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

-------
                                          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

-------
                                   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

-------
                                  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

-------
                                   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

-------
                                   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

-------
                             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

-------
                         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

-------
                             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

-------
                                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

-------
                                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

-------
                              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

-------

-------
                                   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

-------
                 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

-------
      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

-------
        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

-------
     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

-------
                                                                     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

-------
                                   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.


                                     2-1

-------
     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.
                                     2-2

-------
                 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.
                                         2-3

-------
                  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
                                     2-4

-------
          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)
                                     2-5

-------
     •  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.
                                     2-6

-------
     (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.

                                     2-7

-------
 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.
                                     2-8

-------
     •  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.
                                     2-9

-------
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.
                                     2-10

-------
     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.
                                      2-11

-------

-------
                                   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

                                     3-1

-------
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).
                                     3-2

-------
     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

-------
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.
                                     3-4

-------
          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

-------
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

                                     3-6

-------
        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.
                                     3-7

-------
     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.
                                     3-8

-------
     •  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.

                                     3-9

-------
     •  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)


                                      3-10

-------
     •   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.
                                     3-11

-------
     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.
                                     3-12

-------
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.
                                     3-13

-------
     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.
                                     3-14

-------
             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.
                                3-16

-------
                                   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


                                     4-1

-------
                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
                                     4-2

-------
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


                                      4-3

-------
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
                                      4-4

-------
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)
                                     4-5

-------
     •  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
                                      4-6

-------
      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)
                                     4-7

-------
                            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
                                     4-8

-------
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
                                     4-9

-------
     •  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.
                                     4-10

-------
     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
                                     4-11

-------
     •  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

                                     4-12

-------
     •  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.
                                     4-13

-------
     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.

                                     4-14

-------
     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.
                                     4-15

-------
                    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)
                                     4-16

-------
                            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.
                                     4-17

-------
                                       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
                                     4-19

-------

-------
                                   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.

                                     5-1

-------
     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

                                      5-2

-------
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.

                                     5-3

-------
 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.


                                     5-4

-------
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

-------
     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

                                     5-6

-------
 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.

                                      5-7

-------
              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:
                                    5-8

-------
     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

                                     5-9

-------
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
                                     5-10

-------
 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

                                     5-11

-------
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
                                     5-12

-------
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

                                     5-13

-------
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

                                     5-14

-------
 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.

                                      5-15

-------
     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

                                     5-16

-------
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.
                                     5-17

-------

-------
                                   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

                                     6-1

-------
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.
                                      6-2

-------
      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


                                     6-3

-------
(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
                                     6-4

-------
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


                                     6-5

-------
 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


                                     6-6

-------
(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
                                     6-7

-------
     •  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,


                                     6-8

-------
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,

                                     6-9

-------
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

-------
     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

-------

-------
                                   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

-------
   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

-------
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

-------
     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

-------
        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

-------
     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

-------
        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

-------
     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

-------
                 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

                                     7-12

-------
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).
                                     7-13

-------
                             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

-------
                        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.

-------
                       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.

-------
          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
                                     7-20

-------
                               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).
                                     7-22

-------
          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


                                     7-23

-------
                        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

-------
      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

-------
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

-------
     •  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

-------
     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

-------
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

-------
                           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).
                                     7-32

-------
      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.
                                     7-33

-------

-------
                                   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.
                                     8-1

-------
        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
                                     8-2

-------
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
                    8-3

-------
                                    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

-------
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.
                                     8-5

-------
     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.
                                     8-6

-------
        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

-------
                            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.
                                     8-8

-------
     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
                                     8-9

-------
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


                                     8-10

-------
 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
                                     8-11

-------
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
                                     8-12

-------
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.
                                     8-13

-------

-------
                                    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.
                                     9-1

-------
     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.

                                     9-2

-------
               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)



                                     9-3

-------
                            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
                                     9-4

-------
 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.
                                     9-5

-------
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.
                                     9-6

-------
           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

-------
     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

-------
     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

-------
     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

-------
                                 BIBLIOGRAPHY
Adams, C.E., D.L. Ford, and W.W. Eckenfelder, 1981.  Development of
     Design and Operational Criteria for Wastewater Treatment.  Enviro Press,
     Inc., Nashville, Tennessee.

Aldrich Chemical Co., 1980.  The Aldrich Catalog Handbook of Organic and
     Biochemicals.  Milwaukee, Wisconsin.

American Conference of Governmental Industrial Hygienists, 1980.  Documen-
     tation of the Threshold Limit Values.  4th Edition.  ACGIH, Cincinnati,
     Ohio.

American Conference of Governmental Industrial Hygienists, 1984.  TLVs
     Threshold Limit Values for Chemical Substances and Physical Agents in the
     Work Environment with Intended Changes for 1984-85.  ACGIH, Cincinnati,
     Ohio.

American National Standards Institute, Inc., 1980.  American National
     Standard, Practices for Respiratory Protection.  ANSI Z88.2, 1980k.
     ANSI, New York.

American Public Health Association, 1980.  Standard Methods for the
     Examination of Water and Wastewater.  15th Edition.  APHA, Washington,
     D.C.

American Society for Testing Materials, 1974.  Instruments for Monitoring Air
     Quality.   ASTM, Philadelphia, Pennsylvania.

Banner, T., et al., 1981.  Hazardous Waste Incineration Engineering.  NDC,
     Park Ridge,  New Jersey.

Bell v. Industrial Vangas,  California Appellate Court, 1980,  California
     Supreme Court, 1981; S.L.  Birnbaum and B. Wrubel, "California Supreme
     Court Adopts a "Manufacturer1 Liability Exemption to the Exclusive Remedy
     Provision of Workers'  Compensation," The Forum, Spring 1982.

Blank, L., 1980.   Statistical Procedures for Engineering Management, and
     Science.   McGraw-Hill  Book Company, New York.

Blankenship v. Cincinnati Milacron Chemicals, No.  81-402 (Ohio Sup. Ct. filed
     March 3,  1982); S.L. Birnbaum and B. Wrubel,  "Worker Exclusivity Under-
     mined by Ohio Decision," The National Law Journal, Vol.  4 (38): 17, 20,
     (May 31,  1982).  Book 69 Ohio State Second Code, 1982.

-------
Boutwell, S.H., 1984.  Selection of Models for Remedial Action Assessment.
     Prepared by Anderson-Nichols and Co., Palo Alto, California, for U.S.
     EPA, Environmental Research Laboratory,  Athens, Georgia.

Brown, S.M., 1983.  Simplified Methods for Remedial Action Evaluation.
     Prepared by Anderson-Nichols and Co., Palo Alto, California, for U.S.
     EPA, Municipal Environmental Research Laboratory, Cincinnati, Ohio.

Brown, S.M., S.H. Boutwell, and B.R. Roberts, 1983.  Use of Numerical Models
     for Remedial Action Evaluation.  Prepared by Anderson-Nichols and Co.,
     Palo Alto, California, for U.S. EPA, Municipal Environmental Research
     Laboratory, Cincinnati, Ohio.

Buecker, D.A., and M.L. Bradford, 1982.  "Safety and Air Monitoring Consider-
     ations at the Cleanup of a Hazardous Waste Site" in Management of Uncon-
     trolled Hazardous Waste Sites.  Hazardous Materials Control Research
     Institute, Silver Spring, Maryland.

Callahan, M.A., M.W. Slimak, N. W. Gabel, et  al., 1979.  Water Related Fate of
     129 Priority Pollutants.  EPA Report No. 440/4-79-0296.  Washington, B.C.

Clark, E.L., 1958.  "How to Scale Up Pilot Plant Data and Equipment."
     Chemical Engineering, October 6, 1958, p. 129.

Cohen, R.M., and W.J. Miller, III, 1983.  "Use of Analytical Models for
     Evaluating Corrective Actions at Hazardous Waste Sites."  Proceedings of
     the 3rd National Symposium on Aquifer Restoration and Groundwater Moni-
     toring.  National Water Well Association, May 25-27.

Cole, C.R., R.W. Bond, S.M. Brown, and G.W. Dawson, 1983.  Demonstration/
     Application of Groundwater Technology for Evaluation of Remedial Action
     Alternatives.  Prepared by Battelle, Pacific Northwest Laboratory,
     Richland, Washington, for U.S. EPA, Municipal Environmental Research
     Laboratory, Cincinnati, Ohio.

Cralley, Lewis, and Lester Cralley, 1981.  Patty's Industrial Hygiene and
     Toxicology, Volumes I-III.  3rd Edition.  John Wiley & Sons, New York.

Dalehite v. U.S., 346 U.S. 15 (1953); Indian Towing Co. v. U.S., 350 U.S. 61,
     (1955).

Dawson, G.W., C.J. English, and S.E. Petty, 1980.  Physical Chemical Prop-
     erties of Hazardous Waste Constituents.   U.S. EPA, Office of Research and
     Development, Athens, Georgia.

DeRonzo, D.J. (ed.), 1982.  Pollution Control Technology for Industrial
     Wastewater.  NDC, Park Ridge, New Jersey.

Devary, J.L., and J.P. Hughes, 1984.  Krigelib - A Kriging Software Library;
     Geostatistical Theory and User's Manual.  Battelle Project Management
     Division, Office of Hazardous Waste Management, Richland, Washington.

-------
 Donigian,  A.S.,  Jr.,  1981.   "Water Quality Modeling in Relation to Watershed
      Hydrology in  Modeling  Components of Hydrologic Cycle" in V.  Singh,  ed.,
      Proceedings of the International Symposium on Rainfall Runoff Modeling,
      Mississippi State University.  Water Resources Publications,  Littleton,
      Colorado.

 Ecology and  Environment,  Inc.,  1980.  Generic  Activities Conducted  During an
      Investigation of an  Uncontrolled Hazardous Waste  Site.   EPA  Contract No.
      68-01-6056.

 Eckenfelder,  W.W.,  and P.A.  Krenkel,  1974.  "Advanced  Waste Water
      Treatment  Course," AIChE Today Series.   Atlantic  City,  New Jersey.

 Federal Register  July 16,  1982.   "National Oil and Hazardous  Substances
      Contingency Plan."  40  CFR  300,  Volume 47,  No.  137.

 Ford,  P.J.,  P.J. Turina,  and D.E.  Seely,  1983.   Characterization of Hazardous
      Waste Sites -  A  Methods Manual:   Volume  II.Available Sampling Methods.
      EPA Report  No. 600/4-83-040.   NTIS  No. PB84-126920.   U.S.  EPA.  Las
      Vegas,  Nevada.

 Ford,  P.J.,  P.J. Turina,  and D.E.  Seely,  1984  (in  preparation).  Character-
      ization  of  Hazardous Waste  Sites -  A Methods  Manual:   Volume  I.
      Integrated Approach.  U.S.  EPA,  Las  Vegas, Nevada.

 Freeze,  A.R.,  and  J.A.  Cherry, 1979.   Groundwater.   Prentice-Hall  Inc.,
      Englewood Cliffs,  New Jersey.

 Hansch,  C.,  and A.J.  Leo, 1979.  Substituent Constants  for  Correlation
     Analysis  in Chemistry and Biology.   John Wiley, Inc.,  New  York.

 Hawley,  G.G.,  1981.   Condensed Chemical  Dictionary.  Van Nostrand  Reinhold
     Co., New York.

 Journel, A.G., and  C.J. Huijbregts, 1978.  Mining  Geostastics.  Academic
     Press, London.

 JRB Associates,  1982.   Guidelines  for Development  of Hazardous Waste Site
     Remedial Action Procurement Documents Which Protect Pennsylvania From
     Liability and Cost Uncertainties. Washington,  D.C., March  1982.

 JRB Associates and CH2M Hill, 1983.  "Remedial Action Costing Procedures
     Manual."  Prepared for U.S. EPA, Office of Emergency and Remedial
     Response, Washington, D.C.

Kirk-Othmer,  1978.   Kirk-Othmer Encyclopedia of Chemical Technology.  3rd
     Edition.  John Wiley and Sons, New York.

Kufs, C., E.  Repa,  P.  Rogoshewski,  et al., 1983.  Leachate Plume Migration
     Control.  Contract No.  68-03-3113.  U.S.  EPA,  Cincinnati, Ohio.

-------
Lippitt, J., et al., 1982.  "Worker Health and Safety Considerations:  Costs
     of Remedial Actions at Uncontrolled Hazardous Waste Sites" (draft final
     report).  Prepared by SCS Engineers under Contract No. 68-03-3028, for
     the Municipal Environmental Research Laboratory, U.S. Environmental
     Protection Agency, Cincinnati, Ohio.

Lyman, W.J., W.F. Reehl, and D.H. Rosenblatt, 1981.  Chemical Property
     Estimation Methods.  McGraw Hill, New York.

Mabey, W.R., J.H. Smith, and R.T. Podoll, 1982.  Aquatic Fate Process Data for
     Organic Priority Pollutants.  EPA Report No. 440/4-81-014.  Prepared by
     SRI International.  Prepared for:  U.S. EPA, Monitoring and Data Support
     Division, Office of Water Regulations and Standards.

Mackison, F.W., R.S. Stricoff, and L.J. Partridge (eds.), 1978.  NIOSH/OSHA
     Pocket Guide to Chemical Hazards.  NIOSH Publication No. 78-210.
     National Institute for Occupational Safety and Health and Occupational
     Safety and Health Administration, U.S.  Government Printing Office,
     Washington, D.C.

Mason, B.J., 1983.  Protocol for Soil Sampling; Techniques and Strategy.
     EPA-600/54-83-002.  U.S. Environmental Protection Agency, Las Vegas,
     Nevada.

Mercer, J.W., and C.R. Faust, 1981.  Groundwater Modeling.  National Water
     Well Association.

Metcalf and Eddy, Inc., 1979.  Wastewater Engineering:  Collection, Treatment,
     Disposal, McGraw-Hill Book Company, New York.

Mills, W.,  et al.,  1982.  Water Quality Assessment:  A Screening Procedure for
     Toxic  and Conventional Pollutants, Volumes 1 and 2.  EPA Report No.
     600/6-82-004abc.  Prepared by Tetra Tech, Inc., for U.S. EPA.

National Fire Protection Association, 1978.  Fire Protection Guide to Hazard-
     ous Materials.  7th Edition.  Quincy, Massachusetts.

National Fire Protection Association, 1981.  National Fire Codes.  Volumes
     1-16.  Quincy, Massachusetts.

National Institute  for Occupational Safety and Health, expected publication
     date:  Early 1985.  Guidance Manual for Superfund Activities, Volumes
     1-9.   U.S. Department of Health  and Human Services, National Institute
     for Occupational  Safety and Health, Cincinnati, Ohio.

National Institute  for Occupational Safety and Health, 1981.  "NIOSH Certified
     Equipment List as of June  1, 1980."  NIOSH Publication No. 80-144.
     Public Health  Service, Center for Disease Control, U.S. Department of
     Health and Human  Services.  Cincinnati, Ohio.  Also:  "Supplement to the
     NIOSH  Certified Equipment List,  October 1981."  NIOSH Publication No.
     82-106.

-------
National Institute for Occupational Safety and Health, 1981.  Occupational
     Health Guidelines for Chemical Hazards.  DHHS (NIOSH) Publication No.
     81-123.  Superintendent of Documents, U.S. Government Printing Office,
     Washington, D.C.

National Institute for Occupational Safety and Health, 1973.  The Industrial
     Environment—Its Evaluation and Control. GPO Stock Number 017-00100396-4.
     Superintendent of Documents, U.S. Government Printing Office,
     Washington, D.C.

Onishi, Y., R.J. Serne, E.M. Arnold, C.E. Cowan, and F.L. Thompson, 1981.
     Critical Review:  Radionuclide Transport, Sediment Transport, and Water
     Quality Mathematical Modeling; and Radionuclide Adsorption/Desorption
     Mechanisms.  Report No. NUREG/CR-1322.   U.S. Nuclear Regulatory
     Commission, Washington, D.C.

Orlob, G., 1971.  "Mathematical Modeling of Estuarial Systems."  International
     Symposium on Mathematical Modeling Techniques.

Oster, C.A., 1982.  Review of Groundwater Flow and Transport Models in the
     Unsaturated Zone"!  Report Nos. PNL-4427 and NUREG/CR-2917.Prepared by
     Battelle, Pacific Northwest Laboratory, Richland, Washington.

Permeggiani, Luigi (ed.), 1983.  Encyclopedia of Occupational Health and
     Safety.  Third (Revised) Edition.  Two Volumes.  International Labour
     Organization, Geneva 22, Switzerland.

Perry, R., and C. Chilton, 1973.  Chemical Engineers Handbook.  5th Edition.
     McGraw-Hill Book Company, New York.

Perry, R.H., and C.H. Chilton, 1972, Chemical Engineers Handbook, McGraw-Hill
     Book Company, New York.

Peters, M.S., and K.D. Timmerhaus, 1981, Plant Design and Economics for
     Chemical Engineers.   3rd Edition.  McGraw-Hill Book Company, New York.

Porcella, B., 1983.  Protocols for Bioassessments of Hazardous Waste Sites.
     EPA Report Nos.  600/23-83-054 and PB-83-241737.  Prepared by Tetra Tech,
     Inc. for U.S. EPA, Office of Toxic Substances, Washington, D.C.

Sax, N.I., 1984. Dangerous Properties of Hazardous Materials.  6th Edition.
     Van Nostrand Reinhold Company, New York.

Schroeder, E.D., 1977.  Water and Wastewater Treatment,  McGraw-Hill Book
     Company, New York.

Schwope, A.D., et al, 1983.   "Guidelines for the Selection of Protective
     Clothing."  American Conference of Governmental Industrial Hygienists,
     Cincinnati, Ohio.

-------
Shuckrow, A.J., A.P.  Pajak, and D.J.  Towhill.   1983.  "Management of
     Hazardous Waste  Leachate."  Report No. SW-871 (also published by NDC) .
     U.S. EPA, OSW, Washington, D.C.

Seely, B., P. Turina, N. Pangaro, B.  Myatt, S. Pendleton, 1983.  "Development
     of protocols for ambient air sampling and monitoring at hazardous waste
     facilities:  methods summary report."  Draft Report.  GCA Corporation,
     Prepared for:  U.S. Environmental Protection Agency, Office of Solid
     Waste, Land Disposal Branch.

Senate Report No. 96-848, to accompany S. 1480, the Environmental Emergency
     Response Act, by the Committee on Environmental and Public Works, 96th
     Congress, 2nd Session, July 13,  1980, p.  62.

Silka, L.R. and J.W.  Mercer, 1982.  "Evaluation of Remedial Actions for
     Groundwater Contamination at Love Canal,  New York."  Proceedings of
     National Conference on Management of Uncontrolled Hazardous Waste Sites.
     Hazardous Materials Control Research Institute, Silver Spring, Maryland.

Skoog, D.A. and D.M.  West, 1980.  Principals of Instrumental Analysis, 2nd
     Edition.  Saunders College, Philadelphia, Pennsylvania.

Smith, J.M., 1981.  Chemical Engineering Kinetics, 3rd Edition, McGraw-Hill
     Book Company, New York.

Snedecor, G. W. and W. G. Cochran.  1980.  Statistical Methods.  7th Edition.
     The Iowa State University Press, Ames, Iowa.  507 pp.

State Rep. No. 96-848, to accompany S. 1480, the Environmental Emergency
     Response Act, by the Committee on Environmental and Public Works, 96th
     Cong., 2d Sess., July 13, 1980,  p. 62.

Stover, E.L. and D.F. Kincannon, 1983.  "Biological Treatability of Specific
     Organic Compounds Found in Chemical Industry Wastewaters."  J. Water
     Pollution Control Federation (55) 1:97.

Tatken, R.J. and R.J. Lewis (eds.), 1983.  Registry of Toxic Effects of
     Chemical Substances, 1981-82 Edition.  GPO Stock No. 017-033-00406-4.
     3 Volumes.  Superintendent of Documents, U.S. Government Printing Office,
     Washington, D.C.

Thomas, S.D., B. Ross, and J.W. Mercer, 1982.  A Summary of Repository Siting
     Models.  NUREG/CR-2782.  U.S. Nuclear Regulatory Commission, Washington,
     D.C.

U.S. Coast Guard,  1978.  A Condensed Guide to Chemical Hazards  (CHRIS),
     Volumes  I and II.  U.S. Department of Transportation, Washington, D.C.

U.S. Department of Commerce, 1961.  "Rainfall Frequency Atlas of the United
     States."  Technical Paper No. 40.  Weather Bureau, Washington, D.C.

-------
 U.S.  Department  of  Commerce,  1968.   Climatic Atlas  of  the United  States.
      Environmental  Sciences  Services  Administration, Environmental  Data
      Service, Washington, D.C.

 U.S.  Department  of  Labor, 1980.  Hot  Environments.  NIOSH Publication No.
      80-132.  Superintendent  of Documents, U.S. Government Printing Office,
      Washington, D.C.

 U.S.  Department  of  Labor, 1983.  "General  Industry  OSHA  Safety  and  Health
      Standards (29  CFR Parts  1900 to  1910).  OSHA 2022 Revised  as of July  1,
      1983."  Superintendent  of Documents,  Government Printing Office.
      Washington, D.C.

 U.S.  Department  of  Labor, 1983.  29 CFR Part 1920 to End.  Revised  as of July
      1,  1983.  Superintendent of Documents, Government Printing Office.
      Washington, D.C.

 U.S.  Department  of  Transportation, 1982.   "Transportation, Subchapter C—
      Hazardous Materials Regulations."  49 CFR  171-178.  Superintendent of
      Documents,  U.S. Government Printing Office, Washington, D.C.

 U.S.  EPA, Office of General  Counsel,  undated.   "Abstract of General  Counsel
      Memoranda,  EPA's Responsibility  to Contractor's Employees."

 U.S.  EPA, 1971.  Guidelines  for Air Quality Surveillance Networks.   Report No.
      AP-98.  Research Triangle Park,  North Carolina.

 U.S.  EPA, 1977.  Procedures Manual for Groundwater Monitoring at Solid Waste
      Disposal Facilities.  EPA Report No.  530/SW-611.  U.S. Environmental
      Protection Agency, Office of Water and Waste Management, Washington, D.C.

 U.S.  EPA, 1979a.  Safety Manual for Hazardous Waste Site Investigations.
      National Enforcement Investigations Center, Washington,  D.C.

 U.S.  EPA, 1979b. Water-Related Environmental Fate of 129 Priority Pollutants.
      Vols. I and TTEPA 440/4-79-029.NTIS No.  PB80-204373.Office of
      Planning and Water Standards, Washington, D.C.

 U.S. EPA,  1979c.  Handbook for Analytical Quality Control in Water  and
     Waste-water Laboratories.  EPA-600/4-79-019.   NTIS No. PB80-297451.
     Office of Research and Development,  Cincinnati, Ohio.

 U.S. EPA, 1980.   Enforcement Considerations for Evaluations of Uncontrolled
     Hazardous Waste Sites By Contractor.   Office  of Enforcement, National
     Enforcement Investigations Center, Denver, Colorado.

U.S. EPA, 1980a.   Guidelines and Specifications for  Implementing Quality
     Assurance Requirements for EPA Contracts.QAMS-002/80.Office of
     Research and Development, Cincinnati,  Ohio.

-------
OU.S. EPA, 1980b.  Guidelines and Specifications for Implementing Quality
     Assurance Requirements for EPA Contracts.  QAMS-005/80.  Office of
     Research and Development, Cincinnati, Ohio.

U.S. EPA, 1980c. Interim Guidelines and Specifications for Preparing Quality
     Assurance Project Plans.QAMS-005/80.Office of Monitoring Systems and
     Quality Assurance, Washington, D.C.

U.S. EPA, 1980d.  Chemical Information Resources Handbook.  In:  Toxic
     Integration Information Series (Final).  EPA No. 560/TIIS-81-001.  NTIS
     No. PB84-124585.  Office  of Pesticides and Toxic Substances, Washington,
     D.C.  January.

U.S. EPA, 1981a.  Contractor Requirements for the Control and Security of TSCA
     Confidential Business Information"!  EPA Report No. 560/1-82-002.  NTIS
     No. PB82-177759.  Washington, D.C.

U.S. EPA, 1981b.  National Enforcement Investigations Center Policies and
     Procedures Manual.  EPA Report No. 330/9-78-001-R, Washington, D.C.

U.S. EPA, 1981c.  TSCA Confidential Business Information Security Manual.  EPA
     Report No. 560/1-82-001.   NTIS No. PB82-195330.  Washington, D.C.

U.S. EPA, 1981d.  "Technical Methods for Investigating Sites Containing
     Hazardous Substances."  (June 1981 Draft).  Monograph No. 24, p. 1.

U.S. EPA, 1981e.  "Technical Methods for Investigating Sites Containing
     Hazardous Substances."  (June 1981 Draft).  Monograph No. 27, p. 8.

U.S. EPA, 1981f.  FIFRA Confidential Business Information Security Manual.
     Office of Pesticides Programs.

U.S. EPA, 1981g.  NEIC Manual  for Groundwater/Subsurface Investigations at
     Hazardous Waste Sites.  EPA Publication No. 330/9-81-0021, Denver,
     Colorado.

U.S. EPA, 1982a.  Environmental Modeling Catalogue.  PM-211A.  U.S. EPA,
     Information Clearing House, Washington, D.C.

U.S. EPA, 1982b.  EPA Field Guide for Scientific Support Activities Associated
     with Superfund Emergency Response.  EPA Report No. 600/8-82-025.  NTIS
     No. PB83-226399.  Corvallis, Oregon.

U.S. EPA, 1982c.  Handbook for Sampling and Sample Preservation of Water and
     Wastewater.  EPA Report No. 600/4-82-029.  NTIS No. PB83-124503.
     Environmental Monitoring  Systems Laboratory, Cincinnati, Ohio.

U.S. EPA, 1982d.  Handbook; Remedial Action at Waste Disposal Sites.  EPA
     Report No. 625/6-82-006.   NTIS No. PB82-239054.  Office of Emergency and
     Remedial Response, Washington, D.C.

-------
 U.S.  EPA,  1982e.   Interim  Standard Operating  Safety Guides, Revised  September
      1982.  Hazardous  Response  Support Division, Office of Emergency and
      Remedial Response, Washington, D.C.

 U.S.  EPA,  1982f.   "Memorandum on Inspection Procedures,"  April  11,  1982.
      Office of Enforcement, Reprinted in Bureau of National Affairs  Environ-
      ment  Reporter, p. 41:2452.

 U.S.  EPA,  1982g.   Treatability  Manual.  Volumes I-V.  EPA Report No.
      600/2-82-001.  Washington, D.C.

 U.S.  EPA,  1983a.   EPA  Guide for Identifying Cleanup Alternatives at  Hazardous
      Waste Sites and Spills;  Biological Treatment.  Report No. EPA-600/3-83-
      063.  Prepared by Battelle, Pacific Northwest Laboratory, Richland,
      Washington, for the U.S. EPA, Office of  Emergency and Remedial  Response.

 U.S.  EPA,  1983b.   Community Relations in Superfund:  A Handbook.  (Interim
      Version.) EPA/HW-6, Washington, D.C.

 U.S.  EPA,  1983c.   "Superfund Feasibility Study Manual:  Source Release,
      Environmental Fate, Exposed Population,  and Integrated Exposure Analyses"
      (draft dated  9/14/83).  Prepared by Versar, Inc., Springfield,  Virginia
      for U.S. EPA, Exposure Evaluation Division.

 U.S.  EPA,  1983d.   Superfund Risk Evaluation Manual.  Prepared by ICF, Inc.,
      Versar, and Environ Corporation for U.S. EPA, Office of Emergency and
      Remedial Response.

 U.S.  EPA,  1983e.   Office of Toxic Substances  Information Architecture
      Notebook.  EPA No. 560/7-84-001.NTIS No. PB84-188655.Office of Toxic
      Substances, Washington, D.C.  August.

 U.S.  EPA,  1983f.   Methodology to Inventory, Classify, and Prioritize
      Uncontrolled  Waste Disposal Sites.  EPA  Publication No. 600/4-83-048.
      Las Vegas, Nevada.

 U.S.  EPA,  1983g.   Handbook for Evaluating Remedial Action Technology Plans.
      EPA Report No. 600/2-83-076, NTIS No. PB84-118249.   Cincinnati, Ohio.

 U.S.  EPA,  1983h.   Rapid Assessment of Potential Groundwater Contamination
      Under Emegency Response Conditions.   EPA Publication No.  600/8-83-030.
      Washington, D.C.

 U.S.  EPA, 1983i.  Vadose Zone Monitoring for Hazardous Waste Sites.  EPA
      Publication No. 600/X-83-064.Las Vegas, Nevada.

U.S.  EPA, 1984a.  Geophysical Techniques  for Sensing Buried Wastes and Waste
     Migration.   EPA Publication No.  600/7-84-064.   Las  Vegas,  Nevada.

U.S. EPA, 1984b.  Slurry Trench Construction for Pollution Migration Control.
     EPA Report No. 540/2-84-001.   NTIS  No.  PB84-177831.   JRB  Associates.
     Prepared for:   U.S.  EPA,  Washington,  D.C., and Cincinnati, Ohio.

-------
U.S. EPA, 1984c.  "Draft RCRA Confidential Business Information Security
     Manual."  Office of Solid Waste, Washington, D.C.

U.S. EPA, March 1984d.  Draft Contractor Requirements for the Control and
     Security of RCRA Confidential Business Information.  Office of Solid
     Waste, Washington, D.C.

U.S. EPA, 1984e.  "Methodology for Selection and Evaluation of Remedial
     Responses."  Draft.  JRB Associates.  Prepared for:  Municipal
     Environmental Research Laboratory, Cincinnati, Ohio, and Office of
     Emergency and Remedial Response, Washington, D.C.

U.S. EPA, 1984f.  "Health Risk Assessment Guidelines for Chemical Mixtures"
     (Proposed Guidance).  Environmental Criteria and Assessment Office,
     Cincinnati, Ohio.

U.S. EPA, 1984g.  "Guidance for the Preparations of Exposure Assessments"
     (Proposed Guidance).  Environmental Criteria and Assessment Office,
     Cincinnati, Ohio.

U.S. EPA, 1984h.  Revised Interim Guidelines for the Health Assessment of
     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.
                                      10

-------
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

-------

-------
                     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.
                         A-l

-------
     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
                     A-2

-------
         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:
                        A-3

-------
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.
                     A-4

-------
    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].
                        A-5

-------
     [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
                     A-6

-------
         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.]
                        A-7

-------
    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
                        A-8

-------
          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.
                    A-9

-------
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.
                        A-10

-------
     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

-------