Water Contamination Incident Remediation Plan (WaterCIRP) Guide and Template for Drinking Water and Wastewater Utilities


£%	United States

Environmental Protectio
hI	Agency

Water Contamination Incident
Remediation Plan (WaterCIRP)

Guide and Template for Drinking
Water and Wastewater Utilities

[Department/Agency Name]

[Department/Agency Address (Street, City, State, Zip Code)]

Office of Water (4608T) EPA 810-F-23-025 January 2024

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Water Contamination Incident Remediation Plan (WaterCIRP) Guide and Template

This guide, and accompanying template, describe the components needed to develop a comprehensive
Water Contamination Incident Remediation Plan (WaterCIRP). A WaterCIRP can be used by drinking
water and wastewater utilities to detail how remediation actions will be implemented, monitored, and
evaluated for effectiveness during water contamination incidents (refer to the red box in Figure 1 from
EPA's Distribution System Contamination Incident Action Checklist). Given the variability among the
potential contamination incidents, the template is formatted to enable water systems flexibility to
modify and adapt their WaterCIRP, as needed.

Figure 1. Water Contamination Incident Response and Recovery

O
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During a contamination incident, remediation action decision-making and/or response objectives may
be informed or guided by federal, state, local, tribal, or territorial (SLTT) public health and/or
environmental organizations as part of an Incident Command or Unified Command (IC/UC). Incident
Command System (ICS) resources can be found via the following EPA link and/or FEMA link. Utilize
relevant ICS and National Incident Management System (NIMS) documentation and command
management structures to support the WaterCIRP and its facilitation during an incident. Relevant ICS
forms can be used to develop a common operating picture and an Incident Action Plan. This Water
Contamination Incident Remediation plan would be attached to the incident management team plan or
IC/UC full incident action plan to represent the strategies and tactics being implemented for
contamination remediation.

During response activities, it is critical to ensure consistent coordination and updating/issuing risk
communication/public notification with the public information officer as remediation actions are
implemented. Public notifications should constantly be assessed during remediation to ensure the
public is aware of progress toward clearing the system for normal use. The drinking water and
wastewater utility should coordinate issuing notices with the primacy/regulatory agency and public
health authorities and keep customers informed of activities that could impact them.

In addition to the development of a WaterCIRP, incident-specific documents including the Health and
Safety Plan (HASP), Sampling and Analysis Plan (SAP), Quality Assurance Project Plan (QAPP), and Waste
Management Plan (WMP) may need to be developed. As remediation progresses, the WaterCIRP, HASP,
SAP, and WMP should be reviewed and updated as needed. The appendix contains additional
information on the HASP, SAP, QAPP, and WMP.

This section describes background information about the incident and contamination information,

determined during characterization, that is used to develop and implement remediation actions.

1.1 Incident Background

~ Provide a description of the incident. Include (1) name of contaminant(s) that entered the
system, (2) how much contaminant entered the system (if known), (3) time and date
contamination was detected, (4) how and when the contaminant was detected, (5) number and
types of customer complaints, (6) initial water quality analytical results, (7) if known, how the
contaminant was introduced into the system, (8) system operations since the beginning and
during the contamination incident, (9) operational responses to limit the movement of
contaminated water or wastewater (such as closed valves, isolated tanks, or other actions to
hydraulically isolate areas of the system), (10) other response actions taken including
implementation of the Incident Management System and coordination with response partners,
(11) risk communication measures and public notifications regarding contamination such as "Do
Not Drink" or "Do Not Use Order") orders, and (12) measures taken to provide an emergency
water source (e.g., bottled water, tanker trucks).

~ List/identify the roles, responsibilities, and contact information for utility staff and external
partner organizations (e.g., primacy agencies, federal, SLTT public health and/or environmental
organizations, emergency responders, contractors, technical assistance providers) involved
in/consulted on the response to this point.

The incident background can be entered into the template, and, if needed, supplemental
information (e.g., map of contaminated area) can be attached to the WaterCIRP.

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1,2 Contaminant Characteristics arid System Components Affected

~ Describe contaminant characteristics and possible interactions with infrastructure materials.
Include information such as (1) the Maximum Contaminant Level, if one exists, and (2) health
impacts.

• This information may be provided by the responsible party (i.e., entity that created the
contamination) or appropriate regulatory body that has oversight of the facility.

— A helpful resource includes EPA's Water Contaminant Inform at (WCIT), a database

with information on over 800 drinking water and wastewater contaminants, including
pathogens, pesticides, and toxic industrial chemicals. WCIT users must register and be
approved for a WCIT account.

Attach the contaminant's Safety Data Sheet and other relevant background information as an
appendix to the WaterCIRP.

~ List public health and environmental risks of the contaminant at concentrations detected.

~ Identify any statutory and regulatory requirements surrounding the contaminants and any
aesthetic levels (taste, odor, color) that might make the water undesirable for use.

• This information should come from the appropriate regulatory body.

• List changes in water use restrictions (i.e., a change from "Do Not Use" to "Do Not Drink" or
allowing use for fire suppression only).

~ Describe approximate boundaries or areas of contamination/system components affected and,
if applicable, prioritization of affected areas. Include maps and/or hydraulic models of impacted
area and pictures, if available. This can include:

• Drinking Water - source water; raw water transmission pipe; treatment facilities; water
within the distribution system; distribution system pipes; pumping facilities; finished water
storage; premise plumbing; interconnections with other water systems, etc.

• Wastewater - wastewater within the effluent collection system; sewage collection system
pipes; collection system overflows; lift stations; treatment facilities; meter vaults; combined
sewer and storm water storage facilities, etc.

~ List the potential number and types of customers impacted.

2.0 Remediation Plan(s)

This section describes the determination, development, implementation, and evaluation of remediation
actions for treatment of the water and decontamination of the system, including infrastructure and
disposal options. It may be necessary to identify and implement multiple remediation actions and
methods to address each of the contaminated areas. In addition, the sampling and analysis approach
may change based on the goal of the sampling (e.g., determining extent of contamination versus efficacy
of the remediation actions).

2.1 Remediation Objectives

~ Determine remediation objectives - the intent of the actions used to remediate the system.

and state what the cleanup will accomplish, including whether the intent is for the water to be
safe to drink/use (for drinking water) or to meet environmental standards (for wastewater).
Describe system constraints that may affect the remediation objectives. Incidents can involve
multiple contaminants of concern that may be difficult to evaluate using a single method.

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Consider what will serve as the indicator(s) of contamination when developing objectives.

Consult with the appropriate entities such as primacy agencies, federal, SLTT public health
and/or environmental organizations, emergency responders, contractors, technical assistance
providers, and consider the following resources and requirements when determining what the
objectives should achieve:

— Safe Drinking Water Act (SDWAi requirements including Maximum Contaminant Levels
(MCLsi.

— National Pollution Discharge Elimination System (NDPESi Permit Requirements.

— Radiation Protective Action Guides (PAGsi.

— Agency for Toxic Substances and Disease Registry (ATSDR).

— Public health and regulatory agency requirements for unregulated contaminants.

-> Federal, state, local, tribal, or territorial public health and/or environmental regulatory
requirements.

-> Any other applicable federal, SLTT regulatory requirements.

~ Determine the clearance goals for each contaminant (i.e., contaminant concentration at which
the system may be returned to normal service and advisories removed). Consider:

• Public health and environmental risks

• Regulatory levels

• Aesthetic concerns

• Public perception

~ Identify tentative timelines for near-term (i.e., hours and/or days) and long-term goals.

2,2 Remediation Action(s) Identification and Development Phase

~ Identify and select possible remediation action(s) and strategies to be taken based on
established objectives. Remediation is the process of removing or limiting the effect of a
contaminant that has entered the drinking water or wastewater system. Remediation actions
may include:

• Water treatment, the addition of chemicals, physical removal such as filtration or adsorption
conducted to remove the contaminant from drinking water and wastewater or to decrease
the concentration to an acceptable level.

• Removal, transportation, and disposal of contaminated water from within the system.

• Distribution system flushing, the discharge of water out of the entire drinking water or
wastewater system or part of the system. Routine flushing is recognized as a best
management practice to maintain distribution system water quality. During remediation,
flushing may be considered to discharge contaminated water.

• Infrastructure decontamination, the removal or treatment of contaminants that are adhered
to physical infrastructure.

• Infrastructure replacement, the removal, disposal, and replacement of some portion of the
utility's physical infrastructure that was affected by the contaminant(s).

• Premise plumbing should also be evaluated and addressed in parallel with remediation of the
water system.

Resources that could be used when selecting remediation actions include:

— EPA's Science Models and Research Tools (SMaRT), a searchable inventory of models, tools,
and databases from EPA's Office of Research and Development.

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— EPA's Water Treatability Database, a searchable database containing referenced

information gathered from thousands of literature sources on the treatment of over 120
individual drinking water contaminants.

-> Consultation with regulatory agencies or subject matter experts (i.e., American Water
Works Association [AWWA], Water Environment Federation [WEF], Water Information
Sharing & Analysis Center [WaterlSAC]).

~ Identify the benefits and feasibility of each potential remediation action.

~ Coordinate with the appropriate entities such as primacy agencies, federal, SLTT public health
and/or environmental organizations, emergency responders, contractors, technical assistance
providers to ensure that remediation action will be in compliance with applicable regulations
and/or will not incur enforcement actions.

~ Develop and document the remediation strategies. Consider the following:

• Processes and procedures necessary for implementation.

• Monitoring and evaluation criteria to assess the success of each remedial action.

• Operational constraints.

• Potential limitations of the remedial action(s).

• Near-term and long-term actions.

• Evaluate remediation actions and approaches using tools/resources (e.g., modeling).

• Confer with subject matter experts and regulatory entities.

• Identify contingencies.

• Document signatories on the final strategies.

• Develop a Clearance strategy to confirm overall success of remediation actions (refer to
Section 3.0 Clearance/Return to Service).

Attach the final remediation strategies and supporting data as an appendix to the WaterCIRP.

~ List roles and responsibilities and contact information for utility staff and external partner
organizations involved (e.g., primacy agencies, federal, SLTT public health and/or environmental
organizations, emergency responders, contractors, technical assistance providers, industrial
hygienists, health and safety personnel, laboratories).

2.3 Sampling and Analytical Approach

~ Describe worker safety measures and practices, such as use of appropriate PPE (e.g., safety
gear), monitoring, and other safety controls. EPA provides an outline on the four levels of PPE.

~ Determine and provide an overview of sampling and analysis approaches for both the
remediation and clearance phases including:

• Sampling procedures for both field and laboratory analysis.

• Field analytical methods.

• Laboratory analytical methods.

• Laboratories providing analytical support.

-> More than one laboratory may be required to support sampling and analysis. EPA's
Water Laboratory Alliance provides a nationwide network of laboratories designed to
provide analytical support during contamination incidents that may exceed utility
laboratory capability and capacity.

-> Laboratory certification for analysis of unregulated contaminants is generally not
available through the state. Therefore, it may be necessary to work with laboratories

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that are qualified but not certified. For additional information, EPA provides the
Sampling Guidance for Unknown Contaminants in Drinking Water.

• If applicable, evaluate the need for expedited sampling support. Describe the availability
and immediate support for lab analysis to provide timely results for decision making
needs. This could include potential expedited escorts, air transportation, or on-site analysis
that may assist with timely sample results.

• QA/QC details for the selected sampling and analysis approaches and updates to the
incident QAPP with the requirements. Inform any laboratories receiving samples of the
requirements. Include a reference to the QAPP in the WaterCIRP.

~ Describe shipping and Chain-of-Custody form requirements. This may include (1) conditions for
transportation and storage of samples, (2) tracking numbers, (3) how to maintain and manage
Chain-of-Custody requirements, (4) where to deliver or ship samples, and (5) instructions for
sample and records retention.

~ Attach the following sample collection forms, as appropriate:

• Map with sampling locations identified, if available.

• Chain-of-Custody form.

• Site characterization form (e.g., field measurements).

The sampling and analytical approach section of the WaterCIRP will provide high-level information.
Additional details will be provided in the incident-specific HASP and SAP. Refer to the Appendix for
additional guidance on developing the HASP and SAP.

2.4 Water Remediation Actions

~ Describe worker safety measures and practices, such as use of appropriate PPE (e.g., safety
gear), monitoring, and other safety controls. EPA provides an outline on the four levels of PPE.

~ Describe remediation action(s) that will be used. Include rationale that supports the selected
remediation action(s), uncertainties or contingency measures with selected action(s), and any
consultation or comments from regulatory agencies or subject matter experts (i.e., utility
consultants, AWWA, WEF). Consider:

• Potential public health and environmental impacts associated with remediation activities.

• Compliance with applicable regulations.

• Whether remediation actions will potentially incur enforcement actions.

• Benefits and consequences of each remediation action.

~ Identify parameters that will be measured to monitor and assess removal efficacy and the
impact of the remediation action(s) on water quality:

• Contaminant or surrogate concentrations.

• Byproduct levels.

• Water quality parameters (e.g., pH, total organic carbon, turbidity, chlorine residual,
dissolved oxygen).

~ List remediation action sequence of operations. Consider the following:

• Site preparation and permitting (what is needed, applicable permits from which agencies).

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• Evaluate the availability of resources (e.g., equipment, personnel), if necessary, request
resources from neighboring utilities and mutual aid organizations (e.g., WARN).

• Establish site security, access control, and considerations for neighborhood/impacted area.

• Consideration for power, communications, and monitoring needs.

• Timing and means of equipment delivery.

• Implementation requirements (pumps, piping, bypass equipment, sampling devices, and the
need for off-site disposal facility and transport).

~ List roles and responsibilities and contact information for utility staff and external partner
organizations (e.g., primacy agencies, federal, SLTT public health and/or environmental
organizations, emergency responders, contractors, technical assistance providers, industrial
hygienists, health, and safety personnel).

2.5 Infrastructure Decontamination Procedures

~ Describe worker safety measures and practices, such as use of appropriate PPE (e.g., safety
gear), monitoring, and other safety controls. EPA provides an outline on the four levels of PPE.

~ Describe infrastructure decontamination method(s) and/or removal/replacement
approach(es). Consider:

• Whether infrastructure decontamination generates water that must be treated and/or or
removed from the system. Refer to Section 2.6 for management of any wastewater
produced as part of the decontamination process.

• If infrastructure decontamination is not effective and removal/replacement is necessary.

• System limitations and operating conditions (such as maintaining system within a specific
pressure).

~ Provide the infrastructure decontamination sequence of operations. Determine prioritization
of infrastructure, if applicable. Consider the order in which areas of the distribution system will
be decontaminated and if or when customers/locations will be affected, along with any other
use restrictions. Consider developing and attaching a process flow chart that depicts the order
of remediation actions needed to clear each system component affected by the contamination.

~ Provide the infrastructure removal/replacement sequence of operations. Determine
prioritization of infrastructure, if applicable, and consider developing and attaching a process
flow chart that depicts the order of infrastructure removal/replacement and if or when
customers/locations will be affected.

2.6 Waste Management and Disposal

~ Describe worker safety measures and practices, such as use of appropriate PPE (e.g., safety
gear), monitoring, and other safety controls. EPA provides an outline on the four levels of PPE.

~ Describe waste management activities. Include all waste materials and liquid wastes, or
byproducts generated during decontamination activities, and detail the waste management
procedures used during response activities. Determine volume of waste and its feasibility to be
stored, hauled, and/or treated. Waste management can include:

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• In-situ containment of the water during treatment.

• Temporary storage of water (including applicable regulations, contracts, or permits).

• Transportation of the water off-site (including applicable regulations, contracts, or permits).

• Source reduction or other actions to minimize/control the volume of waste material
generated.

~ Explain waste disposal procedures. Ensure the selected water treatment methods are adequate
to treat water to levels acceptable for the disposal option (this includes any byproducts
generated during decontamination activities). Consult destination jurisdiction and regulatory
oversight agencies for protocols and sample requirements. Include:

• Final disposal locations (i.e., a water reclamation facility, groundwater or surface water
discharge, solids disposal facility) and include any related disposal permits.

• Volume of material to be transferred.

• The request and receipt(s) from waste carriers and/or the disposal facility, indicating
pertinent information (e.g., time, date, facility location, and volume and classification of the
disposed material). Include record/document management procedures (e.g., retention
requirements) for receipts from waste carriers and/or waste disposal facilities.

The waste management and disposal section of the WaterCIRP will provide high-level information.

Additional details will be provided in the incident-specific WMP. Refer to the Appendix for additional

guidance on developing the WMP.

3.0 Clearance/Return to Service

To achieve clearance goals and return the system to normal operations, the following actions may be

taken:

~ Document the clearance strategy to confirm the overall success of the remediation actions at
removing the contamination and to clear the system for normal operation. Perform additional
sampling and analysis throughout the contaminated areas to verify that clearance goals and
remediation objectives have been achieved.

• Samples should be collected from across all portions of the contaminated area and include
large and small diameter water mains, service lines, different pressure zones, and major
system components such as storage tanks and pump facilities.

• Depending on the incident, different sections of the system may be cleared at different
times or clearance may occur gradually by allowing different uses of the water (e.g., toilet
flushing, bathing, drinking).

• Include the primacy/regulatory agency, as well as any SMEs or other stakeholders, when
making final clearance decisions.

• If sampling indicated clearance goals have not been achieved, the strategy should return to
the remediation development to reassess the actions and strategies selected.

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Appendix: Supplemental Reference Information

Key Terms

• Characterization: Determining the extent of contamination and infrastructure affected by the
incident.

• Water Treatment: Any activity conducted to remove the contaminant from drinking water and
wastewater or to decrease the concentration to an acceptable level.

• Infrastructure Decontamination: The inactivation or elimination of contaminants on surfaces.

• Clearance: The process of determining if the clearance goal(s) and remediation objectives have been
met.

• Operational Responses: Actions and strategies taken by the utility in response to a contamination
incident to isolate, mitigate, treat, or remove the contaminant from the system and/or
infrastructure.

• Risk Communication: Communications with response partners and the public during a water
contamination event.

• Recovery: When clearance goals and remediation objectives have been met, a water or wastewater
utility may implement a long-term monitoring plan to ensure the remediation actions taken are
effective in the long-term. This may include limited sampling and analysis within the affected areas
and development of additional actions or strategies to further implement full return to normal and
long-term recovery needs.

Health and Safety Plan

In the context of this guide, the purpose of a Health and Safety Plan (HASP) is to ensure maximum
protection to workers in a way that is consistent with requirements needed to safely perform sample
collection and operational efforts during remediation of a water contamination incident. Each
contamination incident poses specific health hazards, and an incident-specific HASP should be available
to sample collectors. For PPE guidelines, refer to OSHA 29 CFR 1910.120 Appendix B. HASPs should, at a
minimum, include instructions and guidelines in accordance with OSHA regarding:

• Names, positions, and contact information • Site or incident control

of key personnel and health and safety • Emergency response plan, containing off-
personnel site emergency contact information such as

• Site- or incident-specific risk assessment local hazardous materials response teams
addressing sample collection activities or additional trained rescue personnel

• Training requirements • Entry and egress procedures

• Personal protective equipment (PPE) on-site • Spill containment

and usage requirements • Personnel decontamination procedures

• Medical screening requirements (maintain
confidential documents properly and
securely)

An EPA On-Scene Coordinator Health and Safety Plan template can be downloaded here.

Sampling and Analysis Plan

The purpose of the Sampling and Analysis Plan (SAP) is to guide the collection of water and surface
samples that will be analyzed to determine if the remediation actions are reducing the contaminant

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concentrations in the water and on affected system components to meet the established clearance
goals. A typical SAP should include the following elements:

Laboratories to perform
analysis

Sample collection
procedures

Sample preservation and
holding time
requirements
Field parameter testing

Chain-of-custody
protocol

Laboratory analytical
methods

Quality control analyses
Data reporting
Sample disposal

• Description of the
system (including maps)

• Required personal
protective equipment
(PPE)

• Sampling objectives

• Data quality objectives

• Sampling sites and
number of samples

The SAP guide and template can be accessed by clicking on this link. developed]

Quality Assurance Project Plan

A Quality Assurance Project Plan, or QAPP, is a written document outlining the procedures a monitoring
project will use to ensure the data it collects and analyzes meets project requirements. Typical QAPP
elements that may be included when conducting sampling and analysis during remediation of water
contamination may include:

Instrument/equipment
testing, inspection, and
maintenance
Inspection/acceptability
of supplies and
consumables

Non-direct
measurements
Data management

• Sampling process design

• Sampling methods

• Sampling handling and
custody

• Analytical methods

• Quality control
For more information on QAPPs, see:

• EPA Requirements for Quality Assurance Project Plans

• Quality Assurance Project Plan Development Tool

• WLA-RP Appendices: Please see Appendix N: Short Form Quality Assurance Project Plan (QAPP)
Template for Emergency Response Lab Services for Drinking Water Incidents

Waste Management Plan

The purpose of a Waste Management Plan (WMP) during remediation of a water contamination incident
is to outline requirements and procedures for managing waste generated during remediation activities
and sample collection. Ideally, a utility would develop or have a general WMP in place that can be used
to prepare an incident-specific WMP. A WMP should be in place prior to initiation of any sample
collection or remediation activities. This incident-specific plan should address federal, state, and local
waste management requirements for the different waste streams. The plan should address waste
characterization and waste acceptance sampling and analysis, identification of waste management
facilities, on-site waste management and minimization strategies and tactics, off-site waste
management, and waste transportation, health, and safety. In addition, it should address tracking and
reporting of waste sampling results. State and local waste management officials should be contacted as
early in the development process as possible.

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• For more information on WMPs. see EPA's Waste Management Benefits, Planning and
Mitigation Activities for Homeland Security Incidents.

• Guidance on developing a pre-incident Waste Management Plan can be found at: Pre-incident
All-hazards Waste Management Plan Guidelines: Four-step Waste Management Planning
Process.

• Information on tools and other resources for managing sample collection waste can be found at
Managing Materials and Wastes for Homeland Security Incidents.

• Incident Waste Decision Support Tool (l-Waste DST) provides access to technical information,
regulations, and guidance to work through important disposal issues to assure safe and efficient
removal, transport, treatment, and/or disposal of debris and waste materials.

Case Studies

The following highlights examples, for consideration, of real contamination incidents including the
remediation responses/decisions made by the affected utility and incident responders.

In 2014, approximately 10,000 gallons of a mixture of 4-methylcyclohexanemethanol (MCHM) and
propylene glycol phenyl ether (PPH) leaked from a chemical storage tank into West; Virginia's Elk River,
contaminating the potable water supply of about 300,000 West Virginia residents. Shortly after, West
Virginia American Water (WVAW) reported contaminated water with a licorice odor had been
discovered entering the distribution system. WVAW concurred with the West Virginia Bureau of Public
Health, state officials, and West Virginia Governor's Office, and a do-not-use order was issued. The West
Virginia Governor declared a state of emergency and requested a federal emergency declaration, along
with guidance from the US Centers for Disease Control and Prevention (CDC) on a MCHM drinking water
concentration that was safe for humans. CDC advised a "concentration of 1 mg/L was the appropriate
screening level for a 14-day exposure." After the water treatment plant effluent MCHM concentration
dropped below 1 mg/L and distribution system flushing by zone was begun, the do-not-use order began
to be lifted, and the population was directed to flush the contaminated water out of their premise
plumbing.

In January 2015, a damaged crude oil pipeline released approximately 31,000 gallons of Bakken crude oil
into the Yellowstone River 6-7 miles upstream of Glendive, MT. When volatile organic compound (VOC)
contamination at the water treatment plant was confirmed, the city issued a Do Not Consume advisory.
Ice cover on the river caused VOC volatilization to not occur as anticipated and caused the VOCs to mix
into the water, potentially reaching the depth of the water treatment plant intake. Plant operators
began increasing the dosage of granular activated carbon to the water to aid treatment, added air
strippers to the outside of the clear well, and covered the filter gallery to restrict VOC release within the
facility. Once clean water was being produced, the WTP began filter backwashing and flushing the entire
plant. Oil recovery from ice in the river was slow due to safety concerns. By the end of January, 45% of
the oil had been recovered, with the remaining oil trapped in ice. To prepare for the future expected
spike in VOCs in the source water in early spring due to ice melt, WTP operators prepared the pre-
sedimentation basins, clear well, and treatment units and maintained the finished water storage tanks
to continuously ensure they could provide the city with treated water for up to 2.5 days.

The 2021 Marshall Fire in Colorado destroyed more than 1,000 homes and businesses, displaced over
40,000 people, and damaged six public drinking water systems. The fire caused all water systems to lose
power. Boil water advisories were issued by the Colorado Department of Public Health and Environment

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(CDPHE) within the first 24 hours. Each public drinking water system had varying distribution system
infrastructure and experienced varying amounts of structural damage, and subsequently water pressure
reductions and water loss. All water systems first focused on assessing damage to their systems, then
flushing water to ground or storm drains, and re-pressurizing their water distribution systems. In two of
the six water systems, system-wide flushing usually took four to six weeks; however, neighboring water
systems provided mutual aid that enabled flushing to be completed within four, 24-hour working days.
Additionally, the state drinking water primacy agency required coliform and disinfectant residual
sampling, and when no coliform contamination was found, the boil water advisories were lifted and
premise plumbing flushing guidance was given by CDPHE. Two weeks following the wildfires, VOC
contamination was found in isolated parts of the distribution system at two water systems. VOC levels
decreased during weeks of water main and service line flushing based on VOC surveillance monitoring.

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Water Contamination Incident Remediation Plan

(WaterCIRP)

for

[Site/Incident Name]

Prepared by:

[Name and Address of Organization/Utility]

Prepared for:

[Name and Address of Utility]

Name/Position

Signature

Date

Prepared by:

Reviewed by:

Approved by:

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

Page 1

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Table of Contents

1.0 Incident Description 3

1.1 Incident Background 3

1.2 Contaminant Characteristics and System Components Affected 3

2.0 Remediation Plan(s) 4

2.1 Remediation Objectives 4

2.2 Remediation Action(s) Identification and Development Phase 5

2.3 Sampling and Analytical Approach 6

2.4 Water Remediation Actions 8

2.5 Infrastructure Decontamination Procedures 9

2.6 Waste Management and Disposal 10

3.0 Clearance/Return to Service 12

Appendix A: Acronym List 14

Appendix B: Example Chain-of-Custody Form 15

Page 2

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1.0 IIincident Description

1,1 Incident Background
Description of the incident:

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Emergency Responders
(e.g., HazMat)]

[Contractors]

[Technical Assistance
Providers]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

1.2 Contaminant Characteristics and System Components Affected
Contaminant characteristics:

[Attach the contaminant's Safety Data Sheet and other relevant background information as an
appendix.]

Public health and environmental risks:

Statutory and regulatory requirements:

Areas of contamination/system components affected:

Page 3

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[Include the potential number and list of critical customers impacted.]
Number and types of customers impacted:

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Emergency Responders
(e.g., HazMat)]

[Contractors]

[Technical Assistance
Providers]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

2.0 Remediation Plan(s)

2.1 Remediation < lives

Intent of the actions used to remediate the system (e.g., water safe to use/drink, or meeting
environmental objectives):

Clearance goals:

Near-term (i.e., hours and/or days) and long-term goals:

Page 4

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)n Actii ' " tificati ' ?velopment Phase

Remediation action(s) and strategies:

Benefits and feasibility:

Applicable regulations:

Overview of selected remediation strategies:

[Attach final remediation design and supporting data as an appendix.]

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Emergency Responders
(e.g., HazMat)]

[Contractors]

[Technical Assistance
Providers]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

Water Contamination Incident Remediation Plan Signatories

Signature: Affiliation: Date:

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2.3 Sampling and Analytical Approach

Safety measures:

Personal Protective Equipment Level:

~ Level A ~ Level B ~ Level C ~ Level D

[List the items, example: boots and inner and outer chemical-resistant gloves.]

Sampling and analytical approaches for decontamination and clearance phases:

Sampling procedures for both field and laboratory analysis:

Field analytical methods:

Laboratory analytical methods:

Laboratories providing analytical support:

Expedited availability and immediate support for lab analysis (if applicable):

QA/QC details for sampling and analysis approaches:

Chain-of-Custody requirements (see Appendix B):

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Attach the following sample collection forms, as appropriate:

~ Sample plan/Map with sampling locations

~ Chain-of-custody (COC)

~ Site characterization information/form

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Utility Operations]

[Emergency Responders
(e.g., HazMat)]

[Contractors]

[Laboratory(ies)]

[Technical Assistance
Providers]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

For additional details related to the sampling and analytical approach, refer to the attached Sampling
and Analysis Plan and Health and Safety Plan.

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2,4 Water Remediation Actions

Safety measures:

Personal Protective Equipment:

~ Level A ~ Level B ~ Level C ~ Level D

[List the items, example: boots and inner and outer chemical-resistant gloves.]

Water remediation action(s):

Parameters measured to monitor and assess removal efficacy and impact of the remediation
actions(s) to water quality:

Sample Location

Parameter

Treatment Objective
(concentration)

[Include spatial indicators as
needed (address, lat/long,
photos, etc.)]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

Remediation action sequence of operations:

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Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Utility Operations]

[Contractors]

[State and Federal
Regulatory Agencies]

[Treatment

Technology/Method

Vendor(s)]

[Technical Assistance
Providers]

[Health and Safety
Personnel]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

2,5 Infrastruc* ui i' \ ^contamination Procedures
Safety measures:

Personal Protective Equipment:

~ Level A ~ Level B ~ Level C ~ Level D

[List the items, example: boots and inner and outer chemical-resistant gloves.]

Infrastructure decontamination method(s) and/or removal/replacement approach(es):

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Infrastructure decontamination sequence of operations:

Infrastructure removal/replacement sequence of operations:

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Utility Operations]

[Contractors]

[State and Federal
Regulatory Agencies]

[Treatment

Technology/Method

Vendor(s)]

[Technical Assistance
Providers]

[Health and Safety
Personnel]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

2.6 Waste Manage ' ;posal

Safety measures:

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Personal Protective Equipment:

~ Level A ~ Level B ~ Level C ~ Level D

[List the items, example: boots and inner and outer chemical-resistant gloves.]

Waste management activities:

Waste disposal procedures:

Sample Location

Parameter

Treatment Objective for Disposal
(concentration)

[Include spatial indicators as
needed (address, lat/long,
photos, etc.)]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Utility Operations]

[Contractors]

[State and Federal
Regulatory Agencies]

[Technical Assistance
Providers]

[Health and Safety
Personnel]

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Organization

Responsibilities

Primary Contact

Contact Information

[Disposal Facility]

[Waste Transport
Vendor]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

For additional details related to waste management and disposal, refer to the attached Waste
Management Plan.

3.0 Clearance/Return to Service

Clearance strategy:

Roles, responsibilities, and contact information:

Organization

Responsibilities

Primary Contact

Contact Information

[State Primacy Agency]

[SLTTpublic health/

environmental

organizations]

[Utility Operations]

[Contractors]

[State and Federal
Regulatory Agencies]

[Technical Assistance
Providers]

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

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Water Contamination Incident Remediation Plan Signatories

Signature: Affiliation: Date:

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Appendix A: Acronym List

EPA

Environmental Protection Agency

SAP

Sampling and Analysis Plan

HASP

Health and Safety Plan

WaterCIRP

Water Contamination Incident Remediation Plan

SDWA

Safe Drinking Water Act

WMP

Waste Management Plan

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

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Appendix B: Example Chain-of-Custodv Form

Chain-of-Custody Form

Site/Incident Name:

Laboratory:

Field Sampling Team Lead Name:

Laboratory Contact Name:

Contact Information:

Sample ID

(location, description, etc.)

Collection
Date/Time

(24 h)

Matrix

(drinking water,
untreated water,
soil, etc.)

Type

(grab/
composite)

Preservative(s)

No./Type of
Bottles

Analyses Requested

Comments

Samples Relinquished By

Samples Received By

Date

Time

Name (print)

Signature

Date

Time

Name (print)

Signature

Method of Sample Transport:

Shipper: Phone No.: Shipper's Tracking No.:

[Note: To add additional text to a cell hit "enter". To add an additional table row hit "tab". ]

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