xvEPA
            47United States
            Environmental Protection
            Agency
             Office of Emergency and
             Remedial Response
             Washington DC 20460
EPA/540-R-92-021
PB92 -963375
September 1992
            Superfund
                          9345.1-05
Guidance for Performing
Site Inspections Under
CERCLA
            Interim Final

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                                 EPA540-R-92-021
                                 Directive 9345.1-05
                                  September 1992
Guidance for Performing Site
 Inspections Under CERCLA

           Interim Final
        Hazardous Site Evaluation Division
    Office of Solid Waste and Emergency Response
       U.S. Environmental Protection Agency
           Washington, DC 20460

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                                        NOTICE

The  procedures  set forth in this  document are intended as guidance to employees of the U.S.
Environmental protection Agency (EPA), States, and other government agencies. EPA officials may
decide to  follow the guidance provided in this directive, or to  act at variance with it, based on
analysis of specific site circumstances. EPA also reserves the right to  modify this guidance at any
time without public notice.

These guidelines do not constitute EPA rulemaking and cannot be relied upon to create any rights
enforceable by any party in litigation with the United States.

Mention of company or product names in this document should not be considered as an endorsement
by EPA.

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Site Inspection Guidance	Contents


                                        CONTENTS


CHAPTER 1:  INTRODUCTION 	    1

     1.1 SITE ASSESSMENT PROCESS 	   2

         1.1.1  Preliminary  Assessment   	   4
         1.1.2  Site  Inspection	   5
                     Review Available Information  	   6
                     Organize Project Team and Develop Plans	   6
                     Perform Field Work  	   7
                     Evaluate Data	   7

CHAPTER 2:  SI APPROACHES	   9

    2.1 FOCUSED  SI	   9
    2.2 EXPANDED  SI	  1/1
    2.3 SINGLE SI APPROACH	  12

CHAPTER 3:  PLANNING  	  15

    3.1  SAMPLE COLLECTION ISSUES	  15
         3.1.1  Sample Types	  15
         3.1.2 Sample Variability	  17
                     Sample Collection and Handling Variability	  17
                     Spatial Variability	  18
                     Temporal Variability	  19
                     Media  Variability	  19
    3.2  FIELD QA/QC CONSIDERATIONS  	  21
    3.3  I-IRS  SAMPLING CONSIDERATIONS  	  22
     3.4  SAMPLE ANALYSIS OPTIONS	  23
         3.4.1  CLP  Services 	  24
         3.4.2  Non-CLP  Services	  25
     3.5  REVIEW INFORMATION FOR SI PLANNING	  25
         3.5.1  Review Non-Sampling Information	  26
         3.5.2 Review Analytical Data 	  26
     3.6  SI PLANS	  30
         3.6.1  Work  Plan  	  30
         3.6.2  Sample Plan 	  30
         3.6.3 Health and Safety Plan
                     Routine Operations	  33
                     Emergencies	  33
         3.6.4 IDW Management Plan 	  34
     3.7  SITE RECONNAISSANCE	  35
         3.7,1 Emergency Response	  35
         3.7.2  Effects of Removal Actions  	  36
         3.7.3 Site Access	  36
                      Voluntary Entry	  36
                      Conditional Entry	  37

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Contents                                                              Site Inspection Guidance
                      Entry With Warrant	  37
                      Entry Without Warrant  	   37
         3.7.4 Community and Neighborhood Contacts	  37
         3.7.5 Government Contacts	   38
     3.8 SITES CONTAINING RADIOACTIVE SUBSTANCES	  38
         3.8.1 Key Radiation Site Personnel  	   38
         3.8.2 Radiation Survey Instruments  	   39
                      Gamma Detectors	   39
                      Alpha and Beta Detectors  	   41
         3.8.3 Survey  Techniques	   41
         3.8.4 Special Sampling and Analysis Issues  	   42
         3.8.5 HRS Requirements for Radiation Sites  	43
         3.8.6 Radiation Health and Safety Plan	   44
         3.8.7 IDW  Plan	   44

CHAPTER 4: SAMPLING STRATEGIES	   45

     4.1 SI SAMPLING PRINCIPLES	45
         4.1.1 General Sampling Principles	   45
         4.1.2 Focused SI  Sampling Principles	   47
         4.1.3 Expanded and Single SI Sampling Principles  	   48
     4.2 SOURCE CHARACTERIZATION	   50
         4.2.1 Focused SI Strategy-Source Characterization	  52
         4,2.2 Expanded and Single SI Strategy-Source Characterization  	   53
         4.2.3 Example of Source Sampling Strategy 	   53
     4.3 QA/QC  SAMPLES	   55
         4.3.1 Focused SI Strategy-QA/QC Samples   	   56
         4.3.2 Expanded and Single SI Strategy-QA/QC Samples	   56
     4.4 SAMPLE TO DEMONSTRATE A RELEASE	   57
         4.4.1 General Principles	   57
                      Background Sampling Considerations 	   57
                      Attribution Considerations	  59
                      Target Considerations  	   59
         4.4.2 Focused SI Strategy-Sample to Demonstrate a Release	  60
         4.4,3 Expanded and Single SI Strategy-Sample to Demonstrate a Release  	   60
     4.5 GROUND WATER PATHWAY 	   60
         4.5.1 Focused SI Strategy-Ground Water Pathway	   61
         4.5.2 Expanded and Single SI Strategy-Ground Water Pathway	   62
                Well Installation	   62
         4.5.3 Example of Sampling Strategy   	,   64
     4.6 SURFACE WATER PATHWAY	   67
         4.6.1 Focused SI Strategy	   69
         4.6.2 Expanded and Single SI Strategy	   70
         4.6.3 Example of Sampling Strategy   	   70
     4.7 SOIL EXPOSURE PATHWAY	   74
         4.7.1 Focused SI Strategy vs. Expanded and Single SI Strategy	   76
         4.7.2 Example of Sampling Strategy   	  78
     4.8 AIR PATHWAY  	   81
         4.8.1 Focused SI Strategy-Air Pathway  	  82
         4.8.2 Expanded and Single SI Strategy-Air Pathway  	  82
         4.8.3 Example of Air Sampling Strategy	83
                                                IV

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Site Inspection Guidance                                                           Contents


    4.9 SUES WITH RADIOACTIVE WASTES	  86
         4.9.1 General Sampling Principles	  86
                     Focused SI Sampling Principles	  87
                     Expanded and Single SI Sampling Principles	  88
         4.9.2 Source Characterization	  88
         4.9.3  QA/QC Samples  	  89
         4.9.4 Sample to Demonstrate a Release	  89
         4.9.5 Ground Water and Surface Water Pathways  	  90
         4.9.6 Soil Exposure Pathway	  91
         4.9.7  Air Pathway  	  91
    4.1 O SUMMARY	  92

CHAPTER 5: SI EVALUATION	   97

    5.1  REVIEW AND VALIDATE ANALYTICAL DATA	  97
    5.2  IDENTIFY ANALYTICAL DATA FOR SCORING	  98
    5.3  EVALUATE NON-SAMPLING INFORMATION	  99
    5.4  SCORE THE SITE	  100
         5.4.1  Scoring Tools	  101
                     SI Worksheets	  101
                     Prescore   	  102
                     Other Scoring Tools	  103
         5.4.2 Characterize and Evaluate Significant Site Sources	  103
         5.4.3 Characterize and Evaluate Significant Pathways	  104
         5.4.4 Evaluate Releases and Targets Exposed to Contamination	  105
         5.4.5 Check Scoring and Collect Additional Information	  107

CHAPTER 6 REPORTING REQUIREMENTS	  109

    6.1 NARRATIVE REPORT	  109
    6.2 SCORE  AND DOCUMENTATION	  113
    6.3 REVIEWS	  114

GLOSSARY	117

REFERENCES	123

    REFERENCES CITED	123
    SUPPLEMENTAL REFERENCES	125

APPENDIX  A:  SI SAMPLEPLAN (EXAMPLE)	A-l
APPENDIX B:  SI DATA SUMMARY	B-l
APPENDIX  C:  SITE INSPECTION WORKSHEETS	C-l
APPENDIX  D:  SI NARRATIVE REPORT (EXAMPLE)	D-l
APPENDIX E:  EQUIPMENT LIST 	E-l

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Figures
Site Inspection Guidance
                                  FIGURES AND  EXHIBITS

Figure 1-1:  Site Assessment in Superfund	   3
Figure 1-2:  The Remedial Phase of Superfund	
Figure 2-1:  Site Inspection DecisionT ree	
Exhibit 3-1:  Checklist for Usability of Previous Analytical Data	
Exhibit 3-2:  SI SamplePlan Outline	  31
Figure 4-1:  Lakefield Farm Site Sketch#l	  54
Figure 4-2  Lakefield Farm Site Sketeh#2	  65
Figure 4-3:  Lakefield Farm Site Sketeh#3	  72
Figure 4-4:  Carveth Landing Site Sketch	  79
Figure 4-5:  Vega Ore Site Sketch	  84
Exhibit 6-1:  SI Narrative Report Format	 110
                                                VI

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Site Inspection Guidance                                                                   Tables


                                            TABLES

2-1:   Hours to Complete Focused SI Tasks  	10
2-2:   Hours to Complete Expanded SI Tasks  	11
2-3:   Typical SI Data Collection Activities  	12
3-1:   Types of Samples	16
3-2:   Filtered and Unfiltered Water Samples	! 7
                                                                                                 is
3-3:   Potential Contaminants from Sampling Devices and Well Casings	i0
3-4:   Sampling Issues Affecting Confidence in Analytical Results	* "
3-5:   Typical SI Field QC Samples	21
3-6:   Media-Specific Benchmarks	^3
3-7:   Types of Analytical Data	27
                                                                                                 IS
3-8:   Review of Previous Analytical Data.	
3-9:   Gamma Radiation Survey Instruments	
3-10:  Alpha and Beta Radiation Survey Instruments	
3-11:  Radiation Surveying Methods	
3-12:  Radioactivity Measurement Procedures - References,	
4-1:   Sample Planning Considerations	"*"
4-2:   Priorities for Focused SI Samples	4"
4-3:   Priorities for Expanded SI Samples	
4-4:   Source Sampling Strategies	^
4-5:   Source Sampling Strategy for Example Site	55
4-6:   Guidelines for Minimum QA/QC Sample; Expanded SI or Single SI	*"
4-7:   Strategies for Observed Release Sampling	
4-8:   Ground Water Sampling Strategies	"•*
4-9:   Ground Water Sampling Strategy for Example Site; Focused SI	66
4-10:  Surface Water Samples to Support a Release and Target Contamination	68
4-11:  Surface Water Sampling Strategies	71
4-12:  Surface and Ground Water Sampling Strategy for Example Site; Focused SI	73
4-13:  Surface Water Sampling Strategy for Example Site; Expanded SI and Single SI	'^
4-14:  Soil Sampling Strategies	77
4-15:  Soil and Surface Water Sampling Strategy for Example Site; Focused SI  	80
4-16:  Soil Sampling Strategy for Example Site Expanded SI  	°1
4-17:  Air Sampling Strategy for Example Site; Single SI  	85
4-18:  Summary of SI Sampling Strategy  	93
5-1:   Data Review Considerations	98
5-2:   Data Use Categories (DUC) for SI Scoring	  100
5-3:   SI Worksheets versus Prescore ...,	  102
5-4:   Characterize and Evaluate Sources	  ™*
5-5:   Target Evaluation	  105
6-1:   Additional Evaluation of SI Results	  110
                                                 VII

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Executive Summary
                    Site Inspection Guidance
                                    EXECUTIVE  SUMMARY
This guidance presents EPA's site inspection (SI)
strategy. The strategy discusses procedural guidelines
to investigate potential Superfund (CERCLA) sites for
evaluation pursuant to the Hazard Ranking System
(FIRS), revised in accordance with the Superfund
Amendments and Reauthorization Act of 1986. The
HRS is the primary means by which EPA evaluates
sites for Superfund's National Priorities List (NPL).

EPA  uses a multiphase evaluation process to
determine appropriate action at Superfund sites. In
the first phase, hazardous substance releases or
threatened releases from a site are evaluated during
two investigations: the preliminary assessment (PA)
and the SI. During the PA, EPA collects background
information to determine whether the SI is warranted.
During the SI, EPA further evaluates the extent to
which a site presents a threat to human health or the
environment by, among other things, collecting and
analyzing wastes and environmental media samples to
determine whether hazardous substances are present
at the site and are migrating to the surrounding
environment. At the end of the SI, EPA  decides
whether the site qualifies for possible inclusion on the
NPL or should be dropped from further Superfund
consideration. Additionally, the SI supports removal
and enforcement actions and collects data to support
further Superfund or other response actions.

The SI is not intended to be a detailed extent-of-
contamination or risk assessment. Efforts requiring
intensive background investigation or specialized
techniques are normally part of the next phase in the
Superfund process after a site is placed on the NPL
and becomes eligible for remedial funding.

The most efficient investigative  approach for the
majority of sites recommended for further action after
the PA is conducted in  two steps: a focused SI
followed by an expanded SI, if necessary. Other sites
may require only a single SI, which is a combination
of a focused SI and an expanded SI.

In general, the focused SI is limited to testing PA
hypotheses to determine if the site warrants further
Superfund investigation. The scope of the focused SI
depends on the number of PA hypotheses requiring
investigation, the questions remaining after the PA,
and the number of migration and exposure pathways
that significantly influence the further action
recommendation.    Focused  SI  sampling is not
designed to document observed releases or observed
contamination per HRS requirements.    Hence,
sampling during the focused SI may not include the
full set of quality assurance/quality control (QA/QC)
and background samples.

After the focused SI, one of three recommendations
may be made:

  •  Site evaluation accomplished (SEA);
  •  Further action (e.g., expanded SI) recommended;
    or
  •  Preparation of an HRS package scheduled if all
    necessary data are available.

The objective of the expanded  SI is to provide
documentation for the HRS package to support NPL
rulemaking.      Remaining   HRS  information
requirements are addressed and site hypotheses not
completely supported during previous investigations
are evaluated. Expanded SI sampling is designed  to
satisfy HRS data requirements by  documenting
observed releases, observed contamination, and levels
of actual contamination at targets.    In addition,
investigators   collect  remaining    non-sampling
information.   Sampling during  the  expanded  SI
includes background and QA/QC samples to fully
document releases and attribute them to the site.
Following the expanded SI, EPA site assessment
managers assign the site a priority for HRS package
preparation and proposal to the NPL.

In some cases, it may be possible to conduct a  single
SI instead  of the focused and expanded SI. The
single SI presumes that a site would not be screened
by  a focused SI  and fufills  the functions of the
expanded SI to  collect  analytical  data  and non-
sampling information to  complete an HRS package.
The single SI is similar in scope to the expanded  SI
and may be appropriate for certain high priority sites
that are highly likely to be placed on the NPL.
                                                 Vlll

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Site inspection Guidance
                                  Introduction
                                          CHAPTER  1
                                       INTRODUCTION
   This document provides guidance for conducting site inspections (Sis) under CERCLA. Data collection
   requirements for these investigations are consistent with data needed for the revised Hazard Ranking System
   (HRS). This guidance discusses how to review and evaluate available information, plan an effective sampling
   strategy to acquire analytical data to evaluate a site according to the HRS, and prepare required reports and
   work products. Outlines and examples of completed work products  are provided to illustrate content and
   length. This guidance will help investigators conduct efficient, high quality Sis that result in correct site
   recommendations on a nationally consistent basis.
The objective of an SI is to gather information to
support a site decision regarding the need for further
Superfund action. The SI is not a study of the full
extent of contamination at a  site or a risk assessment.
The appropriate level of information gathered and
analyzed to meet this objective can only be achieved
through strategic planning to determine what data are
essential to the decision.

The SI phase of the Superfund program is  a dynamic,
flexible process that should be tailored to the specific
circumstances  of individual  sites  it  is not  a
standardized process to be repeated at every site. The
SI investigator, in coordination with EPA Regional
and State officials, is  responsible for the design and
execution of the SI, and  should determine how best to
use the flexibility of this process. As conditions are
tested and hypotheses are either confirmed or rejected,
the investigation should  be adjusted.    These
adjustments,  like the  site  decision itself, involve
balancing a wide variety of factors and  exercising
professional judgment.

This document contains six chapters:

  •   Chapter 1: Introduction  provides background
     on the purpose and implementation of Superfund
     legislation, discusses the structure  of the site
     assessment process, and provides  specific details
     on the role of the  preliminary assessment (PA)
     and SI in the site assessment process.

  •   Chapter 2: SI Approaches  discusses  the
     objectives, purpose, and scope of the SI, and
     provides guidelines for  selecting the approach to
     investigate a site.
 •  Chapter 3: Planning  provides an overview of
    sampling and analysis considerations and HRS
    analytical  data requirements, discusses  the
    importance of available data in developing SI
    plans, and provides guidelines for reviewing
    analytical data for SI planning.

 •  Chapter 4  Sampling Strategies   discusses
    sampling principles to investigate site-specific
    conditions, test PA hypotheses, and document
    HRS information; presents sampling strategies
    for each pathway and for multiple pathways; and
    provides   examples   illustrating    sampling
    strategies.

 •  Chapter 5: SI Evaluation  addresses how to
    interpret and apply analytical data and non-
    sampling information.

 •  Chapter 6:  Reporting Requirements   discusses
    guidelines for preparing SI work products to
    report results, provides a detailed outline of a
    standard SI narrative report, and  presents
    procedures for reviewing SI scores  and
    documents.

Separate EPA documents provide key direction to
implement the  HRS and  should be consulted as
supplemental  references:

    Guidance  for  Performing Preliminary
    Assessments Under CERCLA (OSWER Directive
    9345.0-01A, September 1991) provides guidance
    for conducting the PA, including PA evaluation
    and the  use of PA scoresheets.

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Introduction
                    Site inspection Guidance
 •   Site Assessment Information Directory (SAID),
     1991, is a directory of information sources for
     use in site investigations.

 •  Hazard Ranking  System  (HRS)  Guidance
    Manual (OSWER Directive 9345.1-07, in
     development) provides guidance for scoring sites
     and discusses important HRS concepts.

 •  Management of Investigation-Derived Wastes
    During Site Inspections (OERR  Directive
     9345.3-02, May  1991)  presents  general
     regulatory information and options to manage
     investigation-derived wastes (IDW) generated
     during Sis.

 •   Guidance for Data Usability in Site Assessment
     (OSWER Directive 9345.1-05, in development)
     provides guidance  on how to collect and apply
     analytical data to support HRs scoring.

 •   Superfund Removal  Procedures  Manual
     (OSWER Directive 9360.3431, December 1990)
     provides guidance on daily activities at removal
     sites.    The manual  consists of guidance
     documents  on  the following topics: Action
     Memorandum preparation, removal reporting,
     response management, removal enforcement for
     On-Scene Coordinators, public participation,
     removal  decisions, special circumstances,
     consideration of ARARs, and State participation.

1.1  SITE ASSESSMENT  PROCESS

In  1980, Congress   enacted  the Comprehensive
Environmental Response, Compensation, and Liability
Act (CERCLA) establishing the Superfund  program
to respond to  releases  and threatened releases of
hazardous substances. CERCLA Section 105 required
EPA to establish criteria for determining priorities
among releases or threatened releases of hazardous
substances for the purpose of taking remedial action.
To meet this requirement, EPA developed  the HRS
(47FR 31180, July 16, 1982) to evaluate sites for the
National Priorities List  (NPL). Sites on the  NPL are
eligible for Federally funded remedial action.

The Superfund Amendments and Reauthorization Act
(SARA) of 1986 required EPA to  revise the HRS to
more accurately "assess the relative degree  of risk to
   CERCLA, as amended by SARA, required
   certain revisions  to  the  National  Oil  and
   Hazardous Substances  Contingency Plan (NCP)
   (40 CFR Part 300, March  1990) to implement
   the new authorities and responsibilities of the
   CERCLA amendments. The revisions to the
   NCP  establish  assessment  programs to
   investigate releases:

    •  Section 300.410  establishes a  phased
       investigation approach to address potential
       emergency response or removal situations,
       consisting  of a  removal  preliminary
       assessment  (PA) and  a  removal  site
       inspection  (SI) to evaluate whether a
       removal action is appropriate.

    •  Section  300.420  specifies  the   site
       assessment  process—known   as   the
       preremedial  process-which designates
       sites that qualify as priorities for long-
       term remedial evaluation and response.
       The process  consists of a remedial PA
       (Section 300.420 (b)) and a remedial SI
       (Section 300.420 (c)).

   The subject  of this document is site evaluation
   within the site assessment  process, and unless
   specifically  identified as activities  in  the
   removal  assessment  process, PAs  and  Sis
   described in this guidance are the PAs and Sis
   specified under NCP Section 300.420.
human health and the environment posed by sites."
SARA also required the HRS to take into account
recreational use of surface waters, contamination of
the human  food chain and drinking water supplies,
and potential contamination of ambient air. EPA
published the revised HRS on December 14,1990 (55
FR 51532).

The  site assessment  process  begins with site
discovery, or notification to EPA of possible releases
of hazardous substances. All sites are entered into
CERCLIS, EPA's computerized inventory of potential
hazardous waste sites. EPA then evaluates the sites
using a phased investigation consisting of the PA and,

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Site Inspsection Guidance
                                  Introduction
if necessary, the  SI. The PA is a  limited scope
investigation based primarily on available information
and performed by EPA or States for every CERCLIS
site. The PA distinguishes sites that pose no threat to
human health and the environment from sites that
may pose a significant threat. Sites that may pose a
threat receive a further action recommendation after
the PA and undergo an SI, where investigators collect
sufficient waste and environmental media samples to
identify sites that have  a  high Probability of
qualifying for the NPL.

When the PA and SI are completed, EPA calculates
the HRS site score and either recommends  further
investigation and possible proposal to the NPL or
makes a "Site  Evaluation Accomplished" (SEA)
determination. A SEA recommendation drops the site
from  further  Federal Superfund  consideration;
however, the removal program may continue to
address threats and any site may be reassessed if new
information becomes available.   Information  for
dropped sites is provided to States or other regulatory
authorities, which may take action on their own. If
no statutory provision or EPA policy indicates  that the
site should not be listed on the NPL, a site with an
HRS score of 28.50 or greater is eligible for the NPL.
These steps-discovery and entry into CERCLIS, PA,
SI, HRS package preparation, and listing-make up
the site assessment phase of the Superfund  process
(Figure 1-1). The remaining steps in the Superfund
process are the remedial investigation/feasibility  study
(RI/FS), Record of Decision (ROD), remedial design/
remedial  action  (RD/RA),  and  operation and
maintenance (O&M) (Figure 1-2). Under Superfund's
removal authority, the RI may start at any time during
   The "Site Evaluation Accomplished" (SEA)
   recommendation replaced the  "No Further
   Remedial  Action Planned"  (NFRAP)
   recommendation  (see  Henry Longest
   Memorandum,  May 11, 1992).    A SEA
   recommendation denotes that, to the best of its
   knowledge, EPA has completed its assessment
   at a site and has determined that no further
   steps to list the site on the NPL will be taken
   unless information indicating that this decision
   was not appropriate make a recommendation
   for listing appropriate  at a later time. The
   CERCLIS qualifier remains "N" as it was for
   NFRAP.    The "NFA" indicator in the
   CERCLIS List.8 Report  was changed to
   "SEA."              P              S
the site assessment. The RA for Fund-lead sites,
however, can begin only after a site is on the NPL.

Sites  placed on the  NPL are subject to  further
investigation  during the  remedial phase.  The
objective of the remedial  phase is to eliminate,
reduce, or otherwise control risks to human health and
the environment.   The  steps for  selection  and
implementation of a  remedy include the remedial
investigation, feasibility study, record of decision,
remedial design, and remedial action.

At  any time during  the site assessment  process,
conditions at the site may warrant removal  actions.
Removal actions, as defined in CERCLA Section 104,
                         FIGURE  1-1: SITE ASSESSMENT IN SUPERFUND
Discovery
w
w
CERCLIS
. fe
w
Preliminary
Assessment
(PA)
k
W
Focused
Site
Inspection
(SI)
_t
r
Expanded
Site
Inspection
(ESI)
^
W
Hazard
Ranking
System (HRS)
Package
^
-F
National
Priorities
List
(NPL)
                                   i	i
                                   SEA (Information provided to States and other regulatory authorities)
                                 Sites may be referred for removal actions at any stage

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Introduction
                                                                Site Inspection Guidance
                      FIGURE 1-2: THE REMEDIAL PHASE OF SUPERFUND
        Remedial
      Investigation/
    Feasibility Study
         (RI/FS)
                      Record of
                      Decision
                        (ROD)
Remedial Design/
 Remedial Action
     (RD/RA)
Operation and
 Maintenance
    (O&M)
  K
Sites may be referred for removal actions at any stage
are actions taken to eliminate, control, or otherwise
mitigate a threat posed to public health or  the
environment due to a release or threatened release of
hazardous substances.

EPA has developed a new model for streamlining  and
accelerating the Superfund program, the Superfund
Accelerated  Cleanup  Model  (SACM)  (OSWER
Directives 9203.1-01, April 7, 1992 and 9203.1-03,
July 7, 1992). SACM includes an integrated approach
for site assessment. SACM implementation will
change the structure and goals of the SI, but the
content of the data collected will not change. The
principles of site assessment and the concept of the
focused SI contained in this document are quite
consistent with SACM.

1.1.1 Preliminary Assessment

The  PA distinguishes  sites that  pose little or no
potential threat to human health and the environment
from sites that warrant further investigation. The PA
   The primary objective of the remedial site
   assessment program is to obtain enough data to
   evaluate sites under the  HRS and identify those
   that should be on the NPL. The revised HRS
   requires more data than the original HRS, and
   the site assessment process  has  been
   restructured to balance the need to accurately
   assess site conditions with the need to conserve
   resources.
                                            also fulfills public information needs and supports
                                            emergency response and removal activities  "by
                                            providing specific background information.

                                            The PA is a relatively quick, low-cost compilation of
                                            readily available information about the site and its
                                            surroundings.    The PA  emphasizes identifying
                                            populations and other targets that might be affected
                                            by the site. It includes a reconnaissance of the site
                                            and its  surrounding environment but not sampling.
                                            The simplified approach used for the PA examines
                                            key HRS indicator factors that can be evaluated
                                            within the limited scope of the PA. Factors that are
                                            not critical to the score use reasonable default values
                                            and truncated evaluations.

                                            The PA provides information on:

                                             •  Historical  waste  generation and  disposal
                                                practices
                                             •  Hazardous substances associated with the site
                                             •  Potential sources of hazardous substances
                                             •  Important migration pathways  and affected
                                                media
                                             •  A comprehensive survey of  targets
                                                Critical sample locations for the SI

                                            PA scoresheets identify critical HRS factors  and
                                            provide instruction for their evaluation. Professional
                                            judgments made during the PA form the foundation
                                            for hypotheses that are tested during the SI.

                                            Data important to the HRS may not be available
                                            during the PA—for example,  analytical data on

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Site Inspection Guidance
                                   Introduction
hazardous substance releases and targets exposed to
actual contamination. For these factors, the site
investigator exercises professional judgment applied
in a reasonable and consistent manner  to  form
hypotheses regarding the likelihood of release of
hazardous substances and their migration to targets.

1.1.2  Site inspection

Generally, the SI is the first investigation to collect
and analyze waste  and environmental samples to
support a site evaluation according to the HRS. SI
sample locations are strategically planned to identify
the substances present, determine whether hazardous
substances are being released to the environment, and
determine  whether  hazardous substances  have
impacted specific targets. At  the end of the SI, the
investigator submits findings to EPA Regional and
State  officials who  decide whether the site should
undergo further investigation (resulting in possible
NPL placement) or be  dropped from further Federal
Superfund consideration.

PA recommendations for further investigation may be
based  on  a  suspected  threat  without analytical
documentation, since field samples are not taken. If,
after sampling to test PA hypotheses, the site is found
to present no significant threats to human health or
the environment the SI serves as a second screening
investigation.

When  initial site samples verify some or all PA
hypotheses, or  other  data indicate the site poses a
sufficient threat to warrant NPL consideration, the SI
must be comprehensive and support HRS package
preparation,

Often the scope of an  SI can be limited to screening
the site to confirm that it has no reasonable chance
for placement  on  the  NPL. A few strategically
located samples may be enough to indicate that no
further Superfund action needs to be planned. In such
a case, collecting all information needed  for HRS
scoring is unnecessary. Instead, if critical questions
remain after the PA regarding contamination that a
few strategically placed samples could answer, the SI
investigator can efficiently focus on those questions to
determine  how serious the threat posed by the site
may be. This guidance manual refers to this type of
SI as  a focused SI.
At  some  sites, source, release,  and  target
contamination  are known  during the PA from
previous sampling investigations. Samples that focus
on identifying substances and critical contamination to
screen the site are not necessary. Instead, the scope
of the SI is expanded to fully characterize the most
significant threats posed by the site. An expanded SI
should not result in a SEA recommendation;  the
option to perform an expanded SI should be reserved
for sites that appear to qualify for the NPL.

An efficient way to fulfill both the screening and
listing functions  of the SI  is  to conduct  the
investigation in two parts: as screening (focused SI)
and follow  up,   larger scale  (expanded   SI)
investigations.  Alternatively, the focused SI may
collect enough  information to document the HRS
evaluation. And, as a final option,  a single  SI,
generally  expanded in  scope, may  satisfy HRS
requirements without a screening stage.

Generally, the focused SI allows the investigator to
determine  if the site  qualifies for the NPL or to
support a SEA recommendation by testing  PA
hypotheses. It may be possible to prepare the HRS
scoring package after the  focused SI. However, most
sites that are proposed for the NPL will require an
expanded SI to  complete sample and data collection
to support an HRS package.  Chapter 2 provides
guidance on selecting an SI approach.

The SI consists of four major activities:

  1)     Review available information, including
        analytical data.
  2)     Organize project team and develop SI work
        plan, sample plan, health and safety plan,
        and investigation-derived wastes (TDW) plan.
  3)     Perform field work to visually inspect the
        site and collect samples.
  4)     Evaluate all data  and prepare the SI report.

For some sites, the SI may involve additional tasks to
help meet SI objectives and support  HRS data
requirements and emergency response  and remedial
efforts (see Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA,
OSWER Directive 9355.3-01).

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 Introduction
                     Site Inspection Guidance
   National  Contingency  Plan (NCP)  Section
   300.420(c)  (55 FR 8845) establishes  two
   Primary goals for the SI:

     •   To collect additional data to evaluate sites
        using the HRS, and
     •   To screen out sites that will not score
        high enough for the NPL.

   Other SI goals are to support potential removal
   or enforcement actions and to collect data to
   support  the remedial investigation  and
   feasibility study (if the site is subsequently
   placed on the NPL) or response action under
   other authorities.
Review Available  Information

 Before developing SI plans, the investigator should
 review  results from  previous  investigations,
 particularly analytical data. Site-specific analytical
 data may help guide further sampling, provide data to
 test site hypotheses, and evaluate threats to:

  •  Drinking water wells by migration of hazardous
     substances to ground water;
  •  Drinking  water  intakes by migration  of
     hazardous substances to surface water;
  •  Fisheries  and  sensitive  environments  by
     migration of hazardous substances to surface
     water;
  •  Residents, students, and sensitive environments
     by soil contamination; and
  •  Populations and  sensitive  environments  by
     migration of hazardous substances to air.

 The SI investigator may need to update or reevaluate
 the basis of the screening decision for certain sites,
 for example, at sites with a PA not based on the
 revised HRS and at  certain sites with an SI completed
 before 1989  where no decision has been made.
 Approximately 40  to 100 additional hours may be
 needed to
 •   Formulate  hypotheses  regarding  projected
     hazardous substance releases and targets
     suspected to be exposed to actual contamination.
  •  Document the findings in a narrative report and
     scoresheets (or deliverables specified  by the
     Region or State).

The investigator should develop SI plans if the site
warrants an SI (i.e., site score is greater than or equal
to  28.50).

Organize  Project Team  and  Develop  Plans

After reviewing the assignment and the site data, the
project team should be organized.  A project team
consists of administrative, scientific, technical, and
field personnel with specific responsibilities  contained
in the plans. The team includes the project manager,
field sampling personnel, health and safety officer,
chemist, geologist, and subcontract administrator,
among others.   The project manager, generally
referred to as the SI investigator in this  guidance
document, coordinate all project  activities.  This
includes directing planning activities, managing day-
to-day SI tasks, and ensuring that all field activities
are documented.    The  field team supports  plan
development prior to conducting  site work, as well as
reconnaissance and field preparation activities. Upon
completing field work, the team  documents all field
activities.

Most SI field teams  require a  minimum of four
persons, including the health and safety officer,
chemist, geologist, and subcontract administrator.
The health and safety officer prepares the health and
safety plan, ensures staff certification, reviews safety
equipment checklists, and monitors health and safety
procedures during the SI. The chemist performs field
screening, recommends  analytical services, and
interprets and validates analytical data. The geologist
evaluates hydrogeological information, interprets other
geological data, and supervises geophysical activities.
The  subcontract  administrator  prepares  bid
specifications and procures  and schedules  special
analytical  services, drilling  operations, and  data
validation contracts.
     Gather the information necessary to update the
     PA evaluation.
After  evaluating  previous results  and  all other
pertinent information, the SI investigator prepares four
plans to document SI procedures:

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Site Inspection Guidance
                                   Introduction
  • Work plan
  • Sample  plan
  • Heath and safety plan
  • IDW management plan

These plans ensure thorough planning before field
activities begin.    Clear and concise plans are
prerequisites for obtaining quality analytical data and
making reliable conclusions.

The design of the work plan and sample plan is based
on the objectives of the SI and I-IRS requirements.
The sample  plan includes justification for proposed
sample locations and explicit instructions for sample
collection.    Health and safety plans describe
procedures to protect workers according to specific
standard operating procedures (SOPS). An IDW
management plan is prepared in accordance with
Management of Investigation-Derived Wastes During
Site Inspections  (OERR Directive  9345.3-02).

Chapter 3 of this  document provides a detailed
discussion of SI planning.

Perform Field Work

SI field  work  involves site reconnaissance, field
observations and measurements, sampling, and health
and safety monitoring.

A site reconnaissance (see Section 3.7) is conducted
before field work begins to examine site and  source
conditions and to verify the practicality of sample
locations.    Sample analysis should be scheduled
before field work begins.

SI field work typically takes two to six days. Typical
field  activities  include;   1) completing field
observations and site and pathway sketches that
accurately identify sample locations; 2) locating and
measuring  distances to targts;  3)  evaluating
populations near the site; 4) collecting samples  of
source materials at the site and environmental media
that may impact human and environmental receptors;
5) completing decontamination procedures;  and 6)
packaging and shipping samples to the laboratory for
analysis. Field work may take longer for very large
sites, sites with several sources, or expanded SI sites
requiring installation of ground water monitoring
wells. Chapter 4 discusses sampling strategies for the
focused SI and expanded SI.

Evaluate Data

The investigator should assemble and summarize all
data to evaluate the site. SI sample results should
allow the investigator to evaluate

  •   Site and source characteristics;
  •   Presence of contamination for specific HRS
     pathways; and
  •   Targets actually or potentially  exposed to
     contamination for specific HRS pathways.

Chapter 5 discusses evaluating SI data.

Per Regional and State instructions, an HRS score is
developed after the site data are evaluated. Three
types of scoring tools are available EPA's PREscore
computer program; SI worksheets; and other
evaluation tools developed by EPA Regional or State
Offices.

The investigator must prepare a narrative report
highlighting significant findings, including the history
and nature  of waste handling at the site, known
hazardous substances, pathways of concern for these
substances,   and  the  impact  on  human  and
environmental targets.

Other deliverables, as directed by EPA Regional or
State officials, may include a summary record of the
SI data (see Appendix B).  Chapter 6 discusses SI
reporting requirements.

Based on the conclusions of the SI, EPA makes one
of three site decisions:

  •   Site evaluation accomplished (SEA);
  •   Further investigation or
  •   Schedule preparation of the HRS package if all
     necessary data are available.

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Site Inspection Guidance
                                SI Approaches
                                          CHAPTER  2
                                      SI  APPROACHES
   This chapter discusses approaches for conducting an SI. These include the focused SI, expanded SI, and single
   SI options. The focused SI tests PA hypotheses requiring further investigation and may be used to screen sites
   to determine the need for further Federal Superfund action. The expanded SI gathers information to fulfill
   HRS requirements for sites with a high probability of qualifying for the NPL. The single SI approach
   combines the functions of the focused and expanded Sis and may be chosen under certain conditions.
2.1  FOCUSED SI

The goal of the focused SI is to obtain and analyze
environmental samples, to investigate human and
environmental exposure to hazardous substances, and
to test PA hypotheses that are the basis of the further
action conclusion. Any of the following hypotheses,
or any combination of them, can result in a PA
further action decision.

  •  Release and migration (or threatened release) of
     a hazardous substance to drinking water wells or
     intakes.
  •  Release and migration of a hazardous substance
     to  surface  water  sensitive  environments  or
     fisheries.
  •  Presence of a hazardous substance on residential,
     school, or day care properties or terrestrial
     sensitive environments.
  •   Release of a hazardous substance into the air.

Because these hypotheses  are often based on
professional judgement rather than analytical data, the
focused SI emphasizes obtaining critical analytical
data of waste and environmental samples  that are
usually not  available during the PA. The focused SI
should reflect  the HRS  significance of hazardous
substance migration from sources at  the  site and
contamination of targets.

As an  example  of how to test  a PA hypothesis,
consider the following situation:

     The PA for ZZ Metals, an abandoned
     plating facility, revealed that the only
     significant target is a shallow community
     well serving 50 people located 800  feet
     south of the site. PA investigators suspect
     that hazardous substances have migrated to
     this well, although no recent sample data
     are available to test this hypothesis.

The focused SI for ZZ Metals must include samples
to test the PA hypothesis of contamination at the
community well.   Theoretically, this site could be
screened from further Federal Superfund investigation
by collecting  only one  sample from the well. If
hazardous substances  are not  detected in that sample,
the site would not  score high  enough for NPL
consideration, regardless of other HRS scoring
factors, such  as waste  characteristics.  However,
additional sampling will increase  the  degree of
confidence in the conclusion and better characterize
the site.  Additional samples, for example from
private wells, may be necessary to investigate public
health and human exposure, even if contamination in
those wells alone would not result in an HRS score
greater  than or equal to 28.50.

Collecting samples to characterize sources  helps
determine whether hazardous substances are actually
associated with the site.    Where a hazardous
substance problem exists, source sampling identifies
the specific substances at the site. If only low levels
of hazardous substances are detected, investigators
will have more confidence  using other analytical
results  (e.g., from an uncontaminated community
well)  to screen the site. Conversely, if a specific
hazardous substance is found in both the community
well and  site sources, target contamination  can
tentatively be attributed to the site.

The focused SI typically requires 12 to 20 samples
(average 15) to investigate PA hypotheses of target

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SI Approaches
                     Site Inspection Guidance
contamination and to determine the types  of
hazardous substances present at a site. The scope of
a focused SI is defined by the  number of critical
hypotheses and questions remaining after the PA and
the number of pathways contributing to the further
action recommendation.

Conclusively attributing target contamination to the
site or establishing the range of background levels for
substances of concern are not necessary to test critical
PA hypotheses and screen the site. The number of
focused SI samples is typically less than the number
of samples required to detect all hazardous substances
present and to definitively attribute them to the site.
More background, quality assurance, and quality
control (QA/QC) samples may be needed to  support
HRS attribution requirements.

The hours to complete the focused SI varies with the
amount of information available from the PA and the
complexity of the site.   On average, 350  to 450
technical hours are sufficient (Table 2-1). Most time
will be spent preparing for the sampling visit and
collecting samples in the field. At sites where the PA
was conducted using the original HRS, additional
hours will be necessary to update PA information and
evaluate the site based on the revised HRS.

The investigator provides information to EPA officials
at the end of the focused SI so that they may make
one of three site disposition decisions:

  • Site Evaluation Accomplished;
  •   Further action (e.g., expanded SI); or
  •   Schedule HRS  package preparation if all
     necessary data are available.

To  make a site disposition  decision,  EPA  site
assessment managers (SAMs) consider all data in
light of the SI sample results to refine the site score
developed at the PA.  SAMs typically use EPA's
PKEscore computer  program or SI worksheets to
generate the site score for the focused SI. If PA
hypotheses are confirmed, the SI site score will be
high  enough to warrant the  expanded SI  or
preparation  of the HRS package, since the threat or
potential threat to human health or the environment
can now be  established. Otherwise, the site can be
eliminated from further Superfund  consideration at
this time.

In most cases, a focused SI site score greater than
28.50 will approximate or represent  a complete HRS
site  score that will be high enough for NPL
consideration.   However, in some instances,  the
focused SI score may be based on assumptions that
have not been fully explored within the limited scope
of a focused  SI. Further investigation may change the
site decision from further action to SEA. This can
occur, for example, when hazardous substances
detected during the focused SI at target locations are
presumed to be from  the site, but samples during the
expanded SI reveal they are not attributable to the
site. If attribution to the site is questionable  or levels
of contamination are very low, site  assessment staff
experienced in the HRS should review the analytical
                     TABLE 2-1: HOURS TO COMPLETE FOCUSED SI TASKS
Task
PA review and work and sample plan development
Mobilization, travel, and demobilization
(1 to 3 days, 3 to 5 team members)
Sampling and data collection
(generally not for all four pathways)
Report preparation, HRS evaluation, and reviews
Total
Hours
50
150
120
80
400
Percent
12.5
37.5
30.0
20.0
100.0
                                                  10

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Site Inspection Guidance
                               SI Approaches
results and site score to make sure an expanded SI is
warranted. This review also will help define activities
and objectives for the expanded SI.

2.2  EXPANDED  SI

The objective of the expanded SI is to collect all data
necessary to prepare an HRS scoring package to
propose the site to the NPL. To fully evaluate the
site and to fulfill HRS  package  documentation
requirements, the SI investigator should

  •  Investigate and document critical hypotheses or
    assumptions not completely tested during the
    focused SI.
  •  Collect  samples   to attribute hazardous
    substances to site operations.
  •  Collect samples to  establish representative
    background levels.
  •  Collect  any other  missing HRS  data  for
    pathways of concern.

When  environmental samples do  not provide the
information   needed for HRS  documentation
requirements, investigators also may need to perform
special field  activities.    The  purpose  of these
procedures, which are beyond the screening scope of
the focused SI, is to supply data to refine and
document the site score. Special expanded SI field
activities may include monitoring well installation, air
sampling, geophysical studies, drum or tank sampling,
borehole installation, and complex  background
sampling studies.
The expanded SI typically requires 25 to 35 samples
(average 30) and 600 to 650 technical hours (Table 2-
2). The complexity of the site  and the need for
special procedures will determine the scope of the
investigation and whether additional technical hours
are required.

Sampling during the expanded SI should be designed
to support and document HRS requirements, including
1) observed releases of harzardous substances  relative
to background, 2) observed contamination, and 3)
levels of contamination.    The expanded  SI
investigator should collect a complete set of QA/QC
and background samples to fully and confidently
document and attribute releases to the site.

To illustrate the difference between expanded SI and
focused SI sampling, again consider the ZZ Metals
Site

    Focused SI sampling results showed high
    levels of phenol in the community well
    800 feet south of the site and in sources  at
    the site.   However, wastes containing
    phenol are also associated with a second
    facility 600 feet  southeast of the
    community well.

The  expanded  SI should  investigate whether
contamination  in the community  well can  be
attributed to ZZ Metals. This would require sampling
selected wells located between ZZ Metals and the
community well, plus additional wells between the
                    TABLE 2-2: HOURS TO COMPLETE EXPANDED SI TASKS
Task
Previous investigation review (PA, focused SI) and work and
sample plan development
Mobilization, travel, and demobilization
(2 to 3 days, 5 team members)
Sampling and data collection
(generally not for all four pathways)
Report preparation, HRS evaluation, and reviews
Total
Hours
130
150
240
100
620
Percent
20
25
40
15
100
                                                 11

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SI Approaches
                     Site inspection Guidance
   An expanded SI is not necessarily larger in
   scope than a focused SI. The  scope of  an
   expanded SI depends on the HRS data gaps
   remaining after all previous investigations.
community well and the second facility. If no wells
exist in these areas, ground water monitoring wells
should be installed to determine whether ZZ Metals is
contributing, at least partially, to the contamination of
the community well.

The expanded SI also differs from the focused SI by
emphasizing collection of all missing non-sampling
information for pathways of concern. These data may
be used to support  previous documentation or
references, fulfill remaining HRS data requirements,
and identify other sources of contamination in the site
vicinity.    Table 2-3 compares focused  SI and
expanded SI data collection activities.

At the  end of  the expanded SI,  the investigator
prepares a report of all expanded SI findings and
analytical  results.   Per EPA Regional and State
instructions, the investigator should evaluate all site
data according to the HRS. If the site is to be
proposed for the NPL, assembling an HRS package
will be scheduled. The HRS package consists of the
HRS documentation record, reference materials, HRS
scoresheets, and site narrative summary along with
other administrative requirements as specified in
Regional Quality  Control Guidance  for NPL
Candidate Sites (OSWER Directive 9345.1-03, 1991).
Preparing the HRS package is not part of SI activities;
however, all data necessary to  document an HRS
score should be collected during  the expanded SI.

2.3  SINGLE SI  APPROACH

Investigators may consider performing a  single SI if
the quality of available data and site characteristics
strongly indicate a significant threat.   Another
consideration to perform a single SI is whether all
data necessary to document an HRS score  can be
collected efficiently at one time.  A complex site may
require a two-stage field investigation even if it is
clearly  an NPL candidate. For such a case,  the
investigator should restrict the scope of the focused SI
to obtaining data needed to support efficient future
sampling and to address HRS documentation
requirements.
                     TABLE 2-3: TYPICAL SI DATA COLLECTION Activities
Activity
Non-sampling data collection
Target sampling
Source sampling
Release sampling
Background sampling
Attribution sampling
QA/QC sampling
Special data collection or sampling tasks
Focused SI
/
//
//
/
/
—
/
—
Expanded and
Single SI
/
//
//
//
//
//
//
if necessary
KEY: // = Major activity
/ = Minor activity
                                                  12

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Site Inspection Guidance
                                SI Approaches
If the  complexity of the  site does not preclude a
single phase field investigation, and if previous data
fulfill the screening functions of the focused SI and
indicate that the site will score high enough for NPL
consideration,  the  focused SI may be bypassed.
However, if conclusions are drawn exclusively from
sample results, the investigator must be sure that
previous analytical data are of sufficient quality to
support the conclusions (see Section 3.5.2). Sample
locations, sampling protocols, analyzed substances,
and data validation procedures all influence how
previous analytical data can be used at the SI (e.g, for
HRS  scoring,  testing PA  hypotheses, sample
planning). Figure 2-1 outlines basic selection criteria
for a single  SI. Site conditions consistent  with a
single field investigation are discussed below.

Sites with  Available Analytical Data:   Municipal,
county, State,  or Federal authorities  may have
conducted prior sampling investigations at some sites.
The effect this information may have on the scope of
the SI depends on their quality (see Guidance for
Data Useability in Site Assessment, in development)
and whether they support or refute PA hypotheses. If
previous analytical data clearly demonstrate that the
site score will be high enough  for NPL consideration,
a single SI  may be conducted, unless the complexity
of the site dictates iterative sampling.

"Simple" Sites: Some sites have characteristics that
simplify the HRS evaluation. For "simple"  sites, it
may be possible to compile all data necessary to
prepare an  HRS package (i.e., expanded SI objective)
within the  focused SI sampling budget. This  is true
for sites with:
 •   Well-defined source and waste characteristics
 •   No other potential  sources of contamination in
     the area
 •   One pathway of concern
 •   Few targets requiring sampling

In a few cases, even in the absence of analytical data,
site characteristics are well-defined at the PA stage.
These sites may qualify  for NPL consideration with
limited sampling. For example, if the site historically
operated as a wood treatment facility and is located
immediately adjacent  to surface water used by
fishermen, a single investigation may be a reasonable
approach. In  this situation, it may  be possible to
characterize threats to the surface water pathway with
a relatively limited investigation.

Remote Sites: Investigations at some sites require
considerable travel because of remote locations.
Travel-related activities  often account for as much as
40 percent of the budget for such investigations. At
sufficiently remote sites, a  single SI may be cost-
effective,  provided a second site visit will not be
necessary later to  collect missing data.

Potential  Contamination Sites:   Some sites are
recommended for further action after  the PA  because
the targets subject to potential contamination are
significant. If available information indicates a strong
likelihood of a release, the  focused SI  may be
bypassed if the site score will be high enough for
NPL consideration based on potential to release or an
observed  release  only (as  opposed to  actual
contamination).
                                                   13

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SI Approaches
Site inspection Guidance
                        FIGURE 2-1: SITE INSPECTION DECISION TREE
                                           Regional
                                           Evaluation
                                             PA
                                         or Equivalent
                                                                   Review Data from PA and
                                                                    Previous Investigations
                                                                          Does Site
                                                                         Meet Criteria
                                                                       for the Expanded
                                                                         or Single SI?
                                           Regional
                                           Evaluation
                                             Does
                                           Existing
                                        Information (Incl
                                        Analytical Data)
                                          Support MRS
                                             Score
                                           £28.50?
                                                14

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Site Inspection Guidance
                                      Planning
                                          CHAPTER 3
                                           PLANNING
   Each SI requires a site-specific work plan, sample plan, health and safety plan, and investigation-derived
   wastes (IDW) plan. These plans help investigators adhere to planned procedures in their field work and
   identify potential sources of error that could jeopardize the quality of analytical data. Specific plans also
   facilitate the investigation by defining the activities that will produce information needed to meet SI objectives.
   This chapter discusses key elements to consider in SI planning and provides background information on sample
   collection issues to help design the SI and assess the usability of available data. This chapter also provides
   guidance on SI project management and on site reconnaissance. Special guidance on SI planning for sites
   containing radioactive substances is provided at the end of the chapter.
3.1  SAMPLE COLLECTION ISSUES

The SI collects selective samples to demonstrate that
hazardous substances are present and to determine
whether they have migrated from their original
locations. The SI differs from traditional approaches
to environmental monitoring, for which samples are
collected to represent "average" contamination in the
environment. For SI selective and limited sampling,
careful planning for data collection is essential to
avoid sampling errors.

When sampling is  limited, the probability of false
negatives in samples increases.  "False negative"
means a hazardous substance is present but  not
detected. The potential for false negatives in samples
underscores the importance of a well-designed sample
plan for the site. Conclusions based on false negative
data may result in decisions that do not protect human
health and the environment. False positive samples—
a substance is detected but is not present at the site-
are also undesirable;  however, they often can  be
identified by evaluating quality control sample  results.
The  frequency of false positives  is  normally
influenced by sampling and analytical procedures, and
not by the sampling approach.

This section provides information on sample types
and sample variability that will help the investigator
design and implement an effective sample plan.
3.1.1 Sample  Types

Normally, SI  sampling strategies  require  biased
sampling, also  known as non-random or judgmental
sampling. Biased sampling uses knowledge of the
site and visual  observations to propose sample types
and locations.  Table 3-1 summarizes sample types
and their advantages and disadvantages.

SI samples are generally waste source samples or
media (environmental) samples. Most SI samples are
media samples of ground water, surface water, soil, or
air. Analytical  data from media samples indicate the
presence or absence of hazardous substances released
to the environment, exposure of humans to hazardous
chemicals, or  contamination of the environment.
Because concentrations of hazardous substances in
media  samples may have  been diluted  by
environmental influences, proper sampling procedures
are particularly important-even minimal sample
contamination or loss  could  significantly  affect
analytical results.   Source sample results identify
hazardous substances present and support attribution
of contamination to site operations.

The SI  sample plan may specify several types of
samples. Grab  samples represent chemical conditions
at  a  specific  location.    They  offer  the most
information regarding hazardous substance variability
and are  recommended to investigate observed releases
                                                  15

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Planning
Site Inspection Guidance
                          TABLE 3-1: TYPES OF SAMPLES
SAMPLE TYPE
Biased
(non-random,
judgmental)
Unbiased
(random,
systematic
grid)
Grab
Composite
Media
Waste
Filtered
Unfiltered
ADVANTAGES
Promotes timeliness
Uses knowledge of site
Focuses sampling effort
Increases representativeness
Reduces chance of false negatives
Allows limited site knowledge
Increases representativeness and
variability
Reduces cost
Increases area of investigation
Reduces chance of false positives
Supports releases
Supports target contamination
Optimizes contaminant identification
Supports attribution
Allows comparison with drinking water
benchmarks
Allows comparison with surface water
environmental benchmarks
DISADVANTAGES
Decreases representativeness
Increases chance of false negatives
Increases cost
Increases time required
Requires more samples
Requires careful placement
Provides average concentrations only
Allows substances to interact
May require off-site access permits
Subject to temporal variation
May result in elevated concentrations
May require sample dilution
May require special procedures and
equipment
Comparison with surface water
environmental benchmarks not valid
May increase sample handling errors
Comparison with drinking water
benchmarks not valid
                                        16

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Site inspection Guidance
                                     Pianning
and target exposure to contamination. Composite
samples consisting of several grab samples represent
average concentration values and may be used to
identify hazardous substances present in sources.

Aqueous samples may be filtered or unfiltered. Most
samples collected during the SI are unfiltered (see
Table 3-2). Because laboratory analysis of unfiltered
samples  can  release metals loosely  bound to
suspended solids in water, metal concentrations can
be overestimated. For this reason, faltered samples
are recommended to establish an observed release of
metals in a drinking water supply, although either
filtered or unfiltered samples are acceptable. Even
highly turbid filtered water samples can be compared
to health-based drinking water regulatory standards,
such as Maximum Contaminant Levels (MCLs).

Monitoring well and  surface water environmental
target aqueous samples should not be filtered in the
field, unless they are to be  compared to faltered
samples to establish  observed releases.  Likewise,
filtering is not  needed  when establishing  actual
contamination of a drinking water supply by organics.
Therefore, when  the  full  range of hazardous
substances at a site  is  unknown, collecting both
filtered and unfiltered water samples may be
warranted. Hazard Ranking System (HRS) Guidance
Manual and Guidance for  Data Usability in Site
Assessment (both in development) may provide more
information on using filtered or unfiltered water
samples for HRS scoring.

3.1.2 Sample Variability

The sample plan should minimize the potential for
errors related to  sampling procedures.    Errors
resulting from improper sampling are often several
times more significant than errors introduced by
analytical procedures. To minimize these errors, the
investigator should:  adhere to standard operating
procedures (SOPS);  choose appropriate sampling
equipment, containers, and preservatives; and plan the
sequence of, and schedule for, sample collection.

Samples may reflect variability in collecting and
handling samples,   or variability  of  hazardous
substances with location, time, or medium.

Sample Collection and Handling Variability

Errors introduced by sample collection and handling
variability can change sample concentrations due  to
incorrect sampling procedures, cross-contamination,
and improper sample preservation. Variability caused
by error can be reduced through training and by
performing all sampling activities in accordance with
SOPS. Adhering to SOPS can reduce or eliminate
                   TABLE 3-2: FILTERED AND Unfiltered WATER SAMPLES
HRS PATHWAY/
THREAT
Ground Water
Surface Water
Drinking Water
Threat
Environmental
Threat
METALS ANALYSIS
Filtered/Unfiltered
Filtered/Unfiltered
Filtered when compared
with MCLs, MCLGs1, and
Screening Concentrations
Unfiltered when compared
with AWQCs2 and
AALACs3
ORGANIC
ANALYSIS
Unfiltered
Unfiltered
Unfiltered
Unfiltered
SAMPLES FROM
KARST AQUIFERS
Unfiltered
Not Applicable
Not Applicable
Not Applicable
'MCLG — Maximum Contaminant Level Goals
2AWQC — Ambient Water Quality Criteria
'AALAC — Ambient Aquatic Life Advisory Concentrations
                                                 17

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Planning
                    Site Inspection Guidance
variability within  and between  sites for a given
sampling method. Collection and handling errors can
rarely be corrected without additional sampling and
analysis.   Before implementing any non-standard
procedure, the investigator must  assess  whether
changes may jeopardize data quality.

Potential contamination problems  attributable to
sampling devices, sample containers, or construction
materials include cross-contamination, hazardous
substance sorption, and chemical leaching (see Table
3-3). The importance of decontamination increases
when investigating barely detectable concentrations.
By planning carefully, the investigator can reduce and
possibly eliminate contamination. In particular, the SI
investigator should remember that polyvinyl chloride
(PVC) and other plastics (except Teflon®) tend to
absorb organics, and that some halogenated organic
compounds and pesticides adsorb to  glass surfaces.

Contamination from  substances  leaching  from
sampling or monitoring equipment is a particular
problem in water samples and may contribute to false
negative or false positive results. Contaminants may
have analytical interference effects, decreasing or
even preventing quantification of the substances of
concern. If any samples have been contaminated by
equipment, resampling may be needed. Equipment
decontamination is particularly important following
sampling in areas of suspected high concentrations of
hazardous substances. When possible, background
and media samples should be collected before waste
or source samples.

Confirming the purity of preservatives is important in
planning. Contaminated, outdated, or improperly
stored preservatives can place analytical results
outside the limits of random error.

Holding  time-how long a sample can be stored
before preparation and analysis without significantly
affecting the analytical results-will vary from sample
to sample, depending on the substance, preservation
technique, and analytical method.

Spatial Variability

Spatial  variability-how  substances  and  their
concentrations vary from one location to another—
depends  on the substance and site conditions. As a
general rule, variability increases as a source becomes
less uniform. In some media, such as soils, spatial
variability  can be significant. Potential sampling
problems due to spatial variation can be significantly
   TABLE 3-3:  POTENTIAL CONTAMINANTS FROM SAMPLING DEVICES AND WELL CASINGS
MATERIAL
Rigid PVC-threaded joints
Rigid PVC-cemented joints
Flexible or rigid Teflon® tubing
Flexible polypropylene tubing
Flexible PVC tubing
Soldered pipes
Stainless steel containers
Glass containers
POTENTIAL CONTAMINANTS
Chloroform
Methyl ethyl ketone, toluene, acetone, benzene, methylene
chloride, organic tin compounds, tetrahydrofuran, ethyl
acetate, cyclohexanone, vinyl chloride
None detectable
None detectable
Phthalate esters, other plasticizers
Tin and lead
Chromium, iron, nickel, molybdenum
Boron, silicon
Source: Keith, 1991
                                                  18

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Site Inspection Guidance
                                                                                         Planning
reduced by  using previous site information and
professional judgment in choosing sample locations.
Chapter 4 provides guidance in selecting locations.

For homogeneous sources (e.g., single phase liquid in
a tank), spatial variability is reduced, and limited
sampling to determine hazardous  constituent  or
wastestream  quantity  may  be  appropriate.
Representative sampling  to determine the HRS
hazardous constituent quantity at  heterogeneous
sources is generally not within the scope of an SI.

Temporal Variability

Hazardous substance concentrations may depend on
variables such as the time of day or season of the
year. Often the most important temporal variable is
weather (i.e., temperature or rainfall).   Because
weather follows cyclical patterns over a day or year,
time-dependent substance levels are expected  to
follow  similar cyclical patterns. The investigator
should identify the cyclical nature of the substance
concentrations caused by temporal variability and
sample when concentrations are expected to be
highest.   For example, during  colder weather a
volatile compound may be less readily released than
during warmer weather.

For Sis, the duration and frequency of sampling are
normally not a  consideration, because one-time
sampling usually  accomplishes the objectives of the
investigation. In some instances, however, seasonal
variations or weather patterns may require more than
one sampling episode.

Media  Variability

Sampling concerns vary according to medium (see
Table 3-4). Each of the variability  concerns discussed
above may be affected by the particular medium
      TABLE 3-4: SAMPLING ISSUES AFFECTING CONFIDENCE IN ANALYTICAL RESULTS
MAJOR AQUATIC
SAMPLING SOIL/ GROUND SURFACE ANIMAL SOURCE
ISSUES SEDIMENT WATER WATER AIR TISSUE MATERIAL
Hazardous Substance
Migration
Temporal Variation
Spatial Variation
Topographic and
Geological Features
Hot Spots
Sample Collection
Sample Preparation
and Handling
Sample Storage
Sample Preservation
//
—
//
//
//
/
//
—
—
	
/
—
//
—
/
//
//
//
/
//
//
_
—
//
//
//
//
/
//
/
/
—
//
//
//
—
_
/
—
	
—
//
//
//
//
//
—
//
	
//
/
/
—
—
Key: SS= Likely source of significant sampling problem
/ = Potential source of sampling problem
Source: Modified from Keith, 1990
                                                19

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Planning
                     Site inspection Guidance
being examined. Sensitivity, precision, and accuracy
of the analysis also are potentially affected by the
medium.

For heterogeneous media (e.g., soil, surface water),
strata should be defined and samples specified by
stratum.   Media heterogeneity influences both the
sampling strategy and data usability.

Surface Water and Ground Water Samples:   The
heterogeneous nature  of water  often  results  in
stratification of hazardous substances  and requires
special sampling and handling procedures. In deeper
surface waters, flow may  be reduced, resulting in
chemical and thermal stratification. Stratification also
may occur in lake and ocean samples and in locations
where mixing occurs, such as the convergence of two
streams or estuarine or near-shore environments.
Density and solubility characteristics also can result in
stratification. Some liquids, such as  halogenated
organic compounds, are heavier than water and will
sink, while others, such  as oils and solids, are lighter
than water and tend to  float on or near the surface.
Surface water collected at the surface should not be
compared to samples collected at depth. Samples
collected in a tidally influenced area  must not be
compared to  samples collected  in fresh water.
Aqueous  samples must not be compared to sediment
samples.

Background and environmental samples must be
similar.    For the ground water pathway, water
samples should be  collected from the same aquifer
and at approximately the same depth (elevation) in the
aquifer. Differences in physical parameters (such as
iron content or pH) may indicate that samples have
been collected from different aquifers. Since different
aquifers can have very different contamination  levels
and  water chemistry,  background wells used to
establish observed releases must be screened in the
same aquifer.    Interconnected  aquifers are not
considered as one aquifer under the  HRS, and
samples from one  aquifer generally should not be
compared to samples from an interconnected aquifer
to establish an observed release.

Sampling devices  should  be selected to minimize
aeration  of the water sample, thereby reducing
volatilization or oxidation  of hazardous  substances.
Aeration is a common problem when bailers are used
to sample wells.   If bailers are  used, water field
blanks are recommended to detect absorption of air
contaminants introduced during sample transfer.

Soil and Sediment Samples:  Heterogeneity of
media size, and distribution of particles, and bias
introduced by sampling and analysis cause variability
in soil and sediment samples. Substantial variability
in a  single soil  type  may  result  from  lateral
heterogeneity, soil horizons, and grain sizes. Primary
soil heterogeneity is due to the parent material, as
well as vegetation, slope, climate, and weathering.
Vertically composite samples may help overcome the
lack of homogeneity in the distribution of chemical
species;  however, peak  values  from  composite
samples may be diluted.

The investigator must document location, depth, and
description of the soil to determine the relationship of
background to other samples. If the depth and
thickness of soil horizons vary with location, the SI
investigator must ensure that samples to be compared
are from the same horizons and soil types.

Air Samples: Atmospheric conditions are always a
concern in air sampling, since some conditions tend
to lower detectable concentrations. Conditions that
may influence air  sample results include

  • Wind speed and direction
  •  Temperature
  •  Relative humidity, including precipitation
  •  Terrain
  •  Atmospheric stability

Air sample results are unusable if wind direction was
not monitored.  Wind speed and direction  data may
be required to establish the migration pattern of
emissions from a source. A  slight  shift  in  wind
direction  can substantially  alter  the amounts of
hazardous substances collected  in an air sample over
a short period of time.

Tissue Samples:  Signficant variations often occur in
sampling human food chain organisms. Differences
between species, variations within the species, species
mobility, and tissue differentiation present unique
challenges. Factors that complicate tissue sampling
include:

  • Type of organism
  « Age of individual
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She Inspection Guidance
                                                                    Planning
  •   Population size
  •   Availability and cost of sampling materials
  •   Migratory organisms
  •   Seasonal, feeding, spawning, or other periodic
     activities that influence concentration or location
     of the substances within an organism

Individual organisms should be chosen at random
from a well-defined population. Documentation
should include the reasoning behind which parts (e.g.,
filet) of the specimen were analyzed and the accuracy
of the measurement.

Containerized Material:  Samples from containers
(e.g., drums, tanks) can be heterogeneous, especially
when different liquids are  present, resulting  in
multiple  layers  of immiscible liquids. Sampling
should be designed to obtain a representative sample
of the liquid at all depths. Composite samples from
various  depths  within the  container may help
overcome the heterogeneity, although hazardous
substance concentrations may be underrepresented. If
peak concentrations of various hazardous substances
are required, several grab samples should be analyzed.
Documenting collection procedures will be important
to evaluate the use of these data.

3.2  FIELD  QA/QC CONSIDERATIONS

Proper field documentation is an important part of the
QA/QC program.   Field documentation includes
                              accounting for procedures or SOPS to record sample
                              locations, label samples, maintain the chain-of-custody
                              process,  and  document field  observations  and
                              measurements, Any deviation from SOPS should be
                              carefully  noted.     Failure  to provide  proper
                              documentation can limit the use of analytical data,
                              contribute to uncertainty in the analytical results, and
                              compromise the legal defensibility of the data.

                              Collection and analysis of QC samples are important
                              aspects of the QA/QC program.    Sampling and
                              analysis provide numerous opportunities for errors
                              that contribute to the uncertainty of analytical results.
                              Field QC samples help evaluate analytical results and
                              field methods. Field QC samples must be collected,
                              stored, transported, and analyzed in the same manner
                              as site samples. The laboratory  analyzing the samples
                              should not  know which are  QC samples. These
                              practices ensure that the QC results  reflect routine
                              procedure and reliably indicate the quality of field
                              methods, analytical methods, and site  sample data.

                              Table 3-5 summarizes field QC samples appropriate
                              for the SI Regional guidelines should be consulted
                              to determine the number and type of QC samples,
                              which may be the following:

                              Co-located or duplicates are  usually two samples
                              collected at  the same time  and location. They  are
                              used as measures of  either the homogeneity of the
                              medium  sampled in a particular location or  the
                              precision  in sampling.
                           TABLE 3-5: TYPICAL SI FIELD QC SAMPLES
  TYPE OF SAMPLE
                                PURPOSE
  Field Duplicate

  Field Blank



  Trip Blank


  Field Rinsate
To estimate medium homogeneity and sampling precision

To estimate bias caused by contamination introduced during field sampling and
laboratory analysis; to compare with laboratory method blank to determine source
of contamination

To estimate bias due to contamination from migration of VOCs into the sample
during shipping from the field and storage at the laboratory

To estimate bias caused by contamination from sampling equipment; to indicate
cross-contamination, poor decontamination procedures, and potential contamination
due to sampling devices
                                                 21

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Planning
                     Site inspection Guidance
   A comprehensive and well-documented quality
   assurance/quality control (QA/QC) program is
   essential to obtain precise and accurate data
   that represent the site and are scientifically and
   legally defensible.
Replicates or splits  are usually one sample that is
divided and sent to the same or separate laboratories
for analysis. Replicates are used to check instrument
precision  and accuracy of a laboratory analysis.
Samples may be split for independent analysis.

Field blanks are samples of contaminant-free medium
that are either transferred from one  container to
another in the field or exposed to field conditions,
These  samples  are used as an indicator of sample
contamination during the entire  process, including
sampling, transport, sample preparation, and analysis.
They are especially critical as concentrations approach
detection limits.

Trip or  transport  blanks  are prepared from
contaminant-free media prior to the SI in extra sample
containers. They are kept unopened with site samples
throughout the  field investigation. They are used to
measure possible contamination,  particularly cross-
contamination, introduced during collection, shipping,
and storage of samples.

Field rinsates (or equipment blanks)   are samples of
deionized water (or the decontamination solution)
flushed through sampling equipment (e.g., bailer,
pump, auger)  after decontamination and before
resampling to monitor decontamination procedures.
Although not  routinely  collected, field  rinsates
analyzed via field analytical screening techniques can
be extremely valuable in indicating  and correcting
cross-contamination during sampling.

Field matrix spikes   are samples prepared in the field
by adding a known amount of contaminants to
selected site samples. They are used to  identify field,
transportation, and  matrix effects.  Because of the
possible sources of error in preparing field spikes,
they are  not recommended  during the SI unless
specialized technical support is available. Any results
should be compared to laboratory matrix spike results.
3.3  HRS SAMPLING
     CONSIDERATIONS

Sample planning should reflect the importance of data
collection in the I-IRS process. The investigator needs
a good understanding of the HRS to develop  an
appropriate sample plan and to improve the quality
and usefulness of SI information. The following HRS
elements require sample data:

Site  and  Source  Characterization:   Analytical data
are important in characterizing sites  and sources,
primarily to identify hazardous substances present in
site sources. Analytical data also support determining
hazardous waste quantity, delineating  source
dimensions, and investigating the degree of source
containment.

Observed Releases  and  Areas  of  Observed
Contamination:  Analytical data may provide direct
evidence of  an  observed  release of hazardous
substances to  affected media, demonstrate significant
contamination (observed contamination in the soil
exposure pathway), estimate areas of contamination,
and show that the contamination is attributable to  the
site.    For  an  observed  release (or  observed
contamination),  significance relates  only to the
concentration found  in a particular pathway or
medium,  not to the environmental or health effects of
that  release.

Levels of Contamination at Specific Targets:
Analytical data  are required to document actual
contamination of targets, including wells and surface
water intakes supplying drinking water; residential
and  school properties; and fisheries, wetlands, and
other sensitive environments.    If data do  not
demonstrate  that targets  are  exposed  to actual
contamination, targets are evaluated as potentially
exposed.  The HRS levels of contamination are:

  •   Level I: Concentrations that meet the criteria
     for actual contamination (e.g., observed release
     or observed contamination), and are at or above
     media-specific benchmark levels (see Table 3-6).

  •   Level II: Concentrations that either meet  the
     criteria for actual contamination but are less than
     media-specific benchmarks, or meet the criteria
                                                  22

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Site Inspection Guidance
                                     Planning
                           TABLE 3-6: MEDIA-SPECIFIC BENCHMARKS
HRS PATHWAY/THREAT
Ground Water
Surface Water
Drinking Water Threat
Human Food Chain Threat
Environmental Threat
Soil Exposure
Air
BENCHMARKS1
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Screening concentrations2^
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Screening concentrations*3
Food and Drug Administration Action Levels
Screening concentrations"
Ambient Water Quality Criteria
Ambient Aquatic Life Advisory Concentrations
Screening concentration~
National Ambient Air Quality Standards
National emissions standards for hazardous air pollutants
Screening concentrations2'3
'See Superfund Chemical Data Matrix (SCDM)
"Screening concentrations for cancer corresponding to concentrations for the 106 individual cancer risk for
oral exposure (inhalation exposure for the air pathway)
'Screening concentration for noncancer toxicological responses corresponding to RfDs for oral exposure
(inhalation exposure for the air pathway)
     for  actual contamination  based on direct
     observation.

  •   Potential: No observed release is required but
     targets must be within the target distance limit.

Level II contamination is assigned to targets meeting
the criteria for actual contamination when none of the
eligible substances for a pathway or threat has an
established benchmark.

The HRS assigns different relative weights to targets
associated with the three levels of contamination. For
all pathways and threats, Level I contamination target
values are multiplied by 10, Level II contamination
target values are multiplied by 1, and  potential
contamination target values are multiplied by 0.1.
The  presence  of targets  exposed  to actual
contamination may significantly affect the site score.
Generally, actual contamination can only be supported
with analytical sampling data; therefore, proper
selection, collection, and handling of target samples is
critical to the  success  of  the  SI.

Target Distances: In some instances,  analytical data
may be used to establish target distance limits.
Analytical data also may be used to identify sample
locations to make measurements for I-IRS data
requirements (e.g., depth to aquifer, distance  to
surface water, distances to nearest targets).

3.4 SAMPLE ANALYSIS OPTIONS

The SI investigator must plan  which  analytical
methods and services to use. Although laboratory
analyses are routinely used, field analyses may often
                                                 23

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Planning
                     Site inspection Guidance
provide the type and quality of data needed to support
site assessment decisions, and satisfy data quality
objectives (DQOs). To select analytical methods and
services, the SI investigator should consider:

 •   Available  information to identify substances
     present
 •   Objectives of the SI (e.g., screening or listing)
 •   Quality of data needed to support decisions or
     planning activities
 •   Availability of services
 •   Desired turnaround time
 •   Anticipated number of samples to be analyzed
 •   Need for special separation  or  analysis
     techniques
 •   Need for lower detection limits
 •   Need for real-time monitoring
 •   Comparability and representativeness of data
     sets

In general, DQOs for analytical data generated during
the focused SI may be less  demanding than the
objectives for data generated during the expanded SI
In addition, lower levels of data quality may be
acceptable to screen a site rather than document a site
score. The minimum data quality requirements for
scoring depend on the specific HRS factor being
evaluated.   Investigators should be  familiar with
minimum data quality requirements so  they may plan
SI sampling and analysis strategies that accomplish
the dual goals  of meeting DQOs  and minimizing
sampling and analysis costs.

SI samples  are analyzed by contract laboratory
program (CLP) and non-CLP laboratory  services.
CLP services  may be provided through routine
analytical services (RAS)  and  special analytical
services  (SAS).  Non-CLP services  include field
analytical support project (FASP) methods. The SI
investigator should ensure that non-CLP services meet
the DQOs of the  SI

3.4.1  CLP Services

CLP provides analytical services, including sample
data management, through a nationwide network of
laboratories under contract to EPA. CLP acceptance
criteria ensure data of known quality with a high
degree of confidence. CLP data satisfy the highest
data quality criteria EPA has established for the HRS
(i.e., Data Use Category (DUC) I). Therefore, CLP
data can typically be used to evaluate all HRS factors
requiring analytical data. Sometimes CLP data, like
other analytical data, are qualified  (e.g., J, R data
codes), which may affect their application. However,
since CLP codes are nationally consistent, defining
how the data can be applied in scoring may be easily
determined, as described  in  Guidance for  Data
Usability in Site Assessment. Non-CLP  services may
vary in their  criteria for  qualifying  data, so the
investigator should determine whether the laboratory's
coding criteria are compatible with the DQOs of the
investigation.

Under CLP, the majority of analytical needs are met
through standardized laboratory services provided by
RAS. RAS currently concentrates  on analysis of
organics and inorganic  in water or solid samples.
Other types of analysis  may be scheduled as SAS.
Among the SAS procedures  are air and tissue sample
analyses and detection of dioxins.

RAS provides broad-spectrum analyses for target
analyte list (TAL) and target compound list (TCL)
hazardous substances.     TAL  and TCL  are
recommended for Sis at CERCLA  sites where the
composition of wastes  are not known. However, full
TAL and TCL analyses may not be necessary for all
investigations,   especially  if source  hazardous
substances are well known and analyses can be
narrowed down to measure  specific compounds. For
example, results from  previous  investigations can be
used to focus CLP analyses for specific  substances or
classes of substances (e.g., pesticides, volatile organic
compounds)  to  investigate  releases, observed
contamination,   or targets exposed to  actual
contamination. If partial analyses are scheduled, the
investigator should determine whether the  resultant
data will be representative of the risks at the site and
similar to other data sets.

The Users Guide to the Contract Laboratory Program
(OSWER Directive 9240.0-0 ID) and the Samplers
Guide to the Contract Laboratory Program (OERR
Directive 9240.0-06) provide information on CLP
services. Section 5 of A  Compendium  of Superfund
Field Operations Methods (OSWER Dir. 9355.0-14)
explains procedures for using CLP laboratories and
non-CLP laboratories.
                                                  24

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Site Inspection Guidance
                                      Planning
3.4.2 Non-CLP Services

Non-CLP services may provide data of quality similar
to CLP. Non-CLP laboratories near the site may be
appropriate if fast turnaround is needed. If non-CLP
services are used, analytical protocols, data qualifier
assignments,  and   reporting parameters and
requirements need to be specified in the packages sent
to bidders. For EPA-lead sites, laboratories receiving
invitations to bid have usually been approved by the
EPA Regional QA  representative. For State-lead
sites, non-CLP services are usually subcontracts with
the prime  contractor and are  specified when the
project is initiated.

Non-CLP data may be CLP quality (DUC I) or lesser
quality (DUC II or III). For SI  planning purposes,
these categories are roughly comparable to the quality
of data needed to document a  site score, test site
hypotheses, or plan sampling.  Guidance for  Data
Useability in  Site Assessment provides  a detailed
discussion of sample analysis considerations.

The SI may use FASP to provide onsite screening of
samples for suspected hazardous substances. Field
screening instruments range from the relatively simple
(e.g., hand-held organic vapor detectors) to the more
sophisticated (e.g., field gas chromatography) and
typically are calibrated  to  identify  only selected
substances.  When the investigator is relatively certain
of the hazardous substances expected to be found at
the site, FASP methods may be appropriate.

As with non-CLP services, FASP and other field
screening methods provide data of variable  quality
that are useful to plan Sis, test hypotheses, and to
some extent, evaluate the HRS wore. For example,
screening data analyzed in the field can be used to
establish  source  boundaries  and  select sample
locations, thereby reducing CLP  costs, particularly at
larger hazardous waste sites where widespread soil
contamination  is suspected. FASP data can also
facilitate scoring releases  and actual contamination.
When  field screening results are used  directly to
support scoring,  10 to 20 percent of the screening
results  should be  confirmed  by CLP analyses.
However, such confirmation may not be necessary for
the focused SI depending on the quality of  other
analytical data.
FASP analyses (or other field screening analyses)
may also help to:

  •  Design soil sampling grids.
  •  Select  well locations  based  on soil gas
    monitoring.
  •  Select well screen depths.
  •  Determine the extent of hazardous substance
    migration.
  •  Estimate hazardous waste quantities (particularly
    based on area estimates).

In planning field screening services, the investigator
should be aware of several important constraints:

  •  The hazardous substances must be confirmed by
    CLP quality data.
  •  Not all substances  are amenable to field
    methods.    Complex  sample matrices,  high
    hazard samples, and certain substances  (e.g.,
    dioxin)  are  best  analyzed under  the more
    controlled conditions of a fixed laboratory.
  •  The sample  plan for field screening, like the
    CLP  plan, must be reviewed by EPA Regional
    management.
  •  A QA plan specific to sampling and  analysis
    should be prepared, including a  description or
    reference to all analytical procedures.

3.5 REVIEW INFORMATION FOR SI
     PLANNING

Before developing SI plans, the investigator should
compile all relevant and available site data. Review
of the data should determine what additional work is
needed and, for expanded Sis, any remaining non-
sampling information needed for HRS documentation.
Review of available information also will help avoid
duplicating previous efforts and save resources.

Information  describing hazardous waste  sources,
migration pathways, and human and environmental
targets  is available from  many sources. Previous
Superfund investigations typically supply the most
useful information for SI planning. Other sources of
information are site investigations conducted by other
parties, investigations  of nearby sites listed  in
CERCLIS, and the CLP Analytical Results Database
                                                  25

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Planning
                     Site inspection Guidance
(CARD),  which  compiles  information on  EPA
environmental  sampling.

The SI investigator should refine the site hypotheses
as new information is gathered and the nature of the
problem at the  site is  better understood.  New
information also may require updating the preliminary
site score,  or  modifying the scope of the SI The
investigator   should assess   whether  available
information:

  •  Helps characterize site sources.
  •  Supports testing of site hypotheses.
  •  Provides information for site scoring.
  •  Guides further sampling and analysis.
  •  Indicates  the  need for emergency response
     actions.
  •   Indicates health and safety concerns.

The scope of the SI often depends on the quality of
previous analytical data supporting the evaluation of
significant pathways of  concern.   By  reviewing
available information, the investigator can determine
the starting point of the SI and identify further
information needed  to  test or  substantiate  site
hypotheses and satisfy HRS data requirements. Each
planned SI sample location should reflect these needs.
The  investigator may find that substantial data
requirements have been satisfied and further sampling
is not necessary.    For  example,  when existing
analytical data from a critical sample location (e.g.,
municipal well, fishery) adequately test or support a
site hypothesis, resampling in this location may not be
necessary.

3.5.1  Review Non-Sampling information

The review of non-sampling information contributes
to understanding the site. This knowledge serves  two
purposes:

  •   To help determine the scope of future sampling
     efforts by verifying the physical characteristics
     of the site and its surroundings,  particularly
     target locations.
  •  To determine if existing hypotheses are sound.

Because site hypotheses are the basis of the sample
plan, they should reflect current conditions and be
well-founded.   Inaccurate target information may
preclude the development of realistic site hypotheses
and an effective sample plan. For example, target
information based on an outdated PA may not include
a new housing development near  the  site.  The
investigator should update target information if
necessary and determine the significant pathways of
concern.   Other circumstances that may warrant
collecting additional non-sampling information prior
to sample planning include flooding of the  site,
natural disasters,  removal of wastes, and altered
conditions.

Non-sampling information may come from a variety
of sources, including EPA and other Federal agency
studies, State and local environmental and health
studies, academic studies, and the records  of present
and former owners and operators of the facility.

3.5.2  Review Analytical Data

The  SI investigator should review  any available
analytical data for information to support  the design
of the sampling and analysis program, test site
hypotheses,  and  document the site  score.  While
analytical data collected for other purposes may not
meet  SI objectives,  site-specific  analytical data
generally help to clarify the nature of the problem at
the site, regardless of data sources or data quality.
The  scope  of  the  review depends on the overall
quality and quantity of data, the  intended use of the
data, and whether they are representative  of current
site  conditions  and comparable  to  SI data.
Determining whether available data  can be applied as
Si-generated data requires the professional judgment
of an experienced reviewer. Table 3-7 provides some
general guidelines for using various types  of data.

Both validated  and non-validated  analytical data may
be available. Previous SI data generally will  be
validated and of CLP-quality. Non-validated data
may contain false positives and false negatives,  as
well as quantitation, transcription, and calculation
errors. If data of unknown or questionable  quality are
critical to make decisions, the investigator should
review all available information to assess the level of
certainty associated with the data. If these data are
used for HRS documentation, they may  have to  be
validated.
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Sits Inspection Guidance
                                      Planning
                             TABLE 3-7: TYPES OF ANALYTICAL DATA
TYPE OF DATA
CLP
Qualified CLP
Non-CLP
Field screening
Owner/operator
APPLICATION
No specific limitations; used as necessary for all SI activities
Some general limitations depending on types of data qualifiers and bias (e.g.,
unknown, low, high) associated with the data
Few limitations if non-CLP data are shown to be equivalent to CLP data (e.g., level of
QA/QC documentation, level of laboratory performance, level of data quality,
independent data quality review)
Limitations if non-CLP data cannot be shown to be comparable to CLP data
Augments SI samples, especially to investigate area of contamination
Few limitations; used as necessary for all SI activities
The investigator may be able to determine the general
quality of the data by reviewing QC data.  False
positives can occur when blanks are contaminated or
pike recoveries are very high. False negatives can
occur if spike recoveries are very low. If hazardous
substances are found in one  duplicate but not the
other, results may be false positives or negatives.

The investigator should ensure that non-Si analytical
data accurately represent conditions at the site when
used to test site hypotheses. For  example, a release
to ground  water may be suspected based on site
characteristics (e.g.,  shallow  ground water, heavy
rainfall, high infiltration, waste disposal  below
ground) but not supported by non-Si analytical data.
The non-Si data may be unreliable due to changed
site conditions, or the samples may not have been
collected from the appropriate location. These data
should not be applied to override reasonable site
hypotheses based  on strong information on site
characteristics unless the investigator is confident that
sampling results are reliable, of adequate quality, and
truly representative of the site.

Older data may not reflect risks from continuing
hazardous substance migration, and partial analyses
may not identify all hazardous substances present at
the site. If previous samples were not collected from
areas  where  contamination is suspected, false
negatives may  result. Careful review of both the
sampling design and overall data  quality helps
determine whether non-Si data confidently test site
hypotheses. Table 3-8 provides a general approach to
review previous analytical data.

Combining data sets from different  sampling and
analyses events may not be appropriate when non-Si
data are used  to document the HRS evaluation.
Problems in comparing sample results generally are
caused by differences in  the sample design and time
periods-for  example, a water  sample  collected
during a period of high precipitation may not be
comparable to a water sample collected during the dry
season. Comparability also is a problem if analytical
methods differ or if detection limits  are unknown.
The use of routine analytical methods simplifies
comparability when combining data sets because all
laboratories follow the same standardized procedures
and reporting requirements.

The amount of  previous analytical data varies
substantially. Full data review may be appropriate for
smaller amounts of data.  For larger data volumes, the
investigator may choose  to screen for useful sample
results before review, Different levels  of data review
allow the investigator to efficiently assess previous
data within the time and resource constraints of the
SI Automated data review systems (e.g., Computer
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Planning
                    Site Inspection Guidance
                     TABLE 3-8: REVIEW OF PREVIOUS ANALYTICAL DATA
PROCEDURE
Determine what data are available
Evaluate purpose and scope of
previous investigations
Review sampling locations, dates,
depths, and sample descriptions
Evaluate the sampling results and
hazardous substance concentrations
Review field preparation and collection
techniques for previous samples
Review available laboratory
documentation
Assess usability of previous data
CONSIDERATIONS
What are the types of previous data: CLP, non-CLP, field
screening, full TCL analysis, partial TCL analysis, owner/operator,
state?
Why were data collected? What type of investigation State or
Federal facility investigation, enforcement action, emergency
response, RCRA facility inspection, general assessment of ground
water quality, environmental property assessment, NPDES permit
requirements?
Was the design of the sampling program similar to the SI
sampling strategy? Did it include background samples and field
QC samples?
Are a sample plan and sample location map available? Is a field
notebook available that describes all sampling activities?
What hazardous substances were detected? What are the range of
concentrations, background levels, data qualifiers and codes
attached to data, and detection limits?
Were appropriate SOPS used for sample collection and handling?
Are QA/QC procedures or data validation procedures available?
What are the name of the laboratory, the type of analyses
performed, and the performance results?
What is the overall usability of the data set?
Assisted Data Review and Evaluation (CADRE)) also
should be used for large amounts of data.

The data review may focus on:

 •   The entire site
 •   Specific sample locations
 •   Specific hazardous substances
 •   Elevated substance concentrations
 •   Ranges of concentrations
 •   QC assessment
 •   Background levels
 •   Attribution considerations
SI DQOs should be flexible to allow use of lesser
quality data for screening purposes. Different review
levels and quality standards apply depending on the
planned end use of data. For the expanded SI the
level of contamination at  a target from the  site
generally requires appropriate background and
attribution samples and may require documentation.
However, screening a site from further investigation
during the  focused  SI may not require  the same
analytical data quality as the expanded SI To take
maximum advantage of previous investigations, all
data, including data of lesser quality,  should be
weighed during SI planning.
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Site Inspection Guidance                                                                  Planning
          EXHIBIT 3-1: CHECKLIST FOR USABILITY OF PREVIOUS ANALYTICAL DATA
  1.   Have samples been taken at the appropriate location, depth, or stratum to confidently
      test site hypotheses?                                                            d Yes  D  No

  If the answer is "no," additional sampling will likely be needed to fully test hypotheses
  and provide a basis for the site disposition decision. The data may nevertheless be useful
  in  developing sampling and analysis plans  and identifying hazardous substances of
  concern.
  2.    Is documentation available to support the analytical procedures used to derive the data
       (e.g., laboratory QA/QC procedures, type of analyses, detection limits, and data
       review)?                                                                       D Yes  D  No
  3.   Are representative background  levels  available for targets  exposed to actual
      contamination and hazardous substances that may demonstrate releases?              D Yes  D  No
  4.   If background samples are available, are they temporally and spatially comparable to
      samples indicating releases and exposure of targets to actual contamination?          D Yes  D  No

  If the answer to questions 2, 3, or 4 is "no," the data may not support HRS documentation
  requirements and further review is needed to determine usability. However, the data may
  support testing of site hypotheses and development of a sampling strategy.
  5.   Do data provide evidence that attributes the hazardous substances detected in various
      media and waste samples to the site?                                             HI Yes  D  No

  If the answer to question 5 is "no,"  additional samples will be needed to fully support
  releases and targets exposed to actual contamination.

  If the answers  to questions 1 through 5 are all "yes," the previous analytical data may
  support testing PA hypotheses,  identification of hazardous  substances  of concern,
  development of a sampling strategy, and HRS documentation requirements, including
  releases and targets exposed to actual contamination.
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 Planning
                     Site Inspection Guidance
3.6 SI PLANS

Site-specific considerations  identified during data
review are addressed during development of the SI
plans. Four plans are developed to help refine  the
objectives of the investigations and to ensure that SI
activities  procceed  efficiently, safely, and on a
nationally consistent basis:

  • Work plan
  • Sample  plan
  • Health and safety plan
  • Investigation-derived wastes (IDW) plan

SI plans document procedures to be used,  resources
needed, and the rationale behind the anticipated tasks
to ensure that all planning and review steps have been
completed prior to starting field activities. The work
plan primarily covers administrative activities, while
the other three plans cover field activities. The
sampling, health and safety, and IDW plans may be
sections within the site-specific work plan, or separate
documents.

All plans should be prepared with input from all
agencies and organizations involved in SI  activities.
Lead personnel from these organizations should
approve and sign all plans.

3.6.1 Work  Plan

The work plan specifies administrative and logistical
requirements. The purpose of the work plan is to
efficiently  schedule  resources such as personnel,
equipment, and laboratory services. Preparing the
work plan requires a thorough understanding of the
site, its  surroundings, and the nature of possible
contamination and hazards. Clear and concise work
plans are prerequisites for obtaining quality analytical
data and making reliable site recommendations.

In general, work plans should include:

  •   A summary of background information on  the
     site, emphasizing how this information can help
     identify SI objectives;
  •   Objectives-for example, "to identify hazardous
     substances and document a release to surface
     water;"
  •   Schedule;
  •   A  description of personnel, special training
     needs, organization of teams, and equipment
     requirements; and
  •   A description of any non-standard equipment
     and contract services needed.

The work plan must address general considerations
and site-specific condition

  •   Hazards: What  physical or chemical hazards
     may be encountered? How will they affect time,
     expense, personnel, or equipment requirements?

  •   Location:  Is  the site accessible? How faraway
     is the laboratory or  home office? Will samples
     be shipped or hand delivered to the laboratory?

  •   Schedule:  Can the site be adequately sampled
     at this time of year, or will frozen ground or
     short daylight hours limit sampling?   Have
     recent rains or dry periods affected water levels
     or created swampy conditions? Does the public
     frequent the site at certain times?

  •   Mobilization/demobilization: How much time
     and equipment are needed? Does anything have
     to be ordered?

3.6.2 Sample Plan

Exhibit 3-2 suggests a  general outline  for work plan
elements combined into the sample plan. Appendix
A is an example of such a plan.

The sample plan can be incorporated into the work
plan or it may be a separate document. During the
focused SI the PA hypotheses and assumptions, along
with information from previous investigations, help
identify the specific areas that require samples or
additional data. Similarly, the focused SI results are
used to identify any remaining HRS data requirements
at the expanded SI The  sample plan specifies the
locations,  types,  and number of  samples and
procedures. A typical sample plan describes:

  •   Field operations: Discusses the sequence for
     conducting field activities.     Identifies the
     functions of each individual worker, specifying
     who will  take  samples, supervise  chain-of-
     custody  procedures,  maintain the field log book,
     and monitor the site  for potential hazards.
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Site Inspection Guidance                                                                    Planning


                              EXHIBIT 3-2: SI SAMPLE PLAN OUTLINE
  INTRODUCTION
   •  Briefly state the authority and purpose for conducting the SI and the scope of the investigation. Discuss
      the objectives and goals of the SI

  SITE DESCRIPTION AND REGULATORY AND OPERATIONAL HISTORY
   •  Describe the site location. Identify the type of facility, whether it is active or inactive, and years of
      operation. Describe its physical characteristics and setting (e.g., local land use, climate, topography,
      geology, hydrology, hydrogeology). Include a map showing the location. Include a site plan or sketch
      showing features on and around the  site.

   •  Describe historical site operations, including all past and current operations and conditions. Identify
      current and former owners/operators, types of site activities, wastes generated, and waste disposal
      practices. Identify all sources and source types. Provide the hazardous waste quantity disposed in each
      source, if possible, and provide volume or area of the sources. Identify hazardous substances associated
      with or detected in the sources. Describe source containment. Describe any spills that have occurred at
      the site.

   •  Specify whether any sources are regulated by RCRA. Describe past regulatory activities, including
      permits, permit violations, and inspections by local, State, or Federal agencies. If applicable, provide
      emergency response and waste removal information. Summarize analytical results of earlier
      investigations. Specify type of data (e.g., CLP, non-CLP, owner/operator).

  COLLECTION OF NON-SAMPLING DATA
   •  Describe additional non-sampling information to be collected (e.g., aquifer boundaries, interconnections,
      and discontinuities; resources; drainage area; soil group; particulate migration factors) and the rationale
      for collecting this information. Discuss any field activities needed to obtain this information,

  SAMPLING ACTIVITIES
      Discuss objectives of planned field activities. Describe procedures and necessary resources. Discuss the
      rationale for these tasks.

      Provide explicit instructions for all field activities, including field observations, sampling, environmental
      monitoring for health and safety purposes, and field QA/QC protocols. Reference appropriate Standard
      Operating Procedures (SOPS). Discuss purpose of both onsite and offsite reconnaissances and
      observations (e.g., to verify the selection of sample locations, to evaluate the degree of containment at
      site sources, to measure source dimensions, to verify distances to nearby targets, and to characterize
      additional sources of contamination not identified during previous investigations).

      Justify proposed  sample locations. Discuss methods to more fully characterize wastes and sources.
      Identify specific targets to be sampled (e.g., drinking water wells  or intakes, fisheries, sensitive
      environments) to test or substantiate target contamination hypotheses. Describe sampling strategy to test
      or substantiate observed release hypotheses and presence of media contamination (e.g., soil, ground
      water, sediment,  air, surface water).
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                Site Inspection Guidance
                       EXHIBIT 3-2: SI SAMPLE  PLAN OUTLINE  (concluded)
   •   Include a map or site sketch showing previous and proposed sample locations.

   •   Summarize sample plan in a table, identifying sample types, sample numbers, sample locations, and
       sample-selection  criteria.  Describe methods of sample collection and preservation, field measurements,
       and analytical methods. Refer to Standard Operating Guidelines (SOGs) or provide a table or checklist
       describing the SOGs.

   •   Describe investigation-derived wastes (IDW) that may result from field activities. Reference the IDW
       plan that describes the management approach  for non-hazardous  and hazardous IDW.

  PROJECT MANAGEMENT
   •  Identify all persons who will be involved in the field activities and discuss their specific
      responsibilities. Identify all safety and sampling equipment and supplies. Describe any contractual
      services needed to accomplish field activities. Summarize all transportation and shipping information.

   •  Describe community relations plans and meetings.

   •  Provide information on SI costs (e.g., number of technical hours; number of CLP, field screening, or
      other samples; subcontracting costs). Provide schedule for SI activities and deliverables. Summarize
      any special requirements that impact the SI (e.g., special safety considerations, special analytical
      services (SAS), or special equipment).

   •  Reference the work plan.

  ATTACHMENTS
       Sample summary table

       Sample location sketch

       List of references cited in this plan

       Health and safety plan

       Appropriate SOPS and SOGs
     Sample locations and rationale:   Identifies the
     location of each sample on a site map, explains
     the rationale for each location, and specifies the
     type (e.g., soil, sediment, water), volume, and
     number of samples.'

     Field quality control samples:   Identifies the
     number, location,  and type  of blank  and
     duplicate samples.
Sampling equipment    decontamination:
Identifies sample decontamination procedures,
including decontamination solutions and any
special handling.

Analytical requirements and  sample handling:
Identifies the specific analysis parameters-for
example, organics, metals, dioxins—for each
sample. Identifies the preservation techniques
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Site Inspection Guidance
                                      Planning
     and reagents for each sample. Specifies whether
     samples are to be filtered, and explains why.
     Identifies the equipment, sampling devices, and
     type of containers  used for  each  sampling
     episode. Much  of this can be addressed by
     referencing the  appropriate field  SOPS.
     Identifies any procedures not covered by, or that
     are different from, the SOPS.

 •   Sample delivery: Identifies where samples are
     to be delivered for shipment or analysis, where
     splits should be delivered if they are collected,
     and if appropriate, specifies special storage or
     transport requirements.

3.6.3 Health and Safety Plan

The purpose of the health and safety  plan is to
establish requirements and procedures  to protect the
health and  safety of investigative personnel and the
nearby public.  The plan  must specify levels of
protection necessary for each field activity, provide
detailed  instructions  for routine  operations and
emergency situation responses (see below), list key
safety personnel, and describe health and  safety
monitoring requirements. The health and safety plan
is  generally prepared after the sample  plan and
included as an appendix to the work plan. The health
and safety plan  must be distributed to all  team
members, discussed at a team meeting prior to site
entry, and posted at a conspicuous location at the site
before field activities  begin.

Routine Operations

Safety practices for routine operations parallel
standard industrial hygiene and industrial  safety
procedures. The health and safety plan at a minimum
must:

 *   Describe hazards and risks associated with the
     field work to be performed at the site, including
     all known or suspected  physical,  biological,
     radiological, or chemical hazards.

 •   List key safety personnel and alternates. Also
     identify other key personnel assigned to various
     site operations.    Indicate where telephone
     numbers, addresses, and organizations of these
     people will be posted.
 •   Designate levels of protection required  by
     location or task, specifying types of respirators
     and clothing to be worn for each level.

 •   Designate  work areas-exclusion  zone,
     contamination reduction  zone, and support
     zone-on the site map. Include zone boundaries
     and  access  control  points for each zone.
     Indicate where the map will be posted.

 •   List  security control  procedures to prevent
     unauthorized access—for example, fences, signs,
     security patrols,  and check-in procedures.
     Identify procedures to ensure personnel wear the
     prescribed protective clothing.

 •   Discuss environmental monitoring protocols at
     or around the site to indicate chemicals present,
     and  their hazards, possible  migration,  and
     associated safety requirements.

 •   Specify routine and special training required.

 •   Describe  procedures for weather-related
     problems, such as temperature extremes, high
     winds, rain, and snow. Identify shelters when
     necessary. Discuss procedures to minimize heat
     stress of field team members wearing protective
     clothing.

Emergencies

Emergencies resulting from fire, chemical exposure,
physical injury, or other events require immediate
responses to prevent harm to onsite workers,  the
public, property, or the environment. Contingency
plans for managing emergencies should

 •   Advise workers of their duties  during  an
     emergency—for example,  site personnel should
     be designated as site  safety officers, standby
     rescue personnel, decontamination personnel,
     and  emergency medical technicians. Identify
     their functions and expertise.

 •   Identify the location of the nearest telephone.

 •   Designate    emergency    communications
     alternatives-for example, citizen band  and
     hand-held radios.
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  •   Identify  names,  telephone  numbers,  and
     locations    of local emergency   response
     officials-for example, fire, police, explosives
     experts, and hazardous materials response units.

  •   Specify worker evacuation procedures.

  •   List onsite emergency equipment and all other
     local medical, rescue, transport, and fire-fighting
     equipment..

Emergency medical care is an important component
of the health and safety plan. To ensure that injured
workers are transported to the nearest medical facility
and receive appropriate treatment:

  •   Identify the nearest medical or emergency care
     facility that handles chemical exposure cases.
     Record its location, travel time, directions, and
     telephone number.

  •   Identify the telephone number of the nearest
     ambulance service.

  •   Maintain accurate records on any exposure or
     potential  exposure of  site workers during
     emergencies.

  •   Specify decontamination procedures for injured
     workers, transport vehicles, medical facilities, or
     medical personnel.

3.6.4 IDW Management Plan

Management of Investigation-Derived Wastes During
Site Inspections (OERR Directive 9345.3-02) presents
a general regulatory background and options to
manage IDW generated during Sis. These wastes
include soil cuttings, drilling muds, purged ground
water, decontamination fluids  (water and other fluids),
disposable sampling equipment (DE), and disposable
personal protective equipment (PPE). The directive
addresses typical IDW management scenarios, and
describes cost-efficient methods of handling hazardous
and  non-hazardous IDW to:

  •   Minimize the quantity of wastes generated.
  •   Leave a site in same condition or not worse than
     prior to the investigation.
  •   Remove wastes that pose an immediate threat to
     human health or the environment.
 •   Comply with Federal and State applicable or
     relevant and appropriate requirements (ARARs)
     to the extent  practicable.

Specific elements of the strategy are to:

 •   Characterize  IDW by available information (e.g.,
     manifests, Material Safety Data Sheets, previous
     test results, knowledge of the waste generation
     process, and other relevant records) rather than
     analyze IDW samples.

 •   Delineate an  Area of Contamination (AOC) unit
     for leaving RCRA hazardous soil cuttings,

 •   Dispose of RCRA  hazardous ground water,
     decontamination fluids, and PPE and DE (if
     generated in  excess of 100 kg/month) at RCRA
     Subtitle C facilities.

 •   Leave onsite RCRA non-hazardous soil cuttings,
     ground water,  and decontamination fluids,
     preferably without containerizing and testing.

EPA does not recommend removing wastes from all
sites and, in particular, from those sites where IDW
do not pose any immediate threat  to human health or
the environment. Removing wastes from all sites
would not benefit human health and the environment
and would be unduly expensive, thus impairing EPA's
ability to successfully meet the goals of the site
assessment  program.

The NCP requires that IDW generated during Sis be
managed in compliance with all ARARs to the extent
practicable. In  addition, other legal and practical
considerations may  affect the handling of IDW.
Investigators should be familiar with OERR's  IDW
directive as well as the requirements of the NCP for
identifying ARARs.

IDW from  Sis may contain hazardous substances as
defined by CERCLA  Section 101(14) and listed at 40
CFR Part  302.4.    Some CERCLA hazardous
substances are RCRA Subtitle C hazardous wastes,
while other substances may be regulated  by other
Federal laws such as the Safe Drinking Water Act,
Clean Air Act, Toxic Substances Control  Act, and
Clean Water Act.  EPA estimates  that to date RCRA
hazardous IDW have  been generated at fewer than 15
percent  of CERCLA  sites.    However, RCRA
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Site Inspection Guidance
                                       Planning
regulations,  and in particular the RCRA Land
Disposal Restrictions, are very important as potential
ARARs since they regulate treatment, storage, and
disposal of many of the most hazardous materials.

3.7 SITE  RECONNAISSANCE

Site reconnaissance may occur prior to completing the
SI sample plan, since the primary objective of site
reconnaissance is to verify planned sample locations
by examining the site and its surroundings. Before
site reconnaissance field  activities  begin,  the
investigator should arrange for site access and prepare
a  specific health  and safety plan, even if a
reconnaissance was  performed during a previous
investigation. The investigator also should consider
informing interested  parties (e.g., community
representatives, and local, State, or Federal officials)
of upcoming field activities. Early  contact should
facilitate the reconnaissance  and subsequent field
sampling  and alleviate possible negative impacts
caused by site activities.

The site reconnaissance team should perform the
following  activities to verify the planned sample
locations.

  •  Locate all sources.
  •  Determine the physical state of wastes deposited
    at the source.
  •  Identify each source type.
  •  Examine each source for evidence of hazardous
    substance migration.
  •  Evaluate the degree of source containment.
  •  Identify overland flow paths.
  •  Determine the distances from sources to onsite
    and nearby targets.
  •  Refine  the site sketch  depicting  important
    features (e.g., source locations, nearby targets).

Investigators  should allocate sufficient time to verify
or,  if necessary, modify sample locations based on
site reconnaissance information. Preferably, a small
crew should conduct the site reconnaissance prior to
sampling. If an onsite reconnaissance was conducted
recently, the site reconnaissance for SI sampling may
be conducted on the first day of field activities.

Site reconnaissance also is important when  evaluating
the need for emergency response action at the site.
Emergency response could include the stabilization or
removal of wastes, fencing the  site or  specific
sources, evacuation of nearby populations, and other
activities that eliminate, control, or otherwise mitigate
an imminent threat to  human  health  and  the
environment.    If monitoring equipment indicates
radioactivity, field team members should immediately
leave the site and notify the EPA Regional radiation
program office.

3.7.1 Emergency Response

At any time  during the Superfund process, an
emergency response action (or removal) may be taken
at the site. Removals typically are relatively short-
term actions designed to respond to situations that
require immediate action to eliminate a present threat
or avoid a more serious  future problem.    Some
conditions that may result in a removal action include
the threat of:

  • Fire or explosion
  • Direct contact with hazardous substances
  • Continuing release of hazardous substances
  • Drinking water contamination

Removal actions can include, but are not limited to:

  •  Fencing the site;
  •  Providing 24-hour security to restrict public
     access;
  •  Stabilizing waste sources, such as leaking drums
     or overflowing surface impoundments;
  •  Removing hazardous substances from the site;
  •  Capping areas of contamination;
  •  Evacuating local  populations and
  •  Providing alternative drinking water supplies.

While not every SI will be of interest to the Regional
emergency response program, there will be a number
of sites where it is important to consult with them.
The  Regional  EPA  site assessment  contact, in
conjunction with removal program personnel, will
determine if a removal site evaluation is necessary,
The  SI  investigator should  review  the PA to
determine if the conclusions are still accurate. If
there was a referral to the emergency response
program at that time, the  emergency response action
memorandum and any follow up action should be
included in the SI background material. If no referral
was  made, the  SI investigator should assess site
conditions to determine if an emergency response
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Planning
                     Site Inspection Guidance
action is warranted.   If this is  the  case, the SI
investigator  should involve  emergency response
personnel in planning SI field  activities to determine
if a removal  action is appropriate. The emergency
response  representative should identify sampling
information that should be collected during the SI that
will assist future response activities. Likewise, if an
immediate response is necessary, emergent y response
personnel may be able to collect valuable information
to assist SI field activities.

3.7.2 Effects of Removal  Actions

Removal actions may affect SI activities, including
sample  planning and  site  scoring. The effects  of
removal actions may be considered when evaluating
the HRS score (The  Revised Hazard Ranking System:
Evaluating Sites After Waste  Removals, OSWER
Directive  9345.1-03FS). Three requirements  that
must be  met for  a removal to affect  the  site
evaluation are:

  •   The  removal action must physically  remove
     waste from the site.
  •   The removal action must have occurred before
     approval of the SI work plan for non-Federal
     facilities, and 18 months after a Federal facility
     has been placed on the  Federal Facilities Docket.
  •   The  removed wastes must be  disposed or
     destroyed at a  facility  permitted under RCRA,
     Toxic Substance Control Act (TSCA), or the
     Nuclear Regulatory  Commission  (NRC), as
     appropriate.

While removal actions may affect the way specific
HRS factors are  evaluated,  the  removal itself
generally will not alter significantly the SI sampling
strategy, which determines:

  •   Whether a hazardous substance has impacted a
     target;
  •   The types of substances at the site; and
  •   Whether a release has  occurred.

If analytical data indicate that a release of hazardous
substances has occurred before or after a removal, the
removal  does not  negate this information.  If  a
removal  has eliminated   the  entire  source, but
professional judgment concludes that a release has
occurred, samples should be collected.  The resulting
analytical data can  be used to evaluate specific HRS
factors, regardless of the status of the removal. The
investigator is not responsible or required to document
that the source and the threat of a release from the
source has been completely eliminated.

If a removal has eliminated a portion of site sources,
sample planning should focus on the remaining
portion. Unless the potentially responsible party (e.g.,
site owner or operator) can document otherwise, the
SI investigator can reasonably  assume that the
remaining  portion  contains  the  same hazardous
substances as the removed portion.  Note that the
substance-specific waste characteristics factors (e.g.,
toxicity, mobility, persistence) cannot be based on a
hazardous  substance that was completely removed
from  a site through a removal; however, the
investigator is  not  required to obtain substance-
specific information.

3.7.3  Site Access

Legal access to the site must be obtained from the site
owner before conducting a site reconnaissance. In
some  Regions,  EPA personnel are responsible for
obtaining access.    In other  Regions, State or
contractor personnel may make access arrangements.
While the owners, operators, or persons in charge of
a site cannot prevent EPA's entering the property,
they can require a court order. Four types of access
agreements can be used for the SI

  •  Voluntary entry (consenting)
  •  Conditional entry
  •  Entry with warrant (nonconsenting)
  •  Entry without warrant

The Regional SAM should consult with State counsel
to ensure that all appropriate State requirements are
met before initiating the SI State laws for collecting
evidence may be more restrictive than Federal laws,
and noncompliance could result in suppression of
evidence in a legal proceeding. Finalizing site access
arrangements can take considerable time; hence these
activities should be initiated early in the SI planning
process.

Voluntary Entry

In general, the investigator should pursue voluntary
entry  fist, followed by  conditional entry, and if
necessary, entry with a warrant.    An entry is
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Site Inspection Guidance
                                      Planning
considered voluntary as long as the owner agrees,
The  field team must  not  exhibit any  form  or
semblance of coercion to gain entry. Entry gained via
verbal or physical threat may later be determined
invalid,  and  any information  obtained during
inspection could become inadmissible  in legal
proceedings.

The investigator should confirm consent to entry by
notifying the owner in writing of the activities to be
conducted (e.g., sample collection, picture taking,
visual  observations).     CERCLA requirements
governing split samples  and receipts take precedence
over a State law when the State program is operating
with Federal funds.

Upon arrival at the site, field team members should
present their  credentials  and inform the owner/
operator or designee of the nature of the work and
their authority for conducting the SI If the owner
withdraws consent at any time, which is equivalent to
refused entry, a warrant is required to complete the
SI Any  information gathered before consent  is
withdrawn, including samples and photographs, can
be used in a legal proceeding, as can any information
obtained in an area open to the public.

Conditional Entry

The owner may consent to entry but impose
conditions-for example, limiting areas of the site
reconnaissance, limiting employees to be interviewed,
or requiring confidentiality agreements. If avoiding
conditional entry  is  not possible, accept  only
conditions that do not significantly interfere with the
SI and note them in the logbook. State employees
should consult with their own counsel or the EPA
Office  of Regional  Counsel to determine if such
agreements are acceptable or should be treated as a
refusal of entry. The field team should be  informed
about such conditions prior to arriving at the site.

Entry With Warrant

If consent cannot be obtained or is withdrawn, the
investigator should seek an entry warrant. The SI
must be conducted strictly in accordance with the
warrant, which might, for example, restrict access to
certain areas  or  records. Failure to  do so could
jeopardize the admissibility of  the  information
obtained.
When refused entry, the investigator should note in
the logbook the person refusing entry, the date and
time of refusal, the reasons given for refusal, and
other pertinent details. The investigator should then
leave the premises and immediately seek a warrant.

Entry Without Warrant

Entry without a warrant is normally reserved for
emergencies and instances  where evidence might be
lost if site entry is delayed. When ownership of an
abandoned site cannot be determined, the investigator
should discuss the need for a warrant with  the EPA
Office of Regional Counsel.

Some courts have ruled that inspections under the
Federal Insecticide, Fungicide, and Rodenticide Act
and the Toxic  Substances Control Act involving
industries that are highly regulated are not subject to
warrant requirements. Investigators should consult
with the EPA Office of Regional  Counsel before
entering a site without consent and without a  warrant.
Investigators should consider requesting assistance or
backup from local police  for types of entry.

3.7.4 Community  and  Neighborhood
        Contacts

Local representatives should be contacted in  advance.
Community relations coordinators can help identify
appropriate representatives. Only designated team
members should participate in discussions with local
residents, remaining as factual as  possible  and
avoiding expressing opinions or raising expectations
for future action. Team representatives should always
refer questions to the  Regional SAM, who may

  •   Explain the purpose of SI activities.
  «   Identify the site location.
  •   Explain the tasks to be performed.
  •   Identify a contact for further information.
  •   Determine whether meetings should be held and
     whom the SI results  and other information
     should be provided.

For guidance on community relations during Sis, see
Community Relations in Superfund: A Handbook,
Section 4.1 (OSWER Directive 9230.0-03C, January
1992).
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Planning
                     Site Inspection Guidance
3.7.5 Government Contacts

EPA Regional management should contact appropriate
municipal, county, State, and Federal officials before
stating field work.  These groups frequently have
information on the site's waste practices, history, and
compliance records, and may be aware of other
investigations or enforcement activities at or near the
site. Activities  by other agencies do not provide
sufficient reason to cancel or postpone the SI but the
work schedule can be  adjusted  if it  does not
compromise the health and safety of the public or the
environment.

3.8 SITES  CONTAINING RADIOACTIVE
     SUBSTANCES

Sis for sites containing radioactive substances require
many of the same  considerations for site-specfic
planning  discussed  in  previous sections  of  this
chapter. Investigators performing Sis at radiation
sites also collect a limited number of selective
samples,   rather than  an  extensive number of
"average"   samples, to  investigate sources  and
migration pathways and establish contamination levels
at targets. Sample collection issues, including types,
variability, and QA/QC requirements, are generally
similar for sites with radioactive substances.

The SI approach for radiation sites  differs from
nonradioactive sites based on HRS data needs,  field
instrumentation and procedures, sample collection and
handling, laboratory support, and analytical methods.

This section provides a supplemental discussion of SI
planning    considerations  for  sites  containing
radioactive substances. Guidance is  provided on
radiation survey instruments and techniques, special
sampling and analysis issues, and HRS requirements.
This section also provides information on components
of a radiation health and safety plan, an IDW plan,
and supporting documentation.

For additional information on radiation concepts and
terminology, background levels of radionuclides in the
environment, and data usability considerations for
radioactive substances, the SI investigator should  refer
to Guidance for Data Useability in Site Assessment.
3.8.1 Key Radiation  Site Personnel

When planning Sis at sites  containing radioactive
waste, the SI investigator should consult with a health
physicist and  a radiochemist during all phases of
sample planning and implementation.   A health
physicist can assist the investigator by:

  •   Reviewing the site  history and records  to
     identify radionuclides and radioactive sources
     and waste streams;
  •   Planning samples and  analysis, including the
     selection of field instruments;
  •   Implementing  the SI sample  plan  and
     interpreting measurement data;
  •   Preparing and  implementing a radiation health
     and safety  plan,   including  training  and
     monitoring SI personnel;
  •   Preparing and implementing IDW plans; and
  •   Determining data adequacy and usability.

The health physicist may facilitate planning field
activities.  For example, the health physicist may
identify  techniques, such as walkover and  grid
surveys, to locate radioactive  contamination, A health
physicist may know  where maximum concentrations
(hot spots) are likely to be found. Often, certain
locations between, or at the fringe of, grid patterns
should be investigated, such as near the foundations
of structures or along a facility's sanitary sewer lines.
Establishing actual contamination may hinge on this
data. During field work, the health physicist may
interpret measurements so that technical decisions can
be made in the field.

A radiochemist can  assist the investigator by

  •   Specifying sample size, collection, handling, and
     holding time considerations;
  •   Establishing desired  analytical sensitivities,
     turnaround times, and QA/QC requirements to
     meet data needs;
  •   Recommending radionuclide- and media-specific
     radioanalytical  procedures;
  •   Selecting radiochemical laboratories
  •   Interpreting radioanalytical claw,
  •   Resolving data  discrepancies and data gaps; and
  •   Determining  data adequacy  and usability.
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Site Inspection Guidance
                                     Planning
For health physics and radioanalytical support, the SI
investigator should contact EPA Regional, laboratory,
or Headquarters Office of Radiation Programs (ORP)
staff.

3.8.2 Radiation Survey Instruments

In  addition to laboratory  analysis  of collected
samples, radionuclides can  be investigated  by a
variety of field survey instruments and techniques.
These instruments and techniques provide immediate
information on the location and distribution of sources
and releases of radionuclides, allowing rapid field
screening of potential radiation sites.

The SI investigator should consider the  capabilities
and limitations of the  various types of radiation
survey instruments  when  planning field  work.
Instrument selection depends  on several factors,
including the type (alpha, beta, gamma, and x-ray)
and energy of radiation emitted by each radionuclide
of concern, expected concentrations (activity per unit
mass) above background levels, shielding and self-
absorption by the contaminated material, and desired
measurement sensitivity.

Gamma  Detectors

Five types of field survey detectors are commonly
used for measuring gamma radiation exposure rates:
ion chambers, pressurized  ion chambers  (PICs),
Geiger-Mueller (GM) counters, sodium iodide (Nal)
scintillation detectors,   and organic scintillation
detectors  (see  Table 3-9).   Nal  and organic
                    TABLE 3-9: GAMMA RADIATION SURVEY INSTRUMENTS
INSTRUMENT
[on Chamber
Pressurized Ion
Chamber (PIC)
Geiger-Mueller
(GM) Tube
Nal Scintillation
Detector
Organic
Scintillation
Detector
SPECIFICATIONS
Moderate to high exposure rate
range: 1 to 2,000 mR/hour
Accuracy: ±5% at the high end
of the scale
Low range 1 to 500 uR/hour
Accuracy: ±5% full scale
Moderate to high range: 1 to
5,000 mR/hour
Accuracy: ±10% full scale
Low range 1 to 5,000 pR/hour
Accuracy: ±10% at high end to
±30% at low end of scale
Low range: 1 to 25 pR/hour
Accuracy: ±10% full scale
ADVANTAGES
Reading is directly
proportional to radiation field
Suitable for high radiation
fields
Very portable
Reading is directly
proportional to radiation field
Suitable for near-background
radiation rates
Also detects beta radiation
Very portable
Suitable for background
radiation rates
Very portable
Suitable for background
radiation rates
Very portable
DISADVANTAGES
Poor sensitivity
Inadequate for near-
background radiation
rates
Not as portable as ion
chamber
Allows fewer
measurements per day
Poor sensitivity
Reading is not directly
proportional to radiation
field; response varies
with photon energy
Reading is not directly
proportional to radiation
field; response varies
with photon energy
Response is generally
linear with energy
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Planning
                    Site Inspection Guidance
scintillation detectors are used most often because of
their portability and ability to measure exposure rates
at and above natural background  levels.   These
detectors  usually  record exposure  rates  in
microroentgens per hour(pR/hr), microrem per hour
(prem/hr), or counts  per minute (cpm), which are
converted to |LlR/hr or [Irem/hr by an instrument-
specific calibration factor. The SI investigator should
cross-check exposure rate measurements made with
these detectors against a limited number of PIC
measurements because the response characteristics of
Nal and organic scintillations detectors are energy
dependent. Although less portable than hand-held
survey detectors, PICs provide a  flatter response over
a wider range of gamma energies.

Two other portable detectors may be useful in field
surveys:  high-resolution gamma spectroscopy systems
(HRGS)  and field instruments for detecting  low
energy radiation (FIDLER). HRGS typically use a
germanium-lithium detector coupled to a multichannel
analyzer to identify gamma-em{tig radionuclides by
determining the energies and  relative  detection
frequencies of incident gamma and X-ray photons,
The energy spectrum acquired from the analyzer is
compared against reference spectra for known or
suspected radionuclides. FIDLERs are specialized
Nal detector systems that measure low-energy photon
radiation from radionuclides such as plutonium or
americium.

Prior to the field survey, all survey instruments should
be calibrated for the range of gamma radiation
energies  expected. At a minimum, EPA requires a
two-point energy calibration at 25 and 75 percent of
full scale, performed annually by  a certified
laboratory using gamma standards traceable to the
National Institute  of Standards and  Technology
(NIST). A current calibration certificate must be
provided for each survey instrument. Moreover,
during the field survey, the proper operating response
of each instrument should be confirmed daily using a
gamma radiation check source in a  reproducible
geometry. The results of instrument checks should be
recorded in the field notebook.
               TABLE 3-10: ALPHA AND BETA RADIATION SURVEY INSTRUMENTS
INSTRUMENT
Alpha
scintillation
probe1
Air proportional
detector
Geiger-Mueller
(GM) pancake
type probe1
Side-shielded
GM probe1
RADIATION
DETECTED
Alpha
Alpha
Alpha, beta, and
gamma
Beta and
gamma
ADVANTAGES
High detection efficiency
Very portable
Large surface area
High detection efficiency
Large surface area
Detects all types of radiation
Discriminates between beta and
gamma radiation
Useful in high gamma radiation fields
DISADVANTAGES
Very fragile
Measures only alpha particles
Very fragile
Measures only alpha particles
Affected by moisture
Decreases ability to discriminate
among radiation types
Not recommended for measuring
alpha particles
Gamma reading is not directly
proportional to radiation field;
response varies with energy
1A11 probes are attached to an appropriate rate meter or sealer (pulse counter)
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Site Inspection Guidance
                                      Planning
Alpha and Beta Detectors

Survey instruments for measuring alpha and beta
radiation include alpha scintillation probes, air
proportional detectors, GM pancake type probes, and
side-shielded  GM  probes  (see  Table  3-10).
Measurements made with alpha and beta detectors are
usually recorded as counts per minute (cpm) per unit
area for the active detection area of the probe. These
measurements are then converted to activity units of
disintegrations per minute (dpm) per unit area by an
instrument-specific efficiency factor. Alpha and beta
detectors should also be properly calibrated using
appropriate NIST standards and their responses
checked daily in the field.

Operation, maintenance, and calibration standards for
radiation monitoring instruments may be found in the
American National Standards Institute's Radiation
Protection Instrumentation  and Calibration (1978).

3.8.3 Survey Techniques

In planning SI sampling and field screening, the
investigator should be  aware that background levels of
radioactivity and radiation exposure rates can vary
significantly in the environment, both spatially  and
temporally.   The accuracy of background level
evaluations can be increased by using a combination
of surveying methods and sampling, especially for
soil and air releases  at radiation sites.   The  SI
investigator should research natural radiation exposure
rates  and  background  concentrations  for   all
radionuclides suspected to be at the site.

In general, four types of radiation survey techniques
may be used during focused and expanded Sis (see
Table  3-1  1):  walkover surveys,  grid surveys,
downhole gamma logging, and special purpose
surveys. A walkover survey may assist  planning
focused  SI samples by  detecting hot spots and
releases of radionuclides and aiding sample location
selection. This survey is conducted by walking the
site and offsite areas with a hand-held radiation
detector. At sites with gamma-emitting radionuclides,
gamma exposure rates are measured with a Nal or
organic scintillation detector held one meter above the
ground surface. Measurements may also be made
closer to the ground to pinpoint gamma sources. At
sites with radionuclides that do not emit gamma
radiation, alpha and beta survey meters may be used
to scan surface areas for elevated count rates. During
the field survey, all areas with elevated exposure rates
or count rates should be marked with survey stakes
and measurement results recorded on the site map.

A grid  survey during the expanded SI can refine
gamma  exposure  rate measurements  and  help
                         TABLE 3-11: RADIATION SURVEYING METHODS
SURVEY TYPE
High Resolution Gamma
spectroscopy
Downhole Gamma Logging
Beta/Gamma Measurements
Gross Alpha or Gross Beta/Gamma
Measurements
Surface Area
Walkover Survey (Focused SI
Grid Survey (Expanded SI
MEDIUM
All
Soil
Soil
All
Soil
Soil
DATA PROVIDED
Identify specific gamma-emitting radionuclides
Identify distribution of gamma-emitting radionuclides
relative to soil depth
Identify distribution of radionuclides relative to soil depth
Screen for radioactivity levels prior to laboratory analysis
Identify hot spots for future investigation
Establish areas of observed contamination
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Planning
                     Site inspection Guidance
delineate areas of surface contamination. In this type
of survey, a grid system should be planned for the
area of radioactivity determined during the focused
SI  Additional survey  measurements  with other
instruments may be planned at grid point locations to
contribute to the evaluation of contaminated soil
volume and hazardous waste quantity.

Downhole gamma logging may determine the
distribution  and   depth of gamma-emitting
radionuclides in soil. In this type of survey, a gamma
radiation probe is lowered down a hole drilled in the
soil, and exposure or count rate measurements are
recorded  at selected depths  (typically every six
inches). Downhole measurements taken at selected
locations where gamma  radiation has been detected
are compared with similar measurements taken at
background locations.

The SI investigator may  plan  special  purpose
surveying to support other SI activities related to
quality assurance and the health and safety of field
personnel. Examples of special surveying procedures
may include GM and alpha scintillation  detector
surveys of surveying  and sampling  equipment,
potentially radioactive structures, investigation-derived
wastes, and decontamination process materials. The
SI investigator should consult a health physicist
during  SI planning for guidance on:  selecting,
calibrating, and operating radiation survey meters;
conducting survey techniques; and interpreting survey
results. Additional guidance on survey instruments
 and techniques can be found in the references listed
 in Table 3-12.

 3.8.4  Special Sampling  and Analysis Issues

 In planning radionuclide sampling and analysis, the SI
 investigator  should be  aware that radionuclide
 analyses are not currently conducted as part of CLP
 RAS. Instead, these analyses are conducted under
 SAS or a  separate CLP-equivalent program. For
 information to evaluate and select laboratories with
 radioanalytical services,  the investigator should
 contact EPA's  National Air  and  Radiation
 Environmental Laboratory (NAREL) in Montgomery,
 Alabama,  or the Nuclear Radiation Assessment
 Division of the Environmental Monitoring Systems
 Laboratory in Las Vegas, Nevada.

 The Nuclear Radiation  Assessment Division also
 provides quality assurance oversight for participating
 radiation   measurement laboratories,  including
 radionuclide  analytical    services   through  the
 Environmental  Radioactivity  Intercomparison
 Program. Quality assurance plans for all analytical
 procedures involving radioactive samples may be
 derived from several sources, including the U.S.
 Nuclear Regulatory Commission's Quality Assurance
for Radiological Monitoring Programs (Normal
 Operations-Effluent Streams and the Environment,
 Regulatory Guide No. 4.15, Revision 1 (1979) or
 American  National Standards Institute's Quality
 Assurance Program  Requirements for Nuclear
 Facilities, Report No. ANSI/ASME NQA-1 (1986).
          TABLE 3-12:  RADIOACTIVITY MEASUREMENT PROCEDURES  -  REFERENCES
  Conference of Radiation Control Program Directors, Inc., 1979. Ionizing Radiation Measurement Criteria for
  Regulatory Purposes. Prepared for U.S. Department of Commerce, National Bureau of Standards. NBS GCR
  79-173.

  National Council on  Radiation Protection  and Measurements, 1985. A Handbook  of Radioactivity
  Measurements Procedures. NCRP Report No. 58.

  National Council on Radiation Protection and Measurements, 1978. Instrumentation and Monitoring Methods
  for Radiation Protection. NCRP Report No. 57.

  Schleien, B., and Terpilak, M.S., Editors, 1984. The Health Physics and Radiological Health Handbook,
  Nucleon Associates, Inc.
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3.8.5 MRS  Requirements for Radiation Sites

Section 7 of the I-IRS addresses  sites containing
radioactive substances, alone or in combination with
other hazardous substances. Major I-IRS factors and
special analytical data requirements are summarized
below.

Human toxicity factors:  Radionuclides are evaluated
on the basis of carcinogenicity and are designated as
weight-of-evidence category A carcinogens. Toxicity
is determined for each radionuclide individually based
on its  slope  factor values,  expressed in terms of
lifetime  excess  total cancer risk per  unit of
radioactivity ingested  or inhaled.  SCDM  Part B
(OSWER Directive 9345.1-13)  provides toxicity
values for a limited number of radionuclides.

In general, sites containing mixed  radioactive and
other hazardous substances are evaluated in greater
detail than  sites with only one of these types of
hazardous substances. Human  toxicity factor values
are evaluated for  radioactive and nonradioactive
components  separately;  the substance posing  the
greatest hazard is selected based on toxicity, mobility,
persistence, and/or  bioaccumulation  potential.  Source
hazardous waste quantity factors for mixed radioactive
and other hazardous substances also are evaluated
separately   for radioactive and  nonradioactive
substances,  and the combined quantities of both
components  are summed  to  derive the pathway
hazardous waste quantity factor value.

Source Characterization:      The quantity of
radioactive substances in a source is based on the net
activity content (after subtracting background levels)
of all radionuclides  present rather than on their mass.
To characterize sources, radioanalytical data  are
required to:

 •   Identify all radioactive substances and decay
     products present in the source.
 •   Determine the concentration of each radionuclide
     in the source.
 •   Determine the natural background concentration
     of each radionuclide.
 •   Delineate  source  dimensions  (area,  depth,
     volume).
 •   Investigate source containment.
Observed  Releases  and  Areas  of Observed
Contamination:     Observed  release criteria for
naturally occurring  and  ubiquitous man-made
radionuclides in   the  environment    require
radioanalytical data to:

 •  Identify  all  such  radionuclides  and  decay
    products present in each migration pathway.
 •  Determine the concentration of each radionuclide
    in these media.
 •  Determine the  mean site-specific  natural
    background concentrations of each radionuclide
    in each medium.
 •  Determine the minimum detectable activity
    (MDA) concentration for each radionuclide in
    each medium.

Observed release criteria for non-ubiquitous, man-
made radionuclides in the environment require
radioanalytical data to:

 •  Identify  all  such  radionuclides  and  decay
    products present in each migration pathway.
 •  Determine the concentration of each radionuclide
    in these media.
 •  Determine the lower limit of detection (LLD)
    for each radionuclide in each medium.

In addition, observed contamination criteria for the
soil exposure pathway require radioanrdytical data to

 •  Determine gamma radiation exposure rates at
    one meter above the surface of contaminated
    surficial  materials (or one meter away from
    above ground sources).
 •  Establish natural radiation exposure rates at
    uncontaminated background locations.

Levels of Contamination at Specific Targets:
Media specific benchmarks for radionuclides  used to
establish Level I and Level  II contamination, in
activity units rather than mass units, include:

 •  Maximum Contaminant Levels (MCLs) for the
     ground water pathway and the drinking water
     threat in the surface water pathway;
 •   Uranium Mill Tailings Radiation Control Act
     (TJMTRCA) standards for the soil exposure
     pathway; and
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Planning
                     Site Inspection Guidance
  •   Screening concentrations  for  radionuclides
     corresponding to a 10~6 lifetime cancer risk
     following lifetime exposure via inhalation (air
     pathway) or ingestion  (ground water pathway,
     drinking water or human food chain threats, and
     soil exposure pathway).

Persistence: Persistence criteria for the surface water
pathway require radioanalytical data to determine the
effective radioactive and volatilization half-life for
each radionuclide evaluated.

3.8.6 Radiation Health and Safety Plan

The basic techniques for protecting the health and
safety of the  field investigative team assessing  a
radiation site overlap  those involving other hazardous
substances. Important differences relate to the gamma
radiation exposure pathway, monitoring procedures
for  radionuclide  exposures, and  regulatory
requirements.     Radionuclides emitting  gamma
radiation, even if contained in buried sources, may
expose personnel. Exposure also may result from the
inhalation and ingestion of contaminated air, water,
and soil, from dermal contact or through open  cuts.
A health physicist should be onsite at all times during
the SI to monitor the work of field personnel. Ail
field personnel should meet minimum qualification
criteria for radiation protection, as defined in the
American National Standards Institute's Selection,
Qualification and Training of Personnel for Nuclear
Power Plants, Report No. ANSI/ANS-3.1  (1987).

Exposure conditions and limits are regulated under
Federal statutes. Federal regulations require that
records of personnel exposures must be maintained,
These should include records of external and internal
exposure, records of unusual exposure, records of
exposure from previous employment, and records of
special investigations.

The radiation health  and safety plan should provide
accurate monitoring and  reporting  of  personnel
exposures. The most common personnel radiation
monitors  are  film  badges or thermoluminescent
dosimeters worn by individuals.

Several approaches may be used alone or combined
to assess internal exposure, Air sample analysis may
provide a quantitative assessment of radionuclides in
breathing air. For gamma emitting radionuclides,
calibrated  whole body counters are commonly used to
quantify the body burden of radionuclides.  Since
radionuclides once ingested or inhaled also may be
excreted from the body, bioassays involving urine,
blood, or feces can be used to assess body burdens
for radionuclides.

In addition, adequate records should be maintained to
document personnel qualifications (training, respirator
fit test, medical exams, etc.), personnel access to
controlled locations onsite, and analytical services for
personnel dosimeters, bioassays, work area monitoring
samples, and respirators.

EPA is  developing an Agency-wide radiation health
and safety program. SI investigators should contact
ORP,  the  Safety,  Health, and Environmental
Management Division (SHEM), or Regional health
managers for information on this program.

3.8.7  IDW Plan

Radioactive wastes generated  during the SI must be
packaged  and  removed  according  to  Federal
guidelines.   Contract services are available  for
removal of radioactive wastes. The IDW plan should
discuss  all aspects of radioactive waste temoval. The
IDW plan also should include a plan for the storage
and removal of rinsates that qualify as radioactive
liquid waste. The investigator should consult with a
health physicist to keep current with developing low-
level radioactive waste (LLRW) regulations.  Some
States operate  LLRW repositories.
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Site Inspection Guidance
                         Sampling  Strategies
                                         CHAPTER 4
                                SAMPLING  STRATEGIES
   This chapter discusses sampling strategies for the focused and expanded SI and provides guidelines for
   developing sample plans. The chapter also discusses the conditions and objectives for the single SI approach.
   Special guidance on sampling strategies for sites containing radioactive substances is provided at the end of
   the chapter. The investigator should tailor sampling strategies to collect samples to demonstrate the presence
   of hazardous substances and determine whether those substances have migrated from sources or disposal
   locations. SI objectives and sampling strategies, however, may change as site-specific factors change or
   become known.
Because uncontrolled hazardous waste sites vary
greatly in size and complexity, specific SI sampling
guidelines that apply to all sites are not possible. The
primary purpose of the SI sampling program is to
assess the nature of the problem at the site, and to
support response  and further  action decisions.
Additional purposes include  meeting  public
information needs and  incorporating  remedial
investigation (RI)  sampling objectives whenever
possible. SI sampling is not meant to determine the
full extent of a hazardous substance problem at a site,
nor is it limited to the data needed to score the site
according to the HRS.

Sample locations should be selected based on the
likelihood of detecting hazardous substances at higher
than  background  level concentrations.    After
reviewing available information, the investigator
should prepare the SI sample plan, including the
location, number,  and types of  samples  to be
collected.    Table  4-1 presents  sample planning
considerations.

The investigator should also determine the parameters
for sample analysis. If previous analytical results do
not adequately assess all the potential hazardous
substances, full target analyte list (TAL) or target
compound list (TCL) analysis should be performed.
However, full TAL or TCL  analysis  may not be
required for Sis where previous analytical results
address specific analytes or classes of substances
(e.g., pesticides, volatile organic compounds). Partial
analyses  should be considered  during planning
because they are less expensive or may have lower
quantitation limits than full TAL or TCL analysis.
Section 3.1.1 provides more information on sample
types (e.g., media, waste, grab, field screening).
Also, EPA's A Compendium of Supefund Field
Operations Methods (OSWER Directive 9355.0-14)
contains detailed information on sampling procedures
and techniques.

4.1  SI SAMPLING PRINCIPLES

The following key principles can be the basis of an
effective sample  plan.    Note  that  site-specfic
circumstances, including adverse weather, sampling
equipment problems, sample location accessibility,
health and safety concerns, and CLP scheduling may
affect the application of these principles.

4.1.1 General Sampling Principles

Sample  to  Identify Targets  Exposed  to  a
Hazardous Substance:  Identifying populations or
sensitive  environments  exposed to hazardous
substances is a critical early step in protecting public
health and the environment under the Superfund
program. The presence of contamination at a target
contributes significantly to the HRS score and triggers
a high priority for follow  up action. Absence of
target contamination is also important because it could
indicate that public health is not endangered or that
no further investigation  is necessary.   Sampling
targets (e.g.,  drinking water wells  and  intakes,
sensitive environments,  fisheries)  within target
distance limits can accomplish two objectives during
the SI

  • It may demonstrate a release.
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Sampling  Strategies
                                   Site Inspection Guidance
                       TABLE 4-1: SAMPLE PLANNING CONSIDERATIONS
              CRITERION
                    CONSIDERATIONS
  sources
Source types
Safety
Containment
Available data
  Number of pathways sampled
Pathway media
Strata within HRS pathway media
Targets likely to be exposed to contamination
probability of release to media
Probability of contamination attributable to the site
  Number of QC samples
Screening vs. listing
Field duplicate, replicate, split
Number of samples
Blank (trip, field, equipment rinsate)
Field evaluation
  Number of background and attribution
  samples
Screening vs. listing
Number of source samples
Alternative sources of contamination
  Application (usability) of previous
  samples
Analytical results
Quality
Reliability
Sample dates, locations, and descriptions
Potential for data validation
  Analytical methods
Previous analytical data
costs
Detection limits
  •   A measurable concentration of a hazardous
     substance found at the target may be used to
     evaluate  target exposure  relative to media-
     specific benchmarks.

Analytical support to detect substances at or above
benchmarks, particularly in drinking water samples,
may require planning for special CLP analyses.

As a general rule, sample locations should be selected
for targets that may be contaminated by hazardous
substances likely  to be attributable to the site.
Sampling should focus on migration paths and the
direction of nearest targets. The SI investigator
should evaluate the likelihood of finding measurable
concentrations at various distances from site sources.
               Sample to Identify. Hazardous Substances Present
               at the Site: The objective of sampling sources is to
               identify hazardous substances present and to support
               attributing them to the site. Source samples may not
               be necessary if previous data document the types of
               waste found at the site. However, if data are  not
               available or reliable, sources and other possible waste-
               disposal locations may need to  be sampled.

               If multiple hazardous substances are suspected at the
               site,  sampling should focus on the more mobile
               substances, which are generally easier to locate in a
               specific medium, particularly soil, because of their
               greater tendency to migrate.   Most hazardous
               substances will segregate into one or more media
               based on their physical and chemical characteristics—
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Site Inspection Guidance
                          Sampling Strategies
for example, PCBs tend to bind to soils and may not
be present in all pathways.

Sample to Demonstrate a  Release: SI  sampling
should focus on demonstrating the release of a
hazardous substance to a pathway, particularly when
a release  is either  suspected during the PA and
contributes significantly to the site score or was not
fully documented previously.

To demonstrate a release, analytical data muse

  •   Indicate that the hazardous  substance is present
     at levels significantly above background.
  •   Demonstrate that the significant increase is at
     least partially attributable to the site.

For the soil exposure pathway, the investigator must
collect soil samples to  support the  presence of
observed contamination in surficial materials.

Suspected releases that are not critical to the site
screening or listing decision should  not be sampled.
An SI sampling approach should consider evaluating
the non-critical pathway for potential to release and
allocating samples for the factors critical to the site
score.

Sample  to Discriminate Among Alternative
Sources of Contamination:  If there are multiple
sources of contamination in the area of the site being
investigated,  sampling  should be designed  to
determine  whether the  site is at least partially
responsible for the contamination (see Section 4.5.3).

Sample to Determine Representative Background
Concentrations:  To determine whether  a hazardous
substance is present significantly above background,
the  background level must be known. The
investigator   should    consider   whether   the
concentrations of hazardous substances are related to
naturally  occurring levels  or  offsite influences.
Background samples are normally collected during the
SI However, in some situations they may not be
required-for example, when the substance does not
occur naturally and is known to  be present at the site
based on previous analytical data. The same methods
should be used whenever possible to  sample  and
analyze both background and elevated concentrations.
Sample to Verify Field and Laboratory Practices:
QA/QC samples help to monitor any contamination
introduced by field methods, evaluate laboratory
analytical results, and help increase overall confidence
in analytical results. QA (or performance) samples
relate to procedures regarding program oversight,
while QC samples relate to the methods themselves.
During the SI these samples should be collected
using the  same methods as for other samples-for
example,  the QC  samples should  be stored,
transported, and analyzed in the same manner as site
samples.  Several types of QC  samples  may be
collected, including split and  duplicate samples, as
well as field and  trip  blanks (see Section 3.3).

4.1.2 Focused SI Sampling Principles

The focused SI emphasizes collecting analytical data
to test site  hypotheses generated during the PA and to
determine the need for further investigation. During
the focused SI the investigator collects samples to
determine the types of hazardous substances at the
site, whether a hazardous substance has been released,
and whether the release impacts targets.

During the  focused  SI  sampling  should  test
hypotheses for the ground water  and surface water
pathways where a release suspected during the PA
contributed significantly to the further action decision.
Also, sampling may be warranted to test the presence
of actual contamination for the  soil exposure pathway.
For sites with a suspected release and primary target
hypotheses, sampling to demonstrate actual target
contamination  also  tests  the  suspected  release
hypothesis.

Sample results will be the most important factor in
determining whether or not a site will require further
investigation after the focused SI Making effective
screening decisions with a limited number of samples
depends  on  carefully  planning the  focused SI
sampling strategy. Principles emphasized during the
focused SI sampling include:

  •   Identifying targets exposed to a hazardous
     substance;
  •   Identifying hazardous substances present at a
     site; and
  •    Demonstrating a release.
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Sampling  Strategies
                    Site Inspection Guidance
Other factors that may affect the sampling approach
depend on the objectives of the investigation, number
of site hypotheses to be tested, availability and  quality
of previous analytical results, and site characteristics.
To  illustrate the focused  SI sampling strategy,
consider the example in the sidebar.

Other considerations of focused SI sampling strategies
include the following.

  •   Concentrate samples on  major pathways
     affecting the score:  For most sites, only  certain
     pathways will be of concern after the PA. The
     importance of a  specific  pathway and  the
     individual factor scores for a site must be taken
     into account when developing the focused SI
     sample plan.    Sample  collection should
     emphasize evaluating factors most critical to the
     site score.

  •   Use previous analytical data:  If any previous
     data are usable for the focused SI (see criteria
     discussed in Section 3.2), they should be used to
     evaluate the site and facilitate planning  sample
     locations. For example, if reliable previous data
     demonstrate site-related contamination in an
     area, do not resample these areas during the
     focused SI Note that if previous analytical data
     indicate an HRS score of 28.50 or greater, the
     site may be a candidate for the single SI rather
     than a focused SI

 •   Limit collection of background and QA/QC
     samples: Demonstrating a release or an actually
     contaminated target for screening purposes does
     not require the full complement of background
     and QA/QC samples needed for an expanded SI
     Conserve field investigation hours and sampling
     costs by limiting the number of background and
     QA/QC samples, where appropriate.

Table  4-2 summarizes sampling  criteria and
considerations to help the investigator plan samples to
meet focused SI objectives.

4.1.3  Expanded and Single SI Sampling
        Principles

All sampling principles are emphasized during the
expanded and single SI however, some principles
may apply to a lesser extent depending on availability
         EXAMPLE OF FOCUSED SI
           SAMPLING STRATEGY

   A site advanced to the focused SI based solely
   on suspected contamination of nearby surface
   water used for recreational  fishing. The SI
   investigator proposed to sample  along the
   overland migration path towards surface water.
   However, those samples would not directly test
   the PA hypothesis that the fishery is  exposed to
   contamination. Theoretically,  a single sediment
   sample taken  at a likely area  of sediment
   accumulation in surface water near the probable
   point of entry (PPE) can test two hypotheses—
   suspected contamination of a  fishery and
   suspected release to surface water. A second
   sediment sample collected at the PPE would
   increase    the probability    of  detecting
   contamination, increase confidence  in the
   sample results, and may address quality control
   of sampling procedures.     If  a hazardous
   substance is not detected in the PPE sample,
   the site may receive a SEA recommendation.
   The  investigator may consider  collecting
   several sediment samples from the PPE since
   testing  the  hypothesis  of an   actually
   contaminated fishery is critical to  the screening
   decision.
and  quality  of  information (including  previous
analytical results) to support HRS documentation
requirements. For most sites, not all pathways will
prove to be of concern after the focused SI The
relative importance of the pathway for the site must
be taken into account when planning expanded SI
samples.

The primary objectives of the expanded SI are to
collect fully documented  data to prepare an HRS
package and, for some sites, to collect field data for
the remedial investigation  (RI).     Expanded SI
sampling should be designed to completely investigate
and  document  observed    releases,   observed
contamination, and levels of target exposure to
contamination. The focused  and expanded SI may
require different degrees of documentation for key
HRS factors. For example, if the focused SI indicates
that surface water sediments have high concentrations
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Site Inspection Guidance
                     Sampling  Strategies
                       TABLE 4-2: Priorities  FOR FOCUSED SI SAMPLES
SAMPLE BUDGET
CATEGORY
Number of pathways to
evaluate with samples
Number of targets sampled
Number of sources sampled
Number of release samples
Number of background and
QA/QC samples
Other criteria
PRIORITIES
Sample pathways critical to PA further action recommendation
If multiple pathways are critical to screening decision, plan sampling to test
all critical hypotheses
Sample primary drinking water wells and intakes suspected of exposure to
site-related contamination (see glossary: Primary Target)
Sample nearest targets or targets most likely to be exposed to site-related
contamination for critical pathways if contamination suspected during PA
If sample budget permits, take more than one sample at surface water and
soil target locations that are critical to the site decision
Sample sources to identify hazardous substances present at site
If multiple sources exist, sample each different source type
Sample to test if a release has occurred for critical pathways. When
possible, test release hypotheses in conjunction with target samples
If the magnitude of potentially contaminated targets is responsible for
screening decision, limit number of release samples
Limit collection of background and QA/QC samples to those needed to
screen site. Background or QA/QC samples may not be necessary
Use previous analytical data to plan sample locations
Do not resample at locations where reliable previous analytical data detected
a hazardous substance
of metals, the expanded SI would include collecting
samples   to  establish  sediment background
concentrations to attribute the metals to the site being
evaluated, and samples to document surface water
targets exposed to  actual contamination.

The  expanded SI also involves field  activities to
document aspects  of the HRS evaluation that may be
beyond the scope of a focused SI which is limited to
screening.   If necessary, the following may  be
expanded SI activities:

  • Install monitoring wells.
  • Collect physical parameter data of subsurface.
  • Install boreholes.
Collect non-routine soil gas or air samples.
Conduct geophysical surveys to  delineate areas
of buried waste.
Document waste characteristics for significant
sources (e.g., hazardous waste quantity).
Supplement documentation of releases and areas
of contamination (e.g., fisheries, soils).
Supplement documentation of targets exposed to
actual  contamination.
Distinguish the level of contamination (e.g,
Level I) for targets.
Document  complex  attribution  issues  (e.g.,
industrial areas and ground water plumes).
Support  the  quality of analytical data with
additional QA/QC samples.
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                    Site Inspection Guidance
         EXAMPLE OF EXPANDED SI
           SAMPLING STRATEGY

   A site advanced to the expanded SI based on
   observed contamination on school property and
   a suspected release to ground water. For the
   school property, surficial soil samples detected
   hazardous substances, but concentrations were
   not quite above health-based benchmarks, In
   addition, background soil sample analytical
   results were qualified (coded as "UJ") during
   data validation due to low recovery of internal
   standards. The data reviewer commented that
   these  results  were biased  low,  resulting in
   reported concentrations most likely below real
   concentrations. The investigator did not feel
   confident that these samples  fully investigated
   contamination on the school property, and
   decided to resample during the expanded SI to
   document the threat to resident population
   targets for the soil exposure pathway, including
   the level of contamination for  the student
   population.

   For this site, the only background ground water
   sample collected during the focused SI was  2
   miles  from the  site, and  other sources of
   contamination were nearby. Drinking water
   wells were not likely to be exposed to actual.
   contamination, while the school and several
   residential properties were likely to be exposed.
   The  investigator determined that the  soil
   exposure pathway was a greater threat than the
   ground water pathway, and designed a sampling
   strategy to fully document resident population
   threat targets. For this site, installing wells may
   not be necessary, because the ground water
   pathway can be evaluated based on potential to
   release and potentially contaminated  targets.
 The expanded SI may be used to refine estimates of
 hazardous waste quantity by sampling bulk source
 materials, such as tanks or containers. Other work
 may be necessary to demonstrate the boundaries of
 surficial  contamination  or the total number of
 contaminated drinking water wells, particularly if
several nearby residential properties are likely to be
contaminated, not all of which were sampled during
the focused SI

Other  considerations  for  expanded  SI  sampling
include:

 •   Collect samples to improve  documentation for
     factors that significantly affect scoring:   For
     example, if background levels for ground water
     are in question—perhaps due to data of
     unknown quality-and a release to ground water
     is  critical  to  scoring, the investigator may
     sample to ensure valid data.

 •   Collect adequate background and QA/QC
     samples: Demonstrating a release or a target
     exposed to actual contamination requires the full
     complement of background and QA/QC samples
     to adequately document information for NPL
     purposes.    Background and QA/QC samples
     should not be limited by the sample budget—
     collecting these samples will prevent the need to
     return to  the site.    Section  4.3  discusses
     optimizing the number of  QA/QC  and
     background samples.

Field screening methods may  be used during the
expanded SI to further characterize the site, to
identify CLP sample locations, or to support
documentation  requirements (e.g.,  designing soil
sampling grids, selecting ground water well screen
depths, and better describing the areas of surficial
contamination). If soil samples need to be collected
from adjacent residences or schools to document a
sufficient number of resident population targets for
the soil exposure pathway, field screening may be
used to  identify the samples  submitted for CLP
analyses.

Table 4-3 summarizes expanded SI sampling criteria
and priorities to help the investigator plan and allocate
samples for expanded SI objectives.

4.2 SOURCE  CHARACTERIZATION

Characterizing sources generally requires collecting
source samples  to investigate the types of wastes
deposited at the site and specifically to identify
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Site Inspection Guidance
                                                  Sampling  Strategies
                      TABLE 4-3:  PRIORITIES  FOR EXPANDED SI SAMPLES
   SAMPLING CRITERIA
                            PRIORITIES
  Number of pathways
  sampled
Sample pathways critical to site score

If multiple pathways are critical to site score, sample to fully document all
remaining site hypotheses
  Number of targets sampled
Sample targets (e.g., drinking water wells and intakes, residential and school
properties, surface water sensitive environments and wetlands) most likely to
be exposed to site-related contamination

Resample targets where previous analytical results are questionable, or where
background concentrations are needed to document contamination of targets
  Number of sources sampled
Sample sources to attribute hazardous substances to site

Sample to more fully describe areas of observed surficial contamination

If multiple source types exist at site, at a minimum, sample each different
source type
  Number of release samples
Sample to document a release for critical pathways. When possible, collect
samples to document an observed release in conjunction with a target
exposed to actual contamination

Limit number of release samples to critical pathways
  Number of background and
  QA/QC samples
Collect background and QA/QC samples necessary to confidently document
site score
  Other criteria
Use previous analytical data to optimize sample locations

Do not resample at locations where reliable previous analytical data fully
documented a hazardous substance or a release unless samples are needed to
pair those with background samples taken at the same time
hazardous substances. Investigators should sample as
many different types of sources as possible on the
assumption that different hazardous substances will be
found in different sources. A surface impoundment,
for example, may yield different hazardous substances
than  a waste pile.   Even if analytical data  on
hazardous substances are available, sources should be
sampled to confirm the data. Source sampling could
support attribution if the same hazardous substances
or transformation products  are detected in  samples
taken at release or target sample locations.
                         Samples from visibly contaminated soils may be more
                         useful to characterize sources than samples from a
                         specific drum or container because such samples may
                         identify more hazardous substances. Also, sampling
                         soils presents  fewer safety  issues than sampling
                         containers, If little  is  known about historical site
                         operations and no distinct sources exist, sampling
                         where wastes are most likely to collect, such as onsite
                         ditches, pools, drainage pipes, or other structures, may
                         provide information  on the  types  of  substances
                         previously handled.   Historical aerial photos  may
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Sampling Strategies
                                                 Site Inspection Guidance
show prior disposal areas and changes to site feature
or topography affecting the location of wastes.

When submitting a source sample for CLP special
analytical services (SAS), the SI investigator should
notify  the laboratory  of  hazardous  substances
suspected in the sample, expected concentrations, and
analytical protocols to  be followed.

Table 4-4 compares the focused and expanded SI
source sampling strategies.
                            4.2.1 Focused SI  Strategy—Source
                                    Characterization

                            Identifying hazardous substances present at the site is
                            a prime objective of the focused SI Information on
                            waste management practices or previous data from
                            source areas can reduce the number of  samples
                            needed to characterize the sources. At the end of the
                            focused SI quality-assured analytical data (e.g., CLP
                            data) should identify the specific hazardous substances
                           TABLE 4-4: SOURCE SAMPLING Strategies
       CRITERION
       FOCUSED SI
     EXPANDED SI AND  SINGLE SI
  Primary objective
To identify hazardous
substances associated with site
sources; to confirm substances
known or  suspected

To refine target distance limits
To verify inconclusive data collected during
focused SI

In limited situations, to help quantify hazardous
waste quantity
  Data quality
All DUCs
DUC-I for hazardous constituent quantity

DUC-I and DUC-II to establish heterogeneity
or homogeneity of wastes

All DUCs for other hazardous waste quantity
measures and to identify hazardous substances
associated with site sources
  Samples to help
  demonstrate  observed
  contamination
Generally limited to samples
used to test a site hypothesis
regarding  soil contamination
within 2 feet of surface
Samples to further describe the areas of
observed contamination in the direction of
targets for the soil exposure pathway
  Samples to help
  evaluate source
  containment or source
  type
Generally not collected
Generally only collected when the containment
factor value for a migration pathway is not 10;
sometimes collected to demonstrate a biogas
release if air pathway is significant pathway
  Samples to help
  describe source
  boundaries and estimate
  hazardous waste
  quantity
Generally limited to surficial
samples within 2 feet of
surface

Generally limited to
contaminated soil sources
In certain situations, samples to estimate the
depth of a source or to further describe the
area of sources other than contaminated soil
(e.g., landfill, land treatment, buried surface
impoundment)

In certain situations, samples to estimate
hazardous constituent quantity or hazardous
waste volume quantity
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Site Inspection Guidance
                          Sampling  Strategies
at the site and confirm the presence of substances
known or suspected during the PA.

Samples should not be collected to directly establish
the degree of containment for a source. Containment
generally  can  be  evaluated accurately  by field
observations. Samples collected to identify hazardous
substances, however, may also document poor source
containment, if necessary.

Samples  to support estimates of source volume,
hazardous constituents, and source area are generally
beyond the scope of the focused SI For source types
with  reasonably  well-defined boundaries (e.g.,  surface
impoundments,  waste piles), physical measurements
taken with a steel tape measure or laser range finder
should be used to determine area and possibly  volume
dimensions. Hazardous waste quantity factor values
are determined by calculating a hazardous waste
quantity for each source and then assigning a factor
value for a range of waste quantities. The ranges for
these values are quite broad, so that  a small increase
in quantity, unless near a breakpoint, could have no
impact on the factor value assigned. For example, a
measure  of hazardous waste quantity for the  soil
exposure  pathway is  areal extent  of observed
contamination. More than 78 acres of contaminated
soil would be needed to increase the hazardous waste
quantity  factor value above the minimum value.
Rather than determining the full  areal extent of
contamination, samples should focus on documenting
contaminated targets. The SI investigator  should bear
in mind that actual contamination in water or air may
be sufficient for a site to qualify for the NPL (i.e.,
I-IRS score greater than 57 for a single pathway).

4.2.2 Expanded and Single SI Strategy-
        Source Characterization

Source characterization sampling during an expanded
and  single SI should focus on HRS documentation
requirements. As with the focused  SI background
information on waste management practices or
previous sampling efforts may significantly reduce the
number of samples needed to investigate site sources.
If data from site records and previous sampling
investigations, including the focused SI are of good
quality, little or no source samples may be  needed
during the expanded SI
Some samples used to identify hazardous substances
may be used to document containment for a source.
For  some sites, limited  samples may be collected
during the expanded SI to evaluate the degree of
containment for a source,  or to determine whether the
source is releasing methane or other biogases.

Sampling to document  hazardous waste quantity
estimates  is generally  beyond the scope of  the
expanded SI Such sampling may be appropriate for
some sources (e.g., containers  such as drums and
tanks with homogeneous  wastes), but is generally not
cost-effective given the wide ranges for hazardous
waste quantity factor values and values that can be
obtained using other tiers.

4.2.3 Example of Source Sampling  Strategy

     Located near a town of 10,000 people, the
     Lakefield  Farm  Site  is an abandoned
     strawberry farm that was used for various
     types of waste activities for an unknown
     period (Figure 4-1). During the PA,  three
     potential  sources were identified a wet
     surface impoundment with a volume of
     approximately 45,000 cubic  feet  of
     electroplating sludge; a drum storage area
     containing about  30  leaking  drums,
     contents unknown, at the southeast comer
     of the sie;~ and an area of stained soil near
     the site's western boundary.

As this example  illustrates, understanding the scoring
implications of the wide quantity ranges used to
assign hazardous waste  quantity factor values will
help identify the samples necessary to  determine
substance-specific waste characteristics.  Table 4-5
summarizes a suggested  strategy to characterize the
potential waste sources. For this site, it is reasonable
to sample the soil underlying the drums, assuming it
is representative of the drum contents. In general,
when the contents of any  container are unknown, the
investigator should sample the soils near or beneath
the source and not sample the contents of the source
itself. Direct sampling of the containerized sources
requires specialized expertise, such as the Technical
Assistance Team.
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Sampling  Strategies	                               Site Inspection Guidance
                       FIGURE 4-1: LAKEFIELD FARM SITE SKETCH #1
•
          A
                      Surface Impoundment
                           (Sludge)
                                                            Nearest Well and
                                                               Nearest
                                                              Individual
                                                                   LAKEFIELD
                                                                   FARM SITE
                        Stained Soil
                                                          GREENACRES
                                                          SUBDIVISION
          Source samples                                                               |

          Drinking water well                                Municipal Well          	ft


          Irrigation well                                        ~^9

                                                                              NOT IX) SCALE
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Site Inspection Guidance
                          Sampling  Strategies
                TABLE 4-5: SOURCE  SAMPLING STRATEGY  FOR EXAMPLE SITE
POTENTIAL WASTE
SOURCE AREA
Wet surface
impoundment
Drum storage area
Stained soil
FOCUSED SI
SAMPLING STRATEGY
Collect 1 composite source
sample of impoundment
sediments (SD- 1) plus one
sludge sample (SL-1) to
evaluate hazardous
substances present
Collect 1 composite
surficial soil sample (SS-1)
from beneath drums to
determine hazardous
substances present
Collect 1 composite
surficial soil sample (SS-2)
to determine if area is
contaminated and to
identify hazardous
substances
HRS
CONSIDERATIONS
More than 675,000
cubic feet are needed
to increase HWQ
factor value to next
category value
More than 1,000
drums are needed to
increase HWQ factor
value to next category
value
More than 78 acres of
contaminated soil are
needed to increase
HWQ factor value to
next category value
NON SAMPLING
DATA COLLECTION
Obtain physical
dimensions of source;
evaluate containment.
Consider using aerial
photos
Verify number of
drums evaluate
containment; look for
container markings;
examine area around
drums
Obtain physical
dimensions of area;
evaluate containment
4.3 QA/QC SAMPLES

The investigator should collect appropriate QA/QC
samples during the SI to confirm the collection of
precise and  accurate data that represent  site
conditions. EPA Regional guidelines  suggest the
number of QA/QC samples to collect. These samples
(Table 4-6) should be collected, stored, transported,
and analyzed in the same manner as the other site
samples.

Several types of field QC samples may be used to
monitor contamination of samples-for example,
duplicate and split samples, as well as field and trip
blanks (see Section 3.2). In general, 1 co-located and
1 replicate are taken for each 20 samples at a site.
Some Sis will not require co-located or replicate
samples if fewer than 20 samples are collected. Field
blanks are required for ground water, surface water,
and soil samples at the rate of 1 field blank per
matrix per day, or 1 for each 20 samples at a site,
whichever is fewer. Field blanks are not required for
source material or air samples.
Trip blanks for each day of sampling are required for
ground water, surface water, and air samples that
involve volatile organics. Field matrix spikes are
recommended only if the appropriate technical support
is  available. For some sites, an extra volume of
liquid from a sample location is collected for matrix
spike  analysis; analysis of the spike is requtid by
CADRE. If it is collected, the results should be
compared with  laboratory matrix spike results.

For both field and QA/QC samples, the investigator
should be able to correlate results of specific sample
analyses to those locations  where samples  were
collected during the SI During SI field work, the
investigator should record information regarding
sampling  activities  and observations,  including
sampling protocols and locations, as well as pertinent
physical and topographic features of the site. A map
showing sample locations, contaminated areas, and
other  features pertinent to data evaluation should be
provided. In addition, notations concerning the SI
samples should be made by either the investigator or
the laboratory-for example, whether a sediment
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                    TABLE 4-6: GUIDELINES FOR MINIMUM QA/QC SAMPLES
                                   EXPANDED SI OR SINGLE SI
MEDIUM
Aqueous
Soil and sediment
Air
Source material
REPLICATES/
DUPLICATES
Iin20
Iin20
Iin20
Iin20
FIELD BLANKS
Iin20
Iin20
Not applicable
Usually not required
TRIP BLANKS
I/day of sampling
Usually not required
I/day of sampling
Usually not required
Sample requirements should be developed on a site-specific basis. Laboratory blanks and spikes are method-
specific and are not included in the table.
sample had coarse grains or fine grains, or whether a
ground water sample was muddy or clear. These
notations should accompany the data during reporting.
Analytical data should be accompanied by a table or
matrix that correlates field sample numbers with
laboratory sample numbers.

Reported data should indicate whether samples were
filtered or unfiltered.   This information  may  be
needed to compare  background levels with site
samples and to compare sample data with media-
specific benchmarks.

4.3.1  Focused SI  Strategy—QA/QC Samples

During the focused SI only a few QA/QC  samples
should be collected to ensure that sample results have
not been influenced by contamination introduced
during field activities.  Focused SI QA/QC  samples
might  consist of one trip blank for each day of
sampling activities along with one equipment rinsate
blank for each matrix sampled. Blanks serve  to
indicate  false  positive sampling results,  and  to
monitor  the  field team's sample  handling and
decontamination procedures.

At sites where both soil or sediment and  aqueous
samples  are collected, the SI  investigator should
consider using  only the  aqueous trip blank and
eliminating the soil or sediment trip blank. Aqueous
blanks, unlike soil or sediment blanks, are used to
detect organic  and inorganic contamination.
Generally, contamination introduced by improper field
activities is more easily detected in the water matrix.
The focused SI may also require one rinsate for soil
or sediment sampling equipment and one rinsate for
water sampling equipment.

Duplicate samples for data validation generally should
not be collected during the focused SI since precision
of the data generally will not affect  the screening
decision. Thus, a limited number of QA/QC samples
may be  sufficient to support focused SI objectives.
Generally, these samples should represent 10 to 15
percent of the total number of samples collected.

4.3.2 Expanded and Single SI Strategy—
        QA/QC Samples

During  the  expanded  and  single SI the  full
complement of QA/QC samples should be collected
to ensure data of rigorous quality. In contrast to the
focused  SI strategy, duplicate  samples for  data
validation may be appropriate to monitor the precision
of the analytical data. Trip blanks should be collected
for all media sampled during the expanded  SI If
hazardous substance concentrations likely are to be
near detection  limits  or near  media-specific
benchmarks,  multiple samples at critical locations
may also be appropriate.

In summary, a greater number of QA/QC samples
may be necessary to support expanded SI objectives.
As a general rule, these samples are 15 to 25 percent
of the total number of samples collected.
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4.4 SAMPLE TO DEMONSTRATE A
     RELEASE

4.4.1 General Principles

This section  discusses three considerations for
sampling to demonstrate  a release or observed
contamination-background, attribution, and  target—
followed by focused and expanded SI strategies.
Table 4-7 compares SI strategies to investigate a
release.

To demonstrate a release by chemical analysis for a
pathway,  at  least  one   sample  must  show
contamination significantly above the background
level for a hazardous substance, In the absence of
any other evidence, the sampling strategy should
generally specify collecting at least two samples from
each appropriate pathway to demonstrate a release:

 •  One sample representative of background levels
 •   One  sample  downgradient (or downslope,
    downstream,  downwind) of the source of
    contamination

Since concentrations of hazardous substances usually
decrease with  distance from sources, sampling near
sources may  also help to distinguish between
alternative sources of contamination in the vicinity of
the site,
Background Sampling Considerations

Establishing a release requires evaluating background.
Background is the ambient  concentration of a
hazardous substance and includes naturally occurring
concentrations, concentrations from man-made sources
other than the site being evaluated, and concentrations
from the site. Generally, background levels  are best
supported by chemical analysis.

Background and release samples and analyses should
be similar, and should focus on the comparability of
samples in representing target impacts. To establish
background by chemical analysis, the location and
number of background samples depends on

 •  Hazardous substances present at the site and
    expected concentrations
 •  Availability and quality  of previous information
    and analytical data
 •  Objectives of the investigation
 •  Site hypotheses to be tested
 •  Media variability
 •  Size of the site and number of sources types
 •  Pathway-specific considerations (e.g., geologic
    formations, types of surface water bodies)
 •  Other potential sources of contamination in the
    vicinity of the site
                   TABLE 4-7: OBSERVED RELEASE SAMPLNG STRATEGIES
CRITERION
Objective
Data quality
Background
samples
Attribution samples
QA/QC samples
FOCUSED SI
To test hypothesis (suspected release)
Less rigorous (e.g, DUC-II) to rigorous
(e.g., DUC-I)
Limited, 1 background to 3 release
samples
May rely on published regional data
Limited to what is necessary to test
hypothesis (suspected release)
Limited to what is necessary to test
hypothesis (suspected release)
EXPANDED SI AND SINGLE SI
To demonstrate a release based on HRS
documentation requirements
Rigorous (e.g., DUC-I)
2 background to 3 release samples
Generally should not rely on published data
to establish background levels
Those necessary to attribute a portion of a
release to the site being evaluated
Those necessary to obtain precise and
accurate data within the scope of the SI
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In some situations, appropriate background sample
collection may  not  be possible-for example, no
sample could be taken that would represent surface
water background levels for comparison with sample
concentrations from an isolated pond adjacent to a
site. In other situations, background samples may not
be needed. For  instance,  if sample results over a
period of time  indicate that  a well was  once
uncontaminated  and  is now contaminated, that well
can establish its own  background and release levels.
Also, some man-made hazardous substances (e.g.,
chlorinated organic solvents, short-lived radioactive
substances) are not naturally occurring or ubiquitous
and can only be attributed to a man-made source. If
the site is the only source of these substances, the
background levels are assumed to be zero (or below
detection).

An SI may  not require sampling to establish
background levels of a specific hazardous substance
if the following conditions are met:

  •   The specific substance is known to be present at
     the  site  based  on previous analytical  data,
     historical records, or other information such as
     written statements.
  •   The  specific substance  is  not  known to be
     naturally occurring or ubiquitous.
  •   No  other sources of contamination  for that
     substance are identified in the vicinity of the site
     (particularly for nonindustrial areas).
   The HRS documents an observed release in one
   of two ways:

     •   Direct observation:  Material containing
        a hazardous  substance  is  observed
        entering or  is known to have directly
        entered the medium (i.e., ground water,
        surface water, or air) from the site (e.g,
        through direct deposition of substances
        below the water table, or  an outfall
        discharging to surface water).

     •   Chemical analysis: Analytical evidence
        of a hazardous substance in a medium at
        concentrations significantly above the
        background  level where a portion of the
        significant increase is attributable to site
        sources.
Potential background sample locations include nearby
wells that are not expected to be influenced by the
site or sediments from non-tidal surface water bodies
upstream from the probable point of entry (PPE) to
surface water. Background samples for each pathway
are discussed in Sections 4.5 through 4.8.

Analytical data near method detection limits and
qualified  sample  results complicate  the use of
background sample data. During the expanded SI
collecting  additional background  samples  from
representative locations may increase the confidence
in determining the presence or absence of site
contamination.

Some hazardous  substances  (e.g., lead, arsenic,
copper) occur naturally in  many areas. If they are
used in scoring,  background  levels are best supported
by samples of representative ambient conditions.
Without site-specific background data, background
levels may be based  on other data for naturally
occurring concentrations of the substance.    The
investigator should consider the following sources of
information:

  •   Background  sample data for other nearby
     CERCLA site investigations
  •   Local surveys by other Federal or State agencies
     (e.g., Soil Conservation Service, TJSGS, BLM,
     mining industry)
  •   Local universities (e.g., graduate theses)
  *   Natural concentration ranges and averages in
     soil

Published naturally occurring  ranges of common
metals and inorganic may sometimes be used to
determine background levels and  to assess whether
site-specific substance concentrations are indeed
representative of regional background variability.
However, published values may not account for
regional    variations or   unique   site-specific
characteristics.  Even when concentration data from
scientific literature may not be appropriate to establish
a background concentration for the site, such data
may be used to plan SI samples and to support data
interpretation.

As a general  rule,  the investigator should use
background concentration data from this sampling
investigation.   However, in the absence of data
generated from a SI published data may be used to
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establish background levels if documentation indicates
that the published background data and the sample
data  showing  contamination  have  similar
characteristics, or are influenced equally by alternative
sources of contamination. For the focused SI site-
specific background data are less essential,

Attribution Considerations

To demonstrate an observed release, some portion of
the release must be attributable to one  or  more
sources at the site. Where attribution of hazardous
substances is questionable, sampling  should  be
designed to produce analytical data that demonstrate
the site to be  at least partially responsible for the
contamination. Contributions from other sources of
contamination may be differentiated by identifying a
single hazardous substance that is unique to the site
being evaluated (e.g., wastestream "fingerprinting").
This may require specific analysis and specific review
of the data.

In many cases, the she being evaluated is not the only
source,     Complex  attribution  concerns  (e.g.,
widespread ground water contamination involving
several substances, soil contamination in an industrial
area, sediment  contamination in harbors) may require
investigation  better suited to the expanded  SI
However, if attribution is not  complex, it can be
addressed  during the focused SI For many  sites,
attribution concerns   may be  addressed by
characterizing sources at the site.

Target Considerations

When evaluating actual contamination, particularly the
level of human food chain contamination (see Section
4.6), the investigator should note any potential for
sampling errors and false assumptions affecting data
representativeness.    If the  concentration  of  a
hazardous substance  meets actual  contamination
criteria and equals  or exceeds its benchmark
concentration, the  sample location is considered
subject to Level I contamination for that pathway or
threat,     If media-specific  hazardous  substance
concentrations  analyzed in the target sample meet the
criteria for actual contamination for the pathway but
are less than the media-specific benchmark, or if none
of these hazardous substances have an  applicable
benchmark, Level II concentrations apply. Special
"F'and "J" indices, based on screening concentrations,
   In the HRS, significance relates only to the
   concentration found in a pathway, not to any
   health or environmental effects. A release may
   be below the recommended regulatory action
   level and still constitute an observed release. If
   the site qualifies for the NPL, remedial studies
   will determine the  risks associated with the
   release and appropriate corrective actions. The
   criteria used  to determine analytical significance
   include the following:

    •  A sample measurement confirms that the
        release  is equal to or greater than the
        sample  quantitation limit (SQL). The SQL
        is the amount of a hazardous substance
        that can be reasonably quantified, given
        the limits of detection for the methods of
        analysis and sample characteristics that
        may  affect quantitation (e.g., dilution,
        concentration).

    •  If the background concentration is not
        detected or is less than the detection limit,
        a  release is  established if the sample
        measurement equals or exceeds the SQL.
       For HRS purposes, the detection limit used
        is the method detection limit (MDL) or the
       instrument detection limit (IDL) for real-
       time field instruments.

    •  If the background concentration equals or
       exceeds the detection limit, a release is
       established if the sample measurement is
       at least three times  the  background
       concentration and attribution is established.
are  calculated  when no hazardous  substance
individually equals  or  exceeds its benchmark
concentration, and when more than one hazardous
substance meets the criteria for actual contamination
for the sample (or comparable samples). If either
index equals or exceeds  1, Level I  concentrations
apply for the sample location.

Under certain circumstances, sample data that are
biased high may be used to score an observed release,
but such data must only be used to establish Level II
contamination, not Level I contamination and not
hazardous waste quantity Tier A.
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4.4.2 Focused SI Strategy-Sample to
        Demonstrate a Release

Focused SI  sampling  does not  require fully
documenting observed  releases, which often involves
extensive background sampling as well as sampling to
rule out other sources of contamination.  To
demonstrate a release,  analytical data must indicate
that a hazardous substance is present at an elevated
level  and is  related  to the site.    Sampling to
demonstrate  actual target contamination  also
investigates a release hypothesis. The scope of the
focused SI does not  require  collecting  the  full
complement of background and field QA/QC samples,
which can total as much as 30 percent of all samples
for a complete listing investigation.  Sampling to
document attribution  is typically an expanded SI
activity. However, the  focused SI can include some
background  and  QA/QC samples, according to
Regional or  State guidelines,  to increase  the
investigator's  confidence  in  the quality and
representativeness of analytical results.

Focused SI sampling should concentrate on providing
evidence of contamination in the ground water and
surface water pathways  where a release was suspected
during the PA. Also, samples should be collected to
support or  refute the presence of  surficial
contamination for  the soil exposure pathway. Air
sampling is  an expanded SI activity.

4.4.3 Expanded  and Single  SI  Strategy—
        Sample to Demonstrate  a Release

Expanded SI sampling should focus on demonstrating
and documenting a  release based on data of rigorous
quality. The full complement  of background, QA/QC,
and attribution samples should be collected.  In
contrast to the focused  SI which tests the hypothesis
of a release, expanded SI sampling should meet HRS
documentation  requirements for a release, The
expanded SI should also include samples linking the
presence and  migration of hazardous substances to
sources at the site.

Representative background samples  may be difficult
to collect if the sample  medium is heterogeneous and
the background samples are subject to interference
from alternative sources of contamination (e.g., urban
soils). If any existing background samples are subject
to  potential  interference, the investigator should
determine if they accurately represent background
conditions by assessing whether the interference:

 •  Affects  background  and  release  samples
    significantly;
 •  Affects background and release samples equally;
 •  Affects background and release samples; and
    unequally and bias can be determined.

If  the interference is  insignificant, background
samples from previous investigations may be used.
Likewise, if both  samples are  affected  equally,
previous background data may be appropriate. If the
samples are affected unequally, previous background
concentrations biased high may be used; background
concentrations that are biased low should not be used.

4.5 GROUND WATER  PATHWAY

The ground water pathway score  and the aquifers and
wells to be sampled depend on the:

 •  Number of people served by each aquifer
 •  Likelihood of a release to each aquifer
 •  Likelihood that  drinking water wells are
    contaminated by the site

To document a release to  ground water by direct
observation,  material containing one or more
hazardous substances must be known to have entered
ground water through direct deposition or must be
seen entering  ground water.   Direct deposition
establishing a release may include  injection and
deposition of hazardous substances below the water
table. In most cases, chemical  analysis of ground
water  samples  from an aquifer is preferred to
establish a release.

To document whether a population is drawing from a
contaminated  drinking water supply, the analytical
results must demonstrate a release to the pathway by
   If  SI targets  include  municipal wells
   hypothesized to  be  exposed  to actual
   contamination, the investigator should review
   well monitoring data under the Safe Drinking
   Water Act to determine if the well has  been
   properly monitored and if adequate data exist to
   determine whether the well is contaminated,
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HRS criteria.    A  drinking water  well  and  its
background well must be finished in the same aquifer
and screened in a comparable zone.

Filtration of ground water samples for metals is one
way to reduce the turbidity of highly turbid samples
due to rushed well construction practices. However,
if some samples are filtered, other samples should be
filtered to ensure comparability. Unfiltered samples
may be  used  to establish a  release for  many
hazardous substances.

When sampling ground water, the investigator should

 •   Collect the appropriate types of water samples.
 •   Collect only unfiltered metals samples from
     karst aquifers;
 •   Collect only unfiltered water samples for the
     analysis of organic substances;
 •   Collect background well samples  from the same
     aquifer as  the wells used to establish a release;
 •   Verify that samples are representative  of the
     ground water at that location;
 •   Verify that the  sample  is not  altered  or
     contaminated  by sampling and handling
     procedures; and
 •   Clearly designate whether data derived from the
     samples are from filtered or unfiltered samples.

If the wells are screened, the well screen intervals
must be in the same aquifer, particularly when water
occurs within small lenses isolated by  clay segments
in surrounding material (e.g, glacial terrain).

Even if  interconnection of  aquifers  has been
established, both background and release wells must
be completed in the same aquifer. For example, a
background sample from a bedrock aquifer must not
be compared with a sample from a surficial alluvial
aquifer, even  though the two  are hydrologically
connected.

To the degree possible, background  and observed
release samples should be taken from approximately
the  same  depth in the aquifer  of concern.  In
determining depth, the investigator should consider
elevation relative to a reference (e.g., mean sea level)
rather than depth below the ground surface.

To the degree possible, well completion techniques
should be similar for background and observed  release
wells. Because some hazardous substances adsorb to
suspended matter, unfiltered water samples from
separate  wells that vary in suspended matter
concentration may not be comparable, For example,
an older drinking water well may provide water
containing very little suspended matter, while a new
or incomplete monitoring well may yield  samples
containing substantial suspended matter.

Background and release samples are best collected
within 1 to 3 days.   Background wells should be
outside the influence of sources at the site. Ground
water samples should not be affected by artifacts of
sampling equipment or procedures.

4.5.1 Focused  SI  Strategy-Ground Water
        Pathway

Sampling to establish observed release is  not
necessarily a focused SI objective. Documenting an
observed  release  for the  ground  water pathway
according to the HRS may require  installing
monitoring wells, which is beyond the scope of the
focused SI If background data are critical to the site
screening recommendation and no applicable wells
exist, the  investigator could establish background
through one of the following:

  •  Published data on regional ground water quality
  •   Samples  from a well potentially less influenced
     by the site (e.g., a more distant well)
  •   Reliable  previous data from a nearby site

Every well identified as a primary target need not be
sampled during the focused SI The investigator
should review PA scoresheets to select drinking water
well sample locations most likely to detect hazardous
substances.   Investigators should sample existing
wells if they are strategically located for critical site
decisions.

If a release to ground water was hypothesized during
the PA, the SI investigator should sample the nearest
well suspected of contamination. If contamination of
drinking water was hypothesized and the nearest well
is not a drinking water well, sampling the nearest
drinking water well in addition to the nearest well
would be a feasible strategy; sampling the nearest
drinking water well may be more  informative and
could serve to test both the release and contaminated
target hypotheses.
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If actual contamination of drinking water wells is
suspected, these wells should be sampled during the
focused SI to test hypotheses and determine the level
of contamination. If sampling every drinking water
well suspected of contamination  is  not possible,
nearby wells, especially municipal wells, should be
sampled  if there  is a reasonable probability  of
detecting a release and target exposure. Additional
sampling to more clearly define all contaminated
drinking water wells may be conducted during the
expanded SI if necessary.

If a blended municipal water supply system has more
than one well within 4 miles of site sources, the SI
investigator should sample the nearest well of the
system. If the direction  of ground water flow is
uncertain, the nearest wells reasonably expected to
have contamination attributable to the site should be
sampled. The investigator may also want to sample
additional drinking water wells to ensure  protection of
public health.

Nearby wells drawing from the aquifer and screened
at similar depths are potential background sample
locations. The wells may be monitoring, private,
public, industrial, or  irrigation wells.   The SI
investigator can compare analytical results from
drinking  water wells with  these background wells.

Background samples may not be necessary during the
focused SI to confirm whether hazardous substances
have migrated from some sites. For example, if the
hazardous substances associated with the site are not
naturally occurring and no other potential sources
exist in the area, the focused SI investigator should
collect the minimum number of background samples
to screen the site. In this example, the focused SI
investigator need not collect any background samples.

4.5.2 Expanded and Single SI Strategy—
        Ground Water  Pathway

The expanded SI ground water pathway  investigation
should begin  with a  careful  review  of existing
analytical data from wells within the vicinity of the
site. The SI investigator should review existing  data
to identify abnormalities and any required resampling.
For example, if a background sample  contains an
unusually high level of metals, the investigator should
suspect artificially induced sample contamination
(e.g., entrained sediments) and should review the data
with the program staff responsible for collecting and
analyzing   the  sample  to  determine   if  the
contamination warrants resampling.

Samples from existing wells finished in the aquifer
being evaluated or installation of monitoring wells
may be necessary if no reliable data exist. The wells
being evaluated for a release should also be finished
in that aquifer and screened at a depth comparable to
the background well.   Multiple wells should be
selected to increase the likelihood of intercepting the
contaminated plume.

In most cases, a ground water background sample will
be needed, requiring samples from a minimum of two
wells to document a release, The selection of these
wells depends on the direction of ground water flow.
To determine flow direction, the investigator can:

  •   Install piezometers;
  •   Compare static water-level elevations in a series
     of wells completed in the same aquifer;
  •   Review published hydrogeologic reports; and
  •   Examine  evidence   of other  previously
     investigated nearby ground water contamination.

One well in the aquifer being evaluated should
generally be upgradient of the  site to serve as a
background measure.     While  an  upgradient
background well is preferred, any well outside (or, in
some cases, within) the influence of sources at the
site can be used to establish background levels.

If background wells are not available, a spring sample
collected before the ground water reaches the surface
may be used to establish background. A pipe should
be inserted near the point of ground water discharge
at the spring. The investigator  should accurately
document the sampling procedure  in the field
logbook.   Table 4-8  compares the focused and
expanded SI ground water sampling strategies.

Well installation

Monitoring wells should not be installed unless they
are necessary for the site score to be 28.50 or greater
based on an  observed release.   It may not be
necessary to document a release if the site will score
28.50 or greater due to other major pathways, or if
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                     TABLE 4-8: GROUND WATER SAMPLING STRATEGIES
CRITERION
Primary objective
Data quality (see
section 5.2)
Average number of
samples
Types of activities
Background samples
Attribution samples
QA/QC samples
FOCUSED SI
To test hypotheses regarding a suspected
release or targets suspected to be exposed
to actual contamination
When possible, test release hypothesis in
conjunction with target sampling
Less rigorous (e.g, DUG -II) to rigorous
O to 6 depending on site hypotheses and
number of existing wells to sample
Sample existing wells
Install drive points or shallow boreholes
if there are no nearby wells
Limited, 1 background per 3 release
samples
May rely on published regional data
Limited to testing release hypotheses
Limited to testing release hypotheses
EXPANDED SI AND SINGLE SI
To demonstrate a release based on HRS
documentation requirements
To demonstrate targets exposed to actual
contamination and determine levels of
exposure
Rigorous (e.g., DUC-I)
O to 14 based on HRS documentation
requirements
Resample existing wells if previous data
did not conclusively demonstrate a release
or targets exposed to actual contamination
Sample wells not yet sampled
Collect multiple samples from drinking-
water wells where hazardous substance
concentrations are likely to be near
benchmarks
Install monitoring wells as needed
2 background per 3 release samples
Install background monitoring wells, if
necessary
Generally should not rely on published
data
Those necessary to attribute a share of a
release to the site
Those necessary to obtain precise and
accurate data
the ground water pathway already scores high based
on potential to release.   Before deciding to install
wells, the investigator should also consider:

  •  Unknown source of the contamination in nearby
     wells
Depth to aquifer and type of geologic materials
underlying site sources
Likelihood of detecting contamination in the
monitoring wells
Installation costs
Public health concerns
                                               63

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Sampling  Strategies
                     Site  Inspection Guidance
          DNAPLs - A Special Case

   Dense nonaqueous phase liquids (DNAPLs) are
   separate-phase hydrocarbon liquids that are
   denser than water, such as chlorinated solvents,
   wood preservative and coal tar wastes, and
   pesticides.  DNAPLs, also known as sinkers,
   move downward under the influence of gravity
   until reaching a less permeable formation where
   they  may  accumulate,  move down-slope, or
   penetrate fractures. Special precautions need to
   be taken at sites with DNAPLs to ensure that
   drilling does not induce the spread of free-phase
   DNAPL contamination.  Drilling should be
   suspended when a low-permeability unit or
   DNAPL is  encountered. Fine-grained aquitards
   (such as clay or silt) should be  assumed to
   permit  downward migration of DNAPLs. For
   guidance  on  sites with potential DNAPL
   contamination, see Estimating the Potential for
   Occurrence of DNAPL at  Superfund  Sites,
   OSWER Directive 9355.4-07FS, 1992.
The primary objective of installing wells is to collect
ground water data that can be used to establish a
release. Other goals are beyond the scope of the SI—
for example, to delineate a hazardous substance plume
or track movement of a substance.

During monitoring well installation, the field team
geologist should prepare a drilling log. The log should
describe the general texture, color, size, lithology, and
depth of the geologic materials encountered during
drilling. Information obtained during well installation
may be used to document potential to release factors,
including lithology, hydraulic conductivity, travel
time, and depth to aquifer.

Caution should be exercised when correlating data
between drill holes. Extrapolations of data more than
20 feet apart are not acceptable in nonhomogeneous
geologic environments. To  assess the homogeneity of
the subsurface geology, site-specific data should be
compared to regional geologic information.

Drilling can create interconnections between karst
aquifers.   Installing  wells in a karst aquifer  is
generally not recommended due to the high likelihood
of introducing hazardous substances into karst
aquifers.

4.5.3 Example of Sampling Strategy

     The PA determined that residents near the
     Lakefield Farm  Site rely on shallow
     domestic wells  for drinking  water.  A
     municipal well that provides drinking water
     to about 10,000 people is located 0.5 mile
     southeast of the site. The municipal well
     and several nearby irrigation wells are
     screened in  the  deep  aquifer,  which
     appears to be interconnected with the
     shallow aquifer,   The PA identified all
     domestic wells within 0.25 mile of the site
     and the municipal well as primary targets.
     The focused SI indicated ground water
     flows to the south. Several domestic wells
     appear to be downgradient from the site
     (Figure 4-2).

The SI investigator  and EPA Regional site assessment
manager planned a two-stage SI for this site because
of the large number of ground water targets and the
lack of reliable previous information, Based solely on
the ground water  pathway, the site will not score
greater than 28.50 if evaluated on potential to release,
given the maximum waste characteristics score this
site could receive (18), and potentially contaminated
ground water targets. The site will not score above
the cutoff unless the municipal well (Sample GW-12)
or four domestic wells, as well as domestic wells in
the Green Acres subdivision, are exposed to actual
contamination. Based on these considerations and
source conditions described earlier, the focused SI
required 18 samples—1 municipal well, 9  private
wells, 4 source, 2 background, and 2 QA/QC—to test
site hypotheses. If these wells are not contaminated,
Lakefield Farm may not  require further Superfund
investigation.

Background conditions  for the municipal well could
be established by sampling the irrigation wells north
of the site (GW-1 and GW-2), which draw from the
deeper aquifer. Background samples might also be
collected  from  the  shallow  aquifer to  compare
samples  from the  domestic wells. Field blank and
equipment rinsate samples could  be collected for
QA/QC. Table 4-9 summarizes the suggested focused
                                                  64

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Site Inspection Guidance
                                                                   Sampling  Strategies
                 FIGURE 4-2: LAKEFIELD FARM SITE SKETCH #2
                                         GW-1
                                                    GW-2
                                                      LAKEFIELD
                                                      FARM SITE
                                                                        Direction of
                                                                      groundwater flow
                                         GW-4
KEY
Drinking Water Well
Source Sample
Irrigation Well
                              _,,
                              tjW"9
                            GW-10      GW-11
                                            GW-6    GW-7    GW-8
                                                  GREEN ACRES
                                                   SUBDIVISION
                                                Municipal WeU
                                                   GW-12

                                                                    NOT TO SCALE
                                      65

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Sampling Strategies
                    Site inspection Guidance
           TABLE 4-9: GROUND WATER SAMPLING STRATEGY FOR EXAMPLE SITE
                                          FOCUSED  SI
SAMPLES
Municipal well
(GW-12)
Domestic wells
(GW-3 through
GW-11)
Background
(GW-1, GW-2)
Sources
(SD-1, SL-1,
SS-1, SS-2)
Quality control
(Q-l, Q-2)
(Not shown)
SI SAMPLING
STRATEGY
Collect sample prior to
treatment; sample to
document contamination,
identify hazardous
substances, and determine
level of contamination
Sample nearest domestic
drinking-water wells
suspected of exposure to
contamination
Sample drinking water
aquifer; limit number of
background samples
Collect grab or composite
soil samples to identify
hazardous substances
present at site
Monitor sample collection
and decontamination
procedures; 1 rinsate and 1
field blank
HRS CONSIDERATIONS
Determine municipal well
contamination, which is critical
to protecting public health and
the screening decision
Determine domestic well
contamination, which is critical
to protecting public health and
the screening decision
Sample to determine
concentrations of hazardous
substances
Do not sample to increase
hazardous waste quantity
(amounts are not close to HWQ
factor value breakpoints)

NONSAMPLING
DATA COLLECTION
Verify aquifer from
which well draws; verify
population served
Verify aquifer from
which wells draw; verify
population served
Verify aquifer from
which well draws
Obtain physical
dimensions of surface
impoundment and
estimate area of
contaminated soil; verify
number of drums and
look for drum labels

SI sampling strategy. Other focused SI considerations
include:

  •   Collecting a second sample from the municipal
     well to increase the  chance of documenting
     contamination;
  •   Collecting additional samples to demonstrate
     background conditions;
  •   Verifying ground water flow direction by
     measuring water levels in wells; and
  •   Checking  if  contamination  has  been
     demonstrated in the deep aquifer within 2 miles
     of the site.
For this example, assume that focused SI sample
results indicate that the municipal well sample was
not contaminated, but one ground water sample (GW-
4) showed elevated concentrations of a hazardous
substance also found  during source sampling. Based
on these results, the site score is not greater than the
cutoff score:  the site is  screened  from further
Superfund consideration; and the expanded SI may
not be necessary. The focused SI met its objectives,
and EPA can refer the site and the contaminated
domestic well to the appropriate authorities  (e.g.,
removal program or State authorities).
                                               66

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Site Inspection Guidance
                          Sampling Strategies
As a variation to this example, assume that two
domestic wells south of the site were closed prior to
the SI due to  contamination by volatile organic
compounds (VOCs), and just east of the site are two
facilities that use solvents.  In  this scenario, it is
uncertain whether Lakefield Farm has contributed to
ground water contamination. Monitoring wells may
need  to be installed to  attribute a portion of the
contamination to the site. If ground water is the only
significant pathway, and because attribution is critical
to determine whether  this  site requires further
Superfund attention, installing these wells may be
planned as a  single SI that bypasses the focused SI

4.6  SURFACE WATER PATHWAY

In general, sample locations for the surface water
pathway include rivers, brooks, or streams flowing
through or adjacent to a source, as well as bodies of
water that may receive overland runoff or leachate.
Before identifying sample locations, investigators
should determine whether overland runoff or ground
water discharge  to  surface  water can result in
contamination of a surface water body. The likely
overland runoff pathways may be determined by
reviewing the drainage network in the vicinity of the
site. Generally, if there are no surface waters within
2 miles of the site, the surface water pathway need
not be evaluated.

The  investigator should review  the  physical
characteristics of the  surface water migration route.
Some hazardous substances mix and disperse rapidly
in turbulent waters, while others may remain as a
plug or plume for longer distances in less turbulent
waters. The latter may reach a surface water target
while still concentrated.  The SI investigator should
consider the  influence of conditions such as rocky
bottoms, rapids, and meanders on the likelihood of
detecting hazardous substances.

The types and locations of water bodies near the site
and the persistence of hazardous substances should be
considered when developing the surface water sample
plan. For abandoned or inactive  sites, collecting
sediment samples may be more appropriate  than
collecting aqueous  samples. Flow  rate is also a
consideration because  high-volume flows tend to
disperse and dilute hazardous substances more quickly
than low-volume flows.
An observed release  to  surface  water may  be
documented through direct observation if material
containing hazardous substances are:

  •   Seen entering surface water;
  •   Known to have entered surface water through
     direct deposition; or
  •   Present in a source area in contact with surface
     water  through  flooding.

A single, short-duration discharge of hazardous
substances  to surface water may establish  a release,
even without upstream and downstream samples.
Leachate flowing from a source into surface water
and an  outfall  from  a surface  impoundment
discharging to surface water are examples of direct
deposition into surface water. In these cases, samples
(or other analytical  evidence) should be collected to
show that the leachate and outfall materials contain a
hazardous substance.

Some analytical results will be compared with media-
specific benchmarks.   For drinking water targets
suspected to  be  subject to  actual contamination,
samples (either aqueous, sediment, or sessile benthic)
should  be collected at or downstream of the  targets to
score Level I or Level II  contamination.   Only
aqueous  samples can  be used to  score Level I
drinking water targets; aqueous, sediment, and sessile
benthic organism tissue samples can be used to score
Level  n.    Surface water samples  that cannot
demonstrate Level I contamination may still be used
to support Level II contamination.   Table 4-10
summarizes the types of samples for each surface
water  pathway  threat and the  level  of  actual
contamination each sample type can support.

If documenting    actual  human food  chain
contamination is essential to the site recommendation,
sediment samples should be considered in preference
to catching  and analyzing organisms. Tissue samples
of aquatic  food chain organisms may be  collected
during the expanded SI if necessary, to evaluate
immediate health  and environmental threats. Prior to
collecting samples,  the investigator should  review
HRS guidance and food chain threat benchmarks for
those substances expected to be present in fish tissue
and benthic organisms. Sessile benthic human food
chain organisms include mussels and oysters. Non-
sessile  benthic organisms  include crabs,  snails,
                                                  67

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Sampling Strategies
                    Site Inspection Guidance
       TABLE 4-10: SURFACE WATER SAMPLES TO SUPPORT A RELEASE AND TARGET
                                        CONTAMINATION
HRS Factors
Observed release
Level I drinking water
Level II drinking water
Level I sensitive
environments
Level n sensitive
environments
Level I fisheries
Level II fisheries
Sediment1
Yes
No
Yes
No
Yes
No
Yes5
Aqueous
Yes
Yes
Yes
Yes
Yes
No
Yes5
Effluent2
Yes
No
Yes
No
Yes
No
Yes5
Sessile
Benthic
Organisms
Yes
No
Yes
No
Yes
Yes3
Yes3
Non-sessile
Benthic
Organisms
No
No
No
No
No
Yes3'4
No
Finfish,
Amphibians,
and Reptiles
No
No
No
No
No
Yes3'4
No
1 No benchmarks available; evaluate as Level II contamination.
2 Does not require comparison to background to document a release.
3 Sample only tissues of edible species to evaluate human food chain level of contamination.
4 Can be used to score Level I targets, but not an observed release; must be collected within boundaries of
surface water contamination.
s Targets can be evaluated if hazardous substance has a bioaccumulation factor value of 500 or greater.
crayfish, and lobsters. Examples of other aquatic
human food chain organisms include fish, frogs, and
eels. Samples may be collected at any point within or
beyond a fishery boundary to evaluate actual human
food chain contamination.

For water bodies where fishing is  prohibited, if a
hazardous substance for which the fishery was closed
is found in a release sample within the boundaries of
the closed fishery, samples from the water body can
be used to score actual contamination even though no
human food chain organism presently exists.

For the environmental threat, samples  should be
collected at, or downstream of, wetlands and other
sensitive environments suspected of contamination.
Only aqueous samples can be used to score Level I
environmental contamination.   If the investigator
suspects that a wetland is exposed to contamination,
in addition to samples near the PPE, two samples
should be collected from the wetland which are at
least 0.1 mile from the PPE into surface water. Data
from unfiltered surface water samples should be
compared to ecologically-based benchmarks.

Unfiltered samples may be used to establish a release.
Water samples collected to analyze organic substances
do not  have to be filtered for  comparison with
drinking water benchmarks.

Special precautions should be taken to ensure that
samples  are representative of the surface water at that
location, and that the sample is not  altered or
contaminated by sampling and handling procedures.
Background samples should be collected in the same
water body as samples used to investigate a release—
for example, the investigator should not compare a
background sample from a small tributary and a
release sample from a major river.   In addition,
chemical and physical properties of surface water can
vary considerably within a small  area. The lack of
mixing in large, slowly flowing segments of rivers
                                                68

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Site Inspection Guidance
                          Sampling Strategies
may affect  background levels.    Also,  chemical
transformations, biological influences, and physical
transport mechanisms  may  affect surface  water
quality. Background and release samples should be
collected during the same time period.

Other sampling considerations include:

  •   Weather conditions affecting streamflow
  •   Grain size, organic content, and structure of
     sediments

Higher streamflows generally carry more suspended
solids but may dilute some dissolved substances.
Streamflow volume and dilution may vary following
heavy  rainfall or snow melt.    Some  types of
sediments may adsorb substances to a greater extent
than others. For example, fine clay particles may
adsorb metals to a greater extent than larger particles.

When  investigating  actual  contamination  or  an
observed release, the investigator should be aware of
potential sampling errors  and false  assumptions
affecting data representativeness. Such considerations
are especially important when establishing  actual
contamination and determining level of contamination
in the human food chain.

If necessary, an observed release can be established
based on the chemical analysis of tissue samples from
sessile benthic organisms. Samples of similar tissue
should  be obtained to document  background.
Comparing  dissimilar  tissues-for example, liver
tissue and muscle tissue-may yield false positive of
false negative results (i.e., significant differences
between background and release samples attributable
to tissue types rather than a release).  Edible tissue
samples are more appropriate for evaluating human
health threats via the food chain. Where edible tissue
samples are not available, the following is a hierarchy
of preference for other sample types:

  •   Edible  tissue  samples with associated tissues
     attached or only partially removed
  •   Whole-body samples
  •   Samples of other specific tissues or organs

Samples should be obtained from the same species
and from organisms of similar ages. As with other
surface water  samples, the  investigator should
descriptively document sample locations and note
possible sources of influence on the analytical data.

4.6.1 Focused SI Strategy

Surface water  should be sampled if a release to
surface water was  suspected  during the PA  and
surface water targets are present (e.g., drinking water
intakes,  fisheries, wetlands  and other  sensitive
environments), Before identifying sample locations
for the surface water pathway, the investigator must
review the drainage pattern in the vicinity of the site.
Water bodies that receive leachate or runoff from
sources at the site should be sampled.

During the focused SI the investigator should select
sample locations near or immediately downstream of
the site PPE to the nearest surface water body.
Sampling effluent discharge into surface water at the
PPE could document direct observation of hazardous
substances contaminating surface water. In this case,
background comparisons are not required.

The investigator should review surface water targets
evaluated as primary targets during the PA. To
investigate threats to public herlth,  all drinking water
intakes suspected to be contaminated should be
sampled regardless of scoring  impacts.   For the
drinking water threat, aqueous or  sediment samples
should be collected at or downstream of the intake
suspected to be exposed to contamination. (However,
only aqueous samples can establish Level I drinking
water contamination). And if multiple targets are
present downstream of the PPE,  the protection of
public health may indicate collecting at least one
sediment sample at or beyond each target likely to be
contaminated.

Samples to establish background must be the same
type as the samples collected to test  surface water
release  hypotheses  or  targets  exposed to
contamination. Background sample locations for the
surface water pathway include

  •   Sediments from the surface water body upstream
     from the PPE and outside the area of hazardous
     substance influence from the  site
                                                  69

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Sampling Strategies
                    Site Inspection Guidance
 •  Aqueous samples upstream from the PPE (only
    if  drinking  water  intakes  or  sensitive
    environments are immediately downstream from
    the PPE)

4.6.2  Expanded and Single  SI  Strategy

Investigators should determine if analytical data from
nearby surface waters are available. A minimum of
two samples is needed to demonstrate a release:

 •  One upstream of the PPE to  reflect background
    levels. It  should be located within the same
    hydrologic setting as the downstream sample
    and, if possible, should not be influenced by
    other sources of potential contamination.

 •  One downstream reasonably close to the PPE.

If  aqueaus samples are planned, they should be
collected prior to collecting sediment samples at the
same location. In most cases, sediment samples are
preferred to document a release to surface water
because they are generally more  likely to have
concentrations significantly above background and
they can support the evaluation of targets exposed to
actual contamination. During the expanded SI the
investigator should consider collecting additional
surface water samples for target locations not sampled
during previous investigations.     Expanding the
boundaries of fishery contamination by  collecting
additional samples may be important if the human
food chain threat has a major influence on the site
score and if the waste characteristics factor category
value  is  relatively low. Conversely, if the waste
characteristic factor is relatively high, the boundaries
of demonstrated contamination may not  require
expansion. Sampling to further document the extent
of wetland contamination may also be warranted at
some sites.  Table 4-11 compares the focused and
expanded SI strategies for surface water sampling.

4.6.3 Example of Sampling  Strategy

    Returning to the Lakefield  Farm  site
     example, the site description now includes
    the Apsley River, a  moderate to large
    water body  (streamflow   900  cubic
     feet/second), approximately 200 feet north
     of the surface impoundment (Figure 4-3).
     A recreational fishery is located within the
     river, and a 10-acre wetland lies 1 mile
     downstream from the PPE. An unnamed
     creek flows into Apsley about 750 feet
     upstream of the PPE, and an outfall to this
     creek   is  1  mile  upstream  of  this
     confluence.      During   the  PA,  the
     investigator  suspected a release  to the
     Apsley River from Lake tie Id Farm, and a
     release to ground water.

     Because  of significant  threats to  both
     ground  water and  surface  water and
     because attribution is a problem, a focused
     SI is planned with an expanded SI to be
     performed if necessary.    Focused  SI
     sampling will test whether ground water
     and surface water targets are exposed to
     contamination.

If the  number of samples to test all  hypotheses
exceeds the  focused  SI budget, a subset of these
samples may be collected for the most important
hypotheses to screen the site (Table  4-12).  The
previous ground water example specified 18 sample
locations to meet focused SI objectives.  To test
surface water hypotheses, 5  additional sediment
samples should be collected. A single sample from
the municipal well (GW-7) or 3 samples from the
river (SED-1, SED-4,  and SED-5)  may indicate
whether further Superfund investigation is warranted.

Sediment samples may be collected from downstream
wetland locations in addition to the 3 surface water
samples identified above; however, these are not
essential to test the suspected release to surface water.
The SI investigator  may perform other optional
samples (e.g., a second background surface water
sediment sample), and QA/QC  samples (Q-l through
Q-4) consisting of 2 equipment rinsates,  1 trip blank,
and 1 field blank.

Assume that focused SI ground water sample data do
not  detect  hazardous substances  at  elevated
concentrations.   Fishery and  wetland  samples are
contaminated with several heavy metals, and source
samples from the surface impoundment at the site
also contain some metals. Analytical results from the
background samples were given "J" qualifiers and
determined to be biased low. The investigator cannot
conclusively determine whether the heavy metals
found in the Apsley River are attributable to Lakefield
                                                 70

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Site Inspection Guidance
                         Sampling  Strategies
                    TABLE 4-11: SURFACE WATER SAMPLING STRATEGIES
CRITERION
Primary
objectives
Data quality
Average
number of
samples
Types of
activities
Background
samples
Attribution
samples
QA/QC
samples
FOCUSED SI
To test hypotheses regarding a suspected
release and primary targets
When possible, sample at or beyond targets
to test release hypotheses
Less rigorous (e.g, DUG -II) to rigorous
(e.g., DUC-I)
O to 6 depending on site hypotheses and
number of surface water targets to sample
Sample easily accessible surface water
locations
Sample sediments at or beyond targets most
likely to indicate contamination
1 background per 3 release samples
May rely on published data
Limited to testing release hypotheses
Enhance confidence in sample results
EXPANDED SI AND SINGLE SI
To document a release based on HRS
requirements
To document targets exposed to actual
contamination and determine levels of
exposure
Rigorous (e.g., DUC-I)
O to 14 based on HRS documentation
requirements
Resample surface water locations if
previous data did not document a release
or targets exposed to actual contamination
Sample surface water targets not yet
sampled, particularly sensitive
environments and wetlands
Collect multiple aqueous samples from
drinking water intakes where hazardous
substance concentrations are likely to be
near surface water benchmarks
2 background per 3 release samples
Should not rely on published data
Those necessary to attribute a portion of a
release to the site
Those necessary to obtain precise and
accurate data within the SI scope
Farm, or whether they had entered the river through
the outfall to the unnamed creek upstream of the site.
A goal of expanded SI sampling will be to document
that any  significant  increase in heavy metals
concentrations found in the river are at least partially
attributable to the site.

During the expanded SI outfall discharge samples
should be collected to determine if heavy metals are
being released to the creek (OUT-1). Samples (SW-1
and SED-1) upstream of this discharge point should
also be taken to determine if other sources (or sites)
are releasing heavy metals to  surface water.  To
further demonstrate actual wetland contamination,
both aqueous  and sediment samples  should  be
collected further downstream along the wetland at
locations likely to be exposed to a release from the
site. The aqueous samples may demonstrate Level I
                                                71

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 Sampling Strategies
                Site Inspection Guidance
                         FIGURE 4-3: LAKEFIELD FARM SITE SKETCH #3
SED-l
                                                                   LAKEFIELD
                                                                   FARM SITE
                                                  SS-1
                                                      I   GW-5
                                                    GW-4
                                                             GREEN ACRES
                                                             SUBDIVISION
                                                                                        iSED-7
          KEY
      Q  Surface water sediment sample
      Q  Surface water aqueous sample
      %  Source sample
          Drinking water well
          Irrigation well
          Fishery
Municipal Well
micipal'


 GW-7
                              t
                          — N —
                         NOT TO SCALE
                 NOTE: Surface water aqueous and sediment sampling should begin downstream
                 and progress upstream. In this example, sample SED-7 should be collected first,
                 followed by SED-6 and soon upstream in reverse numerical order.
                                                72

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Site Inspection Guidance
Sampling Strategies
  TABLE 4-12: SURFACE AND GROUND WATER SAMPLING STRATEGY FOR EXAMPLE SITE
                                FOCUSED SI
SAMPLES
Municipal well
(GW-7)
Domestic wells
(GW-3 through
GW-6)
Background for
ground water
(GW-1, GW-2)
Surface water
target locations
Background for
surface water
(SW-1, SED-1)
Sources
(SD-1, SL-1,
SS-1, SS-2)
Quality control
(Q-l through
Q-4)
(Not shown)
APPROACH
Sample drinking water prior to
treatment; sample to document
contamination, identify
hazardous substances, and
determine level of
contamination
Sample nearest domestic wells
suspected to be exposed to
actual contamination
Sample drinking water aquifer;
limit number of background
samples
Sample sediments to determine
if contamination is present in
the fishery (SED-4) or wetland
(SED-5, SED-6)
Limit number of background
samples
Identify hazardous substances
present at the site through
composite samples
Monitor collection and
decontamination procedures; 1
rinsate for ground water
equipment, 1 rinsate for
surface water equipment, 1 trip
and 1 field blank
RATIONALE
Determining municipal
well contamination is
critical to protecting
public health and to the
site screening decision
Determining domestic
well contamination is
critical to protecting
public health and to the
site screening decision
Sample to determine
relative concentrations of
hazardous substances in
ambient conditions
Human food chain or
sensitive environment
contamination is vital to
the screening decision
Sample to determine
levels of hazardous
substances
Do not sample to
increase hazardous waste
quantity if amounts are
not close to HWQ factor
value breakpoints

NONSAMPLING
DATA COLLECTION
Verify aquifer from
which well draws;
verify population served
Verify aquifer from
which wells draw;
verify population served
Verify aquifer from
which wells draw
Verify linear footage of
wetland exposed to
actual contamination
Collect information
about background
sample location,
including setting, flow,
and physical
characteristics (e.g.,
sediment grain size)
Obtain physical
dimensions of surface
impoundment and
estimate area of
contaminated soil;
verify number of drums
and look for drum
labels

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                                                       Site inspection Guidance
contamination for the wetland, the sediment samples
may demonstrate Level II. (The wetland sample
locations should be at least 0.1 mile apart, the
minimum frontage length needed to receive a non-
zero factor value.)

Other background samples should be collected from
the Apsley River upstream of the confluence with the
unnamed creek. Samples from within the fishery
should be taken  to compare to background and
attribution samples. Also, QA/QC samples should be
collected following EPA Regional guidance. For this
expanded SI example, 2 equipment rinsates, 1 trip
blank, 1 duplicate, and 1 blank could monitor sample
collection and handling procedures (Table 4-13).
                                  4.7 SOIL EXPOSURE PATHWAY

                                  The primary objective of soil exposure sampling is to
                                  identify whether residential or school properties are
                                  contaminated. Sample locations for the soil exposure
                                  pathway should:

                                    •   Document any observed contamination within
                                       property boundaries of a residence, school, day
                                       care center,  or workplace,  or  within the
                                       boundaries of a terrestrial sensitive environment
                                       or resource;
                                    •   Document observed contamination significantly
                                       above background levels and attributable to the
                                       site;
           TABLE 4-13: SURFACE WATER SAMPLING STRATEGY FOR EXAMPLE SITE
                                  EXPANDED  SI AND  SINGLE  SI
    SAMPLES
       APPROACH
      RATIONALE
NON SAMPLING DATA
  Surface water
  locations
Sample sediments and surface
waters to confirm
contamination of surface
water targets, levels of actual
wetland contamination, linear
frontage  of wetlands exposed
to actual  contamination, and
attribution  to  the  site
Target samples  should  be
comparable to background
samples collected

If necessary, wetland
sample locations should be
selected to demonstrate
that at least 3 miles of
linear frontage are exposed
to actual contamination
Measure linear frontage of
wetland exposed to actual
contamination
  Background and
  attribution
  (SW-1, SED-1,
  SW-2, SED-2,
  OUT-1)
Sample to determine if outfall
or  another  source upstream
may  be  contributing  to
surface water contamination
Sample  to determine
relative levels of hazardous
substances in ambient
environment

Show contamination
attributable to site

Ensure sufficient
background samples for
listing  documentation
Research other potential
sources (e.g.,  industrial
areas)
                                                                          Collect information about
                                                                          background sample
                                                                          location
  Quality control
  (QA-1 through
  QA-5)
Monitor sample collection,
decontamination, transport,
and handling procedures; 2
equipment rinsates, 1 trip
blank, 1 duplicate, and 1 field
blank
Ensure sufficient QA/QC
samples to validate
sampling and analytical
procedures
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  •   Delineate areas of surficial contamination at the
     site; and
  •   Identify the level of contamination within these
     areas.

Samples, including  composite samples, must be
collected within 2 feet  of the  surface. No
impenetrable material (e.g., asphalt, concrete) should
be present above the sample location. Most surface
samples during the SI will be soil material, although
some may be leachate, source material, sediment from
overland runoff drainage ditches, and other surficial
materials.    Certain conditions  are imposed on
establishing observed contamination at a sample
location. Similar to an observed release, analytical
evidence should demonstrate whether the hazardous
substance is attributable to  the site and present at a
concentration significantly above background levels.
If no surficial contamination significantly above
background levels and  attributable to  the site is
detected, the  soil exposure pathway  cannot be
evaluated.

Areas of observed contamination are delineated based
on  analytical  evidence  meeting the criteria for
observed contamination. Observed contamination in
the soil exposure pathway cannot be established by
direct observation. Samples that contain hazardous
substance   concentrations    significantly   above
background and are attributable to the site are used to
document points of  observed contamination. The
most important analytical data for the soil exposure
pathway are   samples   that  establish  observed
contamination  and level of contamination.

Documenting  resident population targets requires
detecting contamination (most commonly in soil)
within the property  boundary, within 2 feet of the
surface on  the property and within 200 feet of
residences, schools, day care centers, or workplaces.
The  SI investigator should identify and sample routes
through which  hazardous substances  may be
transported by air or water.     Physical site
characteristics and background information, especially
aerial photography, may help identify potential former
disposal areas  that are close to, or part of, residential
properties.

The investigator should sample surface materials
based strictly on identifying resident population threat
targets. A minimum  of three samples is necessary to
estimate the area of observed contamination. Two
samples may be sufficient to define a linear strip of
contaminated soil, where targets within the strip are
critical to the site score and area is not important. If
a large number of residences (e.g., mobile home park,
residential development on a landfill) are likely to lie
within an  area of contamination,  estimating the
boundaries of contamination, particularly during the
focused SI may be more practical. The expanded SI
would include samples to  distinguish  levels  of
contamination within this  area.

For sources other than contaminated soil (e.g., a
surface  impoundment),  a single source  sample
demonstrating observed contamination may be used to
identify the entire source as an area of observed
contamination. Any sample establishing hazardous
substance   concentrations    significantly   above
background levels indicates the source area is an area
where observed contamination is greater than O.
Thus, one point of known  contamination may provide
sufficient information for scoring. For  contaminated
soil, locations of samples that  demonstrate observed
contamination and the area between those locations
comprise the area of observed contamination, unless
information indicates otherwise.

To evaluate  the level of contamination for each
residential, day care, or school property, each area of
observed contamination  should  be delineated
according  to  concentration levels relative to
benchmarks.      For  HRS   scoring purposes,
contamination can be inferred between 2 points of
observed contamination  based on site conditions;
however, the population associated with the areas of
inferred contamination are evaluated as Level II
resident threat targets.   The investigator should
identify areas where observed  contamination can and
cannot be inferred.  For  decision-making purposes, the
investigator may use analytical evidence with non-
sampling evidence to infer or corroborate the area of
observed contamination-for example, observation of
stained soil coupled with  analytical results from the
stain. Other corroborative information may be:

  •   Data derived from other investigations, such as
     geophysical or soil-gas surveys;
  •   Documented historical waste deposition patterns
  •   Patterns of stressed vegetation;
  •   Infrared  satellite  imagery  indicating soil
     anomalies; and
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Sampling Strategies
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  • Topography and drainage patterns.

If samples not meeting the criteria for observed
contamination are collected from within an area of
inferred contamination, the  investigator should
evaluate whether the area of contamination needs to
be refined or modified. For example, if liquid wastes
containing hazardous substances were spilled at  the
site, areas of higher elevation than the spill generally
should  be excluded from  the  area of  inferred
contamination, even if they are within the originally
inferred area. However, the  scope of the SI generally
does not warrant fully delineating areas that are  not
subject to observed contamination; instead,  the
primary objective is to identify targets that may be
threatened by the site.

Special precautions should be taken to ensure  the
sample represents the surface at that location, and that
the sample is not altered or contaminated by  sampling
and handling procedures. Soil samples collected  for
comparison should be the same soil type and from  the
same  soil horizon. Considerable variability may
occur between soil types as well as within a single
soil type because of  grain size, mineralogy,
composition, soil horizons, and lateral heterogeneity.
Soil type should be identified and delineated. For
metals   analysis, background,  and  observed
contamination, soils should have  similar texture,
color, and grain size.

For general HRS purposes,  grab  samples are better
than composite samples for  the soil pathway. Where
composite samples are needed, the SI investigator
should avoid mixing soils from different properties.
Also, all portions of the composite sample should be
taken within 200 feet of the school or residence on
the property.

Background samples generally should represent  the
uncontaminated area around the site. Background
samples should be collected from undisturbed areas if
the site is located near areas filled in with soils from
different sources. However, if the site is located in
fill material, the background sample should come
from  the fall. Soil within drainage channels (e.g.,
overland migration segments) may be subject to
influences unrelated to the site and generally should
not be used as  background.   Background and
observed contamination samples should be collected
within a reasonable time (1  to 3 days).
   Data resulting from field screening methods
   may be useful to investigate source boundaries
   and areas of contamination. For example, if
   soil samples need to be collected from adjacent
   residences or schools  to investigate resident
   population targets, field screening can help plan
   the locations of samples to be  collected for
   CLP analysis. Field screening samples may
   support evaluation of observed contamination
   and  reduce the  number of CLP samples
   necessary to  document the pathway score.
Establishing  background conditions  for the soil
exposure pathway can be difficult, particularly when
the hazardous substances found  at  the site are
naturally occurring.   Onsite samples to establish
background  should  be collected from  off-source
surficial soils  that are not likely to be impacted by the
source. Similarly, the SI investigator should collect
offsite samples to establish background conditions
from shallow soils that are not impacted by  other
sources in the vicinity.

Results from  other nearby site investigations can be
used during the focused SI to  establish background.
Literature values, especially for naturally occurring
substances such as metals in mining areas, may be
used as background measures during the focused SI

4.7.1 Focused SI Strategy vs. Expanded
        and  Single SI Strategy

To plan  target sample locations, the investigator
should review PA conclusions  of resident population
targets suspected  of exposure to contamination.
Samples  collected from a  terrestrial sensitive
environment must be within the delineated boundaries
of the specific sensitive environment. To investigate
the threat to workers at the site or at adjacent
properties, samples must be collected on the facility
property within 200 feet of the workplace.

For the expanded SI the investigator only should use
data of rigorous quality to support target exposure.
Less rigorous  data and non-sampling information may
corroborate  attribution and representativeness  of
samples.
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One or more background samples to compare to
observed contamination areas are necessary to
document contamination.  Background samples should
not be  influenced by other potential sources of
contamination. Generally, samples taken at a higher
elevation than site sources can be used as background,
unless the hazardous substances can be transported by
wind. For all  background  sample locations, care
should be taken to ensure  that they are not affected by
substances blown from the site.

Careful selection of background sample locations is
important since any measurable concentrations of
specific  substances found at  residences, schools, day
care centers, workplaces, and terrestrial sensitive
environments will be compared to background data.
If several of these properties are present, observed
contamination may be inferred between two points of
observed contamination based on terrain, drainage,
surficial runoff, elevation, and other site  conditions
unless  available information indicates  otherwise.
However,  populations  associated with  inferred
contaminated properties  cannot be scored as Level I
resident threat targets. Sampling each property is not
necessary, although documentation will be stronger if
each property  is sampled. Table 4-14  compares
focused and expanded  SI  strategies for the soil
exposure pathway.
                           TABLE 4-14: SOIL SAMPLING STRATEGIES
CRITERIA
Primary
objectives
Data quality
Average
number of
samples
Types of
activities
Background
samples
Attribution
samples
QA/QC
samples
FOCUSED SI
To test hypotheses regarding suspected
observed surficial contamination and
targets exposed to actual contamination
Less rigorous (DUG -II) to rigorous
(DUG -I); depends on objectives
O to 10 depending on site hypotheses and
resident population to investigate
Sample source and target areas indicating
possible surficial contamination, exposed
or within 2 feet of surface
Limited
May not be necessary for some organics
May rely on published data
Limited
As approved by Regional guidelines
EXPANDED SI AND SINGLE SI
To document target exposure to hazardous
substances related to site sources
Rigorous (DUG -I); depends on objectives
O to 20 based on documentation requirements
and number of sources and targets
Resample locations if previous data did not
demonstrate areas of observed contamination or
targets exposed to actual contamination
Sample other resident target properties not yet
sampled
Collect multiple samples from properties where
hazardous substance concentrations are likely to
be near benchmarks
As many as necessary; research natural soil
concentrations as well as development history in
the area to select critical background sample
locations; use aerial photographs.
Those necessary to attribute substances to the
site being evaluated
Minimum 1 split and 1 blank or per Regional
guidelines
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4.7.2 Example  of Sampling  Strategy

     The Carveth Landing Site is a dump near
     a residential neighborhood and elementary
     school (Figure 4-4). The PA reported that
     dumping occurred for an unknown period
     of  time and  allegedly included paints,
     organic and  inorganic substances,  and
     construction debris. The area is devoid of
     vegetation. Sources at the site  include
     several piles of 5-gallon containers  and two
     poorly defined  areas of stained soil.
     Pigeon River, which flows at  1600 cubic
     feet per second (cfs) and is located 400
     feet east of the site, has flooded the site
     twice in the past 7 years. Commercial and
     recreational oyster beds are downstream of
     two PPEs to  surface water.    The PA
     concluded that flooding may have carried
     hazardous substances into surface water
     and onto adjacent school and residential
     properties.     Hazardous    substances
     associated with the site are not known, but
     could involve metals typically found  in
     paints.

A two-stage SI was planned for Carveth Landing
because testing critical PA hypotheses could screen
the  site  or  identify  significant  threats.  Sample
planning involved the following considerations: 1)
surface water and soil exposure are both pathways of
concern; 2) hazardous substances present at  the site
are poorly-defined, some of which may be naturally
occurring;  and 3) source  information  is poor.
Focused SI samples were  collected to test  the
suspected release  to Pigeon River,  identify  the
hazardous substances present, and determine whether
any suspected resident population threat target is
exposed to actual contamination.

During  the  focused SI  soil source samples were
collected to  identify hazardous  substances two
samples from each  stained soil area  and two samples
near the container piles (SS-1 through SS-6). These
samples also helped characterize areas of surficial
contamination and attribute possible contamination of
residential properties to site sources. Samples were
collected from properties  most likely to  exhibit
surficial contamination. A significant objective was
to demonstrate contamination on the school property.
During the focused SI samples (SS-1 and SS-2) were
collected from the school and from the three nearest
residential properties, all within  200  feet of the
residences and school building. Two background soil
samples (SS-7 and SS-8) were collected 12 inches
below the  surface in offsite soils.

Establishing  a  release by direct observation was
considered for the surface water pathway; however,
the available site information could not conclusively
demonstrate  that material containing hazardous
substances was present at the site during flooding.
Therefore, focused SI sampling included two sediment
samples (SED-3 and SED-4) from locations where
overland runoff from site sources entered surface
water (i.e., PPEs) to test a suspected release to Pigeon
River and actual human food chain contamination.
Background surface water sediment samples (SED-1
and SED-2) were collected near the  right and left
banks of Pigeon River, 200 and 800 feet upstream of
the most upstream PPE into Pigeon River. QA/QC
samples consist of two  equipment rinsates (1 for
sediment and 1 for soil) and a field blank (Table 4-
15).

Although  lead  concentrations in  this  focused SI
example  are   above   soil  exposure  pathway
benchmarks, the concentrations are not significantly
above background soil levels. For this example, the
background samples were inadvertently taken within
an area of soil contaminated by automobile emissions,
floods, wind-blown wastes, or naturally high lead
concentrations.

The expanded SI includes 2 additional source samples
(XS-1 and XS-2) and more soil samples to document
observed contamination at the site, on  the properties
sampled  during the focused SI and on other
residential properties potentially affected by the site
(Table 4-16). Background soil lead concentrations
should  be researched  by  literature values and
additional background samples (XS-3  through XS-6
and XS- 10) collected at locations less influenced by
potential sources of lead contamination. Soil samples
from residential properties southeast of the site should
also be taken since they are closer to the river. In
addition, samples from targets previously sampled
during the focused SI should be taken  if background
samples collected during the focused SI are not
similar to the additional target samples.
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  Site Inspection Guidance
                                          Sampling  Strategies
                          FIGURE 4-4:  CARVETH LANDING  SITE SKETCH
         A XS-3
                           XS"4
                                              XS-5
                               A SS-7
                                                                                   XS-10
                 A XS-11
                       . SS-10

                        A SS-9
            SCHOOL
    Key
 •  Source sample
 A  Soil sample
 Cl  Sediment sample
•^  Fishery
 A  XS = Expanded SI soil sample
                                        XS-
                                            XS
t
                              — N —
                              NOT TO SCALE
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    TABLE 4-15: SOIL AND SURFACE WATER SAMPLING STRATEGY FOR EXAMPLE SITE
                                FOCUSED SI
SAMPLES
Surface water
locations
(SED-3,
SED-4)
Residential soil
samples
Background
soil
(SS-7, SS-8)
Background
surface water
(SED-1,
SED-2)
Sources
(SS-1 through
SS-6)
Quality control
(Q-l through
Q-3)
APPROACH
Sample sediments to
demonstrate a release;
determine if contamination is
present and level of
contamination
Sample to determine if
nearby residential properties
(SS-11, SS-12, SS-13)and
the school yard (SS-9, SS-10)
are exposed to surficial
contamination
Limited
Collect sediment samples
upstream of PPEs
Ensure samples are beyond
tidal influence of hazardous
substance migration
Identify hazardous substances
present at the site; sample to
test hypothesis of surficial
contamination
Monitor sample collection
and decontamination
procedures; 2 rinsates and 1
trip blank
RATIONALE
Investigate release to
surface water and
determine if fishery is
exposed to actual
contamination
Investigate population
exposure to hazardous
substances
Sample to determine
relative levels of
hazardous substances
under ambient conditions
and to better define
effects of flooding at site
Sample to determine
relative levels of
hazardous substances
under ambient conditions
Do not sample to
increase hazardous waste
quantity because amounts
are not close to HWQ
factor value breakpoints

NON SAMPLING DATA
Document use of river for
fishing; estimate annual
commercial food chain
production for oysters
Determine number of people
per residence and number of
students attending school
If available, obtain historical
aerial photographs and
FEMA maps
Research natural
background levels of metals
Research other potential
sources of hazardous
substances
Estimate physical
dimensions of stained soil;
count paint pails and look
for drum labels

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                          Sampling Strategies
                  TABLE 4-16: SOIL SAMPLING STRATEGY FOR EXAMPLE SITE
                                           EXPANDED  SI
SAMPLES
Resident samples
(X3-7, XS-8, XS-
9, XS-11 through
XS-17)
10 samples
Background
(XS-3 through
XS-6,XS-10)
Quality Control
(Q-l through
Q-6)
APPROACH
Sample to document
resident targets and levels
of actual contamination
Sample areas less
influenced by site;
document contamination
attributable to site
Monitor sample collection
and decontamination
procedures; transport and
handling procedures; 2
equipment rinsates, 2
duplicates, 1 field blank,
1 replicate
RATIONALE
To establish observed
contamination on residential
and school properties, target
samples must be 3 or more
times the ambient
background levels
Show that target
contamination is attributable
to the site, rather than other
potential sources of lead;
ensure sufficient
background samples for
HRS documentation
Ensure sufficient QA/QC
samples for I-IRS
documentation
NON-SAMPLING DATA
Determine number of
residents, property
boundaries, and number of
students


Expanded SI QA/QC samples for this example (Q-l
through  Q-6) include  2  equipment rinsates, 2
duplicates, 1 field blank and a replicate sample at the
site owner's request.

4.8 AIR PATHWAY

Generally, air sampling is an expanded SI activity. If
suspected air pathway  contamination hypothesized
during the PA or focused SI is solely responsible for
further investigation (i.e., all other pathways have
minimal  effect on scoring), air  samples should be
collected during a single or an expanded SI Formal
air sampling to document a release is limited to the
single or expanded SI unless there is concern about an
immediate threat to human health.

The SI air sampling strategy requires understanding
the types of hazardous substances associated with the
site. The most dispersible substances should be
identified. Air sampling should be conducted either
before or after all other-sampling activities (i.e., not
during field activities that may release substances to
the air). Air sampling may require returning to the
site, for  example, on  a dry warm  day when the
potential for volatilization is high. Air sampling
should be avoided if the site or nearby facilities are
discharging substances to the atmosphere.

Hazardous substances can  be released into  the
atmosphere by wind,  file, explosion, evaporation,
sublimation, and industrial processes. Defining the
likely path and dispersion of a release to air requires
information on release characteristics and atmospheric
conditions. Emissions of contaminated fugitive dusts
(e.g., contaminated soil particles) originating from a
source can result from a combination of factors at the
site, such as wind erosion, heavy  equipment or
vehicular traffic, and incineration. The likelihood of
a release to air also depends on the type of source
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                     Site Inspection Guidance
containing hazardous substances, the  chemical
properties of these substances, and the thickness of
cover at the source.

An observed release to  air may  be  documented
through  direct observation.     An example is
observation of particulate matter  entering  the
atmosphere directly and information indicating the
material contains one or more hazardous substances.
In this case, a photograph referenced in the field
logbook  may be  adequate  to  document  direct
observation (e.g., a dust cloud from a tailings pile).
A sample of particulate material from the  pile
detecting  hazardous  substances  strengthens  the
documentation of the release by direct observation.

Unlike other pathways, direct sampling of air targets
suspected to  be exposed to contamination  is not
required, an air observed release allows any person
regularly present or any sensitive environment within
the distance category, or a closer one, to be evaluated
as subject to  actual contamination.   Investigators
should note the distance from sources at the site to air
sample locations.    Monitoring stations should be
placed near source areas to maximize the use of data
in HRS air target evaluations. A release into the air
of an enclosed structure is not considered an observed
release.

Samples should be representative of the location and
not be altered by sampling and handling procedures.
Background air samples and samples establishing an
observed release should  be collected  in  a  similar
setting and at the same time. Background samples
should be outside the influence of sources to ensure
that hazardous substances  detected in release samples
are attributable to the site.

4.8.1 Focused SI Strategy—Air Pathway

Air  sampling for  CLP  analysis  should not be
conducted during  the focused SI However, an
ambient air "screening'program may be warranted
for health and safety monitoring and to initially
assess a release.    This  program  should examine
specific hazardous substances with a high propensity
for a release (e.g., VOCs). However, data collected
during the screening program typically do not fulfill
HRS  documentation requirements.
For the focused SI the investigator should review the
results from the PA and other investigations. For
sites with several pathways of  concern, field
instruments such as an OVA or HNu should be used
to refine the evaluation of a suspected release to air.
Readings above  background in  a  zone near
undisturbed source areas, or particulate matter
observed migrating from source areas, could be used
to evaluate an observed release to  air during the
focused SI Further investigation during the expanded
SI would pursue documenting the release. If the air
pathway scored greater than 57 during the PA and is
the only pathway responsible for the further action
recommendation, the single SI option is appropriate.

For VOCs, the screening program could include an
initial survey using portable instruments designed to
provide a field-expedient  measure of total VOCs.
The initial survey locates and delineates potential
emission  sources for formal air sampling during the
expanded SI During the focused SI field screening
methods-for example, collecting air samples with a
field  gas  chromatography equipped with  a
photoionization detector-may be useful.

4.8,2 Expanded and Single SI  Strategy—Air
        Pathway

Air sampling may be appropriate during the expanded
SI if air is a pathway of concern or if public health  is
threatened in  the vicinity of the site. Investigators
should review the likelihood of atmospheric releases
(gases  and particulate) from  site  sources. Of all
HRS pathway media, air may be most dependent on
weather,  particularly wind speed  and direction,
temperature, and relative humidity. A minimum 12-
hour sampling time is recommended during hot and
dry weather to compensate for possible variations in
these factors over time.

The predominant wind direction should be determined
throughout the time period of sampling. Air should
generally  be  sampled  upwind  of  sources  for
background measures. Formal air sampling during a
single SI  should include a complete set of background
samples because of the level of effort involved in an
air sampling program.    This  differs  from  the
guidelines for other pathways. Air should be sampled
downwind of  sources to investigate a release. Up
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wind and cross-wind samples may also be acceptable
for background.  Multiple background and target
samples should always be considered. Background
and observed release samples should be taken at the
same time from approximately the same heights above
the ground. Samples collected at great heights (e.g.,
rooftops) are  not useful.  Samples from very low
heights are  also  not encouraged because  field
activities, particularly surface  disturbance, may
introduce artificial contamination, In general, dust or
wipe samples  are not recommended to establish a
release to air. Analytical results from these samples
are not usable to document a release to air for HRS
scoring package purposes.

Soil  samples  may  not qualify to document  an
observed air  release  by  chemical analysis  since
substances may have migrated via non-atmospheric
transport mechanisms, Soil-gas surveys, although
sometimes useful in determining the placement of air
monitoring stations, do not provide the quality of data
needed to document  an observed  release to air.
Although methane may support a release of other
hazardous substances from a source, methane cannot
be used as the observed release substance because it
is  not a designated  hazardous substance  under
CERCLA Section 101(14).  In addition, methane
alone (which can occur naturally) does not indicate
that  hazardous substances are present or migrating
from a site.

For sites where several pathways are of concern, field
instruments such as an OVA or HNu should be used
to  refine the evaluation of a release to air. Readings
above background near undisturbed source areas or
particulate matter observed migrating from source
areas should be documented during the expanded SI

4.8.3 Example of Air Sampling Strategy

     Vega Ore is a remote site near Smalltown
     where ore is processed for the extraction of
     lead, zinc, and silver (Figure 4-5). The
     site has  been operating since 1930, and
     current activities are very limited. Waste
     sources include three tailings piles, a drum
     storage  area for acids,  and an above-
     -ground tank.

     The nearest residence is 1000 feet from a
     tailings pile. Smalltown relies on drinking
     water from an intake 3 miles away. A
     National Park is located 900 feet from the
     site. A total of six ranches within  0.25
     mile of the site rely on both bottled water
     and cisterns for drinking water. Based on
     PA research, the significant threats posed
     by Vega Ore involve suspected migration
     of hazardous substances through  air that
     may   impact people   and  sensitive
     environments.  No ground water targets
     exist, and the nearest surface water body is
     more than two miles from the site.

Because only the  air pathway significantly affects the
example site score,  a single SI is planned for Vega
Ore to investigate a release to air and targets exposed
to actual air contamination within the 0.25-mile target
distance category.    Table  4-17  summarizes  a
suggested air sampling strategy for Vega Ore. Air
samples to demonstrate targets exposed to actual
contamination should be collected at locations outside
source boundaries. These locations should be within
the boundaries of the National Park and the other
areas within the 0.25-mile radius.

Soil samples from sources should be collected to help
attribute hazardous substances found in the release
samples to Vega Ore.  Five source samples (SS-1
through SS-5) should be taken, including 1 sample
from each tailings  pile, 1 from soils in the drum
storage area, and 1 from soils near the above-ground
tank. Air sampling should be designed  to collect
particulate since  the largest quantities of hazardous
substances associated with the site (i.e., lead, zinc,
silver) do not  typically  exist as gases  in  the
environment.   Sampling  should occur when the
prevailing easterly winds are steady and other weather
conditions are suitable. Wind speed and direction, air
temperature, and other atmospheric characteristics
should be continuously monitored and noted in the
logbook.

All air samples should be taken during the same time
period, and sample collection should run for at least
12  hours (air  samples  to establish Level  I
contamination for lead must be collected over a 24
hour period).  A high-flow pump may be used to
collect both background and release samples through
a filter cartridge.   Air sample stations should be
placed both upwind  (A-l through A-3) and downwind
(A-4  through A-8) of site  sources. Cross-wind
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                             FIGURE 4-5: VEGA ORE SITE SKETCH
                                     Prevailing wind direction
                                       during air sampling
                                                                               National Park
                                                                                         0.25 Mfle
                                                                                       Target Distance
                                                                                           Limit
            KEY
          • Source samples
          * Air samples
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              TABLE 4-17: AIR SAMPLING STRATEGY FOR EXAMPLE SITE
                                   SINGLE SI
SAMPLES
Release and
Air Targets
(A-4 through
A-6)






Support for
Release and
Air Targets
(A-7, A-8)



Background
(A-l through
A-3)





sources
(SS-1 through
SS-5)




Quality control
(Q-l through
Q-4)
(Not shown)
APPROACH
Sample to test if
contamination is present and
determine level of actual
contamination

Monitor wind speed,
direction, and other
atmospheric conditions


Sample to test if other
sources of air contamination
exist in the site vicinity, or
if wind direction changes
during the sampling event;
establish cress-wind sample
stations
Sample to collect
background levels of
ambient air concentrations

Sample to determine
background soil levels


Identify hazardous
substances present at the site
through surficial soil
samples and tailing samples



Monitor sample collection
and decontamination
procedure 2 trip blanks
and 2 duplicates
RATIONALE
Determining whether the
0.25-mile target distance
category is exposed to
actual air contamination is
vital to investigating the
public health and the
screening and listing
decisions


Support determining
whether the 0.25-mile target
distance category is
exposed to actual air
contamination


Sample to determine
relative levels of particulate
hazardous substances in
ambient conditions
Ensure sufficient
background samples for
listing purposes

Do not sample to increase
hazardous waste quantity
(amounts are not close to
HWQ factor value
breakpoints)


Ensure sufficient QA/QC
samples for listing purposes


NON SAMPLING DATA
Determine population of
Smalltown lying within the
0.25-mile target distance
category from site sources

Determine number of
workers at Vega Ore

Determine boundaries of
National Park







Identify other sources of
particulate emissions in
area

Collect descriptive
information for all
background sample
locations
Obtain physical
dimensions of tanks,
drums, and tailings piles,
and estimate area of
contaminated soil; verify
number of drums and look
for drum labels




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sample stations may be appropriate depending on
atmospheric, weather, and site characteristics, and the
potential for other sources of air contamination to
contribute to particulate concentrations.    QA/QC
samples (Q-l through Q-4) could include 2 trip blanks
(i.e., the sampling event will  take 2 days) and 2
duplicates. A field blank is not  normally required.

For specific procedures on air sampling, refer to the
National Institute for Occupational Safety and Health
(NIOSH) Manual of Analytical Methods, Volumes 1-
7, and EPA's A Compendium of Superfund Field
Methods.

4.9 SITES WITH RADIOACTIVE
     WASTES

This section provides guidance for performing Sis at
sites with wastes containing radioactive substances.
For  field investigations  of sites with radioactive
wastes, the SI investigator should refer to EPA's
Radiochemical Procedures Manual (1984) and the
Department of Energy's EML Procedures Manual
(1983). The SI investigator should also consult the
EPA Regional, laboratory, or Headquarters Radiation
Programs staff. In addition, the following references
provide useful information:

  •  National Council on Radiation Protection and
     Measurements,  1976. Environmental  Radiation
     Measurements, NCRP Report No. 50

  •  U.S. EPA,  1979, Radiochemical Analytical
     Procedures For Analysis  of Environmental
     Samples. EMSL-LV-0539-17

  •  Us.   Nuclear Regulatory   Commission,
     Radiological  Assessment:  A  Textbook on
     Environmental  Dose  Analysis.  NUREG/CR-
     3332. Till and Meyers (Eds.).

Sampling strategies for sites with wastes containing
radioactive substances are similar to those described
in previous sections for other hazardous substances,
but  with some important differences.    These
differences can be attributed, in part, to:

  •  Higher specificity and sensitivity of procedures
     used to detect radionuclides in the environment;
     and
  •   Special data requirements for scoring radiation
     sites under the HRS.

The SI investigator should  be aware  of special
precautions in sampling, handling, and disposing of
radioactive materials, and should work with an EPA
health physicist or radiochemist in planning the
sampling strategy.

4.9.1 General Sampling Principles

In general, sampling strategies for  sites with only
radioactive substances are less complex than strategies
for sites  with other  hazardous  substances. The
sensitivities, specificities, and instantaneous readout
capabilities  of many field instruments facilitate
investigating sources  and  releases  of  radioactive
substances. Field identification and monitoring of
specific radionuclides, source locations, release points
and distances to targets can be used to focus sampling
efforts and reduce the number of samples required for
scoring. In addition, real-time radiation measurements
allow modification to the  sample plan, alert site
personnel of unsafe radiation exposure levels, and
permit  the  monitoring of collection and
decontamination procedures.

Prior to  developing the SI  sample plan, the SI
investigator should review PA and previous sampling
data regarding sources and pathways with known or
suspected radioactive substances  to plan samples.
Also, early in the SI planning process, the investigator
should review section 7 of the HRS and be familiar
with the data requirements of radionuclide-specific
factors that require special sampling. For example,
calculations  of factor values for radionuclide
benchmarks and hazardous waste quantity require that
measurements be reported in activity units rather than
mass units.

The investigator should review available site data to
identify potential  radionuclides. Data sources can
include records of the site operating history, handling
and disposal manifests, radioactive materials licenses
issued by  the Nuclear Regulatory Commission (NRC)
or through State agreement, and previous sampling
and analysis. Interviews with  former employees  can
also provide useful information on  site operations.
The investigator should use these records to construct
an initial list that contains the following data for each
radionuclide:
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  •  Atomic number and atomic weight
  •  Radioactive half-life
  •  Principal decay modes and radiation energies
     and abundances
  •  Chemical and physical forms
  •  Decay products

Half-life  information  is  critical to determine
persistence factor values and the degree of activity
equilibrium between decay products. Half-life also
affects holding times for analyses.

The type (alpha, beta, gamma photons and x-rays),
abundance, and energies of the radiation emitted by a
radionuclide are unique. Sampling and analysis
procedures, radioanalytical methods, and  radiation-
detection instruments must be  consistent with the
decay mode and radiation energies and abundances of
the radionuclide.

Bioaccumulation potential  and metabolic behavior of
a radioisotope are governed by its chemical and
physical form, not by its radioactive properties. The
toxicity of a radioisotope depends on its radioactive
properties, Since radionuclides may be released to
the environment as solids, liquids, or gases  in a
variety of chemical forms, oxidation states, and
complexes, information on the most likely chemical
and physical form of each radionuclide at the time of
production, disposal, release, and  measurement is
important for developing initial sampling strategies.

Radioactive decay of an isotope  of one element may
result in the formation of an isotope of a different
element or a different isotope of the same element.
Resulting decay products have physical and chemical
properties different from  the parent radionuclide.
Often, a decay product is also  radioactive and decays
to form  another radioactive substance.    Decay
products should be considered on a substance- and
site-specific basis in the evaluation of factor values
for radionuclide toxicity, hazardous waste quantity,
and mobility and persistence because:

  •  Total activity content and potential hazard of a
     sample may be underestimated if decay products
     are not included;
  •  Decay products may be more toxic, either alone
     or in combination, than the parent radionuclide;
     and
 •   Environmental   transport,    fate,    and
     bioaccumulation characteristics    of decay
     products may be substantially different from
     those of the parent radionuclide.

In selecting detection instruments and procedures, the
SI investigator should consider  the following
conditions  for each radionuclide in each  media
sample:

 •   Type, abundance, and energy  of radiation
     emitted by radionuclides of concern
 •   Expected activity concentrations of radionuclides
     in sources and environmental media
 •   Background concentration
 •   Turnaround time for analyses
 •   Required analytical sensitivity
 •   Data requirements for specific HRS factors

The  SI investigator should schedule analyses with
laboratories that can provide radioanalytical services
through the CLP SAS or a CLP-equivalent program.
The investigator must specify radiochemical methods
and QC test requirements. These should be compared
with  the lists of procedures  for radionuclides,
matrices, detection  limits  and sample collection,
preservation, holding times, and shipping requirements
supplied by  each  candidate  laboratory.  The
investigator should review the radioactive materials
license and conditions of each sampling laboratory to
ensure that the laboratory can accept the samples for
analysis.

Focused SI Sampling Principles

Similar to other sites, the focused SI at radiation sites
uses analytical data to test PA hypotheses and to
recommend the site for further evaluations. However,
the focused Sis sampling strategy  to  investigate
radioactive substances relies more heavily on field
instruments and methods to

  •   Locate elevated sources of radioactivity and
     external radiation exposure rates;
  •   Determine    the  identities    and  activity
     concentrations of radionuclides in situ;
  •   Estimate areal extent of contamination;
  •   Identify major migration pathways;
  •   Confirm releases; and
  •   Confirm  offsite contamination.
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                       EXAMPLE OF A FOCUSED SI SAMPLING STRATEGY
                                       AT A RADIATION SITE
   From 1910 until 1952, the ACD Corporation
   produced luminescent aircraft cockpit dials using
   radium-based paint.    The area immediately
   surrounding the ACD factory  supports a
   residential population of about 18,000. Historical
   records indicate that the factory received
   substantial quantities of unprocessed radium ores
   during its years of operation. These ores were
   unloaded at a bay adjacent to railroad tracks.
   The abandoned factory grounds cover about
   20,000 square feet and the property is accessible
   to the public due to a broken security fence.

   A review of available records suggested that
   processed radium ores were discarded at the
   factory.    The  PA site visit confined the
   presence of several large piles of processed
   radium ore and smaller amounts of unprocessed
   radium ore discarded along the railroad tracks.
   A drinking water aquifer lies approximately 30
   feet below the site.

   The  SI investigator  conducted  a walk-over
   gamma radiation survey of the site and collected
   a limited number  of samples  to test the PA
   hypotheses that site sources and soils on adjacent
residential properties contained elevated levels of
radium. The investigator identified Ra-226 and
its decay products as the primary radionuclides
of concern and assumed that these radionuclides
were present in equal activity concentrations.
Background  samples were not collected, but
natural activity concentrations for radium in soil,
water, and air were noted from scientific reports
for the surrounding region.

Survey measurements identified at least  17
source  waste piles  with gamma  radiation
exposure rates significantly above background
levels. The soil on four residential properties
adjacent to the site also showed significant
exposure rate readings.    Four surface soil
samples were collected one from  an ore pile on
the factory grounds and the others  from the front
yards  of three of the homes. Every sample
contained highly elevated radium concentrations.
Results of the single ground water well sample
(900 feet from the site) were negative. Based on
these  documented levels  of  radioactive
contamination and confirmed exposure of targets,
the investigator recommended this site for an
expanded  SI
The number of focused SI sources and environmental
samples should be kept to a minimum. Sampling and
surveying efforts should focus on investigating target
exposure to contamination. The criteria and planning
considerations  in  Table 4-2 apply to sites  with
radioactive  wastes.

Expanded and Single SI Sampling Principles

Similar to sampling strategies for other hazardous
substances, expanded and single  SI strategies for
radiation sites collect data to

  •   Determine site-specific background radioactivity
     concentrations and exposure rate levels;
  •   Confirm the identities and activity concentrations
     of  all principal  radioactive  substances of
     concern, including decay products;
   •  Document releases to principle pathways;
   •  Document Level I and Level II contamination;
      and
   •  Support QA/QC requirements.

  Table 4-3 applies  to  expanded SI sampling for
  radionuclides.

  4.9.2  Source  Characterization

  Evaluations of the hazardous waste quantity factor
  values for radionuclides differ from the approaches
  used for other hazardous substances in three primary
  ways:

    •   Activity units, rather than mass units, are used
      to evaluate sources.
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Site Inspection Guidance
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 •   To evaluate radionuclide constituent quantity
     (Tier A), calculation of the estimated net activity
     content for the source is based on the activity
     concentration above the respective background
     concentration for each radionuclide attributable
     to the source.

 •   Only two tiers, Tier A (radionuclide constituent
     quantity) and Tier B (radionuclide wastestream
     quantity), are used for determining hazardous
     waste quantity factor values.

To determine a source hazardous waste quantity factor
value based on radionuclide constituent quantity data,
the source area and depth (or volume) and the net
activity concentration of each radionuclide in the
source or area of observed contamination must be
obtained.

Surface exposure rate surveys are often used to assess
areal extent of observed contamination for the soil
exposure pathway.     These exposure  rates  are
measured in microroentgens per hour at 1 meter
above ground level using hand-held survey meters.
Measurements are recorded at grid intersections,  and
must be accompanied by a set of x- and y- reference
coordinates. These measurements  should be sufficient
to locate  maximum gamma exposure  rates and
indicate zones of equal exposure around these points.

Down-hole gamma logging is performed to estimate
depth of contamination.  This survey uses gamma
sensitive probes lowered into  drilled holes to provide
measurements of the gamma exposure rate or gamma
count-rates at predetermined depth  intervals. An
expanded SI may require a number of down-hole
measurements.   Depths of each bore hole should
extend to the bottom of the contaminated layers plus
at least 1 foot. When  grade levels are approximately
equal, boreholes should terminate at the same depth.

4.9.3  QA/QC Samples

The types and numbers of QA/QC samples required
for focused and expanded Sis at radiation sites are
essentially identical to those recommended in Section
4.3 and Table 4-6 for other  hazardous substances,
with two exceptions. Trip blanks and matrix spike
analyses  may not be  required for  radionuclide
sampling because of  the remote  possibility of cross-
contamination.
4.9.4 Sample to Demonstrate a  Release

The criteria  to  establish  a release by direct
observation are pathway-specific and are discussed in
each pathway section. The criteria and significance
levels to establish an observed release through the
analysis of samples   for radionuclides differ
considerably from the  criteria used for other
hazardous  substances  (see HRS   Section 7).
Radionuclide criteria are divided into three groups:

  •   Radionuclides that occur naturally or ubiquitous
     manmade radionuclides in the environment
  •   Manmade radionuclides that are  not ubiquitous
     in the environment
  •   External gamma radiation  (soil exposure
     pathway only)

To  establish an observed release based on sample
analysis for the ground water, surface  water, and air
pathways for  naturally  occurring or ubiquitous
manmade radionuclides, the measured concentration
(in  units of activity concentration, such as pCi/g,
pCi/L, pCi/m3) of a given radionuclide in the sample
must be at a level that

  •   Equals or exceeds  a value of two standard
     deviations above  the mean  site-specific
     background concentration for that radionuclide
     in that type of sample; or

  •   Exceeds the upper-limit value of the range of
     regional background concentration values for
     that specific radionuclide in that type of sample.

In both cases, some portion of the increase must be
attributable to the site  to establish  an observed
release.

To  establish areas of observed contamination for the
soil exposure pathway, the measured concentration of
naturally   occurring  or   ubiquitous  manmade
radionuclides in soil samples (in activity units) must
meet the above criteria, and the radionuclide must be
present at the surface or covered by 2 feet or less of
cover material.

To establish an  observed  release  for manmade
radionuclides   without    ubiquitous background
concentrations in the environment,  the following
criteria must be met:
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  •   The measured activity concentration of a given
     radionuclide in the sample must equal or exceed
     the SQL for that radionuclide in that specific
     medium.

  •   The increase in the sample activity concentration
     for that radionuclide in a specific medium must
     be attributable to the site.

Under special circumstances, the following  sets of
criteria may apply. If the radionuclide concentration
equals or exceeds the SQL, but its release can be
attributed to one or  more sites, the measured
concentration  of that radionuclide in the  sample must
also:

  •   Equal or exceed a  value of two standard
     deviations above the mean concentration of that
     radionuclide contributed by those  neighboring
     sites; or

  •   Equal three times its background concentration,
     whichever is lower.

To  establish  observed contamination  for the soil
exposure pathway, the measured concentration of a
nonubiquitous manmade radionuclide in soil samples
must meet the  criteria listed  above, and the
radionuclide  also must be present at the surface or
covered by 2  feet or less of cover material.

For the soil  exposure pathway,  observed
contamination is also established if  the gamma
radiation exposure rate equals or exceeds a level equal
to twice the site-specific background gamma radiation
exposure rate. Some portion of the increase in the
gamma radiation  exposure rate must be attributable to
the site.  If gamma-emitting  radionuclides can be
detected where persons may be exposed to gamma
radiation, the radionuclides do not have to be  present
at the surface or covered by 2 feet or less of cover
material  to establish observed contamination.

Level I and Level II actual contamination of targets
evaluation uses different media-specific benchmarks
for radioactive substances (see HRS Section 7). For
the soil exposure pathway, Level I concentrations are
assigned automatically to a sampling location if the
external gamma radiation exposure rate (in units of
pR/hr measured with a survey instrument at 1 meter
above the ground surface) equals or exceeds two
times the background level.

4.9.5 Ground Water and Surface Water
        Pathways

In addition to the guidance provided in Sections 4.5
and 4.6, the SI investigator should be aware of special
considerations for collecting and analyzing ground
water and surface water aqueous samples and surface
water sediment and tissue samples for radioactive
substances. The SI investigator should check with
EPA Regional, laboratory, or Headquarters Radiation
Programs staff for guidance and  standard  procedures
manuals (U.S. EPA, 1984, and U.S. DOE, 1983) and
special  instructions regarding sample  collection,
handling, and preservation.

With the  exception of tritium, water samples  for
radionuclides should be collected in clean plastic or
teflon containers.   Tritium  samples  should be
collected in glass containers only. The standard
preservation technique for radionuclides  in water is
acidification to a pH of less than 2 using nitric or
hydrochloric acid. Preservatives should be added as
soon as possible after filtration. The following  are
exceptions:

  •   Tritium, C-14, and isotopes of iodine should not
     be acidified and analysis should be conducted as
     soon as possible after collection.
  •   Cesium radioisotopes should be preserved with
     hydrochloric acid only.

In  all  cases,   the  laboratory performing  the
radioanalysis should be contacted prior to sample
collection for their recommendations on  sample
handling and preservation.

The volume of water sampled can range from a  few
milliliters to several liters, depending on the decay
mode, radiation abundance and half-life of  the
radionuclide,  expected  concentrations, and  the
sensitivity of the radioanalytical method.     The
laboratory should be consulted for recommendations.
Holding times for water samples  depend primarily on
the half-life of the radionuclide. Again, the analytical
laboratory should be  consulted on this issue.
Radionuclide water concentrations are reported in
activity concentration units, usually in picocuries per
liter (pCi/L).
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Like Sis for non-radioactive waste investigations,
radioactive sediment samples are taken to establish a
release to surface water and to document targets
exposed to actual contamination. If surface water
sediment and aqueous samples are co-located, the
sediment  samples  should  be  collected  after  the
aqueous samples. In some cases where high levels of
gamma-emitting radionuclides have been released,
submersible radiation detection survey probes and
instruments may  aid in the selection of sediment
sample locations.

Handling and preservation techniques for surface
water sediment samples are similar to those for soil
samples. Core sediment samples are usually frozen in
the collection tubes, sectioned (1 to 6 inches in length
depending on analytical sensitivity), air- or oven-
dried, ground, and analyzed either intact or after
radiochemical separation and concentration.

For surface water tissue sampling and analysis, two
key factors should be  considered the species of
aquatic organism sample;  and the portion of the
organism analyzed. Radionuclide concentrations in
aquatic organisms can vary among different species
based on feeding habits, habitat, and position in the
food chain.     Certain radionuclides  may  also
concentrate in specific tissues. For example:

 •   Strontium-90, cesium-137, manganese-54, and
     radium tend to  concentrate  in  the shells of
     freshwater crustaceans  and mollusks.
 •   Cobalt-60 accumulates in the kidney.
 •   Iron-55 and iron-59 accumulate in the spleen
     and kidney.
 •   Zinc-65 accumulates in the spleen and liver.

Tissue sampling   locations   and methods  for
radionuclides are similar  to those described in Section
4.6. Tissue samples  are normally frozen  before
analysis. Special care  should be taken when wet- or
dry-ashing biological  samples containing  polonium,
cesium, lead, manganese,  or cobalt are being analyzed
to  avoid volatilization  of these radionuclides. Tissues
containing radionuclides should not be dry-ashed or
treated with oxidizing  agents.   If tissue sample
analysis is necessary to evaluate actual contamination
of a fishery, replicate  samples may be needed due to
the uncertainty of the exposure  history of these
organisms.
Concentrations of radionuclides in  surface water
sediment and tissue samples are generally reported in
activity concentration units of picocuries per gram
(pCi/g) or per kilogram (pCi/kg) on a wet weight
basis.

4.9.6 Soil Exposure Pathway

In addition to the guidance provided in Section 4.7,
the  SI investigator should  be  aware  of special
considerations for collecting and analyzing soil for
radioactive  substances.

In general, no preservation techniques are required for
radionuclide soil samples. However, soil samples
with high organic levels should be dried or ashed,
with the following exceptions:

  •   Aliquots of soil samples selected for H-3 should
     not be dried or ashed.
  •   Aliquots of soil  samples selected  for C-14
     should not be ashed or leached with acid.
  •   Aliquots of soil samples selected for elements
     with volatile oxidized forms (e.g., I, Tc) should
     not be treated with oxidizing acids.
  «   Aliquots of  soil samples selected for Ra-226
     analysis by  gamma  spectrometry should be
     dried, crushed, or sieved, but an appropriate
     post-preparation holding time is necessary to
     reach equilibrium with radon daughters.

Holding times for soil samples depend primarily on
the half-lives of the radionuclides to be  analyzed.
Soil sample amount depends on a number of factors,
including (but not limited to) the  decay modes, half-
lives and  expected  concentrations of the specific
radionuclides, analytical sensitivity, and analysis time.
Concentrations of radionuclides in soil are generally
reported in activity concentration units of picocuries
per gram (pCi/g) of dry soil.

4.9.7  Air Pathway

In addition to the guidance provided in Section 4.8,
the  SI investigator should  be  aware of special
considerations  for  collecting and  analyzing air
samples for radioactive substances.

In general, suspended radioactive particulate should
be collected on a  filter  using a high-volume sampler
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                     Site Inspection Guidance
at high flow rates (> 20 ftVmin). For radiochemical
analysis, membrane filter paper are preferred because
they are readily ashed. Either membrane filters or
glass fiber filters are suitable for direct counting of
activity on the filter. Collection efficiencies for both
types of filters remain high (> 99 percent) over a
wide range of particle sizes and filtration velocities,
however both produce moderately high pressure drops
and are fragile. Radioactive air samples are usually
collected over a period of several hours to days. The
laboratory  performing the analyses  should be
consulted for recommended sampling procedures and
times prior to collection. Filter sample measurements
should be delayed for at least 5 hours after collection
to allow for the decay of short-lived radon progeny
that are also collected on the filter from ambient air.
Gaseous isotopes of iodine (primarily 1-131) should
be collected on an activated charcoal cartridge or on
silver zeolite. Particulate iodine should be collected
on a glass fiber or membrane filter. Normally, both
gaseous  and particulate  iodine are  collected
simultaneously in a sampling apparatus consisting of
a particulate filter, charcoal  cartridge, and vacuum
pump in series.

Tritium, in the form of tritiated water vapor, is
usually collected from the atmosphere onto silica gel
(see NCRP, Tritium Measurement Techniques, NCRP
Report  No. 47,  (1976)).  Tritium  vapor should be
sampled at high flow rates for a few days to collect
larger sample volumes and increase detection
sensitivity. However, care must be taken to control
the  flow  rate and sampling  time  to avoid
oversaturation  of the  gel  with water  vapor.
Temperature and humidity are important factors to
consider in determining sampling times and flow rate.
Air  sample  volumes for radionuclide  analyses
normally range from 1 to 30 or more cubic meters.
Concentrations of radionuclides in air samples are
usually reported in units of picocuries  per liter of air
(pCi/L) or in units of picocuries per cubic meter of
air (pCi/m3).

4.10 SUMMARY

SI objectives determine the types,  number,  and
location of  samples to  collect. By evaluating the
benefits  of sampling  at specific locations  and
assessing  the validity of analytical data available
before sampling, the investigator will be  able to
achieve the dual goals of meeting  SI objectives and
conserving Superfund resources. Because the SI is a
limited-scope,  biased  sampling  event,  strategic
selection of sample locations is perhaps the  most
critical decision that will affect the success of the
investigation. Table 4-18 summarizes the focused and
expanded  SI strategies designed to  optimize selection
of sample  locations.
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                                                 TABLE 4-18:  SUMMARY OF SI SAMPLING STRATEGY
               FACTOR
           Hazardous
           substance
           characteristics
           Hazardous waste
           quantity
           Release to ground
           water
           Drinking water
           targets exposed to
           actual ground
           water
           contamination
           Release to surface
           water
       PA
 STRATEGY
Maximum values
assumed1
Calculated value
Suspected release
Primary targets
Suspected release
          FOCUSED SI STRATEGY
Sample sources to identify specific hazardous
substances present at the site.
Review PA data; obtain additional records; obtain
source quantity and area measurements; do not sample
to determine hazardous waste quantity; contaminated
soil source area may be estimated based on visual
observations.
Sample nearest well suspected to be exposed to
hazardous substances.  Sampling to test a suspected
release could be conducted in conjunction with
sampling to test contaminated target hypothesis.
Sample nearest drinking-water wells suspected to be
contaminated. Sample municipal wells, regardless of
depth, if reasonable probability of site related
contamination.
Sample at or just downstream of the probable point of
entry. Sampling to test a suspected release could be
conducted in conjunction with sampling to test a
contaminated target hypothesis.  Also consider direct
observation option.
  EXPANDED AND SINGLE SI STRATEGY
Same
Review previous data; in limited cases, sample to
determine hazardous waste quantity; contaminated soil
source area may be further characterized based on
analytical data.
Sample wells likely to be exposed to hazardous
substances.  Sampling to document a release could be
conducted in conjunction with sampling to document
targets exposed to actual contamination.  Install and
sample monitoring wells if ground water pathway is
significant to scoring  and attribution is an issue.  If
necessary, resample focused SI locations.
Sample drinking-water wells likely to be
contaminated.  Sample municipal wells, regardless of
depth, if there is some reasonable probability of site
related contamination.  If necessary, resample focused
SI locations. Note that for metal analysis, filtering
may be necessary.
Sample at or just downstream of the probable point of
entry.  Sampling to document a release could be
conducted in conjunction with sampling to document
targets exposed to actual contamination.  If necessary,
resample focused SI locations.  Also consider direct
observation option.
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                             TABLE 4-18:  SUMMARY OF SI SAMPLING STRATEGY (CONTINUED)
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   FACTOR
       PA
  STRATEGY
          FOCUSED SI STRATEGY
 EXPANDED AND SINGLE SI STRATEGY
Drinking water
targets exposed to
actual surface
water
contamination
Primary targets
Collect sediment and aqueous samples at or beyond
the point of drinking water withdrawal prior to
treatment.  Note that Level I contamination can only
be scored based on aqueous sample results.
Collect sediment, aqueous, and benthic samples at or
beyond points of drinking water withdrawal prior to
treatment.  If necessary, resample focused SI
locations.  Note that Level I contamination can only
be scored based on aqueous samples.  Note that for
metal analysis, filtering may be necessary.
Human food
chain organisms
exposed to actual
surface water
contamination
Primary targets
Collect sediment and aqueous samples from within or
beyond the fishery boundary and as close to the PPE
as possible. Tissue samples should generally not be
collected at the focused SI.
Collect sediment, aqueous, and benthic tissue samples
from within or beyond the fishery boundary.  Collect
other tissue samples (e.g., fish) from within or beyond
the boundaries of actual fishery contamination.  If
necessary, resample focused SI locations.  Note that
Level I contamination can only be score based on
tissue samples. Only collect tissue samples if human
food chain threat is significant to scoring.
Sensitive
environments
exposed to actual
surface water
contamination
Primary targets
Collect sediment and aqueous samples at or beyond
the sensitive environment  Sampling to test suspected
contamination of a surface water sensitive
environment may be conducted in conjunction with
sampling to test a suspected release to surface water.
If possible, collect at least two samples 0.1 miles
apart to test suspected contamination of a wetland.
Note that Level I contamination can only be scored
based on aqueous sample results.
Collect sediment and aqueous samples at or beyond
the sensitive environment  Sampling to document a
release to surface water may be conducted in
conjunction with sampling  to document targets
exposed to actual contamination. If possible, collect
at least two samples 0.1 miles apart to document
contamination of a wetland. Note that Level I
contamination can only be  scored based on aqueous
sample results.
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                                       TABLE 4-18: SUMMARY OF SI SAMPLING STRATEGY (CONCLUDED)
              FACTOR
           Observed surficial
           contamination
          Resident
          population targets
          exposed to
          observed surficial
          contamination
          Release to air
          Populations and
          sensitive
          environments
          exposed to actual
          air contamination
       PA
  STRATEGY
Surficial
contamination
assumed1
Resident
population
Suspected release
Primary targets
          FOCUSED SI STRATEGY
Sample source areas to determine surficial
contamination.  Sampling for this factor should be
conducted in conjunction with waste and source
characterization samples. Samples must be collected
from a depth of 2 feet or less.
Sample properties suspected of being resident targets.
Samples must be collected from within the property
boundary and 200 feet from targets, except for
terrestrial sensitive environments for which samples
must be collected from within environment
boundaries.
Sampling to test a suspected release to air when only
the air pathway is cause for further investigation.
Generally, air sampling is an expanded SI activity.
Evaluate targets based on their location relative to the
distance category in which the release to air is
evaluated.
 EXPANDED AND SINGLE SI STRATEGY
Sample source areas to better characterize observed
surficial contamination.  Sampling for this factor
should be conducted in conjunction with source
characterization.  Samples must be collected from a
depth of 2 feet or less.
Sample properties suspected of being resident targets.
Samples must be collected from within the property
boundary and 200 feet from targets, except for
terrestrial sensitive environments and resources, for
which samples must be collected from within the
environment or resources boundaries.
Sample to document a release when this pathway is
the only significant pathway to scoring.  Some sample
locations should be located away from site sources.
Evaluate targets based on their location relative to the
distance category in which a release to air is
documented.
                 1 Unless analytical data indicate otherwise
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Site Inspection Guidance
                                 SI  Evaluation
                                          CHAPTER 5
                                       SI   EVALUATION
   This chapter discusses activities that occur after analytical data and non-sampling information from the SI have
   been received or collected. These activities include review and validation of analytical data, identification of
   analytical data for scoring, review of non-sampling information, and site scoring.
The most important decision made after any SI is
whether further investigation is necessary. If so, the
investigator should establish the purpose and scope of
the additional investigation. If not, the site is ready
to be scored or deemed SEA. The type and quantity
of scoring information needed depend on the objectives
of the SI—for example, the data needed to screen the
site from further Superfund investigation will differ
from the data needed to fulfill HRS documentation
requirements.

5.1 REVIEW AND VALIDATE
     ANALYTICAL DATA

Before scoring the site, the investigator should evaluate
previous results (e.g.,  PA, earlier  SI, State
investigations,   emergency   response   actions,
owner/operator investigations) and new SI results.
These results include analytical data and non-sampling
information. Chapter 3 of this guidance discusses
evaluating previous results in planning the SI; this
section discusses how to integrate all data for  scoring.

All analytical data should be evaluated for validity and
applicability before scoring. Site assessment validation
includes review of laboratory analyses and comparison
of the body of data to performance criteria. The
investigator or project  chemist should evaluate
analytical data and laboratory information to determine
whether  sampling  protocols  and procedures used
Regionally  approved methods. The reviewer should
examine:

  •   Sampling   dates,  locations,  depths,  and
     descriptions
  •   Sample collection and preparation techniques
 •   Laboratory preparation techniques, analytical
     methods, and analytical results
 •   Method detection limits or sample quantitation
     limits
 •   QA/QC samples
 •   Documentation

The investigator, assisted by the project chemist,
QA/QC personnel, and the laboratory, is responsible
for obtaining valid and usable analytical data. Table
5-1 identifies data review considerations.

Laboratory data packages are validated according to
guidelines established in the SI work plan. Items
reviewed during the data validation process depend on
the QA objectives of the data user (usually determined
by EPA Regions or States). Data that may need to be
validated include:

 •  Sample  holding times
 •  Initial and continuing calibration verification
 •  Interference check sample for inorganic
 •  Determination of bias (percent recovery)
 •  Precision (e.g., replicate analysis)
 •  Detection  limits
 •  Confimned  identification  data

Professional judgment is used to validate the overall
data package. The reviewer should comment on SI
sample sets if several  QC criteria are  out of
specification. The additive nature of QC factors out
of specification  is difficult to assess, but the reviewer
should inform the user about  data quality and
limitations.   This helps avoid applying the data
inappropriately, while still allowing exclusion of the
data. The reviewer should be provided with the data
quality objectives (DQOs) of the  SI  samples.
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                           TABLE 5-1: DATA REVIEW CONSIDERATIONS
    n  Review data reports for transcription and typographical errors (e.g., 0.5 v. .05; ppb v. ppm)

    D  Determine if sampling protocols were appropriate

    D  Compare data against field and trip blanks to detect cross-contamination

    D  Compare field replicates samples

    D  Review laboratory QC (e.g., laboratory blanks, method standards, spike recovery, duplicates)

    D  Summarize detection  limits for non-detectable results

    D  Review detection limits for positive but non-quantifiable data

    D  Review sampling program design for assessing media variability

    D  Review background concentrations to help identify site-specific contamination

    D  Delete unusable data, attach qualifiers to usable data, and explain limitations of qualified data
Gtuidance for  Data Usability in Site Assessment
discusses data validation procedures in more detail.

The reviewer verifies the usability of analytical results
by reviewing QC samples and qualifiers. Routine CLP
analyses  have well-defined  reporting requirements,
while special CLP analyses and non-CLP analyses
have  differing  requirements. The review assesses
overall analytical performance, considering both the
laboratory and  the methods. In some cases, the data
reviewer may have to notify the laboratory to resolve
performance problems (e.g.,  to  retrieve  missing
information, request re-analysis  of samples from
extracts, or request construction and re-interpretation
of analytical results).

The  scope  of data  review depends on user
requirements.    Communication between the data
reviewer and the project chemist is crucial during data
evaluation.    The  chemist  should interpret  issues
resulting  from the data review and correlate analytical
review with  site-specific information,  such as physical
conditions at the site that affect sample results.

During data validation, problems with the data package
sometimes  prevent the reviewer from adequately
qualifying the data, especially if raw data, chain-of-
custody, traffic reports, or  data reporting forms are
missing.  If the reviewer's sample calculations do not
match the laboratory results,, the reviewer should
contact the laboratory. Samples analyzed according to
special CLP methods (or non-CLP methods) may
require verification of sample quantitation limits,
methods of extraction (particularly for fish tissue), and
analytical procedures.

5.2 IDENTIFY ANALYTICAL  DATA
     FOR  SCORING

Investigators may use analytical data  differently to
screen a site than to list a site. Investigators should
refer  to  Guidance for Data Usability in Site
Assessment  and  Hazard  Ranking System  (HRS)
Guidance Manual for further information on  the
application of analytical data and guidelines to apply
data to list sites. The following HRS aspects generally
depend on analytical date:

  •  Observed releases
  •  Observed  contamination  (soil exposure pathway
     only)
  •  Targets exposed to actual contamination
  •  Levels of target contamination
  •  Hazardous waste quantity, particularly constituent
     quantity

 The investigator's professional judgment determines
 whether the quality of analytical data are adequate for
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Site Inspection Guidance
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scoring. Sometimes non-CLP data provided by other
parties  or generated  by  EPA during previous
investigations, such as emergency response actions,
may be used. Examples include the following.

 •   Analytical data obtained from the site owner
     without accompanying QA/QC information may
     be used if the data are reasonable for their
     intended use and can be applied in a similar
     manner as SI analytical data.

 •   Data supplied by local or State authorities (e.g.,
     county health  department) indicating high
     concentrations of a  particular hazardous substance
     in surficial soils at the site may be used  if that
     substance can be attributed to the site.

The SI investigator  must attempt to obtain QA/QC
documentation for the results. Concentrations from
non-CLP data provided by other parties or from
previous EPA investigations most  likely support
observed contamination and should be used to evaluate
waste characteristics and  other HRS factors (e.g.,
containment, human population targets).

The primary source of laboratory services for the SI
are Regional Laboratories and the CLP. However,
other analytical services may be more appropriate than
CLP and generate data of comparable or acceptable
quality. The minimum data quality acceptable for SI
scoring depends on:

 •   Intended use of the data (e.g., to screen or list the
     site);
 •   Specific  site  hypothesis  being tested (e.g.,
     suspected surficial contamination);  and
 •   Particular HRS factor being evaluated (e.g.,
     hazardous waste constituent quantity).

CLP data may be qualified during laboratory analysis
or data validation. Qualified data may be more useful
for focused SI screening than to meet the  listing
objectives during a single or expanded SI. Qualified
data (coded as "J", "TJ",  "UJ", or "R") generally
represent estimated concentrations that are qualitatively
correct but may not meet specifications for quantitative
accuracy and precision. Qualified data may be used
only if the bias (unknown, low, high) associated with
the data and the reasons for qualification are known.
Some qualified data still may not be appropriate to
develop a score for listing. The investigator should
refer to Guidance for  Data  Useability  in  Site
Assessment and Hazard  Ranking  System (HRS)
Guidance Manual for detailed information on  using
qualified data to list a site.

Analytical data of unknown quality are generally not
adequate to  score a site. However, previous  data
meeting minimum usability  requirements may be
combined  with SI data to  test site  hypotheses.
Similarly, data not meeting minimum requirements
may be used if subsequently confirmed by SI data.

EPA has established three data use categories (DUCs)
(see Table 5-2):

  •   DUC-I  data  (e.g., CLP data) are the most
     rigorous and are associated with a high degree of
     confidence.
  •   DUC-II  data  lack the detailed validation
     procedures of DUC-I.
  •   DUC-III data (e.g., qualitative concentration
     ranges reported by health and safety monitoring
     instruments) are the least rigorous and are
     associated with a low degree of confidence.

Examples of analytical data not adequate to test
hypotheses or to score an SI include

  •   Background samples with higher concentrations
     of hazardous substances  than onsite samples
  •   Ground water samples where the matching blanks
     show contamination possibly due to improper
     sampling procedures
  •   Volatile organic analyses for aqueous surface
     water samples qualified due to excessive holding
     times

If the analytical  data are  not adequate to test
hypotheses or to score  the site, the investigator should
talk to EPA Regional officials.  The  investigator
should determine whether the SI objectives can be met
regardless of inadequate  analytical data. Chapter 6
discusses where additional evaluation may be needed.

5.3  EVALUATE  NON-SAMPLING
      INFORMATION

The SI investigator should evaluate the quality of all
non-sampling information and identify factors requiring
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                     Site inspection Guidance
                  TABLE 5-2:  DATA USE Categories (DUG) FOR SI SCORING
HRS FACTOR
Observed Release/Observed Contamination
Hazardous Waste Constituent Quantity
(Tier A)
Hazardous Wastestream Quantity (Tier B), Hazardous Waste Volume
Quantity (Tier C), or Area Quantity (Tier D), although rarely based
on sample results
Area of Observed Contamination
Targets Exposed to Actual Contamination
Hazardous Substances Associated with Site Sources
SI SCREENING
DUC-I
DUC-II
DUC-HI
DUC-I
DUC-II
DUC-I
DUC-II
Duc-m
DUC-I
DUC-II
ouc-ni
DUC-I
DUC-II
ouc-ni
DUC-I
DUC-II
ouc-ni
LISTING
DUC-I
DUC-II
DUC-I
DUC-I
DUC-II
DUC-I
DUC-II
DUC-I
DUC-I
DUC-II
additional information. If site conditions have changed
since the  previous  investigation,  non-sampling
information should be  updated during the SI. Changes
in site conditions also may affect the  SI sampling
strategy. Nearby target information, in particular,
should be evaluated if considerable time has elapsed
since the information was collected. For example:

     While assembling reference materials during
     the focused SI, the investigator noticed that
     the SI field logbook mentioned a closed
     chemical plant adjacent to the site. When
     the PA was performed, she considered the
     plant  employees the nearest individual
     factor (air pathway). After further research,
     she learned the  plant had been closed, its
     closing had no relationship to the site she
     was evaluating.  The HRS value  for this
     factor was  modified since the chemical
     plant was now abandoned and its employees
     were no longer air pathway targets.
The investigator should ensure that the quality of non-
sampling information is acceptable. In some cases,
this review will identify factors requiring additional
information, such as stream flow or census data.

5.4 SCORE THE SITE

After reviewing and verifying the SI results, the SI
investigator must evaluate the site score according to
the HRS. The primary difference between PA and SI
scoring involves  key  HRS factors  that  require
analytical data. Several tools are available for scoring:

  •   SI worksheets
  •   PREscore software package
  •   Other  evaluation  tools  developed by  EPA
     Regional or State offices

The general approach for site scoring, applying any of
these tools, is to characterize and evaluate sources and
significant pathways, evaluate releases and targets
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Site Inspection Guidance
                                  SI Evaluation
exposed to contamination, check scoring, and collect
additional information, if needed. This approach may
be modified according to the amount of available site
information and the types of investigations that have
been performed at the site.

For some sites, a preliminary screening score should
be calculated. If the screening score is based on non-
site  specific data-for example,  best  estimates,
information from a nearby CERCLA site, or regional
geologic information-the investigator may have to
collect more information before completing the site
score.  The screening score should be evaluated to
determine whether more data or additional samples
should be collected. As new data become available,
the screening score should be updated.

The investigator may use the SI Data Summary tool
(Appendix B) to compile analytical data and non-
sampling information. These sheets also may serve as
a checklist to:

  •   Summarize previous and new information.
  •   Identify  quantitatively important HRS factors.
  •   Identify factors  that have  not  been fully
     evaluated.
  •   Document data by reference.
  •   Focus additional data collection efforts.

Completed SI Data Summary sheets may facilitate
entering data into PREscore or other SI scoring tools.

Generally, if the contribution of a pathway or threat
to the overall score is minimal, it should still be
qualitatively  discussed in the SI narrative report,
particularly  if  partial  data  are  available.  This
discussion will help present a more complete picture
of the conditions and threats at the site and may
provide useful  information for planning remedial
investigations and other work, if necessary.

Investigators  should  refer to Hazard Ranking System
(HRS) Guidance Manual for guidelines to evaluate
HRS factors. This  directive  provides general and
technical guidance for investigators applying the HRS
to prepare packages for NPL consideration, including
general rules for organizing data and information,
clarification of HRS terms and concepts, policy issues,
effective scoring strategies, and instructions  for
relatively complex HRS factors.
5.4.1      Scoring Tools

SI worksheets (provided in Appendix C) and other
evaluation tools support  site  screening  scores.
PREscore supports both screening and listing scores.
The focused SI investigator may rely on any of these
scoring tools. PREscore should be used to evaluate
the site score for the expanded or single SI.

SI Worksheets

The SI worksheets may be appropriate to  score most
sites. The investigator may use the worksheets when
the SI tests a limited number of hypotheses that are
responsible for the PA further action recommendation,
for example, a suspected release to surface water and
a primary target such as a fishery  exposed to actual
contamination. In this example, no other pathway or
combination of pathways  scored high  enough to
warrant further site investigation. The SI worksheets
generate a representative site score without requiring
the entry of more complete  data into PREscore.

The SI worksheets build on PA  information and
hypotheses by explicitly evaluating analytical data
generated during the SI and other investigations. The
worksheets quantitatively evaluate the key HRS factors
affecting the site score, saving resources by reducing
data and documentation requirements for the focused
SI. Materials to assist scoring include instructions to
evaluate HRS factors, scoresheets, hazardous substance
value look-up tables, and hazardous substance chemical
benchmark tables. The SI worksheets differ from the
PA scoresheets in two significant areas:

  •   Tables to identify hazardous substances detected
     in observed  releases  and at exposed targets
     replace PA "criteria lists."    The tables allow
     determining the level (i.e., Level I or Level II—
     see  Section 5.4.4 of  this guidance)  of
     contamination at exposed targets based on sample
     concentrations.   Applying analytical data, the
     HRS terms  "observed  release" and  "actual
     contamination" replace the PA terms "suspected
     release" and "suspected contamination."

  •  SI worksheets add substance-specific factors
     (e.g., toxicity/mobility, toxicity/persistence) and
     waste characteristics values from O to 100 (O to
      1,000  for  surface water food chain and
     environmental threats),
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                     Site Inspection Guidance
The SI worksheets  may  be used to evaluate all
pathways to reflect the relative importance of each
pathway to the overall site evaluation.  Minimally
contributing pathways or threats should be  scored, even
if only partial data (e.g., information collected during
the PA) are available. For these lesser pathways and
threats  the SI investigator should provide a brief
qualitative discussion of available information in the
SI narrative report to present a more complete picture
of the conditions  and threats at the site.   Such
information may be used to plan the expanded SI, if
necessary, or to identify additional  non-sampling
information needs. Scoring all pathways also helps
reduce "false negatives" in screening process results.

PREscore

PREscore automates operations to assign HRS factor
values, allowing  entry and  evaluation  of site
information, including sampling data, hazardous waste
quantity and waste characteristics, physical parameters
of the  site, population data, and other target
information. PREscore includes PREprint, a program
that prints I-IRS scoresheets and a documentation
record for sites to be considered for the NPL.
PREscore is the appropriate tool to score some sites,
particularly if the focused SI tests several hypotheses
and CLP analytical data establish observed releases
sufficiently for HRS documentation. PREscore also
may be the best tool if the site score is primarily based
on  potential to release for a significant migration
pathway or multiple pathways. Finally, PREscore
helps propose and screen alternative scoring scenarios
(e.g., scoring multiple aquifers or watersheds, observed
release versus potential to release), and can  save
considerable  time in evaluating substance-specific
waste characteristics.

PREscore should be used to develop the site score for
listing purposes (e.g., at the end of the single or
expanded SI). This program calculates I-IRS factors
from raw data, retrieves values from hazardous
substance look-up tables, calculates site scores, and
generates HRS documentation and other records.
PREscore assists  investigators  in  meeting  HRS
requirements and minimizes potential mathematical
errors in scoring. The PREscore user must be familiar
with all aspects of the HRS. See PREscore Software
Users Manual & Tutorial (OSWER Directive 9345.1-
04, 1991) for instructions.
                         TABLE 5-3: SI WORKSHEETS VERSUS PREscore
CRITERIA
Amount of Information
Quality of Analytical Data
Effort, Resources Available
Importance of Potential to Release
Factors
Scorer's HRS Experience
Number of Pathways to Evaluate
Test Scenarios, Calculate HWQ and
SCDM Values
SI WORKSHEETS
Sufficient for screening
Incomplete information is
generally acceptable
Variable
Lower
Lesser importance, evaluates
only the most critical
potential to release factors
Low
All pathways
Tricky
PREscore
Sufficient for screening or
listing
Generally requires complete
information
High
Higher
Higher importance, evaluates
all potential to release factors
High
Significant pathways
Easy
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                                 SI  Evaluation
HRS pathways posing significant threats to human
health and the environment should be scored using
PREscore. The term "significant" applies not only to
the overall level of relative threat at the site compared
to other sites, but also to the level of relative threat for
an individual pathway at the site compared to the level
of relative threat for other pathways at that same site.

Other less significant pathways or threats may be
scored using PREscore if:

  •   Complete information is available for the
     pathway or threat;
  •   An observed release (or observed contamination)
     has been demonstrated for the pathway or threat,
     regardless of the number of targets exposed to
     actual contamination; and
  •   An observed release has not been demonstrated
     for the  pathway or threat, and a large number of
     targets are exposed to potential contamination.

A combination of the SI worksheets and PREscore
may be appropriate to score sites. For example, the
SI worksheets may be used to develop a preliminary
screening score, i.e., a "back of the envelope"  score
to scope results and the next steps. After a reviewer
experienced with the HRS ensures the SI worksheets
justify  a more complete scoring effort, the investigator
would use PREscore to evaluate and document the site
score. If the  SI worksheets indicate that the site score
will  be less than 28.50, PREscore may  not be
necessary.    Applied  this way, both  tools  can
complement each other to help focus scoring efforts
and save resources.

Other Scoring Tools

In addition to PREscore and the SI worksheets, other
scoring tools are sometimes used by EPA Regional or
State offices. These  tools should be applied in a
consistent manner when developing SI scores. In all
cases, these tools should reflect HRS requirements to
the extent practicable, and training should be provided
to allow investigators to efficiently score sites.

5.4.2     Characterize and Evaluate Significant
          Site Sources

The  investigator should briefly characterize each
source (see Table 5-4) by assessing:

  •   Hazardous substances associated with the source;
  •   Hazardous waste quantity; and
  •   Pathways for which the source is evaluated.

Containment characteristics should be investigated for
sources that do not contribute to  a release to a
migration pathway or for any pathway evaluated based
on potential to  release.   Once all sources are
characterized for each pathway, target distance limits
can be measured.
                      TABLE 54: CHARACTERIZE AND EVALUATE SOURCES
ITEM
Location
Hazardous Substances
Hazardous Waste Quantity
Eligible Pathways
Containment Characteristics
(If necessary)
SCORING CONSIDERATIONS
Refer to site map or sketch.
Consider analytical data and historical records. Hazardous
substances should be associated with the source or the site in
general.
Consider analytical data, historical records, field
observations, and aerial photos. Consider qualifying
removals.
Indicate pathways for which the source is evaluated.
Identify source type. Consider construction diagrams,
historical records, field observations, and analytical data.
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For each source, the investigator should characterize
wastes deposited to identify the specific hazardous
substances associated with the source. Substance-
specific  characteristics  (e.g., toxicity,  mobility,
persistence) then can be evaluated.

Only substances associated with documented or
suspected pathway contamination and substances
associated with a  source  having  poor  or  no
containment for  the pathway being evaluated are
considered. Where a substance can be identified as
being present at the site,  but the sources of that
substance  cannot be identified,  the substance is
considered to  be present in all sources  at  the
site,except for sources where available information has
ruled out the presence of that substance.

In some cases, samples collected during the SI may be
used to refine the hazardous waste quantity evaluation
for site sources. For example, surficial soil samples
collected during the focused SI may indicate that the
area of observed  contamination is greater than that
indicated by the PA. In most cases, however, the
limited number of samples collected during the SI
generally will not be sufficient to calculate hazardous
waste  constituent quantities but may be used to
document other hazardous waste quantity measures,
such as volume or area of the source.
by the site should be considered in evaluating the
surface water pathway.

Frequently, sites  are recommended  for further
investigation because a single pathway or threat scores
57 or greater; the evaluation of other pathways or
threats may increase a site score already greater than
the cutoff score. In many cases, an observed release
or observed contamination and targets exposed to
actual contamination are needed for the site score to
be greater than or equal to 28.50 based on a single
pathway or threat.  Types of single significant hazards
for which a site score  may be above the cutoff score
include:

  •   If ground water is the only pathway evaluated,
     either an observed release or potential to release
     to large target populations is critical.

  •   If the surface water drinking water threat is the
     only threat evaluated, either an observed release
     or potential to release to large target populations
     is critical.

  •   If surface water human  food chain threat or
     environmental threat is the only threat evaluated,
     a fishery or sensitive environment exposed to
     actual contamination is critical.
Investigators  should evaluate the sources of site
contamination. SI investigators need not fully evaluate
sources, but should briefly describe in the narrative
report any source that cannot release hazardous
substances to a particular migration pathway, cannot
be adequately characterized due to poor or incomplete
information (e.g., no reliable evidence indicates the
source received hazardous waste), or which has been
eliminated by  a qualifying removal (see The Revised
Hazard Ranking System: Evaluating Sites After Waste
Removals, OSWER Directive 9345.1-03FS, 1991).

5.4.3     Characterize and Evaluate Significant
          Pathways

The pathways posing the  most significant threat to
human health and the environment should be identified
and characterized. For example, more than one aquifer
may be threatened by hazardous substance releases
from the site; therefore, each aquifer  should be
evaluated for its contribution to the ground water
pathway score. Similarly,  all watersheds  threatened
 •   If surface water human food chain threat is the
     only threat evaluated, observed release to surface
     water, but not to the fishery, is critical,

 •   If soil exposure is the only pathway evaluated,
     areas of observed contamination and a resident
     population or terrestrial sensitive environment are
     critical.

 •   If air is the only pathway evaluated, an observed
     release and a population or sensitive environment
     near the site are critical.

The SI investigator need not score a specific pathway
for a given site if:

 •   No significant targets are associated with the
     pathway.

 •    All sources at the site have a containment factor
     value of O for the migration pathway, and no
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     observed release to that  pathway has been
     demonstrated.

  •   No observed contamination  is established for the
     soil  exposure  pathway  (e.g.,  no surficial
     contamination within 2 feet of the ground surface
     has been documented).

Pathways or threats that do not significantly contribute
to the site  score may not require evaluation. However,
if the resulting site score is near the cutoff when one
or more pathways are not scored, the investigator
should score pathways that initially appeared not to be
significant.
                                     5.4.4     Evaluate Releases and Targets
                                               Exposed to Contamination

                                     Table 5-5 provides general considerations to evaluate
                                     targets for each pathway. In addition, the investigator
                                     should verify the consistency of target information
                                     between pathways.    Note that populations vary
                                     between pathways. For example, targets for the soil
                                     exposure nearby population threat are evaluated based
                                     on travel distance, while targets for the air pathway are
                                     evaluated based on straight line distance. Also, soil
                                     exposure nearby population includes only students, day
                                     care centers, and residents, while the  air pathway
                                     population also includes workers regularly present.
                                 TABLE 5-5: TARGET Evaluation
    PATHWAY
                         TARGET  CONSIDERATIONS
    Ground
    water
Determine targets for each aquifer separately
Determine targets exposed to actual contamination and the level of contamination
Determine any aquifer discontinuities or interconnections within defined distance limits
Determine population served by each target
Evaluate standby wells
Identify and verify blended water-supply systems
Identify resource uses and Wellhead Protection Areas, if necessary
    Surface
    water
Identify water bodies within the target distance limit; determine flow rates (or depths for
oceans and Great Lakes); determine whether each water body is fresh water, salt water,
or brackish
Identify significant surface water targets
Determine targets exposed to actual contamination and the level of contamination
Identify drinking water intakes and populations served; evaluate standby intakes
Identify and verify blended water-supply systems
Calculate potentially exposed target values after applying dilution weighting factors
Identify resource uses, if necessary
    Soil
    exposure
Determine approximate area of observed contamination
Determine whether contamination occurs within the property boundaries of residences,
day care centers, or schools, or on terrestrial sensitive environments or resources
Determine targets exposed to actual contamination and level of contamination
Identify workers and resource uses, if necessary
    Air
Evaluate people regularly occupying areas near or on site sources
Verify populations near the site (e.g., within 1 mile)
Determine targets exposed to actual contamination and level of contamination
Identify sensitive environments near the site (e.g., within 1 mile)
Identify resource uses, if necessary
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Investigators also should make sure that a population
is scored for the distance category in which the target
is located.

The SI often tests the likelihood of a release  or
exposure by collecting a limited number of samples to
determine whether a pathway exhibits evidence of
contamination. For screening purposes, this evidence
need not meet HRS requirements to  document an
observed release (or contamination), but needs to show
that it  is  likely to be  documented upon further
investigation.

SI samples collected at  appropriate locations can be
used to  evaluate specific substances associated with
site operations and containment at a specific source
and to test hypotheses regarding suspected releases and
targets exposed to actual contamination. For example:

     Based on historical records indicating that
     plating wastes containing chromium were
     generated and disposed onsite, a suspected
     surface water release was hypothesized at
     the PA.  If SI sediment samples from a
     nearby surface water body receiving runoff
     from  the site show concentrations of
     chromium above background levels, they
     could be used to establish  a  release.
     However, if  these samples showed no
     elevated concentrations of chromium, the
     surface water pathway would be evaluated
     based  on potential  to release  factors,
     refining the surface water pathway score.

Note that the absence of contamination for a particular
pathway based on a one-time sampling event does not
necessarily mean that  releases have not occurred.
Weather conditions, seasonal variations  affecting
ground water and surface water flow, and the selected
sample locations  may  not be  conducive  to
demonstrating contamination.    If  other  evidence
supports presence  of contamination, the investigator
should collect additional samples during the expanded
SI to further test site hypotheses.

Three categories of target contamination (Level I,
Level II, and potential)  are used to assign HRS values
to the nearest target (e.g., well, intake, food chain
individual,  resident, or individual) and  the population
and sensitive environment  factors:
  •   Level I  contamination:  concentrations  for
     targets that meet the criteria for observed releases
     or observed contamination, and are at or above
     media-specific benchmark  concentrations.

  •   Level II contamination:  concentrations  for
     targets that either meet the criteria for observed
     releases or observed contamination but are less
     than media-specific benchmarks, or meet the
     criteria for actual contamination based on direct
     observation.

  •   Potential contamination:   targets potentially
     threatened by releases (i.e., targets that are not
     actually  exposed to contamination via that
     pathway or threat).

If none of the hazardous substances  eligible to be
evaluated at a target has an applicable benchmark, the
actual contamination at the target is designated Level
II. If a hazardous substance benchmark has not been
established for a particular hazardous substance, the
default level (Level II) is used for targets that meet the
criteria for actual contamination.

The investigator should ensure that targets exposed to
actual and potential contamination have  been
adequately documented.  Among the three factor
categories  for an HRS  pathway—likelihood of release,
waste characteristics,  and targets-the targets factor
category is the only category that is not limited  to a
maximum value.  Therefore,  this category has the
largest potential to affect the site score.

During the PA, the investigator hypothesizes whether
targets  are suspected  to be  exposed  to actual
contamination using professional judgement. During
the SI, samples are  collected  to demonstrate the
presence or absence of hazardous substances at these
targets and to distinguish the  level  of actual
contamination. Note that such sample evidence need
not meet  HRS requirements to document actual
contamination, but only need show that actual
contamination is likely to be documented upon further
investigation. For example, if samples from nearby
drinking  water  wells  have elevated chromium
concentrations, they could be used to confirm a PA
suspected release to ground  water  and  confirm
hypotheses that specific ground water targets are
exposed to actual contamination.   The chromium
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concentrations found in these samples also could be
used to distinguish the level of contamination, thus
refining the ground water pathway score.

5.4.5     Check Scoring and Collect
          Additional Information

Personnel with HRS experience should check scores.
In most cases, a preliminary site score will accurately
indicate whether the site should be considered for
further investigation or  possible listing. However, this
preliminary score may differ from the final score
documented for the site. Some of these differences
may occur because previous  analytical data only
partially supported scoring observed releases and
targets exposed to actual contamination, but further
sampling did not.   Some  unusual conditions or
circumstances  may result in  an incorrect  site
recommendation because of simplifications inherent to
the SI  screening score.    Before  resources  are
committed to further investigation, experienced HRS
personnel should review the preliminary site score to
determine if it is reasonable.

Investigators initially should complete the preliminary
score, review all pathway scores, and verify key HRS
factors or scoring considerations. Elements that should
be verified include:

  •   Observed releases
  •   Areas of observed surficial contamination
  •   Property boundaries for soil exposure targets
  •   Targets exposed to actual contamination
  •   Factor values whose data are near a break point
     to next higher or lower  factor value
  •   Aquifer   boundaries,   discontinuities,  and
     interconnections
  •   Quality of analytical data

The preliminary score may indicate that another
scoring tool should be used, or  that alternative
scenarios to  score the site may be appropriate. If SI
results did  not support  a PA hypothesis  for  a
significant pathway (e.g., suspected ground  water
release), the investigator may consider evaluating
factors  involving  the alternate hypothesis (e.g.,
potential to release to ground water). The investigator
should collect additional information to score the
pathway, as necessary.

The preliminary site score  should be  analyzed to
determine where more data should be collected during
the SI or during additional investigation (e.g., the
expanded SI or prior to preparing the  HRS package).
Additional information  should  be collected if
significant HRS information cannot  be adequately
documented, or if newer information would  change the
site score above or below the cutoff.

Also, the investigator should ensure  that  the available
information reflects current site conditions, and is not
based on unreasonable assumptions or  estimates,
particularly at the end of the single or expanded SI.
In some cases, this review will identify factors for
which additional information is needed. If conditions
have significantly  changed since  the  previous
investigation-perhaps    due   to    a   residential
development, a natural catastrophe, or recent waste
disposal activities-the appropriate  non-sampling
information should be updated during the SI. For
example

     The previous SI was  performed  in
     September 1991 for a site consisting of a
     large  surface impoundment. During  an
     October 1992 hurricane, the diking  around
     the impoundment failed. A considerable
     portion   of  the  site may  now  be
     contaminated at the ground surface. Some
     factors that may require updating include:
     1) distance to surface water, 2) source type,
     and 3) containment, Sampling  from the
     area of surficial contamination also  may be
     appropriate during the next investigation.

For some sites, the investigator may  be unable to fully
meet the objectives of the SI,  particularly with respect
to testing  site hypotheses.    Chapter 6 discusses
circumstances where additional evaluation of the SI
results may be necessary.
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                                  SI Reporting
                                          CHAPTER 6
                              REPORTING REQUIREMENTS
   To fulfill SI reporting requirements, the SI investigator should complete two work products: a narrative report
   and scoresheets. The narrative report summarizes the findings of the field investigation, particularly the
   contamination associated with the site and migration pathways, The scoresheets evaluate the data according
   to the HRS. Scoresheets are considered preliminary and deliberative, and, as such, are confidential. They should
   not be attached to the narrative report and may not be released until EPA makes a final site disposition decision.
6.1  NARRATIVE REPORT

After scoring the site, the investigator prepares a
narrative report summarizing what is known about the
site, the activities conducted during the SI, and all
information researched. The report should:

  •   Describe the history and nature of waste handling
     at the site;
  •   Describe known hazardous  substances;
  •   Describe  pathways  of  concern for these
     substances;
  •   Identify and describe human population and
     environmental targets; and
  •   Present SI analytical results.

EPA and other agencies will refer to the narrative
report during future site evaluations. Following EPA
Regional guidelines, the report may be a letter report
or a  stand-alone document transmitted under separate
cover. Factual  statements in the  report should be
keyed by number to supporting references attached to
the  report. References not generally  available to the
public also should be attached. Information that rules
out specific factors (e.g., "No sensitive environments
were identified within 4 miles of the site") should be
included and documented.

The structure and content of each SI report should
follow the suggested format provided in the annotated
outline (Exhibit 6-1) or as recommended per Regional
guidelines. The body of the report begins with site
and source characterization and moves logically
through threats and targets associated with each
pathway. The  Summary and  Conclusion  section
summarizes the most important characteristics of the
site  and  identifies significant pathways and  targets.
Depending on  the complexity  of the site and the
amount of information presented, narrative text may
range from 10 to 12 'pages and up to 20 pages,
excluding attachments and references. All reports and
scoresheets should include a numbered reference list
and attached references.

The narrative report is a public information resource
that describes the steps taken to inspect the site and
provides information on the site based on EPA's
inspection. It should contain sufficient information and
documentation to support EPA's site  disposition
recommendation.  . For sites not warranting further
investigation, this means demonstrating that further
Superfund  activity  is  not necessary.  For  sites
warranting further investigation, this  means
demonstrating sufficient cause for additional response.
In either case, the SI report serves as the basis for
subsequent  planning.

The SI report should be restricted to factual statements.
SI scores and site recommendations, which  EPA
considers deliberative and protected from disclosure,
should not be included or referred to in the report.
The investigator  should check with EPA Regional
officials to ensure that the SI report is consistent with
current EPA policy on releasable information. The
summary and conclusion should summarize the major
findings  of the  field investigation and highlight
objective data supporting major conclusions. This
section  should discuss all  hazardous  substances
detected in sources at  the site  and in samples from the
migration pathways and the soil exposure pathway.

Avoid using HRS terminology in the narrative report.
While many HRS factors may be discussed, the
investigator should not refer  to them as "factors," or
cite the HRS. The narrative report is a record of the
investigation that lay persons and interested citizens
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                          EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT
  INTRODUCTION

   1 State that an SI was performed, the name of the agency performing it, and the authority under which it
      was conducted (e.g., CERCLA as amended by SARA, and EPA contract or cooperative agreement).

   . State the site name, CERCLIS identification number, and location (street address, city, county, State,
      latitude/longitude coordinates). If necessary, provide brief directions to the site.

   1 State the purpose, scope, and objectives of the SI.

  SITE  DESCRIPTION AND REGULATORY HISTORY

   •  Identify the type of site (e.g., plating facility, chemical plant, municipal landfill), whether it is active or
      inactive, and  years of operation. Describe its physical setting (e.g., topography, local land uses).
      Include the appropriate portion of a USGS 7.5-minute topographic map locating the site and showing a
      1-mile radius. On the map, identify the surface water drainage route; nearest well, drinking water
      intake, and residence; and wetlands and other sensitive environments. Include a drafted sketch showing
      site layout, source areas, and features on and around the site.

   •  Briefly summarize dates and scope of previous investigations.

   •  Describe prior land use  and past regulatory activities including the site's RCRA status, permits, permit
      violations, and inspections by local, State, or Federal authorities. Discuss any citizen complaints.

  OPERATIONAL  HISTORY AND WASTE CHARACTERISTICS

   •  Provide an operational history of the site. Identify current and former owners and operators, and
      describe  site activities. Identify and describe  wastes generated, waste disposal practices, waste source
      areas, waste source containment, and waste quantities.   Indicate source areas on the site sketch.

   •  Discuss any previous sampling at the site; provide dates of sampling events and sample types.
      Summarize analytical results in a table. Include a site map of all previous sample locations.

   •  Discuss  SI source sampling results. List in a table each waste source sample  and  summarize analytical
      results. Include a site map of all waste source and pathway sample locations.

   •  Identify hazardous substances associated with sources.

   •  Describe accessibility to source areas.

  GROUND WATER

   •  Describe the local geologic and hydrogeologic setting (e.g., stratigraphy, formations, aquifers, karst
      features, confining layers, depth and permeability to each aquifer).
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                    EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT (continued)
  GROUND WATER (continued)

   •  Discuss ground water use within a 4-mile radius of the sources. Identify the nearest private and
      municipal drinking water wells and state the distance from sources. Quantify drinking water
      populations served by wells within 4 miles, differentiating between private and municipal wells and
      specifying aquifers. Identify any municipal wells that are part of a blended system; state number of
      wells, locations, pumping rates,  and aquifer from which water is drawn. Identify wells in karst aquifers.

   •  Identify designated wellhead protection areas (WHPA) and specify location.

   •  Discuss any previous ground water sampling results; provide dates of sampling events and the depths
      and names of sampled aquifers.

   •  List in a table each well or spring sampled during the SI, provide the depth from which it draws
      drinking water and the screened interval, quantify the population associated with it, and identify its
      distance from  site sources. Discuss SI ground water sampling results. List in a table each sample and
      summarize analytical results. Include a site map of sample locations. Identify drinking water wells
      exposed to hazardous substances and quantify the drinking water populations served by each.

  SURFACE WATER

   •  Describe the local hydrologic setting, including  site location with  respect to floodplains, and the
      overland and in-water segments of the surface water migration path. State the distance from the site to
      the probable point of entry (PPE) into surface water. Identify the water bodies within the in-water
      segment, and state the length of reach and flow  or depth characteristics of each; describe tidal influence.
      Include a drafted sketch of the surface water migration path. Describe upgradient drainage areas, onsite
      drainage (including storm drains, ditches, culverts, etc.), facility discharges into surface water, permits,
      and historical information, including floods, fish kills, fishery closures, and other events.

   •  Indicate whether surface water within the target distance limit supplies drinking water. Identify the
      location and state the distance from the PPE to each drinking water intake. Quantify the drinking water
      population served by surface water and identify blended systems.

   •  Indicate whether surface water within the target distance limit contains fisheries. Identify and state the
      distance from the PPE to each fishery; briefly characterize each fishery.

   •  Indicate whether sensitive environments are present within or adjacent to the in-water segment. Identify
      and state the distance from the  PPE to each sensitive environment. Describe each sensitive environment
      and state the frontage length of wetlands on surface water.

   •  Discuss any previous surface water sampling results, dates, locations, and types of samples.

   •  Discuss SI surface water sampling results. List  in a table each sample and summarize analytical results.
      Identify surface water intakes exposed to hazardous substances and quantify the drinking water
      populations served by each. Identify fisheries exposed to hazardous substances and quantify the food
      chain population associated with each. Identify sensitive environments and wetlands exposed to
      hazardous substances; quantify the frontage of  exposed wetlands.
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                    EXHIBIT 6-1:  SI  NARRATIVE  REPORT FORMAT (continued)
  SOIL EXPOSURE

   •  State the number of workers on properties with site-related contamination.

   •  State the number of people who live on properties with site-related contamination and within 200 feet
      of an area of observed contamination. State the hazardous substance concentration and compare to
      health based benchmarks.

   •  Identify schools and day care facilities within 200 feet from an area of observed contamination on the
       school property and state the number of attendees.

   •   Identify terrestrial sensitive environments and resources in an area of observed contamination.

   •  State the number of people who live within 1 mile travel distance of the site.

   •  Discuss any previous  sampling results of sources of surficial materials, including dates and locations.

   •  Discuss SI surficial source samples. List each sample in a table and summarize analytical results.

  AIR

   •   Identify the location of, and state the distance to, the nearest individual. State the population within 4
       miles of the site, including students and workers. Identify sensitive  environments on sources and
      within 4 miles.

   •   Discuss any previous  air sampling results, including dates, locations, sampling procedures, and
       meteorological conditions.

   •  Discuss SI air sampling procedures and results. Identify sample locations on  a map. List in a table
       each sample and summarize analytical results.

  SUMMARY AND CONCLUSION

   •  Briefly summarize the major aspects of the site and its history that relate to the release or threatened
       release of hazardous substances and the exposure of targets. Briefly summarize principal pathways and
       targets of concern,

   •  Summarize sampling results, including substances detected in site sources and in environmental media.

  PHOTODOCUMENTATION LOG

   •   As an attachment, provide photographs of the site taken during the SI depicting pertinent site features
       such as waste source  areas, containment conditions, stained soil, stressed vegetation, drainage routes,
       and sample locations. Describe each photograph in captions or accompanying text. Key each photo to
       its location on the site sketch.
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                    EXHIBIT 6-1: SI NARRATIVE REPORT OUTLINE (concluded)
  APPENDICES

    •   Analytical results reports

    •   QA Report

    •   Other attachments

  REFERENCES

    •   List, in bibliographic citation format, all references cited in the SI report.

    •   Attach copies of references cited in the SI report. Include  complete copies of site-specific references
       (e.g., USGS topographic maps, records of communication, drinking water population apportionment and
       calculation worksheets, GEMS and other database printouts, waste handling records or shipping
       manifests). Include only the title page and pertinent excerpts of publicly available references (e.g.,
       geologic reports).
should be able to read and understand. The report
should not refer to HRS values or scores.

6.2 SCORE AND  DOCUMENTATION

Prior to documenting the SI score, the investigator
should complete a preliminary site score, review all
pathway scores, and verify key HRS factors or scoring
considerations. Personnel with HRS experience should
be  consulted  to check the  score.  All  relevant
additional information should be collected before
preparing a final SI score.

When developing the SI score, the investigator should
start with general site information, followed by source
characteristics,    and then   individual  pathway
information. Assumptions used in scoring should be
supported  by references, field observations,  and other
notes. These materials should be well-organized and
clear to reviewers  and EPA Regional and State
officials.

Several tools are available to score the site (see
Section 5.4.1), including SI worksheets (see Appendix
C) and PREscore. The SI worksheets contain brief
instructions and tables to record the results of SI
samples and other analytical data.  They provide HRS
tables and minimum tools to apply  collected data and
develop a rough (preliminary or site screening) SI
score.    Alternatively, PREscore-generated HRS
scoresheets may be submitted with the SI narrative
report to fulfill reporting requirements.

Analysis of a preliminary site score should focus on
factors that require data collection during the SI or
additional investigation. The investigator should judge
whether sampling is justified. The sample plan should
be designed to support the site score, with each sample
serving a specific purpose. For example

     The preliminary site score developed at the
     end of the focused SI was 20.00. The
     investigator noted that a municipal well
     approximately 600 feet away from the site
     was evaluated as Level II contamination
     although hazardous substance concentrations
     approached  benchmark  levels. The
     investigator proposed resampling the
     municipal well and two additional wells
     during the expanded SI, because if these
     wells were found to be contaminated above
     benchmark levels (i.e., Level I), the site
     score would increase to 50.00.

Additional evaluation  of  the  SI results may be
necessary if analytical  data are inadequate and the
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investigator is unable to fully meet the SI objectives
for scoring. If additional evaluation is warranted, the
SI investigator should consult with EPA Regional
officials before completing the site score or drafting
the SI narrative report. Further investigation, such as
collecting additional samples or performing special
field activities, may be necessary to  obtain better
information for scoring. If so, the scope of the follow
up investigation could be reduced to the essentials,
with the previous SI results used in planning these
activities.  Table  6-1 provides action options for
situations where additional evaluation may be needed.

6.3 REVIEWS

Review of the SI  report and scoresheets  involves
evaluation by three parties, each with particular
functions.

  •   The SI investigator should perform a detailed
     review  of  the  SI  report and scoresheets,
     particularly  for completeness  and  internal
     consistency.

  •   A reviewer with considerable  site  assessment
     experience should examine these materials to
     provide an independent evaluation of the SI
     results  and  should  determine  whether the
     available analytical data  are open to any
     alternative intepretations that would significantly
     affect site scoring.

  •   EPA Regional officials or State personnel should
     review the draft narrative report, SI scoresheets,
     and other materials to ensure that the results are
     reasonable and reflect site conditions. The final
     review  should verify  that the  SI meets  its
     objectives and that the appropriate hypotheses
     were tested.

After the three part review, the  SI reports and
materials can be finalized.

SI review ensures an appropriate site recommendation.
For sites receiving  SEA recommendations, the review
should confirm that the judgments and data reasonably
 support the conclusion that the site poses little threat
 or that EPA will address the site under other statutes.
 For sites receiving further action recommendations, the
 review ensures that the SI results reasonably support
 the need for further investigation.

 Some sites may require a more detailed review of the
 site score and analytical  results to ensure that a
 recommended follow up investigation is warranted.
 Furthermore, the review will evaluate the need for
 subsequent investigation, such as installing monitoring
 wells, collecting additional soil samples,  and collecting
 more  non-sampling information.

 After the review of a focused SI, EPA makes one of
 three recommendations:

  •   SEA,
  •   Further action (e.g., expanded SI) recommended
      or
  •   Priority for preparation of HRS package.

 Screening recommendations  are usually made by
 comparing the focused SI  score to 28.50. In certain
 cases, some form of further action other than the
 expanded SI may be appropriate-for example, a site
 where a  domestic well is  contaminated but lacks
 sufficient users to result in a site score greater than the
 cutoff score. In such a case, it may be  prudent to
 recommend that the local health department, or other
 authority, be appraised of  the situation. At any site,
 emergency response action may be recommended
 regardless of site score.

 After the review of the expanded SI, EPA Regional
 management will determine the priority for preparation
 of an HRS package. If the site is being considered for
 the NPL, EPA will establish a schedule to prepare the
 HRS  package,   which  consists of  the HRS
 documentation record, reference materials, and site
 narrative summary along with other administrative
 requirements (see Regional Quality Control Guidance
for NPL Candidate Sites,  OSWER Directive 9345.1-08,
 1991). Preparation of the HRS package is outside the
 scope of SI activities.
                                                   114

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Site Inspection Guidance
                                                     SI  Reporting
                      TABLE 6-1: Additional Evaluation  OF SI RESULTS
            CONDITION
                      POSSIBLE ACTIONS
  Analytical data do not meet
  appropriate DUCs for screening
Consider using data to refine or reformulate site hypotheses

Consider scoring the site based on potential to release to migration
pathways

Use PREscore  to determine factors that will significantly affect site
score after evaluating substance-specific waste characteristics (e.g.,
toxicity, mobility, persistence)

Use SI worksheets or other scoring tools to estimate site score based
on reasonable  projections to screen the site

Consider another investigation similar in scope to the previous SI
  Analytical data do not meet
  appropriate DUCs for listing
Consider using data to screen the site from further action

Consider using data to refine or reformulate site hypotheses

Consider collecting additional non-sampling information

Use PREscore  to determine factors that will significantly affect
pathway or site score after evaluating substance-specific waste
characteristics (e.g., toxicity, mobility, persistence)

Consider resampling at site
  Some analytical data do not fully
  support site score for screening or
  listing
Consider if the data significantly affect the pathway or site score

Consider scoring the pathways based on potential to release,
particularly ground water or surface water pathways
  Hazardous substances used to score
  observed releases or targets
  exposed to actual contamination
  are not conclusively attributable to
  the site
Review operational histories of nearby sites

Consider expanding the site description to include other sources, if
possible

Evaluate whether these hazardous substances are naturally-occurring
or ubiquitous or are significantly higher than regional or local levels
  Analytical data support Level II
  contamination for some targets but
  Level I contamination is needed to
  achieve a site score > 28.50
Review the hazardous substances detected at the Level II target;
determine if media-specific benchmarks are available for those
substances

If benchmarks are available, consider resampling at a few, non-
random locations
                                                   115

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SI Reporting
                                     Site Inspection Guidance
              TABLE 6-1: Additional Evaluation OF SI RESULTS (concluded)
           CONDITION
                    POSSIBLE  ACTIONS
  Analytical data support Level I
  contamination for some targets but
  not enough targets for a site score
  228.50
Examine concentrations of hazardous substances detected at Level I
targets; review whether such concentrations are likely at other targets
not sampled

If such concentrations are likely, consider sampling at additional
locations
  Score is just below 28.50 based on
  significant pathways
Consider evaluating all four pathways based on non-sampling
information

Consider collecting additional samples
                                               116

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Site Inspection Guidance
                                     Glossary
                                           GLOSSARY
Actual contamination:  A target exposed to hazardous
substances based on analytical data or through direct
observation.

Apportioned  population:    In the evaluation of
drinking water target populations associated with a
blended system, the portion of the population evaluated
as being served by an individual well or intake within
the system.

Aquifer:   Reek or sediment that is saturated and
sufficiently permeable to transmit economic quantities
of water to wells and springs, Not all ground water
is in an  aquifer.

Background:  The natural ambient concentration of
a hazardous substance.    Includes  both  naturally
occurring concentrations and concentrations from
human-made  sources other than  the site being
evaluated.

Blended system:  A drinking water supply system that
can  or  does combine  (e.g., via connecting valves)
water from more than one well or surface water intake,
or from a combination of wells and intakes.

Computer-Aided Data Review and Evaluation
(CADRE):  A PC based software program designed
to aid the analytical data review for CLP RAS data
according to  the  QC  criteria defined  in  EPA's
Laboratory Data  Validation Functional Guidelines for
Evaluating Organic Analyses.

CERCLA Information  System (CERCLIS):  EPA's
computerized inventory and tracking  system for
potential hazardous waste sites.

CLP Analytical Results Database  (CARD):    A
national database designed to store and integrate CLP
results and QA/QC data. CARD consists of Superfund
chemical analysis and  analytical information on
hazardous waste sites. Analytical data entered into
CARD can be downloaded into electronic software
applications, such as CADRE.
Coastal tidal waters:  Surface water body type that
includes embayments, harbors, sounds, estuaries, and
back bays.  Such water bodies are in the interval
seaward from the mouths of rivers and landward from
the 12-mile baseline marking the transition to the
ocean water body type.

Comprehensive    Environmental  Response,
Compensation,  and  Liability  Act  of 1980
(CERCLA):  Legislation that established the Federal
Superfund for response to uncontrolled releases of
hazardous substances to the environment.

Contaminated soil:     Soil onto  which  available
evidence indicates that a hazardous substance was
Spilled, spread, disposed, or deposited,

Contract Laboratory Program (CLP):   A nation-
wide  network of commercial laboratories under
contract to EPA that provides analytical data of known
and documented quality for Superfund enforcement
actions. The CLP consists of routine and non-routine
standardized analytical procedures and associated
quality control requirements managed under a broad
quality assurance program, which includes sample
projections,  sample scheduling,  chain-of-custody
requirements,    reporting   and  documentation
requirements, audits, and data  evaluations.

Data Quality Objectives  (DQOs):  The full set of
qualitative and quantitative constraints needed to
specify the level of uncertainty that a manager can
accept when making a decision based on data. The
DQO process is a planning tool that enables the site
manager to specify the quality  of the data (analytical
methods  and services to be used) required to support
the objectives of the site investigation,

Data Use Categories (DUCs):     A level of data
quality defined by a  specific combination of method,
QA/QC, documentation, and review requirements.

Depth to aquifer: The vertical distance between the
lowest known point of hazardous substances to the top
of the aquifer being  evaluated.
                                                 117

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Glossary
                     Site Inspection Guidance
Distance to surface water:   The shortest distance that
overland runoff would follow from a source to surface
water.

Drinking water population:  The number of residents,
workers, and students who  drink water drawn from
wells or surface water intakes located within target
distance limits.

Drums:  Portable containers designed to hold a
standard 55-gallon volume of wastes.

Emergency  response: An  action taken to eliminate,
control, or otherwise mitigate a threat posed to the
public health or environment  due to release  or
threatened release of a hazardous substance. Removals
are  relatively short-term  actions  to respond  to
situations requiring immediate action.

Factor: The basic element of the HRS requiring data
collection and evaluation to assign a score.

Factor category: A set of related I-IRS factors. Each
HRS pathway consists of three factor categories—
likelihood of release or exposure, targets, and waste
characteristics.

Field Analytical Support Project (FASP):   Field
sampling techniques designed to provide  sample
screening information during the field activities and
provide real-time analytical data. Sample analysis is
performed from afield base, mobile laboratory, or with
portable instruments.

Federal Register (FR):    Daily publication of the
Government Printing Office; contains public notices,
rules, and  regulations issued by the  Federal
Government, Cited as " FR ."

Fishery:  An area of a surface  water body from which
food chain organisms are taken or could be taken  for
human consumption on a subsistence, recreational, or
commercial basis. Food chain organisms include fish,
shellfish, crustaceans, amphibians, and  amphibious
reptiles.

Geographical  Exposure Modeling System  (GEMS):
Population database maintained by EPA's Office of
Toxic Substances that provides residential populations
in specified distance categories around a point location.
Hazard Ranking System (HRS):   Scoring system
used by EPA to assess the relative threat associated
with  actual  or potential releases  of hazardous
substances at sites. The I-IRS is the primary way of
determining whether a site is to be included on the
NPL.

Hazardous constituent:  Hazardous  substance.

Hazardous substance:     Material defined  as  a
hazardous substance, pollutant, or contaminant in
CERCLA Sections 101(14) and 101(33).

Hazardous waste:    Any  material containing  a
hazardous substance, pollutant, or contaminant that is
or was in a source.

Investigation-derived wastes (IDW):      Wastes
generated during the process of collecting samples
during CERCLA investigations that must be handled
according to all applicable or relevant and appropriate
requirements, These wastes include soil, ground water,
used personal protective equipment,  decontamination
fluids, and disposable sampling equipment.

Karst: A kind of terrain with characteristics of relief
and drainage arising from a high degree of rock
volubility. The majority of karst conditions occur in
limestone areas, but karst may also occur in areas of
dolomite, gypsum, or salt deposits. Features associated
with karst terrain may include irregular topography,
abrupt ridges, sinkholes, caverns, abundant springs,
disappearing streams, and the lack of a well-developed
surface drainage system of tributaries and streams.

Lake: A type of surface water body that includes:

     •  Natural and artificially-made lakes or ponds
        that lie along rivers or streams (but excluding
        the Great Lakes).
     •  Isolated  but perennial lakes,  ponds, and
        wetlands.
     •   Static water  channels  or  oxbow   lakes
         contiguous to streams or rivers.
     •   Streams or small rivers, without diking, that
         merge into surrounding perennially-inundated
         wetlands.
     •   Wetlands contiguous to water bodies defined
         as lakes are considered to be part of the lake.
                                                   118

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Site Inspection Guidance
                                      Glossary
Landfill:  An  engineered  (by excavation or
construction) or natural hole in the ground into which
wastes  have  been  disposed  by backfilling or
contemporaneous soil deposition with waste disposal.

Land treatment:  Landfarming or other land treatment
method of waste management in which liquid wastes
or sludges are spread over land and tilled, or liquids
are injected at shallow depths into soils.

National Contingency Plan (NCP):  National Oil and
Hazardous Substances  Pollution Contingency Plan,
commonly known as the National Contingency Plan.
Regulation that establishes roles, responsibilities, and
authorities for  responding to hazardous substance
releases.    The NCP established the HRS as the
principal mechanism for placing sites on the NPL.

National Priorities List  (NPL):  Under the Superfund
program, the list of sites with releases and potential
releases of hazardous  substances, pollutants, and
contaminants that appear to pose the greatest threat to
public health, welfare, and the environment.

No Further Remedial Action Planned (NFRAP):
Site disposition decision that no further response under
the Federal Superfund program is necessary. Replaced
by   "Site Evaluation Accomplished"  (SEA)
recommendation.

Non-CLP Analytical Services:   Analytical activities
procured outside of the Contract Laboratory Program
(CLP). Non-CLP data are data that are generated
using non-CLP analytical  services  and  are not
produced under the CLP's quality assurance program.
Non-CLP data can be generated by laboratories that
participate in the CLP, by CLP Statement  of Work
analytical methods, and may even be presented to the
user in CLP deliverable format. However, if the
analytical services were not obtained through the
CLP/Regional Sample Control Center (RSCC) route,
they are considered to be non-CLP analytical services.

No suspected release:  A professional judgment PA
conclusion based on site and pathway conditions that
a hazardous substance is not likely to have been
released to the environment.  (No suspected release is
the PA terminology analogous to  the HRS potential to
release.)
Observed  contamination:     The evaluation of a
release of a hazardous substance to the ground surface
based on  analytical  data appropriate for the soil
exposure pathway.

Observed release:  The evaluation of a release of a
hazardous substance to the environment based on
analytical data of the migration pathway or direct
observation of the release into the migration pathway
media.

Ocean: A type  of surface water body that includes:

     •   Ocean areas seaward from a baseline distance
        of 12 miles from shore.
     •   The  Great   Lakes,  including  wetlands
        contiguous to them.

PA-Score: EPA's computer program that automates
scoring sites  during the PA.

Pathway: The environmental medium through which
a hazardous substance may threaten targets. The HRS
evaluates the  migration and threat potential through the
ground water, surface water, air, and soil exposure
pathways.

Pile: Any non-containerized accumulation above the
ground surface of solid, non-flowing wastes; includes
open dumps. Some types of piles are:

     Chemical  Waste Pile—   consists primarily of
     discarded chemical products,  by-products,
     radioactive wastes, or used or  unused feedstocks

     Scrap Metal or Junk Pile—  consists primarily
     of scrap metal or discarded durable goods, such
     as appliances,  automobiles, auto parts, or
     batteries, composed of materials that contain or
     have contained a hazardous substance

     Tailings  Pile—  consists primarily of any
     combination  of overburden from a mining
     operation and tailings from a mineral mining,
     beneficiation, or processing operation

     Trash Pile— consists  primarily of paper, garbage,
     or discarded non-durable goods that contain or
     have contained a hazardous substance
                                                  119

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Glossary
                     Site Inspection Guidance
Potential contamination:   A target located within the
target distance limit that is subject to a potential
release of hazardous substances from the site or for
which no actual contamination has been established.

Preliminary Assessment (PA):  Initial stage of site
assessment under Superfund; designed to distinguish
between sites that pose little or no threat to human
health and the environment and sites that require
further investigation.

PREscore:  EPA's computer  program that automates
scoring sites according to the HRS.

Primary target:  A target, based on professional
judgment  of site and pathway  conditions and target
characteristics known at the  PA, that has a relatively
high likelihood of exposure to a hazardous substance.
(Primary target is the PA terminology analogous to an
HRS target exposed to actual contamination.)

Probable Point of Entry (PPE):   The point at which
overland runoff from the site most likely enters surface
water.

Quality Assurance/Quality Control (QA/QC):
Planned, systematic procedures  or methods to provide
a high degree of  confidence in the quality of work
products or laboratory results.

Removal: An action taken to  eliminate, control, or
otherwise mitigate a threat posed to the public health
or environment due to release or threatened release of
a hazardous substance. Removals  are relatively short-
term actions  to  respond to  situations  requiring
immediate action.

Resident:  A person whose place of residence (full-
or part-time) is within the target distance limit.

Resident  individual:     Under  the soil exposure
pathway, a person living or  attending school or day
care on a property with observed contamination and
within 200 feet of an area of observed contamination
associated with the site.

Resident  population:    Under  the soil exposure
pathway, the number of residents and students on a
property with observed contamination and within 200
feet of an area of observed contamination associated
with the site.
Resource Conservation and Recovery Act of 1976
(RCRA): Legislation that established cradle-to-grave
accountability for hazardous wastes, from point of
generation to point of ultimate disposal.

Routine Analytical Services (RAS):   Standardized
CLP laboratory services that provide analyses of
organic and inorganic  compounds in water or solid
samples.

Secondary target:  A  target, based on professional
judgement of site and pathway conditions and target
characteristics known at the PA, that has a  relatively
low likelihood of exposure to a hazardous substance.
(Secondary target is the PA terminology analogous to
an HRS target exposed to potential contamination.)

Sensitive  environment:    A terrestrial or aquatic
resource, fragile natural setting, or other area with
unique or highly-valued environmental or cultural
features.

Site:    The area consisting of the aggregation of
sources, the areas between sources, and areas that may
have been contaminated due to migration from sources;
site boundaries are independent of property boundaries.

Site  Evaluation Accomplished (SEA):   Site disposition
decision that no further response under the Federal
Superfund program  is  necessary.     A  SEA
recommendation denotes that EPA has completed its
assessment at a site and has determined that no further
steps to list the site on the NPL need to  be taken
unless information indicating that this decision was not
appropriate  make a  recommendation for listing
appropriate at a later time. The SEA recommendation
replaced the "No Further Remedial Action  Planned"
(NFRAP)  recommendation  (see  Henry   Longest
Memorandum, May 11,1992).

Site Inspection (SI):     The second stage of site
assessment under Superfund. Sis are performed at
sites that receive a further action recommendation after
the PA, and build on PA information. Sis typically
include sampling to identify hazardous substances,
releases, and targets exposed to actual contamination
and help characterize sites that pose the greatest threats
to human health and the environment.
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Site Inspection Guidance
                                       Glossary
Source: An area where a hazardous substance may
have been deposited, stored, disposed, or placed. Also,
soil that may have become contaminated as a result of
hazardous substance migration. In general, however,
the volumes of air, ground water, surface water, and
surface water  sediments that may have  become
contaminated through migration are not considered
sources.

Special Analytical Services (SAS):   Nonstandardized
laboratory services  that provide analyses for organics,
inorganic, dioxin, and other compounds in a variety
of matrices. SAS analyses need to be scheduled on
an as-needed basis.

Standard Operating Procedures (SOPs):   Established
Regional, State or contractor procedures approved by
EPA to address non-site specific investigation  activities
and issues. These  procedures cover topics such as
sampling protocols, chain-of-custody requirements, and
quality assurance sampling requirements.

Stream flow:  The average rate of flow of a water
body, expressed in cubic feet per second (cfs).

Stream or river: A type of surface water body that
includes:

     •  Perennially-flowing waters from  point of
        origin to the ocean or to coastal tidal waters,
        whichever  comes first,  and wetlands
        contiguous to these flowing waters.
     •  Abovegroundportions of disappearing  rivers.
     •  Artificially-made ditches, only insofar as they
        perennially flow into other surface water.
     •  Intermittently-flowing waters and contiguous
        intermittently-flowing ditches in areas where
        mean annual  precipitation is less  than 20
        inches.

Student:     A full- or part-time  attendee  of an
educational institution or day care facility located
within the target distance limit.

Superftind Accelerated Cleanup Model (SACM):
A process for streamlining Superfund cleanups. The
site assessment activities  under SACM integrate
elements  of removal assessments,  site assessments
(PA/SI),  remedial investigations  (RI), and  risk
assessments; these are conducted concurrently where
appropriate or advisable.
Superfund Amendments and Reauthorization Act
of 1986 (SARA):  Legislation which extended the
Federal Superfund program and mandated revisions to
the HRS.

Superfund Chemical Data Matrix (SCDM):  EPA's
database of hazardous substances and their chemical
characteristics (such as toxicity, mobility, persistence)
and media-specific benchmark concentrations.

Surface impoundment:   A topographic depression,
excavation,  or diked area, primarily formed from
earthen materials (lined or unlined) and designed to
hold accumulated liquid wastes, wastes containing free
liquids, or  sludges that were  not backfilled or
otherwise covered during periods of deposition. A
depression  may be dry if  deposited liquid  has
evaporated, volatilized, or leached or wet with exposed
liquid. Structures that may be more specifically
described as lagoon pond, aeration pit, settling pond,
tailings pond, sludge pit, etc.    Also  a surface
impoundment that has been covered with soil after the
final deposition of waste materials (i.e., buried or
backfilled).

Surface water: A naturally-occurring, perennial water
body; also, some artificially made and intermittently
flowing water bodies.

Suspected release:   A professional judgement PA
conclusion based on site and pathway conditions that
a hazardous substance is likely to have been released
to the environment. Suspected release  is the PA
terminology analogous to an HRS observed release.

Tanks and non-drum containers:  Any stationary
device designed to contain accumulated wastes and
constructed primarily of fabricated materials (such as
wood, concrete, steel, or plastic) that provide structural
support; any portable or mobile device in which waste
is stored or otherwise handled.

Target: A receptor that is within the target distance
limit for a particular pathway. Targets include wells
and surface water intakes supplying drinking water,
populations,  human food chain organisms, sensitive
environments, wellhead protection areas, and resources.

Target Analyte List (TAL):   The list of inorganic
analytes that is specified in the CLP  Statement of
Work  for inorganic analysis.
                                                   121

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Glossary
                     Site Inspection Guidance
Target Compound List (TCL):   The list of organic
compounds that is specified in the CLP Statement of
Work for organics analysis.

Target distance limit:  The distance over which the
HRS evaluates targets. Target distance limits vary by
pathway: ground water and air pathways—a 4-mile
radius around site sources; surface water pathway—15
miles downstream from the probable point of entry to
surface water; soil exposure pathway—200 feet (for
the resident population threat)  and 1 mile (for the
nearby population threat) from areas of observed
contamination.

Terrestrial sensitive environment:   A terrestrial
resource, fragile natural setting, or other area with
unique or highly valued environmental or cultural
features.
Water body type:  Classification of a surface water
body. Water body types include: streams and rivers;
lakes; oceans (includes the Great Lakes); and coastal
tidal waters. See the specific definition of each water
body type for more detail.

Wetland:   A type  of  sensitive  environment
characterized as an area that is sufficiently inundated
or saturated by surface or ground water to support
vegetation adapted for life in saturated soil conditions.
Wetlands generally include swamps, marshes, bogs,
and similar areas.

Worker: In the soil exposure pathway, a person who
is employed on a full- or part-time basis and whose
workplace  is   within  200  feet  of observed
contamination. In the migration pathways, a person
whose place of employment is within the target
distance limit.
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Site Inspection Guidance                                                              References


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Site Inspection Guidance                                                              References
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Waste and Emergency Response. Directive 9230.0-03C.

U.S. Environmental Protection Agency, 1992. Superfund Accelerated Cleanup  Model (SACM). Don R. Clay
Memorandum, April 7,1992. Office of Solid Waste and Emergency Response. Directive 9203.1-01.

U.S. Environmental Protection Agency, 1992. Guidance on  Implementation of the Superfund Accelerated Cleanup
Model (SACM) Under CERCLA and the NCP. Don R. Clay and Lisa Friedman Memorandum, July 7,1992, Office
of Solid Waste and Emergency Response and Office of General Counsel. Directive 9203.1-03.

U.S. Environmental Protection Agency, 1992. Estimating the Potential for Occurrence of DNAPL at Superfund Sites,
Office of Solid Waste and Emergency Response. Directive 9355.4-07FS.

U.S. Environmental Protection Agency, 1992. "Site Evaluation Accomplished" Memorandum from Henry Longest,
Director, Office of Emergency and Remedial Response. May 11,1992.

U.S. Environmental Protection Agency. Guidance for Data Usability  in Site Assessment. Office of Solid Waste
and Emergency Response. Directive 9345.1-05, in development,

U.S. Environmental Protection Agency. Hazard Ranking System (HRS) Guidance  Manual. Office of Solid Waste
and Emergency Response. Directive 9345.1-07, in development.

U.S. Nuclear Regulatory Commission, 1979. Quality Assurance for Radiological Monitoring Programs (Normal
Operations)-Effluent Streams and the Environment. Regulatory Guide No. 4.15, Revision 1.

U.S. Nuclear Regulatory Commission, 1983. Radiological Assessment A Textbook on Environmental Dose Analysis.
Office of Nuclear Reactor Regulation. Publication NUREG/CR-3332.
                                                125

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References                                                               Site Inspection Guidance


                              SUPPLEMENTAL  REFERENCES

American Society for Testing and Materials, 1983. Thin-Walled Tube Sampling of Soils. Annual Book of ASTM
Standards.

American Society for Testing and Materials, 1984. Penetration Test and Split-Barrel Sampling of Soils. Annual  Book
of ASTM Standards.

Keith, L.H., cd., 1988. Principles of Environmental Sampling,  American Chemical Society, Washington, D.C.

National Council on Radiation Protection and Measurements, 1987. Exposure of the Population in the United States
and Canada from Natural Background Radiation. NCRP Report No. 94.

U.S. Environmental Protection Agency, 1983. Characterization of Hazardous Waste Sites - A Methods Manual:
Volume II - Available Sampling Methods. Office of Research and Development.

U.S. Environmental protection Agency, 1987. Section 404(b)(l) Guidelines for Specification of Disposal Sites for
Dredged or Fill Material Definitions. 40 CFR 230.3(t).

U.S. Environmental Protection Agency, 1987. Hazardous Waste Management System: Definitions. 40 CFR 260.10.

U.S. Environmental Protection Agency, 1987. Identification and  Listing of Hazardous Waste; Definition of Hazardous
Waste. 40 CFR 261.3.

U.S. Environmental Protection Agency, 1987. Data Quality Objectives for Remedial Response Activities: Volume
1- Development Process. Office of Solid Waste and Emergency Response. Directive 9355.0-7B.
                                                 126

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                                   APPENDIX A
                          SI SAMPLE PLAN (EXAMPLE)

  This appendix provides an example of a sample plan for an SI at a fictitious site, following the form
  and content discussed in  Section 3.6.2. Note that this  guidance example does not  include
  complete references, such as applicable SOPS and  SOGs,  an equipment  list, or a site specific
  health and safety plan and IDW plan.
                          SITE INSPECTION SAMPLE PLAN
                               PALMETTO LANDFILL

                       PALMETTO COUNTY, SOUTH CAROLINA
                             EPA ID NO. SCD123456789

                        Prepared Under TDD No. Y9-87912-43
                              Contract No. 99-99-9999
                                  APRIL 9, 1992
                                  XYZ Corporation
Prepared By                 Reviewed By                      Approved By
Joseph Brown               Lucy Pauling                       Maria Gomez
Project Manager             Project  Coordinator                 Regional Project Manager
                                       A-1

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Appendix A: SI Sample Plan (Example)                               Site Inspection Guidance
                                         CONTENTS
   1.  INTRODUCTION	3

   2.  SITE DESCRIPTION	3
          2.1 Location	3
          2.2 SiteDescription/History	3
          2.3 Operational  History and Waste Characteristics	3

   3.  COLLECTION OF NON-SAMPLING DATA	4

   4.  SAMPLING ACTIVITIES	   4
          4.1  Source Sampling	   4
          4.2  Ground Water Sampling	   4
          4.3  Surface Water Sampling	   4
          4.4  Soil Sampling	   4
          4.5  Quality Assurance	   5
          4.6  Field Activities	   5
          4.7  Quality Control Procedures  	   6

   5.  INVESTIGATION-DERIVED WASTES PLAN	6

   6.  PROJECT MANAGEMENT	6
          6.1 Field Equipment/Health and Safety	6
          6.2 Community  Relations	7
          6.3 Project  Schedule	7

       REFERENCES	   7
   Table 1 -  Proposed  Samples
   Table 2 - Cost Summary

   Figure 1 -  Sample Locations:  Source, Surface Water Sediment, and Soil
   Figure 2 - Sample Locations:  Ground Water
   ATTACHMENT A - Health and Safety Plan [omitted]
   ATTACHMENT B - Equipment List [omitted]
   Attachment C -  Applicable Standard Operating Guidelines  [omitted]
   ATTACHMENT D - Drinking Water Well Survey [omitted]
                                             A-2

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Site Inspection Guidance                                  Appendix A: SI Sample Plan  (Example)
   1. INTRODUCTION

   Under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
   (CERCLA) and the Superfund  Amendments and  Reauthorization Act of 1986 (SARA), the U.S.
   Environmental protection Agency (EPA), Waste Management Division, Region 4 will conduct a focused site
   inspection (SI) at the Palmetto Landfill in Palmetto County, South Carolina. The focused SI will investigate
   the threat  to human health and  the environment posed by the site (Reference 1). The scope of the
   investigation will include collecting source samples to determine types and concentrations of hazardous
   substances onsite and collecting media samples to investigate migration of hazardous substances from the site.

   2. SITE  DESCRIPTION

   2.1 Location

   Palmetto Landfill is located at 6250 Palmetto Drive in rural Palmetto County, South Carolina, 1.5 miles east
   of Angleton (Figure 3). The geographic coordinates are 18528'43" N latitude and 6607' 33" W longitude [sic]
   (Reference  2). To reach  the site, travel east from Angleton approximately 0.25 mile from the intersection of
   Rt. 149 and Palmetto Drive.

   The climate of Palmetto County is characteristically temperate; summers are warm and humid with daily
   temperatures reaching90° F or higher, and winters are generally mild with daily average temperature55° to
   60° F. Mean annual rainfall is 46 inches, while net precipitation is 10.87 inches (Reference 3, pp. 7,10).

   2.2 Site  Description/History

   The landfill property covers approximately 10 acres, approximately 6 acres of which were used for disposal
   of wastes (Reference 4). The property is located on flat terrain that slopes  toward the northeast boundary
   (Reference  5) and Wildlife Creek, a small, slowly flowing stream (Reference 6, p. 124). The landfill property
   is rectangular and bordered on three sides by a ditch constructed to intercept ground water upgradient of the
   site and divert it around  the buried wastes (Reference 4). Since the ditch is 8 to 10 feet deep, it does not
   fulfill this function entirely as it does not completely transect the aquifer. However, it does create a barrier
   to runoff from areas upgradient of the site. Vegetation is  stressed along the banks of the ditch (Reference
   5). Water in the ditch is an orange-brown color and is oily in appearance (Reference 5; Reference 7, p. 4).
   No buildings or other structures are on the property. The property is surrounded by an electric chain link
   fence in good condition, and there is a locked entrance gate across the access road to the facility (Reference
   5; Reference 7, p. 3).

   2.3 Operational History  and Waste Characteristics

   Smith and Moore Disposal Services, 1111 Main Street, Angleton, South Carolina, owns Palmetto Landfill.
   The landfill opened in April 1970  for disposal of municipal garbage and household debris. Wastes were
   deposited in ditches 7 to 10 feet deep and covered with soil at the end of each day, Beginning in October
   1978, the landfill accepted industrial wastes on a limited basis. Smith and Moore kept no formal records of
   the amounts and types of wastes  received. The landfill did  receive a one-time shipment of approximately 500
   gallons of trichloroethene  (TCE) waste (Reference 4). Landfilling operations were discontinued in July 1980
   when the landfill reached capacity. A 2-foot soil cover was placed over the entire landfill (Reference 4).

   Palmetto  Landfill operated under permit  number 999-999 issued by the South Carolina Department of Health
   and Environmental Concerns  [sic] (SCDHEC). SCDHEC personnel inspected the landfill to verify the closure

                                                  -3-
                                                 A-3

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Appendix A: SI Sample Plan (Example)                                   Site inspection Guidance
   met the permit requirements. SCDHEC personnel have inspected the landfill several times at irregular
   intervals. To date, there has been no sampling or response action at Palmetto Landfill (Reference 8).

   3. COLLECTION OF NON-SAMPLING DATA

   Non-sampling data collection activities will include verifying population and environmental information as
   well as new information. The integrity of the landfill cover and location of wetlands will be verified by
   visual inspection. The SI will investigate if either of two Federal endangered species, the Bald Eagle and the
   Salt Marsh Harvest Mouse, which have critical habitats in Palmetto County, lives onsite. A drive-by survey
   will be performed to confirm the locations of private wells in the area and a well system questionnaire will
   be distributed to persons using private wells. Additional data will be gathered as necessary from the office.

   4.  SAMPLING  Activities

   The objectives of the  SI are to collect analytical data to identify hazardous substances at the site and
   investigate whether hazardous substances have been released to  the environment and whether the substances
   have impacted human  health and the environment. The plan (Figure 1) calls for waste source, surface water
   sediment, ground water, and soil samples.  The  SE Regional Contract Laboratory in Tallahassee will perform
   full TCL analysis of all samples.

   4.1 Source Sampling

   Sources will be sampled where breaches in the landfill cap and  a leachate seep were identified during the PA.
   These locations were chosen to  identify hazardous substances at  the site. Waste samples will  include black
   sludge-like material from a small depression in the landfill cap  near the center of the site, a sample from an
   area of stressed vegetation northeast of the depression, and a leachate sample from the perimeter ditch east
   of the landfill. A duplicate leachate sample will be collected from the perimeter ditch.

   4.2 Ground Water Sampling

   Ground water samples  will be taken from  the six residential wells  hypothesized as primary targets  during the
   PA. These samples will test whether hazardous substances have been released to the ground water and
   whether the release has impacted drinking water wells.

   4.3 Surface Water Sampling

   Surface water samples will be taken to determine whether a release to surface water has occurred and whether
   the release has impacted the fishery in Wildlife Creek, wetlands along its banks, and habitats of endangered
   species associated with the creek. During the PA, the fishery, wetlands, and sensitive environments were
   evaluated as primary targets. One sediment sample will be taken  at each drainage point of entry to Wildlife
   Creek (fishery), at the  section of wetland closest to the site, and at an area in the wetland approximately 500
   feet downstream from the first sample. Depending on location of endangered species habitats, it may be
   necessary to alter this  plan. Two background sediment samples will be collected upstream of the probable
   points of entry to Wildlife Creek north of the site.

   4.4 Soil Sampling

   A soil sample will be collected offsite, 1500 feet from the landfill. A soil sample will be  taken on the
   property of the nearest residence to investigate if it is affected by the site.

                                                  -4-
                                                 A-4

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Site Inspection Guidance                                  Appendix A: SI Sample Plan (Example)
   4.5 Quality Assurance

   Quality assurance and quality control (QA/QC) for this sampling event will be provided by a combination
   of field blanks and duplicates. One aqueous field blank will be taken during ground water sampling to test
   for contamination possibly introduced by sample containers and preservatives. One duplicate sample each
   will be taken from the nearest well, the downstream entry to Wildlife Creek (fishery), and the leachate.
   Duplicate samples will test the reliability of sampling procedures and results.

   All sample collection, preservation, QA/QC preparation of field blanks and duplicates, and chain-of-custody
   procedures used during sampling activities will be in accordance with the standard operating guidelines
   (SOGs) specified in the Engineering and Support Branch Standard Operating Procedures and Quality
   Assurance Manual, U.S. Environmental Protection Agency, Environmental Services Division,  Region IV,
   Atlanta, Georgia, April 1986.

   4.6 Field Activities

   Field personnel are scheduled to travel to the site on September 3,1991.  EPA Region 4 has requested access
   to the facility September 4. Residents with private wells to be sampled have been requested to provide access
   to sampling personnel on September 4. All environmental  samples and non-sampling information will be
   collected in one day. Field personnel are scheduled to leave the site the morning of September 5.

   Field work will begin with a site reconnaissance in the morning to verify that planned sample locations are
   appropriate and  accessible. During the reconnaissance, ambient air will be monitored with OVA and HNu
   meters, Radiation screening will be conducted during the site reconnaissance with a Victoreen Radiation
   Detector and Mini-Alert according to EPA SOG No. 18,  Revision O. A drive-by survey will verify the
   location of wetlands, the closest resident, private well users, and the population within approximately 0.25
   mile of the site. If necessary, original plans will be modified. Upon collection, all samples will be prepared
   and packaged for shipping.

   Two 2-person teams will be deployed. Sampling will start after the original sample plan and any necessary
   modifications are confirmed. Proposed sample locations are shown in Figures 2  and 3.

   The ground water sampling team will visit each residence to  obtain  an unfiltered sample (none of the
   residences have filter treatment) from the spigot nearest the well. Each resident will be asked to complete
   a well system questionnaire regarding well depth, persons  per household, etc. (Attachment D). This team
   also will collect a soil sample from the residential property 300 feet from the site. Since this residence is also
   the location of a private well, both soil and ground water will be sampled during the same visit. Soil
   samples will be collected 6 to 12 inches below ground surface according to EPA SOG No. 10, Revision O,
   and placed in an  unpreserved 4-ounce container.

   The second sampling team will collect surface water sediment samples according to EPA SOG No, lOa,
   Revision 0, starting with the most downstream sample and proceeding upstream. Sediment samples will be
   collected with a disposable scoop from an area of slow flow; a portion of the collected material will be placed
   into a sterile container.

   After completing the surface water sampling, the second team will collect waste source samples in the
   following order:  1) an aqueous sample from the east perimeter ditch, 2) a sediment sample of the sludge-like
   material in the landfill cap depression, and 3) a soil sample from the area of stressed vegetation.

                                                  -5-
                                                 A-5

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Appendix A: SI Sample Plan (Example)                                  Site inspection Guidance
   The surface water sample will be collected by submerging a sterile container below the surface of the water,
   according to EPA SOG No. 9, Revision 0.   Surface water samples to be analyzed for organics will be
   collected in 44-ml septumed vials and preserved with 100 microliters of 7,000 ppm mercuric chloride solution
   to a final concentration of 16 ppm. The surface water sample for inorganic analysis will be collected in a
   4-ounce polyethylene container, filtered, and preserved with nitric acid to a pH of less than 2.0.

   4.7 Quality Control Procedures

   All sampling equipment will be decontaminated between sample locations according to EPA SOG No. 23,
   Revision O, and sample containers will be rinsed with deionized water. All samples will be stored in coolers
   on ice until they reach the laboratory. Chain of custody will be maintained according to EPA SOG No. 21,
   Revision O by field personnel until samples are handed over to the SE Regional Contract Laboratory in
   Tallahassee.

   5. INVESTIGATION-DERIVED WASTES PLAN

   Investigation-derived wastes include personal protective equipment, disposable sampling equipment, purged
   ground water, and soil not collected as a sample. Personal protective equipment and disposable sampling
   equipment (DE) will be decontaminated and rendered nonhazardous. All dry personal protective equipment
   and DE will be double-bagged and deposited offsite at the EPA Region  4 warehouse.

   Purged ground water is expected to be nonhazardous under the Resources Conservation and Recovery Act
   (RCRA). Per signed agreements with owners of the off-site wells to be sampled, ground water will be poured
   onto the ground next to the wells and allowed to infiltrate. Any quantities of soils  that are not collected as
   samples will be spread around the sample location and covered with surficial soil. These soils are anticipated
   to be RCRA nonhazardous. Any sediments not collected as samples will be returned to the surface water.

   6. PROJECT MANAGEMENT

   The project manager for the Palmetto Landfill SI, Joseph Brown, will schedule field activities and personnel
   requirements, verify site access authority obtained through the EPA Project Officer, direct and oversee all
   onsite and offsite activities  associated with the investigation. The project manager also will document and
   manage all collected samples. The project safety officer is Joan Locke. Max Villeroy, Wanda Grouper, and
   A.J. Hoyt will collect and prepare samples and support all other field operations as required. The estimated
   technical hours total 440 (Table 2). Twenty-one proposed CLP samples  are summarized in Table 1.

   6.1 Field Equipment/Health and Safety

   Safety monitoring equipment will include OVA, HNu, Victoreen Radiation Detector, and TLD badge. Field
   respiratory protection will be level C during the site reconnaissance.   If non-methane contaminants and
   radiation levels are safely below background and  action levels, the reconnaissance will  continue at level D.
   Protection during SI onsite sampling activities will begin at level D; if radiation and volatile contaminants
   are detected, sampling will continue at level C. Offsite sampling will be conducted at level D protection.
   Field dress for reconnaissance will include slush boots, Tyvek 1422A, disposable gloves,  and hardhat. For
   onsite sampling, butyl or nitrile gloves will be worn over the disposable gloves, and the hardhat will include
   a faceshield. Field dress for offsite sampling  entails regular cotton work clothes, work boots, and disposable
   gloves. Other items required for this investigation include sample containers and sampling tools, deionized
   water rinse, alconox wash, and decontamination assembly. (See Attachment B for more specific information).

                                                  -6-
                                                 A-6

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Site Inspection Guidance                                  Appendix A: SI Sample Plan (Example)
   6.2 Community Relations

   The local community has been made aware of the date of the SI field activities. Community relations have
   progressed smoothly thus far.

   6.3 Project Schedule

   The project is expected to start in early June 1991 and end by January 31, 1992. Non-sampling data
   collection will begin in June and continue through late October. The SI field work will take place in early
   September. When the field tasks are completed, preparation of the draft SI report will begin. Analytical
   results will be validated by the middle of December, and the final SI report and I-IRS score will be completed
   by the end of January.
      REFERENCES

   1.   XYZ Corporation, Preliminary Assessment Palmetto Landfill, Palmetto County, South Carolina, TDD
       No. Y9-8765-43, June 10,1991.

   2.   U.S. Geological Survey, 7.5-minute topographic quadrangle maps of South Carolina: Angleton, 1963,
       photo revised 1983; Palmetto, 1975; Winchester, 1975 Danvers,  1963.

   3.   U.S. Department of Commerce, 1983. "The Climatic Atlas of the United States."

   4.   Jennifer Doe, Manager for Smith and Moore Disposal Services, telephone conversation with Joe Brown,
       XYZ Corporation, May 1, 1991. Re: Waste Disposal Practices at Palmetto Landfill.

   5.   Joseph Brown, XYZ Corporation, Photodocumentation Log of Palmetto Landfill Preliminary Assessment,
       May 7,1991.

   6.   A.P. Park, The Surface Water Resources of Palmetto County, South Carolina. South Carolina Water
       Resources  Commission Report No. 101B.

   7.   Joseph Brown, XYZ Corporation, Field Logbook for Offsite Reconnaissance of Palmetto Landfill,
       TDDY9-8765-43,  May 1991.

   8.   John Hill, Technician for South Carolina Department of Health and Environmental Concerns, telephone
       conversation with Joe Brown, XYZ Corporation, May 2, 1991. Re: Remediation and sampling at
       Palmetto Landfill,
                                                 -7-
                                                A-7

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Appendix A: SI Sample Plan (Example)
Site Inspection Guidance

TABLE 1: PROPOSED SAMPLES
PURPOSE
Ground
Water
QA/QC
Surface
Water
Sediment
QA/QC
Soil
Waste
Sources
QA/QC
SAMPLE
PL-GW-1
PL-GW-3
T»T /~*\\r A
iri-r
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Site Inspection Guidance
Appendix A: SI Sample Plan (Example)
                           FIGURE 1: SAMPLE LOCATIONS
                       Source, Surface Water sediment, and Soil
                                        -9-
                                        A-9

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Appendix A: SI Sample Plan (Example)
Site Inspection Guidance
                          FIGURE 2: SAMPLE LOCATIONS
                                  Ground Water
                                       -10-
                                      A-10

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Site inspection Guidance
Appendix A: SI Sample Plan (Example)
                            TABLE 2: COST SUMMARY
TASK
Review PA and supporting materials
Prepare SI workplan
Obtain access; make advance arrangements
Collect site information from office
Travel to and from site and perform field work
Complete information gathering
Evaluate sample results
Prepare SI report and evaluate site score
CLP analysis 21 samples (17 environmental, 3 duplicates,
1 field blank)
TOTAL
ESTIMATED
TECHNICAL
HOURS
30
50
20
40
150
30
40
80

440
COST
(@ $ 	 per
hour)
.

	


	
	
	
$25,200
$

                                      -11-
                                      A-11

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                                    APPENDIX B

                                SI DATA SUMMARY
The investigator may use the SI Data Summary to compile analytical data and non-sampling
information concerning the site. The Data Summary can be a checklist  to:

        •       Summarize previous and newly-collected information
        •       Identify factors that have not been fully evaluated
        •       Focus additional data collection efforts

A completed SI Data Summary may facilitate entering data into PREscore or other SI scoring
and HRS  documentation tools.

Responses on the SI  Data Summary need not be typed; legible handwriting  is acceptable,

The Data Summary is not a mandatory requirement for  SI reporting; EPA Regional guidelines
may recommend using other mechanisms to  summarize  information collected  during the SI or
to compile previous information about the site.

SI Data Summary entries marked with  an asterisk (*)  are optional during a focused SI. For
pathways investigated during an expanded SI, all Data Summary entries  should be completed.

If  necessary,  continuation  pages  to  summarize  additional analytical results  should  be
photocopied and included with the Data Summary. A sample location map should be  provided
or referenced for all analytical results.

The  last page of the Data  Summary may be used to describe  additional  site information
regarding a specific data element. In addition, this page may be used to describe or summarize
site information that has not been collected,, is not available, or is  not well documented.
                                           B-1

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SI Data Summary
Site Name	
                             Site Name
                                   EPA Region,
                                       Date
Contractor Name or State Office and Address
                        GENERAL SITE INFORMATION
1.  CERCLIS ID NO.
   Address	
   County	
                              City.
State
Zip Code
Congressional District
2.  Owner name
                      Operator name
   Owner address
   City	
    State
         Operator address
         City	
              State
3.  Type of ownership (check all that apply):
   D Private   D Federal/Agency	
   D Other	
4.  Approximate size of property:	
5.  Latitude    °         	  Longitude	°_
                          State  d County   D Municipal
                                     Reference(s)	
                       acres
6.  Site status:    D Active D Inactive D Unknown
7.  Years of operation:  From:	to:	 n Unknown
8.  Previous Investigations:
   Type        Aqencv/State/Contractor             Date
                        Reference(s)
                        Reference(s)
                        Reference(s)
                        Reference(s)
                                                              Reference(s).
                                                              Reference(s).
                                                              Reference(s)
                                                              Reference(s)
                                                              Reference(s)
                                                              Reference(s)
                                          B-3

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SI Data Summary                                     Site Name
                      WASTE SOURCE INFORMATION
1.  Waste source types (check all that apply)
   D Constituent
   u Wasiesiream (type)
   n Landfill
   n Drums
   D Contaminated soil
   D Land treatment
   D Tanks or non-drum containers (type)
   D Pile (type)	
   n Surface impoundment (buried)
   D Surface impoundment (backfilled)
   n Other	

   Reference(s)   	
2.  Types of wastes (check all that apply)

   CD Organic chemicals
   CD Inorganic chemicals
   u Municipal wastes
   D Radionuclides
   D Metals
   D Pesticides/Herbicides
   D Solvents
   n Other	
   Rsferencs(s)
3.  Summarize history of waste disposal operations:
    Reference(s)  	


                                          B-4

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SI Data Summary                                         Site Name
4.   Source characterization (Attach pages to show quantity and calculations.)


    Source 1 name:	        Source type_

    Describe source:       	
    Ground water migration containment:

    Surface water migration containment:
    Air migration (gas and migration) containment:
    Physical state of wastes:  D Liquid   D Solid  n Sludge/Slurry   D Gas  D Unknown
    Constituent quantity of hazardous substances:         	(specify units)
    Wastestream quantity containing hazardous substances:         	(specify units)
    Volume of source (yd3):	        Area of source (ft2):	

    Hazardous substances associated with source 1:
    Reference(s)
    Source 2 name:  	          Source type.

    Describe source:       	
    Ground water migration containment:

    Surface water migration containment:
    Air migration (gas and migration) containment:
    Physical state of wastes:  D Liquid  D Solid  D Sludge/Slurry  n Gas   D Unknown
    Constituent quantity of hazardous substances:         	(specify units)
    Wastestream quantity containing hazardous substances:         	(specify units)
    Volume of source (yd3):	       Area of Source (fta):	

    Hazardous substances associated with source 2:
    Reference(s)
                                              B-5

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SI Data Summary                                        Site Name

CONTINUATION PAGE FOR SOURCE CHARACTERIZATION
    Source #	Name	      Source type

    Describe source:
    Ground water migration containment:

    Surface water migration containment:
    Air migration (gas and migration) containment:
    Physical state of wastes:  D Liquid  D Solid  D Sludge/Slurry  D Gas  D Unknown
    Constituent quantity of hazardous substances:         	(specify units)
    Wastestream quantity containing hazardous substances:        	(specify units)
    Volume of source (yd3):	       Area of source (ft2):	

    Hazardous substances associated with source #	:
    Reference(s)
    Source #	Name	      Source type

    Describe source:       	
    Ground water migration containment:

    Surface water migration containment:
    Air migration (gas and migration) containment:
    Physical state of wastes:  D Liquid  D Solid   D Sludge/Slurry  n Gas  D Unknown
    Constituent quantity of hazardous substances:         	(specify units)
    Wastestream quantity containing hazardous substances:        	(specify units)
    Volume of source (yd3):	       Area of source (ft2):	

    Hazardous substances associated with source #	:
    Reference(s)
                                             B-6

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SI Data Summary                                        Site Name	

5.  Description of removal or remedial activities

    If a removal has occurred, identify the removal authority and describe the activities.  Specify the
    date(s) of the removal.
    Rsfsrsncs(s)      	


                                             B-7

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SI Data Summary                                       Site Name
                       GROUND WATER INFORMATION
1.   Ground water drinking water use within 4 miles of site sources:
    D Municipal    D Private  D Both    D No Drinking Water Use

    Reference(s)    	

2.   Is ground water contaminated?
    D Yes D No  D Uncertain but likely   D Uncertain but not likely
    D Additional sampling required
    Is analytical evidence available?   n Yes n No              Reference(s)

3.   Is ground water contamination attributable to the site?
    D Yes D No  D Additional sampling required                Reference(s)
4.  Are drinking water wells contaminated?
   D Yes D No  D Uncertain but likely   D Uncertain but not likely
   D Additional sampling required
   Is analytical evidence available?   D Yes D No              Reference(s)
5,*  Net precipitation (HRS Section 3=1,2,2);	inches        Reference(s)	

6.   County average number of persons per residence:	Reference(s)	

7.   Discuss general stratigraphy underlying the site. Attach sketch of stratigraphic column.
    Reference^)
8.  Using Table GW-1 (next page), summarize geology underlying the site (starting with formation
    #1 as closest to ground surface).  Indicate if formation is interconnected with overlying formation.
                                            B-8

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SI Data Summary
                         Site Name.

TABLE GW-1: SITE GEOLOGY
NAME OF FORMATION
1.
2.
3.
4.
5.
6.
INTER-
CONNECT?
(yes/no)






TYPE OF
MATERIAL






AVERAGE
THICKNESS
(FEET)






HYDRAULIC
CONDUCTIVITY
(CM/SEC)






USED FOR
DRINKING
WATER?






    Reference(s)
9.   Does a karst aquifer underlie any site source?
    DYes DNo
10. Depth to top of aquifer:
   feet
Elevation:
Reference(s)

Reference(s)
11.  In the table below, enter the number of people obtaining drinking water from wells located
    within 4 miles of the site.  For each aquifer, attach population calculation sheets.  Key aquifer to
    formations listed in Table GW-1.
              POPULATION SERVED BY WELLS WITHIN DISTANCE CATERGORIES BY AQUIFER
DISTANCE OF WELL(S)
FROM SITE SOURCES
1/4 mile or less
>1/4 to 1/2 mile
> 1/2 to 1 mile
>1 to 2 miles
>2 to 3 miles
>3 to 4 miles
AQUIFER A: INCLUDES
FORMATIONS






AQUIFER B: INCLUDES
FORMATIONS






AQUIFER C: INCLUDES
FORMATIONS






    Reference(s)
12. Is ground water from multiple wells blended prior to distribution?
    D Yes  n No                                           Reference(s)
                                            B-9

-------
SI Data Summary                                        Site Name
 13.    Is ground water blended with surface water?
   DYes DNo                                           Reference(s)

Briefly describe:   	
14. Distance from any Incompletely contained source available to ground water to nearest
    drinking water well (MRS Section 3.3.1):     	feet            Reference(s)	
15. Briefly describe standby drinking water wells within 4 miles of sources at the site:
    Reference^)
16. Using Table GW-2, summarize ground water analytical results for all sampling Investigations.
    Include and identify background ground water sample results.

17.* Ground water resources within 4 miles of site sources (MRS Section 3.3.3):
    D Irrigation (5-acre minimum) of commercial food or commercial forage crops
    D Commercial livestock watering
    D Ingredient in commercial food preparation
    D Supply for commercial aquaculture
    D Supply for major or designated water recreation area, excluding drinking water use
    D Water usable for drinking water but no drinking water wells are within 4 miles
    D None of the above

    Reference(s)      	

18. Wellhead protection area (WHPA) within 4 miles of site sources (MRS Section 3.3.4):
    D Source with non-zero containment factor value lies within or above WHPA
    D Observed ground water contamination attributable to site source(s) lies within WHPA
    D WHPA lies within 4 miles of site sources
    n None

    Reference(s)      	


Additional ground water pathway description:
References(s)
                                             B-10

-------
TABLE GW-2: ANALYTICAL RESULTS FOR GROUND WATER PATHWAY
SAMPLE ID
&DATE








TYPE OF WELL
D Irrigation D Monitoring
D Drinking water
Peoote served
D Other
D Irrigation D Monitoring
D Drinking water
People served
O Other
D Irrigation D Monitoring
D Drinking water
People served
n Other
D Irrigation n Monitoring
D Drinking water
People served
n Other
n Irrigation D Monitoring
D Drinking water
People served
D Other
D Irrigation n Monitoring
D Drinking water
People served
n Other
n Irrigation D Monitoring
D Drinking water
People served
n Other
n Irrigation n Monitoring
n Drinking water
People served
n Other
SCREENED
INTERVAL








HAZARDOUS SUBSTANCE








CONCENTRATION
(SPECIFY UNITS)








DETECTION
LIMIT








REFERENCES









-------
SI Data Summary                                      Site Name.
                      SURFACE WATER INFORMATION
   Complete this section of the data summary for each watershed If there are multiple
   watersheds.  Photocopy this page If necessary.

1.  Describe surface water migration path from site sources to at least 15 miles downstream.
   Attach a sketch of the surface water migration route.
   Reference(s)
2.  Is surface water contaminated?
   D Yes  D No  D Uncertain but likely  d Uncertain but not likely  D Additional sampling required
   Is analytical evidence available?    D Yes  n No                  Reference(s)	
3.  Is surface water contamination attributable to the site?
   D Yes D No  d Additional sampling required                    Reference(s)

4.  Floodplaln category in which site sources are located (check all that apply):
   m-year n 10-year  n 100-year D 500-year DNone             Reference(s)

5.  Describe flood containment for each source (MRS Section 4.1.2.1.2.2):

   Source #1 	 Flood containment    	

   Source #2 	 Flood containment    	

   Source #3 	 Flood containment    	

   Source #	Flood containment    	

   Source #	Flood containment    	

   Source #	Flood containment    	

   Source #	Flood containment    	

   Reference(s)      	
6.  Shortest overland distance to surface water from any source (HRS Section 4.1.2.1.2.1.3):
    	feet                                                Reference(s)	
7.*  Size of drainage area (HRS Section 4.4.3): 	Acres         Reference(s)

                                          B-12

-------
SI Data Summary
Site Name
8.*  Describe predominant soil group within the drainage area (MRS Section 4.1.2.1.2.1.2).
    Reference(s)
9.*  2-year 24-hour rainfall (MRS Section 4.1.2.1.2.1.2):
    	inches

10/Elevatlon of the bottom of nearest surface water body:
       	feet above sea level

11 /Elevation of top of uppermost aquifer:
       	feet above sea level
         Reference(s).


         Reference(s)


         Reference(s)
12. Predominant type of water body between probable point of entry to surface water and
    nearest drinking water Intake:
    n River    O Lake                                              Reference(s)	
13. identify all drinking water Intakes, fisheries, and sensitive environments within 15 miles
    downstream.
TARGET NAME/TYPE






WATER
BODY TYPE






DISTANCE
FROM PPE






FLOW
(CFS)






TARGET
CHARACTERISTICS'






TARGET
SAMPLED?






    1lf target is a drinking water intake, provide number of people served by intake.
    If target is a fishery, provide species and annual production of human food chain organisms
       (pounds per year).
    If target is a wetland, specify wetland frontage (in  miles). Attach calculation pages.

    Reference(s)      	
14. Is surface water drinking water blended prior to distribution?
    OYes  DNo                                             Reference(s)
                                            B-13

-------
SI Data Summary                                        Site Name
15. Describe any standby drinking water intakes within 15 miles downstream.
    Reference(s)
ib.'Surface water resources within 15 miies downstream (HRt> section 4.1.2.3.3):
   D Irrigation (5-acre minimum) of commercial food or commercial forage crops
   D Commercial livestock watering
   D Ingredient in commercial food preparation
   D Major or designated water recreation area, excluding drinking water use
   u Water designated by the state for drinking water use but is not currently used
   D Water usable for drinking water but no drinking water intakes within 15 miles downstream
   D None of the above

   Reference(s)       	

17. Using Table SW-1, summarize surface water analytical results for all sampling Investigations.
   Include and identify background sample results.
                                            B-14

-------
                     TABLE SW-1: SUMMARY OF ANALYTICAL RESULTS FOR SURFACE WATER PATHWAY
SAMPLE ID
&DATE









SAMPLE
TYPE
CD Aqueous
CD Sediment
n Other
CD Aqueous
D Sediment
n Other
D Aqueous
D Sediment
D Other
D Aqueous
D Sediment
D Other
CD Aqueous
D Sediment
D Other
CD Aqueous
D Sediment
D Other
CD Aqueous
CD Sediment
D Other
D Aqueous
CD Sediment
n Other
CD Aqueous
n Sediment
n Other
SAMPLE OBJECTIVE
CD Release CD Fishery
D Drinking water
D Sensitive environment
Distance from PPE
D Release n Fishery
n Drinking water
n Sensitive environment
Distance from PPE
D Release CD Fishery
n Drinking water
D Sensitive environment
Distance from PPE
n Release CD Fishery
D Drinking water
CD Sensitive environment
Distance from PPE
n Release CD Fishery
n Drinking water
n Sensitive environment
Distance from PPE
n Release CD Fishery
D Drinking water
D Sensitive environment
Distance from PPE
n Release CD Fishery
n Drinking water
n Sensitive environment
Distance from PPE
n Release CD Fishery
D Drinking water
D Sensitive environment
Distance from PPE
CD Release CD Fishery
D Drinking water
D Sensitive environment
Distance from PPE
TARGET
NAME









HAZARDOUS
SUBSTANCE









CONCENTRATION
(SPECIFY UNITS)









DETECTION
UMIT









REFERENCES









00



Ol

-------
SI Data Summary                                        Site Name
                                SOIL INFORMATION
1.   Is surflclal or soil contamination present at the site?
    n Yes  n No   D Uncertain but likely   D Uncertain but not likely
    D Additional sampling required
    Is analytical evidence available?    n Yes n No             Reference(s)	

2.   Is surflclal or soil contamination attributable to the site?
    n Yes  n No   n Additional sampling required

3,   Is surflclal contamination on the property and within 200 feet of a residence, school, daycare
    center, or workplace?
    D Yes  D No   D Uncertain but likely   D Uncertain but not likely
    D Additional sampling required
    Is analytical evidence available?    D Yes n No             Reference(s)	

4.*  Total area of surflclal contamination (HRS Section 5.2.1.2):
    	square feet                               Reference(s)	
5.*  Attractiveness/accessibility of the areas of observed contamination (HRS Section 5.2.1.1). Check
    ail that apply:

    n Designated recreational area
    D Used regularly, or accessible and unique  recreational area
    D Moderately accessible with some use
    D Slightly accessible with some use
    D Accessible with no use
    u inaccessible with some use
    D Inaccessible with no use

    Reference(s)      	

6.  Using Table SE-1, summarize analytical results detecting surflclal contamination within 200 feet
    of a residence, school, daycare center, or workplace.  Include and identify background sample
    results.

7.  Using Table SE-2, summarize analytical  results detecting surflclal contamination within the
    boundary of a resource or a terrestrial sensitive environment.  Include and identify background
    sample results if not listed in Table SE-1.

8.  Population within 1-mlle travel distance from site.  Do not include populations from Table SE-1.
DISTANCE FROM SITE SOURCES
1/4 mile or less
>1/4 to 1/2 mile
>1/2 to 1 mile
POPULATION



    Reference(s)      	


                                            B-16

-------
                            TABLE SE-1:  ANALYTICAL RESULTS FOR SOIL EXPOSURE PATHWAY
SAMPLE ID
ft DATE








SAMPLE
DEPTH








TYPE OF PROPERTY
n Residence D School
n Daycare center
n WorkDlace
D Residence D School
D Daycare center
l-l Ufnrlfn|a~>
D Residence D School
D Daycare center
D Workolace
D Residence D School
D Daycare center
n Workolace
D Residence n School
CD Daycare center
n WorkDlace
a Residence D School
D Daycare center
d Workolace
a Residence D School
D Daycare center
n WorkDlace
D Residence D School
D Daycare center
|—| U/nrknl;a/>o
POPULATION








HAZARDOUS
SUBSTANCE








CONCENTRATION
(SPECIFY UNITS)








DETECTION
LIMIT








REFERENCES








OD

-------
                             TABLE SE-2: ANALYTICAL RESULTS FOR SOIL EXPOSURE PATHWAY
SAMPLE ID
&DATE




SAMPLE
DEPTH




TYPE OF TARGET
D Terrestrial sensitive
environment
H Resources*
D Commercial agriculture
D Commercial silviculture
D Commercial livestock
production or grazing
D Terrestrial sensitive
environment
D Resources*
D Commercial agriculture
D Commercial silviculture
D Commercial livestock
production or grazing
D Terrestrial sensitive
environment
D Resources*
D Commercial agriculture
D Commercial silviculture
D Commercial livestock
production or grazing
D Terrestrial sensitive
environment
D Resources*
D Commercial agriculture
D Commercial silviculture
D Commercial livestock
production or arazina
HAZARDOUS SUBSTANCE




CONCENTRATION
(SPECIFY UNITS)




DETECTION
LIMIT




REFERENCES




CD
00

-------
SI Data Summary                                        Site Name
                                 AIR INFORMATION
1.   Is air contamination present at the site?
    D Yes  D No  D Uncertain but likely  n Uncertain but not likely
    D Additional sampling required
    Is analytical evidence available?    D Yes  D No             Reference(s)
2.  Is air contamination attributable to the site?
    D Yes  n No  D Additional sampling required

3.  Are populations, sensitive  environments,  or wetlands  exposed to  airborne  hazardous
    substances released from the site?
    D Yes  O No  n Uncertain  but likely  D Uncertain but not likely
    n Additional sampling required
    Is analytical evidence available?    D Yes  D No             Reference(s)	

4.  Evidence of blogas release from any of the following source types at the site:
    D Below-ground containers or tanks   D Landfill   D Buried surface impoundment
    Reference(s)	

5.*  Paniculate migration potential factor value:	 (HRS Figure 6-2)

6.*  Paniculate mobility factor value:	 (HRS Figure 6-3)

7.  Distance from any Incompletely contained source to nearest residence or regularly occupied
    area:   	miles      Reference(s)	

8.  Population within 4 miles of site sources.
DISTANCE FROM SITE SOURCES
0 (within site sources)
1/4 mile or less
>1/4 to 1/2 mile
>1/2 to 1 mile
>1 to 2 miles
>2 to 3 miles
>3 to 4 miles
POPULATION







    Reference(s)
9.* Resources within 1/2 mile of site sources (HRS Section 6.3.3):
    n Commercial agriculture
    n Commercial silviculture
    n Major or designated recreation area
    D None of the above

    Reference(s)      	
                                            -B-19

-------
SI Data Summary                                      Site Name

10. Sensitive environments and wetlands within 4 miles of the site.
NAME/DESCRIPTION/LOCATION OF
SENSITIVE ENVIRONMENT OR
WETLAND







DISTANCE FROM
SITE (MILES)







TYPE OF SENSITIVE
ENVIRONMENT







WETLAND SIZE
(ACRES)







   Reference(s)
11.     Using Table AIM, summarize air analytical results for all sampling Investigations.  Include
       and identify background sample results.
                                          B-20

-------
                           TABLE AIR-1: SUMMARY OF ANALYTICAL RESULTS FOR AIR PATHWAY
SAMPLE ID
&DATE




























SAMPLE
TYPE




























DISTANCE FROM
SITE (MILES)




























TARGET(S) WITHIN
DISTANCE CATEGORY
D Number of people
D Name of sens, environment

n Wetland acreage
D Number of people
D Name of sens, environment

D Wetland acreage
D Number of people
D Name of sens, environment

D Wetland acreage 	
O Number of people
D Name of sens, environment

D Wetland acreage
O Number of people
D Name of sens, environment

n Wetland acreage
D Number of people
D Name of sens, environment

n Wetland acreage
D Number of people
D Name of sens, environment

n Wetland acreage
HAZARDOUS
SUBSTANCE




























CONCENTRATION
(SPECIFY UNITS)




























DETECTION
LIMIT




























REFERENCES




























DO
ro

-------
SI Data Summary                          Site Name.
          ADDITIONAL INFORMATION AND COMMENTS
Reference(s)
                             B-22

-------
                                   APPENDIX C

                       SITE  INSPECTION  WORKSHEETS
This appendix consists  of worksheets that  can be used to generate an SI site score.
Completion of these worksheets is not required, but the SI investigator must evaluate an SI
score, either by these worksheets, PREscore, or other Regional scoring tools.

The worksheets consist  of instructions and  data tables to be filled in with scores from HRS
reference tables. The data tables may also call for Data Type and References.

    DATA TYPE: The  Data Type columns should be filled  in with an H, Q, or+ if the
    data are HRS quality and well documented. The Data Type column should be filled
    in with an E, X, or - if the data represent estimates, approximations, or are not fully
    documented. This type  identifies  data  gaps for the expanded SI to investigate.

    REFERENCES: The Reference columns should be  filled in with  coded reference
    numbers. The numbered  reference list should be attached  or the numbering  should
    be  cross-referenced to the SI Narrative Report.

The SI investigator will need the current Superfund Chemical Data Matrix (SCDM) OSWER
Directive 9345.1-13  (revised semi-annually) to complete these  worksheets.
                                         C-1

-------
SITE  INSPECTION  WORKSHEETS
                      CERCLIS IDENTIFICATION NUMBER
SITE LOCATION
SI 1 1 NAME: LEGAL, COMMON, OR DESCRIPTIVE NAME OF SITE
STREET ADDRESS, ROUTE, OR SPECIFIC LOCATION IDENTIFIER
CITY
COORDINATES: LATITUDE and LONGITUDE
STATE ZIP COt
DE TELEPHONE
( )
TOWNSHIP, RANGE, AND SECTION
OWNER/OPERATOR IDENTIFICATION
OWNER
OWNER ADDRESS
CITY
STATE
ZIP CODE
TELEPHONE
OPERATOR
OPERATOR ADDRESS
CITY
STATE ZIP CODE TELEPHONE
SITE EVALUATION
AGENCY/ORGANIZATION
INVESTIGATOR
CONTACT
ADDRESS
CITY
TELEPHONE
( )




STATE ZIP CODE

               C-3

-------
                              GENERAL  INFORMATION
Site Description and Operational History:   Provide a brief description of the site and its
operational history. State the site name, owner, operator, type of facility and operations, size of property,
active or inactive status, and years of waste generation. Summarize waste treatment, storage, or disposal
activities that have or may have occurred at the site; note whether these activities are documented or
alleged. Identify all source types and prior spills, floods, or fires. Summarize highlights of the PA and
other investigations. Cite references.
                                             C-4

-------
                      GENERAL  INFORMATION  (continued)
Site Sketch: Provide a sketch of the site.  Indicate all pertinent features of the site and nearby
environments including sources of wastes, areas of visible and buried wastes, buildings, residences,
access roads, parking areas, fences, fields, drainage patterns, water bodies, vegetation, wells, sensitive
environments, and other features.
                                          C-5

-------
                         GENERAL INFORMATION  (continued)

Source  Descriptions:  Describe  all sources  at the site. Identify source type and relate to waste
disposal operations. Provide source dimensions and the best available waste quantity information.
Describe the condition of sources and all containment structures.  Cite references.


                                      SOURCE  TYPES
Landfill:  A man-made (by excavation or construction) or natural hole in the ground into which wastes
have come to be  disposed by backfilling, or by contemporaneous soil deposition with waste  disposal.

Surface  Impoundment:   A natural topographic depression, man-made excavation, or diked area,
primarily formed from earthen materials (lined or unlined) and designed to hold an accumulation of liquid
wastes, wastes containing free  liquids, or sludges  not backfilled or otherwise  covered; depression  may be
wet with exposed liquid or dry if deposited liquid has evaporated, volatilized or leached; structures  that
may be described as lagoon, pond, aeration pit, settling pond, tailings pond, sludge pit; also  a surface
impoundment that has been covered with soil after the final deposition of waste materials (i.e., buried or
backfilled).

Drum: A portable container designed to hold a standard 55-gallon volume of wastes.

Tank and Non-Drum Container:   Any device,  other than a drum, designed to contain an
accumulation of waste that provides structural support and is constructed primarily of fabricated materials
(such as wood,  concrete, steel, or plastic); any portable or mobile device in which waste is stored or
otherwise  handled.

Contaminated  Soil:  An  area or volume  of soil onto which hazardous substances have been spilled,
spread, disposed, or deposited.

Pile:  Any non-containerized accumulation  above the ground surface of solid, non-flowing wastes;
includes  open dumps. Some types of waste piles are:

    • Chemical Waste Pile:               A pile consisting primarily of discarded chemical products, by-
                                      products, radioactive wastes, or used  or unused feedstocks.

    •  Scrap Metal or Junk Pile:           A pile consisting primarily of scrap metal or discarded durable
                                      goods (such as appliances, automobiles, auto parts, batteries,
                                      etc.) composed of materials containing hazardous  substances.

    • Tailings Pile:                      A pile consisting primarily of any combination of overburden from
                                      a mining operation and tailings from a mineral mining,
                                      beneficiation, or  processing  operation.

    • Trash Pile:                       A pile consisting primarily of paper, garbage, or discarded non-
                                      durable  goods  containing  hazardous  substances.

Land Treatment: Landfarming or other method of waste management in which liquid wastes or sludges
are spread over land and tilled, or liquids are injected at shallow depths into soils.

Other:  Sources not in categories listed above.
                                                C-6

-------
                    GENERAL  INFORMATION  (continued)
Source Description: Include description of containment per pathway for ground water (see MRS
Table 3-2), surface water (see MRS Table 4-2), and air (see MRS Tables 6-3 and 6-9).
Hazardous Waste Quantity (HWQ) Calculation:  SI Tables 1 and 2 (See HRS Tables 2-5, 2-6,
and 5-2).
Attach additional pages, if necessary                              HWQ =
                                        C-7

-------
SI TABLE 1:  HAZARDOUS WASTE QUANTITY (HWQ) SCORES FOR SINGLE SOUR(
           SITES  AND FORMULAS FOR  MULTIPLE SOURCE  SITES


(Column 1)
TIER



A
F^
Hazardous
Constituent
Quantity




B
Hazardous
Wastestream
Quantity




c
Voluma









D
Area





(Column 2)
Source Type




N/A







N/A

Landfill
Surface
impoundment
Drums
Tanks and non-drum
containers
Contaminated soil

Pile

Other

Landfill

Surface
impoundment
Contaminated soil

Pile

Land treatment

Single Source Sites
(assigned HWQ scores)
(Column 3)
HWQ = 10
HWQ=1if
Hazardous
Constituent
Quantity data are
complete
HWQ = 10 if
Hazardous
Constituent
Quantity data are
not complete


< 500,000 Ibs

< 6.75 million ft3
< 250,000 yd3
<6,750 ft3
<250 yd3
s1 ,000 drums
<50,000 gallons

<6.75 million ft3
<250,000 yd3
<6,750 ft3
<250 yd3
<6,750 ft3
<250 yd3
<340,000 ft2
<7.6 acres
<1,300ft2
<0.029 acres
<3.4 million ft2
<78 acres
<1,300ft2
50.029 acres
<27,000 ft2
<0.62 acres
(Column 4)
HWQ = 100




>1 00 to 10,000 Ibs







>500,000 to 50 million Ibs

>6.75 million to 675 million ft3
>250,000 to 25 million yd3
>6,750 to 675,000 ft3
>250 to 25,000 yd 3
>1 ,000 to 1 00,000 drums
>50,000 to 5 million gallons

>6.75 million to 675 million ft3
>250,000 to 25 million yd3
>6,750 to 675,000 ft3
>250 to 25,000 yd3
>6,750 to 675,000 ft3
>250 to 25,000 yd3
>340,000 to 34 million ft2
>7.8 to 780 acres
>1, 300 to 130,000 ft2
>0.029 to 2.9 acres
> 3.4 million to 340 million ft2
> 78 to 7,800 acres
>1, 300 to 1 30,000 ft2
>0.029 to 2.9 acres
>27,000 to 2.7 million ft2
>0.62 to 62 acres
                                C-8

-------
TABLE  1  (CONTINUED)
Single Source Sites
(assigned HWQ scores)
(Column 5)

HWQ = 10,000




>1 0,000 to 1 million Ibs

>50 million to 5 billion Ibs


>675 million to 67.5 billion ft3
>25 million to 2.5 billion yd3
>675,000 to 67.5 million ft3
>25,000 to 2.5 million yd3
>1 00,000 to 10 million drums

>5 million to 500 million gallons


>675 million to 67.5 billion ft3
>25 million to 2.5 billion yd3
>675,000 to 67.5 million it3
>25,000 to 2.5 million yd3
>675,000 to 67.5 million ft3
>25,000 to 2.5 million yd3
>34 million to 3.4 billion ftz
>780 to 78,000 acres
>130,000 to 13 million ft2
>2.9 to 290 acres
> 340 million to 34 billion ft2
> 7,800 to 780,000 acres
> 130,000 to 13 million ft2
> 2.9 to 290 acres
>2.7 million to 270 million ft2
>62 to 6,200 acres
(Column 6)

HWQ =
1,000,000



> 1 million Ibs

> 5 billion Ibs


> 67.5 billion ft3
> 2.5 billion yd3
> 67.5 million ft3
> 2.5 million yd3
> 10 million drums

> 500 million gallons


> 67.5 billion ft3
> 2.5 billion yd3
> 67.5 million ft3
> 2.5 million yd3
> 67.5 million ft3
> 2.5 million yd3
> 3.4 billion ft2
>78,000 acres
> 13 million ft2
> 290 acres
> 34 billion ft2
> 780,000 acres
> 13 million ft2
> 290 acres
> 270 million ft2
> 6,200 acres
Multiple
Source Sites
(Column 7)
Divisors for
Assigning
Source WQ
Values


lbs + 1

Ibs + 5,000


ft3 + 67.500
yd3 + 2,500
ft3 + 67.5
yd3 + 2.5
drums + 10

gallons + 500


ft3 + 67,500
yd3 + 2,500
ft3 * 67.5
yd3 -1-2.5
ft3 + 67.5
yd3 + 2.5
ftz + 3,400
acres + 0.078
ft2 +13
acres + 0.00029
ft2 + 34,000
acres + 0.78
ft2 +13
acres + 0.00029
ft2 + 270
acres + 0.0062


(Column 2)

Source Type




N/A

N/A


Landfill
Surface
Impoundment

Drums

Tanks and non-drum
containers

Contaminated Soil

Pile

Other
Landfill

Surface
Impoundment

Contaminated Soil

Pile

Land Treatment
(Column 1)

TIER


A
Hazardous
Constituent
Quantity
B
Hazardous
Wastestream
Quantity




c
Volume










D
Area





                                   C-9

-------
HAZARDOUS  WASTE QUANTITY  (HWQ)  CALCULATION

For each migration pathway, evaluate HWQ associated with sources that are available (i.e., incompletely
contained) to migrate to that pathway. (Note: If Actual Contamination Targets exist for ground water,
surface water, or air migration pathways, assign the calculated HWQ score or 100, whichever is greater, as
the HWQ score for that pathway.) For each source, evaluate HWQ for one or more of the four tiers (SI
Table 1; HRS Table 2-5) for which data exist: constituent quantity, wastestream quantity, source volume,
and source area. Select the tier that gives the highest value as the source HWQ. Select the source
volume HWQ rather than source area HWQ if data for both tiers are available.

Column  1 of SI Table 1  indicates the quantity tier. Column 2 lists source types for the four tiers. Columns
3,4,5, and 6 provide ranges of waste amount for sites with only one source, corresponding to HWQ
scores at the tops of the columns. Column 7 provides formulas to obtain source waste quantity values at
sites with multiple sources.

1.   Identify each source type.
2.   Examine all waste quantity data available for each source. Record constituent quantity and waste
     stream mass or volume. Record dimensions of each source.
3.   Convert source measurements to appropriate units for each tier to be evaluated.
4.   For each source, use the formulas in the last column of SI Table 1 to determine the waste quantity
     value for each tier that can be evaluated. Use the waste quantity value obtained from the highest tier
     as the quantity value for the source.
5.   Sum the values assigned to each source to determine the total  site waste quantity.
6.   Assign HWQ score from SI Table 2 (HRS Table 2-6).

Note these exceptions  to evaluate soil  exposure pathway HWQ  (see HRS Table 5-2):

•    The divisor for the area (square feet) of a landfill is 34,000.
•    The divisor for the area (square feet) of a pile is 34.
•    Wet surface impoundments and tanks and non-drum containers are the only sources for which
     volume measurements are evaluated for the soil exposure pathway.

                         SI TABLE 2:  HWQ SCORES  FOR  SITES
Site WQ Total
0
1ato100
> 100 to 10,000
> 10,000 to 1 million
> 1 million
HWQ Score
0
1*»
100
10,000
1,000.000
     a If the WQ total is between O and 1, round it to 1.
     b If the hazardous constituent quantity data are not complete, assign the score of 10.
                                            C-10

-------
  SI TABLE 3:

  Site Name:
WASTE  CHARACTERIZATION WORKSHEET
                                             References
  Sources:
  1.
  2.
  3.
               4.
               5.
               6.
7.
8.
9.
SOURCE














HAZARDOUS
SUBSTANCE














TOXICITY














GROUND
WATER
PATHWAY
GW
Mobility
(MRS
Table
3-8)














Tox/
Mobility
Value
(HRS
Table
3-9)














SURFACE WATER PATHWAY
OVERLAND/FLOOD MIGRATION
Per (HRS
Tables
4-10 and
4-11)














Tox/Per
Value
(HRS
Table
4-12)














Bioac Pot
(HRS
Table
4-15)














Tox/
Pers/
Bioac
Value
(HRS
Table
4-16)














Ecotox
(HRS
Table
4-19)














Ecotox/
Pers
(HRS
Table
4-20)














Ecotox/
Pers/
Bioacc
Value
(HRS
Table
4-21)














GROUND WATER TO
SURFACE WATER
Tox/
Mob/
Pars
Value
(HRS
Table
4-26)














Tox/
Mob/
Pers/
Bioacc
Value
(HRS
Table
4-28)














Ecotox/
Mob/
Pere
Value
(HRS
Table
4-29)














Ecotox/
Mob/
Per/
Bioacc
Value
(HRS
Table
4-30)














o

-------
Ground Water Observed Release Substances  Summary  Table

On SI Table 4, list the hazardous substances associated with the site detected in ground water samples
for that aquifer. Include only those substances directly observed or with concentrations significantly
greater than background levels. Obtain toxicity values from the Superfund Chemical Data Matrix (SCDM).
Assign mobility a value of 1 for all observed release substances regardless of the aquifer being evaluated.
For each substance, multiply the toxicity by the mobility to obtain the toxicity/mobility factor value; enter
the highest toxicity/mobility value for the aquifer in the space provided.

Ground Water Actual  Contamination Targets Summary Table

If there is an observed release at a drinking water well, enter each hazardous substance meeting the
requirements for an observed release by well and sample ID on SI Table 5 and record the detected
concentration. Obtain benchmark, cancer risk, and reference dose concentrations from SCDM.  For MCL
and MCLG benchmarks, determine the highest percentage of benchmark obtained for any substance.
For cancer risk and reference dose, sum the percentages for the substances listed. If benchmark, cancer
risk, or reference dose concentrations are not available  for a particular substance, enter N/A for the
percentage. If the highest benchmark percentage or the percentage sum calculated for cancer risk or
reference dose equals or exceeds 100%, evaluate the population using the well as a Level I target.  If
these percentages are less than 100% or all are N/A, evaluate the population using the well as a Level  II
target for that aquifer.
                                             C-12

-------
SI TABLE 4: GROUND  WATER OBSERVED RELEASE SUBSTANCES  (BY  AQUIFER)
Sample ID









Hazardous Substance









Bckgrd.
Cone.









Highest Toxicity/Mobility
Toxicity/
Mobility










References










SI TABLE 5:  GROUND WATER ACTUAL CONTAMINATION TARGETS
Well ID:	  Level I	  Level II	  Population Served.
                                                 References

CO
Sample ID





Hazardous Substance





Cone.
(ug/L)





Benchmark
Cone.
(MCLorMCLG)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






Well ID:
Level I
Level II
Population Served _
References
Sample ID





Hazardous Substance





Cone.
(ug/L)





Benchmark
Cone.
(MCLorMCLG)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD







-------
                         GROUND WATER  PATHWAY
                   GROUND WATER  USE  DESCRIPTION
Describe Ground Water Use within 4 Miles of the Site:
Describe generalized stratigraphy, aquifers, municipal and private wells
Show Calculations of Ground Water Drinking Water Populations for each Aquifer:
Provide apportionment calculations for blended supply systems.
County average number of persons per household:	Reference	
                                      C-14

-------
                   GROUND  WATER  PATHWAY  WORKSHEET
LIKELIHOOD OF  RELEASE
                                                           Score
                          Data
                          Type   Refs
1 . OBSERVED RELEASE: If sampling data or direct observation
support a release to the aquifer, assign a score of 550. Record
observed release substances on SI Table 4.
2. POTENTIAL TO RELEASE: Depth to aquifer: feet. If
sampling data do not support a release to the aquifer, and the site is
in karst terrain or the depth to aquifer is 70 feet or less, assign a
score of 500; otherwise, assign a score of 340. Optionally,
evaluate potential to release according to HRS Section 3.
LR =








TARGETS
3.
   Are any welis part of a blended system?    Yes_
                                               No
If yes, attach a page to show apportionment calculations.

ACTUAL CONTAMINATION TARGETS: If analytical evidence
indicates that any target drinking water well for the aquifer has been
exposed to a hazardous substance from the site, evaluate the
factor score for the number of people served (SI Table 5).
    Level I:
    Level II:
                  . people x 10 s.
                   people x 1
Total
    POTENTIAL CONTAMINATION TARGETS:  Determine the number
    of people served by drinking water wells for the aquifer or overlying
    aquifers that are not exposed to a hazardous substance from the
    site; record the population for each distance category in SI Table 6a
    or 6b. Sum the population values and multiply by 0.1.	
5.  NEAREST WELL: Assign a score of 50 for any Level I Actual
    Contamination Targets for the aquifer or overlying aquifer. Assign a
    score of 45 if there are Level II targets but no Level I targets.  If no
    Actual Contamination Targets exist, assign the Nearest Well score
    from SI Table 6a or 6b.  If no drinking water wells exist within 4 miles,
    assign 0.	
    WELLHEAD PROTECTION AREA (WHPA):  If any source lies
    within or above a WHPA for the aquifer, or if a ground water
    observed release has occurred within a WHPA, assign a score of
    20; assign 5 if neither condition applies but a WHPAls within 4
    miles; otherwise assign 0.	
7.  RESOURCES: Assign a score of 5 if one or more ground water
    resource applies; assign 0 if none applies.

           irrigation (5 acre minimum) of commercial food crops or
           commercial forage crops
           Watering of commercial livestock
       •   Ingredient in commercial food preparation
       •   Supply for commercial aquaculture
           Supply for a major or designated water recreation area,
           excluding drinking water use
                                        Sum of Targets    T=
                                          C-15

-------
SI TABLE 6 (From MRS TABLE 3-12):  VALUES FOR POTENTIAL CONTAMINATION GROUND WATER
                                TARGET POPULATIONS
                           SI Table 6a: Other Than Karst Aquifers


0 '
a> i

Distance
from Site
0 to j mile
>4to2
mile
>~to1
mile
>1to2
miles
>2to3
miles
>3to4
miles
Pop.










Nearest Well =
Nearest
Well
(choose
highest)
20
18

9


5
3

2


1
to
10
4
2

1


0.7
0.5

0.3
11
to
30
17
11

5


3
2

1
Population Served by Wells within Distance Category
31
to
100
53
33

17


10
7

4
101
to
300
164
102

52


30
21

13
301
to
1000
522
324

167


94
68

42
1001
to
3000
1,633
1,013

523


294
212

131
3001
to
10,000
5,214
3,233

1,669


939
678

417
10,001
to
30,000
16,325
10,122

5,224


2,939
2,122

1,306
30,001
to
100,000
52,137
32,325

16,684


9,385
6,778

4,171
100,001
to
300,000
163,246
101,213

52,239


29,384
21 ,222

13,060
300,001
to
1 ,000,000
521,360
323,243

166,835


93,845
67,777

41 ,709
1,000,000
to
3,000,000
1,632,455
1,012,122

522,385


293,842
212,219

130,596
Sum =
Pop.
Value Ref.























-------
   SI TABLE 6 (From MRS TABLE 3-12):   VALUES FOR POTENTIAL CONTAMINATION GROUND WATER
                                     TARGET  POPULATIONS  (continued)
                                   SI Table 6b: Karst Aquifers
Distance
from Site
0 to 7 mile
>4t°2
mile
>2-to1
mile
>1to2
miles
>2to3
miles
>3to4
miles
Pop.









Nearest Well =
Nearest
Well
(choose
highest)
20
20

20

20
20

20

Population Served by Wells within Distance Category
1
to
10
4
2

2

2
2

2
11
to
30
17
11

9

9
9

9
31
to
100
53
33

26

26
26

26
101
to
300
164
102

82

82
82

82
301
to
1000
522
324

261

261
261

261
1001
to
3000
1,633
1,013

817

817
817

817
3001
to
10,000
5,214
3,233

2,607

2,607
2,607

2,607
10,001
to
30.000
16,325
10,122

8,163

8,163
8,163

8,163
30,001
to
1 00,000
52,137
32,325

26,068

26,068
26.068

26,068
100,001
to
300,000
163,246
101,213

81 ,623

81,623
81,623

81,623
300,001
to
1,000,000
521 ,360
323,243

260,680

260,680
260,680

260,680
1,000,000
to
3,000,000
1,632,455
1,012,122

816,227

816,227
816,227

816.227
Sum =
Pop.
Value










Ref.










o

-------
          GROUND WATER PATHWAY WORKSHEET (concluded)
WASTE  CHARACTERISTICS
        Score
      Does
Data   not
Type  Apply
8 . If any Actual Contamination Targets exist for the aquifer or
overlying aquifers, assign the calculated hazardous waste
quantity score or a score of 100, whichever is greater; if no Actual
Contamination Targets exist, assign the hazardous waste
quantity score calculated for sources available to migrate to
ground water.
9 . Assign the highest ground water toxicity/mobility value from SI
Table 3 or 4.
10. Muttip
quant
tablet
ly the ground water toxicity/mobility and hazardous waste
rty scores. Assign the Waste Characteristics score from the
aetow: (from MRS Table 2-7)
Product
0
>0to<10
10to<100
100to<1,000
1 ,000 to < 10,000
10,OOOto<1E + 05
1E + 05to<1E + 06
1E + 06to<1E+07
1E + 07to<1E+08
1 E + 08 or greater
WC Score
0
1
2
3
6
10
18
32
56
100


we =











Multiply LR by T and by WC. Divide the product by 82,500 to obtain the ground water
pathway score for each aquifer. Select the highest aquifer score. If the pathway score is
greater than 100, assign 100.
GROUND WATER  PATHWAY  SCORE:
LR  X T X WC
   82,500
                                                                  (Maximum of 100)
                                     C-18

-------
                       SURFACE  WATER  PATHWAY
Sketch of the Surface Water Migration  Route:
Label all surface water bodies.  Include runoff route and drainage direction, probable point of entry, and
15-mile target distance limit.  Mark sample locations, intakes, fisheries, and sensitive environments.
Indicate flow directions, tidal influence, and rate.
                                        C-19

-------
SURFACE WATER PATHWAY

Surface Water Observed Release Substances Summary Table

On SI Table 7, list the hazardous substances detected in surface water samples for the watershed, which
can be attributed to the site. Include only those substances in observed releases (direct observation) or
with concentration levels significantly above background levels. Obtain toxicity, persistence,
bioaccumulation potential, and ecotoxicity values from SCDM. Enter the highest toxicity/persistence,
toxicity/persistence/bioaccumulation, and ecotoxicity/persistence/ecobioaccumulation values in the
spaces provided.

   •   TP    = Toxicity x Persistence
   •   TPB   = TP x bioaccumulation
   •   ETPB =   EP x bioaccumulation (EP = ecotoxicity x persistence)

Drinking Water Actual Contamination Targets Summary Table

For an observed release at or beyond  a drinking water intake, on SI Table 8 enter each hazardous
substance by sample ID and the detected concentration. For surface water sediment samples detecting a
hazardous substance at or beyond an intake, evaluate the intake as Level II contamination. Obtain
benchmark, cancer risk, and reference dose concentrations for each substance from SCDM. For MCL and
MCLG benchmarks, determine  the highest percentage of benchmark obtained  for any substance. For
cancer risk and reference dose, sum the percentages of the substances listed.  If benchmark, cancer risk,
or reference dose concentrations are not available for a particular substance, enter N/A for the
percentage. If the highest benchmark percentage or the percentage sum calculated for cancer risk or
reference dose equals  or exceeds 100%, evaluate the population served by the intake as a Level I target.
If the percentages are less than 100% or all  are N/A, evaluate the population served by the intake as a
Level II target.
                                            C-20

-------
   SI TABLE 7:  SURFACE WATER OBSERVED RELEASE SUBSTANCES
Sample ID










Hazardous Substance










Bckgrd.
Cone.










Highest Values
Toxicity/
Persistence











Toxicity/
Persis./
Bioaccum











Ecotoxicity/
Persis/
Ecobioaccum











References











   SI TABLE 8:  SURFACE WATER DRINKING WATER ACTUAL  CONTAMINATION  TARGETS

   Intake ID:	  Sample Type	  Level I	  Level II	   Population Served	References_
Sample ID





Hazardous Substance





Cone.
(UG/L)




;
Benchmark
Cone.
(MCLorMCLG)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






o
ro
   Intake ID:
Sample Type.
Level I
Level II
Population Served.
References
Sample ID





Hazardous Substance





Cone.
(ua/U





Benchmark
Cone.
(MCLorMCLG)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD







-------
                    SURFACE WATER PATHWAY
     LIKELIHOOD OF RELEASE  AND DRINKING WATER THREAT WORKSHEET
LIKELIHOOD  OF RELEASE-
OVERLAND/FLOOD MIGRATION
Score
Data
Type  Refs
1.
2.
OBSERVED RELEASE: If sampling data or direct observation
support a release to surface water in the watershed, assign a score
of 550. Record observed release substances on SI Table 7.
POTENTIAL TO RELEASE: Distance to surface
water: (fe
If sampling data do not support a release to surface water in the
watershed, use the table below to assign a score from the table
below based on distance to surface water and flood frequency.

Distance to surface water <2500 feet
Distance to surface water >2500 feet, and:
Site in annual or 10-yr floodplain
Site in 100-yr floodplain
Site in 500-yr floodplain
Site outside 500-yr floodplain
500

500
400
300
100
et)
Optionally, evaluate surface water potential to release
according to HRS Section 4.1 .2.1 .2
LR =








LIKELIHOOD  OF RELEASE
GROUND WATER TO SURFACE WATER MIGRATION
Score
Data
Type  Refs
1 . OBSERVED RELEASE: If sampling data or direct observation
support a release to surface water in the watershed, assign a score
of 550. Record observed release substances on SI Table 7.
NOTE: Evaluate ground water to surface water migration only for a
surface water body that meets all of the following conditions:
1 ) A portion of the surface water is within 1 mile of site sources having
a containment factor greater than 0.
2) No aquifer discontinuity is established between the source and the
above portion of the surface water body.
3) The top of the uppermost aquifer is at or above the bottom of the
surface water.
Elevation of top of uppermost aquifer
Elevation of bottom of surface water body

2 . POTENTIAL TO RELEASE: Use the ground water potential to
release. Optionally, evaluate surface water potential to release
according to HRS Section 3.1 .2.
LR =








                                C-23

-------
                    SURFACE WATER  PATHWAY
     LIKELIHOOD OF RELEASE AND DRINKING WATER THREAT WORKSHEET
                            (CONTINUED)
DRINKING WATER THREAT TARGETS
Score
Data
Type  Refs
Record the water body type, flow, and number of people served by
each drinking water intake within the target distance limit in the
watershed, if there is no drinking water intake within the target
distance limit, assign 0 to factors 3, 4, and 5.
Intake Name Water Body Type Flow People Served




Are any intakes part of a blended system? Yes No
If yes, attach a page to show apportionment calculations.
3. ACTUAL CONTAMINATION TARGETS: If analytical evidence
indicates a drinking water intake has been exposed to a hazardous
substance from the site, list the intake name and evaluate the factor
score for the drinking water population (SI Table 8).
Level 1: people x 10 =
Level II: people x 1 = Total =

4. POTENTIAL CONTAMINATION TARGETS: Determine the number
of people served by drinking water intakes for the watershed that
have not been exposed to a hazardous substance from the site.
Assign the population values from S! Table 9. Sum the values and
multiply by 0.1 .
5. NEAREST INTAKE: Assign a score of 50 for any Level I Actual
Contamination Drinking Water Targets for the watershed. Assign a
score of 45 if there are Level II targets for the watershed, but no
Level I targets. If no Actual Contamination Drinking Water Targets
exist, assign a score for the intake nearest the PPE from SI Table 9.
If no drinking water intakes exist, assign 0.
6, RESOURCES: Assign a score of 5 if one or more surface water
resource applies; assign 0 if none applies.
Irrigation (5 acre minimum) of commercial food crops or
commercial forage crops
• Watering of commercial livestock
Ingredient in commercial food preparation
Major or designated water recreation area, excluding drinking
water use
SUM OF TARGETS T=













































                               C-24

-------
  SI TABLE 9 (From HRS Table 4-14):  DILUTION-WEIGHTED POPULATION VALUES FOR  POTENTIAL

                CONTAMINATION FOR SURFACE WATER MIGRATION PATHWAY
Type of Surface Water
Body
Minimal Stream (<10 cfs)
Small to moderate stream
(10 to 100 cfs)
Moderate to large stream
(> 100 to 1,000 cfs)
Large Stream to river
(>1,000 to 10,000 cfs)
Large River
(> 10,000 to 100,000 cfs)
Very Large River
(>1 00,000 cfs)
Shallow ocean zone or
Great Lake
(depth < 20 feet)
Moderate ocean zone or
Great Lake
(Depth 20 to 200 feet)
Deep ocean zone or Great
Lake
(depth > 200 feet)
3-mile mixing zone in quiet
flowing river
(> 10 cfs)
Pop.










Nearest Intake =
Nearest
Intake
20
2
0
0
0
0
0
0
0
10

Number of people
0
0
0
0
0
0
0
0
0
0
0
1
to
10
4
0.4
0.04
0.004
0
0
0
0
0
2
11
to
30
17
2
0.2
0.02
0.002
0
0.002
0
0
9
31
to
100
53
5
0.5
0.05
0.005
0.001
0.005
0.001
0
26
101
to
300
164
16
2
0.2
0.02
0.002
0.02
0.002
0.001
82
301
to
1,000
522
52
5
0.5
0.05
0.005
0.05
0.005
0.003
261
1,001
to
3,000
1,633
163
16
2
0.2
0.02
0.2
0.02
0.008
817
3,001
to
10,000
5,214
521
52
5
0.5
0.05
0.5
0.05
0.03
2,607
10,001
to
30,000
16,325
1,633
163
16
16
0.2
2
0.2
0.08
8,163
Sum =
Pop.
Value











o

NJ
01
                                                  References

-------
SURFACE WATER PATHWAY

Human Food Chain Actual Contamination Targets Summary Table

On SI Table 10, list the hazardous substances detected in sediment, aqueous, sessile benthic organism
tissue, or fish tissue samples (taken from fish caught within the boundaries of the observed release) by
sample ID and concentration. Evaluate fisheries within the boundaries of observed releases detected by
sediment or aqueous samples as Level II, if at least one observed release substance has a
bioaccumulation potential factor value of 500 or greater (see SI Table 7). Obtain benchmark, cancer risk,
and reference dose concentrations  from SCDM. For FDAAL benchmarks, determine the highest
percentage of benchmark obtained for any substance. For cancer risk and reference dose, sum the
percentages for the substances listed. If benchmark, cancer risk, or reference dose concentrations are
not available for a particular substance, enter N/A for the percentage. If the highest benchmark
percentage sum  calculated for cancer risk or reference dose equals or exceeds 100°/0, evaluate this
portion of the fishery as subject to Level I concentrations. If the percentages are less than 100% or all are
N/A, evaluate the fishery as a Level  II target.

Sensitive Environment Actual Contamination  Targets Summary Table

On SI Table 11, list each hazardous substance detected in aqueous or sediment samples at or beyond
wetlands or a surface water sensitive environment by sample ID. Record the concentration. If
contaminated sediments or tissues are detected at or beyond a sensitive environment, evaluate the
sensitive environment as Level II. Obtain benchmark concentrations from SCDM. For AWQC/AALAC
benchmarks, determine the highest percentage of benchmark of the substances detected in aqueous
samples. If benchmark concentrations are not available for a particular substance, enter N/A for the
percentage. If the highest benchmark percentage equals or exceeds 100%, evaluate that part of the
sensitive environment subject to Level I concentrations. If the percentage is less than 100%,  or all are
N/A, evaluate the sensitive environment as Level II.
                                           C-26

-------
SI TABLE  10:
Fishery ID:	
 HUMAN FOOD CHAIN ACTUAL CONTAMINATION TARGETS  FOR WATERSHED
	Sample Type	       Level I	      Level II	  References
Sample ID





Hazardous Substance





Cone.
(mg/kg)





Benchmark
Concentration
(FDAAL)





Highest
Percent
% of
Benchmark






Cancer Risk
Concentration.





Sum of
Percents
% of Cancer
Risk
Concentration






RfD





Sum of
Percents
% of RfD






SI TABLE 11:   SENSITIVE ENVIRONMENT ACTUAL  CONTAMINATION TARGETS  FOR WATERSHED
Environment ID:	Sample Type	      Level I	       Level II	  Environment Value
o
1
ro
^i
Sample ID





Hazardous Substance





Cone..
(H9/L)





Benchmark
Concentration
(AWQCor
AALAC)





Highest
Percent
% of
Benchmark






References






Environment ID:
              Sample Type.
Level I
Level II
Environment Value
Sample ID





Hazardous Substance





Cone..
(WJ/L)





Benchmark
Concentration
(AWQCor
AALAC)





Hinhast
% of
Benchmark






References







-------
 SURFACE  WATER PATHWAY  (continued)
HUMAN  FOOD CHAIN THREAT  WORKSHEET
Data
HUMAN FOOD CHAIN THREAT TARGETS Score Type Refs
Record the water body type and flow for each fishery within the
target distance limit. If there is no fishery within the target
distance limit, assign a score of 0 at the bottom of this page.
Fishe
Fishe
Fishe
FOOC
7.
8.
ry Name Water Body Flow cfs
Species Production Ibs/yr
Species Production Ibs/yr
ry Name Water Body Flow cfs
Species Production Ibs/vr
Species Production Ibs/vr
ry Name Water Body Flow cfs
Species Production Ibs/vr
Species Production ibs/vr

1 CHAIN INDIVIDUAL
ACTUAL CONTAMINATION FISHERIES:
If analytical evidence indicates that a fishery has been exposed to
a hazardous substance with a bioaccurnuiaiion factor greater than
or equal to 500 (SI Table 1 0), assign a score of 50 if there is a
Level I fishery. Assign 45 if there is a Level II fishery, but no Level
fishery.
POTENTIAL CONTAMINATION FISHERIES:
If there is a release of a substance with a bioaccumulation factor
greater than or equal to 500 to a watershed containing fisheries
within the target distance limit, but there are no Level I or Level II
fisheries, assign a score of 20.
If there is no observed release to the watershed, assign a value
for potential contamination fisheries from the table below using
the lowest flow at all fisheries within the target distance limit:
Lowest Flow FCI Value
< 10 cfs 20
10 to 100 cfs 2
>1 00 cfs, coastal tidal waters,
oceans, or Great Lakes 0
3-mile mixing zone in quiet 1 0
flowing river
FCi Value =
SUM OF TARGETS T =





                C-28

-------
                   SURFACE WATER PATHWAY (continued)
                   ENVIRONMENTAL  THREAT  WORKSHEET

When measuring length of wetlands that are located on both sides of a surface water body, sum both
frontage lengths. For a sensitive environment that is more than one type, assign a value for each type.
ENVIRONMENTAL  TH   AT TARGETS
                                                       Score
   Record the water body i/pe and flow for each surface water
   sensitive environment within the target distance (see SI Table 12).
   If there is no sensitive environment within the target distance limit,
   assign a score of 0 at the bottom of the page.
Environment Name
                Water Body Type
                      Fbw
                                                      _CfS
                                                      _cfs
                                                      _CfS
                                                      _cfs
                                                       cfs
9.  ACTUAL CONTAMINATION SENSITIVE ENVIRONMENTS:  If
   sampling data or direct observation indicate any sensitive
   environment has been exposed to a hazardous substance from the
   site, record this information on SI Table 11, and assign a factor
   value for the environment (SI Tables 13 and 14).
Environment Name
          Environment Type and
          Value (SI Tables 13 & 14)
             Multiplier (10 for
             Level 1,1 for
             Level II)
       Product
                                                    Sum =
                                                 Data
                                                 Type  Refs
10. POTENTIAL CONTAMINATION SENSITIVE ENVIRONMENTS:
Fbw
   cfs
   cfs
   cfs

   cfs
    cfs
Dilution Weight
(SI Table 12)
Environment Type and
Value (SI Tables 13 & 14)
Pot.
Cont.

0.1 =
                                    0.1
                                    0.1
                                    0.1
                                    0.1
Product
                                                    Sum =
                                                       T =
                                         C-29

-------
                                SI TABLE  12 (MRS Table 4-13):
                            SURFACE WATER  DILUTION WEIGHTS
Type of Surface Water Body
Descriptor
Minimal stream
Small to moderate stream
Moderate to large stream
Large stream to river
Large river
Very large river
Coastal tidal waters
Shallow ocean zone or Great Lake
Moderate depth ocean zone or Great Lake
Deep ocean zone or Great Lake
3-mile mixing zone in quiet flowing river
Flow Characteristics
< 10cfs
10to100cfs
> 100 to 1,000 cfs
> 1,000 to 1 0,000 cfs
> 10,000 to 1 00,000 cfs
> 100,000 cfs
Flow not applicable; depth not applicable
Flow not applicable; depth less than 20 feet
Flow not applicable; depth 20 to 200 feet
Flow not applicable; depth greater than 200 feet
10 cfs or greater
Assigned
Dilution
Weight
1
0.1
0.01
0.001
0.0001
0.00001
0.001
0.001
0.0001
0.000005
0.5
o
I
CO
o

-------
             SI TABLE 13 (MRS TABLE 4-23):
SURFACE WATER AND  AIR SENSITIVE  ENVIRONMENTS VALUES
SENSITIVE ENVIRONMENT
Critical habitat for Federal designated endangered or threatened species
Marine Sanctuary
National Park
Designated Federal Wilderness Area
Ecologically important areas identified under the Coastal Zone Wilderness Act
Sensitive Areas identified under the National Estuary Program or Near Coastal
Water Program of the Clean Water Act
Critical Areas identified under the Clean Lakes Program of the Clean Water Act
(subareas in lakes or entire small lakes)
National Monument (air pathway only)
National Seashore Recreation Area
National Lakeshore Recreation Area
Habitat known to be used by Federal designated or proposed endangered or threatened species
National Preserve
National or State Wildlife Refuge
Unit of Coastal Barrier Resources System
Coastal Barrier (undeveloped)
Federal land designated for the protection of natural ecosystems
Administratively Proposed Federal Wilderness Area
Spawning areas critical for the maintenance of fish/shellfish species within a
river system, bay. or estuary
Migratory pathways and feeding areas critical for the maintenance of
anadromous fish species within river reaches or areas in lakes or coastal
tidal waters in which the fish spend extended periods of time
Terrestrial areas utilized by large or dense aggregations of vertebrate animals
(semi-aquatic foragers) for breeding
National river reach designated as recreational
Habitat known to be used by State designated endangered or threatened species
Habitat known to be used by a species under review as to its Federal endangered
or threatened status
Coastal Barrier (partially developed)
Federally designated Scenic or Wild River
Stats land designated for wildlife or game management
State designated Scenic or Wild River
State designated Natural Area
Particular areas, relatively small in size, important to maintenance of unique biotic communities
State designated areas for the protection of maintenance of aquatic life under the Clean Water
Act
Wetlands See S! Table 1 4 (Surface Water Pathway) or S! Table 23 (Air Pathway)
ASSIGNED
VALUE
100
75
50
25
5

      SI TABLE 14 (HRS TABLE 4-24):  SURFACE WATER
             WETLANDS  FRONTAGE  VALUES
Total Length of Wetlands
Less than 0.1 mile
0.1 to 1 mile
Greater than 1 to 2 miles
Greater than 2 to 3 miles
Greater than 3 to 4 miles
Greater than 4 to 8 miles
Greater than 8 to 1 2 miles
Greater than 12 to 16 miles
Greater than 1 6 to 20 miles
Greater than 20 miles
Assigned
0
25
50
75
100
150
250
350
450
500
Value

                        C-31

-------
               SURFACE WATER  PATHWAY (concluded)
     WASTE  CHARACTERISTICS, THREAT, AND PATHWAY SCORE SUMMARY
WASTE CHARACTERISTICS
Score
14. If an Actual Contamination Target (drinking water, human food
chain, 01 environmental threat) exists for the watershed, assign
the calculated hazardous waste quantity score, or a score of 100,
whichever is greater.
15. Assign the highest value from SI Table 7 (observed release) or SI
Table 3 (no observed release) for the hazardous substance waste
characterization factors below. Multiply each by the surface water
hazardous waste quantity score and determine the waste
characteristics score for each threat.

Drinking Water Threat
Toxicity /Persistence
Food Chain Threat
Toxicity /Persistence
Bioaccumulation
Environmental Threat
Ecotoxicity/Persistence/
Ecobioaccumulation


Substance Value
X
X
X

Product
0
>Qto<10
10to<100
100to<1,000
1, 000 to < 10,000
10,OOOto<1E + 05
1E + 05to<1E + 06
1E + Q6to<1E + Q7
1E + 07to<1E + 08
1E + 08to<1E + 09
1E + 09to<1E + 10
1E + 10to<1E+11
1E + 11to<1E + 12
1E + 12 or greater
HWQ Product
—



WC Score
0
1
2
3
6
10
18
32
56
100
180
320
560
1000



WC Score (from Table)
(Maximum of 100)




SURFACE  WATER PATHWAY THREAT SCORES
Threat
Drinking Water
Human Food Chain
Environmental
Likelihood of Release
(LR) Score



Targets (T) Score



Pathway Waste
Characteristics (WC)
Score (determined
above)



Threat Score
LR x T x WC
82,500
(maximum of 100)
(maximum of 1 00)
(maximum of 60)
                      SURFACE WATER PATHWAY SCORE
                      (Drinking Water Threat + Human Food
                      Chain Threat + Environmental Threat)
                                                       (maximum of 100)
                                C-33

-------
SOIL EXPOSURE  PATHWAY
If there is no observed contamination (e.g., ground water plume with no known surface source), do not
evaluate the soil exposure pathway. Discuss evidence for no soil exposure pathway.

Soil Exposure Resident Population Targets Summary

For each property (duplicate page 35 as necessary):

If there is an area of observed contamination on the property and within 200 feet of a residence, school, or
day care center, enter on Table 15 each hazardous substance by sample ID. Record the detected
concentration. Obtain cancer risk, and reference dose concentrations from SCDM. Sum the cancer risk
and reference dose percentages for the substances listed. If cancer risk or reference dose
concentrations  are not available for a particular substance, enter N/A for the percentage. If the percentage
sum calculated for cancer risk or reference dose equals or exceeds 100%, evaluate the residents and
students as Level 1. If both percentages are less than 100% or all are N/A, evaluate the targets as Level II.
                                           C-34

-------
SI TABLE 15:  SOIL EXPOSURE  RESIDENT POPULATION TARGETS



Residence ID:	  Level I	      Level II	       Population
Sample ID





Hazardous Substance





Cone.
(mg/kg)





Cancer Risk
Concentration





Highest
Percent
% of
Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






Toxicity Value





Sum of
Percents
References






Residence ID:
Level I
Level II
Population
o
CO
01
Sample ID





Hazardous Substance





Cone.
(mg/kg)





Cancer Risk
Concentration





Highest
Percent
% of
Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






Toxicity Value





Sum of
Percents
References






Residence ID:
Level I
Level II
Population.
Sample ID





Hazardous Substance





Cone.
(mg/kg)





Cancer Risk
Concentration





Highest
Percent
% of
Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






Toxicity Value





Sum of
Percents
References







-------
            SOIL EXPOSURE PATHWAY  WORKSHEET
               RESIDENT POPULATION THREAT
Data
LIKELIHOOD OF EXPOSURE Score Type Refs
1.
OBSERVED CONTAMINATION: If evidence indicates presence of
observed contamination (depth of 2 feet or less), assign a score of
550; otherwise, assign a 0. Note that a likelihood of exposure
score of 0 results in a soil exposure pathway score of 0.
LE =





TARGETS
2. RESIDENT POPULATION: Determine the number of people
occupying residences or attending school or day care on or within
200 feet of areas of observed contamination (HRS section 5.1.3).
Level I: people x 10
Level II: people x 1

Sum =
3. RESIDENT INDIVIDUAL: Assign a score of 50 if any Level I
resident population exists. Assign a score of 45 if there are Level II
targets but no Level I targets. If no resident population exists (i.e.,
no Level I or Level II targets), assign 0 (HRS Section 5.1 .3).
4. WORKERS: Assign a score from the table below for the total
number of workers at the site and nearby facilities with areas of
observed contamination associated with the site.
Number of Workers
0
1 to 100
101 to 1,000
>1,000
Score
0
5
10
15

5. TERRESTRIAL SENSITIVE ENVIRONMENTS: Assign a value for
each terrestrial sensitive environment (SI Table 1 6) in an area of
observed contamination.
Terrestrial Sensitive Environment Type






Value





Sum =
6. RESOURCES: Assign a score of 5 if any one or more of the
following resources is present on an area of observed
contamination at the site; assign 0 if none applies.
• Commercial agriculture
• Commercial silviculture
• Commercial livestock production or commercial livestock
grazing
Total of Targets T=

















                          C-36

-------
SI TABLE 16 (MRS TABLE 5-5): SOIL EXPOSURE PATHWAY
   TERRESTRIAL  SENSITIVE ENVIRONMENT VALUES
TERRESTRIAL SENSITIVE ENVIRONMENT
Terrestrial critical habitat for Federal designated endangered or
threatened species
National Park
Designated Federal Wilderness Area
National Monument
Terrestrial habitat known to be used by Federal designated or proposed threatened
or endangered species
National Preserve (terrestrial)
National or State terrestrial Wildlife Refuge
Federal land designated for protection of natural ecosystems
Administratively proposed Federal Wilderness Area
Terrestrial areas utilized by large or dense aggregations of animals
(vertebrate species) for breeding
Terrestrial habitat used by State designated endangered or threatened species
Terrestrial habitat used by species under review for Federal designated
endangered or threatened status
State lands designated for wildlife or game management
State designated Natural Areas
Particular areas, relatively small in size, important to maintenance of
unique biotic communities
ASSIGNED VALUE
100
75
50
25
                      C-37

-------
             SOIL EXPOSURE PATHWAY WORKSHEET
                   NEARBY  POPULATION  THREAT
LIKELIHOOD OF EXPOSURE
Score
Data
Type  Ref.
7. Attractiveness/ Accessibility
(from S! Table 1 7 or HRS Table 5-6) Value
Area of Contamination
(from Si Table 1 8 or HRS Table 5-7) Value
Likelihood of Exposure
(from SI Table 19 or HRS Table 5-8)
LE =





TARGETS
Score
Data
Type  Ref.
8. Assign a score of 0 if Level 1 or Level II resident individual has been
evaluated or if no individuals live within 1/4 mile travel distance of
an area of observed contamination. Assign a score of 1 if nearby
population is within 1/4 mile travel distance and no Level 1 or Level
II resident population has been evaluated.
9. Determine the population within 1 mile travel distance that is not
exposed to a hazardous substance from the site (i.e., properties
that are not determined to be Level I or Level II); record the
population for each distance category in SI Table 20 (HRS Table 5-
10). Sum the population values and multiply by 0.1 .
T =








                             C-38

-------
                 SI TABLE 17 (MRS TABLE 5-6):
           ATTRACTIVENESS/ACCESSIBILITY  VALUES
Area of Observed Contamination
Designated recreational area
Regularly used for public recreation (for example, vacant lots in urban
area)
Accessible and unique recreational area (for example, vacant lots in
urban area)
Moderately accessible (may have some access irnprovements-for
example, gravel road) with some public recreation use
Slightly accessible (for example, extremely rural area with no road
improvement) with some public recreation use
Accessible with no public recreation use
Surrounded by maintained fence or combination of maintained fence
and natural barriers
Physically inaccessible to public, with no evidence of public recreation
use
Assigned
Value
100
75
75
50
25
10
5
0
SI TABLE 18 (MRS TABLE 5-7):  AREA OF CONTAMINATION FACTOF
                           VALUES
Total area of the areas of
observed contamination (square feet)
< to 5,000
> 5,000 to 125,000
> 125,000 to 250,000
> 250,000 to 375,000
> 375,000 to 500,000
> 500,000
Assigned
Value
5
20
40
60
80
100
                           C-39

-------
          SI TABLE 19 (HRS TABLE 5-8):  NEARBY POPULATION LIKELIHOOD OF
                                     EXPOSURE FACTOR VALUES
AREA OF
CONTAMINATION
FACTOR VALUE
100
80
60
40
20
5
ATTRACTIVENESS/ACCESSIBILITY FACTOR VALUE
100
500
500
375
250
125
50
75
500
375
250
125
50
25
50
375
250
125
50
25
5
25
250
125
50
25
5
5
1 0
125
50
25
5
5
5
5
50
25
5
5
5
5
0
0
0
0
0
0
0
o
I
•PS-
CD
SI TABLE 20 (HRS TABLE 5-10):  DISTANCE-WEIGHTED POPULATION  VALUES
                           FOR NEARBY POPULATION THREAT
Travel Distance
Category
(miles)
Greater than 0 to -r
4
Greater than - to -r
4 2
Greater than- to 1
Pop.



Number of people within the travel distance category
0
0
0
0
1
to
10
0.1
0.05
0.02
11
to
30
0.4
0.2
0.1
31
to
100
1.0
0.7
0.3
101
to
300
4
2
1
301
to
1,000
13
7
3
1,001
to
3,000
41
20
10
3,001
to
10,001
130
65
33
10,001
to
30,000
408
204
102
30,001
to
100,000
1,303
652
326
100,001
to
300,000
4,081
2,041
1,020
300,001
to
1,000,000
13,034
6,517
3,258
Reference(s) R|I_ _
Pop.
Value





-------
          SOIL  EXPOSURE  PATHWAY WORKSHEET  (concluded)

WASTE CHARACTERISTICS
10.   Assign the hazardous waste quantity score calculated for soil exposure
11.    Assign the highest toxicity value from SI Table 16
12.
Multiply the toxicity and hazardous waste quantity scores. Assign the
Waste Characteristics score from the table below:
Product
0
>0to<10
10to<100
100to<1,000
1, 000 to < 10,000
10,OOOto<1E + 05
1E + 05to<1E + 06
lE + 06to<1E + 07
lE + 07to<1E + 08
1 E + 08 or greater
WC Score
0
1
2
3
6
10
18
32
56
100
                                                             WC =
RESIDENT  POPULATION  THREAT  SCORE:

(Likelihood of Exposure, Question 1;
Targets - Sum of Questions 2,3,4,5,6)
NEARBY  POPULATION THREAT  SCORE:

(Likelihood of Exposure, Question 7;
Targets = Sum of Questions 8,9)
                                      LE X T X WC
                                        82,500
                                      LE X T X WC
                                        82,500
SOIL  EXPOSURE  PATHWAY SCORE:
Resident Population Threat + Nearby Population  Threat
                                                       (Maximum of 100)
                                     C-41

-------
AIR PATHWAY

Air Pathway Observed  Substances Summary Table

On SI Table 21, list the hazardous substances detected in air samples of a release from the site. Include
only those substances with concentrations significantly greater than background levels. Obtain
benchmark, cancer risk, and  reference dose  concentrations from SCDM. For NAAQS/NESHAPS
benchmarks, determine the highest percentage of benchmark obtained for  any substance.  For cancer
risk and reference dose, sum the percentages for the substances listed. If benchmark, cancer risk, or
reference dose "concentrations are not available for a particular substance, enter N/A for the percentage. If
the highest benchmark percentage or the percentage sum calculated for cancer  risk or reference dose
equals or exceeds 100%, evaluate targets in the distance category from which the sample was taken and
any closer distance categories as Level 1. If the percentages are less than 100°/0 or all are N/A, evaluate
targets in that distance category and any closer distance categories that are not Level I as Level II.
                                            C-42

-------
SI TABLE  21:   AIR PATHWAY OBSERVED RELEASE  SUBSTANCES




 Sample ID:	 Level I	  Level II	   Distance from Sources (mi)
                                                  References
Hazardous Substance





Cone, (u-g/m3)





Highest Toxicrty/
Mobility
Gaseous
Part icu late






Benchmark
Cone.
(NAAQS or
NESHAPS)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






 Sample ID:.
Level I
Level II
Distance from Sources (mi)
References
o
1
-p..
CO
Hazardous Substance





Cone. (u,g/m3)





Highest Toxicrty/
Mobility
Toxicity/
Mobility






Benchmark
Cone.
(NAAQS or
NESHAPS)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD






 Sample ID:.
Level I
Level II
Distance from Sources (mi)
References
Hazardous Substance





Cone. (u.g/m3)





Highest Toxicity/
Mobility
Toxicity/
Mobility






Benchmark
Cone.
(NAAQS or
NESHAPS)





Highest
Percent
% of
Benchmark






Cancer Risk
Cone.





Sum of
Percents
% of Cancer
Risk Cone.






RfD





Sum of
Percents
% of RfD







-------
                    AIR  PATHWAY WORKSHEET
LIKELIHOOD  OF RELEASE
Score
Data
Type  Refs
1 . OBSERVED RELEASE: If sampling data or direct observation
support a release to air, assign a score of 550. Record observed
release substances on SI Table 21 .
2. POTENTIAL TO RELEASE: If sampling data do not support a
release to air, assign a score of 500, Optionally, evaluate air
migration gaseous and paniculate potential to release (MRS
Section 6.1.2).
LR =








TARGETS
3. ACTUAL CONTAMINATION POPULATION: Determine the number
of people within the target distance limit subject to exposure from a
release of a hazardous substance to the air.
a) Level I: people x 10 =

4.
5.
6.
7.
8.
b) Level II: people x 1 =

Total =


POTENTIAL TARGET POPULATION: Determine the number of
people within the target distance limit not subject to exposure from
a release of a hazardous substance to the air, and assign the total
population score from Si Table 22. Sum the values and multiply the
sum by 0.1.
NEAREST INDIVIDUAL: Assign a score of 50 if there are any Level
I targets. Assign a score of 45 if there are Level II targets but no
Level I targets. If no Actual Contamination Population exists, assign
the Nearest Individual score from SI Table 22.
ACTUAL CONTAMINATION SENSITIVE ENVIRONMENTS: Sum
the sensitive environment values (SI Table 13) and wetland
acreage values (SI Table 23) for environments subject to exposure
from the release of a hazardous substance to the air.
Sensitive Environment Type




Wetland Acreage





Value




Value





POTENTIAL CONTAMINATION SENSITIVE ENVIRONMENTS:
Use SI Table 24 to evaluate sensitive environments not subject
exposure from a release.

to
RESOURCES: Assign a score of 5 if one or more air resources
apply within 1/2 mile of a source; assign a 0 if none applies.
Commercial agriculture
Commercial silviculture
• Major or designated recreation area
T =





















                               C-44

-------
    SI TABLE 22 (From MRS TABLE 6-17):  VALUES FOR POTENTIAL CONTAMINATION AIR TARGET

                                           POPULATIONS
o
1
-F*
Ol
Distance
from Site
On a
source
0 to 7 mile
>414
mile
>|to1
mile
>1to2
miles
>2to3
miles
>3to4
miles
Pop.







Nearest
Individual =
Nearest
Individual
(choose
highest)
20
*
2
1
0
0
0

Number of People within the Distance Category
1
to
10
4
1
0.2
0.06
0.02
0.009
0.005
11
to
30
17
4
0.9
0.3
0.09
0.04
0.02
31
to
100
53
13
3
0.9
0.3
0.1
0.07
101
to
300
164
41
9
3
0.8
0.4
0.2
301
to
1,000
522
131
28
8
3
1
0.7
1,001
to
3,000
1,633
408
88
26
8
4
2
3,001
to
10,000
5,214
1,304
282
83
27
12
7
10,001
to
30,000
16,325
4,081
882
261
83
38
28
30,001
to
100,000
52,137
13,034
2,815
834
266
120
73
100,001
to
300,000
163,246
40,812
8,815
2,612
833
375
229
300,001
to
1,000,000
521,360
130,340
28,153
8,342
2,659
1,199
730
1,000,000
to
3,000,000
1,632,455
408,114
88,153
26,119
8,326
3,755
2,285
Sum =
Pop.
Value








                                                      References
* Score = 20 if the Nearest Individual is within — mile of a source; score = 7 if the Nearest Individual is between - and—mile of a source.
                              o                                          o   4

-------
SI TABLE 23 (MRS TABLE
  6-18): AIR PATHWAY
 VALUES FOR WETLAND
        AREA
   SI TABLE 24:  DISTANCE WEIGHTS AND
CALCULATIONS  FOR AIR PATHWAY POTENTIAL
 CONTAMINATION  SENSITIVE  ENVIRONMENTS







o
*».
O>
Wetland Area
< 1 acre
1 to 50 acres
>50to 100 acres
> 100 to 150 acres
> 150 to 200 acres
> 200 to 300 acres
> 300 to 400 acres
> 400 to 500 acres
> 500 acres
Assigned
Value
0
25
75
125
175
250
350
450
500

Distance
On a Source
Oto 1/4 mile
1/4 to 1/2 mile
1/2 to 1 mile
1 to 2 miles
2 to 3 miles
3 to 4 miles
> 4 miles
Distance
Weight
0.10
0.025
0.0054
0.0016
0.0005
0.00023
0.00014
0
Sensitive Environment Type and
Value (from SI Tables 13 and 20)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Total Environments Score =
Product























-------
                            AIR  PATHWAY  (concluded)
WASTE  CHARACTERISTICS
9.    If any Actual Contamination Targets exist for the air pathway,
     assign the calculated hazardous waste quantity score or a score
     of 100, whichever is greater; if there are no Actual Contamination
     Targets for the air pathway, assign the calculated HWQ score for
     sources available to air migration.
10.  Assign the highest air toxicity/mobility value from SI Table 21.
11.  Multiply the air pathway toxicity/mobility and hazardous waste
     quantity scores.  Assign the Waste Characteristics score from the
     table below:
Product
0
>0to<10
10 to <1 00
100to<1,000
1 ,000 to < 10,000
10,OOOto<1E + 05
1E + 05to<1E + 06
1E + 06to<1E + 07
1E + 07to<1E + 08
1E + 08 or greater
WC Score
0
1
2
3
6
10
18
32
56
100
                                                              WC  =
AIR  PATHWAY SCORE:
LE x  T x  WC
    82,500
                                                                     (maximum of 100)
                                          C-47

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SITE SCORE CALCULATION
GROUND WATER PATHWAY SCORE (Sow)
SURFACE WATER PATHWAY SCORE (S8W)
SOIL EXPOSURE (Ss)
AIR PATHWAY SCORE (SA)
S





^ /Sew2+Ssw2+Ss2+SA2
Siilt SUUMt ^. .,..,..- 	 '"A
a
S2





COMMENTS
                            C-48

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                                  APPENDIX  D
                      SI NARRATIVE  REPORT (EXAMPLE)

  This appendix provides an example of a narrative report for a SI at a fictitious site, following the
  form  and  content discussed in Chapter 6. Note that  this guidance example does not include
  reproductions of reference material, full-size TJSGS topographic quadrangle maps, site photographs
  and accompanying photodocumentation log, or other applicable attachments.
                      SITE INSPECTION NARRATIVE REPORT
                               PALMETTO LANDFILL
                      PALMETTO COUNTY, SOUTH CAROLINA
                               TDD NO. Y9-87912-43
                                JANUARY 29, 1992
                                 XYZ Corporation
Prepared By                 Reviewed By                       Approved By
Joseph Brown               Lucy Pauling                       Maria Gomez
Project Manager             Project Coordinator                  Regional Project Manager
                                       D-1

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Appendix D:  SI Narrative Report (Example)                             Site inspection Guidance
                                            CONTENTS
   1.       Introduction	  3
   2.       Site Description	  3
           2.1     Location	  3
           2.2     Site Description	  3
           2.3     Operational History and Waste Characteristics	  6
   3.       Waste/Source Sampling	  6
           3.1     Sample Locations	  6
           3.2     Analytical Results	  6
           3.3     Conclusions	10
   4.       Ground Water Pathway	10
           4.1     Hydrogeology	10
           4.2     Targets	12
           4.3     Sample Locations	12
           4.4     Analytical Results  	12
           4.5     Conclusions	14
   5.       Surface Water Pathway	 14
           5.1     Hydrology  	 14
           5.2     Targets  	14
           5.3     Sample Locations	15
           5.4     Analytical Results	15
           5.5     Conclusions	15
   6.       Soil Exposure and Air Pathways	15
           6.1     Physical Conditions	15
           6.2     Soil and Air Targets  	15
           6.3     Soil Sample Locations	16
           6.4     Soil Analytical Results	16
           6.5     Air Monitoring	16
           6.7     Conclusions	16
   7.       Summary and Conclusions 	 16

           References	19
   Table 1:         Sample Collection   	7
   Table 2         Field Measurements for Ground Water Samples	12
   Table 3:         Part 1:  Analytical Results for A queous Samples	17
                   Part 2: Analytical Results for Non-Aqueous Samples	18

   Figure 1:        Site Location Map	   4
   Figure 2:        Site Layout 	  5
   Figure 3:        SI Sample Locations	   9
   Figure 4:        Well Log From 19 Palmetto Lane   	11
   Figure 5:        SI Ground Water Sample Locations	  13
                                                 -2-
                                                 D-2

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Site Inspection Guidance                              Appendix D: SI Narrative  Report (Example)
   Date:           January 29,1992

   Prepared by:    Joseph Brown, XYZ Corporation,
                  Region 4, Atlanta, Georgia

   Site:           Palmetto Landfill, 6250 Palmetto Drive
                  Palmetto County, South Carolina

   EPA ID No.:    SCD123456789

   TDD No.:       Y9-8765-43

   1.      INTRODUCTION

   Under authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
   (CERCLA) and the Superfund Amendments  and Reauthorization Act of 1986  (SARA),  the  U.S.
   Environmental Protection Agency (EPA), Waste Management Division, Region 4 conducted a site inspection
   (SI) at the Palmetto Landfill Site near Angleton in Palmetto County, South Carolina. The purpose of this
   investigation was to collect information concerning conditions at the Palmetto Landfill sufficient to assess the
   threat posed to human health and the environment and to determine the need for additional investigation under
   CERCLA or other authority, and, if appropriate, support site evaluation using the Hazard Ranking System
   (HRS) for proposal to the National Priorities List (NFL). The investigation included reviewing previous
   information, sampling waste and environmental media to test preliminary assessment (PA) hypotheses and
   to evaluate and document HRS factors, collecting additional non-sampling information, and interviewing
   nearby residents.

   2.      SITE DESCRIPTION

   2.1     Location

   Palmetto Landfill is located at 6250 Palmetto Drive in a rural area of Palmetto County, South Carolina,
   approximately 1.5 miles east of the town of Angleton (Figure 1). The geographic coordinates are 18°28'43"N
   latitude and 66°07'33"W longitude (Reference 1).

   Palmetto County is characterized by a mild, temperate climate. Summers are warm and humid with  daily
   temperatures reaching 90° F or higher. Daily high temperatures during winter are 55° to 60° F. Net annual
   precipitation  for the area is  10.87 inches (Reference 2, pp. 7, 10).

   2.2     Site  Description

   The site property covers  approximately 10 acres, approximately 6 acres of which were used for landfilling
   of wastes  (Reference 3). The landfill is located on relatively flat terrain that slopes gently toward the
   northeast boundary (Reference 4) and Wildlife Creek, a small, slowly flowing stream (Reference 5, p.  124).
   The landfill is rectangular in shape and bordered on three sides  by a drainage ditch approximately 8 to 10 feet
   deep and on the fourth side by Wildlife Creek (Reference 3) (Figure 2).

   The original purpose of the ditch was to intercept ground water upgradient of the site and direct it around the
   buried waste (Reference 3). However, because the ditch is less than 10 feet deep and the surficial  aquifer
   is approximately 25 feet deep, the ditch does  not completely transect the aquifer. Also, because the  ditch

                                                  -3-
                                                 D-3

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Appendix D: SI Narrative Report (Example)
Site Inspection Guidance
                          FIGURE 1: SITE LOCATION MAP
                              PALMETTO LANDFILL
                                           Palmetto Landfill
                           ^^J-/1'^"'''^--"***.*
                                      -4-
                                     D-4

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FENCE
WETLANDS
HEAVY VEGETATION
DITCH
PROBABLE POINT OF ENTRY
DRINKINQ WATER WELL
DIRT ROAD (PRIVATE)
DIRECTION OF STREAM FLOW
                               Q-     •«
                          PALMETTO UNOFIU
                                       €3
Site Sketch (Not to Scale)
Palmetto County Landfill
Palmetto County. South Carotin
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Appendix D: SI Narrative Report (Example)                              Site Inspection Guidance
   intersects the top of the local water table, it perennial y flows. The ditch creates a barrier to runoff from areas
   upgradient of the site. Along the banks of the ditch there is evidence of stressed vegetation. Water in the
   eastern segment of the ditch where leachate is draining from the landfill is an orange-brown color and oily
   in appearance (Reference 4).

   No buildings or other structures are on the property. The perimeter of the facility is fenced, the fencing
   appears to be in good condition, and there  is a locked entrance gate across the access road to the site
   (Reference 4; Reference 7, p. 3). The drainage ditch is located outside of the fenced facility.

   2.3     Operational History and Waste Characteristics

   Smith and Moore Disposal Services, 1111 Main Street, Angleton, South Carolina, owns the ten-acre property.
   Landfill operations began in April 1970 for disposal of municipal garbage and household debris. Beginning
   in October 1978, the landfill accepted industrial waste on a  limited basis, Smith and Moore kept no formal
   records of the amounts and types of wastes received. However, there is evidence indicating that the landfill
   received a one-time shipment of approximately 500 gallons of trichloroethylene (TCE) waste (Reference 3).
   The common practice of disposal at Palmetto Landfill was to excavate trenches 7 to 10 feet deep, fill the
   trenches with waste material, and emplace a daily cover of soil. Landfilling operations were discontinued in
   July 1980 when the landfill reached capacity. Upon closure, a 2-foot soil cover was  placed over the entire
   landfill and seeded (Reference 3).

   The soil cap is in relatively good condition except in two places where it appears to have been breached and
   a small depression is filled with a black sludge-like material  (Reference 6). Approximately 200 feet  northwest
   of this depression  is an area where vegetation is brown and dying (Reference 6).

   Palmetto Landfill operated under permit Number 999-999 issued by the South Carolina Department of Health
   and Environmental Concerns (SCDHEC). SCDHEC inspected the landfill when it closed and have  inspected
   it several times at irregular intervals. No previous sampling or remedial action is known to have taken place
   at Palmetto Landfill (Reference 7).

   3.      WASTE/SOURCE SAMPLING

   3.1     Sample Locations

   Table 1 presents sample numbers, locations, and objectives for all samples collected during the  SI. Four
   waste/source samples were collected (Figure 3):

     •     Two  from the landfill surface, one in the small, wet depression and the other 200 feet northwest of
           the depression in an area of stressed vegetation.

     •     Two from the drainage ditch where leachate appeared to be leaking out of the site and  entering
           surface water.

   3.2     Analytical Results

   Sample PL-WS-1, collected from the black sludge material, exhibited estimated concentrations of  TCE and
   chlorobenzene. Aldrin, a chlorinated pesticide, also was identified in sample PL-WS-1 at 560 ppb and in
   sample PL-WS-2 at 75 ppb. Background soil sample PL-SS-2 contained none of these substances. Samples
   PL-WS-3 and PL-WS-4D exhibited the greatest  number of contaminants found at the site.  Benzene,

                                                  -6-
                                                  D-6

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Site Inspection Guidance
Appendix D: SI Narrative Report (Example)

TABLE 1: SAMPLE COLLECTION
Sample
Number
PL-WS-1
PL-WS-2
PL-WS-3
PL-WS-4D
PL-GW-1
PL-GW-2D
PL-GW-3
PL-GW-4
PL-GW-5
PL-GW-6
PL-GW-7
PL-GW-8
Sample
Type
Waste
material
Surficial
soil
Aqueous
waste
Aqueous
waste
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Location
Waste sample collected at depth of 0.5' from
landfill depression to determine types and
concentrations of hazardous substances onsite.
Soil sample collected at depth of 0.5' from area
of stressed vegetation to determine types and
concentrations of hazardous substances onsite.
Leachate sample collected from east side of
perimeter ditch to determine types and
concentrations of hazardous substances onsite
and to investigate release to surface water.
Duplicate of PL-WS-3.
Sample collected from private well approx. 300'
south of landfill to investigate release and target
contamination.
Duplicate of PL-GW-1.
Sample collected from private well approx. 1 ,000'
southeast of landfill to investigate release and
target contamination.
Sample collected from private well 1 ,000' east of
landfill to investigate contamination.
Sample collected from private well 1 ,000' north of
landfill to investigate contamination.
Sample collected from private well 1,200' north of
landfill to investigate contamination.
Sample collected from private well 1 ,200' north of
landfill to investigate contamination.
Field blank
Date
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
Time
1400
1445
1500
1530
1600
1630
1430
1300
1130
1000
0830
0730
-7-

                                           D-7

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Appendix D: SI Narrative Report (Example)
Site Inspection Guidance

TABLE 1: SAMPLE COLLECTION (Continued)
Sample
Number
PL-SD-1
PL-SD-2
PL-SD-3
PL-SD-4D
PL-SD-5
PL-SD-6
PL-SD-7
PL-SS-1
PL-SS-2
Sample
Type
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Surficial
soil
Surficial
soil
Location
Sample collected approx. 1,100' downstream of
Wildlife Creek in wetland.
Sample collected approx. 600' downstream of
Wildlife Creek in wetland.
Sample collected at southern intersection of
perimeter ditch with Wildlife Creek in fishery.
Duplicate of PL-SD-3.
Sample collected at northwest intersection of
perimeter ditch with Wildlife Creek in fishery.
Sample collected approx. 1 00' upstream from
northwest intersection of perimeter ditch and
Wildlife Creek.
Sample collected approx. 200' upstream from
northwest intersection of perimeter ditch and
Wildlife Creek.
Sample collected at depth of 1.5' approx. 300'
southwest of landfill from property of nearest
residence; investigate presence of hazardous
substances in residential property.
Sample from offsite location in native soil.
Date
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
9/4/91
Time
0830
0900
1000
1030
1130
1200
1230
1400
1500
-8-

                                          D-8

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                                                                                                                   5:
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                                                                               FENCE

                                                                               WETLANDS

                                                                               HEAVY VEGETATION

                                                                               DITCH

                                                                               PROBABLE POINT OF ENTRY

                                                                               DRINKING WATER WELL

                                                                               DIRT ROAD (PRIVATE)

                                                                               DIRECTION OF STREAM FLOW

                                                                               SAMPLE LOCATIONS
                  NV

                    V s
            PL-88-1     X\

NEAREST RESIDENCE & WELL
SI SAMPLE LOCATIONS

PALMETTO LANDRLL

PALMETTO COUNTY. SOUTH CAROLINA
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Appendix D: SI Narrative  Report (Example)                              Site Inspection Guidance
   chloroethane, 1,1-dichloroethane, ethylbenzene, and aldrin were found in elevated levels in leachate samples.
   TCE was detected in leachate samples (PL-WS-3 and PL-WS-4D) at concentrations greater than three times
   the detection limit. Several metals were detected at elevated levels, most notably arsenic, lead, chromium,
   and mercury. Toluene and bis(2-ethylhexyl)phthalate, detected in all of the waste source samples, are
   common laboratory  contaminants.

   3.3     Conclusions

   While the landfill was permitted to accept municipal waste, it also accepted industrial wastes on a limited
   basis beginning in 1978. There are also allegations of a one-time shipment of TCE waste material being
   depsited at the Palmetto site. Wastes were deposited by a trench method. There are no records of a liner
   or leachate collection system.   While the cap appears to be in good condition, two areas exist where the
   integrity of the cap appears compromised. Elevated levels of organic and inorganic compounds were detected
   in samples obtained from breaches in the soil cap and from leachate discharging directly to the drainage ditch.

   4.      GROUND  WATER PATHWAY

   4.1     Hydrogeology

   Palmetto  County is in the Lower Coastal Plain Physiographic Province. Geologically, this area is
   characterized by a wedge of overlapping strata that increase in thickness towards the coast. Pleistocene
   terrain deposits underlie the Palmetto County area. These deposits include the following formations (from
   youngest to oldest):  Jacksonville, Charleston, Peerless, and Jacob. These formations were deposited from
   the transgressive/regressive sequences of a glacially controlled Pleistocene  sea  (Reference  8, p. 12).
   According to local well logs, the Jacksonville, Charleston and Peerless formations are the only Pleistocene
   strata underlying the vicinity of Palmetto Landfill (Reference 9; Reference 10).

   The Jacksonville Formation (5 to 25 feet thick) is composed of fine-grained sand and shell with interfingering
   layers of silt and clay. This formation is the only water supply aquifer for rural residents not served by a
   municipal system. The water is produced under water table conditions at a rate of 25 to 100 gallons per
   minute (Reference 8, p. 14).

   The Charlestown Formation consists of a sandy phosphatic limestone that has altered to a clayey, fine-grained
   dolomite at depth. The formation is considered to be a confining unit and is 25 to 45 feet thick in the
   southern Palmetto County area (Reference  8, p. 16).

   The Peerless Formation is a porous, dark gray, fine-grained, fossiliferous limestone. This unit,  approximately
   45 to 60 feet thick, is under artesian conditions and produces brackish water.

   Beneath the limestone is the Jacob Formation (60  to 105 feet thick) consisting of sand, silt, and clay. The
   Jacob Formation also produces brackish water (Reference 8, pp. 17-19).

   Precipitation is the primary type of recharge to the Jacksonville Formation. Discharge is by wells, natural
   seepage, and evapotranspiration. Water flow in this aquifer varies from area to area as water moves by
   gravity from high to low elevations. Depth to ground water varies from  3 to 15 feet below land surface in
   Palmetto County (Reference 8, p. 15). At Palmetto Landfill, the depth to ground water is approximately 10
   feet, as determined from a well log of a nearby drinking water well (Figure 4) (Reference 9; Reference 10).
                                                  -10-
                                                  D-10

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Site Inspection Guidance
   Appendix D: SI Narrative Report (Example)
                        FIGURE 4:  WELL LOG FROM 19 PALMETTO LANE
                  10
                  20 -
                  30
                   40
50—i
                    60
                         /   /   /
                            /    /
                               TD = 64'
                                                   Surface Sofl

                                                   Weathered, red, sandy, roots,
                                                   shells
                                                   Jacksonville Formation (top of water table)

                                                   RIM  grained,  well  sorted,
                                                   unconsoiidated sand, scattered
                                                   shells, thin layers of silt and
                                                   day
                                                   Completed interval:  10 -  28*
                                                   Produced 75 GPM (initial test)
                                                   Chariestown Formation

                                                   White to gray, dense limestone,
                                                   no visible porosity
                                                   Limestone tmerfingering with
                                                   dolomite
Dark  gray   dolomite,
fossiliferous,  moidic porosity.
does  not   appear   to   be
permeable

Peerless Formation
Dark   gray,   fossiliferous
limestone, dense, no  visible
porosity
                                                 -11-
                                                 D-11

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Appendix D: SI Narrative Report (Example)                              Site Inspection Guidance
   4.2     Targets

   Most people within 4 miles of Palmetto Landfill obtain drinking water from a reservoir operated by the
   Palmetto County Water Authority (PCWA). The reservoir is located on the Ono River about 35 miles west
   of Angleton. Three municipal water systems within 4 miles purchase water from PCWA. Discussions with
   PCWA officials, reconnaissance of the area, and topographic maps  have identified residences without
   municipal water service. These residences obtain drinking water from private wells completed in the
   Jacksonville Formation (Reference 6, p. 11; Reference 12).

   Approximately 239 homes within 4 miles use private wells for drinking water (Reference 12). At 2.7 persons
   per household (the average for Palmetto County), this equates to 645 residents (Reference 13). The nearest
   residence relying on a private well is approximately 300 feet to the west of the landfill (Reference 6, p. 10).
   Within 0.25 mile of the landfill are six residences relying on private wells (Reference 6, p. 10).

   There are no wellhead protection areas  (WI-PA) designated within Palmetto County.

   4.3     Sample Locations

   Ground water samples were collected from the six private wells, all within 0.25 mile of the site, regarded as
   primary targets during the PA. A duplicate sample was collected from the nearest well. A field blank was
   collected  to detect possible container contamination. Table 1 presents  sample numbers, descriptions, and
   objectives. Figures 3 and 5 show sample locations. Table 2 presents field measurements
              TABLE 2: FIELD MEASUREMENTS FOR GROUND WATER SAMPLES

                   Sample        Sample       pH           Temperature    Conductivity
                   Number       Depth (ft)                   °C            mmhos/cm
                   PL-GW-1       10           5.8           23.5          650
                   PL-GW-2D   10           5.6           23.0          550
                   PL-GW-3      8            6.5           24.0          700
                   PL-GW-4      7            7.2           23.0          480
                   PL-GW-5      11           6.5           22.0          500
                   PL-GW-6      11           6.3           22.5          355
                   PL-GW-7      10           6.6           23.5          250


   4.4     Analytical Results

   The nearest drinking water well samples (PL-GW-1 and PL-GW-2D) contained vinyl chloride, TCE, and
   benzene in highly elevated concentrations. While vinyl chloride was not detected in any source sample, it
   is a degradation product of TCE, a substance deposited at the site. TCE also was detected at estimated levels
   in samples PL-GW-4 and PL-GW-3, which also exhibited estimated concentrations of vinyl chloride and
   chrysene.
                                                 -12-
                                                 D-12

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Site Inspection Guidance
Appendix D: SI Narrative Report (Example)
                 FIGURE 5: SI GROUND WATER SAMPLE LOCATIONS

                              PALMETTO LANDFILL
                                          Palmetto Landfill .^.
                                             ,   ... PL-GW-4 .--I'.p^
                          PL-GW-1  PL-GW-2D   '

                                   /  )  '-s    ;- -_  • -..r
                                      -13-
                                      D-13

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Appendix D: SI Narrative Report (Example)                              Site Inspection Guidance
   Ethylbenzene was detected in low concentrations in samples PL-GW-5, PL-GW-6, and PL-GW-7. This
   substance, a component of gasoline, could have come from other offsite sources.

   Toluene or bis(2-ethylhexyl)phthalate was detected in all samples except PL-GW-4. Toluene also was
   detected in the field blank, sample PL-GW-8. These compounds are common laboratory contaminants and
   could have resulted from laboratory procedures.

   Arsenic, cadmium, lead, and chromium were detected at elevated concentrations in PL-GW-1 and PL-GW-2D.
   All of these hazardous substances were found in the waste/source samples. Zinc was detected in all samples
   except PL-GW-6.

   4.5     Conclusions

   Due to the lack of any ground water containment system at the landfill, the disposal methods used at the site,
   and the high water table of the uppermost drinking water aquifer, contaminants could migrate into ground
   water at this site. Nearby drinking water wells contain hazardous substances similar to those found in samples
   taken from the source, indicating a release to ground water. The primary source of drinking water for rural
   domestic users in the area is the shallow aquifer.  Samples from the nearest well, located 300 feet from the
   site, exhibited elevated levels of organic and inorganic compounds.

   5.      SURFACE WATER PATHWAY

   5.1      Hydrology

   Palmetto Landfill is bordered on three sides by a perennially flowing drainage ditch.  The ditch also creates
   a localized drainage basin coincident with the 10-acre landfill. Leachate flows from the landfill and enters
   the ditch approximately 250 feet from where the ditch runs into Wildlife Creek. Overland drainage from the
   site flows northeast approximately 250 feet into Wildlife Creek, which has an average flow rate of 5 to 10
   cubic feet per second (cfs). Wildlife Creek flows approximately 3.0 miles and enters Ono River (Reference
   1), which has an average flow of 1,000  cfs (Reference 5, p.  132). Approximately 16 miles downstream the
   Ono River merges with the East River (Reference 5, p. 150).

   5.2     Targets

   No drinking water intakes are within  15 downstream miles of the site. Most residents are  served by a
   reservoir 35 miles upstream of Palmetto Landfill. Residents not served by a municipal system obtain drinking
   water from private wells (Reference 11).

   Wildlife Creek and Ono River are  used for recreational fishing. Aquatic species commonly caught include
   wide mouth bass, shrimp, crabs, and clams. Recreational crawfish fishing occurs in Wildlife Creek and the
   surrounding wetlands (Reference 14, pp. 13,15).

   Numerous wetlands are within 15  downstream miles of the site. The nearest wetland (approximately 250
   acres, 0.5 mile frontage) is approximately 0.1 mile downstream from the site on Wildlife Creek (Reference
   1). No other sensitive environments are within 15 downstream miles of the site (Reference 15).
                                                 -14-
                                                 D-14

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Site Inspection Guidance                              Appendix  D:  SI Narrative Report (Example)
   5.3      Sample  Locations

   Samples were collected at all surface water targets identified as primary targets during the PA, with the
   exception of two  sensitive environments. The habitats of two Federally designated endangered species, the
   Bald Eagle and the Salt Marsh Harvest Mouse, were considered primary targets during the PA because they
   are known to be found in Palmetto County. However, the SI found that these sensitive environments do not
   exist in the surface waters (within 15 downstream miles) near the palmetto landfill.

   Seven sediment samples were collected to evaluate the surface water pathway. Table 1 presents sample
   numbers, descriptions, and objectives sample locations are shown in Figure 3. The seven samples are

    •      Two samples upstream from the site in Wildlife Creek to determine background levels,

    •      Three from Wildlife Creek at points where the drainage ditch intersects the creek to evaluate the
           impact of the site on the fishery one from the northwest intersection point and two from the
           northeast intersection point.

    •      Two within the wetland to investigate contamination.

   5.4      Analytical Results

   Downstream sediment samples collected at the northeast intersection  (PL-SD-3 and PL-SD-4D) contained
   elevated concentrations of several hazardous substances. Aldrin, arsenic, chromium, and lead were detected
   at concentrations significantly greater than those found  in the background samples (PL-SD-6 and PL-SD-7).
   In general, very few organic compounds were found in the sediment samples. Most of the substances were
   detected at estimated concentrations. Mercury was detected at an estimated level in sample PL-SD-5.

   5.5      Conclusions

   A release of hazardous substances  from the site into  the drainage ditch was evidenced by the elevated
   concentrations of TCE, arsenic, chromium, and lead in the leachate  sample (PL-WS-3 and PL-WS-4D).
   Analytical results suggest that these hazardous substances are migrating from the landfill  into Wildlife  Creek
   via the drainage ditch.  Wildlife Creek is used for  recreational fishing. Samples collected from the
   downstream wetland indicate that it has not been impacted by the site at this time.

   6.       SOIL EXPOSURE AND AIR PATHWAYS

   6.1      Physical Conditions

   When the site was closed in 1980, Palmetto Landfill was covered by 2 feet of clean soil and seeded. A chain
   link fence was installed around the site (Reference 3). The site is currently heavily vegetated by grass, weeds,
   and shrubs (Reference 4; Reference 7, p. 2). There is a locked gate across the road to the landfill (Reference
   6, p. 2).

   6.2     Soil and Air Targets

   There are no workers at Palmetto landfill. No people live on Palmetto Landfill. The nearest residence is 300
   feet to the west, and the nearest school is 0.5 mile to the north (Reference 6, p. 10). Six residences are within
   0.25 mile of the site; the total population within 4 miles of the site, as determined by visual observations,

                                                 -15-
                                                 D-15

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Appendix D: SI Narrative Report (Example)                              Site Inspection Guidance
   topographic maps, and the GEMS data base, is 7,989 people (Reference 1; Reference 7, p. 10; Reference 14).
   A 250-acre wetland is located on Wildlife Creek approximately 0.1 mile from Palmetto Landfill. The critical
   habitat of the Bald Eagle is within 3 to 4 miles from the site; however the precise location cannot be
   determined (Reference 15).

   6.3      Soil Sample Locations

   Two samples were collected to investigate the soil exposure pathway—one sample from the property of the
   nearest residence approximately 300 feet from the site, and the other offsite to establish ambient conditions.

   Table 1 presents sample numbers, descriptions, and objectives. Figure 3 shows soil sample locations.

   6.4      Soil Analytical  Results

   Lead was  detected in slightly elevated concentrations at the nearest residence (PL-SS-1).

   6.5      Air Monitoring

   Portable air quality monitors (OVA and HNu) were carried onsite during the SI. No measurements above
   background were detected. No formal air monitoring program was conducted.

   6.6      Conclusions

   The site is located in a sparsely populated rural area. The nearest residence is approximately 300 feet
   southwest of the site, and approximately 7,989 persons live within 4 miles. Them was no indication of a
   release to the  air pathway.   No hazardous substances were detected in the residential soil sample at
   concentrations significantly greater than background levels.

   7.      SUMMARY AND CONCLUSIONS

   The Palmetto Landfill SI attempted to gather data necessary to evaluate the site as a candidate for the NPL.
   Waste and environmental samples were collected and analyzed to characterize the types of substances
   deposited  at the site and potential migration pathways. In addition, information was collected to confirm
   target populations and environments potentially at risk from the site.

   Palmetto Landfill accepted an unknown quantity of municipal and industrial waste,  including approximately
   500 gallons of TCE waste. Wastes were deposited in unlined trenches 7  to  10 feet deep. Landfilling
   operations ceased when the landfill reached  capacity in 1980. The landfill was then covered with 2 feet of
   soil and seeded. A chain link fence also was installed.

   The SI indicated contamination at the landfill and in leachate discharging from the landfill to the drainage
   ditch at the perimeter of the site.  Analytical results of sampling are presented  in Table 3.  Hazardous
   substances related to site wastes were detected in the nearest drinking water well. The substances found in
   the  drinking water wells include TCE, vinyl chloride, arsenic, chromium,  and lead. Other downgradient wells
   also may be contaminated.

   Evidence of releases from the site was found in surface water sediment samples. Sediment samples collected
   where the drainage ditch discharges into Wildlife Creek had elevated concentrations of several inorganic
   compounds, including, arsenic, chromium, and lead.

                                                 -16-
                                                 D-16

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SUBSTANCE
ORGANICS, ug/l
Vinyl Chloride
Chkxoethane
Trichkxoethytene
Benzene
Toluene
Bis(2-ethyl-
hexyl)phthalate
1,1-Dichloroethane
Chkxobenzene
Ethybenzene
Chrysene
Aldrin
INORGANICS, ug/l
Aluminum
Arsenic
Cadmium
Chromium (VI)
Iron
Lead
Mercury
Zinc
J

TABLE 3 (PART 1): ANALYTICAL RESULTS FOR AQUEOUS SAMPLES
PL-WS-3 PL-WS-4O PL-GW-1 PL-GW-2D PL-GW-3 PL-GW-4 PL-GW-5 PL-GW-6 PL-GW-7 PL-GW-8

—
4J
19
10
15
32
5
—
17J
—
2J

6,100
31
5
6.5J
9,000
10
0.2J
60
Material analyzed for but
Estimated value


_ 4J 5 U — — — — —
£ 	 	 	 	 	 	 	 	
15 7.5 4J 2J U — — — —
9 2.6 3.1 — — 5J — —
20 3 5 — 4J — 3 — 2J
14J 4 2 5J — 2 2 3J —
8
„. ___ __ „„_ 	 	 ___ At — _
323J1J — — 2J2J5J —
~-- 2J
7 - - _ _ _ _

4,000 28,000 26,000 1.500J 13,000 15,000 5,300 2,600
26 10 6 —
3 2J 4.2
5.5 12 20J 20 14 5J
9,000 8,400 12,000 2,200 4,900 7,800 32,000 22,000
15 6.2 8.1 5J 10J 2J 5 —
Q 2 	 	 	 	 	 	 	 	
50 32 45 40 15 22J — 5J
not detected above minimum quantitation limit
-18-
ttetection
Limit
CRQL
10
10
10
10
10
10
10
10
10
10
0.05
CRDL
200
10
5
10
100
3
0.2
20


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 5"

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-------
0


CO
SUBSTANCE
ORGANICS, ug/kg
Vinyl Chloride
Chkxoethane
Trichkxoethylene
Benzene
Toluene
Bis<2-ethyl-
hexyl)phthalate
1,1-DicNoroethane
Chtorobenzene
Ethybenzene
Chrysene
Aldrin
INORGANICS
Aluminum
Arsenic
Cadmium
Chromium (VI)
Iron
Lead
Mercury
Zinc
J

TABLE 3 (PART 2):
PL-WS-1 PL-WS-2 PL-SD-1
.„ 	 	
_ _ _
3J — —
— — —
40 9 —
19 13 —
_ _ _
10J — —
5 .„ ,,_
_ _ _
560 75 —

25,000 4,000 3,000
10 — —
15 2J —
29 13 2.6
3,100 2,900 2,500
3QQ 	 	
0.1 — —
64 54 —
ANALYTICAL RESULTS FOR NON-AQUEOUS SAMPLES
PL-SD-2 PL-SD-3 PL-SD-4D PL-SD-5 PL-SD-6 PL-SD-7 PL-SS-1 PL-SS-2 Detection
Umit
„_ 	
— —
- 5J
5J -
— 5J
— —
— —
— —
_ _
— 5J
— 35

4,200 5,500
— 2.4
- 5J
4 29
13,000 12,000
— 14
_ _
5 50
	 	
— —
4 —
— —
5J —
— —
— —
— —
— 5J
7J —
42 —

2,900 3,000
4J —
U 0.5J
37 14
9,500 5,700
8.9 2.5J
— 0.2J
35 25
CRQL
— — — — 10
	 „„. •*/*
___ — » m
_ _ _ _ 10
— — — — 10
330
1A
__ — — — m
— — — _ 10
— — — — 10
— — — — 330
- - - 1.7
CRDL
3,000 1,800 2,600 8,900 200
— _ — — 10
5
5 3 6 3.3 10
4,500 1,500 3,500 6,200 100
0.3J 0.3J 4 3 3
— — — — 0.2
— 5J 5.4 7 20
Material analyzed lor but not detected above minimum quantitation limit
Estimated value


-19-

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Site inspection Guidance                             Appendix D: SI Narrative Report (Example)
   REFERENCES

   1.       U.S. Geological Survey, 7.5-minute topographic quadrangle maps of South Carolina Angleton, 1963,
           photo revised  1983; Palmetto, 1975; Winchester, 1975; Danvers, 1963.

   2.       U.S. Department of Commerce, 1983. "The Climatic Atlas of the United States."

   3.       Jennifer Doe,  Manager for Smith and Moore Disposal Services, telephone conversation with Joe
           Brown, XYZ Corporation, May 1, 1991. Re: Waste Disposal Practices at Palmetto Landfill.

   4.       Joseph Brown, XYZ Corporation, Photodocumentation Log of Palmetto Landfill Preliminary
           Assessment, May 7, 1991.

   5.       A.P. Park, The Surface Water Resources of Palmetto County, South Carolina. South Carolina Water
           Resources Commission Report No. 101B.

   6.       Joseph Brown, XYZ Corporation, Field Logbook for Offsite Reconnaissance of Palmetto Landfill,
           TDDY9-8765-43,  May 1991.

   7.       John Hill, Technician for South Carolina Department of Health and Environmental Concerns,
           telephone conversation with Joe Brown, XYZ Corporation, May 2,1991. Re: Remediation and
           sampling at Palmetto Landfill.

   8.       J.P. Adams, The Ground Water Resources of Palmetto County, South Carolina. South Carolina
           Water Resources  Commission Report No. 99A, 1982.

   9.       Donna Johnson, Driller for Joe Blow Drilling Co., telephone conversation with Joe Brown, XYZ
           Corporation, May 1, 1991. Re:  Palmetto County Drilling.

   10.      Johnson Drilling Company, J.J. Jones Residential Well Log, March 25, 1984.

   11.      Mark Allen, Technician for Palmetto County Water Authority, telephone conversation with Joe
           Brown, XYZ Corporation, May 2, 1991. Re: Palmetto County Municipal Water  Systems.

   12.      Palmetto County Water Authority, Municipal Water Supply Distribution Map, April 1991.

   13.      U.S. Department of Commerce,  Bureau of Census, 1990 Census of Population and Housing, South
           Carolina.

   14.      A.J. Houston, South Carolina Guide to Recreational Hunting and Fishing, South Carolina Department
           of Natural Resources, Wildlife and Game Division Report Number A22, 1975.

   15.      U.S. Fish and Wildlife Service, 1980. Atlantic Coast Ecological Inventory Maps, Palmetto County
           Panels.

   16.      U.S. Census Bureau, Geographical Exposure Modeling System  (GEMS) Database, South Carolina,
           1990.
                                                 -19-
                                                D-19

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                                    APPENDIX  E

                                 EQUIPMENT LIST
This appendix suggests an inventory of expendable and non-expendable equipment that generally
may support SI field and sampling activities. The list is provided as a possible starting point for
a field office to  develop  a checklist of equipment for  site  assessment activities.  Note that  each
item of equipment listed here is not required for every SI, nor does this list include every  piece of
equipment that may be needed for a particular SI. SI investigators should consult the Regional
site assessment program for equipment guidelines.
                                          E-1

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Appendix E: Equipment List                                           Site Inspection Guidance

                                EXPENDABLE  EQUIPMENT

Item                                        Quantity Packaged                     Amount  Required

CHEMICALS
Acetone                                     5 gal.
Acetone                                     1 gal.
Trichloroethane                               5 gal.
Trichloroethane                               1 gal.
Methylene-chloride                            5 gal.
Methylene-chloride                            1 gal.
Hexane                                      1 gal.
Gasoline                                     1 gal.
Gasoline                                     5 gal.
Nitric Acid                                   1 gal.
Nitric Acid                                   5 ml.
Sodium Hydroxide                            1 liter
Motor Oil                                    1 qt.
2-Cycle Oil                                  !/2 pt.
Alconox                                     1 gal.
Baking Soda                                 2 Ib. box

SAMPLE CONTAINERS

40 ml. VOA Bottles                           1 each
!/2 gal. Amber Bottle                           1 each
1 liter Amber Bottle                           1 each
8 oz. Glass Jars                               1 each
1 liter Plastic Bottles                           1 each
Plastic Bags 8" x 12"                          100 box
Plastic Bags 10 x 12"                         100 box
Plastic Bags 12 x 20"                         100 box
Paint Cans w/lid & snaps                       1 gal.
Paint Cans w/lid & snaps                       1A gal.
Paint Cans w/lid & snaps                       1 qt.
Vermiculite                                  4 cu. ft.

BOOTS

Butyl Rubber Boots
Hip Boots (Size ??)
Latex Boot Covers
Tyvek Boot Covers

GLOVES

Neoprene
Viton
Butyl Rubber
Cotton Work
Latex
                                               E-2

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Site Inspection Guidance                                           Appendix E: Equipment List

                        EXPENDABLE EQUIPMENT (Continued)

Item                                        Quantity Packaged                    Amount Required

GLOVES  (Continued)
Leather Work
P.V.C. Surgical

CHEMICAL RESISTANT COVERALLS

Tyvek SM
Tyvek MED
Tyvek LG
Tyvek XLG
Tyvek XXLG
Saranex SM
Saranex MED
Saranex LG
Saranex XLG
Saranex XXLG

SAMPLE  TUBES

Glass Tube .5 mm x 300 mm                    1 each
Glass Tube 1 mm x 300 mm                    1 each
P.V.C. Tube 2" X 10'                          1 each
P.V.C. Tube 4" X 10'                          1 each

FILM

C-135-36-100-Prints                            1 roll
C-135-36-200-Prints                            1 roll
C-135-36-400-Prints                            1 roll
C-135-24-100-Prints                            1 roll
C-135-24-200-Prints                            1 roll
C-135-24-400-Prints                            1 roll
C-135-12-100-Prints                            1 roll
C-135-12-200-Prints                            1 roll
C-135-12-400-Prints                            1 roll
C-135-36-200-Slide                             1 roll
B&W-135-20-400-Prints                        1 roll
SX70 Polaroid                                1 sgl. pack
Kodamatic                                   1 sgl. pack

ROPE

Nylon  3/16                                 600' roll
Nylon 1/4"                                   1000' roll
Manila 1/4"                                  100' roll
Manila 1/2"                                  50' roll
                                              E-3

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Appendix E: Equipment List                                          Site Inspection Guidance

                        EXPENDABLE EQUIPMENT (Continued)

Item                                       Quantity Packaged                    Amount  Required

STATIONERY  SUPPLIES
Graph Paper
Manilla Tags
Paper Towels
Ball Point Pens
Indelible Ink Pens

TAPE

Clear Plastic                                1 each
Duct                                       1 roll
Elec. Vinyl                                  1 roll
Filament                                    1 roll
Flagging                                    100' roll
Masking                                    1 roil
Transparent                                  1 each

MISCELLANEOUS

Aluminum Foil                               500' roll
17# Drums 55 gal.                            1 each
17# Drums 35 gal.                            1 each
Kimwipes                                   box
pH Paper                                   2 roils
Plastic Roll 10' X 25'                          1 roll
Trash Bags 45 gal.                            20 box
Vermiculite                                  1 bag

WRITE IN:
 *Preservatives, calibrating solutions, sample packing materials, and special items of equipment are the responsibility
 of the Project Manager.

                                              E-4

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Site Impaction Guidance	Appendix E: Equipment List

                            NON-EXPENDABLE  EQUIPMENT

Equipment                                                       Amount  Required

CAMERAS
Canon AE1
Polaroid One Step
Polaroid SX70
Camera Bag
Binoculars

AIR  MONITORING

HNU Photoionization Detector
Draeger Tubes (Type:       )
Organic Vapor Analyzer
OVA Chirt Recorder
Explosimeter
Combination Explosimeter and O,Indicator
02 Indicator
Draeger Tube Hand Pump
HP> Gas Indicator
Mercury Sniffer
Photovac
Meteorological Unit

METERS

Radiation  Mini-Alert
Conductivity Meter
pH Meter
Resistivity Meter (Bison)
Resistivity Meter (Soil Test)
Metal Detector

SURVEYING  EQUIPMENT

Optical Rangefinder
Level, Hand 2X
Brunton Transit, w/case
Compass
200' Fiberglass Measuring Tape
300' Fiberglass Measuring Tape
Wheel Distance Recorder

PUMPS AND LIQUID SAMPLING EQUIPMENT

Double Diaphragm Pump 1"
Submersible Pump 1"
Submersible Pump 2"
Pitcher Pump 2"
                                             E-5

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Appendix E: Equipment List	Site inspection Guidance

                    NON-EXPENDABLE EQUIPMENT (Continued)

Equipment                                                     Amount  Required

PUMPS AND LIQUID SAMPLING EQUIPMENT (Continued)
Bacon Bomb Sampler
Kemmerer Sampler
LG Well Kit Sampler
SM Well Kit Sampler
SS Bailer
Teflon Bailer
Bottom  Filling Bailer
Water Level Indicator

SOIL SAMPLING EQUIPMENT

Spoons  LG
Spoons  SM
Spatula LG
Spatula SM
scoops
Trowel
Large Stainless Steel Bucket
Medium Stainless Steel Bucket
Small Stainless Steel Bucket
Split Spoon Sampler
3" Bucket Auger
3.5" Hand Auger
Dredge

DECON EQUIPMENT

Indian Tank
Heavy Duty Sprayer
John Deere Power Spray w/gas can
50' Section Garden  Hose
Mop
LG Hdl Dairy Brushes
SM Hdl Dairy Brushes
Scrub Brushes
Bottle Brushes
Whisk Brushes
Wire Brushes

STANDBY SAFETY EQUIPMENT

20# Fire Extinguishers
02 Resuscitator
 Stretcher
Eye Wash
Trauma Kit
                                            E-6

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Site Inspection Guidance	Appendix E: Equipment List

                    NON-EXPENDABLE  EQUIPMENT (Continued)

Equipment                                                     Amount Required

POWER EQUIPMENT
Digger Mobile
3 HP Water Pump w/gas can
Generator w/gas can
Power Auger w/gas can
Extension Cord-Heavy Duty 100'
Extension Cord-Light Duty 25'
Remote Drum Opener

SELF CONTAINED BREATHING APPARATUS

401 SCBA
Dual Purpose SCBA
CASCADE System
45 cu. ft. Composite Tanks
Umbilical Breathing Air Lines (50' Sec.)
Umbilical Breathing Air System
330 cu. ft. Class "D" Breathing Air Cylinder

PERSONAL  PROTECTION

Hard Hat
Safety Goggles
Safety Glasses
Splash Shield
Full Face Respirator
Respiratory Cartridges
Butyl Rubber Apron
Encapsulated Suits
Life Vests
Rain Jacket
Rain Pants

HAND TOOLS

Hacksaw
Post Hole Digger
Bung Wrench
Rake
Saw
Ax (Bush, Pick, Hand)
Shovel
                                            E-7

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Appendix E: Equipment List                                      Site inspection Guidance

                   NON-EXPENDABLE EQUIPMENT (Continued)

Equipment                                                   Amount Required

MISCELLANEOUS
Beeper
Ventilation Smoke Tube Assy.
Isotemp Oven
Wind Speed and Direction Finder
Garbage Can
Clipboard
LG Ice Chest
SM Ice Chest
Walkie Talkies
WRITE IN:
                                          E-8
                                                          *U.S. G.P.O.:1992-341-835:60761

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