and use of information regarding the
development of the incident and resources status. The Planning Section may include an Environmental
Unit (EU) which facilitates interagency environmental data management, monitoring, sampling, analysis
and assessment. The EU is responsible for scientific support for a response, including support for
response technologies, modeling and data interpretation, natural resources and ecological issues and
establishment of standard methods and permitting issues. It participates in developing sampling and
analysis plans; receives field data from the Operations Section and/or electronic deliverables from
laboratory support; and verifies, interprets, and manages data, among other activities. This role may be
supported by a Scientific Support Coordinator (SCC) who is a technical expert in the issues at hand. The
SSC is a technical specialist and is defined in the National Contingency Plan as the principal advisor to
the Federal On-Scene Coordinator (FOSC) for scientific issues. The SSC is responsible for providing
expertise on chemical hazards, field observations, trajectory analysis, resources at risk, environmental
tradeoffs of countermeasures and cleanup methods, and information management. The SSC is also
charged with gaining consensus on scientific issues affecting the response, but ensuring that differing
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opinions within the scientific community are communicated to the Incident Command. The SSC can
serve as the Environmental Unit Leader.
Logistics Section - Provision of facilities, services, and materials to support the response. It also
participates in developing and implementing the IAP.
Finance Section - Oversight of all financial and cost analysis aspects of the incident.
An ICS may be expanded into a Unified Command (UC). The UC is a structure that brings together ICs of all
major organizations involved in the incident to coordinate an effective response while simultaneously carrying out
their own responsibilities. The UC links the organization responding to the incident and provides a forum for
these agencies to make consensus decisions.
A UC may be used whenever multiple jurisdictions are involved in a response effort. These jurisdictions could be
represented by:
Geographic boundaries (e.g., two states, Indian tribal land)
Governmental levels (e.g., federal, state, local, tribal)
Functional responsibilities (e.g., fire, oil spill, Emergency Medical Services (EMS))
Statutory responsibilities (e.g., Federal Land Managers, Responsible Party)
Some combination of the above
The composition of a UC for a specific incident will be determined on a case-by-case basis. Factors to consider
are incident specifics, determinations outlined in existing response plans, and decisions reached during the initial
meeting of the UC. UC composition may change as the incident progresses. For a UC to be effective, the number
of personnel should be kept as small as possible. A well-defined process requires the UC to set clear objectives to
guide the on-scene response resources.
Figure N-l shows the main ICS structure and how it might interact with the ASR/PRL/MSL structure described
in the WLA-RP. Each of the general staff functions may be further subdivided depending on the situation. This
structure may also increase in complexity as necessary. For more information, please refer to the draft EPA
National Incident Management Handbook.
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Figure N-1. Interaction of the ICS with the WLA-RP Structure
Operations
Command
Incident Commander (1C)
Logistics
Includes:
- Public Information Officer (PCO)
- Liaison Officer
- Safety Officer
Planning
Finance
Analytical Services
Requestor (ASR)
Primary
Responding
Laboratory (PRL)
Or
Environmental Unit
1
Mutual Support
Laboratory (MSL)
Mutual Support
Laboratory (MSL)
Mutual Support
Laboratory (MSL)
Mutual Support
Laboratory (MSL)
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Appendix P Reimbursement Tips for Emergency Laboratory
Response
Note: The document below is a WLA Fact Sheet and can be found at:
www.epa.gov/safewater/watersecurity/pubs/fs watersecurity reimbursementtips laboratory.pdf.
The Water Laboratory Alliance (WLA) provides the Water Sector with an integrated nationwide network of
laboratories with the analytical capabilities and capacity to support monitoring and surveillance, and
response and remediation in the event of intentional, unintentional, and natural water contamination; and
the WLA-Response Plan provides a comprehensive approach to providing a coordinated multi-laboratory
response these events. Emergency response and recovery costs incurred by laboratories supporting the
Water Sector following an incident may be eligible for reimbursement through local, state, or federal level
mechanisms. This tips sheet has been developed in support of the WLA to facilitate laboratory
reimbursement activities.
While the rules for allowable activities vary between reimbursement mechanisms, lessons learned from
past incidents reveal that reimbursement is commonly not maximized due to either lack of knowledge or
failure to follow proper procedures and processes specific to a particular mechanism. This document
presents tips laboratories can use to develop or refine internal processes and procedures that may
maximize their ability to receive reimbursement. The tips are organized by activities before and after an
incident.
Before an Incident
Identification of appropriate resources and mechanisms facilitates the reimbursement process. In
general, laboratories that may provide emergency support services in response to an authorized
Analytical Services Requester (ASR) (e.g., Incident Commander, Analytical Coordinator, Primary
Responding Laboratory [PRL], and local, state or federal emergency operations center representative or
state Emergency Management Assistance Compact [EMAC] coordinator) and seek reimbursement for
these services should prepare in advance. Consideration of the following pre-incident planning and
preparation activities may be helpful:
Review reimbursement eligibility, mechanisms, and resources for laboratory support activities and
how they might differ if response is at a local, state, or federal level.
Establish emergency procurement procedures and logistics for essential laboratory supplies.
Review current staffing and identify personnel and procedures to support contingency or
extraordinary staffing requirements.
Review current resource typing criteria and information (e.g., FEMA 501-9; NIMS Basic Resource
Typing System) for applicable resources.
Review requirements (e.g., sample identification) for criminal and forensic sample analyses.
Establish accounting codes to capture, track, and distinguish routine operational costs from
incident support-related costs (including pre-incident emergency work).
Describe compensation (e.g., overtime) in the personnel policy and review any limitations on
analyst hours (e.g., maximum number of hours in Biosafety Level 3 on a daily basis).
Document routine hours of use for equipment and instrumentation.
Develop...
and maintain a thorough pre-incident inventory of critical resources, including equipment and
instrumentation, reagents, supplies, and consumables related to specialized or anticipated
support activities.
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a comprehensive listing of available support resources (e.g., personnel, analytical capabilities and
capacities, analytical instrumentation, sampling equipment, and supplies) and register your
laboratory with EPA's Compendium of Environmental Testing Laboratories
(http://epa.gov/compendium), if appropriate.
and maintain records of all routine Quality Assurance and Quality Control (QA/QC) procedures
(types and frequency).
and maintain thorough maintenance and calibration records for laboratory equipment and
instrumentation including all required procedures and intervals.
and maintain standard sample evidentiary chain of custody protocols (Note: a link to internal
chain of custody training is available on the WLA Web site).
During and After an Incident
When the potential exists for laboratory support reimbursement, laboratories must maintain accurate
records of expenditures associated with support of an incident. Laboratories may find the following
activities and accounting procedures helpful during and after an incident:
Coordinate with emergency management agencies at local, state, and federal levels to identify all
incident-related activities and ensure that a complete list is provided to State Emergency
Management Agency (EMA), Federal Emergency Management Agency (FEMA) officials and the
Incident Commander, or other responsible designee.
Review reimbursement eligibility, mechanisms, and resources for laboratory support activities.
Review time limitations for potential reimbursement sources, as well as any deadlines for
requesting extensions.
Develop a detailed cost summary sheet to support claims for reimbursement.
Develop and maintain a system to cross-check and validate all records.
Provide secure on-site and off-site storage of all records.
Document...
labor costs in detail utilizing pre-established accounting codes to identify incident-related costs
(including emergency work conducted before a state or federal declaration of disaster). Ensure
that documentation can 1) distinguish between regular and overtime, 2) provide hours on a per-
person, per-day basis, and 3) provide detail on all tasks performed, including hours per task and
task location. In particular, track costs for...
o staff exchange.
o consulting services.
o data review.
o sample collection, analysis, disposition, and disposal.
non-labor costs through pre-established accounting codes and/or detailed logs that 1) separate
emergency from permanent work, 2) provide detail on date, location, task, analyst/technician, and
hours of use, and 3) account for equipment damage/extraordinary use. In particular, track...
o analytical costs, including use/replacement of reagents and supplies and QA/QC analyses.
o courier/transport costs for samples; disposition, storage and disposal of samples, and/or
records.
o acquisition of equipment and equipment (e.g., autoclaves and computers) usage costs
associated with the incident (e.g., need for accelerated equipment maintenance and
calibration, need for earlier replacement of parts, such as microscope bulbs).
o overflow laboratory costs (i.e., the cost of contracting laboratories to cover routine support).
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o incidental costs, such as temporary re-location (e.g., airfare, lodging, food, rental vehicle).
The following resource also may be useful in determining eligibility and reimbursement requirements:
FEMA Public Assistance Information: www.fema.gov/government/grant/pa/
Contact Us
For additional information on the Water Laboratory Alliance, please contact WLA@epa.gov or see
http://cfpub.epa.gov/safewater/watersecurity/wla.cfm. Latisha Mapp may also be contacted directly at
mapp.latisha@epa.gov.
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Appendix Q References and Resources
Laboratory Networks and Associations
Q.1 Water Laboratory Alliance (WLA)
The WLA provides the Water Sector with an integrated nationwide network of laboratories with the
analytical capability and capacity to respond to intentional and unintentional drinking water
contamination events involving chemical, biological, and radiochemical contaminants.
http://cfpub.epa.gov/safewater/watersecurity/wla.cfm
Q.2 Environmental Response Laboratory Network (ERLN)
EPA's ERLN is a national network of laboratories that provides analytical capability and sufficient
capacity to meet project-specific data quality objectives on an as-needed basis. The ERLN integrates
capabilities of existing public sector laboratories with accredited private sector laboratories to support
environmental responses, http://www.epa.gov/erln/index.html
Q.3 CDC Laboratory Response Network (LRN)
The LRN is charged with maintaining an integrated network of state and local public health, federal,
military, and international laboratories that can respond to bioterrorism, chemical terrorism and other
public health emergencies, http://www.bt.cdc.gov/lrn/
Q.4 Food Emergency Response Network (FERN)
FERN integrates the nation's food-testing laboratories at the local, state, and federal levels into a network
that is able to respond to emergencies involving biological, chemical, or radiological contamination of
food. The FERN structure is organized to ensure federal and state inter-agency participation and
cooperation in the formation, development, and operation of the network. The FERN plays a number of
critical roles related to food security and food defense, including prevention, preparedness, response, and
recovery. FERN provides training, proficiency testing, method development and validation, surveillance,
electronic communication, and laboratory outreach/cooperative agreements, http://www.fernlab.org/
Q.5 Association of Public Health Laboratories (APHL)
APHL promotes the role of public health laboratories in shaping national and global health objectives,
and promotes policies, programs, and technologies which assure continuous improvement in the quality
of laboratory practice and health outcomes. A membership must be purchased to access most APHL
publications and services. To view APHL services go to http://www.aphl.org/pages/default.aspx.
Q.6 National Animal Health Laboratory Network (NAHLN)
The USDA NAHLN is a network of laboratories that is organized and supported to have the capacity to
respond to animal-disease outbreaks nationwide. The network is a cooperative effort between the USDA
Animal and Plant Health Inspection Service (APHIS), the National Institute of Food and Agriculture
(NIFA), and the American Association of Veterinary Laboratory Diagnosticians (AAVLD).
http://www.aphis .usda.gov/animal health/nahln/
Q.7 Emergency Management Assistance Compact (EMAC)
EMAC is a congressionally ratified organization that provides form and structure to interstate mutual aid.
The EMAC mutual aid agreement and partnership between member states exist becausefrom hurricanes
to earthquakes, wildfires to toxic waste spills, and terrorist attacks to biological and chemical incidents
all states share a common enemy: the threat of disaster, http://www.emacweb.org/
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Tools and Databases
Q.8 Compendium of Environmental Testing Laboratories (Lab Compendium)
EPA's Lab Compendium is a secure Web-based system that provides users the ability to access and
identify appropriate laboratories to support specific analytical needs. The Lab Compendium contains
laboratory records for several hundred public and private sector environmental testing laboratories and
can be accessed at: http://www.epa.gov/compendium.
Q.9 Response Protocol Toolbox (RPTB) (EPA-817-D-03-001 to 007, December 2003)
Organized in modular format, the Toolbox assists with emergency response preparedness and is of value
to drinking water utilities, laboratories, emergency responders, state drinking water programs, technical
assistance providers and public health and law enforcement officials. These modules provide emergency
response planning tools that are designed to help the water sector to effectively and appropriately respond
to intentional contamination threats and incidents.
http://cfpub.epa.gov/safewater/watersecurity/home.cfm ?program_id=8#response_toolbox
Q.10 Water Contaminant Information Tool (WCIT) for Priority Contaminants
WCIT is a secure on-line database with methods for more than 800 analytes, including detailed profiles
for over 100 chemical, biological, and radiological (CBR) contaminants of concern for the Water Sector.
This allows users to compare and contrast the performance, speed, and relative cost of analytical methods
for response to all-hazard incidents from CBR type contaminants. This tool compiles drinking water and
wastewater-specific data in a single location to help plan for and respond to drinking water contamination
incidents. WCIT functionality and data were shaped and validated by water utility professionals,
scientists, and public health experts. WCIT also features an enhanced "Google-like" search function
capable of scanning all searchable fields in the database. For more information and to learn how to sign-
up for WCIT, visit http://water.epa.gov/scitech/datait/databases/wcit/index.cfm.
Q.11 WaterlSAC
WaterlSAC is a community of water sector professionals who share a common purpose: to protect public
health and the environment. WaterlSAC serves as a clearinghouse for government and private
information that helps subscribers identify risks, prepare for emergencies and secure the nation's critical
water infrastructure. Users must apply to gain access to WaterlSAC. WaterlSAC's services can be
viewed at: http://www.waterisac.org/.
Q.12 Sampling Guidance for Unknown Contaminants in Drinking Water (EPA-817-R-08-
003, November 2008)
This document provides comprehensive guidance that integrates recommendations for pathogen, toxin,
chemical, and radiochemical sample collection, preservation, and transport procedures to support multiple
analytical approaches for the detection and identification of potential contaminants in drinking water. The
guidance is intended to support sampling for routine and baseline monitoring to determine background
concentrations of naturally occurring pathogens, sampling in response to a triggered event, and sampling
in support of remediation or decontamination efforts. The sampling guidance can be found at:
http://www.epa.gov/safewater/watersecurity/pubs/guide watersecurity samplingforunknown.pdf.
Q.13 Web-based Electronic Data Review (WebEDR)
EPA's WebEDR is a web-based system that performs automated data evaluation on ERLN Electronic
Data Deliverables (EDDs). http://webedr.fedcsc.com/app/
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Q.14 National Homeland Security Research Center (NHSRC)
Presidential Directives identified EPA as the primary federal agency responsible for public water supplies
and remediation following an attack on indoor or outdoor areas. In recognition of this expanded role, EPA
established a homeland security research program. This research program is charged with developing and
delivering reliable, responsive expertise and products based on scientific research and evaluations of
technology, http://www.epa.gov/nhsrc/
Analytical Method Information
Q.15 Standardized Analytical Methods (SAM)
SAM is an EPA NHSRC effort to list laboratory analytical methods for priority contaminants relevant to
water security. The methods can be used by environmental laboratories identifying and measuring
chemical, radiochemical, and biotoxin contaminants in environmental samples associated with
remediation activities following a contamination incident. SAM can be found online at:
http://www.epa.gov/sam/. In conjunction with SAM, NHSRC is developing SAM companion documents
that are intended to provide information regarding field screening equipment, sample collection,
laboratory rapid screening/preliminary identification equipment, and sample disposal in support of the
confirmatory methods and analytes listed in SAM. SAM companion documents will be posted on
NHSRC's SAM website (http://www.epa.gov/nhsrc/sam.html) as they become available.
Q.16 Standard Methods for the Examination of Water and Wastewater (2005)
Standard Methods for the Examination of Water and Wastewater is a comprehensive reference that
presents all aspects of water and wastewater analysis techniques. Standard Methods is a joint publication
of the American Public Health Association (APHA), the American Water Works Association (AWWA),
and the Water Environment Federation (WEF). http://www. standardmethods.org/
Q.17 EPA Drinking Water Analytical Methods and Laboratory Certification
This website supports EPA's certification program for laboratories conducting drinking water sample
analyses. This site includes information on the laboratory certification program, EPA approved analytical
methods for drinking water analyses, and the method approval processes.
http://water.epa.gov/scitech/drinkingwater/labcert/methods_index.cfm
Q.18 EPA Test Method Collections
This EPA site comprises a collection of analytical test methods for all media. It also provides information
on current research and development efforts, a list of sources with weblinks, a federal contact list, and
regional laboratory contacts. To view the collection, go to
http: //www. epa. gov/O S A/fem/methcollectns .htm.
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Appendix R Regional Laboratory Contact Information
Note: This appendix serves as a placeholder for regions to insert their
laboratories' contact information and any Region specific information.
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