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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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
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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
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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
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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).
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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
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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
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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
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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
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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
//
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//
//
//
/
//
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/
—
//
—
/
//
//
//
/
//
//
_
—
//
//
//
//
/
//
/
/
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//
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_
/
—
—
//
//
//
//
//
—
//
//
/
/
—
—
Key: SS= Likely source of significant sampling problem
/ = Potential source of sampling problem
Source: Modified from Keith, 1990
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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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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
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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
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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
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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.
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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
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(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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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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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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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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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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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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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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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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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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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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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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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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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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• 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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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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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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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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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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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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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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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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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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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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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
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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
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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
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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).
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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,
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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
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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
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• 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
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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
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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.
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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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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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• 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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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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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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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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• 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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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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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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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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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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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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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.
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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
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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
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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.
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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.
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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
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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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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.
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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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Act. 54 FR 41000, October 4, 1989.
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of Solid Waste and Emergency Response. Directive 9345.1-08.
U.S. Environmental Protection Agency, 1991. The Revised Hazard Ranking System Evaluating Sites After Waste
Removals. Office of Solid Waste and Emergency Response. Directive 9345.1-03FS.
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U.S. Environmental Protection Agency, 1991. Superfund Chemical Data Matrix (SCDM). Office of Solid Waste
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Emergency and Remedial Response. Directive 9240.0-01D
U.S. Environmental Protection Agency, 1992. Community Relations in Superfund A Handbook. Office of Solid
Waste and Emergency Response. Directive 9230.0-03C.
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Memorandum, April 7,1992. Office of Solid Waste and Emergency Response. Directive 9203.1-01.
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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.
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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,
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and Emergency Response. Directive 9345.1-07, in development.
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Operations)-Effluent Streams and the Environment. Regulatory Guide No. 4.15, Revision 1.
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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.
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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
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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]
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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
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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.
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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.
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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).
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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,
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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
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Site Inspection Guidance
Appendix A: SI Sample Plan (Example)
FIGURE 1: SAMPLE LOCATIONS
Source, Surface Water sediment, and Soil
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Appendix A: SI Sample Plan (Example)
Site Inspection Guidance
FIGURE 2: SAMPLE LOCATIONS
Ground Water
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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
$
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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.
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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)
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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)
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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)
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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)
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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)
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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.
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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)
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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)
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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
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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)
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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
-------
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
-------
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
-------
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
-------
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
-------
Appendix D: SI Narrative Report (Example)
Site Inspection Guidance
FIGURE 1: SITE LOCATION MAP
PALMETTO LANDFILL
Palmetto Landfill
^^J-/1'^"'''^--"***.*
-4-
D-4
-------
o
en
LEQEUQ
XXX
-A- ^L
O G>
PPE
o
4
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
CO
(A
•o
O
a
o
3
O
c
5i
u
3
O
O
•n
25
> c
? x
S m
H !?
O CO
O
c
n>
3
Q.
a
CO
n>
-------
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
-------
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
-------
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
-------
5:
o
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
•o
o
o
a.
u
•n
O
3)
TI in
> w
m
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3
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O
o
•o
o
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fri
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
o
5"
-a
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o
I-K
5'
3
O
c
S>
3
O
O
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3
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3
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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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-a
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U
I
o
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o
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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
-------
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
-------
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
-------
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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