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This document provides general guidelines for airport managers, local officials, and other stakeholders for developing a response and recovery plan for a major airport following the release of a biological warfare agent, with specific guidance for remediation. San Francisco International Airport was selected as the example airport during development of the guidance to illustrate specific details. The spore-forming bacterium Bacillus anthracis was selected as the biological agent of primary concern because it is the most difficult of known bioterrorism agents to inactivate and is considered to be one of the agents most likely to be used as a biological weapon. The focus of the guidance is on cleanup and disposal activities associated with the Characterization, Decontamination, and Clearance Phases that are defined herein. Activities associated with the Notification and First-Response Phases are brieÀy discussed in Appendixes A and B, respectively. In addition to the main text of this Remediation Guidance document and associated appendixes, a data supplement was developed specifically for San Francisco International Airport. Requests for the data supplement must be made directly to the Emergency Planning Operations Division of San Francisco International Airport. This document does not describe public health responses to release of a biological warfare agent. If laboratory analytical results confirm the presence of a biological agent, the responsible public health agency involved in the response will commence appropriate public health actions, such as treatment (CDC 2004) and decontamination of potentially contaminated individuals, distribution of prophylaxis, and medical examinations. See the Centers for Disease Control and Prevention web site for more information on emergency public health responses (http://www.bt.cdc.gov/). Effective communication with the media and the public is an essential component of airport remediation and recovery. Whereas such communication is beyond the scope of this document, many helpful resources are available. (See Section 1.1 for more information.) The concept of operations described in this document for cleanup of a Bacillus anthracis release at a major airport conforms to the National Response Framework (NRF) (DHS 2008) and implementation of the National Incident Management System (NIMS 2004). In most cases, a Unified Command would be formed to direct the cleanup process jointly and to take ultimate responsibility for all cleanup decisions. The Unified Command would likely include the Airport Manager or Airport Emergency Operations Manager, representatives from state and local public health and emergency management agencies, and Federal agencies, such as the U.S. Environmental Protection Agency. The Unified Command and Incident Command Staff would ideally be co-located in an Incident Command Post in an uncontaminated area of the airport. If a release is large or complex, co-location of all key players may not be possible. If a major incident is declared, a Principal Federal Official may be appointed by the Department of Homeland Security to facilitate Federal support to the Unified Command. In some facilities and jurisdictions, additional response plans or procedures (such as BioWatch or other emergency response plans, procedures, or protocols) may govern notification and first response. Facility personnel, responders, and emergency management coordinators should be aware of all applicable plans and procedures and how to implement them. Cleanups following the anthrax attacks of 2001 in the U.S. pre-dated the NRF and NIMS and did not make use of a NIMS Incident Command System as we know it today. Most Incident Commanders for the larger of those cleanups chose to convene a Technical Working Group (TWG) of multi-agency, multi-disciplinary, outside experts to advise in developing sampling and decontamination plans. Most of the Incident Commanders also convened a separate Environmental Clearance Committee (ECC) to independently review pre- and post decontamination sampling data as well as data on decontamination parameters, to evaluate whether the decontamination was effective, and to add credibility regarding a decision that decontaminated areas may be reoccupied. Use of such specialized technical expertise is strongly recommended, although it would now operate within the construct of the NIMS Incident Command System. The TWG, if convened, would act in an advisory capacity to the Environmental Unit within the Planning Section. Likewise, the ECC, if convened, would provide independent peer review of products and recommendations by the Environmental Unit. For maximum impartiality, the ECC could also provide recommendations directly to the Unified Command. Cleanup activities commence with site characterization. The principal goal of characterization is to define the extent of contamination and to gather information needed to design the decontamination approach. Initial sampling data collected by first responders are assessed to approximate the location(s) of contamination. Confirmation of the agent type and viability is obtained from a Laboratory Response Network laboratory. Additional characterization data are collected to determine the extent of contamination and where decontamination actions are needed. Areas suspected of being contaminated are contained and isolated to the degree possible to prevent further movement of an agent to uncontaminated areas or the environment, and to reduce the potential for future exposure from the agent or fumigant, if fumigation is needed. Agent air monitoring in areas adjacent to the contained contamination zones is done to ensure the protection of remediation personnel and to monitor any release from the contained zones. Various sampling approaches are considered. For example, wipe samples can be used to sample hard, nonporous surfaces. Swab samples can be used to sample nooks, crannies, joints, and seams. Appendix I is a template for preparing an incident-specific, operational characterization plan. Upon completion of the characterization plan, an internal review is initiated. Upon approval of the plan by the Unified Command, characterization commences. The Site Safety Officer develops a Health and Safety Plan to ensure that coordinated health and safety measures are in place for all responding personnel. This plan describes physical, chemical, and biological hazards at the site, personal protective equipment, personal decontamination procedures, and emergency procedures to be used by sampling and remediation personnel. An incident-specific Remediation Action Plan is developed, which describes the decontamination methods to be used and other details, including waste disposal. Under NIMS, this overall plan, as well as other plans described below, are implemented through a series of standardized, shorter-term Incident Action Plans, which describe specific activities that will take place during a shift or a day. The template in Appendix J is designed to facilitate preparation of the Remediation Action Plan. If fumigation will be done, a Sampling and Analysis Plan will be needed, as well as an Ambient Air Monitoring Plan, which can be a component of the Remediation Action Plan. These three plans are needed to obtain a crisis exemption from the U.S. Environmental Protection Agency for authorized use of an unregistered sterilant or pesticide during cleanup. If pesticide products become registered for inactivation of B. anthracis in the future, the three plans will likely be required by the product’s labeling, but the plans would no longer be submitted to the U.S. Environmental Protection Agency for approval; rather, the Incident Commander would approve them. If fumigation is used, an Emergency Response Plan is also recommended, although such a plan is not required for a crisis exemption. For some nonpersistent biological warfare agents, natural attenuation may be an adequate decontamination option. In cases where contamination is not extensive or an agent is not persistent, application of surface decontaminants or other methods of medical infection control may be effective. For extensive contamination by persistent agents, such as Bacillus anthracis, fumigation may be necessary. In those cases, the Decontamination Phase commences with source reduction, such as pre-cleaning surfaces to reduce the contaminant load. To expedite cleanup and prevent costs from escalating unnecessarily, a cost–benefit analysis should be incorporated in the decision process related to retention versus disposal of facility items and materials. Certain materials and structural components can be decontaminated for reuse, but it may not be feasible or cost-effective to decontaminate other items. Those items must be pre-treated, packaged (with the package decontaminated externally), and removed for disposal as waste. Site preparation includes sealing openings to prevent leaks and setting up equipment. Decontamination reagents and delivery systems are selected, and pre-testing all systems is done before carrying out chemical treatment(s). The important choice of decontamination technologies depends on characteristics of the agent, the nature and extent of contamination, and other site parameters identified during characterization. Decontamination-related decisions can have a major impact on waste-disposal costs, and it is necessary to develop a disposal plan that identifies a means of disposal, necessary approvals, transportation, and other details. A clearance strategy is developed to ensure that after decontamination, the risk of exposure to residual contamination is negligible. A clearance sampling plan is developed, which sets clearance criteria, specifies how to determine whether the criteria have been met, and describes how and where to collect clearance samples after decontamination. In most cases, clearance sampling includes both surface and aggressive air samples. Appendix K is a clearance plan template that identifies the types of required information. To determine whether the decontaminated area may be reoccupied, the Environmental Unit (and the ECC separately, if one is convened) evaluates the results of clearance samples. For the anthrax incidents to date, and given methods that have been used, cleanup was considered successful only when there was no growth of B. anthracis cultured from any environmental samples taken after decontamination. Other factors that will be considered include the decontamination process parameters (e.g., temperature, relative humidity, decontaminant concentration, and contact time) and the results from post-decontamination culture of biological indicators that may have been used during fumigation or sterilization processes. From such an evaluation the Environmental Unit or ECC, or both, recommend whether the area may be reoccupied, or whether further decontamination is necessary. The UC makes the final decision that a facility is appropriately decontaminated for reoccupancy. The facility owner or responsible public health agency makes the final decision to reopen a decontaminated facility. A theme that is emphasized throughout this document is that many activities can greatly reduce the time required to restore airport operations if those activities are conducted prior to an actual release of biological warfare agent. A summary of specific resources (such as Federal, state, and local agency contacts; contractors; prospective team members; subject-matter experts; laboratory facilities; and other entities) that should be identified in advance by airport officials is provided in each pertinent section of this document, and summary contact lists of such resources are provided in Appendix L. A summary of overall pre-planning actions that should be completed by airport officials is presented at the end of this document.
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