United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response and
Office of Waste Programs
Enforcement
Office of Solid Waste and
Energency Response
Washington DC 20460
Office of Research and
Development
Hazardous Waste Engineering
Research Laboratory
Cincinnati OH 45268
Superfund
EPA/540/G-85/002 June 1985
Guidance on
Remedial
Investigations Under
CERCLA
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EPA/540/G-85/002
June 1985
Guidance on Remedial Investigations
Under CERCLA
Prepared for:
Hazardous Waste Engineering Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
and
Office of Emergency and Remedial Response
and
Office of Waste Programs Enforcement
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, D.C. 20460
South Dearborn Street
Chicago, Illinois 60604
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NOTICE
The information in this document has been funded, wholly
or in part, by the iJhited States Environmental Protection
Agency under Contract No. 68-03-3113 to JRB Associates.
It has been subject to the Agency's peer and administra-
tive review and has been approved for publication as an
EPA document.
This handbook is intended to present guidance on the
conduct of remedial investigations to obtain data to
evaluate and select measures to control specific problems
caused by uncontrolled hazardous waste sites.
U,S. Environmental Protection Agency
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FOREWORD
Under the authorities of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), the Office of Emergency
and Remdial Response and the Office of Waste Programs Enforcement are
responsible for overseeing the development and implementation of the
Government's program for response to uncontrolled releases of hazardous
substances. These responses ensure that threats to public health, welfare,
or the environment are appropriately addressed through the effective
management of CERCLA's enforcement and funding authorities. The Hazardous
Waste Engineering Laboratory develops new and improved technologies and
systems to prevent, treat, and manage hazardous waste pollutant discharges
to minimize the adverse economic, social, health, and aesthetic effects of
pollution.
This document is a cooperative effort between the Office of Solid
Waste and Emergency Response and the Office of Research and Development.
It is one of a series of reports being published to implement CERCLA,
otherwise known as Superfund. These reports provide an array of information
necessary for compliance with the National Contingency Plan (NCP, 47 FR
31180, July 16, 1982), including: guidance for remedial investigation and
feasibility studies, guidance for exposure assessments, analytical and
engineering methods and procedures, research reports, technical manuals,
toxicological and engineering data bases, and other reference documents
pertinent to Superfund.
This guidance document provides guidance on the conduct of remedial
investigations in support of feasibility studies under Superfund and the
National Contingency Plan. It describes the requirements which need to be
met to obtain valid data which are necessary and sufficient to determine
what response actions, if any, can be considered, evaluated, and applied to
mitigate impacts on public health, welfare, and the environment posed by
the site. This document describes the essentail steps in the remedial
investigation process and identifies important factors, information, and
analysis needs to scope the investigation; prepare all necessary plans
(health and safety, sampling, data management); conduct the site assessment;
and evaluate and present results. The guidance document provides government
and private personnel with the means to plan, prepare, conduct, and conclude
remedial investigations consistent with hazardous waste site clean-up
legislation and site-specific requirements.
iii
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ABSTRACT
This guidance document is intended to provide a more detailed structure
for field studies involving data collection for remedial decisions under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and the National Contingency Plan (40 CFR 300).
The remedial investigation emphasizes data collection and site char-
acterization and is conducted concurrently with the feasibility study. The
remedial investigation also supports remedial alternative evaluation and
design through bench and pilot studies.
The initial activity in the remedial investigation is the scoping pro-
cess. The scoping effort includes the collection and evaluation of existing
data, identification of remedial investigation objectives, and the identi-
fication of general response actions for the feasibility study. The effort
also identifies preliminary plans, and investigation tasks are identified.
A variety of activities supporting the remedial investigation may require
the preparation of specific plans or implementation of specific procedures.
These include preparing a sampling plan; identifying data management pro-
cedures; planning for health and safety needs; and identifying and reviewing
institutional issues arising from Federal, State, and local regulations,
policies, and guidelines.
The site characterization process is the focal point of the remedial
investigation and involves the collection and analysis of the data needed for
the various types of assessments that are part of the investigation. Because
site data and understanding vary, a multilevel approach to data collection is
recommended: Level I, problem identification and scoping; Level II, problem
quantification; and Level III, problem quantification and detailed investiga-
tion. The focus, data needs, and data evaluations conducted at each level of
the investigation are described for each type of assessment.
Bench- and pilot-scale studies may be needed in the remedial investiga-
tion to obtain enough data to select a remedial alternative. The scope of
these bench and pilot studies address waste treatability, scale-up of
innovative technologies, technology application issues, and evaluation of
specific alternatives.
A recommended format for the Remedial Investigation Report is also
provided. It describes the specific elements to be included, the rationale
for their inclusions, the level of detail, and the documentation that should
accompany the report.
IV
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CONTENTS
FOREWORD
ABSTRACT iv
CONTENTS v
FIGURES ix
TABLES x
ACKNOWLEDGMENTS xl
1. INTRODUCTION 1-1
1.1 Overview of the Remedial Investigation Process 1-1
1.2 Relationship Between the Remedial Investigation and the
Feasibility Study 1-5
2. SCOPING . . . 2-1
2.1 Introduction 2-1
2.2 Existing Data Collection and Evaluation 2-1
2.2.1 Collection of Existing Data 2-2
2.2.2 Evaluation of Potential Impacts 2-5
2.3 Determining the Need for Removals or Initial
Remedial Measures 2-6
2.4 Development of General Response Actions 2-9
2.5 Data Needs 2-10
2.5.1 Data Limitations in the Assessment of Potential
Impacts 2-10
2.5.2 Data Limitations in the Assessment of Remedial
Actions 2-11
3. SAMPLING PLAN DEVELOPMENT 3-1
3.1 Introduction 3-1
3.2 Elements of the Sampling Plan 3-2
3.2.1 Objectives 3-3
3.2.2 Background 3-3
3.2.3 Evaluation of Existing Data 3-3
3.2.4 Determination of Chemical Contaminants of
Interest 3-5
3.2.5 Determination of Sample Types 3-6
3.2.6 Determination of Sampling Locations and
Frequency 3-7
3.2.7 Preparation for Sampling 3-8
3.3 Factors to Consider in a .Sampling Plan 3-10
3.3.1 Record-keeping 3-10
3.3.2 Related Management Plans 3-11
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CONTENTS (continued)
3.3.3 Specification of Sampling Personnel 3-11
3.3.4 Decontamination and Disposal 3-12
3.4 Specification of Sampling Procedures 3-13
3.5 Data Acceptability and Utility 3-14
3.6 Estimating Efforts Required for Sampling Plan
Development 3-14
4. DATA MANAGEMENT PROCEDURES 4-1
4.1 Introduction 4-1
4.2 Overview of Data Management Protocols and Guidelines .... 4-1
4.2.1 Data Processing and Storage 4-3
4.2.2 Quality Assurance/Quality Control (QA/QC) 4-6
4.3 Data Management Requirements for Specific RI Tasks 4-10
4.3.1 Data Management for Scoping 4-11
4.3.2 Data Management for Site Characterization
and Sampling 4-11
4.3.3 Data Management for Health and Safety Programs. . . . 4-12
4.3.4 Data Management for Institutional Issues 4-13
4.3.5 Data Management for Bench- and Pilot-Scale
Studies 4-14
4.4 Financial and Project Tracking 4-14
5. HEALTH AND SAFETY PLANNING FOR REMEDIAL INVESTIGATIONS 5-1
5.1 Introduction 5-1
5.1.1 Overall Approach 5-1
5.1.2 Applicable Regulations to Protect Workers 5-2
5.2 The Health and Safety Program 5-4
5.2.1 Responsibility for Health and Safety 5-4
5.2.2 Selection of Personnel for Remedial
Investigations 5-6
5.2.3 Medical Surveillance Program 5-6
5.2.4 Training 5-7
5.2.5 Equipment 5-10
5.2.6 Standard Operating Procedures 5-12
5.3 Site-Specific Health and Safety Plans 5-13
5.3.1 Preparation and Approval 5-14
5.3.2 Site Description 5-14
5.3.3 Hazard Evaluation 5-14
5.3.4 Monitoring Requirements 5-16
5.3.5 Levels of Protection 5-16
5.3.6 Work Limitations 5-16
5.3.7 Authorized Personnel 5-16
5.3.8 Decontamination 5-17
5.3.9 Emergency Information 5-17
VI
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CONTENTS (continued)
INSTITUTIONAL ISSUES 6-1
6.1 Introduction 6-1
6.2 Site Access and Data Collection 6-1
6.2.1 Consensual Entry 6-1
6.2.2 Nonconsensual Entry 6-2
6.2.3 Warrantless Entry 6-3
6.2.4 Confidentiality 6-3
6.2.5 Sampling 6-3
6.2.6 Control of Contaminated Materials 6-3
6.3 Liability 6-4
6.3.1 Workers Compensation 6-4
6.3.2 Federal Liability 6-5
6.3.3 State Liability 6-5
6.3.4 Employer Liability 6-5
6.4 Subcontracting for Special Services 6-6
6.5 Community Safety and Health 6-6
6.6 Community Relations During Remedial Investigations 6-7
6.6.1 Progress Reports 6-7
6.6.2 Eliciting and Documenting Community Concerns 6-8
6.7 Coordination 6-8
6.7.1 Enforcement Personnel 6-8
6.7.2 Department of Interior (DOl) 6-9
6.7.3 U.S. Army Corps of Engineers 6-9
6.7.4 U.S. Coast Guard (USCG) 6-9
6.7.5 National and Regional Response Teams 6-10
6.7.6 Agency for Toxic Substances and Disease
Registry (ATSDR) 6-10
6.7.7 United States Geological Survey (USGS) and
State Geologists 6-11
6.7.8 Other Organizations 6-11
SITE CHARACTERIZATION 7-1
7.1 Introduction 7-1
7.2 Approach to Site Characterization 7-3
7.2.1 Characterization Activities 7-5
7.2.2 Data To Be Collected 7-5
7.2.3 The Philosophy of Necessary and Efficient
Equipment 7-6
7.2.4 General Characterization Methods 7-7
7.2.5 Assessments To Be Performed 7-8
7.2.6 Summary 7-9
7.3 Investigation and Assessment Procedures Necessary
for Characterization 7-9
7.3.1 Technical Investigations 7-9
7.3.2 Assessment Procedures 7-26
vn
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CONTENTS (continued)
7.4 Programmatic Factors Affecting Site Characterization
Activities 7-32
7.4.1 Responsible Party Actions 7-32
7.4.2 Documentation and Recordkeeping 7-33
7.4.3 Timing and Scheduling Concerns 7-33
8. BENCH AND PILOT STUDIES 8-1
8.1 Introduction 8-1
8.2 Overview of Bench and Pilot Studies 8-2
8.2.1 Difference between Bench and Pilot Studies 8-2
8.2.2 Approach 8-5
8.2.3 Example Testing Programs 8-6
8.2.4 Cost Considerations 8-6
8.3 Bench-Scale Studies 8-6
8.3.1 Preplanning Information Needs 8-6
8.3.2 Specification of Objectives and Level of Detail . . . 8-9
8.3.3 Limitations 8-9
8.3.4 Statement of Work 8-9
8.4 Pilot-Scale Studies 8-9
8.4.1 Preplanning Information Needs 8-10
8.4.2 Specifications of Objectives and Level of Detail. . . 8-10
8.4.3 Limitations 8-10
8.4.4 Statement of Work 8-11
8.5 Data Analysis 8-11
8.5.1 Data Management 8-11
8.5.2 Data Analysis and Interpretation 8-11
8.5.3 Reliability 8-12
8.5.4 Application of Results 8-12
9. REMEDIAL INVESTIGATION REPORT FORMAT 9-1
9.1 Introduction 9-1
9.2 Final Report Format 9-2
9.2.1 Executive Summary 9-2
9.2.2 Introduction 9-5
9.2.3 Site Features Investigation 9-7
9.2.4 Hazardous Substances Investigation 9-7
9.2.5 Hydrogeologic Investigation 9-8
9.2.6 Surface-Water Investigation 9-9
9.2.7 Air Investigation 9-9
9.2.8 Biota Investigation 9-9
9.2.9 Bench and Pilot Studies 9-10
9.2.10 Public Health and Environmental Concerns 9-10
9.2.11 References 9-10
9.2.12 Appendices 9-10
BIBLIOGRAPHY
APPENDIX A
viii
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LIST OF FIGURES
Figure Page
1-1 Remedial Investigation Process 1-2
1-2 RI/FS Process 1-6
4-1 Sample Cost Status Format 4-19
5-1 Organization Chart for Remedial Investigations 5-5
5-2 Example Health Sumnary Form 5-8
7-1 Overview of Effects and Interaction at a Representative
Hazardous Waste Site 7-2
7-2 Supportive Information for Environmental Assessment 7-31
8-1 Bench/Pilot Study Logic Diagram 8-3
IX
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LIST OF TABLES
Table Page
2-1 Data Collection Information Sources 2-3
2-2 Site and Waste Characteristics 2-4
3-1 Appropriate Technical Disciplines for Sampling Plan
Preparation 3-15
4-1 Examples of RI Support Documentation 4-2
4-2 Outline of the File Structure for the Superfund Sites 4-7
4-3 Sample Status Report Format 4-16
4-4 Sample Status Report Format 4-18
7-1 Summary of Important Source and Facility Information 7-10
7-2 Summary of Important Geologic Information 7-14
7-3 Summary of Important Ground-Water Information 7-15
7-4 Summary of Important Surface-Water Information 7-18
7-5 Summary of Important Pedological Information 7-19
7-6 Summary of Important Atmospheric Information 7-21
7-7 Summary of Important Environmental Information 7-24
8-1 Bench and Pilot Study Parameters 8-4
8-2 Examples of Bench and Pilot Scale Testing Programs 8-7
9-1 Remedial Investigation Report Format 9-3
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ACKNOWLEDGMENTS
This document was compiled for the Office of Solid Waste and Emergency
Response in partial fulfillment of Contract No. 68-03-3113, by JRB Associates.
Dr. Craig Zamuda, Mr. Bruce Clemens, and Mr. Richard Stanford* of the
Office of Emergency and Remedial Response (OERR), and Mr. Douglas Ammon of
the Hazardous Waste Enginneering Research Laboratory were the EPA Co-Project
Officers. Robert Cochran and Virginia Hodge were successive project managers
with JRB Associates. Clarence demons, Center for Environmental Research
Information, ORD is acknowledged for his technical assistance with publication
of this document.
This report is the compilation of the efforts of several major
contributors, which include:
James Lounsbury
Mary Anne Chillingworth
Virginia Hodge
John Kubarewicz
Gilah Langner
Gary McKown
Frank Priznar
Ben Roberts
Lee Schulz
Phil Smith
Brian Steelman
David Zimomra
Director, Policy Analysis Staff,
OERR
CH2M Hill
JRB Associates
Engineering Science
ICF, Inc.
Battelle Office of Hazardous
Waste Management
Booz, Allen & Hamilton
Anderson-Nichols & Co., Inc.
Versar, Inc.
CH2M Hill
Battelle Pacific Northwest Laboratory
Booz, Allen & Hamilton
Ms. Helen Room provided editorial assistance in producing this document.
We also extend our appreciation for the assistance and contributions
of the following people:
Brint Bixler
Roy Murphy
Lawrence Raniere
Don Sannlng
Jim Spatarella
Office of Emergency and Remedial
Response
Office of Waste Programs Enforcement
Environmental Research Laboratory-Corvallis
Hazardous Waste Engineering Research
Laboratory
Office of Emergency and Remedial
Response
^Currently with Clean Sites, Inc.
xi
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CHAPTER 1
INTRODUCTION
The Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) not only established a Fund (commonly known as Superfund) for
financing the cleanup of uncontrolled hazardous waste sites, it also required
that procedures be established to evaluate remedies, to determine the appro-
priate extent of the remedy, and to ensure that remedial measures are cost-
effective. Such remedial measures must, to the extent practicable, be in
accord with the National Contingency Plan (NCP). For Superfund-financed
sites, the need to protect public health, welfare, and the environment at a
specific site must be weighed against the ability of the Fund to finance
remedial action at other sites posing other threats to public health, welfare,
or the environment.
The U.S. Environmental Protection Agency (EPA) has the authority and
responsibility for carrying out these provisions under CERCLA. The plan for
enacting these provisions appears in the revised National Contingency Plan
(47 FR 31180, July 16, 1982; 40 CFR 300) as Subpart F (40 CFR 300.61-300.71).
The NCP describes the evaluation and selection of remedial actions.
Within the framework of the NCP, this guidance document provides Regional
Project Officers with a more detailed structure for field studies involving
data collection for remediation decisions. At Superfund sites where enforce-
ment actions are taken, or where claims against the fund are made, remedies
consistent with the NCP must be found. Therefore, this guidance should also
be used in conducting investigations supporting enforcement and litigation.
Private parties involved in hazardous waste management may also find this
document helpful.
1.1 OVERVIEW OF THE REMEDIAL INVESTIGATION PROCESS
The remedial investigation emphasizes data collection and site charac-
terization. Conducted concurrently with the feasibility study, the remedial
investigation is the data collection mechanism for the feasibility study
effort; this relationship is discussed further at the end of this chapter.
The remedial investigation also supports remedial alternatives evaluation
through bench and pilot studies. Figure 1-1 illustrates the remedial invest-
igation process and keys chapters within this document to the parts of the
remedial investigation.
1-1
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Figure 1-1. Remedial Investigation Process
Data Management
(Ch. 4)
Scoping Remedial
Investigation
(Ch. 2)
Sampling
Plan Development
(Ch. 3)
Health and Safety
Planning (Ch. 5)
Institutional
Issues (Ch. 6)
Scoping and Planning
Processes Direct Site
Characterization
Assessments
Site Characterization (Ch. 7)
Contamination Assessment
Public Health Assessment
Environmental Assessment
Bench/Pilot-Scale
Studies
(Ch. 8)
Remedial
Investigation Report
(Ch. 9)
1-2
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The initial activity in the remedial investigation is the scoping pro-
cess. The scoping effort includes the collection and evaluation of existing
data, identification of remedial investigation objectives, and the identi-
fication of general response actions for the feasibility study. Data needs,
preliminary plans, and investigation tasks are identified. The investigation
scoping process may recur or be modified as more data are collected and site
characterization becomes more complete. Details of the scoping process are
addressed in chapter 2.
The scoping process is critical to the development of a sampling plan
and subsequent remedial investigation. Chapter 3 provides detailed guidance
on developing this plan and on the required level of effort. This sampling
plan describes the sampling studies to be conducted, including sample types,
analyses, and sampling locations and frequency. Planning needs such as sam-
pling operational plans, materials, record-keeping, sampling team personnel
needs, and sampling procedures are also developed or identified for the
investigation.
Associated with the scoping and sampling plan efforts are a variety of
support activities that may require the preparation of specific plans or
implementation of specific procedures to supplement the remedial investiga-
tion and documentation of data. Discussions of these activities appear in
chapter 4, which addresses data management procedures, including quality
assurance/quality control programs; chapter 5, which summarizes health and
safety planning requirements, including development of an overall health and
safety program and a site-specific health and safety plan; and chapter 6,
which reviews institutional issues arising from Federal, State, and local
regulations, policies, and guidelines that may affect the investigation.
The site characterization process, the focal point of the remedial
investigation, is described in chapter 7. Site characterization involves the
collection and analysis of the data needed for the various types of assess-
ments that are part of the investigation. This chapter also describes the
focus, data needs, and data evaluations conducted at each level of the
investigation for each type of assessment.
Because site data and understanding vary, a multilevel approach to data
collection is recommended. Each level differs in the scope of the activities.
The three levels of data collection and site characterization efforts are:
Level I - Problem Identification and Scoping. Existing site informa-
tion is collected and evaluated to define the problem(s) at the site,
public and environmental threats, and site features contributing to
the problem(s). This assessment is conducted for all sites and
provides the basis for immediate mitigation actions for defining
investigation needs in levels II and III. The data collected at this
level are also used in identifying and analyzing remedial technolo-
gies.
Level II - Problem Quantification. Specific site data are collected
through sampling and field studies to characterize site problems and
1-3
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their dimensions more fully. Sufficient data should be collected to
identify contaminants of concern, to verify actual exposure pathways,
and, in general, to characterize the site well enough to support, at a
minimum, the screening of remedial technologies and alternatives.
Level III - Problem Quantification and Detailed Investigation. If
level II data are insufficient, additional data are collected for use
in detailed analysis of remedial alternatives or in the selection of a
cost-effective alternative.
The remedial investigation does not require that all three levels be
completed; the process may terminate at any level provided that sufficient
data have been obtained. For some sites, a level I study may furnish enough
data for response decisions, particularly if a site has been well-studied or
the need for an immediate response is obvious. The investigation may end at
level II if characterization data are sufficient to permit the selection of a
response. Alternatively, where level I analyses are sufficient to support
feasibility study decisions and a level II effort is not necessary, a level
III study involving bench or pilot testing may be needed to select between
alternatives or finalize a design. Thus, the investigation needs vary from
site to site, and the levels of the remedial investigation must be appropriate
to these needs.
Bench- or pilot-scale studies may be needed in the remedial investigation
to obtain enough data to select a remedial alternative. The scope of bench
and pilot studies in the remedial investigation specifically address waste
treatability, scale-up of innovative technologies, technology application
issues, and evaluation of specific alternatives. Bench and pilot studies may
also be conducted during remedial alternative design or construction to more
fully evaluate specific requirements of the selected alternative, however,
these studies are outside the remedial investigation and feasibility study
process. In general, bench-scale studies are appropriate for the remedial
investigation stage while pilot-scale studies, if required, may be conducted
during the final design. Chapter 8 describes the analysis of the need for
bench and pilot studies in the remedial investigation, the requirements of
these studies, and data analysis procedures.
Chapter 9 discusses the recommended format for the Remedial Investigation
Report. It describes the specific elements to be included, the rationale for
their inclusion, the level of detail, and the documentation that should
accompany the report.
Before turning to the details of the remedial investigation process,
several overall points should be emphasized:
1. The remedial investigation is the data collection activity for the
feasibility study; through bench and pilot studies, it supports the
remedial alternative design effort as well.
1-4
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2. The remedial investigations must be conducted consistently with the
process set forth in the National Contingency Plan.
3. Data needs differ between enforcement-lead, fund-lead, and private
party-lead remedial investigations. The data collection process must
be tailored to meet specific investigation needs and objectives,
including data quality and sufficiency.
4. All supporting files and supporting documentation must be collected
and retained.
1.2 RELATIONSHIP BETWEEN THE REMEDIAL INVESTIGATION AND THE FEASIBILITY STUDY
The user should also recognize that the remedial investigation and the
feasibility study are interdependent. The activities comprising these two
projects are generally performed concurrently rather than sequentially. The
remedial investigation emphasizes data collection and site characterization,
whereas the feasibility study emphasizes data analysis and decisionmaking.
Figure 1-2 depicts the concurrent activities associated with the remedial
investigation (Rl) and feasibility study (FS). The upper portion of the
figure consists of two flow charts illustrating the sequential, interdependent
events associated with the RI/FS process. The lower portion of the figure is
a tabulation of the tasks identified in the Model Statement of Work for the
RI/FS. This Model Statement of Work sets forth the tasks that a contractor
will perform in conducting a government-lead RI/FS and is included in this
document as Appendix A. The lower portion of Figure 1-2 also identifies the
chapters in the Remedial Investigation and Feasibility Study Guidance
Documents corresponding to the tasks in the Model Statement of Work. The
numbers in the boxes of the flow charts correspond to the individual RI/FS
tasks listed in the Model Statement of Work.
The vertical lines on the chart indicate some of the plans, reports, or
milestones recommended in the RI/FS guidance. These connectors and the list-
ings below them illustrate the integration of the RI/FS process.
Management and coordination of RI/FS activities will affect the
resources, timing, and completeness of the RI and FS reports. Site-specific
conditions will govern the extent of data collection and analysis for each
level of the RI and FS process. It must be emphasized that the objective of
this guidance is not to instruct the user in specific methodologies for
conducting the remedial investigation, but instead to provide direction for
the overall process.
1-5
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Figure 1-2. RI/FS Process
REMEDIAL INVESTIGATION
f
FEASIBILITY
STUDY
Site Map
(
8
> ,
9 10 11
r
I 12
k
Remedial Options
) Negotiations Document SOW for Bench and
w Pilot-Scale Tests
QA/QC Plan
g
\
Final Rl
Interim Report Health and Safety Plan
- Site Background Management Plan
- Nature of Problem Sampling Plan
- Extent of Problem Community Relations Plan
13
)
Report
(
Endangerment
Assessment*
14
Administrative Reports
Document Control
1
Draft FS or RI/FS Report
Fma
Report
15
- History of Response Data Management Plan
Endangerment
Assessment*
Post Closure Plan
Compliance Monitoring Schedule
Administrative Reports
Document Control
Remedial Investigation
Feasibility Study
Model Statement of Work
for Remedial Investigations
Task #1 Description of Current Situation
Task #2 Plans ft Management
Task #3 Site Investigation
Task #4 - Site Investigation Analysis
Task #5 - Laboratory & Bench-Scale Studies
Task #6 Reports
Task #7 - Community Relations Support
Guidance Document for
Remedial Investigations Under CERCLA
CH 1 - Introduction
CH 2 Scoping
CH 3 - Sampling Plan Development
CH 4 - Data Management Procedures
CH 5 Health and Safety Planning for
Remedial investigations
CH 6 - Institutional Issues
CH 7 Site Characterization
CH 8 Pilot and Bench Studies
CH 9 - Remedial Investigation Report Format
Model Statement of Work
for Feasibility Studies
T Numbers in the boxes refer to tasks described in the Model Statement of Work for RI/FS under CERCLA Guidance i:
* Endangerment assessments may be prepared dt any point in the RI/FS process in support of enforcement actions
Task # 8 - Description of Proposed Response
Task # 9 Preliminary Remedial Technologies
Task #10 Development of Alternatives
Task #11 - Initial Screening of Alternatives
Task #12 - Evaluation of Alternatives
Task #13 - Preliminary Report
Task #14 - Final Report
Task #15 - Additional Requirements
sued February 1985 See Appendix A
Guidance Document for
Feasibility Studies Under CERCLA
CH 1 - Executive Summary
CH 2 - Develop a Range of Remedial
Alternatives
CH 3 - Conduct a Detailed Technical
/ Evaluation
CH 4 - Evaluate Institutional Requirements
CH 5 - Evaluate Protection of Public Health
Requirements
CH 6 - Evaluate Environmental Impacts
CH 7 - Cost Analysis
CH 8 - Summarize Alternatives
CH 9 - Feasibility Study Report Format
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CHAPTER 2
SCOPING
2.1 INTRODUCTION
The National Oil and Hazardous Substances Contingency Plan (NCP)
(47 FR 31180, July 16, 1982; 40 CFR Part 300 et seq.) describes the criteria
for judging the necessity and type of remedial actions at a site [40 CFR Part
300.68(e)]. These criteria generally involve the determination of the extent
to which substances on-site or off-site endanger public health, welfare, or
the environment. Remedial investigations [40 CFR Part 300.68(f)] are under-
taken to obtain the necessary data for the evaluation of the criteria and the
subsequent evaluation of remedial action alternatives. This chapter outlines
the process for determining the type and extent of remedial investigations.
Scoping a remedial investigation involves the analysis of existing data;
this sets the basis for developing a sampling plan based on specific data
needs. These data may be regional, such as published information on geology
and soils, or site-specific if field investigations have been conducted.
Generally, these data will include preliminary assessment and site inspection
reports or their equivalent. The information is used to evaluate potential
impacts on the public health, welfare, and the environment and to eliminate,
if possible, response actions that are not appropriate to the site.
After this analysis, the remedial investigation activities necessary to
collect the missing data are identified. The goal is to provide whatever
additional information is necessary so that the potential impacts on public
health, welfare, and the environment can be evaluated and remedial alterna-
tives can be developed and selected. Additional data may be necessary to
satisfy requirements of sites designated for enforcement. The scope, costs,
and schedule of the remedial investigation are prepared and presented in the
Remedial Investigation Sampling Plan.
2.2 EXISTING DATA COLLECTION AND EVALUATION
The primary objectives of data collection and evaluation are to summarize
existing information on hazardous waste sources, pathways, and receptors, and
to evaluate potential impacts on public health, welfare, and the environment.
Analytical data from field investigations at the site, as well as information
of a regional nature, are considered in this section.
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2.2.1 Collection of Existing Data
Existing information on hazardous waste sources, migration pathways, and
human and environmental receptors is available from many sources; some of the
more useful sources are summarized in Table 2-1. Much site information is
often gathered in the National Priorities List (NPL) ranking process and may
be found in EPA, field investigation team (FIT), technical assistance team
(TAT), contractor, and State files. Files from site investigations, removal,
or clean-up actions conducted by EPA's Emergency Response Program, for
example, may contain useful historical, sampling, or cost data, especially if
EPA conducted a Superfund removal at the site.
The initial step in data collection is to compile a site description,
history, and chronology of significant events. These are important organiza-
tional tools in the collection of data on hazardous waste sources, migration
pathways, and potential receptors. The site description should include
location, size, ownership, physiographic province, topography, geologic
history, and other pertinent details. Historical events of concern include
site visits, disposal practices, sampling events, legal actions, regulatory
violations, and changes in ownership. Also, information concerning previous
clean-up actions, such as removal of waste drums, is valuable for determining
the characteristics of wastes remaining at the site.
The site description uses only existing information. Gaps or insuffi-
ciency of existing data are noted, but the site description process focuses on
summarizing existing data and analyses and not on the development of data to
complete the description. Table 2-2 lists site and waste characteristics that
may be important in the site description and the evaluation of problems and
potential impacts.
2.2.1.1 Hazardous Waste Sources
The varieties and quantities of hazardous wastes disposed at the site
should be investigated. The results from any sampling episodes should be
summarized in terms of physical and chemical characteristics, contaminants
identified, and concentrations present. If available, information on the
precision and accuracy of the data should be included.
Records of disposal practices and operating procedures at the site can be
reviewed to identify locations of waste materials on-site, waste haulers, and
waste generators. Where specific waste records are absent, waste products
that may have been disposed at the site can be identified through a review of
the manufacturing processes of the waste generators.
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TABLE 2-1. DATA COLLECTION INFORMATION SOURCES
Information Source
U.S. EPA Files
U.S. Geological Survey
U.S. DOA - Soil Conservation Service
U.S. DOA - Agricultural Stabilization
and Conservation Service
U.S. DOA - Forest Service
U.S. DOI - Fish and Wildlife Agencies
U.S. DOI - Bureau of Reclamation
U.S. Army Corps of Engineers ,
Federal Emergency Management Agency
U.S. Census Bureau
National Oceanic and Atmospheric Admin.
State Environmental Protection or Public
Health Agencies
State Geological Survey
State Fish and Wildlife Agencies
Local Planning Boards
County or City Health Departments
Town Engineer or Town Hall
Local Chamber of Commerce
Local Airport
Local Library
Local Well Drillers
Regional Geologic and Hydrologic
Publications
Court Records of Legal Action
Department of Justice Files
State Attorney General Files
Facility Records
Facility Owners and Employees
Citizens Residing Near Site
Waste Haulers and Generators
Site Visit Reports
Photographs
Preliminary Assessment Report
Field Investigation Analytical Data
FIT/ TAT Reports
Site Inspection Report
Hazardous
Waste
Sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Migration Pathways
Subsurface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
X
X
X
X
X
X
X
X
X
X
X
X
Receptors
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U.S. DOA Soil Conservation Service County Soil Survey Reports are very useful.
The Federal Emergency Management Agency publishes floodplain maps.
"Interviews require EPA concurrence.
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TABLE 2-2. SITE AND WASTE CHARACTERISTICS
SITE CHARACTERISTICS
Site Volume
Site Area
Site Configuration
Disposal Methods
Climate
- Precipitation
- Temperature
- Evaporation
Soil Texture and Permeability
Soil Moisture
Slope
Drainage
Vegetation
Depth to Bedrock
Depth to Aquicludes
Degree of Contamination
Direction and Rate of
Ground-water Flow
Receptors
Distance to:
- Drinking Water Wells
- Surface Water
- Ecological Areas
Existing Land Use
Depth to Ground Water or
to Plume
WASTE CHARACTERISTICS
Quantity
Chemical Composition
Carcinogenic ity
Toxicity - Chronic and Acute
Persistence
Biodegradability
Radioactivity
Ignitability
Reactivity/Corrosiveness
Treatability
Infectiousness
Solubility
Volatility
Density
Partition Coefficient
Safe Levels in the
Environment
Compatibility with Other
Chemicals
Source: U.S. EPA, 1985a
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2.2.1.2 Migration Pathways
A summary of existing site-specific and regional information should be
compiled to identify subsurface, surface, atmospheric, and possibly biotic
migration pathways. Information of concern includes geology, pedology, hydro-
geology, hydrology, meteorology, and air, water, and biology inventories.
Regional information will help identify background soil, water, and air
quality. Results of environmental sampling at the site should be summarized
in this section. Evidence of soil, water, air, or biotic contamination should
be documented, and national and State standards or criteria should be
referenced.
2.2.1.3 Receptors
Data on human and environmental receptors (e.g., plants and animals) in
the area surrounding the site should be compiled in this section. Demographic
and land use information such as whether the area is used for agricultural,
industrial, commercial, or residential purposes will help identify potential
human receptors. Residential, municipal, or industrial wells should be
located. Surface water uses should be identified for areas surrounding and
downstream of the site.
The ecology of the site should be described and the common flora and
fauna of the area identified. Any threatened, endangered, or rare species in
the area as well as sensitive environmental areas should be identified.
Results from biological testing should be included, if available, to document
bioaccumulation in the food chain.
2.2.2 Evaluation of Potential Impacts
The potential effects of hazardous substances at the site are evaluated
relative to the danger they pose to public health, welfare, or the environ-
ment. Impacts should be evaluated in terms of contaminant source, migration
pathways, and receptors.
Valuable resources in determining the potential impacts of chemical
contaminants include the following sources:
Registry of Toxic Effects of Chemical Substances (NIOSH, 1980)
Dangerous Properties of Hazardous Materials (Sax, 1984)
Handbook of Environmental Data on Organic Chemicals (Verschueren,
1977)
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Water-Related Environmental Fate of 129 Priority Pollutants (U.S. EPA,
1979a)
Hazardous Chemicals Data Book (Weiss, 1980)
The Merck Index (Windholz, 1976)
Chemical Information Resources Handbook (U.S. EPA, 1980d)
Office of Toxic Substances (OTS) Information Architecture Notebook
(U.S. EPA, 1983e).
These references are cited in the bibliography to this guidance. Additional
sources include:
EPA Chemical Activities Status Reports (series, contact Office of
Pesticides and Toxic Substances' Library)
EPA water quality criteria documents (series, contact Criteria and
Standards Division, Office of Water Regulations and Standards).
2.3 DETERMINING THE NEED FOR REMOVALS OR INITIAL REMEDIAL MEASURES
Remedial actions, as defined by the NCP in section 300.68(a), "...are
those responses to releases on the National Priorities List that are con-
sistent with a permanent remedy to prevent or mitigate the migration of a
release of hazardous substances into the environment."
Inmediate removals, planned removals, and Initial Remedial Measures
(iRMs) are remedial actions taken at a site before final selection of appro-
priate remedial actions. The intent of these actions is to protect the public
health or the environment during the stages of remedial investigations,
feasibility study, and remedial action design and construction.
Immediate removal actions, defined under section 300.65 of the NCP , may
be considered appropriate in cases where "the lead agency determines that the
initiation of [an] immediate removal action will prevent or mitigate immediate
and significant risk of harm to human life or health or to the environment in
such situations as:
Proposed revisions to the NCP (February 12, 1985) include changes in removal
authority. The user should consult with EPA officials to determine the
appropriate factors to consider when evaluating the need for a removal
action.
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(1) Human, animal, or food chain exposure to acutely toxic substances;
(2) Contamination of a drinking water supply;
(3) Fire and/or explosion; or
(4) Similarly acute situations."
Once an immediate removal action is determined to be appropriate, actions
"begin as soon as possible to prevent or mitigate danger to the public health,
welfare, or the environment. Actions may include, but are not limited to:
(1) Collecting and analyzing samples to determine the source and
dispersion of the hazardous substance and documenting these samples
for possible evidentiary use.
(2) Providing alternative water supplies.
(3) Installing security fencing or other measures to limit access.
(4) Controlling the source of release.
(5) MeMeasuring and sampling.
(6) Moving hazardous substances off-site for storage, destruction,
treatment, or disposal provided that the substances are moved to a
facility that is in compliance with Subtitle C of the Solid Waste
Disposal Act. . . .
(7) Placing physical barriers to deter the spread of the release.
(8) Controlling the water discharge from an upstream impoundment.
(9) Recommending to appropriate authorities the evacuation of
threatened individuals.
(10) Using chemicals and other materials in accordance with Subpart H to
restrain the spread of the substance and to mitigate its effects.
(11) Executing damage control or operations." [NCP section 300.65(b)]
Specific criteria regarding immediate removals and their implementation are
addressed in section 300.65 of the NCP.
2
Planned removals may also be implemented . These removals may be done
where continuation of an immediate removal would result in substantial cost
savings, or where the public and/or environment is "at risk from exposure to
2Ibid.
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hazardous substances if response is delayed at a release not on the National
Priorities List" [section 300.67(a)(2) of the NCP]. Planned removals must be
requested by the affected State (via the Governor or his designee).
Factors used to determine the need for a planned removal (as listed under
section 300.67(c) of the NCP) are:
"Actual or potential direct contact with hazardous substances by
nearby population;
Contaminated drinking water at the tap;
Hazardous substances in drums, barrels, tanks, or other bulk storage
containers, that are known to pose a serious threat to public health
or the environment;
Highly contaminated soils largely at or near surface, posing a serious
threat to public health or the environment;
Serious threat of fire or explosion; or
Weather conditions that may cause substances to migrate and pose a
serious threat to public health or the environment."
Criteria regarding the need for planned removals and their implementation are
addressed further in section 300.67 of the NCP.
Initial remedial measures are implemented where "such measures are deter-
mined to be feasible and necessary to limit exposure or threat of exposure to
a significant health or environmental hazard and if such measures are cost-
effective ."
Seven factors are listed in section 300.68(e)[1](i-vii) of the NCP for
determining whether IRMs are appropriate:
"Actual/potential direct contact between hazardous substances and
nearby populations. (Measures might include fences and other security
precautions.)
Absence of an effective drainage control system (with an emphasis on
run-on control). (Measures might include drainage ditches.)
3
Proposed revisions to the NCP (February 12, 1985) include changes in
remediation authority. The user should consult with EPA officials to
determine the appropriate factors to consider when evaluating the need for
initial remedial measures.
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Contaminated drinking water at the tap. (Measures might include the
temporary provision of an alternative water supply.)
Hazardous substances in drums, barrels, tanks, or other bulk storage
containers above surface, posing a serious threat to public health or
the environment. (Measures might include transport of drums
off-site.)
Highly contaminated soils largely at or near the surface, posing a
serious threat to public health or the environment. (Measures might
include temporary capping or removal of highly contaminated soils from
drainage areas.)
Serious threat of fire or explosion or other serious threat to public
health or the environment. (Measures might include security or drum
removal.)
Weather conditions that may cause substances to migrate and to pose a
serious threat to public health or the environment. (Measures might
include stabilization of berms, dikes, or impoundments.)"
A limited feasibility study is performed when more than one remedial
measure is considered technically viable for the immediate control of a
threat. The costs of alternative initial remedial actions must be estimated
and the ability of each alternative to minimize the threat to public health,
welfare, or the environment must be analyzed. Existing site information is
usually all that is required for such an analysis, but occasionally limited
sampling is performed. The most cost-effective alternative is then recom-
mended. A report summarizing the development and analysis of alternatives,
cost estimates, selection of the most cost-effective alternative, and a
schedule for implementation is submitted to the EPA. This report is similar
in format and content to a full feasibility study although less detailed; a
more detailed study methodology is presented in the Guidance Document for
Feasibility Studies Under CERCLA (U.S. EPA, 1985a).
2.4 DEVELOPMENT OF GENERAL RESPONSE ACTIONS
General response actions are developed during scoping so that the data
necessary for developing and evaluating corresponding alternative remedial
actions in the feasibility study can be identified. General response actions
address all the potential impacts identified in section 2.2.2. The identifi-
cation of general response actions will eliminate obviously inappropriate
actions, thus focusing the effort to collect data and develop remedial action
alternatives. The Guidance Document for Feasibility Studies Under CERCLA
(U.S. EPA, 1985a) and the Manual on the Selection and Evaluation of Remedial
Responses (U.S. EPA, 1984d) provide specific guidance for identifying general
response actions and explain the role of this process in the feasibility
study.
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2.5 DATA NEEDS
Remedial investigations must obtain sufficient data to allow a feasi-
bility study,of remedial action alternatives. The NCP recognizes in section
300.68(i)(3) that: "[l]n performing the detailed analysis of alternatives,
it may be necessary to gather additional data in order to complete the
analysis." In the remedial investigation, it is not necessary to determine all
the site and waste characteristics for every site. The information on site
and waste characteristics that must be obtained depend on the information
required to:
Assess alternatives (including the no-action alternative) during the
feasibility study
Support enforcement or cost recovery procedures
Conduct health assessments or special studies.
2.5.1 Data Limitations in the Assessment of Potential Impacts
The evaluation of existing data will identify what remains to be clari-
fied about the types and extent of contamination, pathways of contaminant
migration, and receptors. The limitations identified in the data should be
compiled under each of the data evaluation subheadings:
Hazardous waste sources, including location, quantities, concen-
trations, and characteristics
Migration pathways, including information on geology, pedology,
hydrogeology, physiography, hydrology, water quality, meteorology,
and air quality
Receptors, including demography, land use, and ecology
Engineering aspects, including soils, etc.
The most important criterion in determining if the information within a
particular category is sufficient is that the data must be complete enough to
allow the RI/FS team to evaluate fully the need for source control or manage-
ment of migration measures and the alternatives for meeting these needs.
4Federal Register, Vol. 47, No. 137, July 16, 1982.
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2.5.2 Data Limitations in the Assessment of Remedial Actions
While the remedial investigation is still going on, initial data col-
lected from field efforts will be used to analyze the feasibility of remedial
alternatives. During the analysis of remedial alternatives for the feasi-
bility study, data gaps may be identified which require that additional
information be collected during the site characterization. In other words,
the remedial investigation and feasibility study activities overlap as
specific data needs are identified during the development, screening, and
evaluation of alternatives. It is essential that these data needs be commu-
nicated to the remedial investigation team. The more effective the user is in
communicating data needs from the feasibility study to the remedial inves-
tigation, the more efficient the site characterization process will be. In
addition, the information collected will be more valuable if it is focused on
resolving issues that will determine the adequacy and design characteristics
of the remedial alternatives being analyzed.
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CHAPTER 3
SAMPLING PLAN DEVELOPMENT
3.1 INTRODUCTION
The sampling plan defines the level of effort and specific field activi-
ties for a remedial investigation. The objectives of a sampling plan are to:
Provide specific guidance for all field work
Provide a mechanism for planning and approving site activities
Provide a basis for estimating costs of field efforts
Ensure that sampling activities are limited to those that are
necessary and sufficient
Provide a common point of reference for all parties to ensure com-
parability and compatibility between all activities performed at the
site .
A sampling plan should be prepared for any site investigation that includes
field work.
While the basis of a sampling plan is the existing site information,
additional information needs may be identified during scoping (chapter 2) or
from technical, environmental, and health information needs identified during
feasibility studies. During the remedial investigation, or a concurrent
feasibility study, it may be necessary to revise the sampling plan to increase
the detail of information collected or to focus efforts on a particular
problem. Before development of a sampling plan, the validity of available
data should be assessed, and the value of additional data should be deter-
mined. Only those data that are necessary and sufficient to meet the objec-
tives of each investigation should be proposed for collection.
Sampling plans are normally developed by the contractor's Site Project
Manager for review and approval by the Remedial Site Project Officer. The
Regional .Director, the EPA Office o.f Emergency and Remedial Response, and
other cognizant State and Federal agencies may also review the plan, as
directed by the Remedial Site Project Officer. The approved sampling plan may
also be reviewed by the potentially responsible parties. Because elements of
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the sampling plan are directly related to the site-specific quality assurance
plan, the Regional Quality Assurance Office must participate in the review.
The sampling plan must incorporate data needs for enforcement, or any
health-study-related objectives. Where enforcement activities are involved,
the plan should be reviewed by the Office of Waste Programs Enforcement or
regional enforcement personnel. Where health studies are involved, the plan
should be reviewed by the responsible health agency.
Because sites vary greatly in size and complexity, it is not possible
to develop general quantitative guidelines. The guidance in this document
focuses on considerations during plan development. Section 3.2 contains a
general discussion of the elements that constitute an acceptable sampling
plan. Factors of a programmatic or procedural nature that should be con-
sidered during preparation of a plan are presented in section 3.3. Sections
3.4 and 3.5 discuss general procedures for sampling and data collection, with
reference to more specific information. Finally, section 3.6 provides
guidance on estimating the efforts required during sampling plan development.
3.2 ELEMENTS OF THE SAMPLING PLAN
The sampling plan should, at a minimum, discuss the following:
Investigation objectives
Site background
Analysis of existing data
Analytes of interest
Sample types
Map of locations to be sampled
Sample locations and frequency
Analytical procedures
Operational plan/schedule
Cost estimate.
The sampling plan should also refer to other relevant documentation, data
management, quality assurance/quality control, and health and safety proce-
dures identified in the respective project plans (see chapters 4 and 5).
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3.2.1 Objectives
The investigator should clearly state the specific objectives of a sam-
pling effort. These objectives will be developed within the framework of the
overall remedial investigation.
The sampling plan objectives state the precise reasons for the sampling
effort, with respect to the ultimate use of the data. The objectives will be
determined by the detail required at a site. The data needs identified by
scoping activities may focus sampling activities on specific subareas,
matrices, or contaminants of interest. Any limitations in focus should be
identified and presented in the plan.
3.2.2 Background
The site background description will be based on data collected during
scoping activities (chapter 2). Background information should consist of the
following information:
A description of the site and surrounding area will be referenced,
noting any conditions that may affect the sampling effort. This
includes any limitations in conducting field activities, such as
extreme weather or difficult terrain.
A discussion of known and suspected contamination sources will be
referenced, listing probable transport pathways and impacts. Expected
concentrations of contamination should be noted.
Sources of information about the site should be referenced. Informa-
tion sources may include visual observations, files of the waste
generator or facility owner, files of local or State authorities,
geological and meteorological records, and the project files dealing
with site characterization.
Any observed or reported environmental impacts in the vicinity of the
site or along the probable transport pathways should be referenced.
Any specific data gaps should be noted, and the approach that is being
taken to fill these gaps should be discussed.
3.2.3 Evaluation of Existing Data
Analysis and evaluation of data collected in accordance with an approved
sampling plan are essential site characterization activities. However, it may
also be necessary to evaluate existing data before sampling begins in order to
develop an effective sampling plan. Statistical analysis can show the need
for additional data by examining the validity, sufficiency, and relevancy of
3-3
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existing data. Additional sampling locations can be included in the analysis
to determine how they would affect the accuracy of the site characterization.
In this way, statistical techniques can be used to determine the optimum
sampling locations, thereby minimizing the number of new sampling points
required. The results of these analyses should be included in the sampling
plan.
3.2.3.1 Determining Data Validity
Because the remedial investigation/feasibility study decision process
depends on data collected at the site, quantitative evaluation of the validity
of the data is essential. Validation analyses should be performed on all
existing data before the sampling plan is developed to ensure that errors are
identified and any necessary resampling is scheduled.
Before existing data are used, the data and supporting documentation
should be evaluated. This evaluation should be similar to a quality assurance
audit. Data may be considered invalid if the following information is not
available:
Sampling date
Identity of sampling teams or person in charge
Sampling location and description
Sampling depth increment
Collection technique
Field preparation technique
Laboratory preparation technique
Laboratory analytical methods
Laboratory detection limits.
Data validity may also be checked using statistical cross-validation
procedures (Devary and Hughes, 1984). These procedures involve predicting a
data value for one member of the population from the remaining members of the
population. The difference between the measured and predicted data value,
when compared with the prediction uncertainty, may suggest an invalid data
point or an inaccurate conceptualization of the phenomenon being studied. For
example, a measured surface-water flow rate considerably higher than predicted
or indicated by data trends could suggest an erroneous data value, or perhaps
could be the result of an as yet unidentified phenomenon.
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3.2.3.2 Determining Data Sufficiency
Determining data sufficiency means answering the question, "Do the
existing data adequately characterize the site?" This determination entails
defining the number of samples of each matrix that are necessary and suffi-
cient to satisfy the sampling objectives. Statistically, data sufficiency
involves determining whether confidence levels for measured or predicted
values are rigorous enough to satisfy regulatory and engineering criteria.
For example, it might be mandated that the ground-water contaminant concen-
tration near a water supply will be below EPA drinking water standards with
a specified certainty. Various statistical methods can be used to plan
sampling that will efficiently meet this certainty requirement. Similarly,
the sensitivity analysis may suggest that no additional sampling is required,
i.e., the added data will not significantly reduce uncertainty. The sampling
plan should discuss both such analyses.
Statistical methods alone, however, may not be able to address all
aspects of data sufficiency; for example, when statistical analyses indicate
the need for an unreasonable number of samples, scientific insight into the
phenomenon being studied may allow reductions. Best engineering judgment
should be considered along with statistical accuracy in determining the suf-
ficiency of site characterization activities. These judgments should be
documented and summarized in the sampling plan.
3.2.3.3 Determining Data Sensitivity
During the initial phase of data evaluation, sensitivity studies may be
performed to determine the impact on site assessment if additional sampling is
not performed. Methods are available that may be used to calculate the range
of probable values at nonsampled locations and to determine the effect of this
uncertainty on site assessment; one example of such methods is the kriging
technique of conditional simulation for ground water (journal and Huijbregts,
1978). Sensitivity studies also permit the evaluation of sampling plans
without actual performance of the sampling.
3.2.4 Determination of Chemical Contaminants of Interest
Specification of the hazardous substances to be considered at a site is
essential to scoping the sampling and analysis program. The sampling plan
should contain a list of the parameters for which data are needed. The waste
constituents that are known to be, or are likely to be, found at each site (or
at each major source within a site) and in surrounding environmental media
should be identified. These may be identified from site data defining source
characteristics including records .identifying wastes deposited, site history,
site operations (e.g., chemical manufacturing, metal finishing), generators of
wastes deposited at the site (e.g., likely producing processes), etc. If
information on source characteristics is insufficient to identify analytes of
3-5
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interest, candidates can be selected from the list of hazardous substances as
defined in the Comprehensive Environmental Response, Compensation, and
Liability Act, sections 101(14) and 104(a)(2). Field screening methods may
also be appropriate to determine the contaminants of interest. Although cost
is important, it is not advisable to limit the analytical parameters if data
sources are inadequate.
If only specific analytical parameters are selected, a site characteriza-
tion bias may be introduced. Sampling for only the selected parameters may
then result in incomplete site characterization. A trade-off analysis should
be performed of the uncertainties introduced by biased sampling and analysis
versus the need to limit sampling and analysis efforts to those that are
necessary and sufficient. The objectives of the remedial investigation for
which the sampling effort is being planned are the basis for this trade-off
analysis.
3.2.5 Determination of Sample Types
The environmental matrices to be sampled depend on the characteristics
of the source and the site environment, as well as the purpose of the inves-
tigation. The appropriateness of biased or unbiased sampling will aid in
selecting the matrix of interest. The matrices chosen for biased sampling
would be those most likely to provide positive evidence of hazardous mate-
rials, probably at high concentrations. Unbiased sampling would include
matrices from all migration routes to a thoroughly characterized contaminant
distribution.
The sampling plan should identify the number of each sample type to be
collected, describe collection methods, specify each sampling location, and
give a brief rationale for the selection of the location. (Selection is
discussed in section 3.2.6.) Because some analyses can be performed in the
field, the plan should differentiate between those that will be conducted
on-site and those that will be sent to a laboratory.
The objectives of the remedial investigation determine the types of
samples to be collected. Ground-water and surface-water problems require many
data items including source strengths, disposal practices (release times and
durations), water contamination concentrations, precipitation/infiltration
rates, and aquifer characteristics. Air deposition problems require such data
as source strengths, disposal practices (release times and duration), soil
contamination levels, as well as meteorological information collected over
sufficiently long time periods. Occasionally, receptor sampling is necessary
to define the effects of a hazardous waste site on the susceptible environ-
ment. Further, modeling studies may have information requirements different
from those for establishing contaminant levels.
Samples are generally of the following types:
Samples to characterize the source. Characterization of the source
may require extensive sampling if transport modeling for remedial
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actions, source control measures, or removal operations are being
considered.
Samples to characterize transport pathways. Evaluation of the trans-
port of hazardous substances from source to receptor may require
extensive air, surface-water, ground-water, soil, and sediment
sampling.
Samples to define receptor impacts and effects. Assessments of
exposure or endangerment may require collection of flora and fauna as
receptor organisms. The major drawback of receptor studies is the
large uncertainty associated with uptake and dose mechanisms; cause
and effect is very difficult to prove with any certainty. The basic
statistical mechanism for comparing differences between receptor test
and control (or background) populations is the modified Student's
t-test for unequal variances (Snedecor and Cochran, 1980) .
Samples to conduct modeling studies. Successful use of environmental
models may require media-specific studies of air, surface water,
ground water, soil, or sediments.
3.2.6 Determination of Sampling Locations and Frequency
The parameters of a sampling program include the types, locations, and
frequency of sampling. These parameters are site-specific. Sampling loca-
tions should be specified in the plan, preferably both in tables and on maps,
which should be based on aerial photography. Each sample location should also
be justified. Information in Ford, Turina and Seely (1983) provides guidance
on scoping a sampling plan.
The general criteria for sample location are: (1) enough samples should
be taken to delineate the source, the spatial extent of contamination, actual
(or potential) pathways through the environment, the impact on susceptible
receptors, and to support anticipated modeling needs, and (2) the number of
samples should be minimized according to the "necessary and sufficient"
philosophy while still meeting the objectives of the investigation. The
sampling plan should clearly state levels of confidence within which data will
be considered accurate. These levels are determined in part by the objectives
of the study and by guidelines contained in the quality assurance plan.
The frequency of sampling depends on the site environment and the most
probable pathways for transport. Pathways or receptors affected by seasonal
variations or weather patterns may require multiple sampling. Examples of
multiple sampling areas include crop sampling over a growing season and
surface-water sampling through seasonal variations. Hourly sampling may be
required to evaluate environmental variations in tidally influenced areas.
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3.2.7 Preparation for Sampling
Adequate preparation for a field sampling trip is extremely important
and should be specified in the sampling plan. The EPA1s National Contract
Laboratory Program (CLP) or other qualified laboratories may conduct sample
analysis for Federal-lead projects. State or private parties must generally
procure qualified laboratories for sample analysis. The following elements
can affect field operations, safety, sample validity, and analytical results:
Coordination with analytical laboratories. For Federal-lead sites,
coordination with the CLP Sample Management Office or with the labora-
tory that will conduct the analyses should begin during sampling plan
preparation. Limitations on sampling due to laboratory capacity or
special sample requirements may require scheduling or sample col-
lection modifications. Further, the analytical capabilities of the
laboratory should also be ascertained to enable selection of the
appropriate laboratory; for example, certain analytical techniques
such as gas chromatography (GC) or mass spectrometry (MS) may not be
available from CLP laboratories. The Sample Management Office will
require information on analytes, matrices, number of samples,
approximate concentrations, and when samples will start to arrive.
The name and shipping address of the laboratory to be used will be
provided by the Sample Management Office. Analytical laboratories
should be provided with the same information requested by the Sample
Management Office for actions carried out by States or responsible
parties. Similarly, these requirements should also be met where
non-CLP laboratories are used in Federal-lead projects.
Sample containers. Containers will be obtained from the Sample
Management Office. For responsible party actions or non-CLP labo-
ratories, the laboratory should provide containers that have been
cleaned according to U.S. EPA procedures. Sufficient lead time should
be allowed. Container specifications will depend on the analyte and
sample matrix types. Shipping containers for samples, consisting of
sturdy ice chests with locks, are provided by the remedial investi-
gation contractors.
Equipment. All equipment should be checked for serviceability prior
to packing. Before packing, the mode of shipment should be selected
and necessary arrangements made. Motor freight will handle some
things that air freight will not; also, motor freight is less expen-
sive but takes longer.
On-site analytical equipment. All instrumentation for use on-site
should be checked and calibrated before and after shipping. Appro-
priate standards, solvents, glassware, and cleaning materials should
be shipped or acquired. If a mobile laboratory is to be used on-site,
schedules and other arrangements should be made.
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Protective clothing, safety equipment. Protective clothing and safety
equipment should be checked for serviceability before packing.
Duplication of necessary equipment and spare parts is essential.
Sufficient quantities should be packed to meet changing needs as well
as to replace damaged items.
Record-keeping. Necessary labels, shipping forms, chain-of-custody
forms, etc., should be ordered from the Sample Management Office or
from the laboratory. Plenty of lead time should be allowed.
Cleaning materials. Distilled water, paper towels, etc., may be pur-
chased locally. A sample of the distilled water can be sent to the
lab for analysis as a field blank.
Preservation materials. Preservatives should be available in ample
quantities for the required number and type of samples.
Packing materials. Vermiculite, paint cans, plastic bags, tape, and
shipping labels should be available for the numbers of samples and
shipping containers expected.
3.2.7.1 -Development of Operational Plans for Sampling
Clearly specified responsibilities and procedures contribute to cost-
effective and safe field sampling. A sampling logistics plan should contain
the following elements:
Team members. Team members should be chosen and notified as far in
advance as possible to ensure availability of the required expertise.
The team leader and other team members should have input to the sam-
pling plan. Each team member should be trained in field procedures
and equipment operation, especially if new techniques or special
procedures will be used.
Documentation. Evidentiary (chain-of-custody) requirements demand
extensive paperwork and documentation. All paperwork (sample sheets,
labels, shipping forms, log books, etc.) should be identified in the
sampling plan, and forms obtained well before the trip. (See U.S.
EPA, 1982b, for more information.) Sampling team members should be
familiar with the required documentation before they go in the field.
Equipment. A list of equipment required in the field and a set of
procedures for using the equipment should be provided. All equipment
should be tested and checked for operability and safety before field
use.
Sampling order. Using a map of sample locations and type of samples,
an "operations" plan should be devised to use team members most
effectively in the field.
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Decontamination. Specific decontamination procedures and equipment
should be specified, chosen, and obtained prior to the trip. Disposal
of decontaminated clothing, solutions, etc., should be arranged in
advance. Disposal permits or clearance of procedures by State
agencies may be necessary.
3.2.7.2 Summary of Guidance on Weights and Volumes of Equipment
and Supplies
Typical sampling efforts need large volumes and heavy weights of equip-
ment and supplies. Therefore, planners of investigation activities must
consider the time required for shipping and shipping costs. Good planning
ensures timely delivery of materials at the site. Costs should be minimized
within the time constraints imposed by material availability and site needs.
All shipping should conform to Department of Transportation regulations
(40 CFR 172).
Field activity planning must also consider shipment of samples to the
laboratory. Many samples have limited holding times after which analytical
results are suspect. Therefore, the method of shipment will be determined
based on applicable holding times. Such arrangements should be made in
advance of field activities to prevent delays in the field. The analytical
laboratory may be able to provide guidance on applicable and reliable shipment
methods.
3.3 FACTORS TO CONSIDER IN A SAMPLING PLAN
The sampling plan should consider the requirements for documentation,
efficiency, and safety. The degree to which these aspects are addressed in
the sampling plan varies from site to site. At a minimum, record-keeping,
quality assurance/quality control, health and safety, personnel requirements,
and decontamination/disposal apply to all sites.
3.3.1 Record-keeping
Because all data and means of data collection may be used for evidence,
a rigid system is needed for data and activity documentation and record-
keeping. The EPA Contract Laboratory Program has established standard
operating procedures for sampling documentation. The following documents,
forms, labels, and other records have been found useful by CLP and should be
specified in the sampling plan:
Organic traffic reports (Field Sample Record and Transmittal/
Submission form for samples for organic analyses)
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Inorganic traffic reports (Field Sample Record and Transmittal/
Submission form for samples for inorganic analyses)
High-hazard traffic reports (Field Sample Record and Transmittal/
Submission form for any sample suspected of containing at least
15 percent contamination)
Sample tags/custody seals
Chain-of-custody forms
Field log books
Other special logs and/or forms.
The sampling plan should allow adequate time and labor for handling the
paperwork associated with field exercises. For large sampling efforts, one
full-time member per sampling team is necessary; for smaller efforts, about a
20 to 25 percent increase in sampling time should be allowed for documen-
tation.
3.3.2 Related Management Plans
The sampling plan should include sampling quality assurance and health
and safety plans. These plans are part of the overall and site-specific
quality assurance and health and safety programs described in chapters 4
and 5, respectively.
3.3.3 Specification of Sampling Personnel
As a rule, sampling and other field work should be conducted by expe-
rienced personnel who are, at a minimum:
Thoroughly familiar with field sampling procedures, protocols, and
ancillary requirements
Involved in a health and safety monitoring program (including appro-
priate training)
Able to work as part of an organized team
Available for the entire sampling trip.
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The following sampling team functions, major criteria, duties, and
responsibilities will normally be specified within a sampling plan:
Team Leader. Performs background research; selects team; prepares
sampling operational plan; briefs team; handles on-site public
affairs; accepts and releases samples and paperwork; generates
deliverables and reports
Equipment Officer. Collects, checks, packs, ships all equipment and
supplies; calibrates instruments; provides supplies and spare parts;
is responsible for air tanks, decontamination, sample containers
Site Safety Officer. Prepares safety plan; briefs and trains team;
oversees decontamination; oversees health aspects of work; performs
emergency procedures
Record Custodian. Maintains field notebooks, logs, sample labels, and
custody forms; oversees sample packing and shipping
Work Party (as necessary). Works within the controlled access zone
under the direct observation of one or more of the team principals.
Individual team members may perform several of these functions, espe-
cially at small sites. However, for safety reasons, the minimum team size is
three: one person outside the controlled-access zone and at least two people
within the zone operating according to the "buddy system."
3.3.4 Decontamination and Disposal
Almost all on-site activities require some type of protection/
decontamination procedures for personnel and equipment. The sampling plan
should address at least the following:
Decontamination equipment should be ready to use before site entry.
Decontamination solutions should be specified if the type of contami-
nation is known.
Equipment should be decontaminated after each sample to avoid cross-
contaminat ion.
Contaminated equipment, clothing, and decontamination solutions should
be disposed of on-site. If this is unacceptable, alternative disposal
should be arranged before work starts.
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3.4 SPECIFICATION OF SAMPLING PROCEDURES
A complete protocol and step-by-step procedure for each field exercise or
sample collection will be included in the sampling plan. Generally, sampling
may involve any or all of the following matrices:
1. Source Sampling
Drums and tanks
Impoundments, lagoons, and seeps
Solid waste
Highly contaminated media near sources.
2. Ground-Water Sampling
Monitoring wells
Production wells
Domestic supplies.
3. Surface-Water Sampling
Ponds and lakes
Streams
Runoff and springs.
4. Soil and Sediment Sampling
Bottom sediments
Grab samples
Core samples
Samples for physical measurements.
5. Air Sampling
Monitoring stations
Point samples
Composite collection samples.
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6. Biological Sampling
Flora samples
Fauna samples.
For complete descriptions of methods and procedures, the user is referred
to U.S. EPA (1982b,c), American Public Health Association (1980); Ford,
Turina, and Seely (1983); Mason (1983); U.S. EPA (1971), and American Society
for Testing Materials (1974).
3.5 DATA ACCEPTABILITY AND UTILITY
The design of sampling plans should ensure that data will be acceptable
and usable. Statistical analyses similar to those used to evaluate existing
data (section 3.2.3) should ultimately be applied to the results of the
remedial investigation site characterization effort. Recognizing this, the
investigator should review the sampling plan to ensure that it considers
statistical uses and quality control/quality assurance.
3.6 ESTIMATING EFFORTS REQUIRED FOR SAMPLING PLAN DEVELOPMENT
The general organization and key elements of the sampling plan are
discussed in sections 3.2 and 3.3. The personnel and expertise required to
prepare each of these elements of the sampling plan are summarized in
Table 3-1 and discussed below.
Background. Site background information may require input from
several technical disciplines, depending on the problems at the site
and the level of detail of existing information. Personnel trained in
geology, hydrology, meteorology, environmental chemistry, and biology
should be able to discuss existing conditions, sources, pathways, and
effects.
Evaluation of existing data. Staff members with backgrounds in
statistics and geostatistics should be able to discuss data validity,
relevancy, and sufficiency. An analysis of the effect on assessments
and subsequent site investigation may also require inputs from
geologists, chemists, or environmental engineers, depending on site
conditions.
Determination of analytes of interest. Staff members with expertise
in environmental chemistry, analytical chemistry, and toxicology
should identify analytes of interest and describe preservation,
handling, containers, and methods.
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TABLE 3-1. APPROPRIATE TECHNICAL DISCIPLINES FOR SAMPLING PLAN PREPARATION
Sampling
Plan
Element
Appropriate Discipline
Environ- Environ-
Analytical mental mental Industrial
Biology Chemistry Chemistry Engineering Geology Hydrology Hygiene Meteorology Statistics
I
t
Ul
Background
Statistical
Analysis of
Existing Data
Determination
of Analytes
of Interest
Determination
of Sample
Types
Determination
of Sampling
Location and
Frequency
Preparation
for Sampling
Episodes
Quality
Assurance/
Quality
Control
Safety Plan
-------
Determination of sample types. This section of the sampling plan may
require inputs from a variety of technical desciplines. A discussion
of biased versus unbiased sampling approaches must be prepared by a
statistician or geostatistican. Discussions of particular environ-
mental media (water, air, soil, biota) should be prepared by geolo-
gists, hydrologists, environmental engineers, or biologists, as
appropriate.
Determination of sampling locations and frequency. Statisticians/
geostatisticians, geologists, hydrologists, environmental engineers,
and/or biologists will have input into this section of the sampling
plan.
Preparation for sampling episodes. Project management should prepare
the programmatic aspects of this section. Procedural aspects con-
cerning acquisition, packaging, shipment, etc., should be discussed by
a senior sampling technician.
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CHAPTER 4
DATA MANAGEMENT PROCEDURES
4.1 INTRODUCTION
A remedial investigation may involve many agencies, contractors, and
other entities, all of which generate extensive information. This chapter
outlines procedures to ensure that the quality and integrity of the data
collected are maintained for a feasibility study and/or for any legal or cost
recovery actions. The disposition of data during an RI, as well as any
special data handling procedures, are described in this chapter.
The following discussion is divided into three sections:
Overview of data management protocols and guidelines
Data management requirements for specific RI tasks
Financial and project tracking.
4.2 OVERVIEW OF DATA MANAGEMENT PROTOCOLS AND GUIDELINES
Two main types of information associated with an RI must be documented.
The first type of information comprises technical data that are either
required for or generated by a specific RI task such as scoping or site
characterization. This information includes both field data (e.g., samples,
sample tags, field log books) and data resulting from subsequent laboratory or
engineering analyses (e.g., graphs or modeling results).
The second type of information consists of data that must be tracked to
monitor, manage, and document the actual performance of the RI tasks. This
information, called project tracking data, usually includes schedules, cost
estimates, technical progress reports, and financial management reports.
Table 4-1 lists examples of the technical and management documentation that
are usually necessary.
Specific data management protocols and guidelines should be followed in
documenting the two primary types of information. These protocols ensure that
the validity of the data is safeguarded for decisions made during the feasi-
bility study and for any future legal or administrative actions such as cost
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TABLE 4-1. EXAMPLES OF RI SUPPORT DOCUMENTATION
Field/Laboratory Document-at ion
Project/Field Log Books
Sample Tags
Sample Data Sheets and Logs
Chain-of-Custody Records, Seals
Receipt of Sample Forms
Laboratory Log Books
Laboratory Data, Calculations, Graphs
RI Management Reports
Draft/Final Work Plan(s)
Health/Safety Plan
Sampling Plan
Quality Assurance/Quality Control Plan
Data Management Plan
Project Management Plan
RI Task Reports
Site Description
Contamination Assessment
Environmental Assessment
Public Health Assessment
Endangerment Assessment
Draft/Final RI Report
Technical Progress and Financial Reports
Monthly Technical Progress Report
Monthly Financial Progress Report
Cumulative Project Cost Report
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recovery. Such protocols and guidance have been established by the EPA and
include the National Enforcement Investigations Center (NEIC) Policies and
Procedures Manual (U.S. EPA, 1981b) and the Interim Guidelines and Specifica-
tions for Preparing Quality Assurance Project Plans (U.S. EPA, 1980c) which
describe detailed procedures for sample identification, chain-of-custody,
document control, and quality assurance. This guidance should be consulted
prior to planning any RI activities or establishing RI procedures.
Although not necessarily different from other information, some data,
documents, and other materials may be confidential either for business
security (e.g., trade secrets) or legal reasons. These materials should be
treated according to guidelines provided by case attorneys or outlined in the
following publications:
TSCA Confidential Business Information Security Manual (U.S. EPA,
1981c)
Contractor Requirements for the Control and Security of TSCA
Confidential Business Information (U.S. EPA, 1981a)
Draft Contractor Requirements for the Control and Security of RCRA
Confidential Business Information (U.S. EPA, 1984d)
Draft RCRA Confidential Business Information Security Manual (U.S.
EPA, 1984c)
FIFRA Confidential Business Information Security Manual (U.S. EPA,
1981f).
It is difficult to estimate the level of effort required for data manage-
ment, but experience has shown that 5 to 10 percent of the total effort for
the RI is appropriate. Following the guidelines described in this section
will minimize the generation of data that are not scientifically nor legally
defensible and consequently reduce the data management effort.
This section highlights and sunmarizes the fundamental components of good
data management practices. The components discussed include data processing
and storage and quality assurance.
4.2.1 Data Processing and Storage
The two types of data associated with the RI (data required to perform a
specific activity or data generated by the activity) must be accurately commu-
nicated and properly managed. Data processing and storage are essential to
preserve both the results of the individual task and the inputs for other
tasks still to be conducted. Moreover, the information must be carefully
documented to support any future legal or administrative actions that may be
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taken. These actions may not occur for years after the data have been gath-
ered. Thus, it is crucial that records be sufficiently detailed to provide a
complete and accurate history of data gathering and results.
This section focuses on the precautions and essential steps to be taken
in data processing and storage. The topics covered include:
Documenting field measurements and observations
Sample identification and chain-of-custody
Document control, inventory, and filing systems.
These three topics provide the basis for a documentation system suitable for
any RI.
4.2.1.1 Documenting Field Measurements and Observations
All field measurements and observations should be recorded in project log
books, field data records, or similar types of record-keeping books. Field
measurements include pH, temperature, conductivity, water flow, and certain
air quality parameters. All data must be recorded directly and legibly in
field log books with all entries signed and dated. If entries must be
changed, the change should not obscure the original entry. The reason for the
change should be stated, and the change and explanation should be signed and
dated or identified at the time the change is made. Field data records should
be organized into standard formats whenever possible, and retained in
permanent files such as those described in section 4.2.1.3, which discusses
document control, inventory tracking, and filing systems.
4.2.1.2 Sample Identification and Chain-of-Custody
Field samples should be identified by a sample tag or other appropriate
labeling technique (this text refers to all such techniques as sample tags).
The information on the sample tag should include: the date and time the
sample was collected, the sampling location or station and cross-reference to
the sampling plan, the name of the individual collecting the sample, and any
pertinent remarks. Copies of the sample tags should be stored in a permanent
file maintained for the site (see section 4.2.1.3).
Samples and data from samples are often used as legal evidence. There-
fore, sample possession must be traceable from the time the sample is col-
lected or developed until it and the derived data are introduced as evidence
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in legal proceedings. Chain-of-custody procedures should be followed to
document sample possession. A sample is considered under your custody if:
It is in your possession, or
It is in your view, after being in your possession, or
It is in your possession and you locked it up, or
It is in a designated secure area.
Chain-of-custody procedures should be established for each RI and should
address:
Field custody procedures
Transfer of custody and shipment
Receipt of samples
Laboratory custody procedures.
Sample identification and chain-of-custody procedures are established in
the National Enforcement Investigations Center Policies and Procedures Manual
(U.S. EPA, 1981b); this document should be consulted in establishing such
procedures. Any documentation associated with these procedures (e.g., chain-
of-custody records or receipts for sample forms) should also be placed in a
permanent project file.
4.2.1.3 Document Control, Inventory, and Filing Systems
Precautions should be taken in the analysis and storage of the data
collected during an RI to prevent the introduction of errors or the loss or
misinterpretation of data. The data storage and information system should be
capable of:
Receiving all data
Screening and validating data to identify and reject outliers or
errors
Preparing, sorting, and entering all data into the data storage files
(either computerized or manual)
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Providing stored data points with associated quality assurance/quality
control (QA/QC) "labels," which can indicate the level of confidence
or quality of the data. These labels should:
- Indicate what QA/QC activities were included in the major steps of
the monitoring process
Quantitatively describe the precision/accuracy of the analysis
Make data available to users
Assuring efficiency in data security and disclosure.
Specific requirements and procedures for these aspects of data processing will
be described in the QA plan prepared for the project. A member of the project
team should be designated to establish and maintain the document control sys-
tem for the duration of the investigation.
The document inventory/filing systems should be based on serially num-
bered documents. These systems may be manual or automated. A suggested
structure and sample contents of a file for Superfund activities are shown in
Table 4-2. Regardless of the type of document control system used, it should
be protected from intentional or accidental destruction or damage. Often in
the case of enforcement actions, an attorney may designate portions of the
file as "enforcement sensitive." These documents should be maintained
separately.
4.2.2 Quality Assurance/Quality Control (QA/QC)
Decisions concerning the control and management of hazardous substances
documented in the feasibility study or the need for legal actions are based
on analytical data generated during the RI. Because such decisions can be no
better than the data on which they are based, the quality of the data must
be ensured. A comprehensive and well-documented QA program is essential to
obtaining precise and accurate data that are scientifically and legally
defensible. The concepts outlined in the QA program must be considered in
decisions about the selection of sites for sampling; the frequency of
sampling; the number of samples to be collected; the procedures involved in
the collection, preservation, and transport of samples; the calibration and
maintenance of instruments; and the processing, verification, and reporting
of the data. Specific QA/QC requirements apply to several sampling and site
characterization RI activities.
The objectives of sampling quality assurance are: (1) to ensure that the
procedures used will not detract from the quality of results, and (2) to
ensure that all activities, findings, and results follow an approved plan and
are documented. These objectives dictate that much of the sampling quality
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TABLE 4-2. OUTLINE OF THE FILE STRUCTURE FOR THE SUPERFUND SITES
1. Congressional Inquiries/Hearings
Correspondence
Transcripts
Testimony
Published hearing records
2. Remedial Response
Discovery
- Initial investigation reports
- Preliminary assessment report
- Site inspection report
- Hazardous ranking system
- Sampling and analysis data
Remedial Planning
- Correspondence
- Work plans for remedial investigation/feasibility study
- Remedial investigation/feasibility study reports
- Health and safety plan
- Quality assurance/quality control plan
Remedial Implementation
- Remedial design reports
- Pe rm i t s
- Contractor work plans and progress reports
- Corps of Engineers agreements, reports, and correspondence
State and Other Agency Coordination
- Correspondence
- Cooperative agreement/Superfund State contract
- State quarterly reports
- Status of State assurances
- Interagency agreements
- Memorandum of Understanding with State
(continued)
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TABLE 4-2. (continued)
Community Relations
- Correspondence
- Community relations plan
- List of people to contact, e.g., local officials, civic leaders,
environmental groups
Meeting summaries
- Press releases
News clippings
3. Imagery
Photographs
Illustrations
Other graphics
4. Enforcement
Status reports
Cross-reference to any confidential enforcement files and person to
contact
Correspondence
Administrative orders
5. Contracts
Site-specific contracts
Procurement packages
Contract status notifications
List of contractors
6. Financial Transactions
Cross-reference to other financial files and person to contact
Contractor cost reports
Audit reports
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assurance effort be made before the field work. Activities that should
precede sampling include:
Preparing written protocols for all activities
Training all field team members to use the equipment, procedures, and
documentation
Ensuring that all containers and equipment have been properly cleaned
and are appropriate for matrices and analytes of interest
Ensuring coordination with the laboratory.
A distinction should be made between field quality control and laboratory
quality control. Any laboratory analyzing samples from hazardous waste sites
will have an associated quality control program (in the case of the Contractor
Laboratory Program, this program is standard), and it is tempting to rely on
the laboratory for all quality control. However, the laboratory's program
provides adequate quality control for the analytical function only and cannot
be used to ensure the quality of the entire sampling and analysis process.
Consequently, the sampling plan should provide for adequate "field quality
control" to permit evaluation of the validity of results.
In addition to provisions for quality control, sampling quality assurance
should specify a system of quality assurance procedures, checks, audits, and
corrective actions that is specific to the site activities.
The purpose of site characterization quality assurance and control is to
ensure that the data collected are of known and sufficient quality to assess
contamination at the site qualitatively and quantitatively. QA/QC control for
site characterization encompasses two important aspects:
Records of traceability and adherence to prescribed protocols,
complete descriptions of relaxed or lax quality control, and
corrective actions
Data on the quality of the data collection and analyses, deficiencies
that may affect quality, and the uncertainty limits for results.
Thus, the quality assurance/quality control plan should address at least
the following elements:
Objectives of QA/QC
QA/QC aspects of measurements, sampling, and analytical procedures
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Calibration, preventive maintenance, and corrective maintenance
procedures
Data reduction and interpretation procedures
Quality assurance/quality control performance audits, corrective
actions, and verifications
Documentation and document control for QA/QC
Personnel responsible for QA/QC tasks.
Because the primary aim of the quality assurance/quality control program
is to ensure that the data are reliable, rather than to ensure that a poorly
conducted program is adequately documented, the QA/QC aspects of site charac-
terization should be planned in advance as an integral part of the investiga-
tion. Factors that must be considered in this planning include an evaluation
of the types of data needed, the required level of certainty, and the availa-
bility of data collection and assessment procedures that can provide the
desired level of reliability cost effectively. These quality assurance/
quality control factors vary according to the investigation phase. For
example, the uncertainty limits demanded for data during an initial investi-
gation (i.e., for essentially qualitative assessments) may be much broader
than those required during detailed assessments. The essential point is that
data limitations must be known and must be in accordance with the "necessary
and sufficient" philosophy governing RI planning and activities.
4.3 DATA MANAGEMENT REQUIREMENTS FOR SPECIFIC RI TASKS
The following discussion outlines data management guidelines and
procedures that apply to RI activities described in other chapters of this
document. These include:
Scoping
Site characterization and sampling
Health/safety programs
Institutional issues
Pilot- and bench-scale studies .
Procedures for the disposition of data and any special data handling are
presented in this section. This information is oriented toward Government-
lead projects (Federal or State). Privately-lead actions may differ in the
procedures employed and reports required; however, the guidance in this
section indicates the general methods to be used.
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4.3.1 Data Management for Scoping
Scoping objectives and activities are described in chapter 2. Scoping is
the initial step of a remedial response, and the existing site data gathered
and assessed during scoping define the subsequent tasks.
The most important information or reports produced to support and
document the scoping task include:
Site background, including a description of the problem
Site chronology
Site map
Site-specific plans for QA/QC, health and safety, institutional
issues, and management procedures
Sampling plan and map
Final RI work plans.
The extensive information assembled in preparing these reports should be sys-
tematically filed so that it can be readily procured if needed to support the
conclusions of the feasibility study. Suggested filing and document control
systems are described in section 4.2.1. The rationale, results, and costs of
scoping and other RI tasks should also be documented to support any future
legal or administrative actions.
4.3.2 Data Management for Site Characterization and Sampling
Site characterization and sampling are conducted to verify existing data
and to fill data gaps for subsequent and concurrent RI work. Guidance on con-
ducting site characterization and sampling is presented in chapters 3 and 7.
Documentation and record-keeping procedures are most important during site
characterization and sampling because these steps produce the basic data used
in making all subsequent decisions, including remedial technology selection
and enforcement programs.
The most important aspects of data management in these steps are:
QA/QC plans - to provide records of traceability, adherence to
prescribed protocols, nonconformity events, corrective actions, and
inherent data deficiencies
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Data security system - to ensure that records cannot be tampered with
or accidentally lost or damaged
Detailed work plan - to maintain timing and scheduling requirements
with field work, laboratories, holding times, and data turnaround
Sampling plan - to provide sampling guidance and to address all
elements specified in chapter 3.
4.3.3 Data Management for Health and Safety Programs
An appropriate health and safety program includes the following elements:
A statement of policy
A medical surveillance program and insurance plan
A training program for project personnel
A management plan that defines responsibilities and authorities for
health and safety functions
Health and safety monitoring and standard operating procedures
Equipment procurement, inventory, and maintenance
Emergency response procedures
Documentation and records management procedures.
Existing programs are based on widely accepted practices such as those
found in the Safety Manual for Hazardous Waste Site Investigations (U.S. EPA,
1979a). Health and safety program documentation of particular importance
during RI activities includes:
Physicians' reports
Site-specific health and safety plan
Site visitors' log
Personnel monitoring results
Incident reports
Nonconformity reports
Site Safety Officer's daily log
Team leader log
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Equipment calibration logs
Personnel training documentation.
Further information on these aspects of the health and safety program is
provided in chapter 5.
One unusual requirement of data management for health and safety programs
is long-term data storage. Deleterious health effects from contact with
hazardous materials may not show up for many years. Data must usually be
stored for more than 30 years in order to document previous exposure to
hazardous materials. These data could help determine if the employee's poor
health in later years is related to expsoure. In order to ensure confiden-
tiality of personal health status, records should be kept in the personnel
files rather than site files.
4.3.4 Data Management for Institutional Issues
As explained in chapter 6 of this document, Superfund remedial activities
involve institutional requirements including:
Site access
Community relations planning
Coordination with other EPA offices, Federal agencies, and States.
Proper documentation of actions related to these issues will help minimize
delays in the later phases of remedial planning and implementation. Equally
important, this documentation makes it possible to reconstruct the events if
EPA or its representatives are presented with any legal challenges related to
their conduct of the RI.
The events leading to site access and the nature of the access (volun-
tary, nonvoluntary, emergency) should be clearly recorded and this record
carefully stored in case it is required at a later date. Any agreements
regarding the liability of EPA or its representatives during the RI should
also be documented and safely stored.
Many requirements pertain to community relations during the RI phase.
The Conmunity Relations Plan is a guide to all community relations activities
at a site. All actions taken in accordance with this plan should be docu-
mented and the records stored, but particular attention should be given to
recording actions designed to inform the public about work at the site and
public comments. The public comments are a critical input to the "Respon-
siveness Summary" that must be completed for the feasibility study.
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Finally, a written record should be prepared documenting the coordination
of efforts by EPA and its representatives with other EPA offices, Federal
agencies, or States. Again, reconstruction of events may require the exam-
ination of the procedures used.
4-3.5 Data Management for Bench- and Pilot-Scale Studies
Bench- and pilot-scale studies are performed to determine the proper
treatment of hazardous wastes on a site-specific basis. The general approach
to bench and pilot studies is described in chapter 8.
A comprehensive data management plan should be completed before the
initiation of any bench- or pilot-scale study. This data management plan
should include:
Detailed work plan by task, including estimates of the costs,
man-hours, and schedule
Statement of objectives, indicating the intended purpose of the work,
such as a feasibility study or a design study. Adequacy of sampling
should also be addressed
Quality control and quality assurance procedures
Methods for data collection, reduction, validation, storage, and
transfer
Criteria for technology selection or elimination.
The basic data management concepts for bench and pilot studies are
similar to those for field sampling procedures. It is very important that
this information be well documented because it is the basis for the design or
selection of remedial technologies.
4.4 FINANCIAL AND PROJECT TRACKING
The ability to manage and evaluate progress during an RI depends on the
availability of the appropriate financial and project tracking data. The
collection, documentation, and reporting of these data should take a systems
approach, including the following basic elements:
Detailed work plan by task, including estimates of the costs,
man-hours, and schedule associated with each task
Detailed project tracking reports.
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Since RIs are generally conducted by several parties, including EPA
contractors and subcontractors, State contractors, and responsible parties,
the procedures used to document, report, and track these data vary greatly.
One effective approach is described in the model statement of work (SOW)
included in Appendix A. The final work plan developed by the remedial
planning contractor and approved by EPA and/or the state should detail the
schedule for each RI task.
Project tracking reports are critical for tracking both financial and
technical progress. EPA has developed three monthly status reports typically
submitted by 20 calendar days after the end of each reporting period. They
are:
Monthly Work Assignment Technical Status Report
Monthly Work Assignment Financial Status Report
Cumulative Project Costs Graph.
Suggested formats for these reports are given as Tables 4-3 and 4-4, and
Figure 4-1.
The specific procedures for RIs conducted by other parties should be
similar to those for the Federal-lead RIs but allow for special requirements
relating to agreements, contracts, or arrangements. For example, State-lead
RIs are conducted under a Cooperative Agreement. Generally, EPA and the State
sign a separate agreement for each site, and the reporting provisions in the
agreement can vary.
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TABLE 4-3. SAMPLE STATUS REPORT FORMAT
MONTHLY WORK ASSIGNMENT TECHNICAL STATUS REPORT
WORK ASSIGNMENT NUMBER:
SITE NAME/ACTIVITY:
PREPARED BY:
DATE:
PERIOD (Month, Year)
COPIES:
1. Progress Made This Reporting Period - Description of progress made during
the reporting period, including problem areas encountered and
recommendations.
2. Problems Resolved - Results obtained relating to previously identified
problem areas.
3. Anticipated Problem Areas and Recommended Solutions - Anticipated
problems and recommendations including technical, cost, and scheduling
implications for resolution. Actual or projected overruns should be
discussed here.
4. Deliverables Submitted - Deliverables completed and anticipated,
including deliverables to be submitted, dates of anticipated submittals,
and reasons if due dates have been (or need to be) revised.
5. Upcoming Events/Activities Planned - Important upcoming dates, meetings,
hearings, etc. Major tasks to be performed within the next reporting
period, identification of decision points.
6. Key Personnel Changes - Any changes in key personnel assigned to the
work.
(continued)
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TABLE 4-3. (continued)
7. Subcontracting - Extent of subcontracting and results achieved. Efforts
made toward small business, disadvantaged, and labor surplus area
subcontracting.
8. Travel - Extent of travel, including identification of individuals and
their labor categories, and the results of such travels.
9. Contract Laboratories - Experience with EPA contract laboratory service,
number of samples sent, turnaround time, overall evaluation of service
provided.
10. Percent Complete - Level of technical completion achieved, reported as
percent complete for each task and as a single number for the total work
assignment.
11. Schedule - Agreed upon date that deliverables are due and actual date
deliverables were or are planned to be submitted. Any delay should be
explained.
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Table 4-4. Sample Status Report Format
I
K-
OO
WORK ASSIGNMENT FINANCIAL STATUS REPORT
Work Assignment Number.
Site
Activity:
Cost Element
Contractor LOE Hours (#)
Subcontractor LOE Hours (#)
Total LOE Hours (#)
Contractor Sec. Hours (#)
Subcontractor Sec Hours (#)
Total Sec. Hours (#)
Total Hours (#)
Month Ending:
Actual Costs
Project Start Date
Scheduled Completion Date
% Complete
Estimated Costs
Current Cummulative % Spent
Month to Date
Cost to
Complete
Cost to
Completion
Budget at
Completion
Variance at
Completion
Direct Labor ($)
Equipment ($)
Travel ($)
Sub-Pool Cost ($)
ODC's ($)
Indirect Costs ($)
Subtotal Cost (S)
Base Fee ($)
Total WA ($)
WA Next 3-Month Projections:
Direct Hours (#)
WA Total (9)
Month 1
Month 2
Month 3
Total
-------
Figure 4-1. Sample Cost Status Format
Work Assignment Number:
Site/Activity:
Job Number:
Reporting Period:
8
u
'o
a.
LEGEND
Planned Cost
Actual Cost-to-Date
Estimated Cost to Complete
Target
5% Below
Established
Budget
Current
Reporting
Period
Time
(Contract Performance in Months)
Cumulative Project Costs
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CHAPTER 5
HEALTH AND SAFETY PLANNING FOR REMEDIAL INVESTIGATIONS
5.1 INTRODUCTION
Protecting the health and safety of the investigative team, as well as
the general public, is a major concern in hazardous waste site remedial inves-
tigations .
Hazards to which workers may be exposed include known and unknown chem-
icals, heat stress, physical stress, biological agents, equipment-related
injuries, confined space entry, fire, and explosion. Many of these hazards
are encountered in any type of field study, but exposure to chemical hazards,
including toxicity, flammability, corrosivity, reactivity, and radioactivity,
is a major concern for hazardous waste site workers. Toxicity hazards range
from acute effects with clinical symptoms, such as headache, dizziness, and
skin rash, to chronic or irreversible impacts, including impaired health,
cancer, birth defects, and death. Symptoms of chronic effects may not appear
for months or years; occupational cancers, for example, may have a latency
period of 10 to 30 years or more.
In addition to the protection of site workers, the public's health and
safety must also be considered. Remedial investigations frequently attract
the news media, public officials, and curiosity seekers as well as representa-
tives of potentially responsible parties and Federal and State agencies. Not
only is the safety of these observers a concern, but their actions may affect
the operations and safety of the investigative team. Other public health
concerns include hazards and risks to the surrounding community from unantici-
pated chemical releases, fire and explosion, and gross negligence. Resolution
of public health concerns often involves legal consultation as well as selec-
tion of the best technical and logistical approach.
5.1.1 Overall Approach
Investigation work at hazardous waste sites requires a strong commitment
to the health and safety of site workers. Employers express this commitment
in written health and safety programs and written site-specific safety plans.
The health and safety program embodies the employer's philosophy, policies,
and procedures regarding worker protection. The site-specific safety plan
applies the program to a particular situation by prescribing the specific
personnel, procedures, and equipment to be used.
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All parties to a remedial investigation (i.e., Federal, State, and local
agencies; owners; potentially responsible parties; and private contractors)
should be aware of their potential liability for the health and safety of
workers and of the public. Often, contracts or interagency documents specify
the responsibilities for protecting public health. For example, contracts
typically specify the posting of warning signs, the installation of fences, or
the hiring of security guards. Strategies to alert, warn, or evacuate the
public are generally planned with local community response agencies. Before
initiating an RI, all parties should clearly understand their responsibilities
for developing and implementing emergency procedures to protect the public.
5.1.2 Applicable Regulations to Protect Workers
Occupational Safety and Health Administration (OSHA) regulations are
promulgated under the authority of the Williams-Steiger Occupational Safety
and Health Act of 1970, PL 91-596. The stated philosophy of this legislation
is "to assure so far as possible every working man and woman in the nation
safe and healthful working conditions and to preserve our human resources."
The following is a list of the regulations most pertinent to remedial investi-
gations :
Citation Title
29 CFR 1903 Inspections, Citations, and Proposed Penalties
29 CFR 1904 Recording and Reporting of Occupational Injuries and
Illnesses
29 CFR 1910 Occupational Safety and Health Standards
29 CFR 1926 Safety and Health Regulations for Construction
29 CFR 1960 Federal Employee Safety and Health Programs
29 CFR 1975 Coverage of Employers under the Occupational Safety
and Health Act
29 CFR 1977 Regulations on Discrimination against Employees
Exercising Rights under the Occupational Safety and
Health Act
The most specific regulations governing workplace health and safety are
contained in 29 CFR 1910, Occupational Safety and Health Standards. Of parti-
cular relevance to RI work are the-respirator standards (29 CFR 1910.134) and
the toxic and hazardous substance standards (29 CFR 1910.1000 to 1500).
Further, the OSH Act contains a general duty clause requiring employers to
provide a place of employment free from recognized hazards. This clause is
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generally applied whether or not specific standards exist. This clause also
places upon each employee the obligation to comply with OSHA standards,
however, the final responsibility for compliance with the OSH Act requirements
remains with the employer.
Federal employees, as well as contractor employees, are protected by OSHA
regulations. State employees are not covered by OSHA regulations but may be
covered by State regulations.
The health and safety of employees involved in Superfund activities are
specifically addressed in Section lll(c) of CERCLA, which directs EPA, OSHA,
and the National Institute for Occupational Safety and Health (NIOSH) to
develop a program to "...include, but not be limited to measures for identi-
fying and assessing hazards to which persons engaged in removal, remedy, or
other response to hazardous substances may be exposed, methods to protect
workers from such hazards, and necessary regulatory and enforcement measures
to assure adequate protection of such employees." The NCP (40 CFR 300.71)
expands this directive to require all private contractors working on Superfund
sites to comply with OSHA regulations.
The Interim Standard Operating Safety Guides issued by EPA in September
1982 (U.S. EPA, 1982e) are generally accepted as the standard of practice for
hazardous waste site work. The guides should be consulted before planning any
RI activities. NIOSH prepared guidance manuals for Superfund activities that
are currently under Agency review and may be released in early 1985. The Army
Corps of Engineers and the Coast Guard have also published guidelines and
procedures for protecting workers at hazardous waste sites.
Individual States may have occupational safety and health regulations
more stringent than OSHA's. These should be consulted in order to determine
their applicability and to ensure compliance.
One example of greater stringency in State regulation is State "Right to
Know" laws, which require chemical labeling and worker notification of the
hazards of workplace chemicals. The recently promulgated OSHA Hazard
Communication standard (29 CFR 1910.1200) specifically applies only to
employees involved in manufacturing, but various State "Right to Know" laws
may apply to a wider spectrum of employers. The application of such regula-
tions to workers at uncontrolled hazardous waste sites has not been tested
in the courts. Presently, 15 States are covered by "Right to Know" laws:
Alaska, California, Connecticut, Illinois, Maine, Massachusetts, Michigan,
Minnesota, New Hampshire, New Jersey, New York, Rhode Island, Oregon, West
Virginia, and Wisconsin.
Some States have enacted "Good Samaritan" laws. Such laws limit the
liability of workers who may give first aid or cardiopulmonary resuscitation
(CPR) to co-workers or members of the public.
Professional recommendations and standards have been offered by such
organizations as the American Conference of Governmental Industrial
Hygienists, the American Society of Testing and Materials, the American
National Standards Institute, and the National Fire Protection Association.
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Many of their recommendations and standards have been incorporated into legal
standards, while others, although not legally required, represent good prac-
tice criteria.
Other Federal and State regulations also contribute to the health and
safety of RI workers. Department of Transportation regulations (49 CFR
171-178), for example, specify containers, labeling, and transportation
restrictions for hazardous materials. These regulations cover the transport
of compressed air cylinders, certain instruments, solvents, and all samples.
The Resource Recovery and Conservation Act (RCRA) regulations may apply to the
storage, transport, and disposal of investigation-derived materials, including
disposable clothing, used respirator cartridges and canisters, and spent
decontamination solutions.
5.2 THE HEALTH AND SAFETY PROGRAM
A health and safety program represents an employer's philosophy, pol-
icies, and procedures for assuring "safe and healthful working conditions."
The health and safety requirements for remedial investigations are often far
more rigorous, more technically oriented, and more expensive to implement than
the requirements for routine worker protection programs. The following dis-
cussion offers guidance on the scope of a comprehensive health and safety
program for remedial investigation workers.
5.2.1 Responsibility for Health and Safety
Responsibility for the health and safety program should be clearly
delineated within an organization, as shown in Figure 5-1. The Health and
Safety Director should report directly to the general manager. The Director
should have the responsibility and authority for the development and
implementation of the health and safety program.
A Site Safety Officer is designated to accompany each site investigative
team and is responsible for implementing the site safety plan. A Site Safety
Officer must be on-site at all times with the investigative team. This
individual works with the field team leader, but in the event of a dispute
regarding health and safety, the Site Safety Officer reports directly to the
Health and Safety Director. The Site Safety Officer must be experienced in
field operations and be thoroughly familiar with the use of air monitoring
instrumentation, personal protection equipment, and decontamination
procedures .
Each team member is responsible for complying with the health and safety
program and the site safety plans, as well as alerting others to observed or
suspected hazards. All team members must satisfactorily complete formal
training in hazardous waste site operations before they begin site activities
and should increase their proficiency with additional training.
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Figure 5-1. Organization Chart for Remedial Investigations
General Manager
or
Agency Head
Project
Manager
Field Team
Leader
Health & Safety
Director
T
Site Safety
Officer
Team
Members
5-5
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5.2.2 Selection of Personnel for Remedial Investigations
Because work on uncontrolled hazardous waste sites is more hazardous than
other environmental field studies, personnel should be informed of the risks
prior to their assignment to such project tasks. This information should
include a frank discussion of potential hazards, the medical surveillance and
training programs, and the need for the use of personal protective equipment.
At this point, some individuals may refuse the assignment for personal
reasons .
5.2.3 Medical Surveillance Program
The medical surveillance program has three goals:
To ensure through initial medical screening that workers at hazardous
waste sites are in good health and have no medical conditions that
might put them at an increased risk from this work
To ensure the continued good health of each employee by periodic
examinations
To detect and treat any medical conditions potentially arising from
work at hazardous waste sites .
The health and safety program should define all participants in the
medical surveillance program, identify appropriate clinics and examination
protocols, and address record-keeping requirements. All employees who may
enter an uncontrolled hazardous waste site, perform work on or adjacent to an
uncontrolled hazardous waste site, or handle samples from a site are candi-
dates for medical surveillance. At a minimum, the program must require a
medical examination by a licensed physician to certify the medical fitness of
each worker who may wear a respirator on the job. This examination is
required by the OSHA respirator standard, 29 CFR 1910.134, and must be per-
formed within 12 months before respirator use. OSHA also requires specific
medical protocols for workers who are exposed to certain toxic substances (29
CFR 1910.1001-1046).
The medical monitoring program and protocol should be approved by an
informed occupational physician. Factors in determining the type of exami-
nation and frequency of re-examinations include the chemical and physical
hazards at the site, the time spent in the field, and the chemical contam-
inants to which the worker may be exposed. The examination should include
serum chemistry tests, such as liver and kidney function profiles, spirometer
tests, and audiometry tests.
The initial examination should be conducted a few weeks prior to the
worker's entry into the program in order to give the physician enough time to
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review pertinent laboratory data. Also, early examination allows managers
time to select alternate personnel if any employees are found medically unfit
for field work.
Periodic and exit examinations to monitor health status benefit both the
employee and the employer. The physician must evaluate any change in the
worker's health status from the initial medical exam to determine the need for
additional surveillance or treatment. For the employer, results of periodic
examinations indicate the success of the health and safety program and can
reduce potential liability.
Supplemental examinations should be performed whenever there is an actual
or suspected excessive exposure to chemical contaminants, or if the worker
experiences symptoms of exposure (including headache, dizziness, nausea,
blurred vision, and skin rash), a traumatic injury, or heat or cold stress.
Prompt medical attention is essential for proper diagnosis and treatment and
for allaying the employee's fears.
Recordkeeping is regulated by OSHA, which specifies that medical records
must be retained for 30 years after termination of employment (29 CFR 1910.20),
The confidentiality of these records should be preserved, in accordance with
the Privacy Act of 1974 (PL 93-579). The Health and Safety Director must have
access to the physician's certifications of medical fitness and must be
apprised of all medical restrictions placed on occupational activities.
A health summary form, prepared by the physician or Health and Safety
Director, is strongly recommended. This should be a one-page summary of the
worker's health status, noting restrictions, current medications, allergies,
and immunizations, as well as the name and telephone number of the occupa-
tional physician. The employee should bring this form to the site for con-
sultation in case of a medical emergency. Figure 5-2 presents an example of a
health summary form.
5.2.4 Training
Employees selected for work at hazardous waste sites usually have
required skills in a particular area, such as geotechnology, engineering,
chemistry, or hydrology. To perform these skills safely at a hazardous waste
site, however, requires additional health and safety training.
EPA issued a directive on July 12, 1981 (EPA Order 1440.2) that specifies
the health and safety requirements for EPA employees engaged in field
activities. Under this Order, a minimum of 32 hours of instruction plus 3
days of work in the field with an experienced worker are required for health
and safety training certification. Employees who will manage site activities
must complete an additional 8 hours of instruction. All certified employees
must complete a minimum of 8 hours of refresher classroom training annually.
Although this Order applies only to EPA employees, State and private
organizations have adopted several provisions of this Order as models for
training certification prior to full field work participation.
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Figure 5-2. Example Health Summary Form
Name :
Sex:
Height:
Health Restrictions:
Allergies:
Current Medication
HEALTH SUMMARY
Weight:
Birth Date:
Blood Type:
Immunizations :
Date:
Occupational Physician:
Personal Physician:
Family member(s) to notify in case of emergency:
Relationship
Relationship
Telephone:
Telephone:
Telephone:
Telephone:
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All personnel should be familiar with potential routes (inhalation, skin
or mucous membrane contact, and ingestion) by which toxic materials enter the
body and specific measures to prevent exposure.
Given the hazards of RI work and the potential for exposure to toxic
substances or for traumatic injury, first aid and CPR training assume great
importance. Prompt use of correct first aid or CPR techniques is essential to
protect all field investigators. OSHA requires that at least one person be
trained in first aid if an infirmary, clinic, or hospital is not near the
workplace (29 CFR 1910.151); it is advisable to have more than one trained
person as a backup in case that one person is injured. Courses are available
through the American Red Cross and the American Heart Association for a
nominal fee.
The Site Safety Officer or other workers may be required to perform air
monitoring to track potential worker exposures to airborne contaminants or to
determine if on-site activities are causing contaminants to migrate off-site.
These individuals must receive additional training in the use and limitations
of air monitoring equipment, such as colorimetric tubes, total organic vapor
analyzers, explosimeters, oxygen detectors, or radiation detectors. Because
modifications in operational procedures and selection of personal protection
equipment depend on the interpretation of air monitoring instruments, it is
essential that the instruments be properly maintained and calibrated and that
the readings be accurate and properly interpreted. The EPA Emergency Response
Team in Edison, NJ, has prepared Standard Operating Safety Guides (revised
November 1984) which provide further information on air monitoring require-
ments; this information will be released early in 1985 through the National
Technical Information Service (NTIS), Springfield, Virginia, and the U.S. EPA,
Cine innat i , Ohio.
Supplemental training should be considered for unusual site activities
such as container opening, confined space entry, and sediment sampling.
Simulated exercises will help train field investigators to perform these tasks
safely and more efficiently. Often the logistics of these operations are
complex, and dress rehearsals will help identify problems before they occur in
the field.
Nonessential personnel should be kept off-site as much as possible.
Occasionally, an untrained individual may desire or be required to visit a
site to inspect or observe conditions or activities. The health and safety
program should clearly describe measures to protect these visitors. Many pro-
grams prohibit visitors until they have completed the entire training program.
Other programs prescribe an abbreviated training program for visitors and
restrict the visitors' activities and access to the site. Visitors should be
included in a medical surveillance program.
Special service contractors, such as well drillers, heavy equipment
operators, and surveyors, should be required to show proof that all employees
who will be working on or near a hazardous waste site, or who will handle
potentially contaminated material from a site (samples, tools, or equipment)
have received the appropriate medical examinations. These workers should be
required either to complete the full training program conducted by qualified
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and experienced personnel and designed for field investigation workers or to
enroll in a site-specific training program which addresses the hazards of that
site, the use and limitations of personal protection clothing and equipment
necessary for that site, and the standard operating procedures for work at
that site. If site-specific training is incorporated into the program,
qualified trainers and on-site supervisors must be identified.
EPA schedules training courses for hazardous waste site investigations,
as well as specialized courses in specific aspects of site investigation.
These courses, conducted by the Hazardous Response Support Division, Emergency
Response Team, Cincinnati, Ohio, provide participants with fundamental infor-
mation for protecting the public and the environment from chemical incidents
resulting from releases of hazardous materials. Top priority for enrollment
is given to EPA employees, although personnel from other Federal, State, and
private agencies may enroll if space is available. EPA has made training
grants available to States to conduct their own programs.
A few private firms and universities offer training. These courses may
be tailored to the needs of an organization and in some cases may be offered
at the organization's facility. A good training course will offer:
Experienced instructors who have worked in the field and who have
expertise in worker health and safety at hazardous waste sites.
Sufficient equipment and instruments for each class participant to
dress in protective clothing, wear respiratory equipment, handle
monitoring instruments, and become familiar with the use of each.
This is particularly important for training in respiratory protection.
Both classroom instruction and simulated field exercises. The
exercises should be organized so that every student participates.
Training records should be kept for each employee, including dates of
instruction, curriculum, results of any examinations, and copies of certif-
icates (course participation, Red Cross cards, etc.). Records should be
maintained in a permanent personnel file.
5.2.5 Equipment
Specialized equipment for monitoring and personal protection is required
for RI work. The health and safety program should addresss the selection,
procurement, inventory, maintenance, calibration, and repair of this equip-
ment. Often, depending on the size of the organization, one or more part-time
or full-time equipment technicians are required.
Selection and procurement factors include not only the equipment specifi-
cations and necessary approvals but also delivery times and availability of
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spare parts and repair services. Portability, durability, and ease of opera-
tion, as well as intrinsic safety, precision, accuracy, sensitivity, and
specificity, must also be considered in selecting equipment. An equipment
inventory should list all currently owned equipment, including spare parts.
A tracking system may be required if equipment is sent to different sites.
Equipment related to health and safety is broadly divided into two
categories: monitoring and personal protection. Monitoring equipment
includes:
Explosimeter or combustible gas indicator
Oxygen detector
Radiation meter
Organic vapor detectors
Colorimetric tubes for specific compound monitoring
Radiation badges for each team member
Miscellaneous monitoring equipment, such as hydrogen cyanide or
hydrogen sulfide detectors, dust monitors, and personal sampling pumps
and detector dosimeter badges.
The personal protection equipment includes respirators, clothing, decontami-
nation equipment, and emergency equipment; these items may be reusable or
expendable. Communications devices may also be considered as personal
protection equipment.
Selection and maintenance of respirators must conform to OSHA regulations
(29 CFR 1910.134) and NIOSH/MSHA (Mining Safety and Health Administration)
approvals. OSHA requires a written respirator policy that addresses the
selection and use of respirators; specific requirements are outlined in 29 CFR
1910.134(b). Respiratory protection may include self-contained breathing
apparatus (SCBA); supplied air respirators with associated compressors or air
tanks, hoses and hardware; and air purifying respirators. For the air
purifying respirators, appropriate canisters and cartridges must be provided.
For personnel who require corrective lenses, respirator eyeglass inserts must
be provided. Contact lenses are not permitted with respirator use. Their use
at any time on a hazardous waste site should be addressed in the health and
safety program.
Protective clothing is selected on the basis of resistance to chemical
permeation and penetration, durability, and cost. Weather conditions, type of
contaminants at the site, terrain features, and general site layout are other
factors in selection. Eye protection (safety glasses, chemical splash
goggles, face shield, or full face respirator) should be mandatory at all
times. Steel toe, steel shank neoprene boots and hard hats are more or less
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standard, but gloves and other protective clothing (coveralls, splash suits,
aprons, hoods, etc.) are specifically selected based on site-specific dermal
and traumatic injury hazards and job functions. Disposable clothing is
frequently specified because it minimizes decontamination problems; however,
when selecting disposable coveralls, one must consider the likelihood of these
garments ripping or tearing. Guidelines from manufacturers and recent
publications should be consulted to select proper clothing and glove
materials.
Communication is important both among team members (internal network) and
with the outside world (external network). An equipment inventory may include
intrinsically safe, voice-activated radios, whistles, alarms, and bullhorns
for field communications. At remote sites, a CB radio may be required for
emergency communication. In any event, two means of communication (primary
and backup) are recommended for each network. Field expedient means,
including hand signals, can be used.
Decontamination equipment may include solvents, solutions, water
sprayers, steam cleaners, tubs, buckets, and brushes. Most of this equipment
is readily available locally. The methods and equipment used in decontam-
inating personnel, personal protection equipment, sampling devices, air
monitoring equipment, drill rigs and other heavy equipment, and sample
containers must be selected for the specific work being done and the
contaminants expected at the site.
Emergency equipment includes first aid kits, eye wash stations, fire
extinguishers, stretchers, spill control equipment, and other response
equipment. The site-specific health and safety plan should specify the
emergency equipment required.
5.2.6 Standard Operating Procedures
Standard operating procedures have been developed by EPA to promote
safety at hazardous waste sites. The EPA Interim Standard Operating Safety
Guides (U.S. EPA, 1982e) describe procedures that provide uniformity from site
to site, thereby simplifying the training and work plan preparation. Standard
operating procedures for a comprehensive health and safety program include
basic site rules, site organization, monitoring, levels of protection, commu-
nications, and emergency response. For each of these procedures, applica-
bility, implementation, responsibility, and recordkeeping should be addressed
in the site-specific plan.
EPA has defined levels of protection in the Interim Standard Operating
Safety Guides to provide a common vocabulary to describe personal protection
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equipment. The four levels afford varying degrees of respiratory protection,
dermal protection, and protection from traumatic injury.
Level A is the "moonsuit," which consists of a totally encapsulated
chemically protective suit with self-contained breathing apparatus,
offering the highest degree of respiratory and dermal protection.
Level B provides maximal respiratory protection through the use of
supplied air or self-contained breathing apparatus; the level of
dermal protection is selected on the basis of anticipated hazards.
9 Level C incorporates an air-purifying respirator which is specific to
the contaminantCs) of concern; the degree of dermal protection, as in
Level B, depends on the anticipated dermal hazards. A supplied air
escape pack may be required in some Level C ensembles.
Level D is basically a work uniform.
Many variations are possible within each level, and these variations, e.g.,
gloves, coverall material, and splash garments, must be specified in the site
health and safety plan. Criteria for this selection, outlined in the EPA
Interim Guides, are best determined by professional judgment and research.
5.3 SITE-SPECIFIC HEALTH AND SAFETY PLANS
A written site-specific health and safety plan contains an assessment of
the site hazards and specific procedures to protect workers from these
hazards. The preparation of the plan entails a detailed review not only of
all available site data, but also of the RI activities planned in order to
evaluate potential exposures and the means to reduce these exposures. The
health and safety plan is a document tailored to specific activities at a
specified site under specified conditions. It details both procedures and
equipment, as well as limitations on activities.
The site health and safety plan is essential in the planning process and
is a valuable tool for all team members during later operations. It is fre-
quently consulted during site operations, and a copy must be posted so that
all personnel, including visitors, can easily read it. Because it contains
instructions and telephone numbers for emergencies, it should be posted near
the telephone and other communication equipment.
Although the site safety plan is of necessity detailed, conditions at a
site will inevitably change, either naturally with time or through the
activity of various parties, including the RI team. Accordingly, a procedure
for modifying the site safety plan must be specified in the health and safety
program. Many programs specify that a modification agreed to by the team
leader and Site Safety Officer can be telephoned to the Health and Safety
Director for verbal approval. Other programs require written approval of
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modifications to the site safety plan in order to minimize potential misunder-
standings. Regardless, any modifications to the original site safety plan
should be clearly marked on the posted plan and explained to all team members.
5.3.1 Preparation and Approval
The site health and safety plan should be prepared concurrently with the
sampling plan. Early preparation of the health and safety plan is valuable in
identifying potential problems, including the availability of adequately
trained personnel, equipment, and funds. Inputs to the plan include a
detailed site description and maps, results of previous sampling activities,
and field reports. The plan preparer should review all information about the
site. At the same time, the preparer must review all proposed activities to
identify potentially hazardous operations and exposures. Professional
judgment is required to evaluate site conditions and prescribe appropriate
protective measures. Each investigation plan will vary as to degree of
planning, special training, supervision, and protective equipment. The Health
and Safety Director must give final approval to the plan. Because of poten-
tial liability concerns, each employer is responsible for approving health and
safety plans for its own employees. The plans must conform to the agency's or
firm's health and 'safety program.
5.3.2 Site Description
The site health and safety plan starts with a brief description of the
site, including location, topography, climate, history, current status of
wastes and other materials on-site, legal status, site security, and a summary
of the waste types, quantities, locations, etc. The description is brief
because all of the data are given in other documents. The availability of
resources, such as roads, water supply, electricity, and telephone, is
reviewed. This introductory section also states the purpose of the remedial
investigation and lists the planned actions and dates. This description is
important because it is the basis for the prescribed protective strategies.
Changes in the site or activity descriptions may signal the need to revise the
plan.
5.3.3 Hazard Evaluation
Toxicological data on the wastes known or suspected to be present are
summarized. Particularly important is an analysis of exposure routes and
information regarding permissible exposure levels, such as the threshold
limit values (TLVs) or OSHA permissible exposure limits (PELs). An analysis
of synergistic or additive effects- should be included. Because of the rapid
growth of research in this area, current information on toxicity is as essen-
tial to this analysis as is a basic knowledge of toxicology. Many of the
sources listed in the bibliography are useful texts for hazard evaluation. In
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addition, EPA, the National Institutes of Health, and other agencies maintain
online toxicology data services for subscribers and member libraries. These
services include Medline, Toxline, and Chemline, which provide toxicity data
and information on exposure symptoms and effects, as well as guidance on
proper protection and decontamination. The Chemical Information Resources
Handbook and OTS Information Architecture Handbook are additional sources of
information.
Toxicity may be characterized by dose-response relationships. A concen-
tration or dose, termed the threshold limit value, is sought below which no
toxic effect is observed. Toxicity effects are a function of the specific
chemical agent, synergistic effects with other chemical agents, dose, route of
exposure, and individual susceptibility. Thus, for a full assessment of these
hazards, each contaminant must be identified, the concentrations must be
measured, the routes of exposure must be evaluated, and the overall health
status of the worker must be medically reviewed. Often, some of this informa-
tion is unavailable. Accordingly, the personal protection recommendations
should be conservative to allow for missing information.
Threshold limit values for occupational exposures have been published
for approximately 600 of the over 60,000 known chemical substances in com-
mercial use. Even for these 600 substances, the cancer-causing potential is
inadequately characterized (American Conference of Governmental Industrial
Hygienists, 1984). The National Toxicology Program of the Department of
Health and Human Services has embarked on a major program to identify carcino-
gens. Its 1983 annual report lists 117 substances known or reasonably sus-
pected to be carcinogens. Also, the International Agency for Research on
Cancer (IARC) has published a series of monographs evaluating carcinogen risk
of numerous chemicals to humans. Many of the substances studied by these
agencies have been identified at hazardous waste sites. The mutagenic and
teratogenic impacts, which lead to birth defects, miscarriage, sterility, and
chromosomal abnormalities, of the 60,000 known chemical substances are even
less well characterized. Exposure to carcinogens, teratogens, and mutagens
should be reduced to the lowest possible level in order to avoid long-term
effects.
The hazard evaluation also examines physical factors, such as potential
heat stress, frostbite, noise, radiation, falls, electrical shock, heavy
equipment use, unstable ground or structures, and barriers. Any biological
hazards (poisonous animals, insects, or plants) should also be addressed.
The best protection strategies must first and foremost protect the worker
from known or reasonably anticipated hazards. The strategies must be practi-
cal for use in the field and not introduce greater hazards. For example,
manual dexterity, field of vision, and agility may all be reduced by the use
of personal protection equipment. Also, the use of chemically protective
impermeable clothing, especially when combined with the physical stress of
carrying 25 to 50 pounds of protective gear, promotes the onset of heat
stress, even when ambient temperatures are low. The site safety plan must
strike a balance between adequate protection, local conditions, and increased
worker discomfort. However, under no condition should comfort be a deciding
factor in the selection of protective ensembles.
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The need to accomplish RI tasks within budget constraints is a foremost
concern. However, short-term savings should be weighed against the cost of
long-term liability for loss of well-being and health which might result from
inadequate protection.
5.3.4 Monitoring Requirements
The monitoring requirements are based on the hazard evaluation. They
should be as specific as possible, although for many sites, total organic
vapor analyses, rather than compound specific analyses, are most practical.
One of the biggest problems in protecting on-site workers and the nearby
community is the virtual impossibility of identifying and quantifying poten-
tial exposures from every contaminant on the site in real time. By the time
laboratory results are available, site conditions may have changed or the RI
field work may be complete. Real-time analytical techniques and instrumenta-
tion are severely limited in applicability. A major constraint is the need
for prior knowledge of the contaminants of concern in order to be able to
select instrumentation and analytical standards. Survey methods, such as
total organic vapors, have been developed to serve as indicators, but expert
judgment is required to interpret monitoring data and to select optimal
protection strategies.
5.3.5 Levels of Protection
The plan must describe the level of protection (A, B, C, or D, described
in section 5.2.6) for each work activity (e.g., sampling, drilling, decon-
tamination) and the modifications required for initial site entry. It may set
criteria, generally based on the monitoring data, to upgrade or downgrade the
level of protection. When the site contains chemicals of unknown concentra-
tions and composition, a worst-case scenario should be assumed. Included in
this section of the plan are recommendations for specific clothing, gloves,
etc .
5.3.6 Work Limitations
Typically, a health and safety plan is designed for a specific set of
activities. The plan describes limitations on these actions, such as pro-
hibited access to certain high-hazard areas, and sets forth requirements for
lighting, duration of work shift, etc.
5.3.7 Authorized Personnel
The plan describes the responsibilities of each team member, including
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the site team leader and Site Safety Officer. Approval of personnel by the
Health and Safety Director helps to ensure that they have the proper medical
and training certifications.
5.3.8 Decontamination
The requirements for decontamination are prescribed including equipment,
solutions, and step-by-step procedures. One problem that may need to be
addressed is the disposal of waste materials generated during the investi-
gation. Disposal of these materials, which include decontamination solutions,
drilling cuttings or fluids, disposable sampling devices, disposable clothing,
gloves, respirator cartridges, and canisters, may require permits under RCRA.
5.3.9 Emergency Information
Every site health and safety plan should contain the emergency telephone
numbers for police, fire, ambulance, and hospital and a map clearly showing
the fastest route to the hospital. Other useful emergency information
includes telephone numbers of the potentially responsible party (if known),
home office, EPA, poison control center, and consulting physician. Inclusion
of a copy of standard procedures for reporting emergencies, such as whom to
call and what information to give, is also valuable.
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CHAPTER 6
INSTITUTIONAL ISSUES
6.1 INTRODUCTION
Remedial investigations undertaken pursuant to CERCLA often involve
institutional issues relating to Federal, State, and local regulations,
policies, and guidelines. This chapter outlines the institutional issues
related to various components of a remedial investigation, including site
entry and data collection, community safety and health, community relations,
and coordination with other agencies or organizations. Worker safety and
health issues were described in chapter 5.
This chapter explains the institutional requirements and their potential
affects on the reirtedial investigation. Compliance with these regulations is
important not only to the remedial investigation but also to other phases of
the response and to enforcement actions. The data collected during the
remedial investigation are critical to enforcement proceedings and to the
development and evaluation of remedial alternatives in the feasibility study;
therefore, the validity of the data should be ensured by following prescribed
procedures.
6.2 SITE ACCESS AND DATA COLLECTION
In order to protect all parties and to ensure that the data collected are
admissible in legal proceedings, field personnel should enter hazardous waste
sites only in accordance with legal procedures. The revised guidance on State
participation in the Superfund remedial program (U.S. EPA, Office of Emergency
and Remedial Response (OERR); September 22, 1982) indicates that the State, to
the extent of its legal ability, is responsible for obtaining site access if
EPA asks it to do so. However, it is important for the user to be aware of
the site access considerations outlined below.
6.2.1 Consensual Entry
CERCLA section 104(e)(l) requires any person who handles hazardous
substances to "furnish information, relating to such substances and permit ...
[representatives of the President or of a State] at all reasonable times to
have access to, and to copy all records relating to such substances." Section
104(e)(l) also authorizes the representatives to enter establishments where
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hazardous substances have been located and to inspect and obtain samples in
order to determine the need to respond to a release or to enforce the
provisions of Title I of CERCLA (Hazardous Substances Releases, Liability,
Compensation). CERCLA legislative history makes clear that government
contractors are considered representatives of the President or of the State
and are authorized to perform inspections.
Before attempting to enter a site, the inspector should give advance
notice of the inspection to the owner of the site. Surprise inspections can
be detrimental to the investigation process. The inspector should obtain the
owner's verbal consent for the inspection or investigation. In cases where
difficulty in entering is anticipated, the inspector should attempt to obtain
the site owner's consent in writing. If the site owner (who is identified
during the preliminary assessment) is not available, the inspector should
contact the site operator or other person in charge.
The inspector should make clear that he or she is a contractor or
government employee when requesting access to a site. Field personnel must
avoid even the appearance of threatening or coercing the person in charge of
the site to gain entry; otherwise all data collected during that inspection
may be legally invalid. The person in charge may withdraw consent at any
time; if this occurs, all field personnel should immediately leave the site
(later entry, if necessary, would be nonconsensual). All data collected until
consent is withdrawn are legally valid. Observation from publicly accessible
property may continue after consent is withdrawn, but mechanical aids such as
binoculars and detection equipment may not be used in such observation. The
person in charge may also give consent with restrictions, such as execution of
hold harmless or confidentiality agreements. Requiring such agreements should
be treated as a refusal of entry; however, minor restrictions that do not
compromise the remedial investigation may be accepted.
6.2.2 Nonconsensual Entry
The person in charge of a site has the right to deny entry unless there
is a warrant or court order procured. If one owner refuses entry and another
consents or if the owner or person in charge cannot be located, the inspector
should assume that entry is refused. If access is denied, the inspector
should note the name of the person refusing entry, the date and time, the
reasons given for refusal, and any other relevant information. The field
personnel should then leave the site, and the inspector should notify the
Regional Enforcement Attorney and the Deputy Project Officer, who generally
will apply for a warrant or court order. The inspection should be conducted
in strict accordance with the warrant or court order. To ensure the security
of field personnel, they should be accompanied, if possible, by a U.S.
marshall, who is primarily charged with executing the warrant. If violence is
threatened, other security measures may be necessary.
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6.2.3 Warrantless Entry
In an emergency when there is not enough time to obtain a warrant, a
warrantless inspection is permissible. Emergencies include potential imminent
hazard situations or situations where the evidence may disappear or be
destroyed. Nonconsensual entry without a warrant should not be attempted
without the assistance of a U.S. marshall. If possible, the user should
attempt to obtain a warrant during the time necessary to gain the marshall's
assistance because entry with a warrant is less likely to be challenged in the
field or in court.
6.2.4 Confidentiality
If the person in charge of a site claims that certain information is
confidential (i.e., entitled to protection under section 1905 of Title 18 of
the U.S. Code) and this claim is not rejected by the appropriate EPA legal
office, such information must not be disclosed to unauthorized persons.
Failure to protect confidential information can result in criminal penalties
against the inspector and civil suits against the lead agency. If a claim of
confidentiality is made and consent is not withdrawn, information may still be
collected, provided that the general EPA procedures for handling confidential
information are followed (see 40 CFR part 2). Generally, the person collect-
ing the information should have confidential business information (CBI)
clearance, and files claimed to be CBI should be kept separate from other
files and secure.
6.2.5 Sampling
CERCLA section 104(e)(l)(B) imposes certain requirements on sampling
undertaken pursuant to CERCLA. Before leaving the site, field personnel must
give the person in charge of the site a receipt describing the samples
obtained and, if requested, a portion of each sample equal to the portion
retained. (Before sampling starts, the inspector should ask the person in
charge whether split samples are desired.) CERCLA also requires that the
results of sample analysis be furnished promptly to the person in charge of
the site. All samples should be handled according to chain-of-custody
guidelines (see chapter 3).
6.2.6 Control of Contaminated Materials
Contaminated materials are commonly generated during a remedial investi-
gation. Such materials include decontamination solutions, disposable equip-
ment (e.g., protective clothing), drilling muds, and materials contaminated by
spills during the investigation. The work plan for the remedial investigation
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(the sampling plan) should describe the means of controlling contaminated
materials.
Control of contaminated materials involves minimizing the quantities
generated and adequately storing and disposing of the material. The contami-
nated material may contain hazardous substances in sufficient quantities or
concentrations to classify it as hazardous waste under RCRA (see 40 CFR part
261 subparts C and D). If so, storage and disposal should comply with the
technical requirements of RCRA. This reflects a policy regarding the appli-
cability of EPA-administered permit programs to action taken pursuant to
CERCLA. This policy has not yet received Agency approval. Waivers to this
policy may be granted on a case-by-case basis with the written approval of the
Assistant Administrator for the Office of Solid Waste and Emergency Response
(OSWER). The user should conform to the technical requirements for the
storage, disposal, or other handling of the contaminated materials in order to
protect public health and welfare and the environment.
6.3 LIABILITY
Injury to workers or third parties or damage to property during a reme-
dial investigation can lead to liability claims against field personnel, their
company, or the lead agency (e.g., EPA or the Coast Guard). The user of this
document should be aware of liability provisions in order to act appropriately
in the event of injury or illness to workers and avoid actions that would make
the contractor or government liable for damages.
6.3.1 Workers Compensation
Under workers compensation, an employer is usually exempt from damage
suits initiated by its employees, and all benefits for personal injury caused
by accidents arising out of and in the course of employment are paid out of
pre-established funds financed by insurance premiums. Employees at CERCLA
sites are included under different workers compensation systems, depending on
the employer. All Federal employees, including EPA and Coast Guard personnel,
are covered by the Federal workers compensation program administered by the
Department of Labor. All State employees are covered under individual State
programs. Private employees, such as contractor personnel, are covered under
individual State workers compensation laws, which generally require insurance
or other demonstrations of financial ability to compensate workers.
If a State or contractor worker is injured, the first step in processing
a claim is filing a report with the State agency administering the workers
compensation system. If a contractor is located in one State and is investi-
gating a site in another, the worker may have the option of filing the claim
in either State, depending on State laws. Then, in most cases, the employee
and employer reach an agreement based on the particular State regulations
concerning benefits and coverage, and the worker is compensated by the
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employer or the employer's insurance company. If there is some dispute, the
worker appeals the case to the State agency.
6.3.2 Federal Liability
Although a worker might sue the United States for damages resulting from
work at a Superfund site, there are limitations on the liability of a Federal
agency. The Federal Tort Claims Act (FTCA) provides statutory authority for
recovering losses from the government under certain conditions, but recovery
of losses from the government is difficult. As interpreted by the Supreme
Court, the Government is immune from liability for negligence at the planning
or policy level, but not at the operational level (i.e., negligence of a
regulatory official in prescribing safety precautions at a site).
CERCLA section 107(d) precludes liability of the government, firms, or
individuals for "actions taken or omitted in the course of rendering care,
assistance, or advice in accordance with the National Contingency Plan or at
the direction of an on-scene coordinator" with respect to a release or threat
of release of a hazardous substance. This section, however, does not preclude
liability for damages that result from "gross negligence or intentional
misconduct."
6.3.3 State Liability
If the State is responsible for a response (or certain aspects of a
response) to the release or threat of release of a hazardous substance, the
State may be liable for damages resulting from those response actions. CERCLA
section 107(d) limits the liability of the State to damages resulting from
gross negligence or intentional misconduct (see section 6.3.2); the liability
of the State may be further limited by State tort law. For example, in some
States, gross criminal negligence by the State must be shown before any State
entity can be prosecuted.
The State's liability for contracted work varies depending on the con-
tract. Some States (e.g., New Jersey and California) include language in
contracts that indemnifies the State from liability for third-party claims,
placing the responsibility on the contractor.
6.3.4 Employer Liability
In most cases, employers such as contractors would not be liable for
injuries or illnesses incurred by workers at a Superfund site; disabilities
normally would be compensated through workers compensation. In several recent
cases, however, the courts have ruled that there .are situations where an
injured worker can sue an employer. These situations include intentionally
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harmful acts by employers and injuries resulting from faulty equipment manu-
factured and provided by the employer. It is important to note, however, that
the principles of liability depend on State law and differ markedly from State
to State.
Contractor liability is limited by CERCLA section 107(d) to damages
resulting from gross negligence or intentional misconduct (see section 6.3.2).
Contractors of the Federal Government (e.g., the REM/FIT zone contractors)
are, as specified in the contracts, generally not liable for damages to third
parties resulting from response actions. Other contractors, including con-
tractors to States or private parties, may, however, be liable to third par-
ties in some instances, depending on the contract.
6.4 SUBCONTRACTING FOR SPECIAL SERVICES
The user may need to arrange for services (e.g., sample analysis, engi-
neering, construction) that cannot be supplied through existing contract
vehicles. For example, samples requiring unusual analytical equipment might
be analyzed in a laboratory that is not a part of the Contract Laboratories
Program (CLP).
Knowledge of the various contract types and methods for selecting a
contractor will reduce cost uncertainties and ensure timely, quality work.
Available guidance should be reviewed to obtain relevant information. Such
guidance may include EPA or State procurement regulations, or the EPA Project
Officer's Handbook. The appropriate contracting or procurement office
(Federal, State, or private) should be contacted for assistance and guidance
in the contracting process. Careful review and selection of the most quali-
fied firm will help to ensure the quality of the work and reduce cost
uncertainties.
6.5 COMMUNITY SAFETY AND HEALTH
One of the primary concerns during a remedial action is the health and
safety of the people adjacent to the site and of the site workers. The safety
of the people living near the site is the responsibility of the local com-
munity, with the field contractor and EPA personnel assisting when necessary.
Worker safety is protected by appropriate Federal and State agencies and
regulations, as described in chapter 5. Before a field investigation team is
permitted on-site, a comprehensive site-specific safety plan must be developed
(see chapter 5).
Before work begins at a site, the neighboring communities should be
informed of the anticipated site work and any potential hazards it might pose
to the community. A Federal or State government regulatory official knowl-
edgeable in safety should meet with local fire, police, and other safety
officials to discuss the safety of the community and answer related questions
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(see section 5.2.1). The community is responsible for formulating a contin-
gency plan for community safety, but EPA personnel should assist when needed.
This coordination will help in obtaining the aid of the police and fire
departments, if needed, and in ensuring a cooperative relationship with the
local officials.
6.6 COMMUNITY RELATIONS DURING REMEDIAL INVESTIGATIONS
Community relations activities during remedial investigations are dic-
tated primarily by the site-specific community relations plans (CRPs). A CRP
details how EPA or the State will (1) inform the affected community about the
site and (2) elicit community input into response decisions. A CRP must be
prepared and put into action for every CERCLA response before site work
begins, regardless of whether the response is being managed by program or
enforcement staff or by the responsible parties. Thus, when the remedial
investigation begins at a site, EPA or the State will have completed a CRP for
that site and will have started the communications activities specified in the
CRP.
Generally, CRPs should specify two types of activities: (1) providing
periodic progress reports on the findings of the remedial investigation, and
(2) eliciting and documenting comments and concerns from citizens, local
officials, and community or environmental groups. These activities are
discussed below.
6.6.1 Progress Reports
Citizens will want understandable, accurate information about the pro-
gress and findings of the remedial investigation. The CRP will specify the
most appropriate methods for providing this information. The methods include:
Informal meetings for distributing significant test results or other
findings
Meetings with individuals or groups affected by the results of health
studies
Briefings of local and State officials
Progress reports and fact sheets
News conferences
A repository for site information at the local library, health office,
or community center that contains approved technical documents,
official phone numbers, and a copy of the CRP
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Site visits
A toll-free hotline staffed by EPA personnel qualified to respond to
public inquiries.
Further guidance on these activities is provided in "Community Relations in
Superfund: A Handbook, Interim Version" issued in September 1983 by the Office
of Emergency and Remedial Response.
6.6.2 Eliciting and Documenting Community Concerns
Effective community relations programs give members of the affected
community opportunities for input. Citizens should be encouraged to ask
questions and suggest response actions. EPA or the State must respond to
those questions and concerns and consider them in response decisions, whenever
possible. The issues raised by the community may affect subsequent investiga-
tory actions or suggest important issues for EPA or the State to consider in
selecting an appropriate remedy for the site.
Ultimately, EPA or the State will prepare a Record of Decision (ROD)
describing the remedy selected for the site. Superfund community relations
policy requires EPA staff to prepare a responsiveness summary to be included
with the ROD. This responsiveness summary describes the comments and concerns
raised by the community during the RI/FS process and explains how EPA
addressed those concerns in selecting an appropriate remedy. Therefore, any
citizen concerns raised during the remedial investigation and EPA's response
to those concerns must be documented for use in preparing the responsiveness
summary. The activities listed in the previous section are useful techniques
for encouraging community input during the remedial investigation.
6.7 COORDINATION
Many of the institutional considerations discussed above involve coordi-
nation with other agencies or local officials; in addition, it may be neces-
sary to coordinate with other EPA offices, Federal agencies, and States.
6.7.1 Enforcement Personnel
If a site is the subject of litigation or administrative action or
targeted for enforcement, it is essential that the user of this document
coordinate closely with the regional enforcement personnel. In most cases,
both the regional counsel and the program officer assigned to the site should
be contacted. Close coordination is critical to ensure (1) the collection and
documentation of sufficient data for enforcement purposes (see chapters 3, 4,
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and 7) and (2) strict compliance with the community relations plan for the
site, especially regarding the disclosure of information to the public.
6.7.2 Department of Interior (DPI)
The Department of Interior may provide assistance in performing remedial
investigations through its various services and offices. The Fish and Wild-
life Service may be consulted for information on endangered species, critical
habitats, and wetlands in the vicinity of the site. The Bureau of Land
Management (BLM) should be consulted prior to performing investigations
on-site on Federal lands managed by the BLM, and may also be able to provide
background information on the site setting and history. Additionally, the BLM
may be able to assist in investigations of sites abutting BLM-managed lands by
providing access to the site.
In addition, the Office of Environmental Project Review (OEPR) (under
DOl) has specific duties under CERCLA for evaluating danger to natural
resources resulting from releases of oil and hazardous substances. Under the
EPA/DOI Memorandum of Understanding (September 2, 1983), OEPR is responsible
for performing preliminary surveys of damages to natural resources when
notified of the need for such a survey by EPA's Office of Waste Program
Enforcement (OWPE). In performing the preliminary survey, OEPR may require
data developed during the remedial investigation, or may develop data which
should be incorporated in the investigation. OWPE is the EPA point of contact
regarding preliminary surveys conducted under this agreement.
6.7.3 U.S. Army Corps of Engineers
As the Federal authority responsible for the design and construction of
Federal-lead remedial actions, the Army Corps of Engineers should be consulted
in planning and performing remedial investigations to ensure that the inves-
tigation provides the data necessary for final action design, as well as
evaluation of alternatives. The Corps should be consulted as a data source
when sites are located near or adjacent to Corps projects, since the Corps may
have developed data on local soils, ground water, and surface water which
would be of use in the investigation. Additionally, Corps projects near a
site undergoing investigation may need to be considered in developing remedial
alternatives for the nearby site. Such a case occurred at the Brodhead Creek
site in Stroudsburg, PA; therefore, data on project designs and construction
may need to be obtained as part of the RI.
6.7.4 U.S. Coast Guard (USCG)
The USCG has specific responsibility for responses to spills of oil or
hazardous substances in the coastal zone under the terms of NCP section 300.33
and the Memorandum of Understanding between the EPA and the USCG (February 1,
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1982). In investigating sites involving coastal areas, the USCG should be
consulted to obtain data on spills which may have occurred and contributed to
the contamination problem at the site and previous response operations (i.e.,
immediate removals performed by USCG). Additionally, the USCG may be able to
provide assistance in performing the investigation of sites located in coastal
waters by providing supporting equipment and advice on procedures for per-
forming the investigation.
6.7.5 National and Regional Response Teams
The National Response Team (NRT) is a group of people consisting of
representatives from 12 agencies including representatives of EPA and USCG as
chairman and vice chairman, respectively. The NRT performs three basic kinds
of activities: planning and coordination, operations on-site, and communica-
tions. The RRT is a regional response team for planning and preparedness
actions for a response. The RRT consists of representatives from State and
local agencies who are coordinated to evaluate the effectiveness of, and
recommend changes in, the agencies involved in a response.
The NRT and RRT can assist in the performance of remedial investigations
through several means. The NRT and RRT provide an existing structure for
coordinating the activities of Federal and State agencies, and their
contractors, involved in the response. The teams can be used as a point of
contact for collecting information that may be pertinent to the remedial
investigation from member agencies, and for obtaining necessary easements or
access rights across Federal lands. Additionally, the teams can provide data
on any past emergency response actions at the site, and provide support in
response to emergencies that may occur during the remedial investigation. The
teams may also provide advice on precautions to be taken during the remedial
investigation and on the planning of the investigation.
6.7.6 Agency for Toxic Substances and Disease Registry (ATSDR)
ATSDR within the Department of Health and Human Services is responsible
for monitoring the health of workers and citizens at or near CERCLA sites and
for ensuring the availability of adequate health care services. In this
capacity, ATSDR can contribute to the remedial investigation. ATSDR also
conducts and issues health studies and health assessments. After determining
that ATSDR expertise is required, the user should contact the regional ATSDR
representative.
A memorandum of understanding (MOU) between EPA and ATSDR is being devel-
oped to define the responsibilities of these agencies in responses undertaken
pursuant to CERCLA. The MOU, when approved by both agencies, will provide
more detailed procedural guidance relating to ATSDR involvement in remedial
actions.
6-10
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6.7.7 United States Geological Survey (USGS) and State Geologists
The user may want to consult with USGS district offices to gather basic
technical information about a site. USGS can be employed through either the
existing EPA Headquarters/USGS Inter-Agency Agreement or through a State/USGS
Cooperative Agreement. In addition, many States employ geologists who can
provide valuable technical information about sites in their State. State
geologists may be especially useful when a full-time geologist is not needed
at the site. State geologists may be contacted through State departments of
natural resources.
6.7.8 Other Organizations
Coordination with other organizations may also benefit the investigation.
Examples include:
Private associations, such as the Association of State Geologists or
the American Institute of Professional Geologists, may be able to
provide specialized information about a site.
Local universities may be able to provide laboratory or other facil-
ities useful to the investigation, and faculty members experienced in
many disciplines, may contribute useful information.
Local extension services may be able to provide information on local
agronomy and agriculture.
The Soil Conservation Service has expertise in soil types and
characteristics.
6-11
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CHAPTER 7
SITE CHARACTERIZATION
7.1 INTRODUCTION
Site characterization is the most critical portion of the remedial
investigation process. The objective of site characterization is to collect
and analyze enough information to determine the:
Necessity for remedial actions
Extent of any remedial actions
Feasibility of potential remedial actions.
Thus, site characterization activities provide the data to support the
decisions made in the concurrent feasibility study.
Typical interactions associating site characteristics with effects on
human health and the environment are shown in Figure 7-1. As this diagram
indicates, the possible interactions at any site are many and complex, and
special efforts may be needed to limit the site characterization process to
only the necessary data.
This chapter provides guidance for conducting site characterization
studies that will provide the needed data efficiently and cost effectively.
Two important aspects of site characterization are discussed: (1) types of
investigations and resulting data assessments, and (2) programmatic factors
that should be considered in selecting appropriate site characterization
efforts.
The scope of potential interactions (shown in Figure 7-1) suggests that
many technical areas can be studied. Characterization work may be needed in
the areas of waste properties, site engineering, geology, ground-water and
surface-water hydrology and chemistry, geochemical interactions, atmospheric
processes, effects on the environment, effects on human health, and numerical
modeling. The approach to site characterization work is described in section
7.2. Through a discussion of the technical investigations and assessments
that may be used, section 7.3 provides guidance for establishing an appro-
priate site characterization effort.
7-1
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Figure 7-1. Overview of Effects and Interaction at a
Representative Hazardous Waste Site
Release Modes
Migration Modes
Consumption Modes
Burial Site
Waste Dump
Trench
Tank
Lagoon
Spill
Smelter/Kiln
UG Tank
Pipeline/Sewer
Suspension ^
or
Vaporization
Runoff
Infiltration
Air
Surface
Water
Ground
Water
Soils
Deposition
Resuspension
Infiltration
Runoff
Percolation
Stream Flow
GWFlow
GW Discharge
GW Recharge
Air
Surface Water
Ground Water
Soil
Unsaturated Zone
Crops
Livestock
Game Animals
Fish/Aquatics
Birds/Poultry
Inhalation
Dermal
Contact
Ingestion
Humans
^ y
Environmental
Impact
Human Health
Impact
-------
Programmatic factors resulting from the legislative and programmatic
basis for hazardous waste site investigations may influence the site charac-
terization activities. These factors are presented in section 7.4. Guidance
on timing and cost of required activities is provided in section 7.5.
7.2 APPROACH TO SITE CHARACTERIZATION
The remedial investigation consists of various activities to support the
concurrent feasibility study. The approach is designed to provide information
to be used in determining appropriate response alternatives. As such, the
remedial investigation must be integrated with the feasibility study or other
requirements such as enforcement actions to ensure that inputs are available
when needed. For example, various levels of sophistication can be incorpo-
rated into the investigation activities based on the size and complexity of
the site and on the availability and retrievability of the data. This
multi-level approach provides information to satisfy the successively more
refined levels of the feasibility study. This results in an accurately
focused, cost-efficient study.
The RI process defined in this manual consists of three investigation
levels: characterization (l) and two levels of field studies (II and III).
The focus of each level will depend on the fund-financed remedial, enforce-
ment, or health study objectives of the project. All three levels need not be
performed. The investigation may terminate at level I or II or move directly
from level I to level III; these variations could depend on the utility of
existing data, the urgency of site problems, and the specific objectives of
the RI/FS.
Data collection and analysis do not stop at a particular level but only
when sufficient data are available to justify remedial decisions. Thus, the
scope of data collection and analysis must be adjusted to meet specific site
needs. In some cases, a qualitative assessment of a relatively small data
base may be sufficient for selecting remedial alternatives for obvious threat
situations (e.g., removal of drums which are leaking). In other cases, a
quantitative analysis of a larger data base may be necessary (e.g., large
contamination zone). Sufficiency of data depends on the technical appro-
priateness of the sampling, analysis, and evaluations to be conducted and the
judgment of responsible decision-makers. The data may be deemed sufficient at
any RI level, but must be sufficient to select the most cost-effective remedy.
Level I characterization (Scoping, chapter 2) involves the compilation of
existing data to provide as complete a picture as possible of the overall
magnitude of problems at a site and to develop a plan for subsequent detailed
characterization efforts, if required. The level I characterization of
sources, pathways, and receptors should allow a determination of potential
hazards, including the known or suspected sources of contamination, the
probable pathways by which these contaminants can migrate, and the potential
receptors that are affected by contaminant migration. Level I characteriza-
tion efforts utilize existing data including, but not limited to, information
obtained from the Preliminary Assessment, Site Investigation, and Hazard
7-3
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Ranking System, and should be conducted at all sites. This effort does not
address the development of data to complete the site "picture," instead, data
gaps or insufficiencies are noted for potential investigation. This level
corresponds to the qualitative level of detail for an enforcement
endangerment assessment.
In level II characterization, quantitative data are collected from
various technical investigation methods (e.g., geologic or atmospheric
investigations) to evaluate important site characteristics. This information
is used for several purposes during the RI and FS. The level II character-
ization is used to:
Produce data for the contamination assessment in the RI
Produce a quantitative endangerment assessment to support an admin-
istrative action
Develop and screen remedial actions in the FS and produce data for the
public health and environmental assessments conducted in the FS
Develop baseline data to evaluate the no-action alternative.
The level II characterization will generally be broader in scope and more
detailed than the level I effort and will likely require the collection of
considerable field data. Sections 7.2 and 7.3 of this chapter explain the
several types of investigations that may be conducted in order to develop the
assessments listed above.
The need for a complete level II characterization effort should be
weighed against the results obtained in level I, the requirements of the
feasibility study, and the potential for enforcement activities or health
studies. A limited level II investigation, in which only a few samples are
collected, may be warranted:
Whenever an initial response is implemented and post-action site data
are required to determine its effectiveness
Whenever data are insufficient to permit scoping (i.e., level I) of
the remedial investigation.
The results of level II may be sufficient to complete the RI or indicate
the need for more data to evaluate the feasibility of specific alternatives in
detail. The decision that additional data are needed must be made quickly so
that further mobilization costs are not incurred. Documentation for more
studies (level III) should include the justification for additional study,
specific data needs, and the recommended approach for collecting these data.
7-4
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Level III characterization is used to collect additional data on sources,
pathways, receptors, and environmental conditions needed for evaluation of
alternatives in the FS. These data are used in quantitatively assessing the
performance of the remedial technologies judged to be feasible, and in
performing any required risk assessments associated with implementation of
each remedial action. The level III characterization also includes bench and
pilot studies which are discussed in chapter 8.
7.2.1 Characterization Activities
Site characterization provides quantitative data on potentially important
site characteristics. Because several remedial technologies and alternatives
may need to be evaluated, the characterization effort will be much broader in
scope and more detailed than the preliminary assessment activities and will
likely require considerable collection of field data.
In a few cases, two different levels of remedial investigations are
advisable to ensure proper focus of the study. For example:
1. The site may be very large (more than 100 acres) and complex.
Surveying all areas of a large site in great detail, only to find
that the areas of interest are small subareas, would be a waste of
resources. A better approach would be to conduct an initial screen-
ing study which would determine those areas requiring more detailed
subsequent study.
2. Bench and laboratory studies may be needed to evaluate specific
remedial action alternatives identified in the feasibility study.
Such tests may include field-oriented work such as pump tests to aid
in selection and design of well networks. This rationale for a
second level of remedial investigation flows directly from the
integration of activities with the feasibility study.
3. Enforcement actions may require greater definition of contamination
and a more complete characterization of remedial technologies in
order to support negotiations or litigation.
7.2.2 Data To Be Collected
The data that should be collected during site characterization include
but are not limited to the following:
Environmental Setting. Data to define the site and facility charac-
teristics should be collected commensurate with potential remedial
technology options. This information normally includes descriptions
7-5
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of the geography and layout of the site and surrounding areas; topo-
graphy; waste source locations; waste type; geotechnical engineering
considerations; normal and unusual meteorological conditions; surface
drainage patterns; geologic features; ground-water occurrence, flow
direction, and rate; biota at or near the site; and soil type and
chemistry.
Hazardous Substances. Analytical data should be collected to charac-
terize the wastes completely, including type, quantity, physical form,
degree of contamination, disposition (containment or nature of depos-
its), and facility characteristics affecting release (e.g., site
security, and engineered barriers). These data may also be required
to support decisions on removals or initial remedial measures prior
to remedial actions.
Environmental Concentrations. Analytical data on air, soils, surface
water, and ground-water contamination in the vicinity of a site should
be collected. These data should be sufficient to define the extent,
origin, direction, and rate of movement of contaminant plumes. The
data collected should allow an assessment of hazards posed by the
site to the surrounding environment. Data should include time and
location of sampling, media sampled, concentrations found, conditions
during sampling, and the identity of the individuals performing the
sampling and analysis.
Potential Impact on Receptors. Data describing the human populations
and environmental systems that are susceptible to contaminant ex-
posure via the transport pathways from a site should be collected so
that present or potential exposures can be assessed. Chemical anal-
ysis of biological samples will be needed. Data on observable effects
in ecosystems may also be obtained.
Remedial Action Effectiveness. Data relevant to the feasibility and
effectiveness of proposed remedial actions should be collected.
Because of the diversity of potential alternatives, specific inves-
tigations may be delayed until conclusion of relevant portions of
the feasibility study.
7.2.3 The Philosophy of Necessary and Sufficient
It is EPA's policy that remedial investigations should be undertaken only
to the extent "necessary and sufficient" to fulfill the requirements of sub-
sequent remedial action implementation and/or legal enforcement proceedings.
At any site, there is the potential for conducting investigations far beyond
the needs of remedial responses or enforcement actions. The temptation to
pursue such expensive studies should be avoided in favor of a balanced, justi-
fiable, cost-effective approach that satisfies the site-specific objectives.
7-6
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Therefore, it is important that the objectives and scope of the investi-
gation are clearly defined early in the RI planning process, as described in
chapters 2 (Scoping) and 3 (Sampling Plan). This permits the RI effort to
focus on collecting clearly needed data and reduces the potential for repeated
data collection activities.
The scope of the RI effort depends on the quality of existing data, key
site problems, and FS and enforcement needs. These factors determine the
study parameters and the sampling that will be sufficient to meet identified
needs. When the scope of an enforcement RI is in doubt, the Office of Waste
Program Enforcement or regional enforcement staff should be consulted.
7.2.4 General Characterization Methods
Whenever possible, methods that provide quantitative data should be used
during site characterization. These methods are discussed further in section
7.3.1. Sampling plans (see chapter 3) should be devised to preclude biasing
the results toward preconceived ideas about the site and the hazards it may
pose. The advantages of unbiased sampling, however, should be weighed against
the need for the information and cost and time constraints.
Characterization efforts may include:
Review of existing data not found during the preliminary assessment.
Discovery/quantification of hazardous substances and waste sources.
Geophysical surveys to locate and characterize discrete sources.
Geologic investigations to describe influences on ground-water
movement and contaminant migration.
Installation of observation wells or air monitoring stations.
Hydrologic and atmospheric investigations of the contaminant transport
systems.
Sampling and analysis over a wide area to describe and quantify
contaminants, contaminant distribution (horizontal and vertical),
chemical characteristics of the migration pathways that may affect
migration, and effects on the environment or human health. Ground
water, surface water, sediments, surface soils, subsoils, atmosphere,
biota, and/or waste sources may be sampled, depending on the charac-
teristics of the site and the environmental setting.
Integration of all data into an assessment of site characteristics and
contaminant fate and transport. Development of quantitative numerical
models of the site may be appropriate. Flow models can be used to
determine potentially affected areas, whereas contaminant transport
7-7
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models can quantitatively predict impacts that might not otherwise be
obvious. Model development during this phase can aid in minimizing
the amount of data collected by focusing attention on pathways and
locations that are important to contaminant migration.
While these efforts are generally applicable to all sites, a specific scope of
work is site-specific and should be developed on a case-by-case basis.
7.2.5 Assessments To Be Performed
The completion of site characterization should include the evaluation of
data collected from the various types of investigations conducted in the RI
and the compilation of these analyses into a contamination assessment
describing the hazards posed by a site to support alternative development and
analysis during the feasibility study. The remedial investigation data must
be adequate to perform the technical, public health, and environmental
evaluations conducted in the feasibility study. More detailed guidance on
these assessments is provided in section 7.3.2.
The contamination assessment enumerated in the previous paragraph will be
conducted for an enforcement-lead RI. Completion of this assessment, in
conjunction with the public health and environmental evaluations in the
feasibility study, will allow litigation teams to compare the results of these
assessments with the endangerment assessment initially prepared to justify the
enforcement action. This comparison will serve to refine or update the
endangerment assessment to assure that a finding of imminent and substantial
endangerment does, in fact, exist at the site. These three assessments then
complete the endangerment assessment process performed during the RI/FS for an
enforcement- lead site.
The results of site characterization efforts are quantitative and should
permit determination of the doses that may be received by humans and the
ecosystem. These dose rates can be compared to established criteria or to
toxicological evidence to determine the risk associated with the exposure.
This type of analysis is included in public health and environmental
evaluation in the feasibility study.
The remedial investigation assessment is performed for the base case
(no-action) scenario including future potential effects. RI assessments can
also be conducted for specific purposes, such as (1) to allow cost and
effectiveness information to be compiled on remedial action alternatives;
(2) to limit further the number of remedial technologies for which data should
be collected if additional site characterization is required to support the
feasibility study; and (3) to support enforcement activities.
7-8
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7.2.6 Summary
Site characteristics determined during the remedial investigation are
used to identify, screen, and develop appropriate remedial technologies and
appropriate alternatives. As site characterization progresses, the need for
further study must be evaluated on a continuing basis. This decision is based
on the adequacy of the site characterization for evaluating potential remedial
actions. Documentation should include the justification for additional study,
specific data needs, and the recommended approach for collecting these data.
7.3 INVESTIGATION AND ASSESSMENT PROCEDURES NECESSARY FOR CHARACTERIZATION
The various site characterization activities should focus on conducting
specialized types of investigations to collect the data required to determine
the need for interim measures, and for preliminary analysis, screening, or
final evaluation of remedial action alternatives. Characterization of
sources, pathways, and receptors is the basis for determining the need for a
remedial action.
This section provides guidance on the types of investigations and assess-
ments appropriate for providing (via investigations) and evaluating (via
assessments) the data needed to meet the site characterization requirements
described in section 7.2.
7.3.1 Technical Investigations
Technical investigations focus on the characterization of waste sources,
transport pathways, and receptors. These investigations can be categorized as
studies of waste sources, geology, ground-water hydrology, surface-water
hydrology, pedology, atmospherics, contaminants of concern, human populations,
and ecology. The following section discusses the technical investigations
required in each of these categories and concludes with a discussion of the
use of models in site characterization.
7.3.1.1 Investigations of Source Characteristics
Source characterization involves the collection of data describing the
physical and chemical aspects of the waste materials and the matrix in which
they are contained. Relevant data can be grouped into three categories:
(1) waste characteristics, such as the types and quantities of contaminants
that may be contained in or released to the environment; (2) facility data
that characterize how these contaminants may be released; and (3) site
engineering characteristics that affect the implementation of remedial action
alternatives. Key source characterization data are summarized in Table 7-1.
7-9
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TABLE 7-1. SUMMARY OF IMPORTANT SOURCE AND FACILITY INFORMATION
I
I'
o
Information Needed
Waste Characteristics:
Type
Form
Quantities
Chemical and
physical properties
Concentrations
Facility Characteristics:
Type of waste/
chemical containment
Purpose or Rationale
Determine contaminants
for exposure assessments
and for treatment options
Determine parameters for
alternatives identity/
evaluation
Determine magnitude of"
potential releases
Determine environmental
mobility, persistence,
and effects
Determine quantities and
concentrations potentially
released to environmental
pathways
Determine potential
remedies for releases
Appropriate Collection Methods
Primary Secondary*
Site inspection, Sampling and analysis
waste manifests
Site inspection
Site inspection
Handbooks,
CHEMTREC/OHMTADS,
Chemical Information
Service (CIS)
Site inspection
Sampling and analysis,
geophysical surveys
Sampling and analysis,
geophysical surveys
Laboratory analysis
Sampling and analysis
Site inspection
Remote sensing
(continued)
*May be appropriate if detailed information is required.
-------
TABLE 7-1. (continued)
Information Needed
Integrity of waste/
chemical containment
Drainage control
Engineered
structures
Site security
Known discharge
points (outfalls,
stacks)
Mapping and
surveying
Purpose or Rationale
Determine probability
of release and timing
of response
Determine probability
of release to surface
water
Identify possible
conduits for migration
or interference with
remedial actions
Determine potential for
release by direct contact:
may dictate response
Provide points for
accidental or inten-
tional discharge
Locate existing structures
and obstructions for
alternatives evaluation,
site features, and topography
Appropriate Collection Methods
Primary Secondary*
Site inspection
Site inspection,
topographic maps
Site inspection
Site inspection
Site inspection
Existing maps
(USGS, county,
land development)
Sampling and analysis,
nondestructive testing
Remote sensing
Remote sensing,
surveying
*May be appropriate if detailed information is required.
-------
Unless an extensively detailed, verifiable inventory of wastes at a site
exists, it will be necessary to collect data on the types of contaminants, the
location and volume (horizontal and vertical extent) of the sources, and the
variation of concentrations within the source volume. This effort may require
an extensive program involving discrete samples (or composites) over three
dimensions and analysis using sophisticated techniques. Methods suitable for
sampling and analysis are described in Ford, Turina, and Seely (1983).
It may be possible to determine the location and extent of sources and
the variations of materials within a waste deposit by non-chemical analysis.
Geophysical surveys, using a variety of techniques (e.g., ground-penetrating
radar, electrical resistivity, electromagnetic induction, magnetometry, and
seismic profiling), can effectively detect and map the location and extent of
buried waste deposits. Aerial photography and infrared imagery can aid in
defining sources through interpretation of the ecological impacts resulting
from stressed biota. However, all of these geophysical methods are nonspe-
cific, and subsequent extensive sampling of the sources may be required to
provide the data for evaluation of source control measures at the site. The
latter evaluations may also require field and laboratory measurements of soil
porosity, permeability, and engineering characteristics.
The amount of each chemical that is buried in drums, spilled on/in
surface soils, stored above ground, present in a lagoon, etc., should be
determined. The integrity of chemical containment should also be determined;
for example, it is important to know whether drums are leaking or likely to
leak, or whether a lagoon is secure or is likely to overflow or leak into
ground water. All of this information is necessary to estimate either
qualitatively or quantitatively the level of contaminant release from the
site. Pertinent contaminant-specific data include physical/chemical prop-
erties of the target chemicals, which can be obtained from standard chemical
reference sources, such as Weast (1971); Perry and Chilton (1973); Windholz
(1976); Aldrich Chemical Company (1980); Verschueren (1977); Hansch and Leo
(1979); Dawson, English, and Petty (1980); Lyman, Reehl, and Rosenblatt
(1981); Hawley (1981); Kirk-Othmer (1978); Callahan et al., (1979); and Mabey,
Smith, and Podoll (1982). The information is also available from the Chemical
Information Service (CIS) and other commercial computerized data bases.
Obtaining and organizing all of these data constitute the first steps of
the site investigation. Because all subsequent analyses will focus on the
chemicals identified at this stage, great care should be taken to ensure that
no significant chemicals or release sources are overlooked.
7.3.1.2 Geologic Investigations
The geology of the area is important in site evaluation because of the
interrelationships between geology and source releases, water movement and
contaminant transport, and ease of implementation of remedial alternatives.
Structures influencing ground-water flow may include folds, faults, joints,
fractures, and interconnected voids. Stratigraphic information may be used to
identify aquifers and confining formations so that the units most likely to
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transport contaminants can be delineated. Stratigraphic data and composition
of the geologic units are useful in estimating effective porosity, permeabil-
ity, and homogeneity, which cause flow within an aquifer. The geologic infor-
mation that may be needed to evaluate the site hydrology and site engineering
aspects is summarized in Table 7-2.
7.3.1.3 Ground-Water Investigations
Ground-water contamination can result from surface spills, seepage from
injection wells, mass dumping into pits, and leaching from buried wastes or
lagoons. Characterization of contaminant transport in ground water requires
that the hydrologic properties of the aquifer be determined. The direction of
ground-water flow can be determined by comparing static water level elevations
in a series of wells completed in the same aquifer. The flow rate can be
calculated from the gradient of the ground-water surface, and hydraulic con-
ductivity and porosity. The rate can be determined more precisely from the
results of pumping tests. Flow varies according to aquifer type (confined,
unconfined, or perched), hydrologic boundaries, interconnection with other
aquifers (leakage), and hydrologic stresses (recharge or withdrawal).
Ground-water and geologic data not available in the literature
almost always require direct observation through the installation of
ground-water wells, aquifer tests to determine flow parameters such as
permeability and hydraulic potential, and extensive sampling and analysis.
Geophysical survey methods may be useful for determining geologic and
geohydrologic conditions and for evaluating the direction and extent of
contaminant plumes. Procedures for well installation, aquifer testing, and
sampling of the ground-water regime are described in Ford, Turina, and Seely
(1983). The types of hydrologic data that may be needed to characterize the
movement of contaminants in ground water are presented in Table 7-3.
7.3.1.4 Surface-Water Investigations
If contaminants can be transported via surface-water runoff, then
sampling to evaluate the types and levels of contaminants within these media
should be performed. Because the importance of these pathways depends greatly
on weather conditions, data should be collected at specific, known locations
(or stations), under known meteorological conditions, and through periods
representing natural cycles in ambient conditions. For example, surface-water
samples might be collected at an established station over a seasonal or annual
hydrologic cycle and before, during, and after periods of heavy rainfall.
Extensive sampling and chemical analyses may be required. Established sampling
and analytical procedures for surface-water field studies can be found in
Ford, Turina, and Seely (1983 and 1984) and in U.S. EPA (1982c and 1984k).
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TABLE 7-2. SUMMARY OF IMPORTANT GEOLOGIC INFORMATION
Information Needed
Structural Features:
Folds, faults
I Joints, fractures,
4> interconnected voids
Stratigraphic Characteristics:
Thickness, aerial
extent, correlation
of units, extent
(horizontal and
vertical) of aquifers
and confining units
Mineral composition,
permeability and
porosity, grain-size
distribution, in-situ
density, moisture
content
Purpose or Rationale
Determine natural flow
barriers or controls
Predict major boundaries,
avenues of ground-water
flow
Determine geometry of
aquif-.s and confining
layers, aquifer recharge
and discharge
Determine ground-water
quality, movement,
occurrence, produc-
tivity
Appropriate Collection Methods
Primary Secondary*
Existing geologic maps,
field surveys
Existing geologic
profiles, pump tests
Existing geologic maps,
observation wells
Laboratory analysis,
existing geologic
literature
Remote sensing, aerial
photography, geophysical
techniques
Borehole logging and
mapping, geophysical
techniques (limited)
Borehole logging and
mapping, geophysical
techniques (limited)
Existing literature
*May be appropriate if detailed information is required.
-------
TABLE 7-3. SUMMARY OF IMPORTANT GROUND-WATER INFORMATION
Information Needed
Ground-Water Occurrence:
* Aquifer boundaries
and locations
Aquifer ability
to transmit water
Ground-Water Movement:
Direction of flow
Rate of flow
Purpose or Rationale
Define flow limits and
degree of aquifer con-
finement
Determine potential
quantities and rates for
treatment options
Identify most likely
pathways of contaminant
migration
Determine maximum
potential migration
rate and dispersion
of contaminants
Ground-Water Recharge/Discharge:
Location of recharge/
discharge areas
Determine interception
points for withdrawal
options or areas of
capping
Appropriate Collection Methods
Primary Secondary*
Existing literature,
Water Resource Atlases
Pumping and injection
tests of monitor wells
Existing hydrologic
literature
Existing hydrologic
literature
Existing site data,
hydrologic literature,
site inspection
Borehole logging, regional
water level measurements
Water level measurements
in monitor wells
Hydraulic gradient, per-
meability, and effective
porosity from water level
contours, pump test results,
and laboratory analyses
Comparison of water levels
in observation wells,
piezometers, lakes and
streams
(continued)
*May be appropriate if detailed information is required or if it is the only method due to a paucity of published
data.
-------
TABLE 7-3. (continued)
Information Needed
Rate
Ground-Water Quality:
pH, total dissolved
solids, salinity,
specific contaminant
concentrations
Purpose or Rationale
Determine variability
of loading to treatment
options
Determine exposure via
ground water; define
contaminant plume for
evaluation of interception
methods
Appropriate Collection Methods
Primary Secondary*
Existing literature
Existing site data
Water balance calculations
aided by geology and soil data
Analysis of ground-water
samples from observation
wells, geophysics
*May be appropriate if detailed information is required or if it is the only method due to a paucity of published
data.
-------
The transport of a contaminant in surface water is controlled by the
flow, which in streams is a function of the gradient, geometry, and coef-
ficient of friction. The contaminant has three possible modes of transport:
(1) it may be sorbed onto the sediment carried by the flow; (2) it may be
carried as a suspended solid; or (3) it may be carried as a solute (dis-
solved). Solute transport is the fastest mode of transport. The transport
of a dissolved contaminant can be determined by characterizing the flow of the
surface water and the contaminant dispersion, whereas sediment and suspended
solid transport include other processes such as deposition and resuspension.
It is also important to consider possible interactions between surface water
and ground water. The surface-water information that may be required for
remedial investigations is presented in Table 7-4.
7.3.1.5 Pedological Investigations
The amount of contaminated liquid that infiltrates into the ground
depends on the ground cover, antecedent moisture, land use, and the surface
soil type. The amount of contaminated liquid and the pathway it may take to
enter an aquifer depend on the physical properties (e.g., permeability,
porosity) of the subsurface geologic media and the near-surface characteris-
tics (e.g., soil porosity and moisture content, slope, vegetative cover).
Wet soils are resistant to percolation, steeper slopes have greater
runoff, and low permeability clay or silt lenses may deflect contaminant
migration horizontally. A dissolved contaminant can infiltrate with the
water, whereas contaminants that are suspended or sorbed onto sediments may
remain. Rainfall or flooding may result in sudden transport, although the
contaminant would be diluted. Transport of the contaminant can be determined
by soil samples taken at varying depths and distances from the source.
Soil chemistry plays a major role in the transport of chemicals through
the soil and in the availability of the chemicals for biological uptake. Both
physical processes (e.g., adsorption/desorption) and chemical processes within
the soils (e.g., complexation of metals by soil constituents) should be
investigated in characterizing the migration of contaminants through soils.
The species present and the leachability of chemicals from the soil must be
determined to understand potential biological uptake. Table 7-5 summarizes
characteristics of the unsaturated zone and soil properties that should be
identified.
Appropriate methods for collecting geochemical data include sampling/
analysis through the soil column, (e.g., using lysimeters) and adsorption/
desorption experiments. Existing geochemical transport models require an
extensive array of data which may be beyond the scope of site characterization
efforts. Experts in geochemistry and pedology should be consulted to define
appropriate procedures if site conditions warrant investigations beyond
providing chemical data within soil profiles.
7-17
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TABLE 7-4. SUMMARY OF IMPORTANT SURFACE-WATER INFORMATION
I
H
oo
Information Needed
Drainage Patterns:
Overland flow,
topography, channel
flow pattern, trib-
utary relationships
Surface-Water Bodies:
Flow, stream widths
and depths, channel
elevations, flooding
tendencies
Structures
Surface-water/ground-
water relationships
Surface-Water Quality:
pH, temperature, total
suspended solids, sus-
pended sediment,
salinity, specific
contaminant concen-
trations
Purpose or Rationale
Determine if overland or
channel flow can result
in onsite or offsite
flow and if patterns form
contaminant pathways
Determine volume and
velocity, transport
times, dilution potential,
potential spread of
contaminat ion
Effect of man-made struc-
tures on contaminant
transport and mitigation
Predict contaminant path-
ways for interceptive
remedial actions
Provide capacity of
water to carry contami-
nants and water/sediment
partitioning
Appropriate Collection Methods
Primary Secondary*
Topographic maps,
site inspection
Aerial mapping, ground
survey
Public agency data and
atlases; catalogs, maps,
and handbooks for back-
ground data
Public agency maps
and records
Public agency reports
and surveys
Public agency compu-
terized data files,
handbooks, open
literature
Aerial mapping, ground
survey
Water level measurements,
modeling
Sampling and analysis
*May be appropriate if detailed information is required.
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TABLE 7-5. SUMMARY OF IMPORTANT PEDOLOGICAL INFORMATION
Information Needed
Purpose or Rationale
Appropriate Collection Methods
Primary Secondary*
Soil Characteristics:
Type, holding capacity,
temperature, biological
activity, engineering
properties
Estimate the effect of
the properties on infil-
tration and retardation
of leachates and the
release of gaseous con-
taminants
Reports and maps by
Federal and county
agencies, Soil Conser-
vation Service (SCS)
publications
Borehole sampling,
laboratory measurements
(ASTM methods)
Unsaturated Zone
Characteristics:
Permeability, vari-
ability, porosity,
moisture content,
chemical character-
istics, extent of
contamination
Estimate leachate trans- Existing literature
port through soil matrices
Borehole logs, geophysical
surveys, sampling and
analysis, lysimeters
Soil Chemistry
Characteristics:
Solubility, ion speci-
ation, adsorption
coefficients, leach-
ability, exchange
capacity, mineral
partition coefficients,
chemical and sorptive
properties
Predict contaminant
movement through soils
and availability of
contaminants to biolog-
ical systems
Existing scientific
literature
Chemical analysis, column
experiments, leaching tests
*May be appropriate if detailed information is required.
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7.3.1.6 Atmospheric Investigations
Airborne contaminants can be released by fire, explosion, evaporation,
sublimation, and industrial processes. Data on the characteristics of the
release and the atmospheric conditions may be required to define the path and
dispersion of the release. Atmospheric conditions can also cause transport by
other pathways; for example, precipitation can result in transport by both
surface water and ground water. Climatic data can be obtained from the U.S.
Department of Commerce (1961 and 1968). The design and implementation of air
sampling systems are discussed in U.S. EPA (1971a) and ASTM (1974). Table 7-6
summarizes atmospheric investigations that may be needed at a site.
7.3.1.7 Identification of Contaminants of Concern
Before any analysis of the potential for human or environmental exposure
can begin, those chemicals on which the analyses will focus must be selected.
Relatively few chemicals should be selected for analysis for any site; how-
ever, any chemicals for which environmental standards or criteria have been
developed should be included in remedial investigation analyses. Detailed
guidance for selecting target chemicals will be presented in the forthcoming
Superfund public health evaluation guidance.
The goal of chemical selection is to choose chemicals that represent the
most hazardous chemical species or families present at the site, in terms of
prevalence, toxicity, and mobility. Selection is based on hazard-related
criteria, which must be defined during the remedial investigation. Because a
toxic substance does no harm to human health until exposure occurs, the
likelihood of the migration of the chemical from the site is a major
consideration in chemical selection. The following six factors relating to
the migration and exposure potential of a given chemical must be determined:
Amount of each chemical present at the site
Evidence of existing or past environmental contamination
Volatility
Mobility in soil
Solubility in water
Transformation potential.
7.3.1.8 Investigations of Affects on Public Health
To assess public health impacts two broad categories of data should be
collected during the remedial investigation: first, data to evaluate the
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TABLE 7-6. SUMMARY OF IMPORTANT ATMOSPHERIC INFORMATION
N>
Information Needed
Local Climate:
Precipitation
Temperature
Wind speed and direction
Presence of inversion
layers
Weather Extremes:
Storms
Floods
Winds
Release Characteristics:
Direction and speed
of plume movement
Rate, amount, tem-
perature of release
Contaminant concen-
trations
Relative densities
Purpose or Rationale
Define recharge, aeolian
erosion, evaporation
potential, effect of
weather patterns on
remedial actions, area
of deposition of
particulates
Determine effect of
weather extremes on
selection and timing of
remedial actions,
extremes of depositional
areas
Determine dispersion
characteristics of
release
Appropriate Collection Methods
Primary Secondary*
National Climate Center
(NCC) of National
Oceanic Atmospheric
Administration, local
weather bureaus
Onsite measurements
observations
and
NCC, State emergency
planning offices
Information from source
facility, weather
services, air monitoring
services
Onsite measurements
*May be appropriate if detailed information is required.
-------
likelihood of contaminant release from the site and to predict the environ-
mental fate of released substances, and second, information to identify,
enumerate, and characterize human populations exposed to toxics escaping from
the subject site.
Much of the data in the first category will be obtained and organized
when selecting chemicals of concern (see section 7.3.1.7). Various site
hydrologic, climatologic, physiographic, and operational parameters are also
needed (see previous tables). Additionally, the assessment of the biochemical
fate of released contaminants may require information on the geographic
locations of elevated concentrations, biomagnification potential of the
chemicals involved, biotic populations-around sites, biologic behavior
patterns, inter-species ecological relationships, and the interaction between
biota and humans. Sampling and site observations should support any modeling
activity anticipated. These data are generated through site investigation and
contact with local, State, and national wildlife management agencies, census
bureaus, outdoor recreation groups, and agricultural authorities.
The second category of data, obtainable from maps and Bureau of the
Census reports, includes the numbers and locations of inhabitants in a given
geographic area. Data describing the type and extent of human contact with
contaminated media are also needed. This information generally includes:
Local use of surface waters draining the site
Drinking water
- Recreation (swimming, fishing)
Local use of ground water as a drinking water source
Distance of wells from site
Expected direction of ground-water flow
Human use of or access to the site and adjacent lands
Recreation
- Hunting
Residential
- Commercial
Relationship between population locations and prevailing wind
direction.
When mutagenic or teratogenic chemicals are involved, the population age
and sex distribution of the population may be needed to identify high-risk
subpopulations. Also, any existing epidemiological data concerning affects
already shown by populations near the subject site are helpful. These data
may include direct evidence of health impact (e.g., increased morbidity and
mortality) or evidence of potential health impacts (e.g., body burden measure-
ments for contaminants of concern). Potential health impacts can be
characterized using EPA guidelines, being developed for exposure assessments,
carcinogenicity, mutogenicity, teratogenicity and ferotoxic endpoints, and for
exposure to chemical mixtures and systemic toxicants (U.S. EPA 1984f-1984k).
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7.3.1.9 Biological/Ecological Investigations
Biological and ecological information is collected for use in the
endangerment and environmental assessments. The assessment should follow the
guidelines of the National Environmental Policy Act of 1969, as amended;
however, State guidelines may be more stringent and should also be consulted.
The information should include identification of the site fauna and flora
(especially endangered species and those consumed by humans or found in human
foodchains), critical habitats, land use, water use, and the distribution of
water wells (U.S. EPA, 1982b). Special consideration should be given to
environmental characteristics studied in the remedial investigation, and any
public health and environmental assessments performed for the feasibility
study demand special attention; for example, waste components that become
incorporated into potential human food stuffs through the environmental
pathway should be considered.
A summary of required environmental information is provided in Table 7-7.
Most of this information should be available in public records. Environmental
population characteristics and information on land use can be found on local
or regional maps.
7.3.1.10 Use of Models in Site Investigation
Models can be valuable to a remedial investigation by (1) improving the
conceptual understanding of contaminant migration; (2) predicting the impact
of remedial actions or natural processes; and (3) estimating chemical releases
and migration over time, leading to estimates of exposure to humans and/or the
environment. The latter two uses are directly relevant to assessments made
during the feasibility study. Models provide a means of testing (and con-
firming) assumptions about the location of sources and the relative importance
of different environmental pathways and processes. Modeling can also be used
to define future sampling requirements by identifying inconsistencies and
uncertainties in existing data.
Models applicable to site characterization, exposure assessment, and
remedial action assessment can be grouped according to their relative accuracy
and their ability to depict site conditions. Simplified models (e.g., ana-
lytical and semi-analytical models) quantitatively estimate site conditions
with relatively low accuracy and resolution. Typically, they provide order-
of-magnitude estimates (U.S. EPA, 1982a) and require that simplifying
assumptions be made regarding site conditions and chemical characteristics.
They are useful for screening alternative remedial actions and may also be
used for detailed analysis of alternatives.
Simplified models can be well suited to site investigations. Reviews of
simplified models include a comprehensive discussion of simple models of
surface-water contaminant transport and fate by Mills et al. (1982), two
handbooks on analytical ground-water models by Walton (I983a and 1983b), a
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TABLE 7-7. SUMMARY OF IMPORTANT ENVIRONMENTAL INFORMATION
Information Needed
Fauna and Flora
Critical Habitats
Land Use Characteristics
Water Use Characteristics
Biocontamination
Appropriate Collection Methods
Purpose or Rationale
Determine potentially
affected ecosystems;
determine presence of
endangered species
Determine areas on or
near site to be protected
during remediation
Determine if terrestrial
environment could result
in human utilization,
e.g., presence of game
animals, agricultural land
Determine if aquatic
environment could result
in human utilization of
water, e.g., presence of
game, fish, recreational
waters
Determine observable
impact of contaminants on
ecosystems
Primary
Public records of area
plants and animals
survey, survey of plants
and animals on or near
site, survey of site/
area photographs
Public records of site
environment
Agricultural and devel-
opment maps, site survey
Water resource agency
reports, site survey
Secondary*
Remote sensing, ground survey
Ground survey
Remote sensing, ground and
aerial survey
Sampling and analysis,
remote sensing
*May be appropriate if detailed information is required.
-------
paper on subsurface drain modeling by Cohen and Miller (1983), an inventory of
analytical solutions to ground-water contaminant transport problems by van
Genuchten and Alves (1982), and a comprehensive review of simplified methods
for representing remedial actions by Brown (1983).
More detailed mathematical models (e.g., numerical computer codes)
provide greater accuracy and resolution (U.S. EPA, 1982a) because they are
capable of representing spatial variations in site characteristics and
irregular geometries commonly found at actual sites. These models can also
represent the actual configuration and effects of remedial actions on site
conditions. Detailed mathematical models are sometimes appropriate for
investigations where detailed information on contaminant transport and fate
is required. Mercer and Faust (1981) provide an overview of ground-water
modeling, while Thomas, Ross, and Mercer (1982) review numerical ground-water
flow and transport models. Orlob (1971) discusses mathematical modeling of
estuaries. Donigian (1981) reviews runoff and instream contaminant transport
and fate models. Oster (1982) addresses flow and transport in the unsaturated
zone, and Onishi et al. (1981) review sediment transport and water quality
mathematical models.
Deciding whether models should be used and selecting appropriate models
for the remedial investigation can be difficult. Modeling may not be needed
if site conditions are well understood and the potential effectiveness of
different remedial actions can be easily evaluated. Even at more complex
sites, mathematical modeling may not be justified if resources (e.g., data and
expertise) are limited or relatively straightforward remedial actions are
expected to be used. When modeling is potentially appropriate, selection of
the model must consider:
Data requirements
Ability to resolve key variations in site conditions and the physical
configuration of remedial actions
The dimensionality of the flow field
Ability to represent key physical and chemical processes
Cost and time frame for applying, verifying, and using the model
as a predictive tool
Required knowledge and experience of the model user.
Boutwell (1984) presents a methodology designed to help determine:
(1) whether modeling should be considered; (2) if so, what type is the most
appropriate; and (3) the specific capabilities that the model(s) should have.
Thomas, Ross, and Mercer (1982) discuss the selection and use of models in
repository siting studies, and U.S. EPA (1983c) provides guidance on
the selection of models for exposure assessment.
7-25
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In selecting and applying models, it is important to remember that a
model is an artificial representation of a physical system and is only an
alternative way of characterizing and assessing a site. A model cannot
replace field data, nor can it be more accurate than the available site data.
Model selection should be addressed early in the RI planning. Models
have specific information needs that must be satisfied; otherwise their
results may be meaningless. If the specific information needed requires the
collection of samples, such information should be included in the sampling
plan.
The goals of the site characterization are to specify, at least roughly,
the current extent of contamination and to estimate the travel time to and
approximate chemical concentrations at exposure sites. While field data
generally best define the extent of contamination, models can interpolate
among and extrapolate from isolated field samples and interpret field data so
as to create a more detailed description. Models can aid the data reduction
process by providing the user with a structure for organizing and manipulating
field data.
Use of models requires special expertise. Time and experience are
needed to select the appropriate code and subsequent calibration. If these
resources are not' available, modeling should not be attempted. Models are
used in conjunction with scientific and engineering judgment; they are an aid
to, not a surrogate for, a skilled analyst.
7.3.2 Assessment Procedures
Data collected from various investigation activities must be evaluated
and assessed. The purposes of these assessments are to determine whether the
data collected meet the objectives and to present data and interpretations in
formats useful for making decisions about subsequent work during the
feasibility study.
7.3.2.1 Contamination Assessment
The contamination assessment, a necessary initial part of public health
and environmental assessments, determines the severity of hazards by
considering the quantities and types of contaminants at and around the site
and transport mechanisms that are allowing or may allow migration of contam-
inants from the site. The quantities, types, forms, and concentrations of
contaminants at a site and in surrounding environmental media should be
described. A quantitative evaluation of observed and potential migration of
contaminants should be provided. The contamination data and assessment
7-26
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provide input to two questions that should be answered as early as possible in
the feasibility study or as part of the RI:
Are there hazardous substances.at a site of such types and in such
quantities that a remedial action or further study is warranted?
Are hazardous substances migrating or is there significant potential
for them to migrate through environmental pathways in such magnitude
or at such a rate that a remedial action or further study is required?
The assessment consists of a succinct presentation and analysis of the
source and pathways data that have been collected, including:
A description of the environmental setting at a site, including
important geologic, hydrologic, and atmospheric data and determina-
tions. These data should be presented in the form of contour maps
illustrating important features*of potential migration pathways and
other information of use for evaluating remedial alternatives.
A description of the hazardous substances found, including types,
quantities, forms, and degrees of containment. Appropriate regulatory
standards or criteria and analytical detection limits should also be
described.
A description of contaminant concentration levels found in environ-
mental media at and near the site. Concentration contour maps should
be provided in a format directly comparable with the pathways data.
A summary of findings most relevant to the objectives of site char-
acterization and to the evaluation of remedial action alternatives.
Supporting appendices of all data.
7.3.2.2 Public Health Assessment
The public health assessment is conducted during the feasibility study;
however, the remedial investigation must provide data for the assessment.
Broadly speaking, the data should be adequate to answer four basic questions
regarding the evaluation of human population exposure and risk associated with
hazardous waste sites:
To what chemicals are populations potentially exposed?
What are the size and distribution of potentially exposed populations?
7-27
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What is the concentration of each chemical to which populations are
exposed?
How does exposure occur?
These questions can be addressed by analyses of the type and amount of chemi-
cals released from the site, the environmental fate of chemicals migrating
from the site, and the points at which human populations are likely to contact
contaminants in environmental media. The assessment itself can be qualitative
or quantitative, depending on the availability of required data, the depth of
analysis required, and the nature of the problem.
Qualitative human population exposure analyses can be based on existing
information. The one exception to this is the evaluation of the release
potential of selected contaminants of concern. Because release depends
largely on the physical/chemical properties of a substance, chemical-specific
data addressing volatility, solubility in water, and adsorption potential must
be obtained.
The goal of a qualitative analysis is not to quantify the extent of human
exposure and associated risk but (1) to understand how the chemicals migrate
from the site and reach points of contact with local populations, and (2) to
define the potentially exposed populations in general terms.
To evaluate potential human exposure, it is important to consider the
amounts of chemicals present and the manner of their placement at the site
(e.g., buried in drums, spilled in lagoons). The potential for release of
each contaminant of concern from each on-site source to various environmental
media must be evaluated separately. Table 7-1 summarizes pertinent release
sources for which data should be obtained and evaluated in a qualitative
assessment.
Following assessment of the release of hazardous substances from the
site, the potential for migration of these substances in each environmental
media beyond site boundaries is considered. If available, environmental
monitoring results can provide a direct measure of migration potential.
Alternatively, a qualitative fate evaluation may be done using data on the
physical/chemical properties of each target substance and pertinent site and
biologic parameters.
After the environmental fate analysis has determined the general loca-
tions of potentially contaminated media (or the monitoring data have iden-
tified actually contaminated media), exposed-population analysis is conducted
to determine which populations are likely to be exposed through contact with
these media. Human population information required for this analysis is very
general, although it must include all potential points of exposure. Inte-
grated exposure analysis combines various medium-specific exposures (e.g.,
via food, inhalation) to assess overall exposure to contaminants migrating
from the site.
7-28
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If relevant epideraiological data are available, they can provide valuable
evidence of the actual type and severity of health risk posed by the site.
However, care must be taken in interpreting epidemiological data when a site
is located near other sources of the same contaminants (or other contaminants
with similar health effects). It may be difficult or impossible to determine
the cause of observed health effects in these situations.
In a quantitative approach to public health assessment, the supporting
data must be adequate to permit quantitative estimates of hazardous substance
release, ambient concentrations in environmental media beyond site boundaries,
and population exposure. The objectives of this analysis are two-fold:
(1) to generate a most probable case, conservative quantification of maximum
and average exposure at all identified human exposure points of potential
significance, and (2) to calculate the reduction in population exposures
achievable by various remedial technologies. Meeting this second objective
supplies the human-exposure-related input to the screening of remedial
technologies and development of alternatives. Although the quantitative
approach is more detailed than the qualitative, it is still primarily designed
to generate estimates. Guidance on when to use qualitative and quantitative
analysis is included in the public health evaluations chapter in the
feasibility study guidance.
It may be necessary to support assessments by acquiring additional data
on specific contaminant sources via a more targeted site inventory (field
measurements or source monitoring). Also, because risk analysis for public
health addresses both chronic and subchronic risk, these data must be
sufficient to allow generation of an average (averaged over an assumed 70-year
lifetime) and a maximum (usually 7 days) release estimate (U.S. EPA, 1985b).
Additional field monitoring may be necessary to quantify environmental
concentrations of the contaminants.
Environmental standards or criteria that pertain to the contaminants
should be reviewed. When available, these are compared with contaminant
concentrations in environmental media to indicate the extent of risk when
humans come into contact with these environmental concentrations. Sources of
such information include EPA CASR and computerized information for Dialog
File, Chemical Regulations Guidelines System, and the Bureau of National
Affairs' (BNA) Chemlaw (see OTS Information Architecture Handbook).
7.3.2.3 Environmental Assessment
The environmental assessment, like the public health assessment, is
conducted during the feasibility study. The remedial investigation must
provide data to conduct an evaluation of the effects on the environment at or
near a hazardous waste site. Similar to the public health assessment, the
7-29
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environmental assessment should answer four questions (U.S. EPA, 1983d; U.S.
EPA, 1983c):
What chemicals have been or might be released to the environment?
What are the concentrations and exposure levels of these chemicals?
How does the environmental exposure occur?
What is the significance?
The environmental assessment, conducted in the feasibility study, may
require data to complete the five analytical steps shown in Figure 7-2:
Characterize source
Determine fate
Identify populations at risk
Calculate dose
Assess impacts.
Quantification of the source of release is a site characterization task
that is common to all the exposure assessments in the remedial investigation.
The chemical and physical properties of the source and additional site
characteristics that affect the environmental fate of the source must be known
to complete the environmental assessment.
The fate of the contaminants in the environment is critical to the
conclusions of the environmental assessment. It is important to know where
contaminants can enter the environment and what environmental media (water,
air, soil) will receive or transmit the contaminants (pathways). It is also
important to identify those contaminants that will be transformed. Speci-
fically, the assessor should determine which chemicals will be found in areas
on or near the site that are used by plants and animals.
In a related step, it is necessary to identify the plant and animal
populations that will be in direct or indirect contact with the chemicals.
Because extensive plant and animal population surveys can be expensive, data
collection criteria should be established to ensure the most cost-effective
survey. Of particular importance are threatened or endangered species,
species that are consumed by man, species in the food chain up to humans, or
species of local or regional importance. This information may also be
important to the assessment of human health exposure, so data collection
should be designed to fulfill both needs.
Before the environmental assessments can be completed, the dose to
important environmental populations should be Calculated. Dose calculations
7-30
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Figure 7-2. Supportive Information for Environmental Assessment
Analytical Steps of Remedial Investigation
Feasibility
Study
i
u>
Characterize
the
Source
*
Determine
Environmental
Fate
of
Release
*
Determine
Populations
at
Risk
i
t
Supportive information that
can be collected to enhance
the environmental assessment
Survey of
Plant and
Animal
Populations on
Vor Near the Site,
Calculate
the
Dose
i
i
*
Determine
Impacts
on the
Environment
i
t
' Risk t
Assessment |
V /
* _ «*
/ Environmental \ / Bioassays, \
Pathways
Analysis
Microtox.
Ecotoxicity
\ / \ Studies /
-------
should consider environmental concentrations and the potential duration of the
exposure. This task parallels the dose calculation analysis that is necessary
for the public health assessment. For consistency, similar dose determination
techniques or methods should be applied.
Based on the environmental population studies, it should be possible to
focus the detailed analysis of impact on potentially affected species. Ulti-
mately, it may be necessaiy to collect detailed information about a population
or species. Life history data (breeding, spawning, or flowering seasons;
migration and dispersion patterns; and feeding and nutrient requirements) may
be needed to define further the populations (Porcella, 1983).
The calculations of dose may require additional environmental details.
The species tolerances to the chemical(s) in the environment should be
determined, which may require bioassays, microtox analysis, and detailed
biological sampling of the site environment. In addition, responses to
potential degradation products may also need to be addressed. These detailed
and complex procedures illustrate the potential extent of an environmental
assessment.
Guidance on performing environmental assessments is discussed in chapter
6 of the feasibility study guidance.
7.4 PROGRAMMATIC FACTORS AFFECTING SITE CHARACTERIZATION ACTIVITIES
Several constraints on site characterization influence the way in which
the program is conducted. These include connections with potential enforce-
ment actions under CERCLA, the desire to minimize program costs within the
"necessary and sufficient" philosophy, the necessity of ensuring data quality,
and timing and scheduling concerns.
7.4.1 Responsible Party Actions
The U.S. EPA has established the policy of giving responsible parties the
opportunity to conduct site characterization, as well as remedial response
activities, under the NCP, subpart F, sections 300.68(c) and 300.68(f),
according to approved plans for remedial investigations/feasibility studies.
Because site characterization activities can be scoped (see chapter 2),
planned, and conducted by the responsible parties, there is an obvious need
for adequate supervision and for a system of proven document control (see
chapter 4).
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Any previous, concurrent, or subsequent investigations and data provided
by potential responsible parties should be scrutinized closely in formulating
site characterization studies. Questions to ask in screening such information
include:
Is documentation adequate for evidentiary purposes?
Were quality assurance/quality control procedures established and
implemented?
Were standard data collection and assessment methodologies used?
Were the site characterization efforts objective?
Deficiencies that exist in the information supplied by responsible
parties should be considered when planning subsequent site activities.
7.4.2 Documentation and Recordkeeping
Stringent demands for proper documentation and recordkeeping exist
throughout the remedial investigation (see chapter 4). These requirements are
most important during site characterization because these activities generate
the basic data used in making all subsequent decisions. Establishing, main-
taining, and safeguarding data and records according to the principles dis-
cussed in chapter 4 should be an integral part of the site characterization
process. These procedures include establishing document control with partic-
ular emphasis on enforcement-sensitive materials.
7.4.3 Timing and Scheduling Concerns
The timing and scheduling requirements of site characterization activi-
ties are important. Inputs and outputs of the various characterization
activities are connected to other investigative activities within the overall
remedial investigation/feasibility study timeline. In addition to the overall
need to conduct the remedial investigation quickly and efficiently and
proceed, if necessary, with response actions, such interconnections must be
considered during the site characterization planning process. The time
required for each activity (e.g., data collection, assessment, documentation)
varies according to the level of resolution required and also depends on
external factors such as weather, funding mechanisms, the site priority, and
the status of any legal action. Probable schedules for each site activity are
established during the scoping exercises (chapter 2) and must be re-evaluated
once site characterization begins. If adjustments to the overall remedial
investigation/feasibility study are required, they must be coordinated with
all parties concerned.
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CHAPTER 8
BENCH AND PILOT STUDIES
8.1 INTRODUCTION
Bench and pilot studies may be needed to obtain enough data to select and
implement a remedial action alternative. Justification for these studies is
found in section 300.68 of the National Contingency Plan (NCP). This chapter
addresses ways bench and pilot studies are used in remedial investigations and
presents guidance for:
Determining the need for bench and pilot studies based on the
site/waste' characteristics or technology
Developing a test plan by defining the goals and level of study
needed
Interpreting and applying data developed during the study.
Hazardous waste site remediation programs have challenged technologies
in two principal ways. First, both traditional and emerging technologies from
many different disciplines are being applied on an accelerated and often
overlapping basis. Technologies from the materials and soils science fields,
critical to the containment strategies being used, evolved in relatively clean
environments. As a result, there is little information about technology per-
formance in a contaminated environment (i.e., how a synthetic or clay liner
will behave at a waste site). Second, the treatment technologies developed
for industrial wastes depend on an aqueous environment to facilitate the
transfer and conversion of pollutants and removal of byproducts. In the
typical remedial problem, mass transfer is usually a critical or rate limiting
factor.
Almost without exception, the following conditions will apply in a
hazardous site remediation project:
The physical matrix in which a technology must work is hetero-
geneous; that is, solid, slurry, aqueous, or gaseous environments can
exist all within a given setting.
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The hazardous constituents are (usually) as heterogeneous as the
matrix.
As a result of these circumstances, the transferability of a technology
is limited not only by the discipline or science in which the technology
originated but also from one hazardous waste site to the next. All too often
the limits of technology transferability have been ignored or inadequately
considered, and the penalties have been expensive; liner failures, ineffective
treatment systems, and underground gas migration are frequent examples. Bench
and pilot studies are alternatives to haphazard transfer of technology from
one application to another (with attendant risks of time, dollar, and resource
losses).
8.2 OVERVIEW OF BENCH AND PILOT STUDIES
As shown in Figures 1-2 and 8-1 (RI/FS process diagrams), bench and pilot
studies, if needed to support remedial alternatives development and feasi-
bility analyses, are conducted as part of the remedial investigation task
sequence. However, bench and pilot studies may also be conducted for design
and construction of the selected alternative and are outside the scope of
RI/FS activities. In general, bench-scale studies are appropriate for the
remedial investigation stage, while pilot-scale studies, if required, may be
conducted during the final design. The scope of bench and pilot activities
during the RI is generally limited to treatability and materials testing
activities to help identify, screen, and evaluate FS alternatives.
During the initial tasks of the FS, treatment alternatives are developed
and then screened later in the process. Information from these tasks and the
analysis of information from the site investigation are used to identify
information gaps and to establish the need for bench and pilot studies. An
appropriate experimental plan is then developed and documented in a Statement
of Work (SOW). The results are used in the technical analysis for screening
and analyzing remedial alternatives in the feasibility study as well as
developing the design for the selected alternative.
8.2.1 Difference between Bench and Pilot Studies
Bench studies differ from pilot studies in purpose, size, cost, applica-
tion, and other factors, which are summarized in Table 8-1. Their purpose is
to determine the feasibility of an application over the range of conditions
expected. Bench-scale studies are flexible in that a wide range of variables
can be evaluated in determining the performance capabilities and limitations
of a technology.
Pilot studies may be used in the RI to guide the selection of an
alternative when the choice cannot be made from bench-scale data, or they may
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Figure 8-1. Bench/Pilot Study Logic Diagram
Conceptual Development
Determine Extent of Data Base
Determine Study Needs
(Types, Duration)
Study Planning
Bench Performance Pilot
Data Interpretation
Determine Reliability
Application
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TABLE 8-1. BENCH AND PILOT STUDY PARAMETERS
Parameter
Bench
Pilot
Purpose
oo
Size
Quantity of Waste and
Materials Required
Number of Variables That
Can Be Considered
Time Requirements
Typical Cost Range
Most Frequent Location
Limiting Considerations
Define process kinetics,
material compatibility,
impact of environmental factors,
types and doses of chemicals,
active mechanisms, etc.
Laboratory or bench top
Limited amounts
Many
Days to months
0.5-2% of capital costs
Laboratory
Wall and boundary effects;
volume effects; solids
processing difficult to
simulate
Define design and operation
criteria, materials of
construction, ease of
material handling and
construction, etc.
1-100% of full-scale
Large amounts
Few
Months to years
2-5% of capital costs
On-site
Limited number of variables;
waste volume required; safety,
health, and other risks
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be used outside the RI/FS process to define the design and operating criteria
and specific features of a selected alternative. Pilot studies are also
useful in determining the stability of a process or material in an application
and are aimed at delineating specific design and operating criteria. These
studies are much larger than bench studies in scale, cost, time, and waste
volume required.
8.2.2 Approach
The specific need for bench and pilot studies may be identified during
the RI/FS process or during remedial alternative design. The need is defined
from an assessment of what is known and what is required to establish the
feasibility of applying a technology. The level of development of the tech-
nology should be considered (has the process, technique or material been
studied or used previously, and if so with what results?). The characteris-
tics of the liquid, slurry, or solid wastes and the site itself should be
factored into the decision. The cost savings expected from minimizing the
risk of failure at full scale should also be quantified and considered in the
decision.
The scope of' bench and pilot studies is also an iterative process that
progresses through the development of the FS and selected remedial alternative
design and construction. Bench and pilot studies conducted in the RI may
range from limited treatability (bench) studies to screen general technology
types in the FS, to pilot studies to fully evaluate particular alternatives to
the FS. In the design and construction stages, full scale pilot studies may
also be conducted to determine design and operating standards for the remedial
alternative selected in the RI/FS process. The EPA Remedial Project Manager
must decide the scope and phasing of bench and pilot studies.
A formal process for defining and conducting treatability studies is
presented in the logic diagram of Figure 8-1. The initial step consists of
specifying the concept to the extent possible, using available information on
how the process or material works over the expected range of application
conditions and the factors governing or limiting the application. This
specification should be based on a literature review, vendor contacts, and
past experience. The next step consists of determining the type and specific
goals of the study and the level of effort needed. Once these factors are
determined, a complete test plan or SOW is prepared, which contains all
information needed to perform the study including data management and inter-
pretation guidelines. The tests are then conducted, and the results are
tested for reliability and interpreted. Additional testing may be needed
after the data are interpreted, necessitating reevaluation of the SOW and
additional study, particularly if the application is innovative.
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8.2.3 Example Testing Programs
Table 8-2 illustrates the diversity of activities that may be required to
select and apply a remedial technology. The examples of bench and pilot test
programs illustrate the diverse disciplines and sciences required to define
application conditions for the technologies identified in section 300.70 of
the NCP.
8.2.4 Cost Considerations
When deciding the type and extent of studies, cost can be a limiting
factor. Pilot-scale studies are significantly more expensive than bench-scale
studies, and continuous testing is more expensive than batch testing. As
shown in Table 8-1, bench-scale testing may cost 0.5 to 2 percent of the
capital cost of an alternative, while pilot-scale studies may require 2 to
5 percent of the capital cost. However, if the capital cost is low
(e.g., $100,000 or less), the cost for pilot testing will probably be greater
than 5 percent. Therefore, the cost of an extensive testing effort must be
weighed carefully in relation to the cost of applying the technology.
8.3 BENCH-SCALE STUDIES
Once the need for a bench-scale study is established, an experimental
plan or Statement of Work must be developed. The specific study objectives
and the necessary level of detail should be carefully defined. The flexi-
bility and limitations of bench-scale studies must also be considered in the
preparation of a test plan.
8.3.1 Preplanning Information Needs
Certain information is required before the planning of a bench-scale
study. A waste and site characterization must be completed, preliminary
remedial technologies identified, and then information on the alternatives
obtained. This information is then used to screen the alternatives and to
ascertain if the proposed application is so different from prior applications
that process feasibility, efficiency, or material stability cannot be pre-
dicted. If this is the case, bench or pilot studies or both are required for
the technical analysis portion of the screening procedure.
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TABLE 8-2. EXAMPLES OF BENCH AND PILOT SCALE TESTING PROGRAMS
Remedial Technology
Example Testing Programs
Air Pollution and Gas Migration
Control
1. Capping
2. Dust Control
3. Vapor Collection and Treat-
ment (carbon adsorption)
B. Surface Water Controls
1. Capping
2. Grading
3. Revegetation
4. Diversion and Collection
Leachate and Ground-Water
Controls
1. Containment barriers (slurry
walls, grout curtains, etc.)
2. Ground-water pumping (well
points, suction wells, etc.)
3. Subsurface collection drains
4. Permeable treatment beds
(limestone, activated carbon)
5. Capping
D. Direct Waste Control
1. Incineration
2. Solidification
3. Biological Treatment
Activated sludge
Facultative lagoons
Trickling filters
Chemical Treatment
Oxidation/reduction
Precipitation
Neutralization
Ion exchange resins
Bench: Soil density and bearing
capacity vs. moisture content
curves for proposed capping
materials.
Pilot: In-place soil densities;
determination of gas withdrawal
rates to control releases.
Bench: Column testing of capping
material compatibility with wastes
present.
Pilot: In-place testing of geotex-
tiles for control of erosion in
grassed diversion ditches.
Bench: Determination of basicity and
headloss vs. grain size of lime-
stone materials for a treatment
bed. Determination of chemical
compatibility of a compacted clay
with a leachate stream.
Pilot: In-place testing of a soil
type and grain size specification
and tile drain configuration for a
subsurface collection drain.
Bench: Characterization of chemical
and heat content of hazardous waste
mixes; chemical, physical, and
biological treatability studies to
define rate constants, minimal-
maximal loading rates and retention
times, optimal pH and temperature,
sludge generation rates and charac-
teristics, and oxygen transfer
characteristics; chemical type and
dose rates; solids flux rate vs.
solids concentration in sludge
(continued)
8-7
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TABLE 8-2. (continued)
Remedial Technology
Example Testing Programs
E.
Physical Treatment
Carbon adsorption
Flocculation
Sedimentation
Membrane processes
Dissolved air flotation
Air stripping
Wet air oxidation
In-Situ Treatment
Microbial degradation
Neutralization/detoxi-
fication
Precipitation
Nitrification
Land Disposal (landfill, land
application)
Soil and Sediment Containment and
Removal
1. Excavation
2. Dredging
3. Grading
4. Capping
5. Revegetation
thickening systems; air/volume
ratios for stripping towers.
Pilot: Test burns to determine
retention time, combustion chamber
and after-burner temperatures, and
and fuel makeup requirements for
the incineration of a waste.
Endurance/performance tests on mem-
branes in reverse osmosis units for
ground-water treatment. In-situ
microbial degradation testing of
nutrient dose and aeration rates to
support in-place degradation of
contaminants in a plume from an
underground leak. Evaluation of
in-place mixing procedures for the
solidification of a sludge in a
lagoon.
Bench: Determination of soil adsorp-
tive (cation exchange capacity)
properties and chemical composi-
tion.
Pilot: Small-scale dredging to
assess sediment resuspension or
production rates.
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8.3.2 Specification of Objectives and Level of Detail
The objectives of a bench-scale project must be clearly understood from
the beginning. Once the objectives of the study are established, the results
of the work should be anticipated in selecting the level of study detail.
Describing the expected results is essential to defining the variables to be
investigated and the range of values for these variables.
Because of the relatively small scale and cost of bench-scale testing,
many variables can be evaluated. However, to minimize the testing and to
ensure that the work is relevant, the number of variables and range of values
tested should be limited so that only those conditions that are anticipated in
a full-scale application are evaluated. The impact of each individual vari-
able on technology performance should be evaluated carefully as the final
basis for deciding what variables are tested.
8.3.3 Limitations
Bench-scale investigations are flexible, allowing many variables to be
evaluated, but certain parameters cannot be tested at the bench-scale level.
For example, laboratory equipment simply cannot be configured to resemble the
full-scale process. Although certain chemical, biological, and physical
reactions may not depend directly on the size and configuration of the
reactor, the rates do depend on considerations such as mass, heat, and/or
energy transfer, which in turn are affected by the size and configuration.
The shortened time scale of bench studies may also be a limitation because the
performance capabilities of many technologies cannot be demonstrated without
long exposure periods. As a result of these limitations, there are certain
technologies for which only pilot-scale testing can be used to develop the
information needed to select and define an alternative.
8.3.4 Statement of Work
The experimental plan is documented in a SOW. The SOW should include a
clearly defined set of objectives, a detailed work plan by task, a schedule of
completion, and a labor-cost estimate. The SOW should also describe or refer-
ence all experimental and analytical procedures required, a data management
plan, a QA/QC plan, and a health and safety plan.
8.4 PILOT-SCALE STUDIES
Pilot-scale studies generally specify design and operating criteria for
the full-scale application after the remedial action alternative has been
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selected. Although pilot studies are of necessity more targeted than bench-
scale studies, the same general considerations are included in the test plan.
8.4.1 Preplanning Information Needs
A pilot study usually follows a bench study. If a bench study was not
required, the information needed before pilot study planning will include a
complete waste and site characterization, a literature review, and an analysis
of experience with the technology. However, more detailed information about
the process or operation must also be available because pilot work addresses
such issues as selection of materials control strategies, installation proce-
dures, and equipment configurations attendant to a final design. Pilot-scale
testing is done under operating conditions approximating those expected in the
application itself and in a module similar to the full-scale installation.
8.4.2 Specification of Objectives and Level of Detail
The objectives for pilot studies must also be defined rigorously to
ensure a successful outcome. Pilot studies are conducted to select an alter-
native in the RI/FS process or to support design decisions in the design and
construction stages or both. Therefore, the variables evaluated should be
carefully justified so that each key question is examined and so that
reproducible and reliable results are obtained. The variables to be
investigated should have a direct impact on full-scale design and operation.
Scale-up problems should be recognized before the study begins so that
procedures can be incorporated into the test plan to resolve any questions.
8.4.3 Limitations
The flexibility of pilot-scale studies is minimal. Because full-scale
operating conditions are to be simulated, pilot systems require the use of
actual construction materials and operation over relatively long time periods,
often at high cost. Only a few variables can be examined. Conditions for a
pilot test should be as close to full-scale conditions as possible, partic-
ularly with respect to variation in waste composition. Any deviance from
normal conditions must be recorded and considered during data interpretation.
The sampling schedule must be designed to map the critical parameters char-
acterizing the technology. In some cases, the period of rapidly changing
performance is of more interest than is the period of stable performance. For
these reasons, extrapolating data from existing and bench-scale studies may
prove more cost-effective than conducting pilot studies. This option should
be considered on a case-by-case basis.
Several areas of inquiry can be examined only at the pilot scale. The
degree of chemical mixing is especially difficult to evaluate at the bench
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level, as are methods for the separation, thickening, and dewatering of
solids. Pilot investigation is essentially the only means to approximate such
methods, short of constructing the prototype. Factors such as hydrodynamics,
heat and gas transfer, weather effects, corrosion, and erosion effects, etc.,
are also usually best tested by pilot studies. Furthermore, skilled judgment
is needed to predict the performance of pilot-scale technology from bench-
scale data, and prototype performance from pilot data.
8.4.4 Statement of Work
The experimental plan for pilot studies is documented in a Statement of
Work (SOW) submitted to the contracting official that should contain all the
elements mentioned in the bench-scale study SOW (section 8.3.4). If both
bench and pilot studies are conducted, a single SOW may be prepared for both
studies and updated after benchwork is completed. However, in many instances
it may not be possible to prepare a SOW for pilot studies until the results of
the bench studies are available.
8.5 DATA ANALYSIS
The steps in processing bench and pilot study data include data manage-
ment, data analysis/interpretation, reliability determination, and application
of the results. The type and detail of data obtained depend both on the pur-
pose of the study and the type of technology. Different types of data will be
generated by testing for process design than by testing for material handling
or stability. Process testing at the bench scale is done by tracking effluent
characteristics as the parameters are changed in order to determine an optimum
operating condition. Material testing involves determining the characteris-
tics of a material after varying exposure periods to varying environments.
8.5.1 Data Management
These data requirements are addressed in section 4.3.5.
8.5.2 Data Analysis and Interpretation
Data analysis and interpretation involve the comparison of anticipated
results with actual results to ensure the validity of the assumptions made in
planning the study. Major variations between anticipated and actual results
may indicate that the objectives of the study cannot be met. In such cases,
the SOW must be modified and additional studies performed. However, if the
comparison of results shows that the study was properly planned (adequate to
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meet the objectives), graphical and statistical analysis may be used to aid in
data interpretation.
Graphical plots of raw experimental results usually illustrate a random-
ness in the data base that necessitates a statistical analysis in order to
focus on the results and to document their validity (Blank, 1980). A statis-
tical analysis can be performed on sample repetitions to determine the sig-
nificance of the data. However, cost and time limitations often permit only
two repetitions to be performed with provisions to conduct a third if the
results from the first two tests differ. Sample repetitions of only two or
three are difficult to analyze for statistical significance, as a small group
is statistically defined as less than 20 samples and is subject to error at
even this size.
Fortunately, the results of many types of bench and pilot studies can be
graphed to display such trends as isotherms, titration curves, break-through
curves, and other correlations dependent on time and concentration. In trend
analysis, a rigorous repetitional statistical analysis may not be necessary
as random results are more apparent because they stand out from the trend.
Correlation analyses are appropriate for determining the consistency of the
results and useful in developing kinetic, transfer, and other coefficients
from linearized transforms of process or technology performance curves.
8.5.3 Reliability
Analytical procedures can produce major errors if a procedure or instru-
ment is used incorrectly or is not in working order. Inaccuracies also result
from the experimental procedure. Additional inaccuracies occur in the
measurement of low concentrations because the precision, accuracy, and detec-
tion capabilities of the analytical tests are limited. The purpose of the
QA/QC plan developed before beginning the testing procedure is to eliminate
most if not all of these inaccuracies and ensure reliable results. The
ability to justify the performance reliability of a system depends directly on
the reliability of the results.
8.5.4 Application of Results
The quantitative data obtained from bench and pilot studies must be
converted into useful information. To make the most of the results, the
process under consideration must be well understood. This is also true for
qualitative data, which are often used in making judgments.
Results from bench and pilot studies can be used in determining a number
of criteria. For example, although the primary goal of the studies is to
determine technical performance, data can be used to help estimate the cost of
the full-scale process. Additional factors such as the complexity of
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operation, safety, reliability, and projected maintenance requirements can be
specified through treatability studies.
The study findings must be evaluated for application to a full-scale
technology. The optimum scale-up procedure would be a step-by-step approach,
increasing the size of the technology in gradual increments. However, this
procedure is much too costly and time-consuming to be used except in the most
extreme circumstances. Normally, variables are obtained from the studies,
then scaled up using similitude rules and/or mathematical models. Rules of
similitude include dynamic, kinematic, and chemical similitude. The studies
may also be conducted at full scale but demonstrated on a portion of the site
until reliability and operability are proven.
All results, regardless of their use, will ultimately be taken into
account in the RI/FS process. Even negative results must be considered so
that the conditions producing the negative results are not duplicated at the
full scale. Therefore, complete documentation of the study from the pre-
planning stage to the data reduction stage, including QA/QC and a statistical
analysis, is essential to convey all implications of the bench and pilot
investigations leading to design reconmendations.
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CHAPTER 9
REMEDIAL INVESTIGATION REPORT FORMAT
9.1 INTRODUCTION
This chapter presents and discusses the recommended format for reports on
remedial investigations conducted under CERCLA. This format has been designed
to:
Ensure that all major issues are adequately addressed
Produce comparable presentations from different sites
Promote high quality remedial investigation reports
Ensure adequate documentation and complete data for use in
dec is ionmaking.
The recommended format will consolidate data from several investigation
activities into a single presentation and serve as a checklist of activities
conducted and data obtained.
During the remedial investigation process, two reports may be produced
depending on site actions anticipated by the Agency:
Draft and final Remedial Investigation Report (always prepared)
Endangerment Assessment Report (as needed for enforcement actions).
The draff. Remedial Investigation Report is produced at the end of the
remedial investigation process. This report characterizes the site and
summarizes the data collected and conclusions drawn from all investigative
areas and levels. If appropriate, this report may be combined with the
associated Feasibility Study Report to provide one site report containing both
support data and decisionmaking documentation.
The draft, following review, approval, and revision, becomes the final
report. For enforcement-lead actions, the Office of Waste Program Enforcement
or an attorney will review the draft report.
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An Endangerment Assessment Report is produced only if needed for enforce-
ment cases. This report may be prepared at any level of the RI or the FS and
includes contamination, public health, and environmental assessments.
This chapter focuses on the Remedial Investigation Report and discusses
what should be included in this report and why.
9.2 FINAL REPORT FORMAT
Table 9-1 presents the recommended Remedial Investigation Report format
with the numbering system as it would appear in the report. As described
in the preceding section, the report will be prepared for every remedial
investigation and will present only the data generated in the investigation to
support analysis of remedial alternatives in the feasibility study. As such,
it is not intended as a compendium of site information; therefore, all of the
sections identified in Table 9-1 may not be relevant to a given investigation.
The report contents should be adjusted based on the focus of the data collec-
tion and the analyses conducted.
Contaminant levels in the environment will be reported on a mediaspecific
basis. For example, contaminant levels in sediments will be presented in the
surface-water investigation section, while contaminant concentrations in
ground water will be presented in the hydrogeologic investigation section.
For enforcement-lead investigations, the Remedial Investigation Report
format may be different. In such instances, close coordination with regional
enforcement personnel is necessary to determine the appropriate format and
content for the report.
The remaining sections explain each of the sections that may appear in
the Remedial Investigation Report.
9.2.1 Executive Summary
The Executive Summary provides a brief overview of the remedial inves-
tigation and the data collected by the investigation. Key information about
the site and major investigation findings are summarized so the reader is
presented with an instant picture of the site and its problems.
The five major areas addressed in the Executive Summary are:
Purpose of the remedial investigation
Site description, background, and problems
Direction and activities of each investigation phase
Major findings
Data problems and unresolved data needs.
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TABLE 9-1. REMEDIAL INVESTIGATION REPORT FORMAT
EXECUTIVE SUMMARY
1.0 INTRODUCTION
1.1 SITE BACKGROUND INFORMATION
1.2 NATURE AND EXTENT OF PROBLEM(S)
1.3 REMEDIAL INVESTIGATION SUMMARY
1.4 OVERVIEW OF REPORT
2.0 SITE FEATURES INVESTIGATION
2.1 DEMOGRAPHY
2.2 LAND USE
2.3 NATURAL RESOURCES
2.4 CLIMATOLOGY
3.0 HAZARDOUS SUBSTANCES INVESTIGATION
3.1 WASTE TYPES
3.2 WASTE COMPONENT CHARACTERISTICS AND BEHAVIOR
4.0 HYDROGEOLOGIC INVESTIGATION
4.1 SOILS
4.2 GEOLOGY
4.3 GROUND WATER
5.0 SURFACE-WATER INVESTIGATION
5.1 SURFACE WATER
5.2 SEDIMENTS
5.3 FLOOD POTENTIAL
5.4 DRAINAGE
6.0 AIR INVESTIGATION
(continued)
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TABLE 9-1. (continued)
7.0 BIOTA INVESTIGATION
7.1 FLORA
7.2 FAUNA
8.0 BENCH AND PILOT TESTS
9.0 PUBLIC HEALTH AND ENVIRONMENTAL CONCERNS
9.1 POTENTIAL RECEPTORS
9.2 PUBLIC HEALTH IMPACTS
9.3 ENVIRONMENTAL IMPACTS
REFERENCES
APPENDICES
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Specific elements addressed under each of the major areas briefly convey the
important characteristics and findings. Tables and figures are used where
possible to summarize information clearly and concisely. The suggested length
of the Executive Summary is five pages with, at most, one or two tables or
figures.
9.2.2 Introduction
As the introduction to the Remedial Investigation Report, chapter 1
briefly characterizes the site, which establishes a background for the data
collection and analysis activities. The Introduction addresses four major
areas: (1) site background information; (2) the nature and extent of contam-
ination problem(s) at the site; (3) investigation objectives and activities;
and (4) an overview of the report contents. These discussions review the key
features, conditions, and parameters of the site that are essential to
analysis of site problems and selection of remedial action alternatives.
9.2.2.1 Site Background Information
Included in the site background discussion are brief descriptions of past
and existing activities at the site, particularly the current physical,
biological, and socioeconomic factors. Specific elements that may be
addressed in this section of the introduction include:
Facility location, size, configuration, existing structures
Timeframe of waste-related activities
Historical description of:
- facility type
- activities and operations
- types of wastes
- condition of wastes (originally as well as at present)
- incidents (fire, explosion, ground-water contamination, etc.)
- site investigations, sampling, regulatory violations, response
actions, and enforcement activities
- ownership
Physiography
Other factors including
- community perception
- planned use of site
- conflicting or missing information
- site map showing location, size, water supplies, sensitive
environmental areas, and nearby populations.
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All discussions should pertain to the use of the facility for management of
hazardous wastes.
9.2.2.2 Nature and Extent of the Problem
The discussion of the nature and extent of the problem(s) at the site
should concentrate on the materials present and current contamination prob-
lems. This defines a framework for determining the remedial action objectives
and for selecting appropriate remedial action alternatives.
This "problems" section of the introduction focuses on existing and
potential on-site and off-site contamination problems and effects. It should
include the following:
Type, physical state, and quantity of wastes or hazardous substances
on-site
Special waste considerations (explosive, radioactive, etc.)
Present condition of materials and structures (including drums, tanks,
landfills, etc.)
Changes in site (e.g., filling in a waste pit or lagoon, applying
cover material to buried or semi-buried drums)
Effects of contaminants from the site (drawing on monitoring and
geotechnical studies):
- types of contaminant release (leachate, runoff, etc.)
- affected media, movement of contaminants, direction of movement
- resources, population, or environments threatened or harmed by
contaminant movement
- human exposure
Near-future impacts of site conditions and contaminant migration
(subsurface, surface, and atmospheric)
Actions previously taken to mitigate problems and the result(s) of
these actions.
These discussions should describe the threat or potential threat to public
health, welfare, or the environment from the site.
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9.2.2.3 Investigation Summary
The investigation summary identifies the objective(s) of each level and
activity of the remedial investigation. This section also provides an
overview of the investigations conducted.
9.2.2.4 Overview of Report
This section presents an overview of the remainder of the report, briefly
describing the contents of each chapter.
9.2.3 Site Features Investigation
Chapter 2 presents the results of the investigation of the features of
the site. At least four sections are included:
Demography
Land use
Natural resources
Climatology.
Other site feature data may be presented in additional sections as necessary.
Only those site features investigated should be described.
Each section should describe the key parameters investigated and analyzed
for the site and include information pertinent to technical, public health,
and environmental analyses conducted in the feasibility study, particularly
those elements affecting the applicability of the remedial alternatives being
considered. For example, the investigation may have identified the proximity
of waste sources to public wells or National/State forest lands; this
information would be presented as part of the natural resources section.
9.2.4 Hazardous Substances Investigation
Chapter 3 presents data from investigations of the wastes found on-site.
This chapter is divided into two parts:
Waste types
Waste component characteristics and behavior.
9-7
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The first subsection addresses waste quantities, location, components,
containment, and composition. It covers all the materials at the site that
are sources of environmental contamination or public health threat, or may be
disturbed, removed, or treated, or may be "in the way" in a remedial action.
This information will not only aid in selecting a remedial alternative but may
also affect the design and planning of remedial actions (e.g., health and
safety considerations).
The second subsection summarizes the results of the investigation of
waste component characteristics, including testing results for waste con-
stituent toxicity, bioaccumulation, metabolism, environmental transformation,
or other characteristics. These data are used in the public health and
environmental assessments and analyses conducted in the RI/FS.
9.2.5 Hydrogeologic Investigation
Chapter 4 presents the results of the hydrogeologic investigation. This
chapter includes at least three major sections:
Soils
Geology
Ground water.
Additional sections may be included if needed to present hydrogeologic and
contamination problems at the site.
The soil analyses include all soils data and descriptions that charac-
terize the site and affect decisions on remedial alternatives. Data to be
included are soil types, depths, content and characteristics (e.g., clay
content), and contamination levels.
The geology section presents the geologic features and characteristics
identified in the investigation. The focus is on site geology and subsurface
features as well as contaminant levels that may be useful in characterizing
site problems and potential impacts and in choosing remedial solutions.
The section on ground water addresses direction of ground-water flow,
dimensions of contaminant plume, plume migration, and aquifer systems under-
lying the site. This section also identifies contaminant levels.
9-8
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9.2.6 Surface-Water Investigation
The focus in chapter 5 is on surface-water investigations and analyses.
At least four major subsections are included:
Surface-water bodies
Sediments
Flood potential
Drainage.
Additional subsections may be added to address the surface-water hydrologic
and contamination features of the site.
For the investigations conducted, each subsection presents the results of
data analysis and supporting raw data. For example, the section on surface-
water bodies addresses the extent of contamination (spread from site), con-
taminant migration, and surface-water flow. The sediments section describes
concentration variations of contaminants with sediment depth, sediment
particulate size, and the dimensions of contaminant location in sediments.
Similarly, the flood potential subsection focuses on the location of the site
in a floodplain, and the drainage subsection addresses surface-water and
precipitation drainage across the site. Descriptions of all these site
features provide data for environmental, public health, and technological
assessments in the feasibility study.
9.2.7 Air Investigation
Chapter 6 presents the results of the air investigation, including data
on air concentrations of contaminants, contaminant plume dimensions and move-
ment, and airborne particulates. The results of other air investigations and
analyses conducted to define site problems and select and design a remedial
alternative are also presented here.
9.2.8 Biota Investigation
Chapter 7 focuses on the contaminant levels found in site flora and
fauna. Resident endangered species are also identified. These data contrib-
ute to environmental analyses and assessments of present site conditions and
to the selection of remedial alternatives in the feasibility study.
9-9
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9.2.9 Bench and Pilot Studies
Chapter 8 identifies and presents the results of bench and pilot tests
conducted in the remedial investigation. These tests may be conducted to
provide data for remedial alternative selection or design. Each different
test series should be treated independently (i.e., soils studies, treatment
efficiencies, and compatibility tests would be presented separately). For
each test series, testing objectives, results, and analyses should be
presented, with conclusions clearly stated.
9.2.10 Public Health and Environmental Concerns
Chapter 9 presents a discussion of potential public health and
environmental impacts. This chapter consists of three subsections:
Potential receptors
Public health
Environmental impacts.
The potential receptors subsection identifies human and other receptors
(flora, fauna), including endangered species, that are or may be affected by
site contamination. The subsection on public health summarizes public health
concerns resulting from site contaminants and contaminated areas or resources.
The environmental impacts subsection reviews environmental damage from the
site. Together, this information will contribute to the determination of
remedial action objectives for the site.
9.2.11 References
The reference section contains complete bibliographic citations for
information sources used and cited in the main text of the report. References
for information sources cited in an appendix should appear in that appendix.
9.2.12 Appendices
The text of the Remedial Investigation Report summarizes the site
information collected and analyzed in the investigation process. To focus
this summary so that it presents the critical site characteristics and major
analysis features clearly and logically, detailed discussions, diagrams,
sampling data, maps, computer modeling results, and other supporting data and
analyses may best be presented as appendices to the main report. As many
appendices as needed may be added.
9-10
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Suspect Carcinogens" (Proposed Guidance). Environmental Criteria and
Assessment Office, Cincinnati, Ohio.
U.S. EPA, 1984i. "Interim Guidelines for Mutagenicity Risk Assessment"
(Proposed Guidance). Environmental Criteria and Assessment Office,
Cincinnati, Ohio.
U.S. EPA, 1984J. "Guidance for the Health Assessment of Suspect Developmental
Toxicants" (Proposed Guidance). Environmental Criteria and Assessment
Office, Cincinnati, Ohio.
U.S. EPA, 1984k. Characterization of Hazardous Waste Sites - A Methods
Manual; Volume III. Available Laboratory Analytical Methods.
EPA-600/4-84-038. NTS No. PB84-191048. U.S. EPA, Las Vegas, Nevada.
U.S. EPA, 1985a. "Guidance for Feasibility Studies Under CERCLA." U.S. EPA,
Office of Research and Development, Cincinnati, Ohio, and Office of
Emergency and Remedial Response, Washington, D.C.
U.S. EPA, 1985b. Health Effects Assessments. Draft. (In press.) U.S. EPA,
Office of Toxic Substances, Washington, D.C.
van Genuchten, M.T., and W.J. Alves, 1982. Analytical Solutions of the One
Dimensional Convective-Dispersive Solute Transport Equation. Technical
Bulletin 1661. U.S.D.A.
Verschueren, K., 1977. Handbook of Environmental Data on Organic Chemicals.
Van Nostrand/Reinhold, New York.
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Walton, W.C., 1983a. "Handbook of Analytical Groundwater Models." Short
Course Practical Analysis of Well Hydraulics and Aquifer Pollution, April
11-15, International Groundwater Modeling Center, Holcomb Research
Institute, Butler University, Indianapolis, Indiana.
Walton, W.C., 1983b. "Handbook of Analytical Groundwater Model Codes for
Radio Shack TRS-80 Pocket Computer and Texas Instruments TI-59 Hand-Held
Programmable Calculator." Short Course Practical Analysis of Well
Hydraulics and Aquifer Pollution, April 11-15, International Groundwater
Modeling Center, Holcomb Research Institute, Butler University,
Indianapolis, Indiana.
Weast, W.C., 1971. Handbook of Chemistry and Physics. The Chemical Rubber
Co. Cleveland, Ohio.
Weiss, G. (ed.), 1980. Hazardous Chemicals Data Book. Noyes Data
Corporation, Park Ridge, New Jersey.
Windholz, M. (ed.), 1976. The Merck Index. An Encyclopedia of Chemicals and
Drugs. Merck and Co., Inc., Rahway, New Jersey.
11
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APPENDIX A
MODEL STATEMENT OF WORK
FOR CONDUCTING REMEDIAL INVESTIGATIONS
PURPOSE
The purpose of this remedial investigation is to
determine the nature and extent of the problem at the site
and to gather all necessary data to support the
feasibility study. The Engineer will furnish all
personnel, materials, and services necessary for, or
incidental to, performing the remedial investigation at
[specific site], an uncontrolled hazardous waste site.
SCOPE
The remedial investigation consists of seven tasks1:
Task 1 - Description of Current Situation
Task 2 - Plans and Management
Task 3 - Site Investigation
Task 4 - Site Investigation Analysis
Task 5 - Laboratory and Bench-Scale Studies
Task 6 - Reports
Task 7 - Community Relations Support
TASK 1 - DESCRIPTION OF CURRENT SITUATION
Describe the background information pertinent to the
site and its problems and outline the purpose for remedial
investigation at the site. The data gathered during any
previous investigations or inspections and other relevant
data should be used.
This task may be conducted concurrently with Task 2,
development of the work plan.
a. Site Background
Prepare a summary of the Regional location,
pertinent area boundary features, and general
site physiography, hydrology, and geology.
The Remedial Investigation guidance should be
consulted for additional information on the tasks
listed below.
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Define the total area of the site and the general
nature of the problem, including pertinent
history relative to the use of the site for
hazardous waste disposal.
b. Nature and Extent of Problem
Prepare a summary of the actual and potential
on-site and off-site health and environmental
effects. This may include, but is not limited
to, the types, physical states, and amounts of
the hazardous substances; the existence and
conditions of drums, landfills, and lagoons
[substitute site-specific features if different];
affected media and pathways of exposure;
contaminated releases such as leachate or runoff;
and any human exposure. Emphasis should be
placed on describing the threat or potential
threat to public health and the environment.
c. History of Response Actions
Prepare a summary of any previous response
actions conducted by either local, State,
Federal, or private parties, including the site
inspection and other technical reports, and their
results. This summary should address any
enforcement activities undertaken to identify
responsible parties, compel private cleanup, and
recover costs. A list of reference documents and
their location shall be included. The scope of
the remedial investigation should be developed to
address the problems and questions that have
resulted from previous work at the site.
d. Site Visit
Conduct an initial site visit to become familiar
with site topography, access routes, and
proximity of receptors to possible contamination
and collect data for preparation of the site
safety plan. The visit should be used to verify
the site information developed in this Task.
e. Define Boundary Conditions
Establish site boundary conditions to limit the
areas of site investigations. The boundary
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conditions should be set so that subsequent
investigations will cover the contaminated media
in sufficient detail to support following
activities (e.g., the feasibility study). The
boundary conditions may also be used to identify
boundaries for site access control and site
security. [If not in existence, installation of
a fence or other security measures should be
considered.]
f. Site Map
Prepare a site map showing all wetlands,
floodplains, water features, drainage patterns,
tanks, buildings, utilities, paved areas,
easements, rights-of-way, and other features.
The site map and all topographical surveys should
be of sufficient detail and accuracy to locate
and report all existing and future work performed
at the site. [Permanent baseline monuments,
bench marks, and reference grid tied into any
existing reference system (i.e., State or USGS)
should be considered as an option.]
g. Site Office
If agreed to by EPA and the State, establish a
temporary site office to support site work.
h. Contractor Procurement
[When SOW is used for Federal-lead, change to
"Subcontractor Procurement" and modify as
required.] Prepare contractor procurement
documents and award subagreement to secure the
services necessary to conduct the remedial
investigation and feasibility study.
TASK 2 - PLANS AND MANAGEMENT
Prepare all necessary plans for the remedial
investigation. The work plan should include a detailed
discussion of the technical approach, budget, personnel
requirements, and schedules, as well as the following:
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a. Sampling Plan
Prepare a Sampling Plan to address all field
activities to obtain additional site data. The
plan will contain a statement of sampling
objectives; specification of equipment, analyses
of interest, sample types, and sample locations
and frequency; and schedule. Consider use of
field screening techniques to screen out samples
that do not require off-site laboratory
analysis. The plan will also include a quality
assurance and quality control plan with
documentation requirements and estimates of costs
and labor. The plan must address all levels of
the investigation as well as all types of
investigations conducted (e.g., waste
characterization, hydrogeologic, soils and
sediments, air and surface water). The plan will
identify potential remedial technologies and
associated data that may be needed to evaluate
alternatives for the feasibility study.
b. Health and Safety Plan
Prepare a Health and Safety Plan to address
hazards that the investigation activities may
present to the investigation team and to the
surrounding community. The plan should address
all applicable regulatory requirements and detail
personnel responsibilities, protective equipment,
procedures and protocols, decontamination,
training, and medical surveillance. The plan
should identify problems or hazards that may be
encountered and their solutions. Procedures for
protecting third parties, such as visitors or the
surrounding community, will also be provided.
c. Data Management Plan
Develop and initiate a Data Management Plan to
document and track investigation data and
results. This plan should identify and set up
laboratory and data documentation materials and
procedures, project file requirements, and
project-related progress and financial reporting
procedures and documents.
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d. Community Relations Plan
Prepare a plan, based on on-site discussions, for
the dissemination of information to the public
regarding investigation activities and results.
Opportunities for comment and input by citizen,
community and other groups must also be
identified and incorporated into the plan.
Staffing and budget requirements for
implementation also must be included. [Not
required if Community Relations Plan has been
prepared.]
TASK 3 - SITE INVESTIGATION
Conduct only those investigations necessary to
characterize the site and its actual or potential hazard
to public health and the environment. The investigations
should result in data of adequate technical content to
support the development and evaluation of remedial
alternatives during the feasibility study. Investigation
activities will focus on problem definition and data to
support the screening of remedial technologies,
alternative development and screening, and detailed
evaluation of alternatives.
The site investigation activities will follow the
plans set forth in Task 2. All sample analyses will be
conducted at laboratories following EPA protocols or their
equivalents-. Strict chain-of-custody procedures will be
followed and all samples will be located on the site map
[and grid system] established under Tasks 1 and 2.
a. Waste Characteriziation
Conduct a sampling and analysis program to
characterize all materials of interest at the
site. These materials should include wastes
stored above or below ground in tanks, drums,
lagoons, piles, or other structures.
b. Hydrogeologic Investigation
[Generally limited to investigations for off-site
migration.] Conduct a program to determine the
presence and potential extent of ground water
contamination [and to evaluate the suitability of
the site for on-site waste containment].
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[Identify specific aquifer to be studied.]
Efforts should begin with a survey of previous
hydrogeologic studies and other existing data.
The survey should address the degree of hazard,
the mobility of pollutants considered (from Waste
Characterization), the soils' attenuation
capacity and mechanisms, discharge/recharge
areas, regional flow directions and quality, and
effects of any pumping alternatives that are
developed, if applicable. Such information may
be available from the USGS, the Soil Conservation
Service, and local well drillers. An
accompanying sampling program should determine
the horizontal and vertical distribution of
contaminants and predict the long-term
disposition of contaminants.
c. Soils and Sediments Inve-stigation
Conduct a program to determine the location and
extent of contamination of surface and subsurface
soils and sediments [identify specific areas to
be studied]. This process may overlap with
certain aspects of the hydrogeologic study (e.g.,
characteristics of soil strata are relevant to
both the transport of contaminants by ground
water and to the location of contaminants in the
soil; cores from ground water monitoring wells
may serve as soil samples). A survey of existing
data on soils and sediments may be useful. The
horizontal and vertical extent of contaminated
soils and sediments should be determined.
Information on local background levels, degree of
hazard, location of samples, techniques utilized,
and methods of analysis should be included. The
investigation should identify the locations and
probable quantities of subsurface wastes, such as
buried drums, through the use of appropriate
geophysical methods.
d. Surface Water Investigation
Conduct a program to determine the extent of
contamination of [identify specific water
bodies]. This process may overlap with the soils
and sediments investigation; data from stream or
lake sediments sampled may be relevant to surface
water quality. A survey of existing data on
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surface water flow quantity and quality may be a
useful first step, particularly information on
local background levels, location and frequency
of samples, sampling techniques, and method of
analysis.
e. Air Investigation
Conduct a program to determine the extent of
atmospheric contamination. The program should
address the tendency of substances (identified
through Waste Characterization) to enter the
atmosphere, local wind patterns, and the degree
of hazard.
[Note: Other categories of investigations may be
needed for specialized site problems. These could include
biological and radiological investigations.]
TASK 4 - SITE INVESTIGATION ANALYSIS
Prepare a thorough analysis and summary of all site
investigations and their results. The objective of this
task will be to ensure that the investigation data are
sufficient in quality (e.g., QA/QC procedures have been
followed) and quantity to support the feasibility study.
The results and data from all site investigations must
be organized and presented logically so that the
relationships between site investigations for each medium
are apparent. Analyze all site investigation data and
develop a summary of the type and extent of contamination
at the site. The summary should describe the quantities
and concentrations of specific chemicals at the site and
ambient levels surrounding the site. Describe the
number, locations, and types of nearby populations and
activities and pathways that may result in an actual or
potential threat to public health, welfare, or the
environment. [Specify whether a contamination, public
health, and/or environmental assessment is to be
conducted.]
TASK 5 - LABORATORY AND BENCH-SCALE STUDIES
[Note: The following applies when additional studies
are necessary to fully evaluate remedial alternatives.
The paragraphs may be modified to meet specific project
conditions.]
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Conduct laboratory and/or bench-scale studies to
determine the applicability of remedial technologies to
site conditions and problems. Analyze the technologies,
based on literature review, vendor contacts, and past
experience to determine the testing requirements.
Develop a testing plan identifying the type(s) and
goal(s) of the study(ies), the level of effort needed, and
data management and interpretation guidelines for
submission to [specify EPA and State recipients] for
review and approval.
Upon completion of the testing, evaluate the testing
results to assess the technologies with respect to the
site-specific questions identified in the test plan.
Scale up those technologies selected based on testing
results.
Prepare a report summarizing the testing program and
its results, both positive and negative.
TASK 6 - REPORTS
a. Progress Reporting Requirements
[Note: The following paragraph applies when the
SOW is being used in a contract between the State
and an Engineer. Typical requirements are
described but may be modified based on the size
and complexity of the specific project. When the
SOW is used in a Cooperative Agreement, this
section should be replaced with reporting
requirements consistent with 40 CFR Part 30 and
the guidance "State Participation in the
Superfund Remedial Program," February 1984.]
Monthly reports shall be prepared by the Engineer
to describe the technical and financial progress
of the project. These reports should discuss the
following items:
1. Identification of site and activity
2. Status of worK at the site and progress
to date
3. Percentage of completion and schedule
status
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4. Difficulties encountered during the
reporting period
5. Actions being taken to rectify problems
6. Activities planned for the next month
7. Changes in personnel
8. Actual expenditures (including fee) and
direct labor hours expended for this
period
9. Cumulative expenditures (including fee)
and cumulative direct labor hours
10. Projection of expenditures for
completing the project, including an
explanation of any significant
variation from the forecasted target
11. A graphic representation of proposed
versus actual expenditures (plus fee)
and comparison of actual versus target
direct labor hours. A projection to
completion will be made for both.
The monthly progress report will list target and
actual completion dates for each element of
activity, including project completion, and will
provide an explanation of any deviation from the
milestones in the work plan.
b. Final Report
Prepare a final report covering the remedial
investigation and submit [specify number and
distribution] copies to [specify EPA and State
recipients, as appropriate]. The report shall
include the results of Tasks 1 through 5, and
should include additional information in
appendices. The report shall be structured to
enable the reader to cross-reference with ease.
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TASK 7 - COMMUNITY RELATIONS SUPPORT
[Note: The following paragraph applies when community
relations support is conducted under the work covered in
this SOW (e.g., under a Cooperative Agreement). The
paragraph may be modified to meet specific site or project
conditions.]
The Engineer may be required to furnish the personnel,
services, materials, and equipment to undertake a
community relations program. Although this may be a
limited program, community relations must be integrated
closely with all remedial response activities. The
objectives of this effort are to achieve community
understanding of the actions taken and to obtain community
input and support prior to selection of the remedial
alternative(s).
Community relations support should include, but may
not be limited to, the following:
Revisions or additions to community relations
plans, including definition of community
relations program needs for each remedial activity
Analysis of community attitudes toward the
proposed actions
Preparation and dissemination of news releases,
fact sheets, slide shows, exhibits, and other
audio-visual materials designed to apprise the
community of current or proposed actions
Establishment of a community information center
Arrangements of briefings, press conferences,
workshops, and public and other informal meetings
Assessment of the successes and failures of the
community relations program
Preparation of reports and participation in
public meetings, project review meetings, and
other meetings as necessary to the normal
progress of the work
Solicitation, selection, and approval of
subcontractors, if needed.
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All community relations support must be consistent with
Superfund community relations policy, as stated in the
"Guidance for Implementing the Superfund Program" and
Community Relations in Superfund -- A Handbook.
* US GOVERNMENT PRINTING OFFICE 1985 - 559-111/10856 A~ll
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