PROTOCOL
FOR GROUND-WATER EVALUATIONS
U.S. ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
September 1986
U.S. Environmental Protection Agency
Region V, Library * X
230 South Dearborn Street
Chicago, Illinois 60604
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TABLE OF CONTENTS
PAGE
1.0 INTRODUCTION
1.1 Hazardous Waste Ground-Water Task Force 1-1
1.1.1 Introduction 1-1
1.1.2 Objectives 1-2
1.1.3 Scope of Work 1-2
1.2 Purposes of the Protocol 1-3
1.3 Organization of the Protocol 1-3
2.0 FACILITY EVALUATION PLANNING
2.1 Facility Evaluation Team 2-1
2.2 Facility Evaluation 2-1
2.3 Communications- Plan - 2-3
2.4 Confidential Business Information (CBI) Status 2-4
2.5 Problem Resolution 2-4
2.5.1 Introduction 2-4
2.5.2 Technical Questions 2-4
2.5.3 Regulation or Policy Interpretations 2-5
2.5.4 Procedural Disagreements 2-5
2.6 Safety Training 2-6
2.7 Document Control Training 2-6
3.0 DATA PROCUREMENT
3.1 Identification of Information Needs 3-1
3.2 Identification of Information Sources 3-3
3.3 Determination of Information Availability 3-4
3.4 Procurement of Documents 3-5
3.4.1 Visits to Information Locations 3-5
3.4.2 Inventory of Site-Specific Information 3-6
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Table of Contents (Continued)
PAGE
3.5 Document Control System 3-6
3.5.1 Document Numbering System 3-8
3.5.2 Document Number System Codes 3-9
3.6 Document/Subject Cross-Reference Chart 3-11
3.7 Document Narratives 3-13
3.8 Document Package 3-13
3.9 Missing Information 3-13
4.0 FACILITY EVALUATION PLAN
4.1 Development of the Facility Evaluation Plan 4-1
4.2 Entry, Notification and Pre-Evaluation Inspection 4-2
4.3 Evaluation Methods 4-3
4.3.1 Development of the Sampling Plan 4-3
4.3.2 Selection of Sampling Locations 4-3
4.3.3 Manpower Allocations 4-5
4.3.4 Equipment Designation 4-5
4.3.5 Logistical and Safety Considerations 4-6
4.3.6 . Scheduling Requirements 4-7
4.4 Document Control 4-7
4.4.1 Field Document Control 4-7
4.4.2 Sample Coordination 4-7
4.5 Personnel Responsibilities 4-9
4.6 Health and Safety Requirements 4-11
4.6.1 Medical Survillance Program 4-12
4.6.2 Enforcement of Field Safety Practices 4-12
4.6.3 Personnel and Equipment Decontamination 4-13
4.7 Schedule 4-14
4.8 Facility Evaluation Report 4-14
4.9 Quality Assurance/Quality Control (QA/QC) 4-14
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Table of Contents (Continued)
5.0 FACILITY INSPECTION
5.1 Notification Letter 5-1
5.2 Procedures for Facility Entry 5-2
5.2.1 Entry Procedures 5-3
5.2.2 Denial of Entry 5-4
5.2.3 Search Warrant 5-5
5.3 Pre-Inspection Visit 5-6
5.3.1 Scope of Pre-Inspection Visit 5-7
5.4 Facility Inspection " 5-8
5.4.1 Initial Briefing with Owner/Operator
of the Facility , 5-9
.5.4.2 -Interviews 5-10
5.4.3 Records Review 5-11
5.4.4 Visual Inspection 5-14
5.4.5 Evaluation of Pre-Sampling and .
Sampling Procedures 5-16
5.4.6 Evaluation of Laboratory Procedures 5-22
5.4.7 Debriefing Meeting 5-22
6.0 SAMPLING GUIDANCE
6.1 Planning 6-1
6.2 Preliminary Sampling Activities 6-3
6.3 Approaching the Well 6-4
6.4 Measuring Immiscible Constituents
(Floaters or Sinkers) 6-5
6.5 Well Purging 6-7
6.5.1 Purging Equipment Selection 6-7
6.5.2 Purging Procedures 6-8
6.5.3 Determination of Actual Volume of
Purged Water 6-11
6.5.4 Disposal of Purged Water 6-12
6.5.5 Procedures for Slow-Recharging Wells 6-12
6.6 Parameters - Specific Sampling Requirements 6-13
6.7 Monitoring Well Sampling 6-14
6.7.1 Selection of Sampling Equipment 6-15
6.7.2 Collection of Light Immiscibles (Floaters) 6-16
6.7.3 Collection of Heavy Immiscibles (Sinkers) 6-16
6.7.4 Collection of Ground-Water Samples 6-17
6.7.5 Collection of Volatile Organics Samples (VOA) 6-19
6.7.6 Measurements of Field Parameters 6-20
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Table of Contents (Continued)
PAGE
6.8 Sampling Ground-Water Seeps (Surface Water) 6-20
6.8.1 Selection of Sampling Locations 6-20
6.8.2 Sampling Techniques and Equipment 6-21
6.9 Sampling Soil 6-22
6.9.1 Selection of Sampling Locations 6-22
6.9.2 Sampling Techniques & Equipment 6-23
6.10 Sampling Surface Impoundments 6-23
6.10.1 Selection of Sampling Locations 6-23
6.10.2 Sampling Techniques & Equipment 6-24
7.0 FIELD QUALITY ASSURANCE
7.1 Training of Field Personnel 7-1
7.2 Quality Assurance/Quality Control Samples' . 7-2
7.2.1 Field QC Blanks 7-2
7.2.2 Field Duplicate Samples 7-3
7.2.3 Laboratory Duplicate Samples 7-4
7.2.4 Additional Compounds 7-4
7.3 Equipment 7-5
7.3.1 Routine Maintenance/Calibration 7-5
7.3.2" Decontamination 7-6
7.4 Documentation 7-11
7.4.1 Field Forms and Personal Logs 7-11
7.4.2 Photographs 7-12
7.5 Sample Handling 7-13
7.5.1 Containers 7-13
7.5.2 Chain-of-Custody ' 7-17
7.5.3 Labeling and Packaging 7-18
7.5.4 Transportation 7-22
8.0 COMPLIANCE EVALUATION
8.1 Facility Evaluation Report (Technical Report) 8-1
8.2 Development of Consensus on Technical Report 8-2
8.3 Identification of Appropriate Action 8-2
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Table of Contents (Continued)
9.0 FOLLOWUP
9.1 Development of a Facility Management Plan
9.2 Implementation of the Facility Management Plan
9.3 Monitoring the Progress of Initiated Actions
9.4 Identification of Implementation Problems
10.0 REFERENCES
11.0 ACRONYM
PAGE
9-1
9-2
9-3
9-3
10-1
11-1
Appendix-A Comprehensive Facility Sampling Evaluation QA/QC Guidance
Appendix B Superfund Off-Site Policy
Appendix C Subject Outline for Hazardous Waste Ground-Water Task
Force, Facility Evaluation Plan (Project Plan) Outline
Appendix D HSL Parameter List
Appendix E List of Parameters, Sample Volume, and Containers
Appendix F Technical Report Outline
Appendix G Quality Assurance Project Plan
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LIST OF FIGURES
Figure PAGE
3-1 Document/Subject Cross-Reference Chart 3-12
4-1 Overview of Sample Coordination 4-10
5-1 Determination of Volume of Standing 5-21
Water to Remove from Well
5-2 Receipt 5-24
7-1 Chain-of-Custody Form 7-19
7-2 Two-Part Sample Label 7-20
LIST OF TABLES
Table ' ' PA(
3-1 Information List 3-2
3-2 Document Organizational Categories 3-7
6-1 Liquid Volume in One-Foot Section 6-6
of Well Casing
6-2 Purging Equipment Selection 6-9
6-3 Bailer Sample Volume Per One-Foot 6-12
Section of Bailer
6-4 Order of Preferred Sample Collection 6-19
7-1 Containers Available From Sample 7-15
Bottle Repository Program
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1.0 INTRODUCTION
1.1 HAZARDOUS WASTE GROUND-WATER TASK FORCE
1.1.1 Introduction
The basic ground-water monitoring requirements for Resource Conservation and
Recovery Act (RCRA) land-based treatment, storage, and disposal (TSD) facilities,
set forth in 40 CFR, Parts 264 and 265, Subpart F, were originally promulgated in
1980. EPA has recognized the need to verify and assure that owners and operators
of TSD facilities comply with these rules. Wastes from EPA Superfund cleanup
activities are being disposed of at some of these facilities. Compliance oversight is
necessary to determine whether these facilities are posing a threat to human health
or the environment. Ground-water monitoring will assist U.S. EPA in determining
whether these facilities adequately prevent ground-water contamination-'and will
eliminate the future need for costly remedial activities associated with ground-water
contamination.
U.S. EPA established a Hazardous Waste Ground-Water Task Force (Task Force)
to evaluate the level of ground-water monitoring compliance at these facilities and
to address the causes of poor compliance. There are two parts to this effort:
o Planning and Administration
o Field Investigation and Compliance Assessment
First, a small group of technical and management personnel HI U.S. EPA
Headquarters called the Operations Assessment Group (OAG), will identify problems
that have inhibited State and EPA efforts to gain compliance with the rules. The
OAG will evaluate existing and planned training, guidance, regulations, and research
programs in order to identify consistency problems and additional needs. They will
coordinate responses by appropriate offices. The OAG will also evaluate the
existing infrastructure of EPA, identifying where lines of authority, responsibility,
communication, and coordination may be inadequate and, thus, impede efficient
implementation of appropriate action to gain compliance.
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Secondly, a special joint Regional, State, and Headquarters facility assessment
effort will be mounted to evaluate the compliance status of ground- water
monitoring at existing commercial and non-commercial hazardous waste land disposal
facilities and to implement a course of action to resolve identified problems or
areas of non-compliance.'
1.1.2 Objectives
The two primary objectives of the Task Force are:
o To evaluate commercial and on-site land disposal facilities for:
Compliance with the regulations in 40 CFR, Part 265, Subpart F,
"Interim Status Standards for Ground-water Monitoring", Part 270,
Subpart B, Section 270.14(c), "Additional Information Requirements";
and potential compliance with the rules set forth in Part 264,
"Standards for Owners and Operators of Hazardous Waste Treatment',
Storage, and Disposal Facilities."
Potential contamination in the ground water.
Compliance with the requirements set forth in the Superfund off-site
policy for selecting Hazardous Waste Management Facilities to
manage Superfund hazardous materials.
o To establish a rigorous, nationally consistent method of ground-water
evaluation and followup action.
1.1.3 Scope of Work
The Task Force has selected a number of land-based RCRA treatment, storage,
or disposal facilities for evaluation. These facilities are located in U.S. EPA
Regions I through X.
The initial evaluations will be performed at the chosen facilities by balancing
several considerations:
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o Ongoing or near-term planned State, Regional, or National Enforcement
Investigation Center (NEIC) evaluations.
o Volume and variety of waste.
o Receipt of large quantities of wastes from cleanup activities at Superfund
sites.
o Location and number of facilities among the ten regions.
o Seasonal weather conditions, when possible.
1.2 PURPOSES OF THE PROTOCOL
* T
This document presents a protocol for the facility evaluation activities of the
Hazardous Waste Ground-Water Task Force. The intent of this protocol is to
provide detailed guidance and procedures to the members of the Task Force in
executing their evaluation activities for each facility such that national consistency
can be achieved. This protocol will be revised based on additional experience
gained by the Task Force through conducting facility evaluations. The revised
protocol will then be used as a guidance document by staff from U.S. EPA Regional
and/or State regulatory offices for future ground-water monitoring evaluations at
hazardous waste land disposal facilities.
1.3 ORGANIZATION OF THE PROTOCOL
As stated in the previous section, the protocol will aid in achieving consistent
and thorough facility evaluations. The areas covered by this protocol are:
o Facility Evaluation Planning
o Data Procurement
o Development of Facility Evaluation Plan
o Facility Inspection
o Sampling Procedures
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o Field Quality Assurance
o Compliance Evaluation
o Followup Activities
The protocol is presented in eight sections corresponding to the topics listed
above. Discussions and step-by-step items or procedures are listed within each
section.
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2.0 FACILITY EVALUATION PLANNING
2.1 FACILITY EVALUATION TEAM
A team of technical personnel from EPA and various State regulatory agencies
will conduct a comprehensive evaluation of each facility to determine its compliance
with ground-water regulations. This team will include personnel with experience
and training in hydrogeology, field inspections, environmental engineering, Federal
and State regulations, communications (public relations), sampling procedures, and
sample analytical techniques.
The Task Force has formed a special joint Regional, State and Headquarters
team to evaluate the selected hazardous waste treatment, storage, and disposal
(TSD) facilities. Details of the composition and coordination of the Task Force are
described in the -"Hazardous Waste Ground-Water Task Force Facility Assessment
Program Plan" (1986). . ....
2.2 FACILITY EVALUATION
The facility evaluation process is composed of a series of six tasks. These six
tasks are interrelated and sequential. Therefore, each task must be completed
before the next task is initiated. The evaluation process will ensure that the
facility evaluations are conducted in a consistent and orderly manner. The six tasks
are:
o Data Procurement
o Preparation of a Facility Evaluation Plan (Project Plan)
o Facility Inspection
o Samples Analyses
o Preparation of Technical Report
o Development of Facility Management Plan
The first task of the evaluation process, Data Procurement, involves the
collection of data and documents relevant to the specific facility to be evaluated.
Completion of this task will provide complete and current information to the
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evaluation team. The information must include the historical background, current
operational status, and future operational plans of the facility. The information can
be obtained from U.S. EPA offices (Region, Headquarters, ESD, and NEIC), State
regulatory agencies, other governmental agencies, and TSD facility owners and
operators. Section 3.0 of this protocol provides a detailed description of this task.
The second task is the development of a facility-specific evaluation plan. The
data and information gathered during the Data Procurement Task will allow the
evaluation team to decide whether to conduct an on-site inspection. The inspection
may be delayed until the owner or operator installs an acceptable ground-water
monitoring system at the facility. A comprehensive Facility Evaluation Plan must be
developed prior to an on-site inspection. The purpose of the plan is to ensure that
an efficient and comprehensive inspection will be conducted onsite and the
information generated from the inspection can be used to complete an in-depth
evaluation of the ground-water compliance status < of -the facility. 'Section 4.0
describes the various elements and development of such a plan.
The third task, Facility Inspection, will commence after the draft Facility
Evaluation Plan is completed. The inspection will normally be conducted in two
phases. The initial phase of the inspection consists of a pre-inspection strategy
meeting and a reconnaissance of the site. This phase will involve only a few (two
to four) members of the field inspection team. The purpose of the reconnaissance
is to survey the site and gather additional site-specific information so that changes
within the Facility Evaluation Plan can be made to address specific site conditions.
The second phase of the inspection will begin immediately after the Facility
Evaluation Plan is revised. Sampling, record reviews, inspection of waste
management areas, interviews with operational personnel, and other planned
activities will be completed during this phase of the inspection. Section 5.0 of this
protocol details the various elements of a Facility Inspection.
The fourth task of the evaluation process is the analysis of samples collected
during the on-site inspection by an approved laboratory. Prior to the inspection,
the evaluation team must select and contract an approved laboratory for such
analyses. The parameters to be analyzed in each sample must be identified in the
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Facility Evaluation Plan. Section 6.0 of this protocol describes the preparation of
the Sampling Plan.
When the analyses of the samples are completed, the field team leader must
draft a Facility Evaluation Report (Technical Report) to detail the findings from the
review of the data and documents, the on-site inspection, and the results of the
sample analyses. The report must also provide recommendations for achieving
compliance with ground-water regulations and recommendations for determining the
nature and extent of ground-water contamination. Section 8.0 describes the
preparation of the Facility Evaluation Report.
The last task of the facility evaluation process calls for the development of an
amendment to the facility-specific management plan. This plan must detail the
appropriate actions that can be taken by U.S. EPA to address the findings of the
Facility Evaluation Report. The plan must include both a short- and long-term
strategy, action schedules, and progress tracking mechanisms. Section 9.0 describes
the development of a Facility Management Plan.
2.3 COMMUNICATIONS PLAN
The Field (Facility Evaluation) Team Leader and the regional communications
staff may have to develop a facility-specific Communications Plan which will iden-
tify the Communications Coordinator and outline the communications strategy. Use
of this approach will help avoid inconsistent and contradictory statements from
members of the Evaluation Team to the general public or owners/operators of the
facilities. Although it is U.S. EPA policy to make information about the Agency and
its work freely available, this policy does not extend to confidential information and
evidence relating to possible violation of Federal environmental laws. All general
inquiries should be referred to the designated Communications Coordinator for
response. The decision to release facility-specific data or findings to the public
must be made by the Field Team Leader (FTL) in consultation with the regional
communication staff, Regional Counsel, Regional Management, and Headquarters
Management. The Task Force Communications Coordinator has developed a
communications strategy for the dissemination of information related to the
activities of the Task Force. The Coordinator will meet with the FTL and regional
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communications staff to develop a facility-specific Communications Plan tailored to
the local situation. The regional communications staff will be responsible for
implementing this plan.
2.4 CONFIDENTIAL BUSINESS INFORMATION (CBI) STATUS
Pursuant to Title 40 CFR, Part 2, Subpart B, Sections 2.201-2.309 [40 FR
36902, September 1, 1976, as amended in 43 FR 39997, September 8, 1978], a facility
can designate information as "confidential". A facility may also designate a
"business confidentiality" claim for all or part of their information pursuant to 40
CFR 2.203(b). Any information received with a request of confidentiality, as
Confidential Business Information (CBI), RCRA CBI, or Toxic Substances Control Act
(TSCA) CBI, must be handled in accordance with the above mentioned regulations
until the Agency determines that the claim of confidentiality is not valid.
2.5 PROBLEM RESOLUTION
2.5.1 Introduction
Members of the evaluation team may sometimes fail to reach a consensus
during the evaluation process, such as during the development of the project plan
or preparation of the technical report. In such situations, the guidelines outlined in
the following sections will apply.
2.5.2 Technical Questions
Failure to reach consensus on a technical question will usually be due to
insufficient reliable information, a gap in legitimate scientific knowledge, or
different interpretations of available data.
If there is insufficient information, the evaluation team must develop plans for
gathering the necessary additional information from such sources as the owner or
operator, or through additional inspections or contractor action.
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If the problem stems from a lack of scientific knowledge or legitimate
differences in interpretation of available data, the following steps must be followed:
1) The evaluation team, in consultation with Regional Management, may
submit the problem to a team consisting principally of external experts of
national stature for review and recommendations. The Task Force has
assembled such a team of experts and formed a Technical Advisory Panel
to provide review and advice on technical questions.
2) The evaluation team, through Regional Management, may notify
Headquarters of the need for addressing specific technical and
administrative problems and incorporating them into the research
program for future resolution.
2.5.3 Regulation or Policy Interpretations
Federal regulations and policies are often unspecific in terms of performance;
therefore, disagreements may arise in interpreting their specific application. When
consensus cannot be reached, the Director of Hazardous Waste Ground-Water Task
Force is responsible for obtaining official interpretation from the lead Headquarters
office such as the Office of Solid Waste, Office of Waste Programs Enforcement, or
Office of Emergency and Remedial Response.
2.5.4 Procedural Disagreements
Evaluation team members may also disagree as to how to proceed based on the
conclusions reached (such as action on a permit application vs. the use of an
enforcement order to deal with non-compliance). Questions such as this may not be
addressed in regulations and policies issued to date. The regulations and policies
may simply represent alternative acceptable approaches with differing advantages.
The responsible agency (State or Region) should then make an interim decision and
consult the appropriate office for final determination. Regarding the Task Force,
this type of issue may be raised before the Task Force Steering Committee if the
disagreements are strong enough.
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2.6 SAFETY TRAINING
Protecting the health and safety of the investigative team is a major concern
in hazardous waste site investigations. Section 111 (c) of the Comprehensive
Environmental Response-and Compensation Liability Act (CERCLA) and the National
Contingency Plan (40 CFR 300.71) require all work at hazardous waste sites to be
conducted by personnel who are adequately trained in safety procedures. Therefore,
all field staff must have completed the requirements set forth in EPA Order 1440
(1981b), including the classroom and field trainings, such as "Personnel Protection &
Safety (165.2)" and "Hazardous Materials Incident Response Operations (165.5)"
offered by U.S. EPA, or other equivalent health and safety training courses offered
by trade associations or consultants.
2.7 DOCUMENT CONTROL TRAINING
Members of the evaluation team must use °a prescribed set 'of procedure's for
obtaining and handling site-specific information. Such procedures will help provide
efficient retrieval of site-specific information and documents and will provide
defensible evidence for potential litigation.
A document control system must be established for handling documents
obtained throughout the facility evaluation process. This system must consist of the
following elements:
o Document Cataloging
o Document Storage
o Document Retrieval
o Document Accessibility
o Document Routing
o Document Disposal
o Procedures Used By Inspectors when Collecting Field Data
The U.S. EPA National Enforcement Investigations Center (NEIC) has developed
such a document control system and will provide training to all regional U.S. EPA
or State offices to acquaint them with these document control procedures.
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3.0 DATA PROCUREMENT
The evaluation process for a facility begins with the procurement of all
available hydrogeologic and operating information pertaining to the facility. This
process involves identifying all information sources other than the facility operator
or owner, obtaining pertinent documentation from those sources, and determining
what information is missing but necessary for performing the compliance evaluation.
Efforts should then be focused on obtaining the missing information from the files
of owners/operators or through sampling or inspection activities at the facility.
The elements of the Data Procurement process include:
o Identification of information needs
o Identification of information sources
o Procurement of documents
o Document inventory preparation
o Categorizing documents
o Compilation of document package
o Identifying and procuring missing information
3.1 IDENTIFICATION OF INFORMATION NEEDS
The evaluation team should prepare a list identifying the types of information
that will be required for the facility evaluation. This list should be the basis of all
data procurement efforts to promote consistent and complete data collection. A
comprehensive list of necessary information was developed by the Task Force for
collecting information pertaining to the targeted facilities. This list (Table 3-1)
consists of 44 subjects. It is unlikely that there will be facility-specific information
for each of the subjects on the list. Information related to the hydrogeological
conditions of the site, the site ground-water monitoring system, ground-water data.
responses to Notices of Deficiency, inspection reports, and facility descriptions will
be of primary importance for the facility evaluation.
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TABLE 3-1
INFORMATION LIST
RCRA Part B Application (Pertinent Sections)
RCRA Part A Application
Hydrogeologic- Reports
Maps, Drawings, and Aerial Photos
TSCA CBI
Biennial Reports/Quarterly Reports
RCRA Facility Assessment Report
Inspection Reports
Notice of Deficiency
CERCLA Section 103(c) Notices
Litigation Actions
ACL Demonstration
Solid Waste Management Unit Report
-Facility History
Ground-Water Sampling and Analysis Plan
Ground-Water Monitoring/Assessment Plan
Remedial Investigation
Waste Analysis Plan
Engineering Studies
Surface Water Data
Ground-Water Data
Facility Standard Operating Procedures
Closure/Postclosure Plans
Leachate/Liner System
Site Hydrogeologic Reports
Man-Made Hydrologic Controls
Aquifer Characteristics
Well Inventory - Water Use
Waste Inventory/Manifests/Analysis
Well Bore Logs/Well Const./Geophysical Data
Preliminary Assessment
Immediate Remedial Measures
Remedial Design
Remedial Action
Removal Action.
Incident Report
Application for Ground-Water Monitoring Waiver
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3.2
IDENTIFICATION OF INFORMATION SOURCES
The data procurement team must initially obtain all available pertinent
information for each facility from sources other than the owner/operator. The
following agencies have been identified as the primary sources of relevant
information for the facility evaluation. The typical information types likely to be
available from each source listed opposite the source agency.
o
o
U.S. EPA Headquarters
Personnel
U.S. EPA Regional RCRA
Permit Personnel
U.S. EPA CERCLA Personnel
' State Programs Personnel
o U.S. EPA Regional RCRA
Compliance Personnel
o U.S. EPA Regional Counsel
U.S. and State Geological
Surveys
RCRA Part A and Part B
Applications
Application Revisions
Engineering Reports
Hydrogeologic Reports
Ground-Water Monitoring/
Assessment Plan
Site Standard
Operating Procedures
Waste Analysis Plan
Waste Inventory/Manifest/
Analysis
Closure/Post Closure Plan
Permits (air, water, etc.)
Manifests/Receiving Orders
Inspection Reports
Documented Complaints and
Problems
Inspection Reports
Notices of Deficiencies (NODs)
Records of Decisions (RODs)
Litigation Actions
Documented Complaints and
Problems
Geologic and Hydrologic Reports
Water Monitoring Data
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Other public agencies and private companies that have been identified as
secondary sources of information include:
o State Attorney General
Suits brought against the facility
o County Attorney Office
Suits brought against the facility
o County or Regional Planning Agencies
o Other County Offices
Health Department
Planning and Zoning
o City Offices
Engineer
Fire Department
Law Enforcement
o Soil Exploration and Foundation
Contractors/Water Well Drillers
o National Oceanic and Atmospheric
Administration (NOAA)
3.3 DETERMINATION OF INFORMATION AVAILABILITY
Prior to initiating data procurement activities at Federal and State EPA
offices, the evaluation team leader must obtain the names and telephone numbers of
Regional U.S. EPA and State EPA compliance and permit personnel who have files
on the specific facility. The data procurement team will then contact these
Regional and State personnel and determine what information on the list (Table 3-1)
is available, in which files they are located, and their approximate quantities.
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During a telephone conversation with the contact of each source agency, the
data procurement team will identify the types of information on the list which are
apparently available from that source and will note which types of information are
still missing. After determining the location and quantity of the available
documents, the data procurement team will ask the source contact for other possible
sources for the missing information.
The data procurement team will then make telephone calls to the other sources
identified to determine what types of information are available, their quantities,
and, if reasonable, whether or not these can be transmitted directly to the evalua-
tion team. If the source contact states that policies prohibit transmittal of the
desired documents or that it is not feasible to do so, the team will ask the contact
whether the documents can be reproduced. at the source agency or taken to a
commercial reproduction service. If neither is possible, the team will either
purchase documents such as reports and maps, or record pertinent information
regarding the nature of the information and the location of the information. '
This method of tele-networking should be continued until all the information is
located and identified as obtainable or until no further sources are identified.
3.4 PROCUREMENT OF DOCUMENTS
3.4.1 Visits to the Information Locations
The data procurement team should visit the offices of the Federal, State, and
local agencies and any other sources where the information is located. The team
will review the available information during the visits and select those documents
that are pertinent to the facility evaluation.
The team can schedule and perform data procurement activities more effi-
ciently by having the information separated by types prior to the visits to the
information sources. All information sources will be requested to identify and/or
separate site documents into those that can be sent directly to the data
procurement team (reports, maps, aerial photographs) and those that require on-site
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procurement due to their nature and/or quantities. Unless purchased by the team,
all documents sent by the source will be reproduced either at the office of the
team or at a commercial reproduction center, and the originals returned usually
within one week of their receipt.
3.4.2 Inventory of Site-Specific Information
The relevant information obtained for each facility evaluation can be grouped
into nine major categories and their respective subcategories, as shown in Table
3-2. After all available site-specific documents are gathered, each document will be
placed into one of the nine categories and assigned a document number.
Confidential Business Information (CBI) and TSCA CBI will be separated from the
other documents and handled in accordance with the prescribed CBI/TSCA CBI
procedures.
3.5 DOCUMENT CONTROL SYSTEM
The purpose of a document control system is to provide organization and
accountability throughout the facility evaluation process. The system should set
forth handling, routing, and storage procedures to be used for the documents
gathered for ea'ch targeted facility. The control system must include a document
numbering system, a document inventory procedure, and a central filing system.
The control system must also facilitate information retrieval in addition to providing
organization and limiting access to the documents. A document control officer
(DCO) must control the handling and routing of documents and ensure proper
document storage in files. CBI and TSCA CBI must be stored in separate-files.
The Task Force has assigned a DCO at U.S. EPA Headquarters to maintain the
X
documents generated for each facility.
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TABLE 3-2
DOCUMENT ORGANIZATIONAL CATEGORIES
1 Part B Application
01 Application
02 Revisions
2 Part A Application
01 Application
02 Revisions
3 Compliance/Enforcement
01 Inspection Reports
02 Requests, Notices, Orders, Permits from Regulatory
Agency to Owner/Operator
03 Response, .Reports, Applications from Owner/Operator to Regulatory
Agency
4* Hvdrogeologic Reports
5 Correspondence
01 Regulatory Agency to Owner/Operator
02 Owner/Operator to Regulatory Agency
03 Third Party
04 Internal
6 Technical Reports and Plans
01 Engineering Reports
02 Soil/Water Resource Reports
03 General Technical
7* Maps. Drawings and Photographs
8 Confidential Information
01 CBI
02 TSCA CBI
9 Task Force Reports and Plans
01 Technical Reports
02 Data Analysis Report
03 Site Management Plan
* 00 following a major category number signifies the absence of any
subcategory.
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3.5.1 Document Numbering System
The document numbering system used by the Task Force consists of a unique
13-digit document number assigned to each document. This document number allows
the user to extract information concerning the document by simply inspecting its
13-digit alphanumeric document control number. Information such as the specific
commercial facility which the document addresses, who collected the information or
document and from where, and the document's major subject category and
subcategory can be ascertained from the document control number.
An example of a document control number is as follows:
T 001-PO1-202-005
This number contains seven pieces of information labeled a through g
T QpJ. - P OJ. - 2. 0.2 - QOJ.
a b c d e f g
The letters correspond to the following:
a. Task Force project identifier
b. Identification number of the facility
c. Data procurement contractor
d. Agency information source
e. Facility-specific information category
f. Subcategory
g. Sequential document number within each category
For each part (a through g), a specific letter or numerical code has been
designated to represent certain information about the document. A complete list of
the codes used is presented in Section 3.5.2, "Document Numbering System Codes."
Part "a" of the number identifies that this is a Hazardous Waste Ground-
Water Task Force project and has been assigned the letter T.
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OSWER DIR. 9080.0-1
Part "b" of the number identifies the number of the facility being evaluated.
This number is assigned by the Task Force.
Part "c" of the number identifies who obtained the data. In this example, P
has been assigned to represent PRC Environmental Management, Inc.
Part "d" of the number identifies the source of the information. In the
above example, the document was obtained from U.S. EPA Headquarters. A complete
list of all sources used for this specific facility is presented in the following
section, "Document Numbering System Codes." The number codes from "09" to "99"
are reserved for identification of local, State, or Regional regulatory -agencies.
Part "e" of the number identifies the major category in which the document
has been placed.
. o
Part "f" of the number identifies the subcategory under each major category.
This provides the user with an additional description of each document and also
helps the user locate a document within a volume or set of volumes.
Part "g" of the number identifies the individual document within a category.
This number is assigned sequentially by the order of inventory for each category.
3.5.2 Document Number System Codes
Part "a"
T = Task Force. This code will remain the same for all Task Force
related assignments
Part "b"
001 - SCA Chemical Waste Services
Model City, NY
002 = Chemical Waste Management, Inc.
Kettleman Hills, CA
003 * Wayne Disposal Inc., Site #2
Belleville, MI
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004 - Servicios Carbareon, Inc.
Penuelos, PR
005 - Rollins Environmental Services
Deer Park, TX
(Only the first five, facilities are provided as an example)
Part "c"
A = Barbara Elkus
B » Anthony M. Montrone
C = Randall Breeden
D ** Dan Sullivan
E = Jack R. Murphy
F » Donald Shosky
G » Burnell Vincent
H - Rolf Hill
I = Richard Steimle
J =» Mark Witherspoon
K = John Haggard
L a Brian Lewis
M = Joan Middleton
P = PRC Environmental Management, Inc.
Q = GCA
S = Steve Sisk
V = Versar
Part "d"
01 = U.S. EPA HQ
02 = U.S. EPA (Regional Waste Management Division)
Q3 = U.S. EPA (Regional Environmental Services Division)
04 =* U.S. EPA (other Regional Divisions)
05 = U.S. EPA NEIC
06 = USGS
07 = USDA
08 = State EPA
09, 10, ... = Other local, State, or Regional regulatory agencies
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OSWER DIR. 9080.0-1
Paj-ts "e" and "f
As described in the previous section, there are nine major document categories.
Within each category there may be no subcategories (denoted by a "00" notation) or
several subcategories. Note that a subcategory number such as "01" by itself tells
the user little. The subcategory number is of optimal use only when preceded by a
major category number (for example, 501 denotes major category "5",
correspondence, and subcategory "01", regulatory agency to owner/operator, within
that major category). This appears as "501" in the "e" and "f" parts of the
document number.
3.6 DOCUMENT/SUBJECT CROSS-REFERENCE CHART
A Document/Subject Cross-Referencc Chart (Figure 3-1) is provided to identify
the subjects and major category of each document. This chart precedes the
documents located in each document volume.
The nine major document categories are entered as the first nine items in the
subject column of the Document/Subject Cross-Reference Chart, When information
is entered for a specific document in one of the nine categories on the chart, its
document control number is recorded at the top of a column along the
corresponding diagonal line. The major document category corresponding to the
specific document is indicated with a dot in the column under the document number.
This mark (across from one of the first nine category entries) also indicates which
will be used in "Part e" of the document control number. Therefore, one can locate
which volume a document is in by either finding the corresponding category entry
in the subject column or by using the document control number atop each column,
then looking for the appropriate volume.
A list of specific subjects and subject modifiers follows the first nine entries
in the subject column. In addition to the major document category, other dots in
the column further describe the contents of each document. This will allow the
user to quickly identify those documents he/she may be interested in. After a user
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UNIFORM TINES. INC.
OSWER DIR. 9080.0-1
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OSWER DIR. 9080.0-1
selects a document from the chart for further consideration, he/she may refer to
the Document Narratives to find a brief description of the document to determine
whether or not it contains the information being sought.
3.7 DOCUMENT NARRATIVES
The Document Narratives provide a brief description of each document. The
numbers, date, and content of the documents in each volume are presented in the
Narrative for that volume. The Narrative can be used to identify which documents
should be reviewed for further detail. The Narrative is placed between the
Cross-Reference Chart and documents.
3.8 DOCUMENT PACKAGE
After all available documents are gathered, numbered, and placed into one of
the major document categories, the documents are assembled in -binders to form a
Document Package. The Document Package for the Task Force consists of a
Foreword Volume and the document volumes. The Document/Subject Cross-
Reference Chart and Document Narrative are placed in each volume preceding the
documents.
The Foreword Volume consists of a compilation of all the Subject Cross-
Reference Charts and Document Narratives for all the volumes of documents. The
charts and narratives will be organized by volume. A Table of Contents which lists
the documents in each volume is provided in front of the Foreword Volume.
3.9 MISSING INFORMATION
After reviewing the Document Package, if the evaluation team discovers that
additional information is required, the team leader should compile a list of missing
information. The following four options are available to the team leader for
securing the missing information:
o Request the owner/operator to supply the information
o Issue a 3007 letter to the owner/operator
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OSWER DIR. 9080.0-1
o Collect the missing information during the first phase of the
inspection
o Collect the missing information during the second phase of
the inspection
The additional information should be transmitted to the Task Force and
incorporated into the Document Package.
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OSWER DIR. 9080.0-1
4.0 FACILITY EVALUATION PLAN
4.1 DEVELOPMENT OF THE FACILITY EVALUATION PLAN (PROJECT PLAN)
The general objectives of the facility evaluation are to: (1) expand and/or
verify background hydrogeological and monitoring information on the facility, (2)
determine compliance of the facility with Subpart F requirements of Part 265,
potential requirements of Part 264 Subpart F, and 270.14(c), (3) determine the
conformance of the facility with EPA's CERCLA off-site policy (1985c), and (4)
determine the compliance of the facility with State hazardous waste regulations. A
facility-specific evaluation plan will be developed to address the scope, schedule,
and level of effort involved in conducting an evaluation to achieve these general
objectives.' The facility evaluation team (personnel from NEIC, U.S. EPA Head-
quarters, Regional U.S. EPA and State regulatory agencies) will determine specific
objectives of the evaluation after completing a thorough review of the Document"
Package for the facility. The field inspection feam leader (FTL) will then be
responsible for developing the detailed Facility Evaluation Plan. The Plan should
address the following elements:
o Objectives (scope) of the field evaluation
o Procuring additional background data on the facility
o Notification, entry, and pre-evaluation procedures
o Evaluation methods including a sampling protocol
and records review procedures
o Field document control and sample coordination
o Personnel Responsibilities
o Health and Safety Requirements
o Schedule
o Quality Assurance/Quality Control
Appendix C provides a detailed description of subjects to be included in the
Facility Evaluation Plan.
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OSWER DIR. 9080.0-1
The Plan should also identify personnel at the facility who will be interviewed.
A Draft Facility Evaluation Plan should be transmitted to members of the field
inspection team for review and comments. The facility evaluation team leader is
then responsible for incorporating appropriate changes into the final Facility
Evaluation Plan.
4.2 ENTRY, NOTIFICATION, AND PRE-EVALUATION
The Director of the Hazardous Waste Ground-Water Task Force will issue an
official letter of notification regarding upcoming site inspections to the
owner/operator or other responsible official of the facility. The notification letter
identifies the authority under which the inspection will be conducted. The FTL will
coordinate site-specific entry procedures with the owner/operator of the facility.
During the site reqonnaissance (pre-inspection) visit, a strategy meeting will be
conducted between the owner/operator of the facility and representatives of the
inspection team. The following topics will be discussed:
o Schedule for the evaluation
o Activities to be conducted during the evaluation
o Details of the monitoring system design
o Existence and probable nature of any ground-water contamination
o Key personnel of the inspection team
o Sample collection activities
o Logistical problems
o Facility safety policy and procedures
o Collection of additional site information
o Potential personnel to be interviewed
o List of documents to be reviewed
If the inspection schedule conflicts with the facility's sampling schedule, the
owner/operator should be requested to adjust the facility sampling schedule, if
possible, to accommodate the field inspection schedule.
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Decisions reached on these topics will help determine the number and types of
samples to be taken, the general types of equipment needed, and the responsibilities
of sampling and inspection personnel. Once an agreement is reached, details will be
distributed to all parties involved in the field inspection.
4.3 EVALUATION METHODS
The inspection methods portion of the Facility Evaluation Plan includes the
sampling protocol, visual inspection procedures, records review procedures, and
sampling and laboratory evaluation procedures. General field evaluation procedures
are detailed in Section 5.0 and Appendix A of this document; sampling procedures
are detailed in Section 6.0.
4.3.1 Development of the Sampling Protocol
The primary sources of information for developing the sampling protocol are
the Document Package and the Facility Evaluation Plan (Section 4.1) for the facility
and the information obtained during the pre-inspection meeting with the
owner/operator.
The sampling protocol should:
o Identify laboratory analyses to be performed.
o Identify sampling locations.
o Specify the manpower requirements of sampling activities.
o Identify equipment needs.
o Identify logistical and safety considerations.
o Determine the scheduling requirements needed to perform the sampling
activities.
o Identify the locations of all wells and leachate collection points.
4.3.2 Selection of Sampling Locations
During the facility inspection, the inspection team will collect samples from
selected surface water locations, on-site ground-water monitoring wells and leachate
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sumps. These samples will be sent to approved laboratories for analyses to
determine if the surface water, leachate, or ground water beneath the facility
contains hazardous waste constituents or other indicators of contamination.
Selection of the sampling locations is vital to the success of the facility
evaluation. The evaluation team should select surface-water bodies and
ground-water monitoring wells that can immediately reveal, with a high level of
certainty, releases of hazardous waste or hazardous waste consitutents from the
hazardous waste management units. In general, surface-water samples should be
collected from areas of known or suspected ground-water discharge at locations
both upgradient and downgradient of the facility. The evaluation team should
consider the following factors when selecting monitoring wells for sampling:
o "Location of Well - Wells that are located immediately adjacent or closest
to the waste management unit.
o Depth of Well - Wells that are screened at the stratigraphic horizon
which represents a potential contaminant migration pathway from the
waste management unit.
o Accessibility of Well - Wells that can be reached by the sampling
technicians and members of the evaluation team. The sampling
technicians must be able to transport the sampling equipment and
associated gear to the well location without difficulty.
o History of Well - Wells that produced contaminated samples in the past.
Past inspection records and monitoring reports will provide information to
identify these wells.
o Potential Contamination of Well - Wells that may contain contaminants
from waste management unit releases. The evaluation team may be able
to identify these wells from reviewing the design and construction
of the waste management units, operation procedures, and hydrogeo
logical setting of the site'.
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OSWER DIR. 9080.0-1
Sampling locations should be determined first because they will have bearing
on the equipment needs and logistical considerations of the sampling activities.
The sampling protocol should include a map of the facility indicating the
location of all existing wells and leachate collection points. The map should also
indicate all proposed sampling locations and the type of media to be sampled, such
as ground water, surface water, or leachate.
The historical monitoring data of the monitoring well should be considered
when choosing wells for collecting duplicate samples. Where possible, wells
indicating the presence of hazardous constituents in the ground water should be
designated as those wells from which duplicate samples will be collected.
4.3.3 Manpower Allocations
a
The facility sampling protocol should identify the responsibilities of each
member of the field inspection team for specific sampling activities. Generally, the
responsibilities of team members will follow the organization outlined in the Facility
Evaluation Plan. Responsibilities of members of the inspection team are described
in Section 4.5.
4.3.4 Equipment Designation
The sampling protocol should describe the major equipment needed to conduct
the sampling activities. The equipment to be used will be listed in one of three
categorizes: sampling equipment, containers and preservatives, and- expendable
items. Selection of the actual sampling equipment to be used is discussed in
Section 6.0.
The number and types of containers needed at each sampling location depend
on the types of media to be sampled and the analytical parameters of interest. This
information is most easily prepared in a table format, using a reference such as
"Methods for Chemical Analysis of Water and Waste" (U.S. EPA, 1983b) to determine
the specific container types (glass,'plastic) and volumes (pint, liter) needed for each
parameter. The table should have a list of the preservatives required for each of
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OSWER DIR. 9080.0-1
the analytical parameters and should present totals for the various types of
containers needed. The totals must also include the quality assurance samples
required for laboratory analyses, such as field blanks and trip blanks. Quality
assurance samples are dis.cussed in Section 7.0 of this document.
The equipment list should include expendable items that will be needed to
conduct the sampling. These items include, but are not limited to, solvents and
distilled or deionized water for washing sampling equipment, plastic sheeting and
paper products for maintaining a clean work area and for cleaning or drying
equipment, packing boxes and material, and ice for refrigerating samples. Backup
equipment should be available on-site in case of an emergency.
4.3.5 -Logistical and Safety Considerations
The sampling protocol should include a schedule for all activities associated
with on-site sampling. Particular attention should be given to activities that may
delay the sampling schedule. This includes specifying and scheduling equipment
preparation (ordering expendable items, obtaining sample containers), staging and
calibrating equipment (if necessary), and transporting the equipment to the site and
the samples to .the analytical laboratory. The sampling protocol should also detail
the logistics of obtaining the laboratory performance evaluation samples from U.S.
EPA ORD in Cincinnati.
During the planning of the sampling activities, a member of the evaluation
team should contact the contract laboratories through the Sample Management
Office (SMO) to prepare them for receiving shipments of samples. The protocol
should designate the sampling dates, the anticipated number and types of samples,
the kinds of analyses required, and the anticipated method and time of shipment.
The appropriate analyses request forms and other applicable documentation should be
requested at the time of contact.
The sampling protocol should detail the specific safety concerns identified
through available site information and describe the appropriate precautions to be
taken. This issue is discussed further in Section 4.6.
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4.3.6 Scheduling Requirements
The sampling schedule will be included as part of the overall field evaluation
schedule.
4.4 DOCUMENT CONTROL
4.4.1 Field Document Control
Field documents include sample labels, field data sheets, chain-of-custody
forms, and bound field logbooks. Field logbooks should be signed and maintained by
each member of the field evaluation team to provide a daily record of significant
events. All entries must be dated.
All field documents will become part of the permanent. Document Package. It
is the FTL's responsibility to secure all documents prior to completion of all field
activities. (These documents, if referred to in legal proceedings, .are subject to
cross-examination and are admissible as evidence).
Detailed guidance on field document control is presented in Sections 7.4 and
7.5.
4.4.2 Sample Coordination
The facility evaluation team must coordinate activities related to sampling and
analysis including hardware selection, sample distribution, QA/QC, and laboratory
selection (from the Contract Laboratory Program, CLP). The evaluation team should
secure assistance from the Sample Management Office and their contractors to help
coordinate these activities.
The groups involved in the sampling and analysis effort conducted by the Task
Force, and the role each will perform are as follows:
o A contractor (from CLP) will coordinate sample management between the
selected contract laboratory and the Task Force. Routine management
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OSWER DIR. 9080.0-1
activities include scheduling and tracking, subcontracting, special
analytical services, invoicing, and maintaining records.
o Contractor(s) will provide sampling equipment and sampling technicians.
o A contractor (from CLP) will provide sample bottles.
o Contract laboratories (from CLP) will perform sample analyses
o U.S. EPA ORD, Cincinnati will provide performance evaluation (PE)
samples if requested by the Task Force to monitor the performance of
the analytical laboratories.
o U.S. EPA EMSL/LV (Environmental Monitoring Systems Laboratory/Las
Vegas) and a contractor will provide QA/QC of analytical data.
An overview of. the sample coordination among the groups involved in the
sampling and analysis is provided in Figure 4-1. The sample coordination is briefly
summarized below.
1) The FTL submits the sampling protocol to the Facility Evaluation Team
members, sample management contractor, and sampling contractor.
2) The sample bottle contractor supplies the sample containers to the
sampling contractor.
3) At the direction of the FTL, the sampling contractor transports the
necessary equipment and sample containers to the facility.
4) The sampling contractor ships the samples to the contract laboratory for
analysis.
5) The contract laboratory analyzes the samples and distributes the
sample results to the Facility Evaluation Team, laboratory data
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OSWER DIR. 9080.0-1
quality assurance evaluation contractor, and sample management
contractor.
4.5 PERSONNEL RESPONSIBILITIES
The chain-of-command during the facility evaluation must be designated and
described prior to initiating field activities. The field evaluation team consists of
four subgroups, each having specific responsibilities. The four subgroups are
records review, laboratory evaluation, sampling, and management. Members of the
evaluation team are assigned to the records review group, laboratory evaluation
group, or sampling group; however, the management group may .be composed of
members from each of the other three groups. The responsibilities of each member
assigned to the field evaluation team should be outlined in the Facility Evaluation
Plan.
The records review group is responsible for obtaining and reviewing on-site
documents and information to assess the following items:
o Waste location within specific waste management unit
o Waste handling
o Facility design and operation
o Ground-water monitoring capability
The laboratory evaluation group is responsible for obtaining and reviewing
documents and information regarding the laboratory quality assurance program and
the facility waste analysis plan to determine the reliability of analytical data.
The sampling group is responsible for obtaining the best representative samples
of surface water at the facility or ground water beneath the facility and evaluating
the facility sampling technique. Contractor sampling technicians are responsible for
providing the appropriate equipmerit and collecting and handling the samples.
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OSWER DIR. 9080.0-1
The management group is responsible for coordinating the overall operation of
the evaluation team.
4.6 HEALTH AND SAFETY REQUIREMENTS
Contaminants in the soil, surface water, or ambient air may present potential
hazards at RCRA hazardous waste management facilities. Other potential hazards
may include the effects of temperature, presence of machinery or heavy equipment,
and associated noise levels. It is important to recognize all conditions which may
represent physical or chemical hazards and to plan accordingly.
Adherence to standard operating procedures (SOP) and assignment of respon-
sibilities is paramount in reducing the potential risks involved during on- site
monitoring activities. SOPs also allow for prompt corrective actions in the event of
a dangerous occurrence or accident. Guidance for developing site-specific SOPs can
be found in U.S. EPA publications "Standard Operating Safety Guides" (1982),
"Occupational Health and Safety Manual" (I983c), and "Draft Safety Manual for
Hazardous Waste Site Investigations" (1979).
Individuals should maintain a high level of safety consciousness at all times.
All field personnel shall follow all applicable U.S. EPA Regional, State, and facility
health and safety SOPs.
Several components of the health and safety SOPs are discussed below to
ensure adequate preparation and performance of field evaluation activities.
o Responsibilities of the Field Team Leader
Conduct the overall hazard assessment.
Designate protective equipment requirements.
Insure that all field personnel are participating in a
medical surveillance program.
Insure that all field personnel are trained in proper selection and
use of safety equipment.
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o Responsibilities of Sampling and Field Personnel
Comply with the Regional U.S. EPA, State, and facility health and
safety SOPs.
Comply with all safety procedures and regulations governing the use
of protective clothing and equipment.
Ensure that all respiratory devices used fit properly. - Maintain,
inspect, and clean all safety equipment and clothing according to
manufacturers suggested procedures.
4.6.1 Medical Surveillance Program
A program of medical surveillance shall be followed to ensure the .health and
well-being of all personrfel involved in ground-water monitoring at hazardous waste
sites. The program should consist of three main components:
o Comprehensive health examination
o Annual checkups
o Tracking and evaluation
Individuals directly involved in field inspection activities should have a
complete health examination on file. This is important not only to verify one's
physical and mental fitness, but to establish control background levels to which
subsequent test results can be compared. Persons in the monitoring program should
be free of any residual effects of previous hazardous materials exposure.
4.6.2 Enforcement of Field Safety Practices
Enforcement of safety practices in the field is established by:
o Defining a chain-of-command
o Assigning duties and responsibilities
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o Adhering to the facility health and safety plan or to the U.S. EPA
Regional or applicable State environmental agency health and safety SOPs
All the task force members will be equipped with steel toe boots, a hard hat,
a fit-tested full-face respirator, safety glasses, and long sleeve shirts.
4.6.3 Personnel and Equipment Decontamination
When all on-site activities have been completed, appropriate measures should
be taken to decontaminate and/or dispose of all equipment and protective clothing.
The extent of decontamination required at a facility is dependent on the following
factors:
o Type of contaminant
o Amount of contaminant present
o Level of protection used
o Degree or duration of contact
o Location of contaminant
In general, the decontamination procedures involve washing with special deter-
gent solutions, rinsing with large quantities of water, or, if the specific contaminant
is known, rinsing with a specialized solution known to inactivate, alter, neutralize,
or increase the solubility of the contaminant. Explicit doffing and decontamination
procedures are provided in Appendix G of the Interim Standard Operating Safety
Guidelines (U.S. Environmental Protection Agency, Office of Emergency and
Remedial Response, 1982). This document provides step-by-step decontamination
procedures for the various levels of hazard protection.
Disposable sampling equipment or protective clothing should be disposed of in
accordance with the EP-A-approved procedures of the inspected facility. The
sampling contractor for the Task Force will be responsible for packaging the
disposable equipment and clothing and transferring them to the representatives from
the facility who are designated to accept such wastes from the Task Force.
However, the field team leader -is responsible to complete and sign all forms
necessary for the transfer of these wastes to the facility.
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4.7 SCHEDULE
The facility evaluation plan should target specific dates or a range of dates
for the following activities:
o Detailed breakdown of facility evaluation activities
o Completion of laboratory analyses
o Completion of data review
o Completion of draft Facility Evaluation Report
o Completion of final Facility Evaluation Report
4.8 FACILITY EVALUATION REPORT (TECHNICAL REPORT)
The FTL is responsible for preparing a Facility Evaluation Report (Technical
Report) after the analytical results have been reviewed by the QA contractor. The
report will incorporate all aspects of the facility evaluation, cite all deficiencies
found, and summarize all areas of concern. Section 8.0 in this protocol details the
preparation of the Facility Evaluation Report.
4.9 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
A comprehensive and well-documented QA program is essential to obtaining
precise and accurate data during the inspection that are scientifically and legally
defensible. The principles outlined in the QA program must be followed when
determining the sampling locations, the number of samples to be collected, collection
procedures, preservation and transportation of samples, calibration and maintenance
of instruments, and processing, verification, and reporting of the data.
The objectives of QA/QC during facility evaluations are: (1) to ensure that
the procedures used will -not detract from the quality of the results and (2) to
ensure that all activities, findings, and results follow an approved plan and are
documented. These objectives dictate that much of the QA/QC activities during the
facility evaluation effort be conducted before the field work begins. Preparations
should include:
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o Providing written protocols for all activities
o Training all field team members regarding equipment operation, sampling
procedures, and proper documentation procedures
o Ensuring that all containers and equipment have been properly
decontaminated and are appropriate for analyses of interest
o Ensuring coordination with the contract laboratory
Field QA should specify a system of QA procedures, checks, audits, and
corrective actions specific to the site activities. Field QA will be discussed in
greater detail in Section 7.0.
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5.0 FACILITY INSPECTION
The facility inspection activities should be carried out in a methodical,
well-thought-out fashion. Although many inspections may be routine, the possibility
of adversarial postures 'by owners/operators during an evaluation and subsequent
litigation, indicates that the following items should be addressed:
o Notification Letter
o Facility Entry
o Site Reconnaissance (Pre-Inspection Visit)
o Facility Inspection
o Daily Inspection Team Debriefing Meeting
5.1 NOTIFICATION LETTER
A notification letter describing the intent and scope of the inspection
conducted under the authority of RCRA and applicable state statutes will be sent to
the owner/operator. This notification is not required by RCRA, but is intended as a
courtesy to the owner/operator of the facility.
Prior to each inspection, the Director of the Hazardous Waste Ground-Water
Task Force will mail a notification letter to the owner/operator that describes the
intent and scope of the scheduled inspection. Whenever possible, the facility
inspection should coincide with the routine ground-water sampling program of the
facility. Before the notification letter is issued, the FTL will contact all designated
team members to determine if the dates for the inspection visits are satisfactory.
If so, the notification letter can be issued. If the initial dates present a conflict
for some of the team members, the FTL should determine acceptable alternate dates.
In no instance will the notification letter waive the facility's responsibility to
conduct ground-water monitoring as required by either regulations or permit condi-
tions. It is the FTL's responsibility to work out scheduling conflicts and notify all
participants of the final inspection schedule. In no instance will the inspection be
postponed for an extended period because of scheduling conflicts.
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Approximately one week prior to the inspection date, the FTL should telephone
the facility to reaffirm the date and time of the inspection. During this
conversation, the FTL may, if requested, supply the names of U.S. EPA Regional and
State agency personnel, as well as those of any contractors who will participate in
the facility inspection. The FTL should also reiterate the general inspection
procedures including:
o Areas to be viewed
o Facility personnel to be interviewed
o Documents to be reviewed
o Sample collection procedures of the facility
Specific questions about the inspection procedures or matters of compliance
should not be discussed at this time.
5.2 PROCEDURES FOR FACILITY ENTRY
The time of facility entry should be determined by the FTL. All inspections
should be conducted at reasonable times, usually during normal working hours.
Inspections can .be extended beyond normal working hours provided that the facility
representatives agree to the extended hours.
Entry of the facility should be achieved at the location designated in the
owner/operator's response to the inspection notification letter.
The inspection team should be aware that consent to enter or remain in the
facility may be withdrawn at any time. However, any segment of the inspection
completed before withdrawal of consent remains valid. Withdrawal of consent is
equivalent to a refused entry. Therefore, a warrant may be secured to complete the
inspection.
Entry of the facility is not required to observe and report activities in plain
view from an off-site location. This includes observations made while on facility
property in areas open to the public, such as matters observed while the inspector
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presents credentials. However, if the inspector does not have a warrant, access to
any portion of the facility may be limited.
5.2.1 Entry Procedures
The following guidelines should be followed during facility entry:
o Present Credentials
Upon arrival at a facility, an inspector should introduce himself/herself as an
U.S. EPA inspector and present the proper U.S. EPA multi-media enforcement
credentials to the owner, operator, or agent in charge regardless of whether
identification is requested. The person to whom the credentials are presented may
be allowed to closely scrutinize, but not photocopy, the credentials.
o Liability Form
Inspectors shall not sign any liability form or release of liability (waiver)
when entering a facility under the authority of Federal law.
o Visitor Register
It is permissible to sign a sign-in sheet, log, or visitors' register when the
register only requests the name, government agency date, and time.
o Demeanor
U.S. EPA inspectors are required to perform their duties in a professional and
responsible manner. The use of an official position for personal gain is unlawful.
Inspectors are also required to collect and report the facts of an investigation
completely, accurately, and objectively. The inspectors must conduct them- selves
at all times in accordance with the regulations prescribed in the U.S. EPA
handbook, "Responsibilities And Conduct For EPA Employees" (1984b).
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5.2.2 Denial of Entry
If an inspector is refused entry to a facility for the purposes of an evaluation
under Section 3007 of RCRA, certain procedural steps must be carefully followed.
These steps are as follows:
1) Present proper identification to the facility representative
(owner/operator) authorized to consent to an inspection.
Consent must be given at the time of facility entry.
2) Thoroughly document the event, noting time, date, and facility personnel
encountered.
3) If entry is denied, ask the reason for denial.
4) Under no circumstances discuss potential penalties or do any thing which
mav be construed as threatening.
5) If entry is denied a second time, exit from the premises and document
any observations made pertaining to the denial, particularly any suspicions
of violations.
6) Report all aspects of denial of entry to the U.S. EPA Office of Regional
Counsel for appropriate action. Regional Counsel can obtain an
administrative inspection warrant.
7) A U.S. EPA Office of Regional Counsel attorney will assist the inspector
in preparing documents, necessary to obtain a search warrant and will
arrange for a meeting with the inspector and a U.S. Department of
Justice (DOJ) attorney. The documents should describe the needs and
urgency for the inspection. The documents should identify the potential
or suspected endangerments to human health and environment posed by
the operations of the facility and the needs for verification of
compliance with the relevant rules and regulations. The inspector will
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bring a copy of the appropriate draft warrant and affidavits to the
meeting.
8) The U.S. EPA Office of Regional Counsel attorney will inform the
appropriate Headquarters Enforcement attorney of any denials of entry
and send a copy of all papers filed to U.S. EPA Headquarters.
9) The DOJ attorney will then secure the warrant and forward it to the U.S.
Marshall who will issue it to the owner/operator.
It should be stressed that U.S. EPA's policy is to obtain a warrant only when
all other efforts to gain lawful entry have been exhausted.
5.2.3 Search Warrant
An inspection conducted under a search warrant will differ from a normal
inspection. The following procedures should be complied with in these situations:
o Use of a Warrant to Gain Entry
1) The inspector should be accompanied by a U.S. Marshall
if there is a high probability that entry will be refused
even with a warrant or when there are threats of violence.
2) The inspector should never attempt to make any forceful entry of
the facility.
3) If entry is refused to an inspector holding a warrant but not
accompanied by a U.S. Marshall, the inspector should leave the
facility and inform the U.S. EPA Office of Regional Counsel.
o Use of A Warrant to Conduct the Inspection
1) The inspection must be conducted strictly in accordance with
the warrant. If the warrant restricts the inspection to certain areas
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of the premises or to certain records, those restrictions must be
followed.
2) If sampling is authorized, all standard procedures must be followed
carefully, including presentation of receipts for all samples taken.
The facility should also be informed of its right to retain a portion
of the samples obtained by the inspector (split samples).
3) If records or property are authorized to be taken, the inspector
must provide receipts to the owner/operator and maintain an
inventory of all items removed from the premises.
4) In accordance with the warrant, the inspector should take
photographs of all areas where violations are suspected.
Photographs should also be taken at each sampling location as a
quality control measure.
Inspectors should consult supervisory personnel and U.S. EPA regional counsel
for further guidance when entry is denied.
5.3 PRE-INSPECTION VISIT
Most comprehensive sampling evaluations will require a pre-inspection visit to
the facility to determine logistics, manpower requirements, and schedules for the
field activities. This pre-inspection visit should take place after the draft facility
evaluation plan has been reviewed and preferably at least two weeks prior to the
actual facility inspection. This will enable the field inspection team to:
o Have adequate time to mobilize for the actual field inspection.
o Finalize sampling locations.
o Determine a realistic schedule for field activities.
o Determine sampling and safety equipment needs.
o Familiarize themselves with the site.
o Meet the key facility representatives.
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o Anticipate the potential site-specific logistical problems to be
encountered.
The pre-inspection visit should generally last one to two days. The FTL will
conduct this inspection, accompanied by the following individuals as needed:
o U.S. EPA Regional personnel
o U.S. EPA Task Force hydrogeologist
o State environmental personnel
o Sampling technician supervisor
The inspectors should follow the same entry procedures and initial briefing
procedures as outlined for the actual field inspection in Sections 5.2 and 5.4.
5.3.1 Scope of the Pre-inspection Visit
The pre-inspection visit generally sets the stage for a well-executed facility
inspection. The components of this visit are summarized as follows:
o Initial Briefing - The FTL will brief the owner/operator on the purpose
of both the pre-inspection visit and the full facility inspection and will
also outline the scope of the pre-inspection visit.
o Interviews - The owner/operator and other key facility personnel
will be interviewed to help resolve the following items:
1) The type of pertinent facility records for review and their
quantities and locations
2) Scheduling conflicts for the full facility inspection
3) Resources required to complete the field inspection
4) Facility safety requirements for on-site activities
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5) Coordination with facility sampling and laboratory personnel
o Visual Inspection - A brief visual inspection will be conducted to
determine:
1) The locations and conditions of the monitoring wells
2) Access to the sampling areas
3) Additions to or deletions from the recommended sampling
locations
4) Adequacy of in-place sampling equipment at the monitoring
wells
o Closing Conference - The FTL and the owner/operator of the facility will
resolve remaining scheduling conflicts and other logistical problems
identified during the preliminary evaluation.
5.4 FACILITY INSPECTION
The facility inspection consists of:
o Initial briefing with the owner/operator of the facility
o Interviews
o Records review
o Visual inspection
o Sampling procedures evaluation
o Laboratory inspection
Each of these field inspection components are detailed below.
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5.4.1 Initial Briefing with Owner/Operator of the Facility
During the initial briefing with the owner/operator of the facility, the FTL
should state the purpose of the inspection and the authority under which the
inspection is being conducted. If requested, the FTL should furnish a copy of the
Act (RCRA) and appropriate regulations to the facility representative. By
establishing an atmosphere of cooperation between the field inspection team and
facility officials, inspectors should be able to accomplish inspection activities more
easily.
o Scope of Inspection
The FTL should provide the owner/operator with the objectives of the
inspection and a final schedule outlining the facility operations to be examined.
Particular emphasis should be placed on determining the compliance of the
* * .
facility with: (1) Subpart F requirements (Ground-Water Monitoring Require-
ments) of Part 265; (2) Subpart F requirements (Ground-Water Monitoring
Requirements) of Part 264; (3) waste analysis and contingency plans specified
in Subpart B (Permit Application) of Part 270; (4) Subpart C (Permit
Conditions) requirements of Part 270; and (5) other applicable environmental
laws and regulations.
At facilities where sampling and laboratory analysis have been delegated to key
personnel, the FTL should suggest scheduling a meeting with those responsible
persons. A well-planned schedule can eliminate wasted time in waiting for
records to be gathered, key facility personnel to become available, and
intermittent facility operations to be started. During a compliance evaluation,
it would be beneficial to have a facility representative accompany the field
inspection team to describe the facility and its principal operating character-
istics and to answer any questions.
RCRA (Section 3007 (a)(2)) states that the owner/operator and other facility
officials can request and receive splits of all samples collected by the members
of the evaluation team and copies of the analytical results at a later date.
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o Requests for Documents and Data
Most information on ground-water monitoring systems, ground-water
assessment programs, and monitoring waiver demonstrations is available for
review at the Regional U.S. EPA offices and/or at the State environmental
offices. This information should be included as part of the Document Package
collected for the facility (see Section 3.0). The available documents should be
reviewed prior to the site visit. There will be instances when information will
not be available for review until the site inspection. In these cases, the
inspector should request to review the applicable ground-water documents at
the facility.
After reviewing the on-site documents, the inspector should photocopy
those documents that are pertinent to the inspection. Photocopying
should be conducted at the expense of the inspection team. Three acceptable
methods are:
1) Using a portable photocopying machine
2) Sending the material to a local photocopying vendor
3) Using a facility photocopying machine at a fair market price
5.4.2 Interviews
The facility evaluation will be more streamlined if knowledgeable facility
officials are interviewed early during the inspection. Prior to beginning the visual
inspection or records review of the facility, the following people, -if available,
should be interviewed:
1) Owner/Operator
2) Environmental staff
3) Sampling technicians
4) Laboratory manager
5) Corporate officials
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o Owner/Operator and Environmental Staff
The owner/operator and environmental staff can provide the inspection
team with a general understanding of the operations at the facility as
well as the layout of the site. This will help maximize the inspectors'
efficiency during the inspection.
o Sampling Personnel
Sampling personnel can answer specific questions regarding sample
collection procedures. For example, questions pertaining to how ground-water
wells are purged prior to sampling, the disposition of purged water, sampling
equipment and procedures, sample preservation and shipment, chain-of-custody
procedures, and any special safety considerations should be discussed with the
sampling technicians.
a
o Laboratory Manager
The laboratory manager can provide information concerning analytical
procedures and the types of parameters measured. The laboratory manager can
also discuss chain-of-custody procedures and laboratory QA/QC requirements.
The laboratory QA/QC procedures should be discussed in detail and if the
analyses are performed by an outside laboratory, the FTL should determine, on
a case-by-case basis, whether an additional inspection of the outside laboratory
is necessary. This is usually be based on the results of the performance
evaluation samples that the laboratory has analyzed.
5.4.3 Records Review
The amount of records review required at each facility is site-specific and
depends, in part, on the records compiled during the data procurement process (see
Section 3.0).
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The types of records that are important to review include the following:
o Waste analysis plans
o Inspection plans for each hazardous waste management operating unit
o Inspection logs for each hazardous waste management unit
o Operating records
o Contingency plans
o Bi-annual reports
o Ground-Water Monitoring Plan
o Outline of Ground-Water Assessment Plan
o Ground-Water Waiver
o Site Geologic Report
o Process Unit Design Report
o Description of positions and qualifications of personnel
o Training programs
Special attention should be placed on reviewing applicable ground-water
monitoring data. If a detection monitoring system is used at the facility, inspect
the files for, and evaluate the adequacy of:
o Analytical Records - All facilities should have appropriate analytical
records on file. The records should include the following information:
(1) Parameters to be analyzed
(2) Frequency of sample collection
(3) Replicates, as appropriate
(4) Timeliness
If any of the results from the analyses of National Interim Primary Drinking
Water Standards obtained during the first year exceed the respective maximum
concentration limits, the results should have been highlighted in the quarterly
report submitted to the U.S. EPA Regional Administrator.
o Ground-water elevations'- These should be determined each time a well is
sampled before purging and sampling.
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o Sampling and Analysis Plan - This plan should incorporate QA/QC
procedures.
o Well construction data - If data are not available, interview appropriate
personnel who may have knowledge of installation.
o Ground-Water Quality Assessment Outline.
o Evidence of semi-annual statistical comparison of ground-water
data - Where comparisons indicate no significant change, perform
independent comparisons using facility data (note whether alternative
. statistical procedure was used).
o Evidence of implementation of a ground-water quality assessment plan (if
«
the semi-annual statistical comparison indicates that a significant change
in ground-water quality has occurred).
If the facility has implemented an alternate ground-water monitoring program,
the owner/operator must have on record all the items required for a detection
monitoring system, plus:
o An alternate ground-water monitoring system plan (see Appendix A
for specifics regarding certification, dates of submission and
implementation, plan basics, and objectives).
o A report to the appropriate regulatory agency with the results of a
ground-water quality assessment. The report should have been submitted
as soon as technically feasible after implementation of the plan.
o Evidence of continued quarterly monitoring, including analyses and
evaluations.
o Correspondence documenting submission of the annual assessment report
to the appropriate regulatory agency.
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If the owner/operator waives any of the ground-water monitoring interim-
status requirements specified in Subpart F of Part 265, the owner/operator must
keep a detailed demonstration justifying the waiver. The demonstration must be
certified by a qualified -geologist and must comply with the requirements of Subpart
265.90(c).
5.4.4 Visual Inspection
Following the initial briefing with the owner/operator and interviews with
knowledgeable facility personnel, a detailed visual inspection must be conducted.
Appropriate safety requirements must be met when touring the facility. It may be
useful to have the plant environmental staff conduct the tour along with the
sampling technicians of the facility.
. The facility's sampling personnel should direct the inspection team to the
sampling locations specified in the Facility Evaluation Plan (see Section 4.0). They
should also demonstrate the sampling techniques practiced by the facility.
Geomorohic Features
An important aspect of the visual inspection is to ensure that all potential
sources of hazardous waste discharges to the ground water are addressed during the
facility inspection. The inspectors must locate the sources described in the
detection monitoring or ground-water quality assessment programs and determine
whether any waste source has been omitted. In the event that any waste
management areas have been omitted, the inspector must note the location, size,
and type of area in the inspection logbook and on a site map.
The natural erosional or depositional history of a facility can often be deduced
from land forms. When present, common geomorphic features, such as flood plains,
stream terraces, glacial moraines, dunes, sinkholes, drainage divides, and valley
profiles, should be identified. Topography and drainage observations from site maps
may aid in evaluating surface runoff, infiltration, and ground-water flow directions.
Topography around the site governs surface-water flow and may suggest the
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probable direction of ground-water flow. Drainage patterns may indicate bedrock
control through joints or structures which could influence ground-water flow.
The inspectors should carry a site map with them during the entire visual
inspection. All significant topographic or surficial features should be noted in the
inspector's logbook and on the site map. These features may indicate areas of
ground-water recharge or discharge resulting in amendments to the recommended
sampling locations.
Surface Water and Seeps
During the visual inspection, attention should be paid to any surface-water
bodies or- streams on or adjacent to the facility. Since ground water may be dis-
charged to these surface-water bodies, there is a possibility that contaminants in
the ground water may also be present in the surface water. Signs-of contamination
may be:
o An oily sheen on the surface of the water
o Discoloration on the banks from precipitation of contaminants
o Dead or distressed vegetation along the banks
o Unusual foaming or odors
The distances of surface-water bodies, streams, and wetlands from the facility
should be noted in the inspector's logbook as well as on the site map.
Springs and seeps represent ground-water discharge and are generally a result
of the water table intersecting the land surface or of leakage from an artesian
aquifer. Such features should be located on the site map.
Surface-water bodies; such as streams and impoundments, may be contributing
to or receiving ground-water flow. Their importance in this regard must be
evaluated. Streams, rivers, and impoundments near the facility should be located
and described in terms of physical dimensions, source waters, and topographic
relation to the facility. Water-level records for the identified surface-water bodies
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should be checked and used together with ground-water elevation data to predict
the direction of ground-water flow and possible movement of pollutants.
On-Site Wells
There are several activities that should be performed during the visual
inspection with regard to monitoring wells. First, the locations and number of
monitoring wells should be checked to ensure that all wells are located and are in
agreement with the details of the Facility Evaluation Plan (see Section 4.0).
Second, the well head and apron should be checked for overall cleanliness and
condition. Once this is completed, the pre-sampling procedures in Section 5.4.5
should be followed. In many cases, the field inspection team will only observe
facility personnel performing the pre-sampling procedures.
Photographs
Photographs should be taken during the visual inspection to document all
potential areas of noncompliance. These include:
o Overall facility operations
o All sampling locations
o Areas of off-site contamination
o Improper operational procedures
o Geomorphic features which could affect the selection of sampling
locations
Proper photographic documentation procedures are outlined in Section 7.4.2 of
this protocol document.
5.4.5 Evaluation of Pre-Sampling and Sampling Procedures
During the full inspection, the following general practices at the facility
should be evaluated. Specific questions and items to be evaluated are provided as
part of Appendix A of this protocol1.
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6.0 SAMPLING GUIDANCE
The guidance to be followed when performing on-site sampling activities is
described in this section and should be used when developing a site-specific
sampling protocol. Sampling procedures are addressed for the following: preli-
minary activities, approaching the well, measuring floaters or sinkers, well purging,
parameter-specific sampling, monitoring well sampling, and sampling other media. In
addition to the guidance presented in this section, the sampling guidance provided
in the following U.S. EPA documents should be used:
o "Draft RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document" (U.S. EPA, 1985a).
o "RCRA Draft Permit Writer's Manual: Ground-Water Protection 40 CFR
Part 264 Subpart F" (U.S. EPA, 1983a).
» .
6.1 PLANNING
Preparation and assembly of the required equipment and materials for facility
sampling should proceed as follows:
1) Equipment should be assembled based on the requirements of the
facility-specific sampling protocol.
2) All equipment should be checked for proper calibration, assembly, and
operation in accordance with the equipment manufacturer's operation and
maintenance instructions.
3) All sampling equipment that will potentially contact sample materials
should be decontaminated in accordance with the appropriate procedures
(See Section 7.3.2).
4) Equipment blanks should be collected whenever the sampling and well
purging equipment in the* field is changed.
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5) Small sampling implements such as trowels should be wrapped in clean
aluminum foil, plastic bag, or polytetrafluoroethylene (PTFE, such as
Teflon*) during transport and storage.
Mechanical and electrical equipment that will be used for sampling should be
checked to make sure they are in good working order before they are used in the
field. Backup equipment should also be brought to the field. Sampling equipment
and associated material should be assembled in a clean laboratory area for
preparation and checkout. Assembly is facilitated by using an equipment checklist
that can be developed during preparation of the sampling plan. This list should be
prepared in cooperation with all sampling personnel involved in the evaluation.
Prior to departure, items should be checked and rechecked against the list so that
nothing will be overlooked. The list should include:
o Portable analytical equipment (pH meter, conductivity meter)
o Sample preservatives -
o Analytical reagents and cleaning materials
o Glassware
o Drums to dispose of discarded materials
o Appropriate sampling gear (including, but not limited to, Kemmerer bottle
samplers, PTFE bailers, corers and submersible bladder pumps)
o Sample containers
o Shipping and sample storage containers (ice chests)
o Photographic equipment
o Water-level sounding apparatus (mechanical, electrical, or acoustic) or
interface probe
o Logbooks, sample tags, field data sheets, chain-of-custody sheets, sample
traffic reports
* The term "TEFLON" is used in this report by U.S. EPA purely as a generic
expression for polytetrafluoroethylene (PTFE) materials and in no way is meant to
serve as an endorsement of PTFE products under the U.S. Trademark name of E. I.
DuPont DeNemours and Company.
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o Protective clothing, breathing apparatus, first aid equipment, and other
safety and contingency items
o Photoionization detector
o Organic Vapor Analyzer (OVA)
6 Explosimeter
o Gasoline fuel (if gasoline driven pump will be used)
o Source of ice and expendable supplies
o Portable copy machine
o Heater (seasonal)
6.2 PRELIMINARY SAMPLING ACTIVITIES
Befqre collecting samples, the field team leader (FTL) should discuss the
following items with the members of the sampling team.
1) Determine safety considerations in approaching the wells. A point man
.should be designated and equipped with a flame ionization detector (such
as an OVA) or photoionization detector (such as an HNU)**, an
explosimeter, and a radiation survey meter. Levels of protection
appropriated for the anticipated safety action level should be reviewed.
2) Determine techniques and equipment for measurements of the depth to
water and the depth to bottom of the well. Assign individuals to take
measurements and record the results.
3) Determine method and equipment for purging.
4) Determine method and equipment for sample collection.
5) Determine order of sample bottle filling. Check to confirm proper
container labeling; establish a sample preparation area.
** References to HNU meter in this report are for illustration only; they do not
imply endorsement by the U.S. Environmental Protection Agency.
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6) Determine the need for additional sampling technicians or sampling
team to collect all samples on schedule.
7) Determine the-need of decontamination equipment.
6.3 APPROACHING THE WELL
In general, all wells should be assumed to pose a health and safety risk until
field measurements determine otherwise. The point man, accompanied by another
member of the sampling team, should don the appropriate safety gear and approach
the wells from the upwind side. When the wind direction is not apparent, a smoke
tube or similar device should be used to determine the direction. The point man,
responsible for radiation, low explosion limit (LEL), and organic vapor surveillance,
should confirm proper operation and alarm settings on the OVA, explosimeter, and
HNU meters. Ambient background readings should be taken and recorded.
Once at the well, the point man should systematically survey the immediate
area around the well, from casing to ground and from top of casing to breathing
zone. If an elevated OVA, LEL, or HNU meter reading is encountered, the point
man should retreat to a safe area and advise other members of the sampling team
to don the appropriate safety gear. If elevated radiation or LEL encountered, the
point man should retreat to a safe area and contact the FTL and facility personnel.
The FTL should then decide whether to suspend sampling of that well.
Upon opening the well, the point man should systematically survey inside the
well casing, casing to ground, from above well casing to breathing zone, and the
immediate area around the well. If elevated OVA or HNU meter readings at the
breathing zone are encountered, he should retreat and advise other members of the
sampling team to don appropriate safety gear. Action levels are not to be
determined by readings within the well casing but at the breathing zone. The
suggested action levels are:
o EPA Level C Protection' (Full-Face Respirator) - Above background but
below 5 ppm
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o EPA Level B Protection (Self-Contained Breathing Apparatus) - above 5
ppm but below 500 ppm.
If readings above 500 ppm are encountered, additional measurements should be
made to attempt to quantify the chemical(s) of concern before the level of safety
protection is determined.
6.4 MEASURING IMMISCIBLE CONSTITUENTS (FLOATERS OR SINKERS)
When determination of the presence of floaters or sinkers in the monitoring
wells is required, these measurements should be the first activity undertaken. These
measurements can be made by lowering an interface probe slowly to the surface of
the liquid in the well. The following description is for an interface probe
manufactured by, Oil Recovery System, Inc. Other interface probes are available
from other manufacturers "and they operate in a similar manner. When an audible
alarm sounds, the depth should be recorded. If the alarm is continuous, an
immiscible layer has been detected. To determine the thickness of this layer,
sampling personnel should continue lowering the probe until the alarm changes to an
oscillating signal. The oscillating signal indicates that the probe has detected an
aqueous layer. This depth should be recorded as the depth to water; the thickness
of the immiscible layer is the difference in the two recorded depths. The volume
of this immiscible layer can then be calculated. The total depth of the well from
record should be checked against the measured depth of the well.
Sampling personnel should continue lowering the probe into the well to
determine if dense phase immiscibles are present. If the alarm signal changes from
oscillating to continuous, a heavier immiscible layer has been detected. This depth
should be recorded. Personnel should lower the probe to the bottom of the well
and record the depth; the. thickness and volume of the sinker and the total water
volume in the well can then be calculated. A chart is provided in Table 6-1 to
assist in these calculations. (Refer to Sections 6.7.2 and 6.7.3 for the procedures to
collect light or dense immiscible samples).
6-5
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OSWER DIR. 9080.0-1
TABLE 6-1
LIQUID VOLUME IN A ONE-FOOT SECTION OF WELL CASING
Casing inside
diameter (Fluid oz.)
(inches) [V=5.22(I.D.)2]
1 5.22
1 1/2 11.74
2 20.88
3 46.98
4 83.52
Volume of water
(Gallons)
[V=0.0408(I.D.)2]
0.04
0.09
0.16
0.37
0.65
(Milliliters)
[V=154.4(I.D.)2]
154.4
-347.3
617.5
1389.4
2470.0
The volume of water in the well is based on the formula:
ID2
4 x L
where
D = the inside diameter of the well
L = the depth of the water in the well
V = the volume of water in the well
From Table 6-1, the volume of water or liquid in a one-foot section of a
two-inch diameter well is 0.16 gallon. The volume of liquid can be determined for
any depth by multiplying values in Table 6-1 by the depth of liquid (L value).
6-6
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OSWER DIR. 9080.0-1
6.5 WELL PURGING
Each monitoring well to be sampled should be purged of stagnant water in the
well casing according to the following procedures:
1) Determine how the well should be purged, depending on its recharge
characteristics, depth, and casing size.
2) Select the appropriate equipment to purge the well.
3) Record appropriate measurements and field observations prior to and
during the well evacuation.
4) Purge the well of three casing volumes, referring to the chart in Figure
5-1. '
5) Dispose of the extracted water at a location away from the monitoring
well network in accordance with established procedures at the facility.
6.5.1 Purging Equipment Selection
The method used to purge a well is partly dependent upon the inner diameter
of the well to be sampled, depth to water, volume of water in the well, and well
accessibility. Another important factor is the recharge characteristics of the well
as discussed in Sections 6.5.2 and 6.5.4. The types of equipment available for well
purging include hand-operated or motor-driven suction pumps, peristaltic pumps,
compressed-gas (air lift) pumps, submersible pumps, and bailers made of various
materials such as stainless steel, copper, PTFE, and PVC. Wells should be purged
with equipment that will allow large volumes of water to be removed but that will
not contaminate the remaining water in the well. However, at no time during
purging should the evacuation rate be high enough to cause the ground water to
cascade back into the well, thus causing excessive aeration and potential stripping
of volatile constituents. These considerations are discussed thoroughly in documents
such as "Manual For Ground-Water-Quality Sampling Procedures" (U.S. EPA, 198la).
6-7
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OSWER DIR. 9080.0-1
Table 6-2 presents a compilation of available well- purging equipment applicable to
various well casing diameters and water level depths.
The recommended purging equipment to be used during the field inspection are
PTFE- or stainless steel submersible bladder pumps and PTFE bailers. Dedicated
bladder pumps or bailers should be used at each well to minimize decontamination of
equipment in the field. Except when used for very deep wells (greater than 150
feet) or wells in very low-yielding formations, the bladder pumps are the
recommended choice.
Other equipment that may prove acceptable on a site-specific basis include
peristaltic pumps, gas-lift pumps, centrifugal pumps, and venturi pumps. Some of
these pumps may cause volatilization and high pressure differentials, making them
poor choices for collection of pH, specific conductance, metals, and volatile organic
samples. They may be acceptable for purging the wells if sufficient time is allowed
to let the water in the wells stabilize prior to sampling.
If surface soils come in contact with purging equipment, they could introduce
contaminants into the well. To prevent this, a trash can with a replaceable plastic
liner should be used whenever possible to hold the equipment as it is being
withdrawn from or lowered into the well. If a lined trash can is not available, a
clean plastic sheet could be placed adjacent to or around the well. The effects of
cross-contamination can be minimized by sampling the least contaminated well first
and progressing to the more contaminated ones, if such information is known.
6.5.2 Purging Procedures
If the recovery rate of the well is sufficient, three well volumes should be
evacuated (the volumes determined from Figure 5-1) and allowed to recover prior to
sample withdrawal. The amount of water removed can be determined by collecting
it in a container of known volume during the purging operation. Complete
evacuation from some of the wells may not be possible. In these cases, several
factors must be considered in determining adequacy of purging procedures. These
factors include the type of equipment used (bailers or pumps) the discharge rate,
and the intake position in the well (above screen or within screen). Intake position
6-8
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OSWER DIR. 9080.0-1
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6-9
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OSWER DIR. 9080.0-1
will affect flow patterns in the well and could influence the determination of
volumes to be evacuated to ensure sampling of fresh water from the formation.
In some instances, three casing volumes may not yield water that represents
the formation water. Whenever this condition exists, such as in recently installed
and developed wells or wells that have been redeveloped, measurements of pH and
specific conductance should be taken throughout the purging process. Purging
should continue until pH and specific conductance have stabilized; only then should
ground-water samples be collected.
Sampling personnel should record the following information while purging the
well:
1) Type of purging equipment used, types of material it is made of, including
lines used to lower equipment into the well, and types of material used in
well construction. This information should be recorded for each well.
Whether or not facility-dedicated equipment was used should also be
noted.
2) Physical properties of evacuated water:
o Color
o Odor
o Turbidity
o Presence of oil/grease or heavy-phase organic compounds
3) Intake depth in wells not completely evacuated.
4) Volumes purged from all wells.
5) Methods used to determine volumes evacuated.
6) Procedures for collection, management, and disposal of evacuated water.
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OSWER DIR. 9080.0-1
7) Decontamination and cleaning procedures for equipment used to sample
more than one well.
6.5.3 Determination of Actual Volume of Purged Water
The actual volume of purged water can be measured by several acceptable
methods:
o When bailers are used to purge, the actual volume of each bailer can be
measured using a calibrated bucket.
o An alternative method when using a bailer is to use Table 6-3 for
'determining the volume and to count the number of times the bailer is
emptied.
9
o If a pump' is used for purging, the pump rate can be determined by using
a bucket and stopwatch. The pump is then operated until the necessary
volume is purged.
6.5.4 Disposal of Purged Water
When the hazardous nature of the purged water is to be determined, it should
be based upon the facility background data, the location of the well in relation to
the waste management units, and the screening of the purged water with HNU,
OVA, pH, and conductivity meters. If these parameters suggest that the water may
not need special handling, the purged water should be disposed of on-site in the
wastewater treatment system or leachate management system or in accordance with
the established facility procedures. When the purged water is deemed a hazardous
material, it should be drummed and disposed of properly.
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OSWER DIR. 9080.0-1
TABLE 6-3
BAILER SAMPLE VOLUME PER ONE-FOOT SECTION OF BAILER
I.D. Size Sample of Volume
(inches) (Fluid oz.) (Gallons) (Milliliters)
[V»5.22(I.D.)2] [V=0.0408(I.D.)2] [V=>154.4(I.D.)2]
1/2
3/4
1
1 1/4
1 1/2
2
2 1/2
5
4
1.31
2.95
5.22
8.16
11.74
20.80
32.60
47.00
83.50
0.01
0.02
0.04
0.06
0.09
0.16
0.26
0.37
0.65
38.6
86.9
154.4
241.3
347.3
617.6
965.0
1,390.0
2,470.0
6.5.5 Procedures for Slow-Recharging Wells
Where slow-recharging wells are encountered, the three casing volume minimum
requirement may be waived. There are currently several different approaches to
purging and sampling wells that recharge slowly. These approaches include:
o Evacuating the well to dryness and allowing it to recover enough such
that a full sample volume can be withdrawn from the well
o Allowing the well to recharge after complete evacuation while
taking several small incremental samples during recharge
Water level recovery measurements should be taken after purging to justify
previously obtained well recovery information or establish current well recovery
information. During recovery, samples should not be collected until incremental
measurements of pH and specific conductance have stabilized.
Regardless of which approach is used, the volatile organic sample should be
collected as soon as possible.
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Sampling personnel should consult the U.S. EPA "Draft RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document" (I985a) for specific guidance.
6.6 PARAMETER*SPECIFIC SAMPLING REQUIREMENTS
Depending on the type of analyses planned for each of the samples obtained at
a facility, there will be different requirements for containerizing and handling
samples.
Each sample collected during the facility evaluation will be analyzed for the
entire hazardous substance list (HSL) organic and inorganic parameters specified
under the CLP contract. This parameter list closely resembles the standard priority
pollutant parameter list. A copy of the current HSL parameter list is shown in
Appendix D. This list is subject to change as new methods for chemical analysis
are developed or the Task Force modifies the parameter list to meet the goals of
facility evaluation.
Special sampling and sample handling procedures must be followed when HSL
samples are being collected. These procedures are:
1) All sampling equipment which comes into contact with the water in the
well must be decontaminated in accordance with the procedures described
in Section 7.3.2.
2) Sampling personnel must wear a clean pair of disposable gloves at each
sampling location.
3) If possible, background samples and suspected contaminated samples
should be collected by different sampling team members. If this is not
possible, background samples should be collected first and containerized
separately.
4) One member of the sampling team should take all field notes and records
while the other members conduct the sampling.
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OSWER DIR. 9080.0-1
5) Surface water samples should be collected before sediment samples at the
same location.
6) Sufficient sample material should be obtained so that all of the
parameters can be analyzed. For water samples, this requires the
collection of a number of sample aliquots at each sampling location.
Appendix E provides a suggested list of parameters, sample volumes, and
containers.
6.7 MONITORING WELL SAMPLING
The primary objective of a well sampling plan is to obtain representative
samples of ground water that are properly preserved and handled according to the
requirements of the analytical methods. Attention should be given to appropriate
documentation of all activities. The procedures to be used are as follows:
1) Select the right equipment, depending on the construction and depth of
the well, field conditions, and the analytes of interest.
2) Obtain samples from the well, avoiding undue aeration or turbulence and
using the methods specified in Section 6.7.1.
3) Transfer sample material to the appropriate containers and preserve
samples according to standard methods.
4) Measure in-situ parameters (pH, specific conductivity, and temperature) at
the time of sampling.
5) Decontaminate .all sampling equipment before it is used at another
sampling location.
6) Document all sampling activities, including numbers, times, and dates of
samples; personnel involved; and equipment used.
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OSWER DIR. 9080.0-1
6.7.1 Selection of Sampling Equipment
Several different kinds of sampling equipment are available to obtain
ground-water samples. Considering sample integrity as the most important criteria
for sampling equipment selection, the order of equipment preference generally
recognized is:
1) Bailer (PTFE or Stainless steel), provided it is equipped with double check
valves and bottom emptying device
2) Syringe bailer (stainless steel or PTFE)
3) Single check valve PTFE or stainless steel bailers
4) Gas-operated, PTFE or stainless steel squeeze pump (also referred to as a
bladder pump wrth adjustable flow control)
5) Vacuum bottles (However, they should not be used to collect samples for
volatile organics analyses.)
The Agency does not recommend the use of:
1) Gas-driven piston pumps
2) Suction lift pumps
3) Gas-lift samplers
4) Turbine or impeller pumps
Whenever possible, dedicated PTFE bailers with double check valves that are
bottom emptying should be used for ground-water sample collection. Use of
dedicated bailers will minimize potential contamination of sampler. These bailers
can be used to collect all sample parameters.
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OSWER DIR. 9080.0-1
6.7.2 Collection of Light Immiscibles (Floaters)
The approach to collecting floaters is dependent on the depth to the surface
of the floating layer and the thickness of that layer. The floater must be collected
prior to any purging activities. If the thickness of the floater is 2 feet or greater,
a bottom valve bailer is the equipment of choice. The bailer should be lowered
slowly until contact is made with the floater surface, and lowered to a depth less
than that of the floater/water interface depth as determined by preliminary measure
with the interface probe.
When the thickness of the floating layer is less than 2 feet, but the depth to
the surface of the floating layer is less than 15 feet, a peristaltic pump can be used
to "vacuum" a sample.
' When the thickness of the floating layer is less than 2 feet and the depth to
the surface of the floating layer is beyond the effective "reach" of a pump (greater
than 25 feet), a bailer must be modified to allow filling only from the top.
Sampling personnel should disassemble the bottom check valve of the bailer and
insert a piece of 2-inch diameter PTFE sheet between the ball and ball seat. This
will seal off the bottom valve. The ball from the top check valve should be
removed to allow the sample to enter from the top. The buoyancy that occurs
when the bailer is lowered into the floater can be overcome by placing a length of
1-inch stainless steel pipe on the retrieval line above the bailer (this pipe may have
to be notched to allow sample entry if the pipe remains within the top of the
bailer). The device should be lowered carefully measuring the depth to the surface
of the floating layer, until the top of the bailer is level with the top of the
floating layer. The bailer should be lowered an additional one-half thickness of the
floating layer and the sample collected. This technique is the most effective
method of collection if the floater consists of only a few inches of material.
6.7.3 Collection of Heavy Immiscibles (Sinkers)
The best method for collecting sinkers is to use a double check valve bailer.
The sampling personnel should slowly lower the bailer to the bottom of the well and
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OSWER DIR. 9080.0-1
let it remain there for a few minutes before slowly raising the bailer out of the
well. The sinkers must be collected prior to any purging activities.
6.7.4 Collection of Ground-Water Samples
The major consideration for collecting ground-water samples is ensuring that
samples are not altered or contaminated during the process. Sampling equipment
must be constructed of materials compatible with actual or potential contaminants.
These materials must neither leach nor adsorb parameters of interest. Sampling
equipment must be dedicated to individual wells or be capable of being fully
disassembled and decontaminated between well samplings. As previously mentioned,
dedicated PTFE bailers is the preferred method. However, where dedicated sampling
equipment is installed in the monitoring well, and that equipment is deemed
adequate to collect ground- water samples by the FTL, then the sampling personnel
may collect the samples from the dedicated equipment.
PTFE bailers should be lowered into the wells with a cable. PTFE and
stainless steel single-strand cables are the recommended types. Types of cables not
acceptable include polyethylene, viton, neoprene, silicon rubber, tygon, and PVC.
Samples should be collected as soon as possible after the wells are purged
using the recommended equipment specified in Section 6.7.1.
Use of recommended equipment will help minimize the possibility of contami-
nating the sample with material leaching from the discharge tube/hose of the pump
and/or from inadequate decontaminating of the internal pump parts or the inside of
the pump discharge tubing.
The sampling procedure outline below assumes that the preferred PTFE bailer
equipped with double check valves and a bottom emptying device is used for well
sampling. The sampling should proceed as follows:
1) Select a new or cleaned PTFE bailer.
2) Check the operation of check valve assemblies to confirm free operation.
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OSWER DIR. 9080.0-1
3) Attach bailer to a PTFE-coated stainless steel cable or wire. The cable
should be of sufficient length to allow for water-level drawdown during
sampling. Clean sampling equipment should not be placed directly on the
ground. Use. a drop cloth and feed the cable from clean reels. The
cable should be wiped with deionized water and air dryed before it is
rewound onto the reel.
4) Lower bailer slowly until it contacts the water surface.
5) Allow bailer to sink and fill with minimal surface disturbance to minimize
degassing of water.
6) ' Slowly raise bailer to surface. Do not allow bailer line to contact
ground. Place bailer line on protective liner.
» '
7) Open bottom emptying device to allow slow discharge and ensure the
water flows gently down the side of the sample bottle with minimal entry
turbulence. Measurements of pH, temperature, specific conductance, and
turbidity should be obtained from the first sample. An intermediate
container may be used for collection of volatile organics sample (See
Section 6.7.5).
8) Repeat above steps as needed to acquire a sufficient sample volume to fill
all containers.
9) Samples should be collected and containerized in the order of the
parameters' volatilization sensitivity. Table 6-4 lists the preferred
collection order for some common ground-water parameters.
When PTFE-coated cable is reused, it must be decontaminated when the cable
is lifted from the well. The cable should be wiped with hexane and then with
distilled water and allowed to air dry.
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OSWER DIR. 9080.0-1
Special care should be taken in transferring water from the bailer to sample
containers so that the sample is not aerated. This is especially important for
volatile compounds, but is also a concern for metal samples so that oxidation is
avoided.
When sampling deep wells, it is recommended that a boom and crank be used
to lower and raise the bailers. This will reduce the time and manpower required to
sample deep wells.
TABLE 6-4
ORDER OF PREFERRED SAMPLE COLLECTION
1. Volatile organics (VOA)
2. Purgeable organic carbon (POC)
3. Purgeable organic halogens (POX)
4. Extractable organics
5. Pesticide/Herbicide
6. Dibenzofuran/Dioxin
7. Total metals
8. Dissolved metals
9. Total organic carbon (TOC)
10. Total organic halogens (TOX)
11. Phenols
12. Cyanide
13. Nitrate and Ammonia
14. Sulfate and chloride
15. Nitrate and ammonia
16. Radionuclides
6.7.5 Collection of Volatile Organics Samples (VOA)
VOAs should be collected from the first bailer removed from the well after
purging. The PTFE bottom emptying device should then be inserted into the bailer.
The sampling personnel should bring the VOA bottle to tip of the bottom emptying
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OSWER DIR. 9080.0-1
device, and fill the bottle. If a bubble exists, he should repeat the procedure until
no bubbles exist in the VOA bottle.
An intermediate container (such as a properly decontaminated beaker) may be
used when field conditions dictate that collection of the sample' directly into the
VOA bottle cannot be accomplished. The decision will be made by
the FTL.
6.7.6 Measurements of Field Parameters
When each well is sampled, four in-situ parameters should be measured:
temperature, pH, specific conductance, and turbidity. These measurements should be
obtained from the first sample. A separate sample can be withdrawn from the
screened interval of the well into a beaker. Direct-reading instruments will then be
used to record the results.
Many ground-water samples are turbid [>5.0 nephelometric turbidity units
(NTU)]. If the turbidity is caused by suspended silts and clays, it may indicate that
the wells were improperly constructed and/or developed, which may have been
exposed earlier during the review of the well logs. However, turbid samples may be
produced from -wells which are properly constructed and maintained. The source of
this turbidity is not completely understood; however, it could be caused from
dissolved organic compounds, inorganic precipitates, or chelates. The sporadic and
infrequent use of monitoring wells may also allow silts and clays to enter a properly
constructed well. Until this phenomenon is adequately understood, turbidity
readings should be accurately recorded. The Task Force may wish to accumulate
turbidity data, well construction specifications, and aquifer materials for later study.
6.8 SAMPLING GROUND-WATER SEEPS (SURFACE WATER)
6.8.1 Selection of Sampling Locations
Sampling locations for ground-water seepage should be selected on the basis of
their probability for showing contaminant migration from a facility. Prior to any
sampling, surface water drainage at and around the facility should be characterized
6-20
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OSWER DIR. 9080.0-1
using all available background information, including topographic maps and aerial
photography.
Sampling locations may include rivers, brooks, or streams running through or
adjacent to a site. These include bodies of water receiving ground-water discharge
and/or leachate from a site. In areas where the ground surface slopes steeply away
from buried wastes, ground-water seepage or leachate may emerge from the ground,
forming a damp or wet area or a small stream. Samples taken from such streams
may have to be treated as medium or high concentration samples, depending upon
information obtained during the field inspection. Exposed soil should be examined
for areas of discoloration. Areas of excessive dead vegetation, are also good
indicators of leachate emergence.
6.8.2 Sampling Techniques and Equipment
« .
Sampling for ground-water seepage at hazardous waste management facilities
involves a number of different problems and concerns. The major criteria used in
determining how and where to sample surface leachate streams include obtaining a
representative sample, ensuring the safety of the personnel involved in sampling,
and using a method which is applicable at various facilities. Due to the nature of
the facilities, no one sampling method can be considered to be reliable for obtaining
a representative sample at every location. Therefore, the judgment and discretion
of the FTL and sampling supervisor are required to determine the most suitable
sampling technique.
Sampling leachate streams may require creating a weir to enable the fluid to
spring free of the surface and to provide a sufficient volume for the parameter
analyses. The leachate samples will be collected as grabs taken over a short period
of time (less than 15 minutes).
The best method for manually collecting samples is to use the actual sample
container which will be used to transport the sample to the laboratory. This
eliminates the possibility of contaminating the sample with an intermediate device.
The actual sample container must always be used for collecting organic and bacterial
samples.
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OSWER DIR. 9080.0-1
If sampling personnel cannot physically reach the ground-water seeps, an
intermediate collection container may be used. The sample is then collected by
lowering a properly cleaned PTFE, plastic, glass, or stainless steel collection vessel
into the material to be sampled. The type of collection vessel used depends on the
parameter being sampled. Samples should be collected manually by tipping the
collection container into the seep or stream so the mouth of the container faces
upstream. Using this procedure, the container should be rinsed out at least twice
before a sample is collected (except if preservatives are present in the sampling
container or if oil and grease is the parameter of interest). Care should be taken
to avoid collecting leaves, stones, and other debris. The sample bottle should be
filled with about 10 percent ullage (empty space) remaining for shipping purposes.
However, if the bottle is used for a volatile organic sample, it should be filled
until the sample touches the septum of the bottle and all air space in the bottle is
eliminated. In some instances, a wide-mouth quart jar may have to be used to
f
collect the sample. This sample should then be transferred to appropriate sample
bottles for analysis. The quart jar used for sampling should be disposed of at the
facility. The outside surface of all containers used for sampling must be
decontaminated prior to packaging and shipment.
After the samples have been collected, they should be preserved as necessary
and placed on ice (4°C) for transport to the laboratory. Leachate samples are
generally considered hazardous and will not be preserved. Stream samples are
generally preserved since they will most likely be considered environmental samples.
6.9 SAMPLING SOIL
6.9.1 Selection of Sampling Locations
Soil sampling will generally be confined to surface soils or shallow coring
using hand equipment such as shovels, post hole diggers, or hand augers. Surface
soil/sediment sampling should be conducted in depositional areas on the periphery of
the study area, primarily in the downstream or downgradient portion of the area of
interest. ;
6-22
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OSWER DIR. 9080.0-1
6.9.2 Sampling Techniques and Equipment
Soil sampling can be done using either hand or power equipment. Hand equip-
ment such as spoons, scoops, shovels, hand augers, and small diameter push tubes
are available and can be used for sampling at shallow depths. However, hand
equipment is limited even at shallow depths when the soils are difficult to
penetrate. Power equipment such as augers should be used for sampling at shallow
depths when hand coring equipment cannot be used.
Shelby sampling tubes or thin wall push tubes should be used .with both power
and hand equipment. Stainless steel construction is recommended for these tubes.
Soils should be extruded from the tubes for logging and selective sampling or sealed
in the tubes and sent directly to the laboratory.
Surface soil samples can be collected with a stainless steel spoon or scoop.
Grass, leaves, or other debris should be scraped away prior to sampling.
Shallow depth samples should be collected by digging a hole with a shovel or post
hole digger, removing all loose soil, and collecting a sample at the desired depth
using a stainless steel sampling spoon. For deeper sampling using hand equipment, a
larger diameter auger is used until the desired depth is reached. A small diameter
auger or Shelby tube is then used to collect the sample. The sample is extruded
and then placed in an aluminum or stainless steel pan for mixing. These procedures
should be repeated until the desired amount or number of samples are collected. If
an undisturbed sample is required, the Shelby tube and sample should be shipped
intact to the laboratory for analyses.
6.10 SAMPLING SURFACE IMPOUNDMENTS
6.10.1 Selection of Sampling Locations
Surface impoundments used for the storage or evaporation of hazardous wastes
vary greatly in size. It is difficult to collect representative samples from large
impoundments without incurring Considerable expense and assuming excessive risk.
Any samples desired beyond about 10 feet from the bank will require the use of a
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boat or crane and, therefore, generally will not be feasible to collect. Because of
the difficulty in obtaining representative surface impoundment samples, very few
samples in this media are collected during field inspections.
Lakes, ponds, and impoundments have a much greater tendency to stratify than
rivers and streams; the relative lack of mixing requires that more samples be
obtained. The number of water sampling sites on a lake, pond, or impoundment
vary with the size and shape of the basin. In ponds and surface impoundments, a
single grab at the deepest point is sufficient. In naturally-formed ponds, the
deepest point is usually near the center; in impoundments, the deepest point is
usually near the dam.
6.10.2 Sampling Techniques and Equipment
Many different kinds of sampling devices have been developed to obtain
samples from a surface impoundment. The sampling team, in consensus with the
FTL, should select the equipment which best suits the needs of a particular
sampling situation. (Federal regulation 40 CFR 261, Appendix I, recommends that a
pond sampler be used for sampling surface impoundments. Therefore, it is the
recommended choice during comprehensive sampling evaluations.) Several types of
sampling equipment are discussed below.
o Pond Sampler
The pond sampler consists of an adjustable clamp which holds the bottle. The
clamp is attached to the end of a two- or three-piece telescoping aluminum
tube that serves as the handle. This device can be used to collect samples as
far as 10 feet from the bank.
o Kemmerer Bottle Sampler
The sampler consists of a tubular vessel constructed of stainless steel or PTFE
and equipped with a trigger-activated closure at either end. The device is
lowered to the desired depth and closed by sending a weighted messenger down
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the support line to the triggering device. Modifications of this design include
Van Dora and Nanson bottles.
o Rod and Clamp
This device consists of 6-foot sections of aluminum rod which can be taped
together to a desired length. A chain clamp is secured on one end and holds
the sample container. This device is best used to obtain surface samples,
although subsurface samples can be obtained by manipulating the location of
the rods and clamp.
o Sub-Surface Grab Sampler
This device consists of a long aluminum tube with two adjustable stainless
steel clamps which hold a sample bottle. A rod attached to the tube removes
and replaces the sample bottle cap while the bottle is submerged. Samples are
obtained by placing a capped bottle in clamps, submerging the sampler in
liquid, and turning the handle of the rod to remove and replace the cap.
o Weighted Bottle Sampler
This sampler consists of a bottle, usually glass, a weight or sinker, a bottle
stopper, and a line that is used to open the bottle and lower and raise the
sampler. The weighted bottle sampler can be used to sample liquids in a pond,
lake, or impoundment. It cannot, however, be used to collect liquids
that are incompatible or react chemically with the weight sinker and line.
Although there are a few variations of this sampler, the sampling procedure is
the same. The sampler is lowered to the proper depth. The stopper is then
pulled out with a sharp jerk of the chain or cable attached to the stopper.
The bottle is allowed to fill completely, as evidenced by the cessation of air
bubbles. When full, the sampler is raised.
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7.0 FIELD QUALITY ASSURANCE
7.1 TRAINING OF FIELD PERSONNEL
The selection of qualified personnel and their participation in appropriate
training activities is essential for the proper performance of a comprehensive
facility inspection. Preparation for on-site inspection must include detailed
pre-inspection briefings, particularly for less experienced personnel. The
requirement for planning and carefully thought-out field sequences must be stressed.
Field personnel training should stress proper sampling procedures, documen-
tation, and safety. All U.S. EPA or State field inspectors should be U.S. EPA-certi-
fied to conduct RCRA inspections, have completed adequate health and safety train-
ing, be participating in a medical monitoring program, and have U.S.
EPA/State-authorized RCRA credentials.
Specific training that all field inspectors should have includes the following:
o Inspection Procedures
Presentation of Credential
Handling of Denial to Enter
CBI Handling and Review of Data
Documentation in Logbook
Documentation of Photographs
Conducting Exit Briefing
o Field Safety Training
Responsibilities
Safe and Restricted Zones
Observations and Surveillance
Respirators and Self-Contained Breathing Apparatus
Protection Clothing
Health Hazards
Storage and Transportation Requirements of the Department of
Transportation
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The sampling technicians, sampling team supervisor, and field team leader
(FTL) also need to be trained in proper sampling techniques as follows:
o Procedures (sampling site selection, sampling, and field testing)
o Equipment (selection, maintenance, operation, and decontamination)
o Field QA Requirements (QC samples, handling, custody)
o Documentation
o Shipping
Training needs should be identified by the FTL. The FTL should also assume
the responsibility of ensuring that training has been completed and that personnel
are certified in the appropriate areas. A record of the type and duration of
training for each individual should be kept as part of the ongoing program of QA
activities.
.
«
7.2 QUALITY ASSURANCE/QUALITY CONTROL SAMPLES
The sampling activities during an evaluation should include the preparation and
analysis of several sets of quality control (QC) samples. The QC samples fall into
two major categories: field QC blanks and duplicate QC samples.
7.2.1 Field QC Blanks
Several types of field QC blanks are recommended for comprehensive sampling
evaluations. They include trip blanks, field blanks, and equipment blanks.
Trip blanks are used to determine whether contamination is introduced from
the sample containers during transport to the facility and storage at the facility.
These blanks should be prepared by the sampling team using distilled, deionized
water of known high purity and sent with the other sample bottles to "the field.
They should be stored in a cooler in the truck and sent to the laboratory on the
last day of sampling. One set of trip blanks should be prepared for each analytical
parameter group, such as organic ;compounds, metals, and volatile compounds, per
trip.
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Field blanks are used to determine whether contamination is introduced from
the sample collection activities or sampling environment. They should be prepared
by bringing a quantity of distilled deionized water to the field and using this water
to prepare appropriate, sample aliquots for each parameter. This is also the
responsibility of the sampling team. The number of field blanks prepared will
depend on the conditions encountered at the facility. Where conditions exist such
that normal facility operations may influence the samples (such as collecting samples
close to operating units, or collecting samples along the haulroad), more than one
field blank may be necessary. It is the responsibility of the FTL to make this
decision. In all instances, at least one set of field blanks should be prepared per
site inspection.
Equipment blanks are used to determine whether contamination is introduced
from the sample collection equipment. Dedicated purging and sampling equipment
should be provided for each well to be sampled during field activity. All equipment
will have been cleaned in the laboratory in batches and individually wrapped and
sealed prior to shipment to the field. Therefore, a field blank should be collected
for each batch of laboratory decontaminated equipment.
All field QC blanks must be submitted in the same manner as the other field
samples, with no distinguishing labeling or markings.
7.2.2 Field Duplicate Samples
Duplicate samples are used to evaluate the precision of chemical analyses of
ground-water samples for the determination of the reliability and quality of data.
Duplicate samples should be taken at least once for every analytical parameter
group to be tested during each evaluation. Where more than ten wells are sampled,
two wells should be selected for duplicate samples. In addition, all volatile organic
samples are to be duplicated.
The evaluation of duplicate samples is more useful when chemical compounds of
interest are found in the sample. ; The field team leader should choose a well for
duplicate sampling that is known or suspected of being contaminated by the greatest
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number of compounds of interest. This decision can be based on historic
ground-water analyses and/or knowledge of the ground-water flow direction. If
historical data do not suggest contamination from the site, the duplicate samples
should be selected downgradient of any area which has had the minimum safeguards
against leakage. Duplicates are most useful when they contain a large spectrum of
contaminants compared to a sample heavily contaminated with a single compound or
group of compounds.
The duplicate well selection can be separated between organic and inorganic
compounds. For instance, at sites with numerous waste management units, the
inorganic duplicate should be selected from a well monitoring a unit handling
inorganics. Wells selected for duplicates must have enough water to provide the
full aliquot for the inorganic and/or the organic component. No more than two
wells (one- organic, one inorganic) may be used for a single duplicate set or aliquot.
Both organics and inorganics may be duplicated from the same well.
7.2.3 Laboratory Duplicate Samples
Laboratory duplicates are used to evaluate the accuracy of the laboratory
analyses. A laboratory duplicate is obtained by splitting a sample at the laboratory.
One-half of the sample is analyzed as a routine sample; the other half is spiked
with a predetermined concentration of known chemicals before analysis. The
recovery rate for the spike chemicals will indicate the reliability of the laboratory
analysis. Generally, the FTL selects one of the field duplicate samples to be spiked.
The volume of the spiked sample should include an extra 2-liters of water. The
FTL should clearly label the traffic report "Sample to Spike." Laboratory duplicates
are to be taken once every twenty samples or once every week, whichever comes
first. Candidate locations for collecting laboratory duplicates should be tentatively
selected at the facility evaluation (project) plan consensus meeting and confirmed at
the pre-inspection visit.
7.2.4 Additional Compounds
If it is decided that compounds not normally analyzed for should be included
in the sampling program, the Task Force Deputy Director should be notified at least
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two weeks prior to sampling. This notification should include the names of the
additional compounds, the analytical methods, and the detection limits. This topic
should be considered at the facility evaluation (project) plan consensus meeting.
7.3 EQUIPMENT
7.3.1 Routine Maintenance/Calibration
All field equipment used for obtaining field measurements must be calibrated
prior to the inspection and at periodic intervals during use. Calibration records
must be maintained to demonstrate the precision and accuracy of field measurements
made with a particular instrument.
Calibration records should include:
o A unique identification number assigned to the device, such as the
factory serial number
o The source and traceability of the standard(s) used for calibration
o The "name of the person performing the calibration, the date, and a
notation as to whether it was a routine check or one required by
malfunction
Equipment calibration must be further supported by routine maintenance
appropriate for the individual types of equipment in use. Routine maintenance
includes changing batteries in portable meters and lubricating moving parts of a
sampling device with non-contaminating materials. Maintenance of auxiliary equip-
ment, such as portable generators, will also aid the sampling effort.
Maintenance records must be kept similar to calibration records and must
document the type of work done (routine checks, emergency repairs), the person
performing the work, and the identity of the equipment.
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7.3.2 Decontamination
Sampling personnel should assume that sampling equipment, either new or used,
is contaminated and, therefore, should be decontaminated according to the
procedures appropriate for its construction and intended use. The decontamination
of equipment should be performed at the laboratory of the sampling team prior to
the inspection.
The decontaminated equipment should be packaged to protect it from dust.
Aluminum foil is preferred for wrapping the decontaminated equipment. Plastic bags
can be used to hold larger items, such as bailers and bladder pumps, after they are
wrapped in aluminum foil. A label stating the level of decontamination, date of
decontamination, and initials of individual certifying decontamination should be
attached to the protective package in such a way that the label will not be torn
during unpackaging. A piece of equipment in a package with a torn label should
«
not be used for sampling ahd should be considered as contaminated.
Field decontamination of sampling equipment should be performed only under
extenuating circumstances such as logistical considerations and shortage of dedicated
sampling equipment. When field decontamination cannot be avoided, the following
general rules should be adhered to:
1) No equipment should be decontaminated in the field more than once
between laboratory decontamination.
2) Equipment used to collect hazardous waste samples must be
decontaminated before it can be used to collect environmental samples.
In general, any decontaminated equipment should only be used to collect
samples of "lower quality" than the first sample collected.
3) All decontamination and subsequent use of decontaminated equipment
should be documented in a field logbook.
4) Equipment should never be reused if visual signs, such as discoloration,
indicate that decontamination was insufficient.
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Decontamination of small sampling tools, such as soil scoops and containers, is
not be required if the equipment is properly disposed of after use. Disposable
sampling tools and waste products from field decontamination, such as waste rinse
water and waste solvent, should be properly disposed of on-site in accordance with
the disposal procedures of the facility or should be packaged for off-site disposal.
The following eight sections detail the procedures for the five general levels
of decontamination and the field decontamination of pumps, bailers and compositing
containers.
7.3.2.1 Level 1 Decontamination
The following decontamination procedures are suitable for glassware and stain-
less steel equipment that are used for the collection and coatainerization qf organic
samples and that can tolerate high temperatures generated by a muffle furnace.
1) Wash thoroughly with nonphosphate detergent in hot water
2) Rinse several times with tap water
3) Rinse several times with reagent grade distilled/deionized water
4) Rinse" once with acetone
5) Rinse once with pesticide grade hexane
6) Place in muffle furnace at 450°C for 15 to 30 minutes
7) Allow to cool; protect from dust and other contaminants by sealing or
covering with aluminum foil
7.3.2.2 Level 2 Decontamination
The following decontamination procedures are suitable for PTFE equipment and
stainless steel equipment that are used for collection of organic samples and that
cannot withstand the high temperatures of the muffle furnace.
1) Wash thoroughly with nonphosphate detergent in hot water
2) Rinse several times with 'tap water
3) Rinse several times with reagent grade distilled/deionized water
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4) Rinse once with acetone
5) Rinse once with pesticide grade hexane
6) Air dry in hood
7) Cap or cover after drying; PTFE bailers and other applicable equipment
should be wrapped in aluminum foil and then placed in plastic bags
NOTE: Chromic acid can be used to remove persistent organic deposits.
This is never used for metal sample containers.
7.3.2.3 Level 3 Decontamination
The following decontamination procedures are suitable for sample containers
used to store metal samples.
1) Wash thoroughly with nonphosphate detergent in hot water
2) Rinse once with 1:1 nitric acid
3) Rinse several times with tap water
4) Rinse once with 1:1 hydrochloric acid
5) Rinse several times with tap water
6) Rinse several times with reagent grade distilled/deionized water
7) Invert and air dry in dust free environment
8) Cap after drying; use aluminum foil
NOTE: If chromic acid is used as cleaning agent, rinsing must be
increased. Note the use of chromic acid on bottle box seal.
7.3.2.4 Level 4 Decontamination
The following procedures are suitable for decontaminating safety equipment
such as respirators, boots,-and gloves that are susceptible to degradation by solvent
rinsing.
1) Brush off loose dirt with soft bristle brush or cloth
2) Rinse thoroughly with tap water
3) Wash in nonphosphate detergent in warm water
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4) Rinse thoroughly with tap water
5) Rinse thoroughly with reagent grade distilled/deionized water
6) Air dry in dust free environment; keep articles out of the sun.
7) Store in plastic bags.
7.3.2.5 Level 5 Decontamination
The following procedures are suitable for decontaminating ancillary equipment
such as ropes, extension cords, generators, hand carts, and field sampling equipment
to be returned to the laboratory for decontamination.
1) Brush off loose dirt with stiff bristle brush
2) Rinse off with high pressure water
3) ' Air dry
7.3.2.6 Field Decontamination of Pumps
1) Submerge pumps in a nonphosphate detergent solution such as Alconox***
2) Operate pump for a minimum of 10 minutes; recycle the soap solution to
a wash basin through an entire length of hose when the hose must be
reused
3) Clean all exterior surfaces of both tubing and pump with bristle brush
and clean cloth
4) Submerge pump in tap water
5) Operate pump for a minimum of 10 minutes; recycle the water to rinse
basin through an entire length of hose
6) Submerge pump in reagent grade distilled/deionized water
*** References to Alconox in this report are for illustration only; they do not
imply endorsement by the U.S. Environmental Protection Agency.
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7) Pump the deionized water to the rinse basin for disposal (do not recycle
deionized water)
8) Repeat steps 6 and 7 two times
9) Place pump and hose on rack to air dry
10) Wrap pump and hose in aluminum foil and then place the equipment in a
plastic bag; seal bag and place a label on the bag indicating date of
decontamination
7.3.2.7 .Field Decontamination of Bailers
1) Disassemble both .top and bottom check valve assemblies
2) Clean all component parts in nonphosphate detergent solution using a
bristle brush and a bottle brush to clean inside surfaces
3) Rinse all surfaces five times with tap water
4) Rinse all surfaces twice with pesticide grade hexane
5) Rinse all surfaces five times with reagent grade distilled/deionized water
6) Place all components on rack and allow to air dry
7) Wearing clean surgical gloves (powderless), reassemble bailer
8) Wrap bailer in aluminum foil and place it in a plastic bag; seal and label
the bag indicating date of decontamination
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7.3.2.8 Field Decontamination of Compositing Containers
1) Scrub both inside and outside surfaces of container, lid, and PTFE liner
with nonphosphate detergent solution using a bristle brush
2) Rinse five times with tap water
3) Rinse once with hexane
4) Rinse five times with reagent grade distilled/deionized water
5) Place on drying rack and allow to air dry
6) ' Replace PTFE liner and lid
7) Place label on lid and indicate date of decontamination ' '
7.4 DOCUMENTATION
7.4.1 Field Forms and Personal Logs
Accountable field documents include items such as logbooks, field-data records,
correspondence, sample tags, graphs, chain-of-custody records, bench cards,
analytical records, and photographs. Each document must bear a serialized number
and be listed, with the number, in a project document file assembled at the end of
the evaluation.
All field logbooks, field-data records, field-laboratory logbooks, sample tags,
and chain-of-custody records should be numbered and assigned to the inspection
personnel for appropriate distribution and accountability. The logbook of the FTL
should document the transfer of other logbooks to individuals who have been
designated to perform specific tasks during the inspection. All pertinent factual
information must be recorded in these logbooks from the time each individual is
assigned to the inspection team until the inspection is completed. Logbook entries
must be dated, be legible, and contain accurate and inclusive documentation of
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inspection activities. The logbook must contain only facts and observations.
Language should be objective, factual, and free of personal opinions or other
terminology which might prove inappropriate. Entries made by individuals other
than the person to whom the logbook was assigned should be dated and signed by
the individual making the entry.
Assignment of all serialized sample tags to field personnel must also be
recorded in the sampling supervisor's logbook. At no time should any sample tags
be discarded. Tags that are lost, voided or damaged, or transferred on split samples
should be noted in the appropriate logbook immediately upon discovery.
Other documentation of field activities, such as records of sample numbers and
chain-of-custody, is covered in Section 7.5.
7.4.2 Photographs . -
a '
Photographs are important in documenting.the cause and effect relationship of
hazardous materials migrating off-site, especially in the areas of environmental
damage and potential exposure. When samples are collected, photographs may be
taken to verify the written description in the field logbook. The following
information must be written in the logbook whenever a photograph is taken:
o Time, date, location, and, if appropriate, weather conditions
o Complete description or identification of the subject in the
photograph and reason why the photograph was taken
o The sequential number of the photograph and file-roll number
o Name of person taking photograph
When the photographs are developed, the information recorded in the field logbook
should be transferred onto the back of the photographs. Photographs and negatives
are part of the project files and'must be accounted for using document control
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procedures. Duplicate prints of the photographs should be sent to the
owner/operator, if the owner/operator has requested them.
7.5 SAMPLE HANDLING
7.5.1 Containers
Sample containers used for collecting ground water, surface water, and soil
samples at hazardous waste facilities are specified according to the analytical
methodology to be used (see "Methods for Chemical Analysis of Water and Wastes,"
U.S. EPA, 1983b, and "Test Methods for Evaluating Solid Waste - Physical Chemical
Methods," SW-846, U.S. EPA, 1984a).
7.5.1.1 Water Samples
Water samples for organic analyses should be collected in glass bottles
equipped with PTFE-lined screw caps. The water samples should be preserved by
cooling with ice to 4°C. Use of analytical contract laboratories requires that
duplicate samples be collected for volatile compounds. Samples for volatile
compounds are collected in 40 ml glass vials equipped with PTFE-backed silicon
septum screw caps. Bottles and septa are washed with detergent, rinsed with
organic-free water, and dried 1 hour at 105°C.
Samples for extractable organic compounds should be collected in 1-gallon or
four 1-liter glass bottles with PTFE-lined caps. New or used bottle's and liners
must be decontaminated in accordance with the Level 2 decontamination procedures
(Section 7.3.2.2). :
Water samples for metals analysis should be collected in 1-liter high-density
polyethylene bottles with solid polyethylene or polyethylene-lined caps. Bakelite
caps should not be used. The bottles must be decontaminated in accordance with
Level 3 decontamination procedures (Section 7.3.2.3). The samples are preserved
with nitric acid to below pH 2. If acidification requires more than 4 ml. of nitric
acid, the volume should be noted on the sample tag and in field notes. The nitric
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acid concentration must not exceed 0.15 percent if the sample is to be shipped via
air cargo.
Water samples for ammonia and TOC analyses should be collected in 500-mi
polyethylene bottles and preserved with sulfuric acid to below pH 2. The samples
should then be stored at 4°C. Water samples for pH and flouride analysis are
collected in 500-ml polyethylene bottles. Water samples for cyanide analysis are
collected in 1-liter bottles and preserved with sodium hydroxide to a pH greater
than 12. Water samples from sulfide analysis are collected in 1-liter polyethylene
bottles. Two ml of 0.04 percent zinc acetate is added as well as NaOH to pH 9.
These samples should all be stored at 4°C.
7.5.1.2 Soil and Hazardous Samples
Soil, sediment, and potentially hazardous leachate samples should be collected
in wide-mouth glass jars equipped with PTFE-line3 screw caps. These samples
require no preservatives or refrigeration. Bottles should be cleaned with
non-phosphate detergent and rinsed with tap water and deionized water.
7.5.1.3 Sample Bottle Repository Program
Under the Sample Bottle Repository Program, a service provided by the
Contractor Laboratory Program, nine types of sample containers are available to
laboratory and sampling clients. Bottles provided through this program are
precleaned and QC-tested according to prescribed procedures to ensure that no
contamination exists that might affect sample integrity or accuracy.
The types of bottles provided through this program, the case sizes in which
bottles are shipped, and the types of samples appropriate for collection in each
bottle type are listed in Table 7-1. Each bottle type is cleaned and QC-tested by
procedures directly related to the specific analyses that may be performed on
samples collected in the bottle.
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TABLE 7-1
CONTAINERS AVAILABLE FROM THE SAMPLE BOTTLE REPOSITORY PROGRAM
Container
Tvoe
1
Description
80 ounce amber glass bottle
with PTFE-lined black
phenolic cap
40-ml glass via with PTFE-
backed silicon septum cap
1-liter high-density
polyethylene bottle
with poly cap
120-ml wide-mouth glass
No. Per
Case
72
42
72
16-oz wide-mouth glass jar
with PTFE-lined black
phenolic cap
8-oz wide-mouth glass jar
with PTFE-lined black
phenolic cap
48
96
4-oz wide-mouth glass jar
with PTFE-lined black
phenolic cap
120
Expected
Sample Type*
Extractable Organics
Low Concentration
Water Samples
Volatile Organics
Low & Medium
Concentration
Water Samples
Metals, Cyanide
Low Concentration
Water Samples
Volatile Organics
Low & Medium
Concentration
Soil Samples
Metals, Cyanide
Medium Concentration
Water Samples
Extractable Organics
Low & Medium
Concentration
Soil Samples
-and-
Dioxin
Soil Samples
-and-
Organics & Inorganics
High Concentration
Liquid & Solid Samples
Extractable Organics
Low & Medium
Concentration
Soil Samples
-and-
Metals, Cyanide
Low & Medium
Concentration
Soil Samples
-and-
Dioxin
Soil Samples
-and-
Organic & Inorganic
High Concentration
Liquid & Solid Samples
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TABLE 7-1
CONTAINERS AVAILABLE FROM THE SAMPLE BOTTLE REPOSITORY PROGRAM!
(Continued)
Container No. Per Expected
Tvoe Description Case Sample Type*
1-liter amber glass bottle 30 Extractable Organics
with PTFE-lined black Low Concentration
phenolic cap Water Samples
32-oz wide-mouth glass jar 36 Extractable Organics
with PTFE-lined black Medium Concentration
phenolic cap Water Samples
This column specifies the only type(s) of samples that should be collected in
each "container.
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The sampling contractor should contact the U.S. EPA Sample Management
Office (SMO) for authorization to order from the repository and to obtain a supply
of delivery order forms. The contractor should order bottles from the repository
through the SMO. Since the Repository can respond only to orders submitted by a
SMO-designated representative, the SMO should be notified of any change in
contractor representative designations. Orders should be placed following the
guidance in "Users Guide to the CLP Program" (U.S. EPA, 1984d).
7.5.2 Chain-of-Custody
Each sample shipment must be accompanied by a Chain-of-Custody Record
identifying its contents. The original record should accompany the shipment, and a
copy should be retained by the sampling team. Chain-of-custody requirements are
extensively described in numerous documents such as "Enforcement Considerations
for Evaluations of Uncontrolled Hazardous Waste Disposal Sites by Contractors"
(U.S. EPA, 1980). Preferably, as few people as possible should handle the samples;
until shipped or transferred, sample custody should be the responsibility of the
sampling contractor.
The remarks section of the custody form must note when samples are split
with an owner/operator. The note should indicate with whom the samples are being
split and be signed by both the sampler and recipient. If the split is refused, the
form must be so noted and signed by both parties. The person relinquishing the
samples to the owner/operator must request the signature of a representative of the
appropriate party acknowledging receipt of the samples. If a representative is
unavailable or refuses to sign, it must be noted in the "Remarks" space. When
appropriate, as in the case where a representative is unavailable, the custody record
should contain a statement that the samples were delivered to the designated
location at the designated time.
Serialized chain-of-custody records should be assigned and accounted for in a
manner similar to that for the sample tags. When samples are transferred from a
field sampling person or courier to laboratory personnel, the recipient, after signing,
retains the original custody record and files it in a safe place. A copy of the
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custody record should be returned to the sampling team leader and to the desig-
nated document control officer.
A copy of the U.S. EPA Chain-of-Custody Form is shown as Figure 7-1.
7.5.3 Labeling and Packaging
All samples collected should be labeled in a clear and precise way for proper
identification" in the field and for tracking in the laboratory. Sample labels should
be waterproof, and have a pre-assigned, unique number that is indelible. Preferably,
a two-part label should be used so that the sample identification number can be
affixed to the sample bottle and can also be entered in a field logbook at the time
of collection. The label to be attached to the bottle should list only the sample
number; the label for the notebook should include the sample number and the
following information: . ,
o Project code number
o Station location and number
o Date and time
o Sample type (composite or grab)
o Signature of sampler
o Preservative indication (yes or no; type)
o Analyses required
o Additional remarks
An example of the two-part sample label is shown as Figure 7-2. Samples
should be packaged properly for shipment and dispatched to the appropriate
laboratory for analysis. A separate, custody record should accompany each shipment.
Shipping containers should be padlocked or sealed for shipment to the laboratory.
Only metal or plastic ice- chests should be used as the outside shipping container
for routine environmental samples. The outside shipping container must be able to
withstand a 4-foot drop on solid concrete in the position most likely to cause
damage. The drainage hole at the bottom of each ice chest should be permanently
plugged to prevent any possibility bf leakage through the hole. Each ice chest must
be clearly marked with arrows indicating the proper upright position of the
7-18
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OSWER DIR. 90SO.O-1
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7-19
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FIGURE 7-2
TWO-PART SAMPLE LABEL
OSWER DIR. 9080.0-1
nnnnnnnnnn
01615
nnannnnnnn
01615
TASK
PLANT
SAMPLE LOCATION
MATRIX
SAMPLING COMMENTS
SIGNATURE TIME/DATE
7-20
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OSWER DIR. 9080.0-1
container, a label indicating "THIS END UP" on the top, a label stating
"ENVIRONMENTAL SAMPLES" on the lid, and a sticker containing the originator's
name and address.
All field personnel should be cognizant of Department of Transportation (DOT)
criteria for classifying samples as hazardous material. When there is reasonable
doubt as to whether or not a particular sample is subject to DOT regulations, the
shipper should consult with the U.S. EPA Sample Management Office prior to
shipping the sample.
Each ice chest offered for shipment should be securely taped shut. This is
accomplished with reinforced tape wrapped at least twice around the ice chest near
each end where the hinges are located. Sample containers should be packaged in
the following manner:
Glass Containers
o The screw-type lid of the sample container should be securely tightened
before it is placed in the shipping container. Glass stoppers must be held
securely in place with wire or nylon reinforced tape.
o Sample containers should be separated in the shipping container by
cushioning such as styrofoam or absorbent material such as vermiculite to
prevent breakage due to contact with other glass containers or solid
objects.
o Small glass vials of volatile organic samples should be placed inside a
larger plastic container to minimize breakage and to contain any leakage.
Plastic Containers
o The cap should be tightened securely before it is placed in the shipping
container.
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OSWER DIR. 9080.0-1
o Although plastic containers do not need cushioning material between
them, they do need to be protected from punctures by sharp objects.
All sample containers and wet ice should be packed inside a sturdy plastic bag
placed inside the shipping container as an inner pack. The plastic bag should be
tightly closed with wire, nylon reinforced tape, or other such material after all of
the sample containers and ice have been added to prevent any leakage of material
from the bag.
7.5.4 Transportation
Samples transported off-site (CLP, State laboratories, ESD laboratories) must
be packaged for shipment in compliance with current DOT and commercial carrier
regulations. All required government and commercial carrier shipping papers must
be filled out and shipment classifications made according to current DOT
regulations. The sample classification procedures "and shipping requirements are
designed for samples containing less than 10 ppm of any single organic pollutant
and less than 100 ppm of any single inorganic pollutant Total concentrations of
the samples may exceed these limits. The FTL must use his own judgment to
determine if samples suspected of containing substantially higher concentrations
should be treated as hazardous samples. Questions concerning sample packaging may
also be directed to the U.S. EPA Sample Management Office (SMO).
Sample traffic reports, chain-of-custody records, and any other shipping/
sample documentation accompanying the shipment should be enclosed in a waterproof
plastic bag and taped to the underside of the cooler lid. In general, preservatives
added to routine environmental samples will not affect the classification of the
samples for shipping purposes. However, preservatives in pure or concentrated form
should not be shipped via commercial means.
Samples for organics analyses must be shipped "Priority One/Overnight"
because sample holding times of more than a 24-hour period may compromise the
integrity of the sample analyses. When the maximum holding time is exceeded, the
analyses should not be performed. .
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OSWER DIR. 9080.0-1
The SMO should be notified immediately after sample shipment and should be
provided with the following information:
o Sampling contractor's name
o Project number
o Exact number(s) and type(s) of samples shipped
o The name of the facility and location from where the samples are being
shipped
o The laboratory to which the samples are shipped
o Carrier, airbill number(s), method of shipment (priority, 2-day)
o Shipment date and time
o Irregularities or anticipated problems, such as special handling needs and
hazardous.samples
If sample shipments are made after 5:00 P.M. EST, the SMO should be notified
at the start of business the next day (8:00 A.M. EST). The SMO must be notified
by 3:00 P.M EST Friday concerning information on sample shipments going out
Friday intended for Saturday delivery/pickup. CLP laboratories remain open to
receive or pickup Saturday shipments only upon advance notification by the SMO
and only when shipment airbill numbers have been provided to the SMO by the
sampler.
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OSWER DIR. 9080.0-1
8.0 COMPLIANCE EVALUATION
The compliance evaluation task is composed of the following elements:
o Compile 'field notes from members of the evaluation team
o Review the field notes, document package, and analytical results
o Compile the factual observations, findings, and recommendations from
evaluation team members
o Prepare a draft Technical Report
o Develop consensus among team members on the draft Technical
Report
. » .
o Prepare final Technical Report
8.1 FACILITY EVALUATION REPORT (TECHNICAL REPORT)
The Technical Report must combine the findings from the site' inspection with
the results of the sample analyses and the background information from the
Document Package to create a complete profile of the current or potential impact of
the facility on the areal ground water. Based on the Technical Report, the
evaluation team should reach a consensus on the status of the compliance with
ground-water monitoring requirements.
The field team leader (FTL) .should draft a Technical Report after reviewing
the document package, facility inspection notes, and results of sample analyses.
Appendix E is an outline of the Technical Report. The Technical Report will focus
on the following:
o Conclusions regarding regulatory compliance of the ground-water
monitoring program of tire facility
8-1
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OSWER DIR. 9080.0-1
o Probable nature and level of ground-water contamination
o Recommendations regarding technical activities necessary to achieve
compliance or to determine the nature and extent of contamination.
8.2 DEVELOPMENT OF CONSENSUS ON TECHNICAL REPORT
Members of the evaluation team must reach a consensus on the findings in
Technical Report. After the issuance of the draft Technical Report, members of the
evaluation team should review the report and meet to comment and resolve any
disagreements. The FTL should then revise the report accordingly and issue a
second draft to the evaluation team members.
If certain technical problems cannot be resolved at the first meeting, the FTL
should compile a list of these technical problems and follow the "Problem
Resolution" procedures described in Section 2.5 to obtain solutions or guidance for
these problems.
The FTL should schedule a second meeting of team members and Regional
management to review the second draft of the report, to resolve any remaining
disagreements. The evaluation team members should then reach a consensus on
appropriate final changes to the report. The FTL should finalize the report in
accordance with decisions made at the second meeting.
8.3 IDENTIFICATION OF APPROPRIATE ACTION
The Technical Report should identify, discuss, and describe the technical
actions necessary for the facility to gain compliance with the ground-water regula-
tion. The -evaluation team members must agree on the ground-water monitoring
compliance status of a facility in order to determine appropriate action for that
facility. The U.S. EPA publication, "Draft RCRA Ground- Water Monitoring Techni-
cal Enforcement Guidance Document" (1985a) provides detailed technical guidance for
evaluating ground-water monitoring systems at commercial TSD facilities. At a
minimum, the following issues should be addressed in the Technical Report:
8-2
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OSWER DIR. 9080.0-1
o Characterization of Site Hydrogeology
o Placement of Detection Monitoring Wells
o Monitoring Well Design and Construction
o Sampling and Analysis Plans
o Sampling and Analysis Procedures
o Data Quality
o Statistical Analysis of Detection Monitoring Data
o Assessment Monitoring Program
o Corrective Action Program
o State/Federal Permit Changes
o Historic facility operations
Based on the detailed facility-specific evaluation, the probable sources of
contamination, if any, can be identified and the extent of contamination can be
approximated. The evaluation team should then identify the appropriate'action(s)
required to bring the facility into compliance.
Areas in which actions may be appropriate include:
o Modification of the ground-water monitoring system
o Sample collection and handling procedures
o Leachate collection system
o Waste treatment and disposal unit design
o Data QA/QC including chain-of-custody procedures
o Waste analysis
o Waste Management Plan
These recommendations will be incorporated into a comprehensive Facility
Management Plan (Chapter 9) to be prepared by the Regional management.
In addition to amending the Facility Management Plan, it may be necessary to
take enforcement action (see RCRA Ground-Water Monitoring Compliance Order
Guidance, U.S. EPA, 1985b) or issue a permit modification.
8-3
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OSWER DIR. 9080.0-1
9.0 FOLLOWUP
9.1 DEVELOPMENT OF A FACILITY MANAGEMENT PLAN
U.S. EPA Regional .management staff and the Regional Team Leader (RTL) will
prepare a draft Facility Management Plan or an amended Facility Management Plan
based on the findings and recommendations in the final Technical Report. The Plan
will describe the methods to be used by the Region to gain compliance with the
regulations and to resolve problems identified in the Technical Report. The Facility
Management Plan will identify the anticipated administrative and/or enforcement
actions or permit conditions needed to bring the facility into compliance. The
following is a summary of the major elements and areas of concern that should be
addressed in the draft Plan:
o Overview of the facility's history of operations and compliance
status .
«
o Definition of specific short- and long-term objectives to be achieved
by the facility
o Identification of upcoming facility-related deadlines, such as issuance
or reauthorization of permits and enforcement action deadlines
o Outline of available mechanisms for achieving compliance, such as
issuing administrative orders and penalties and issuing new or
modifying existing permit conditions
o Identification of the likely mechanism to gain compliance or to
resolve problems
o Identification of likely participating agencies
o Establishment of roles, responsibilities, and actions to be initiated by
each agency
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OSWER DIR. 9080.0-1
o Establishment of procedures for coordinating actions of State
agencies
Chapter 5 of the U.S. EPA publication, "RCRA Ground-Water Monitoring
Compliance Order Guidance," (1985b) provides detailed guidance on how to
incorporate the the selected technical activities (from the Technical Report) into an
enforcement strategy that will correct present violations and advance a facility
toward permitting.
The Region will provide a draft copy of the Facility Management Plan to each
participating agency for review and comment. One copy of the draft Plan will also
be provided to the Office of Waste Programs Enforcement (OWPE) whose role is to
ensure national consistency in enforcement-related actions.
The FTL will schedule and conduct a consensus meeting with members of the
team and management from the various participating agencies to:
o Discuss the Plan and resolve any problems
o Decide what actions should be implemented
o Develop a schedule for initiating the identified actions
o Assign responsibilities for implementing those actions and for
monitoring progress
9.2 IMPLEMENTATION OF THE FACILITY MANAGEMENT PLAN
Based on the results of the consensus meeting on the Facility Management
Plan, the identified responsible agency (U.S. EPA Regional Office or authorized
State agency) will implement appropriate actions, such as orders, penalties, and
modified or new permit conditions, according to the schedule in the Plan and
through normal operating channels.
9-2
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OSWER DIR. 9080.0-1
The UJS. EPA Headquarters or Regional personnel will provide assistance as
needed by the responsible agency in initiating the selected corrective action. They
will arrange for OWPE and OSW to resolve any issues of regulatory interpretation
and to provide assistance in writing orders or permits.
The schedule of action will include a timetable for meeting each objective in
the Plan. Each schedule will be facility specific and reflect the following issues:
o Magnitude of the problem, as this may dictate the expediency of the
solution
o Local factors, such as weather and availability of equipment and
personnel
The timetable will contain milestones to assess compliance progress.
9.3 MONITORING THE PROGRESS OF INITIATED ACTIONS
The U.S. EPA Regional management must conduct regular reviews with the FTL
on the progress of all actions taken at each facility. In the case of the Task
Force, the review meeting will be conducted at least every other week by the
members of the Task Force and progress reports will be issued to the Director of
the Task Force. The Director will then issue, through his office, bi-weekly
progress reports to the Senior Management Steering Committee of the Task Force
and will brief the Committee on the progress at specific facilities where deemed
appropriate.
9.4 IDENTIFICATION OF IMPLEMENTATION PROBLEMS
When a facility does' not achieve the milestones identified in the timetable, the
responsible agency must examine the problems during the regular review meeting
and identify any additional actions needed and the type and degree of support, if
any, that may be required from the EPA Regional Office or Headquarters.
9-3
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OSWER DIR. 9080.0-1
After concurring on the appropriate additional action (enforcement order,
penalty, fine) which reflects the degree of noncompliance by the owner/
operator, the appropriate agency will initiate that action.
9-4
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10.0 REFERENCES
U.S. EPA, 1986, Hazardous Waste Ground-Water Task Force Facility Assessment
Program Plan.
U.S. EPA, 1985a, Draft- RCRA Ground-Water Monitoring Technical Enforcement
Guidance Document U.S. EPA Office of Solid Waste and Emergency Response.
U.S. EPA, 1985b, RCRA Ground-Water Monitoring Compliance Order Guidance.
U.S. EPA, 1985c Superfund Off-Site Policy. U.S. EPA Office of Solid Waste and
Emergency Response.
U.S. EPA, 1984a, Test Methods for Evaluating Solid Waste - Physical/Chemical
Methods, SW-846.
U.S. EPA, 1984b, Responsibilities and Conduct for EPA Employees.
U.S. EPA, 1984c, Standard Operating Procedures for Well Sampling. U.S. EPA,
Region II.
.U.S. EPA, 1984d, User's Guide to the CLP Program.
U.S. EPA, 1983a, RCRA Draft Permit Writer's Manual: Ground-Water Protection, 40
CPR Part 264, Subpart F.
U.S. EPA, 1983b, Methods for Chemical Analysis of Water and Wastes.
U.S. EPA, 1983c, Occupational Health and Safety Manual.
U.S. EPA, 1982, Interim Standard Operating Safety Guidelines, EPA Office Of
Emergency and Remedial Response.
U.S. EPA, 198la, Manual for Ground-Water Quality Sampling Procedures.
U.S. EPA, 1981b, EPA Order 1440.
U.S. EPA, 1980, Enforcement Considerations for Evaluations of Uncontrolled
Hazardous Waste Disposal Sites by Contractors. U.S. EPA, National
Enforcement Investigation Center.
U.S. EPA, 1979, Draft Safety Manual for Hazardous Waste Site Investigations.
-------
OSWER DIR. 9080.0-1
CBI
CERCLA
CFR
CLP
DCO
DOJ
DOT
EMSL/LV
EPA
ESD
FTL
HSL
ID
LEL
NCP
NEIC
NOD
NTU
OAG
OERR
ORD
OSW
OWPE
OVA
PE
11.0 ACRONYM
Confidential Business Information
Comprehensive Environmental Response and Compensation
Liability Act
Code of Federal Regulations
Contractor Laboratory Program
Document Control Officer
Department of Justice
Department of Transportation
Environmental Monioring Systems Laboratory/Las Vegas
Environmental Protection Agency
Environmental Service Division-(U.S. EPA)
Field Team Leader
Hazardous Substances List
Inside Diameter
Low Explosion Limit
National Contingency Plan
National Enforcement Investigation Center
Notice of Deficiency
Nephelometric Turbidity Unit
Operations Assessment Group
Office of Emergency Remedial Response (U.S. EPA)
Office of Research and Development (U.S. EPA)
Office of Solid Waste (U.S. EPA)
Office of Waste Programs Enforcement
Organic Vapor Analyzer
Performance Evaluation
11-1
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OSWER DIR. 9080.0-1
POC Purgeable Organic Carbon
POX Purgeable Organic Halogens
PRC Planning Research Corporation
PTFE Polytetrafluoroethylene
PVC Polyvinyl Chloride
QA Quality Assurance
QC Quality Control
RCRA Resource Conservation and Recovery Act
ROD Record of Decision
RTL Regional Team Leader
SMO Sample Management Office
SOP Standard Operating Procedures
TOC Total Organic Carbon
TOX Total Organic Halogens
TSCA Toxic Substances Control Act
TSD Treatment, Storage, and Disposal
USDA U.S. Department of Agriculture
USGS U.S. Geologic Survey
VOA Volatile Organic Analysis
11-2
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APPENDIX A
COMPREHENSIVE FACILITY SAMPLING EVALUATION
QA/QC GUIDANCE
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OSWER DIR. 9080.0-1
I. HYDROGEOLOGICAL CONSIDERATIONS
A. Regional Hvdrogeological Information
1) Has a geologic'/hydrologic study been conducted by a qualified
professional?
2) Is a USGS topograhic quadrangle map of the site available?
3) Is a local map of the site available?
4) Is an aerial map from the U.S. Soil Conservation Service available?
5) Are there any significant topographic features?
6) Has the geology of the site been mapped?
7) Is the geologic map available?
8) What type of formation underlies the region?
9) Is the formation consolidated, unconsolidated, fractured?
10) Is the formation heterogeneous .enough to cause a possible differentiation
9
in pollutant ffow?
11) Are any streams, rivers, lakes, or wetlands near the facility?
12) Is there more than one aquifer beneath the site? Are they hydraulically
connected?
B. Site-Specific Hvdrogeological Information
1) Is a site-specific hydrogeologic map available?
What is the date of issue?
Are any recent (post map date)-changes evident?
2) Are local discharging wells noted? Distance? Direction?
3) Does pumping of surrounding wells change or reverse the direction of the
hydraulic gradient?
4) Are potentiometric maps available?
Is ground-water flow direction noted?
Are the contours logical based on other maps?
Are the facility and the hazardous waste units plotted
(Scale)?
What is the proximity of units to surface waters?
Are any seeps or springs shown near the facility?
A-l
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OSWER DIR. 9080.0-1
Are monitoring wells plotted?
Is the site potentiometric surface plotted?
Is the indicated potentiometric surface compatible with
regional hydrology?
Are site flow lines indicated?
What are the contour intervals?
Are static water elevations shown?
5) Does the facility affect the ground-water surface?
C. Monitoring Well Locations
1) Are logs of all on-site or off-site wells and borings available?
2) .What type of firm installed the wells?
3) Are the monitoring wells completed in the same stratum as nearby
water supply wells? If no, please explain. ...
Are any 'types of soil boring/test pit jogs available?
Are geologic cross-sections included?
Were any discrete formation samples taken?
How were these samples taken?
4) Are any physical tests of aquifer materials available?
5) Have the elevations of the wells been surveyed to sufficient accuracy to
determine gradient?
6) Is there sufficient distance between wells to establish a gradient on the
potentiometric surface?
7) Do the regulated units create a ground-water mound?
8) Is the upgradient well(s) placed in a position to represent a background
condition?
9) Does intermittent flow to the disposal site affect the ground-water
mound?
10) Do the downgradient wells monitor the mounding at the water surface?
11) Are the ground-water monitoring wells placed in a position such that they
can immediately detect any ground-water contamination from the
regulated unit?
12) Does the master map clearly show the monitoring wells and their assigned
identification numbers?
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OSWER DIR. 9080.0-1
D. Well Installation and Completion
1) What was the method of drilling? Auger? Mud Rotary? Air Rotary?
Reverse Rotary? Cable Tool? Jetting? Other?
2) Was the equipment cleaned prior to drilling? How?
3) Were any additives, including non-formation water, used during or after
drilling?
4) What precautions were taken to prevent cross-contamination during
drilling?
5) Are the wells constructed of nonreactive materials? Casings? Screens?
Gravel pack materials?
. Have any glues or solvents been used?
6) Have the wells been sealed to prevent downward migration of
contaminants? Bentonite? Cement? Other? ^ How?'
7) Will these contact the sampled water?
8) What type of screen was used?
9) Are the wells gravel or sand packed around the screen?
What materials were used in the pack?
What was the source of those materials?
10) Are the monitoring wells screened in the uppermost aquifer (zone
of saturation)?
Is the full saturated thickness screened?
Does the screen extend above the water surface so as to
detect "floating" contaminants or account for fluctuating
water levels?
For single completions, are the intake areas in the:
o Upper portion of the zone of saturation?
o Middle portion of the zone of saturation?
o .Lower portion of the zone of saturation?
For well clusters, are the intake areas open to different
portions of the saturated zone?
11) Do the intake levels of the monitoring wells appear to be justified due to
possible contaminant density and ground-water flow velocity?
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OSWER DIR. 9080.0-1
12) Are the wells capped and locked to prevent vandalism? If not, what
security measures are taken?
13) Are the wells protected against vehicular damage?
14) Have the wells been developed? By what method? Was any
non-formation" fluid used for jetting or surging?
E. Aquifer Characterization
1) Has the extent of the uppermost saturated zone (aquifer) in the
/
facility been defined?
2) Is there evidence of confining (low permeability) layers beneath the site?
Is the areal extent and continuity indicated?
Is there any potential for saturated conditions (perched
water) to occur above the uppermost aquifer? If so,
should or is this perched zone being monitored?
What is the lithology and texture of the uppermost
saturated zone (aquifer)?
What is the saturated thickness, if indicated?
3) Do fluctuations in static water levels occur?
Are they accounted for (seasonal, tidal)?
Do the water-level fluctuations alter the general
ground-water gradients and flow directions? If so,
will the effectiveness of the wells to detect contami-
nants be reduced?
Based on water-level data, do any head differentials
occur that may indicate a vertical flow component in
the saturated zone?
4) Have aquifer hydraulic properties been determined?
What method were used?
o Pumping tests?
o Falling/constant head tests?
o Laboratory tests (explain)?
If determined, what are the values for:
o Transmissivity?
o Storage coefficient?
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OSWER DIR. 9080.0-1
o Leakage?
o Permeability (horizontal and vertical)?
o Porosity?
o Specific yield?
In cases where several tests were undertaken, were discrepancies in
the results evident?
Were horizontal ground-water flow velocities determined?
If yes, what was the rate of movement?
II. GROUND-WATER MONITORING EVALUATION PROCEDURES
1) Has the owner/operator of the facility implemented a ground-water monitoring
system? If no,-skip to number 11.
.2) Has the owner/operator of the facility implemented an alternate ground-water
monitoring system as described in 265.90(d)?
3) Does the ground-water monitoring system meet the following requirements
of 265.91?
At least one well installed hydraulically upgradient from the limit of the
waste management area?
At least three wells installed hydraulically downgradient at the limit of
the waste management area?
Are the number, locations, and depths of all wells sufficient to yield
ground-water samples that are representative of ground water under the
facility?
4) Has the owner/operator developed a written ground-water sampling and
analysis plan that includes procedures and techniques for:
Sample collection?
Sample preservation and shipment?
Analytical procedures?
Chain-of-custody control?
5) Does owner/operator follow the ground-water sampling and analysis plan?
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OSWER DIR. 9080.0-1
6) Is the ground-water sampling and analysis plan maintained at the facility?
7) Has the owner/operator determined the concentration or value of all the
ground-water monitoring parameters of 265.92(b) in accordance with paragraphs
c and d of 265.92?
Parameters
A. Chloride
Iron
Manganese
Phenol
Sodium
Sulfate
B. pH
Specific Conductance
TOC
TOX
C. Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP-Silver
Radium
Gross Alpha
Gross Beta
Turbidit
Coliform Bacteria
Year 1
Year 2
A - Quarterly
B - Quarterly
C - Quarterly
A - Annually
B - Semi-annually
C - Not required
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OSWER DIR. 9080.0-1
8) Has the owner/operator developed an outline of a comprehensive ground-water
quality assessment program that is capable of determining:
Whether hazardous wastes or hazardous waste constituents have entered
the ground water?
The rate and extent of migration of hazardous wastes or hazardous waste
constituents in the ground water?
The concentration of hazardous wastes or hazardous waste constituents in
the ground water?
9) Has the owner/operator performed statistical analyses of his ground-water
monitoring data as required in 265.93(b)?
o Calculate x (mean) and S2
o Apply t-test
10) Was there a statistically significant increase (or pH decrease) detected in any
well?
If yes, has the owner responded in accordance with the procedures
prescribed in 265.93 paragraphs c through f:
o Obtain additional downgradient samples and analyze for
significant change
o Notify Regional Administrator within 7 days?
o Assessment plan submitted within 15 days?
11) Has the owner/operator prepared a written ground-water monitoring waiver
demonstration for the facility?
Is the waiver demonstration maintained at the facility?
Has the waiver demonstration been certified by a qualified
geologist or geotechnical engineer?
Note: Inspectors should request a copy of the waiver document.
If the facility has a ground-water waiver, skip questions
12, 13, and 14.
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OSWER DIR. 9080.0-1
12) Has the owner or operator submitted an alternate ground-water monitoring
system to the Regional Administrator?
Has the plan been certified by a qualified geologist or geotechnical
engineer?
Note: If the plan for an alternate ground-water monitoring system
was not submitted to the Regional Administrator, the inspector
should request a copy for review.
13) Does the alternate ground-water monitoring plan address the requirements of
265.90(d)?
14) Does the owner/operator submit reports and maintain records as required in
265.94:
o Quarterly for first year?
o Annually/semiannually for 2nd year - submit by March 1?
a
o Elevations annually?
III. FIELD SAMPLING PROCEDURES
A. Well Purging
1) Is the well correctly identified?
2) What method is used to determine water-level elevations in wells (electric
water marker, steel tape, air line, or other)?
3) How were ground elevations at wells determined?
4) Is the depth to bottom measured or available from records?
5) Are well depths measured periodically to evaluate sedimentation?
6) Is sounding equipment cleaned after use?
7) From where in the well is the water drawn? Is this depth consistently
maintained?
8) Is volume to remove calculated?
9) How do you determine whether formation water is being sampled?
Number of well casing evacuated?
Stabilization of pH, oxidation potential, specific conductance,
or temperature?
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OSWER DIR. 9080.0-1
10) What method is used to purge the wells?
If commercially available, what make and model number?
11) Why was this method selected?
Has this procedure been maintained throughout the sampling program? If
not, what other methods have been used?
12) What period of time usually elapses between purging and sampling?
13) Is the water collected and stored if hazardous?
How is this water disposed of?
14) Were the samples turbid or high in sediment? Which ones?
15) What precautions are taken to avoid cross-contamination? Was dedicated
equipment used for each well? What is the material made .of? Is the
pump or bailer and cable/rope cleaned? Is the rope wrapped?
B. Sampling Equipment
1) What type of equipment is used?
2) Is it commercially available? Make? Model No.?
3) Was sampling equipment clean?
4) Was sampling equipment kept clean during use?
5) Was sampling equipment appropriate for contaminants?
6) Was s'ampling equipment properly cleaned in the field if needed?
C. Sample Containers
1) Is there documentation of proper cleaning?
2) Were correct containers used (see Table 1)?
D. Sample Labels
1) Was the integrity compromised?
2) Do they contain required information:
o Unique sample number?
o Name of collector?
o Date and time of collection?
o Place of collection?
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OSWER DIR. 9080.0-1
3) Is optional information included:
o Sample type?
o Preservative used?
o Analyses required?
o Field information?
E. Sampling Procedures
1) Does the same person/contractor/laboratory always take the samples?
2) How are samples obtained:
o Air lift pump?
o Submersible pump?
o Positive displacement pump?
o Centrifugal pump?
o Peristaltic or other suction-lift pump?
T
o Bailerv
o Other?
3) Are all wells sampled with the same equipment and by the same
procedures?
4) With what materials do the samples come in contact with?
5) Are adequate provisions included to clean equipment after sampling to
prevent cross-contamination between wells?
6) Are organic constituents to be sampled?
Are samples collected with equipment to minimize adsorption and
volatilization?
For VGA's, what equipment and what procedure is used to prevent
sample aeration?
7) Are sample containers appropriate for analysis? (See Table 1)
8) Are correct preservatives used? (See Table 1)
9) How are containers handled prior to taking samples?
10) Is correct sample volume obtained? (See Table 1)
11) Are bottles prerinsed with sample water (except pesticides/herbicides)?
12) Are field blanks used? If yes, is the water source regularly tested? Are
field blanks preserved?
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OSWER DIR. 9080.0-1
13) Have the sampling methods used been consistent since the program
started? If no, what changes have been instituted?
F. Field Measurements
1) pH - Meter warmed up?
Calibrated with proper buffers (4 and 7, or 7 and 10)?
Corrected for temperature?
Measurements repeated until within 0.1 pH unit?
2) Conductivity - Calibrated with 0.01 N KC1 standard?
3) Temperature - Measured as soon as sample taken?
G. Sample Seals
1) Was the integrity compromised?
«
2) Do they contain required information:
o Unique sample number (same as label)?
o Name of collector?
o Date and time of sampling?
H. Sample Shipping
1) Are provisions made to store and ship samples under cold conditions
(ice packs)?
2) Are samples packed to prevent breakage?
3) Are chain-of-custody records enclosed?
4) Is sample analysis request enclosed?
5) Is shipping container sealed?
IV. FIELD DOCUMENTATION
A. Field Logbook
1) Is the logbook bound?
2) Does it contain the proper entries:
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OSWER DIR. 9080.0-1
o Purpose of sampling?
o Unique sample number?
o Date and time of collection?
o Names of all persons present?
o Location of sample point (description and/or sketch)?
o Description of sampling methodology?
o Number and volume of sample taken?
o Suspected composition of sample?
o Name and address of field contact?
o Sample distribution and transportation?
o Field observations?
o Field measurements?
o Signature of sampler?
B. Site Verification
1) Is there a plot plan indicating the locations of various facility
components, ground-water monitoring wells, and surface waters?
Is the plot plan used for the inspection the same as in the
monitoring program plan documentation?
2) Are all the components of the facility identified during the inspection
addressed in the monitoring program documentation?
3) Are there any streams, lakes, or wetlands on or adjacent to the site?
what is the distance from the waste management areas?
4) Are any signs of water quality degradation evident in the surface-water
bodies?
5 Is there any indication of distressed or dead vegetation on or adjacent to
the site?
6) Are there any significant topographic or surficial features on or near the
site (recharge or discharge areas)?
7) Are the monitoring well locations and numbers in agreement with the
monitoring program documentation?
Were locations and elevations of the monitoring wells surveyed into
some known datum?
Were the wells sounded to determine total depth below the surface?
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OSWER DIR. 9080.0-1
Were discrepancies in total depth greater than 2 feet apparent in
any well?
8) Was ground water encountered in all monitoring wells? Which wells were
dry?
C. Chain-of-Custodv Records
1) Do records contain required information:
o Sample number?
o Signature of sampler?
o Date and time of collection?
o -Place and address of collection?
o Type of sample?
2) Do records indicate number and type of containers?
3) Are records signed by custodian?
4) Do they have inclusive dates of possession?
5) Are records signed by receiver?
6) Is the shipping container described?
D. Sample Analysis Request
1) Does the request contain field information:
o Name and phone number of collector?
o Date and time of collection?
o Collector's sample number?
o Field information?
o Analysis requested?
o Special handling or storage?
2) Does it contain laboratory information:
o Name of person receiving sample?
o Date of sample receipt?
o Analysis required?
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OSWER DIR. 9080.0-1
V. LABORATORY EVALUATION PROCEDURES
A. Laboratory Evaluation
1) Have laboratories been changed since analysis began? Which?
2) Is the lab quality assurance plan available?
3) Is there documentation of U.S. EPA acceptable methods?
4) Are instrument calibration records available?
o Are analytical instruments routinely calibrated and in good
repair?
o Are calibration records and other recordkeeping-logs kept at
the laboratory?
5) Is there an adequate QA/QC program for all analyses?
6) Are detection limits for each parameter identified?
7) Is glassware cleaned and baked according to proper laboratory procedure
and in accordance with standard methods?
B. Sample Receipt
1) Was the condition of samples checked?
Were containers intact?
Was the preservative present?
Was the seal intact?
2) Was the sample information checked?
3) Are chain-of-custody records present?
4) Does sample and seal information match chain-of-custody record?
5) Are chain-of custody records signed?
6) Is the request for analysis present?
7) Was receipt of sample entered in laboratory logbook?
8) Was laboratory sample number assigned?
9) Are samples refrigerated after collection?
Are samples stored in a secure area?
10) What is the average holding time before samples are analyzed?
Sample handling times not exceeded? (See Table 1)
11) Are time-sensitive parameters measured in the field or in the lab?
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OSWER DIR. 9080.0-1
C. Analytical Procedures
1) Have samples been filtered, where appropriate, prior to analysis?
2) Are the required drinking water suitability parameters tested for?
3) Are the required ground-water quality parameters tested for?
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OSWER DIR. 9080.0-1
TABLE 1
SAMPLE VOLUMES, CONTAINERS, PRESERVATIVES, AND HOLDING TIMES
FOR SELECTED CHEMICAL PARAMETERS
DRINKING WATER QUALITY PARAMETERS
Metals (total)
As, Ba, Cd, Cr, Pb, Se, Ag
200 ml
Plastic or glass
*Filter on site
Add HNO3 to pH less than 2
6-month holding period after digestion
. 9
Hg
100 ml
Plastic or glass
*Filter on site
Add HNO3 to pH less than 2
28-day holding period
Anions
Cl
50 ml
Plastic or glass
No preservative
28-day holding period
F
300 ml
Plastic
No preservative
28-day holding period
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OSWER DIR. 9080.0-1
NO3
100 ml
Plastic or glass
cold (4° C)
Add HNO3 to pH less than 2
Analyze within 28 days
Oraanochlorine Pesticides and Herbicides
Endrin, Lindane, Methoxychlor, Toxaphene
500 ml
Glass with PTFE-lined cap
Cold .(4° C) only, if extracted within 48 hours
Cold (4° C) and adjust pH to 6 to 8 with NaOH or
H2SO4 if extracted after 48 hours ...
All samples extracted within 14 days,
2,4-D: 2,4,5-TP
500 ml
Glass with PTFE cap
Cold (4° C)
All samples extracted within 7 days
GROUND-WATER QUALITY PARAMETERS
Metals
Fe, Mn, Na
200 ml
Plastic or glass
*Filter on site
Add HNO3 to pH less than 2
6-month holding period
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OSWER DIR. 9080.0-1
Anions
Cl
50 ml
Plastic or glass
No preservative
28-day holding period
SO4
50 ml
Plastic or glass
Cold (4° C)
28-day holding period
Oraanics
Phenols
500 ml
Glass
Cold (4° C)
H2SO4 to pH less than 4
1.0 gm CuSO4 per liter
28-day holding period
GROUND-WATER CONTAMINATION PARAMETERS
PH
25 ml
Plastic
No preservative
Determine on site
6-hour holding period
Specific conductance
100 ml
Plastic
Cold (4° C)
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OSWER DIR. 9080.0-1
28-day holding period
Total Organic Carbon (TOC)
25ml
Plastic or glass
Cold (4° C)
H2SO4 or HC1 to pH less than 2
28-day holding period
Total Organic Halogen (TOX)
250 ml
Glass with PTFE septum or liner
No headspace
Cold (4° C)
24-hour holding period-
Semi-volatile Organics
1 liter
Glass, no prerinse
Refrigerate at 4° C
If residual chlorine is present and sample will not be
extracted within 48 hours, add 35 mg sodium thiosulfate
per ppm free chlorine/liter of sample. Adjust pH to 7-10
with NaOH or H2SO4. Record volume of acid or base used.
All samples extracted within 1 days
All samples analyzed within 30 days
Volatile Organics
40 ml
Septum vials
No sample agitation or entrained air
Analyze within 7 days
No preservatives
No prerinse
If known to be chlorinated, prior to shipment of
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OSWER DIR. 9080.0-1
containers, add 1 ug/40 ml sodium thiosulfate to
empty sample containers.
Hold at 4° C
VI. ANALYSIS OF DATA
A. Computation and Reporting
1) Was data transcribed from the laboratory to records and reports without
errors and ambiguity?
2) Were two or more significant digits carried through any computations
performed?
3) Does the owner/operator explain and follow a protocol for determining
and reporting low concentration values?
Is any data reported as less than the detection limit?
If so, does a numerical value accompany it? Were detection limit
values high "or variable? Was the reason for this due to:
o Extremely low concentration of constituents?
.0 Low sensitivity of analytical technique?
o Chemical in the ground water which interferes with the
analytical technique?
Were detection limit values analyzed at half their reported value?
4) Was an outlier (a value much different than most other values for the
same pollutant) used in computation of data or statistical analyses?
B. Presentation of Data
1) Was the data reported complete? Was the reason for missing values
indicated?
2) Were any outliers found in the data review? Did the owner/operator
determine and document the cause of the problem?
3) Were all data values for each pollutant parameter reported with a
consistent number of significant digits?
4) Were all data values rounded off to the same number of significant digits
as in the original lab data results?
5) Did all indicator parameters have at least three significant digits?
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OSWER DIR. 9080.0-1
6) Did units of measure accompany each chemical parameter name?
7) Were units of measure for a given chemical parameter consistent
throughout the report?
C. Statistical Analysis -
1) Were the background mean and variance determined for ground-water
indicator parameters of both the upgradient and downgradient
wells?
Were the values calculated correctly?
Were two or more significant digits carried through the
computation?
2) Was the t-test performed in accordance with the methodology of Appendix
'B in the EPA "Ground Water Technical Enforcement Guidance Document"?
Did the comparison of background date with upgradient well data of
subsequent years show a statistically significant increase?
Was the reason for this increase determined?
Is a modification of the background data warranted?
Did the comparison of background well data with downgradient well
data of subsequent years show an increase?
What did the subsequent analysis of samples indicate?
Was the significant increase due to laboratory error?
Was it the result of ground-water contamination?
3) Did the owner/operator perform the t-test despite incomplete data
collection?
Was the following criteria met?
For background data:
o Were at least three measurements of the upgradient well
sample made during the year for at least one of the
indicator pollutants?
For downgradient data:
o Was at least one well sampled for at least one of
the indicator parameter(s) in the upgradient well?
o Were two replicate measurements made from each well?
A-21
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APPENDIX B
SUPERFUND OFF-SITE POLICY
-------
UN'TED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C 20460
or (>
SOLID WASTE AND I
MEMORANDUM
SUBJECT: Procedures for Planning and Implementing Off-site
Response Act-ions
,
FROM: J/ack W. Mo'GraW
Acting Assistant Administrator
w
TO: Regional Administrators
Regions I-X
This memorandum addresses procedures that must be observed
when a response a-ction involving off-Bite storage, treatment or
disposal of hazardous substances is selected under the Compre-
hensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), and the Resource Conservation and Recovery Act
(RCRA). It prohibits use of a RCP.A facility for off-site manage-
ment of Superfund hazardous substances if it has significant
RCRA violations* or other environmental conditions that affec't
the satisfactory operation of the facility. It also addresses
requirements for analyzing and selecting response actions that
involve permanent methods of managing hazardous substances.
In November of 1984, amendments to the Resource Conservation
and Recovery Act were enacted. These amendments impose new
requirements for the cafe management of hazardous wastes. In
the case of land-.* di spocal facilities, the amendments require
that certain types of units (new, replacement and lateral exten-
sions) be double lined by May 9, 1985. The amendments impose
technical requirements to ensure that when land disposal" facilities
are used they are used safely.
EPA intends to follow the direction established by Congress
in the RCRA amendments when undertaking on-site response actions
A significant violation includes a Class I violation as defined
by the RCRA Enforcement Response Policy (December 21, 1984).
This policy defines a Class I violation as a violation that
results in a r *r a serious threat of release'of hazardous
waste into tr <. ment, or involves the failure to assure
that ground w "- ' be protected, that proper closure and
post closure will be undertaken, or that hazardous
wastes will b for and delivered to RCRA permitted or
Interim atatui s. The policy contains a list of
examples of vie hich are Class I violations. Regions
should recognize Nations other than Cla>ss I violations
ay be aignific' rpoaes of these procedures, depending
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«nd when response actions Involve off-sice management of hazardous
substances. This memorandum details how the Agency plans to
achieve these gosls.
Section I of this memorandum discusses background issues.
Section II A discusses the need to consider treatment, recycling
and reuse before off-site land disposal is used. Section II B
details procedures that muse be followed in selecting any off-site
facility for management of hazardous substances. This section
also discusses the criteria to be used in making the selection.
For facilities in assessment monitoring, this pare states that
conditions which lead to and result from being in assessment
monitoring may constitute conditions that render the facility
unsuitable for disposal of hazardous substances. Therefore,
when a facility is in assessment, the conditions which lead to
the required assessment, and any monitoring data, must be evalu-
ated to determine if the facility poses such conditions. If so,
the facility may not be used unless the owner or operator con^its
to correct the problems and the unit to be used for disposal
poses no problems.
. 9
Section III discusses RCRA manifest requirements. Section IV
discusses PCB disposal requirements. Finally, Section V details
how this policy will be implemented. Attachment A is a chart
summarizing the policy on use of off-site RCRA facilities. This
chart should be used in conjunction with the policy document, not
inlieuofit.
These procedures are applicable to all response and enforce-
ment actions taken pursuant to CERCLA and section 7003 of RCRA.
This memorandum replaces guidance entitled "Requirements for
Selecting an Off-Site Option in a Superfund Response Action",
dated January 28, 1983. This policy is an interim one that the
Agency intends to publish as a notice in the Federal Register
in order to receive public comment 'on its provisions. After
reviewing these comments EPA will determine whether revisions
are necessary.
These revisions strengthen previous requirements in several
ways :
* Coverage - This'memorandum extends requirements to
enforcement acti'otxs under $106 of CERCLA and 57003 of RCRA,
and expands requirements for removal actions.
* Use of Treatment - These procedures require consideration
of treatment, recycling or reuse for all respo'n's-e and
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-3-
enforcement actions, to foster the use of more permanent
solutions, and, in. the case of remedial actions, where
cost-effective. The Agency is not certain whether
sufficient capacity is available at this time to use
treatment In all cases where it is feasible. As oore
information on capacity becomes available, the Agency
will re-examine requirements for treatment to determine
whether they can be strengthened. The previous procedures
did not address use of treatment.
* Requirements for a treatment, storage or disposal facility
Previous guidance required inspection within 12 months
before contract award for storage, treatment or disposal.
The revisions require inspection within six months of
actual storage, treatment or disposal. It also stated
that if a facility had deficiences that resulted in unsound
treatment, storage or disposal practices it should not be
used. The guidance also required RCRA violations that
adversely affected facility performance to be corrected
prior to contract award. Under the revisions, a facility
that has significant RCRA violations or other environmental
conditions that affect its satisfactory operation may not
be used unless certain conditions are met. First, there
must be a compliance agreement in place to correct all
deficiencies at the facility; second, the unit, that i.s
used must not cause or contribute to significant problems
at the facility. This provision recognizes that in some
situations it is infeasible to complete correction of all
violations prior to using a facility (for example, it may
take several years before pumping and treating of ground-
water is completed) and that there may be a unit at such
a facility that is sound.
* Land Disposal Facilities - The 1984 RCRA amendments impose
new requirements on land disposal facilities. When use
of such facilities is contemplated, the policy requires that
the facility meet these minimum technical requirements.
I. BACKGROUND
__________ jj_
Facilities that are not in compliance with RCRA reouirements
may be unacceptable to use for treatment, storage or disposal of
hazardous substances from response actions. Facilities used for
management of substances in connection with response actions
should not pose a significant threat to public health, welfare or
the environment.
CERCLA contains two'feferences to off-site management of
hazardous substances. First, CERCLA section 104(c) requires, as
a condition of Fund-financed remedial response, that the State
assure the availability of an acceptable facility in compliance
with the requirements of subtitle C of RCRA for any off-site
management of hazardous substances. Second, where remedial
measures include off-site storage, tre_itm«nt, destruction or
secure disposition, the statute *_l*o requires such measures to
be more cost-effective than other rewed:ai measures, create new
disposal capacity in compliance with Subtitle C of RCRA-or be
necessary to protect public health, welfare or the environment
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-U-
froo present or potential risk which nay be created by further
exposure to substances. Section 300.65 (b)(6) of the National
Contingency Plan (60 CFR 300) states i hat when off-site adio-i is.
taken In connection with a removal action the facility used for
off-site management oust be in compliance with Subtitle C of
RCRA. This memorandum establishes procedures for i mpl-ement i ne
these CERCLA and NCP provisions.
These procedures-apply to all removal, remedial, and enforce-
ent actions taken pursuant to CERCLA and section 7003 of RCRA.
Any other parties undertaking cleanup under other authorities
are urged to comply with these procedures. In the case of
Superfund-financed removal actions or enforcement actions taken
as a removal action in response to an immediate and significant
threat, compliance with these procedures is mandatory unless the
On-Scene Coordinator (OSC) determines that the exigencies of the
situation require off-site treatment, storage or disposal without
following the requirements. This exception may be used in cases
where the OSC believes that the immediacy of the threat posed by
the substances makes it imperative to remove the substances and
there is insufficient time to observe these procedures without
endangering- public "health, welfare or the environment. In such
cases, the OSC should consider, to the extent possible, temporary
solutions (e.g., interim storage) in order that the feasibility . .
of. using treatment can be evaluated prior to a decision to use
land disposal. Also, in such cases, the OSC oust provide-a
written explanation of his decision to the Regional Administrator.
This explanation should be provided within 60 days of taking
the action. In Regions in which authority to make removal deci-
sions has not been fully delegated by the Reeional Administrator,
the decisions discussed above must be cade by the Regional official
that is delegated removal decision making authority.
II. PROCEDURES FOR SELECTING HAZARDOUS WASTE MANAGEMENT FACILITIES
This section discusses in detail the re c ui r ener. t s Regions
oust follow in assessing and selecting an off-site RCRA facility
for management o f ^ Superfund hazardous substances. Part A requires
consideration of'treatment , recycling or reuse for on-site and
off-site actions in order to foster the use of more permanent
methods of managing hazardous substances. These policies are
consistent with directions taken by Congress in the 1986 amend-
ments to the Resource Conservation and Recovery Act. Furthermore,
Part B of this section establishes procedures Regions must use
in selecting an off-site RCRA facility for management of hazardous
substances. Where off-Vi-ee land disposal oust be used, this Part
requires that disposal facilities be in compliance with the appli-
cable technical requirements of RCRA.
.
A. Treatment
It is EPA's policy to pursue response art:'on* that use
treatment, reuse or recycling over land disposal re. the greatest
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-5-
.extent practicable, consistent with CERCLA requirements for
cost-effective remedial action*. EPA requires that such alterna-
tive* be considered for all Fund-financed and private party
renoval and remedial actions. For Fund-financed removals or
enforced actions in response to immediate and significant threats,
treatment, reuse or recycling must be considered, unless the OSC
determines that treatment, reuse or recycling methods are not
reasonably available considering the exigencies of the situation,
or they pose a* significant environmental hazard.
When developing remedial alternatives, treatment, reuse or
recycling must be considered. Such alternatives should not be
screened out on the basis of cost alone. Section 300.68Ch)(I) of
the NCP allows rejection of alternatives during the screening
stage based on cost, only when the cost of the alternative far
exceeds the cost of others (e.g., by an order of magnitude) and
does not provide substantially greater public health and envjron-
mental benefi ts.
Detailed analysis of these alternatives should include
consideration of long-term effectiveness of treatment and compara-
tive long -and short term costs of treatment as compared to other
remedial alternatives. Finally, when recommending and selecting
the appropriate remedial action, treatment, reuse or recycling
may be found more protective of public health and the environment
than land disposal. Such alternatives may be recommended as the
appropriate remedial action where the detailed analysis of
alternatives shows that the alternative is more cost-effective
than others in minimizing the damage to public health, welfare
or the environment. During the next six months, EPA will be'
developing additional guidelines for evaluating the comparative
long-term costs of treatment and land disposal.
At this time, the Agency does not know the current and
projected treatment capacity available, nor the needs or capacity
that will be required for Superfund actions in the future. Over
the next several months, the Agency plans to undertake a study
of available treatment and interim storage capacity and needs.
Once coiapl e t ed , "t hi s analysis will provide information on treat-
ment facilities currently operating for Regions to use. Additional
information on capacity will be provided at a later date through
a more comprehensive capacity survey being undertaken in support
of the implementation of the 1984 RCRA amendments.
B. Requirements for selecting storage, treatment or disposal
facilities
M^^VMMMMHMMWMMM
Selection of an appropriate facility for off-site management
of hazardous substances requires that a judgment be made as
to the overall acceptability of the facility to receive the
iubstances and the acceptability of the unit that will receive
the hazardous substances. In making this judgment the following
steps must be observed:
1. The owner or operator of any hazardous waste management
facility under consideration for off-site storage, treatment or
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actions under CERCLA or section 7003 of RCRA must have an applic-
able RCRA permit or interim status.2
2. A RCRA compliance inspection oust be performed at any
hazardous waste management facility before it can receive hazardous
substances from a response action. This inspection must assess
whether there are any significant violations or other environmental
conditions that affect the satisfactory operation of the facility,
The RCRA compliance inspection must have taken place not more than
six aonehs prior to the storage, treatment or disposal of the
hazardous substances from a response action. If the Inspection
has not taken place or is not scheduled, REM/FIT contractor
personnel may conduct the inspection under the direction of the
Deputy Project Officer, working in cooperation with RCRA Regional
personnel. If Regions use contractor personnel, the Region should
ensure that such personnel are adequately trained to conduct
inspections. Further guidance on conducting inspections when a
facility is being considered for management of hazardous substance?
will be issued in the near future. The FY 85 and FY 66 RCRA Inple-
mentation Plans establish compliance monitoring and enforcement
targets. For FY 85 the guidance requires Comprehensive Ground-
Water Monitoring Evaluations (CCMEs) at one third of the ground
water monit'oring facilities. Top priorities for this type of
inspection are all facilities receiving wastes froa Superfund
sites. '
* r
a
In States with Phase I or II interim authorization or final
authorization, the inspection should be conducted in accordance
with State regulations or permit conditions. E?A Regions
should always involve States when undertaking an inspection
at a RCRA facility that is likely to accept Superfund wastes.'
Regions must use the results from the inspection, alonz
with other information, to determine whether the facility is an
acceptable one.
Both permits and interim status apply to specific wastes and
specific storage, treatment or disposal processes. The Remedial
Project Manager (RPM) or OSC must determine that the facility's
permit or interim status includes the wastes that would be
transported to the facility and the type of process for which
wastes are being taken to the facility. Because of th'ese
concerns, it It important that facility selection be coordinated
with RCRA personnel. However, not all CERCLA substances are
hazardous wastes unde.r RCRA. Therefore, It is possible that a
particular permit nay hot cover a hazardous substance that may
be taken to the RCRA facility if it is not a hazardous waste.
Moreover, in some situations a hazardous substance under CERCL-
«ay trigger disposal requirements under other laws
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3. It is EPA'i policy to ainitrize the use of land disposal in
accordance with the direction taken by Congress In amending RCRA.
Where land disposal is used, these amendments establish new tech-
nical standards for land disposal facilities. New disposal units,
lateral expansions and replacement units (defined as of November 6,
1984) of interim status landfills and surface iapoundaents aust
have at least two lin.ers and a leachate detection, collection
and reaoval systea above (in the case of landfills) and between
the liners, if they receive wastes after May 8, 1985. All Fund-
financed and enforced response actions (removal and remedial)
Involving the off-site disposal of hazardous substances aust involve
use of disposal facilities that are in compliance with applicable
RCRA minimum technical reqiurements. This means that units first
receiving wastes after November 8, 1984 cannot receive wastes
after May 8, 1985 if not double lined. The RCRA statute does
allow continued use of existing units after that date. In consider-
ing whether to use an existing unit that does not mee't the double
liner requirements, the Agency will consider the toxicity, persis-
tence and mobility of the hazardous substances and the need to
segregate these substances from others. Such a unit can be
used only if it is shown to adequately protect public health and
the environment.
.8
CERCLA hazardous' substances which are not hazardous wastes
under RCRA may, in some circumstances, be disposed of in other
legal units. In such cases, disposal should take place in accordance
with other legal requirements. Hazardous substances which are no:
hazardous wastes nay be taken to a RCRA unit under the terrrs.out-
lined in the proceeding paragraph, or to a unit legal under other
statutory provisions (for example, PCBs may be disposed of in a
TSCA approved disposal facility and radiocative materials in a
radioactive materials disposal facility). This disposal must be
consistent with Section 104(c)(3) of CERCLA, when applicable.
4. Interim status land disposal facilities under considera-
tion for off-site disposal must have adequate ground water
monitoring data>to assess whether the facility poses a threat to
ground water.3 Due to the lack of compliance with RCRA ground
water requirements, available data nay not be adequate to assess
the facility. Moreover, lack of evidence of contaaination fron;
the monitoring data does not necessarily mean the facility is
secure. The aonitoring data aay be faulty. In addition, there
aay be other problems at the facility such as air emissions or
surface run-off. Where doubt exists concerning the acceptability
of a facility, an on-s.i,re inspection should be undertaken to
specifically address these concerns. Where possible, this
on-site inspection should be part of the required RCRA compliance
Inspection.
Allremaining land disposal permit applications will be
requested in FY 1985. These applications contain summaries
of ground water aonitoring data obtained during the interim
status period, and are required to identify any plume
contamination.
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-8-
5. Using information .gathered from the compliance inspection
ether data sources (e.g., RCRA facility pertsit data), any other
facility vi»it» and all other relevant inforsation, Regional
Offices Bust evaluate and aake a judgsent on the acceptability of
ualng the facility for storage, treataer.t or disposal of hazardous
substances. For the facility as a whole, this evaluation should
conaider whether there are any RCRA violations or other environ-
mental conditions4 at the facility which affect its satisfactory
operation. This evaluation should Include consideration of
facility operations as well as whether there are physical condi-
tions at the facility that pose a significant threat to public
health, welfare or the environment. For facilities In assessoer.t
monitoring, the conditions which lead to required assessment
monitoring, as well as resulting monitoring data, must be evaluated
The evaluation -also should consider the nature and quantity of the
substances and whether it is feasible to treat the substances prior
to land disposal to mitigate any adverse effects.
No Superfund hazardous substances shall be taken off-site to
a RCRA facility if the Region determines that the facility has
significant RCRA violations or other environmental conditions that
affect the satisfactory operation of the facility, unless
both the following conditions are met:
(1) The owner or operator must commit, through an enforce-
able agreement (i.e., consent o'rder or decree), to
correct the problem. The agreement must be signed
before the facility may receive the hazardous
substances. In addition, the Regional Administrator
must determine that the agreement is likely to result
in correction of the problem and the owner or operator
of th-e facility is capable of compliance with the terr.s
of the agreement; and
(2) Disposal only occurs within the facility at a new or
existing unit that is in compliance with RCRA require-
ments.;,. The new or existing unit must not contribute
in any significant way to adverse conditions at the
facility.
III. MANIFEST REQUIREMENTS
If an off-site option is chosen, a oanifest for the transpor-
tation of the hazardous* .waste must be obtained. The manifest must
It is recognized that the RCRA regulations aay not at this
tine cover all environmental conditions at a facility. Regional
offices aay consider other envi ronnent al factors at' 'a ' f aci 1 i t y
under consideration including other State and/or Federal
environmental laws. If a facility is in assessment monitor-
ing, the conditions which lead to assessment monitoring may
constitute environmental conditions that adversely affect
facility operations. In such cases, Regions should assess the
conditions at the facility prior to using the facility for
Superfund purposes.
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-9-
be in compliance vith RCRA for the transportation of hazardous
wastes. The manifest must be a Uniform Hazardous Waste Manifest
In compliance with requirements at 40 CFR 262 (see 49 FR 10490,
March 20, 1984). The lead agency or other party undertaking
the cleanup must ensure that the transporter properly notifies
under RCRA section 3010. Where the lead agency allows contractors
to fill out the manifest, the agency should ensure that the
anifest is properly filed.
IV. PCB DISPOSAL REQUIREMENTS
Requirements for the disposal of PCBs are established in
40 CFR 761.60. Generally, these regulations require that whenever
disposal of PCBs are undertaken, they must be incinerated, unless
the concentrations are less than 50 p p m. If the concentrations
are between 50 and 500 ppm, the rule provides for certain excep-
tions that provide alternatives to the incineration requirements.
The principal alternative is disposal in an EPA approved landfill
for PCBs. Landfills used for PCB disposal must be inspected
within six months prior to disposal. Regions oust determine the
acceptability of the facility based on the same criteria used to
evaluate RCRA facilities in Section II. B.5.
V. IMPLEMENTATION
Beginning (30 days from date this document is signed)'all
Records of Decision (RODs) and Enforcenent Decision Documents
(EDDs) for Superfund-1ead and enforcement lead actions, respec-
tively, must include a discussion of coapliance with these pro-
cedures for alternatives involving off-site management of Superfund
hazardous substances at RCRA facilities. Decision documents 'for
removal actions also should include discussion of compliance with
these procedures. It is recognized that actual offsite facility
information will not be available at the ROD stage. However, the
RI and FS should use actual off-site facilities in costing remedial
alternatives, in order to have cost figures that are as accurate
as possible. It is recognized that additional facilities are
likely to be considered during the bidding process. Any facility
ultimately selected for disposal, treatment or storage mus: meet
the requirernents'of this policy.
Provisions requiring compliance with these procedures must be
included in any contracts for response, cooperative agreements
with States undertaking Superfund response and all enforcement
agreements. For ongoing projects, these provisions will be
implemented as follows:
RI/FS: The Regions-shal2 immediately notify Agency contractors
and States that 1) alternatives for off-site manage a-, e n t
of wastes must be evaluated pursuant to the provisions
of this policy, and 2) consistent with the'policy on
other environmental laws, treatment alternatives
should not be dropped during the screening stage.
RD: The Regions shall immediately notify Agency contractors,
the States, and the U.S. Army Corps of Engineers that
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-10-
all remedies that Include off-site disposal of hazardoi"
substances must comply with the provisions of this
policy pertaining to selection of an acceptable off-si
faci1i ty.
RA: The Regions shall immediately assess the compliance
status of land disposal facilities receiving hazardous
wastes from ongoing projects. For a facility not in
compliance, the Reeion should take immediate steps
to bring the facility into compliance with the policy.
Enforcement: Actions currently under negotiation and all future
actions must comply with these procedures. Existing
agreements need not be amended. However, EPA reserves
the right to apply these procedures to existing
agreements, to the extent it is consistent with the
release and reopener clauses in the settlement agree-
ment (See the 1nr e r i a CERCLA Se111eaent Policy. Part
VII; Thomas, Price, Habicht; December 5, 198**).
I.f the response action is proceeding under a Federal-lead,
the Regions should work with the Corps of Engineers or EPA
Contracts Officer to negotiate a contracts modification to an
existing contract, if necessary. If the response action is
proceeding under a State-lead, the Regions should amend the
cooperative agreement. Exceptions for existing contracts and
cooperative agreements may be allowed on a case-by-case basis
by the appropriate Headquarters Office Director.
All Regions must adopt procedures to implement and continual-
ly monitor compliance with these requirements. The procedures
must include designation of a management official who is respon-
sible for providing information on RCRA facilities in the Region
to other Regions. It is the responsibility of the Region in
which the RCRA offsite facility is located to assess the accent-
ability of the facility in consultation with the Region planning to
ehip wastes to the facility. The names of these officials should
be provided to the Office of Waste Programs Enforcement by May
21, 1985. These names will then be forwarded to all Regions.
If you have any questions concerning these procedures, please
contact Sylvia K. Lowrance (FTS 382-4812).
At t a chmen t s
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APPENDIX C
SUBJECT OUTLINE FOR
HAZARDOUS WASTE GROUND-WATER TASK FORCE
FACILITY EVALUATION PLAN
(PROJECT PLAN) OUTLINE
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OUTLINE OF AREAS TO BE ADDRESSED IN THE FACILITY PROJECT PLAN
I. Introduction
A. General Task Force (TF) effort
1. Statement concerning the TF's mission
B. General objective of the TF and the site evaluation
1. Statement concerning why the TF is evaluating
this specific facility (i.e., facility accepts
CERCLA waste/ specific problems with the facility,
etc .)
C. The current regulatory status of the facility
II. Facility Background Information
A. Location
B". Current permit status
1. Federal and State
2. Other operating permits requiring ground-water
monitoring .
C. Compliance status
1. Administrative orders, consent orders, notice
of deficiencies, etc.
D. Physical description of the site
1. Waste management units (current and historical)
2. Hazardous and non-hazardous segregation units
3.. Size of units and subunits
4. Status of the subunits, (active, non-active,
dates of operation)
5. Closure status of all units and subunits
6. Proposed units (future expansion)
7. Leachate collection and removal systems
8. Liner systems
E. Hydrogeologic setting (short general description)
1. Topography (relief, regional and site specific)
2. Surface drainage (sequences, divides, impoundments)
3. General stratigraphy (identification of units,
depths, thicknesses)
4. Historical geologic development of stratigraphy
5. Significant structural features
6. Facility's designation of uppermost aquifer
7. Hydrologic characteristics of units (stratigraphy)
identified above
8. Flow directions (according to existing information)
9. Recharge and discharge areas
10. Gradients, vertical and horizontal
a. Municipal well fields
b. Private water wells
c. Industrial or site water supply wells
d. Surface water supplies
F. Ground-water monitoring system
1. Historical development
a. Number of wells and when completed (with respect
to each other)
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1
1
1
1
1
1
2. Depths ( relative to specific saturated zones)
acquifer")
3. General areal location
4. General map of site, with well locations.
5. Anticipated dates of new well construction
Waste characterization
1. Types of waste handled
a. Waste categories (organics, metals, etc.)
Ignitable?, explosive, radioactive, PCBs?
b. Liquids, sludges
c. CERCLA, RCRA or both
2. Waste handling processes
a. Treatment
b. Solidification
III. Inspection Methods
A. General description of the number of groups that
the TF will divide into:
1. Records review
2. Laboratory evaluation
3. Sampling
4. Management (may not be a separate group but
incorpaorates people from'other groups)
5. Interviews with critical personnel at facility
_ B. Records review group objectives are to obtain and
fi review on-site documents and information in order
^ to assess the following:
1. Actual waste location within specific waste
f| management units
ti " a. Tracking waste from receipt to final disposal
b. Solid waste vs. hazardous waste distribution
in units
J c. Waste analysis plan
2. Waste handling
a. Treatment
b. Solidification
c. Mixing of various categories of hazardous waste
or solid waste and hazardous waste (comingled)
d. Waste handling within specific units
e. Historical aspects of waste handling
3. Facility design and operation
a. Leachate collection systems
b. Drainage control systems (dikes, ditches)
c. Closure specifications of past units
d. Geotechnical data review (compaction, permeabi.'i
etc.)
e. Fill sequences and progressions
f. Historical changes in design
g. Plans and drawing as built, narratives
- surface impoundments
- waste piles
- land treatment
- sanitary landfill
0
n
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4. Ground-water monitoring capability
a. Ground-water monitoring data ( from the PRC
package and and any other ground-water
information that exist
b. Well construction of all wells
c. Hydrology-reports, papers, (local and regional)
d. Ground-water control systems (drains, etc.)
e. Permit conditions and authorizations requiring
ground-water monitoring and associated results
f. Detection monitoring system specifications
g. Assessment monitoring system
h. Waivers
i. Last EPA inspection
j. Last State inspection
5. Records review group logistics
a. How many in group
b. When group will hold interview with facility personi
(time allotment,daily, etc.)
c. When documents are needed
C. Laboratory evaluation group objectives are. to obtain
and review documents and information in order to assess
the accuracy of reported analytical data based on:
1. Laboratory quality assurance (on site and/or off
site)
a. Laboratory analytical procedures
b. Laboratory facilities, equipment, and containers
c. Precision and accuracy of laboratory (calibration
and frequency)
d. Data handling and reporting (validation, routine
accuracy assessment)
e. Sample handling procedures (chain of custody)
f. Laboratory personnel (qualifications)
g. Laboratory records and regulatory requirements
for records
h. Internal quality control checks (performance
and systems audits)
2. On-site waste analysis for waste screening
a. Review of formal waste analysis plan
b. Procedures for obtaining sample of incoming
waste
c. Type of "fingerprinting" done and adequacy
d. Analytical procedures (accuracy, etc.)
e. Equipment and facilities
f. Data handling and reporting
g. Laboratory personnel (qualifications)
3. Laboratory evaluation group logistics
a. How many in this group
b. Which off-site facilities will be visited and
when
c. Which on-site facilities will be visited and
when
d. Facility personnel availability requirements
e. Off-site facility locations and contacts
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1
1
1
Sampling group objectives are to obtain the best
representative samples of existing ground-water
quality (and contamination sources) and evaluate
facility.field sampling techniques to the extent
possible
1. Pre-sampling logistics
a. Indentification of sampling points
- criteria for selection of points (coverage of
all hydrologic units, past data, well integrity
etc.)
- prioritization of sampling points
- criteria for prioritization (past contaminatio
etc.)
- blanks, duplicates, PE samples
Development of sampling schedule will be prepared
by the sampling team leader prior to site inspection,
Sampling schedule based on purge times, facility
traffic, recovery time, accessibility, etc.
b. Personnel requirements
-"facility personnel participation
* how many will be available and what time and
for how long
* role of each facility person available
- description of VERSAR involvement
* role in task force effort
* number of VERSAR people on site
* contaminants to be analyzed for
- description of EPA personnel
* number of EPA personnel available for
sampling group
* designation of sampling team leader
* outline of field authority of sampling team
leader
* role of all EPA personnel on sampling team
- description of State personnel available
* role of State
* number of State personnel
c. Equipment requirements
- facility water level indicator, bottles,
preservatives, pumps, bailers, etc.
- VERSAR water level indicator, pumps or
bailers, HNU, QUA, bottles, preservatives,
field equipment, blank water, shipping
materials, etc.
- EPA: safety, communications, Urban Assualt
Vehicle, etc.
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~! 2. Sample collection and handling
I a. Safety monitoring (HNU, OVA, Geiger counter)
b. Purging procedures (water level, interfaces
i of oil, calculation of volume, etc.)
] - procedures for slow recovering wells
-- documentation-field notes
c. Sampling procedures
j - preparation, containers (volumes and grouping),
' - paperwork in-situ field parameters (pH, SC
temperature)
- collection of sample, blanks, and duplicates
i * priority of parameters (which ones to
delete if need be)
; - documentation-field notes
d. Post collection-preservation, filtering,
chain of custody, receipt of samples, and
shipment
Designate contact laboratories being utilized
to analyze Task Force samples including: methods,
holding times, OA objectives (precision, accuracy,
completeness), turn-around time, OA/OC procedures
e. ^Constitutes to -be analyzed for
f. Photographs
E. Management group objectives are to coordinate all
groups at facility evaluation
1. Safety
2. Group logistics
3. Establish chain of command
4.. Schedule daily debriefing meetings
5. Schedule the debriefing meeting with company
officials
6. Resolve on-site evaluation team problems
F. Interviews
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OSWER DIR. 9080.0-1
o Perform Safety Test
Ordinarily, ground water in a monitoring well does not emit toxic or noxious
gases that would present a safety hazard because wells are constructed in such
a way that the ambient pressure is equalized with the pressure inside the
casing. However, the potential exists for ground water in some wells to emit
toxic or noxious gases. Therefore, the initial approach to a well should
incorporate a safety survey.
Typically, the safety survey should include an inspection of the closed well to
determine if overpressure in the casing may be present. This" would likely be
found in a deep well constructed of solid unvented casing with a threaded cap
or plug. If such a condition is encountered, the sampling personnel should
slowly open the well after donning the appropriate safety gear. The escaping
gas at the well head should be sampled with anorganic vapor analyzer (OVA)
or other air scanning equipment to determine the need for respiratory
protection. Sampling personnel should also be equipped with portable
equipment, such as a Drager sampler, to analyze for other gases such as
hydrogen cyanide and hydrogen chloride.
The survey should be conducted by adhering to the established facility
and/or Regional U.S. EPA health and safety standard operating procedures.
o Opening The Well
Each monitoring well should be unlocked and opened at the time of sampling.
Premature opening of the well (except for evacuation of standing water in
wells drilled into materials .having low permeability) may invite questions
concerning the security of the well and the resultant validity of sample data.
The monitoring wells, that will be encountered may have several different kinds
of closure configurations. Access to each well should not be a problem when
facility personnel accompany or take the place of the field inspection team
personnel at each well. However, the pre-sampling equipment should include
various implements, such as pipe wrenches (for steel casing), strap wrenches
5-17
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OSWER DIR. 9080.0-1
(for plastic), and rubber mallets, to assist in opening corroded or tight well
closures.
o Measure Physical Parameters of the Well
Several physical measurements must be made of each well before sampling can
commence. Depth measurements are needed to calculate the volume of
standing water in the well casing, which in turn will determine the volume of
water that must be purged from the well prior to sampling. Well parameters,
such as total depth, should also be measured to check for casing integrity and
for siltation in the well screen. Corrosion can cause collapse- and/or leaking
of the well casing. This could lead to erroneous or misleading measurements
of water levels. Corrosion and silting can clog well screens, causing a slug-
gish response or no response to water level change.
' The inner diameter of the well casing should be determined and recorded.
Then, the static water level and depth of the well should be determined with a
steel tape. A sounder may also be used for the water-level measurement. If
immiscible constituents are suspected in the well, an interface probe should be
used to determine the depth of the immiscible layer before measuring the
water level and depth of the well. Measuring devices should be lowered into
the water slowly to prevent splashing. Whichever tool is selected should at
least be wiped with a clean paper towel, rinsed/washed with hexane, then
rinsed with distilled water, and air dried prior to and after use. The time of
the measurement of depth to water reading, point of reference, well depth, and
the height of the exposed well casing should be recorded.
The point of reference, such .as a benchmark, used by the facility should
be checked to ensure that elevation recordings were determined properly by a
professional surveyor. Determination of the number of linear feet of standing
water should be made by subtracting the distance from the top of the casing
to the static water level from the total depth of the well. It is important to
determine the static water level before purging the well so that water volume
can be calculated and a point of reference can be obtained for observing the
recharge of the well (especially in low-permeability zones).
5-18
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OSWER DIR. 9080.0-1
O PetermJQfl furying Volume
A minimum of three casing volumes of standing water should be removed
from the casing prior to sampling. The required volume has been calculated in
Figure 5-1 to minimize calculation in the field. Figure 5-1 is applicable for
well casings from a 2- to 8-inch radius, and for standing water levels up to
100 feet. The chart is based on the following formula:
V » r2h(0.49)
where: V = standing water volume in gallons
r = inside radius of well casing in inches
h - linear feet of standing water in the casing
The conversion f actor^ of 0.49 represents three casing volumes and includes the
conversion of inches to feet, cubic feet to gallons, and the incorporation of pi.
The calculation is shown as follows:
1 ft2 7.48 gallons
X X 3.1416 (pi) X 3 (volumes) = 0.49 gal
144 in2 ft3
The effects of pumping a well for a period of time to insure collection of a
"representative" sample have been effectively documented. In most cases, the water
stored in the well casing is of a different chemical quality than that contained in
the aquifer to be sampled. Solutes may be adsorbed or desorbed from the casing
material, oxidation may occur, and biological activity is possible. Therefore, the
stagnant water within the well bore must be purged. This will enable ground water
which is representative of the aquifer to enter the well.
o Determine Liquid Phases in the Well
After reviewing the data package, and during the development of the sampling
plan, it should become apparent whether or not the ground water to be
5-19
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OSWER DIR. 9080.0-1
sampled might include constituents of different densities and solubilities. Any
of the following conditions could be encountered:
1) Immiscible fluids - Insoluble compounds may either rest on the
ground-water surface or descend to a confining layer beneath the aquifer,
depending on the densities.
2) Dense solutions and contaminant stratification - Some soluble
contaminants tend to form discrete stratification sequences with narrow
adjacent zones of dispersion. Ground-water flow velocities are typically
very low and do not create sufficient turbulence to uniformly blend the
solutions.
Sampling personnel should attempt to determine if an immiscible layer is
present at the.top or bottom of the well. This should be done by using .a sensitive
electrical sounder which differentiates between the various fluid media to determine
the various liquid phases.
o Evaluation of Sampling Procedures
The recommended U.S. EPA ground-water sampling procedures are detailed in
the "Draft RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document" (U.S. EPA, I985a). These recommended procedures should be used by
the field inspection team to evaluate the adequacy of the sampling procedures
used at the facility.
Specific sampling evaluation questions to be asked by the inspectors are
detailed in Appendix A of this protocol document.
5-20
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OSWER DIR. 9080.0-1
S
I
§ d
§1
i
5-21
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OSWER DIR. 9080.0-1
5.4.6 Evaluation of Laboratory Procedures
The laboratory evaluation should cover the following general areas:
o OA/QC - This includes reviewing the facility's QA/QC program or plan,
checking to see that holding time criteria are met, ensuring that proper
chain-of-custody procedures are used, and determining whether U.S.
EPA-approved analytical methods are used.
o Equipment - This includes reviewing the adequacy and effectiveness of
the laboratory equipment.
o Recordkeeoiag - This includes reviewing data sheets for accuracy and
detail. The frequency that QA/QC analyses are reported should be noted.
o General Maintenance - This includes cleanliness of the instruments and
glassware.
o Laboratory Employee _Oualif ications - This includes reviewing the training
of chemists and laboratory technicians.
Specific laboratory evaluation questions are detailed in Appendix A of this
protocol document.
5.4.7 Debriefing Meeting
Findings from the inspection should be discussed among team members during
daily debriefing meetings. Discussions may include observed deviations from
prescribed or recommended procedures, resolution of disputes and logistical
problems, and revision of the inspection schedule.
A debriefing or closing conference should be held with the facility owner/
operator and facility personnel at the end of the inspection. The main function of
the inspection team is to observe and evaluate compliance. Overall compliance will
be determined in cooperation with the U.S. EPA Office of Regional Counsel and
5-22
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OSWER DIR. 9080.0-1
Regional Management upon final review of the report and other pertinent findings.
Statements on compliance status or enforcement consequences should not be
discussed with the facility owner/operator or environmental staff. However, facility
officials should be informed of any leaks, spills, or other major problems that
require immediate attention.
At this meeting, inspectors may request additional data, questions may be
asked or answered, requested permit changes and process modifications are noted,
and necessary receipts are provided. The inspectors should make a final review of
QA/QC guidance and field notes before the conclusion of the visit. Field notes
taken during the field evaluation should not be turned over to the facility officials.
The inspectors may inform the owner/operator that a copy of the sample results
may be requested and that results are made available in accordance with the
restrictions of the Freedom of Information Act and 40 CFR Part 2.
Written receipts should be provided to the owner/operator for all samples,
documents, and photographs taken from the facility. A copy of the receipt is
shown as Figure 5-2.
A Declaration of Confidential Business Information form should be provided for
those facilities either wishing to claim information as RCRA CBI or that accept
wastes that are regulated under the TSCA. In particular, facilities that are
approved to treat, store, or dispose of PCBs should be provided with this form.
5-23
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OSWER DIR. 9080.0-1
FIGURE 5-2: RECEIPT
mai MO.
Facility Location
5V-.
Hicsirr Qf rut DOCUMINTISI AMO/OH SAM£UISI OCKMIMO « MtfttBv ACKNOWVIOOI D:
HO.
OMCMWriQN
1 2, 3 2.
Tf
SIQNATU1I
y^Tftf Jj**ts
TIL 73r>-ht^
nun Men ill*
N 1232
5-24
-------
APPENDIX D
HSL PARAMETER LIST
-------
-------
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t e:'i .1 o t q , h , t > P a> / i en e
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"! air,m--i --'3HC
-------
APPENDIX E
LIST OF PARAMETERS, SAMPLE VOLUME, AND CONTAINERS
-------
OSWER DIR. 9080.0-1
APPENDIX E
LIST OF PARAMETERS. SAMPLE VOLUME. AND CONTAINERS
Parameter Sample Volume Containers
Volatile Organics 60 ml 60 ml vials,
(POX, POC) PTFE septa
Acid Extractables }
Base/Neutral Extractables } 1 gallon Glass
Pesticides/Herbicides 2 liter Glass
Total Metals 500 ml Glass or Plastic
Dissolved Metals 500 ml Glass or Plastic
Cyanide 1 liter Glass or plastic
Phenolics 1 liter Glass only
Nitrate and Ammonia 1 liter Glass or plastic
Sulfate and Chloride. 1 liter Glass or plastic
Dibenzofuran/dioxin 2 liter Glass
TOC 40 ml Glass, PTFE septa
TOX 40 ml Glass, PTFE septa
E-l
-------
OSWER DIR. 9080.0-1
APPENDIX F
TECHNICAL REPORT OUTLINE
-------
OSWER DIR. 9080.0-1
TECHNICAL REPORT OUTLINE
I. EXECUTIVE SUMMARY
INTRODUCTION
o Task Force Effort
o Objectives of Evaluation
o Background
History of site (with regard to hazardous waste disposal)
State/Federal Permits, Approvals and other relevant
requirements
Adjacent land use
SUMMARY OF FINDINGS AND CONCLUSIONS
o Interim Status Ground-water Monitoring Program (Part 265, Subpart
F or State Equiv.)
, « ,
o Proposed Ground-water Monitoring Program (Part 270.14 - Part B
submittal)
o Groundwater Contamination (Company and Task Force analytical data
- prior or continuing releases)
o Superfund offsite policy (site in compliance or not with regard to
policy)
II. TECHNICAL REPORT
INSPECTION METHODS
o Records review
o Onsite inspection
o Laboratory inspection
o Task Force sampling locations and methods
WASTE MANAGEMENT UNITS AND OPERATION
o Waste Management Units
Units regulated under interim status
. Surface impoundments
. Landfills
. Other
Pre-interim status units
F-l
-------
OSWER DIR. 9080.0-1
Facility Operation
[Quality of records with regard to preacceptance waste analysis -
how well does the company know what the hazardous waste
constituents are?]
SITE HYDROGEOLQGY
o Hydrogeologic Units
o Ground-Water Flow
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
o Regulatory Requirements
o Ground-Water Sampling and Analysis Plan
o Monitoring Wells
o Sample Collection and Handling Procedures
"o Sample Analysis and Data Quality Evaluation
o Ground-Water Quality Assessment Outline
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL" PERMIT
o Submittal Date(s)
o Summary of Notice of Deficiencies
o Evaluation of Current Proposed Program
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
o Task Force Data
o Company Data
REFERENCES
F-2
-------
APPENDIX G
QUALITY ASSURANCE PROJECT PLAN
-------
TABLE OF CONTENTS
PAGE
LIST
LIST
1.0
2.0
3.0
4.0
OF FIGURES . .
OF TABLES
PROJECT DESCRIPTION
1.2 Objectives
1.3 Schedule
PROJECT ORGANIZATION AND RESPONSIBILITY ".
2.1 Headquarters Core Team
2.2 National" Enforcement Investigations Center . . . .
2.3 Regional Teams
2.4 State Teams
2.5 Program QA/QC Responsibilities . . .
a
DATA QUALITY OBJECTIVES
3.1 Introduction
3.2 Accuracy
3.2.1 Organics Analysis
3.2;2 Inorganics
3.2.3 Goals for Accuracy .
3.3 Precision
3.3.1 Organics
3.6 Comparability
SAMPLING PROCEDURES
4.1 Selection of -Sampling Sites
4.1.1 Facility Selection . .
4.1.2 Monitoring Well Selection
.... iv
.... iv
.... 1-1
.... 1-1
.... 1-4
.... 1-4
.... 1-5
.... 2-1
.... 2-1
.... 2-3
.... 2-3
.... 2-4
.... 2-4
.... 3-1
.... 3-1
.... 3-1
.... 3-1
.... 3-2
.... 3-2
.... 3-6
.... 3-6
.... 3-9
.... 3-9
.... 3-12
.... 3-12
.... 4-1
.... 4-1
.... 4-1
.... 4-2
continued-
-------
Table of Contents - continued
PAGE
4.2 Ground Water Sampling Procedures and Equipment . 4-2
4.3 Sample Handling 4-3
5.0 SAMPLE CUSTODY 5-1
5.1 Introduction 5-1
5.2 Project Chain-of-Custody and Document Control Procedures . 5-2
5.2.1 Field Sampling Operations 5-2
5.2.2 Laboratory Operations 5-2
6.0 CALIBRATION PROCEDURES AND FREQUENCY 6-1
6.1 . Sampling Equipment 6-1
6.2 Analytical Instruments/Equipment 6-1
7.0 ANALYTICAL PROCEDURES ....,.- ..'... 7-1
'
8.0 DATA REDUCTION, VALIDATION AND REPORTING 8-1
8.1 Introduction 8-1
8.2 Data Reduction and Interpretation 8-1
8.2.1 Pesticides/PCBs by GC/ECD 8-1
8.2-.2 Organics by GC/MS 8-1
8.2.3 Inorganics by Atomic Absorption 8-1
8.2.4 Inorganics by Atomic Emission 8-1
8.2.5 Cyanide 8-1
8.2.6 Indicator Parameters 8-2
8.3 Quality Control of Data 8-2
8.4 Data Reporting 8-2
9.0 INTERNAL QUALITY CONTROL CHECKS 9-1
9.1 Analytical Quality Control Checks 9-1
9.2 Sampling Quality Control Checks 9-1
10.0 PERFORMANCE AND SYSTEM AUDITS 10-1
10.1 System Audits ....... 10-1
10.2 Performance Audits 10-1
continued-
ii
-------
Table of Contents - continued
PAGE
11.0 PREVENTATIVE MAINTENANCE PROCEDURES AND SCHEDULES 11-1
11.1 Sampling Equipment 11-1
11.2 Analytical Instrumentation and Equipment 11-1
12.0 SPECIFIC ROUTINE PROCEDURES TO ASSESS DATA PRECISIONS, ACCURACY
AND COMPLETENESS 12-1
12.1 Statistical Procedures for Assessing Precision, Accuracy
and Completeness of Measurement Data 12-1
12.1.1 Precision - 12-1
12.1.2 Accuracy 12-3
12.1.3 Completeness ..... 12-4
12.2 Control Charts 12-4
12.3 Methods Used to Gather Data for Precision and Accuracy
Calculations 12-5
13.0 CORRECTIVE ACTION ° 13-1
13.1 Data Acceptability Limits that Trigger Corrective Actions . 13-1
13.2 Corrective Actions to be Taken 13-1
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 14-1
14.1 Laboratory Reporting Frequency and Format 14-1
14.2 Audit Results 14-1
REFERENCES
ATTACHMENT 1 STATEMENT OF WORK, INVITATION FOR BID (IFB) FOR
ORGANICS ANALYSIS
ATTACHMENT 2 MEMORANDUM FROM LINDA HAAS BOYNTON
ATTACHMENT 3 INVITATION FOR BID (IFB) FOR INORGANIC ANALYSES
iii
-------
LIST OF FIGURES
FIGURE
PAGE
1 Organizational and Functional Relationships for Hazardous
Waste Ground-Water Task Force 0 . 2-2
2 Program Data Flow 2-5
LIST OF TABLES
TABLE PAGE
1 Data Procurement Requests 1-2
2 Laboratory Analyte Spike Levels for Metals Parameters .... 3-3
« a
3 Laboratory Analyte Spikes for Inorganic and Indicator
Parameters 3-4
4 Accuracy Goals for Organic Surrogates and Matrix Spike
Recovery in Water Samples 3-5
5 Accuracy Goals for Inorganic and Indicator Analyses 3-7
6 Program Goals for Precision by Compound Fraction 3-8
7 Program Precision Goals for Matrix Spike/Matrix Spike
Duplicate Analyses 3-10
8 Program Precision Goals for Inorganic and Indicator
Analyses 3-11
9 Analytical Methods to be Used for Indicator Parameter
Analyses 7-2
10 Data Sources for Precision and Accuracy Calculations .... 12-6
11 Quality Assurance Sample Frequency 12-7
iv
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Section No. 1.0
Revision No. 2
Date: September 30, 1986
Page 1 of 5
1.0 PROJECT DESCRIPTION
1.1 Introduction
The U.S. Environmental Protection Agency (EPA) established ground-water
monitoring regulations for land disposal facilities (40 Code of Federal
Regulations (CFR) Parts 264 and 265, Subpart F) under the Resource Conser-
vation and Recovery Act (RCRA). The Agency has established a Task Force to
evaluate the level of compliance in the regulated community and the causes for
poor compliance. Compliance with the monitoring regulations is important to
establish with a high degree of certainty whether land disposal units subject
to the RCRA regulations are leaking and if so, whether they pose a threat to
human health and the environment.
The Task Force consists of two groups. The Operations Assessment Group is
responsible for identifying problems that have inhibited EPA and State efforts
in obtaining facilities' compliance with the ground-water regulations. The
Facility Assessment Group is responsible for evaluating the status of ground-
water monitoring at regulated commercial hazardous waste land disposal facil-
ities and identifying actions to be taken to resolve any problems found. This
Quality Assurance Project Plan addresses the activities to be carried out by
the Facility Assessment Gr.oup.
Current estimates indicate that there are 58 land disposal facilities to be
evaluated. These facilities currently receive and manage commercial wastes.
Phase I of the program will involve evaluation of 6 of the 58 facilities. The
remaining 52 facilities will be evaluated during subsequent Phases of the
Program. Phase I is a "shakedown" effort to identify and correct initial
program problems. Phase I will involve analysis of ground-water samples for
approximately 150-200 compounds whereas in Phase II the number of compounds
may be expanded to include more of the compounds listed in Appendix VIII of 40
CFR Part 261.
The ground-water monitoring effort will involve four major activities. These
are:
1. The review of existing information
2. Site inspections
3. Sampling and analysis
4. Site evaluation
Existing background data on each facility will first be collected and evalu-
ated. Sources of this information may include facility files at EPA Head-
quarters and Region Offices and State Agencies and owner/operator records.
The Core Team leader will meet with the contractor to discuss the site
specific information to be procured by the contractor. A checklist of this
information is presented in Table 1.
-------
Section No. l._0_
Revision No. 2
Date: September 30, 1986
Page 2 of 5
Table 1
DATA PROCUREMENT REQUESTS
Aerial photos
Maps of the facility and surrounding area
Regional geology and physiographic reports, (U.S. Geological Survey,
U.S. Department of Agriculture, Soil Conservation Source, etc.)
Well inventory of the area surrounding the facility
History of the facility, including past waste handling practices,
Standard operating procedures (including protocols for sampling ground
water, air, soil, waste analysis, analytical services,- lab audits,
Quality Assurance/Quality Control (QA/QC))
Facility's assessment plan
Ground-water, monitoring plans (past and present)
Potentiometric maps and flow maps
Well drilling and boring logs (gamma, neutron, resistivity, etc.)
Well construction material
Facility investigation reports used to design the ground-water moni-
toring system
All ground-water sampling and analysis data
Records of leachate levels
Ground-water chemistry data, including the analytical methods used
Pumping or injection rates of all production or injection wells on or
near the facility
Surface-water near the facility
Technical drawings of the units (blueprints, engineering drawings and
specifications)
Geotechnical reports detailing construction activities including
photos of the construction process
Construction logs for the units that have accepted waste
Permit application (Part A and relevant portions of Part B)
Aquifer characteristics information (hydrologic parameters and calcu-
lations)
Man-made hydraulic controls (French drains, slurry walls, etc.)
Design of the leachate collection system
Inspection reports
Notices of deficiency
National Pollutant Discharge Elimination System and other relevant
permit applications
Waste analysis and air monitoring data
-------
Section No. 1.0
Revision No. 2
Date: September 30, 1986
Page 3 of 5
After data collection efforts are completed, in-depth evaluations will be
conducted to determine:
Probable areas of noncompliance with the Subpart F requirements.
Probable existence and nature of contamination of the ground water.
Other shortcomings in monitoring system design and operation.
Validity and comprehensiveness of existing data.
Useful activities to be conducted during the site inspection.
Using the results of this evaluation a management plan developed under the
guidance of this Quality Assurance Project Plan specific to each facility will
be prepared. This site specific project plan will detail the objectives and
activities of the site inspection.
All site inspections will be conducted in accordance with the site specific
project plan. The site inspection will involve: observing owner/operating
sampling protocols; evaluating monitoring well placement and design; deter-
mining, where applicable, owner/operator compliance with the ground-water
monitoring'plan for the facility; and obtaining missing data and information
identified during the data collection and evaluation activities.
The Core Team leader will meet.with the contractor to discuss the site spe-
cific information to be procured by the contractor (Table 1).
It is anticipated that site inspection teams will sample at most or all sites.
Duplicate field samples will be provided to all participating laboratories,
where and when requested. EPA contract laboratories will analyze all samples.
For Phase I there will be one laboratory for organic analyses and one
laboratory for inorganic analyses. Owner/operator laboratories, EPA regional
laboratories and state laboratories may also analyze samples, though their
participation will be on a voluntary basis.
Results of the data evaluation, site inspection and sample analyses will be
used to prepare a facility evaluation report. This report will contain:
Observations and findings from the data review, the oh-site inspection
and sampling and analytical results.
Conclusions covering regulatory compliance and probable nature and
level of ground-water contamination.
Recommendations on technical activities necessary to achieve com-
pliance or determine the nature and extent of contamination.
The draft report will be reviewed, revised and finalized by appropriate Task
Force participants. The- facility evaluation report will be used by the region
to prepare a draft facility management plan that will identify administrative
actions (orders, penalties, permit conditions, etc.) or other actions neces-
sary to gain regulatory compliance or resolve other problems identified in the
facility evaluation report.
The EPA Regional Office or state will be responsible for implementing recom-
mended administrative actions. A Task Force Core Team representative will
track the progress of all actions taken at the facility.
-------
Section No. 1.0
Revision No.2~
Date: September 30, 1986
Page 4 of 5
1.2 Objectives
Four main objectives have been defined for the ground-water monitoring pro-
gram. These are:
1. To determine if the facilities monitored are complying with the RCRA
regulations set forth in 40 CFR Parts 264 and 265 Subpart F.
2. To develop a consistent Agency-wide strategy and approach for
performing comprehensive ground-water monitoring evaluations.
3. To establish nationally consistent actions in the form of permit
conditions, compliance orders, penalties, etc., to bring facilities
into compliance with ground-water monitoring regulations.
4. To identify problems that have inhibited state and EPA efforts in
gaining compliance with the ground-water regulations.
Specific objectives to determine RCRA compliance will be to:
1. Determine if owner/operator sampling procedures are being followed
and performed correctly.
2. Determine if analytical results generated by owner/operator labora-
tories are reasonable.
3. Determine if there is a contamination plume and the source of the .
plume.
To complete this last objective, the ground-water monitoring system in place
at the facility will be evaluated in detail to establish its adequacy for
determining unit leakage.
Experience gained from the actual ground-water monitoring activities will be
used to develop an Agency-wide strategy and approach for performing compre-
hensive ground-water monitoring evaluations. Also based on the experience
gained in these facility evaluations, model language for permit conditions and
compliance orders and the types and magnitude of penalties imposed on any
noncompliant facilities will set precedents for future actions to gain
regulatory compliance.
As mentioned above, the Operations Assessment Group will be responsible for
the fourth objective. However, a Core Team representative will communicate to
the Operations Assessment Group problems with guidance, policies, regulations,
availability of technology, organization, skills and any other identifiable
problem areas that may impact their program.
1.3 Schedule
The Facility Assessment Group will schedule evaluations based on the following
criteria:
Ongoing or planned evaluations by the State, EPA Regional Office or
the National Enforcement Investigation Center (NEIC).
Volume and variety of waste at the facility.
-------
Section No. 1.0
Revision No. 2
Date: September 30, 1986
Page 5 of 5
Receipt of Superfund wastes by the facility.
Location and number of sites in each region (Region I has none).
Seasonal weather conditions.
A schedule for Ground-Water Task,Force activities is provided in the Data
Quality Objective (DQO) document prepared by the Task Force. This schedule
is likely to be modified as details on each facility become available.
The Phase I evaluation of five facilities is scheduled for completion by the
end of fiscal year 1985. Completion of 28 facility evaluations (Phase I and
Phase II combined) is estimated to be October, 1986. The remaining facilities
will be evaluated during subsequent Phases of the Program and may not be
completed for several years.
1.4 Purpose of This Report
The overall purpose of this QA Project Plan is to provide the guidance needed
to ensure that samples and measurements are taken according to EPA protocols
and that data generated under the Program will meet program quality objectives
comparable to data generated by other studies. ' ~
» v
This plan provides general QA/QC guidelines that must be considered in prepar-
ing site specific sampling and project plans before carrying out sampling and
analysis activities that result in data collection and reporting. It should
be emphasized that DQO presented here are derived from the separate Task Force
DQO document prepared by the Task Force and are, at this preliminary stage, a
goal that may be influenced throughout the course of the Program by actual
site data and/or resource constraints. It should also be noted that for
certain elements of the plan, information is presented in greater detail in
other documents. These are referenced where appropriate.
(a) Ground-Water Monitoring Task Force Data Quality Objective (DQO)
Development Process (Preliminary Draft).
-------
Section No. 2.0
Revision No. 2
Date: September 30, 1986
Page 1 of 5
2.0 PROJECT ORGANIZATION AND RESPONSIBILITY
The hazardous waste ground-water monitoring program is organizationally and
functionally complex. Figure 1 depicts the organization and functional
relationships among the various components of the Ground-Water Task Force.
The Task Force was established by the EPA Administrator to evaluate the level
of compliance and address causes of poor compliance. As noted above, the Task
Force consists of two major groups, the Operations Assessment Group and the
Facility Assessment Group. This Plan addresses only the activities of latter
group.
The Facility Assessment Group consists of four major entities: the Headquarters
Core Team, NEIC, Regional Teams and State Teams. These are discussed in
greater detail below.
2.1 Headquarters Core Team
The Core Team is the component of the field evaluation effort managed by EPA
Headquarters. It will include members from states and EPA Regional Offices as
well as from EPA Headquarters staff.
The Core Team will initially be composed of three investigators, each with
hydrogeologic backgrounds and field experience. The Core Team will eventually
be expanded to six hydrogeologists to accommodate additional sites included in
the Program. Each Core Team investigator will be assigned to activities in
one or more Regions.
The Core Team's functions will be to:
1. Ensure consistency and uniformity in the facility evaluation effort.
2. Accumulate, on a nationwide basis, the data necessary to make
Superfund decisions on the disposal of wastes.
3. Identify and evaluate problems encountered in the field so that
guidance, training, regulation and research programs can address
them.
4. Provide a vehicle for technology transfer and cross fertilization
among regions and states.
5. Provide contractor and organizational support to the Program and
develop work plans, checklists, communications plans and other tools
to assure smooth functioning of the effort.
6. Conduct in-depth evaluations of data and information collected on
each facility.
7. Review facility evaluation reports and submit technical problems
that are identified to the Technical Advisory Panel for review and
advice.
-------
Section No. 2.0
Revision No. 2 '
Date: September 30, 1986
Page 2 of 5
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-------
Section No. 2.0
Revision No. 2
Date: September 30, 1986
Page 3 of 5
8. Interface with the Office of Waste Programs Enforcement (OWPE) and
the Office of Solid Waste (OSW) to resolve issues of regulatory
interpretation and to provide assistance in compliance order or
permit writing.
9. Develop entry plans, inspection Standard Operating Procedures (SOPs)
sampling protocols, chain-of-custody procedures, QA/QC procedures
and document control SOPs.
10. Arrange for laboratory audits when analyses of quality control
samples do not provide correct results or when corrective actions
are deemed necessary.
11. Track progress at facilities where actions to gain compliance have
been taken.
2.2 National Enforcement Investigations Center
The NEIC, because of. their previous experience in performing site
investigations, will be responsible for the first facility evaluation in each
Region. The NEIC will review the facility file, propose the draft project
(inspection) plan, provide the on-site coordinator for the inspection and
'draft the facility report for the first facility evaluated in each Region.
The NEIC will function in the Facility Assessment Group to:
Provide consistency to the Task Force effort by bringing a single
team to perform the first evaluation in each region.
Assist the Core Team in developing protocols and SOPs and providing
structure to the Program based on their existing processes and
procedures and their extensive experience in conducting similar
investigations.
Provide an independent source of expertise.
2.3 Regional Teams
Regional Teams will organize Individual facility assessments based on the
guidance and procedures in this document and on protocols and SOPs being
developed by the Core Team. The Team Leader and regional management will
determine the makeup of the Regional Teams. They will include, in most cases,
field inspectors, permit writers, enforcement staff, Regional counsel,
sampling and analytical personnel and a communications expert.
For consistency, all specific facility investigations, except the first in
each region, will be coordinated and scheduled by the Regional Team Leader.
After the first investigation is complete in each region, the Regional Team
will provide the on-site coordinator and will draft the project plan and
facility evaluation report. The Regional Team will be responsible for
logistics from an EPA perspective and for coordinating with the states in
initiating or overseeing state implemention of most decisions.
-------
Section No. 2.0
Revision No. 2
Date: September 30, 1986
Pa8e 4 of 5 _
The region will also be responsible for drafting the facility management plan
that identifies administrative or other actions needed to gain compliance.
The Regional Team Leader will be responsible for arranging a. meeting of Team
Leaders and managers to discuss the facility management plan. They will
determine actions that should ensue. This group will develop a schedule for
taking the corrective actions and assign responsibilities for implementation.
The region may also be responsible for preparing compliance orders, preparing
or modifying permits, assessing penalties, etc., if the state where the
facility is located does not have EPA authorization to implement its own
hazardous waste program.
2.4 State Teams
The states will be participating in the Task Force study at their own
discretion. It is anticipated that most states will agree to an equal
partnership role and participate in the inspection activities and
investigation generally. State Teams will most likely be comprised of
personnel similar to.those on the Regional Team (i.e., Team Leader, field
inspectors, enforcement staff, etc.).
Where states have authorization to manage their own hazardous waste programs,
they will be involved in developing arid implementing the facility management
plan.
2.5 Program QA/QC Responsibilities
The responsibility of ensuring proper QA/QC procedures will be distributed
among several Program participants. Overall coordination of QA/QC efforts for
the Program will- be managed by the Headquarters Core Team Technical
Coordinator, Mr. Richard Steimle, with support from the Waste Analysis and
Methods Program of the OSW. The Quality Assurance Project Officer responsible
for reviewing and approving the Quality Assurance Project Plan is Florence
Richardson.
An ad hoc committee consisting of Environmental Monitoring Systems Laboratory
- Las Vegas (EMSL-LV), Environmental Monitoring and Support Laboratory -
Cincinnati (EMSL-Cin), OSW personnel and support contractors will also
participate in the review of the Quality Assurance Project Plan and will be
responsible for reviewing results of the data evaluation, the performance
evaluation (PE) and laboratory audits and will present their findings to the
Task Force Core Team.
Evaluation of laboratory QC data will be performed by Life Systems, Inc.,
performance evaluation activities (sample preparation and scoring) by EMSL-Cin
and systems audits of the contract laboratories by EMSL-LV. The laboratory QC
evaluation will not involve an interpretation of the data with respect to
actual site conditions (i.e., Is the site leaking?). The Hazardous Waste Task
Force Core Team and designated experts will interpret all data with respect to
actual site conditions.
Figure 2 shows the overall flow of sampling and QA data under the Program.
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Section No. 2.0
Revision No. 2
Date: September 30, 1986
Page 5 of 5
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 1 of 12
3.0 DATA QUALITY OBJECTIVES
3.1 Introduction
The purpose of this section is to provide qualitative and quantitative
information that defines the quality of data that must be collected to meet
the goals of the ground-water monitoring study. The Task Force has prepared a
separate DQO document describing the constraints and requirements taken into
account in developing the DQO incorporated in this Quality Assurance Project
Plan.
The primary goal of the sampling and analytical activities of the program is
to determine if the ground water at a facility is contaminated. The data
generated will provide a "snapshot" of the condition of the ground water at the
time of sampling. Data will not be generated over an extended time period to
show variations due to seasonal or other factors. Thus, the data collected
from the study will be used to support the need for additional data
collection activities and/or be used in conjunction with existing monitoring
data to make decisions regarding needed actions.
The goal for the reliability of Program data will be at the 95Z confidence
level. A goal of ±20% is proposed for sampling precision. Sampling precision
will be evaluated using duplicate field samples. Duplicate sample results
will help to establish precision among different samples collected from the
same site. Splits of the same sample will provide a measure of precision
within that sample (sample homogeneity). Duplicate samples will be collected
for volatile organic analysis at all wells. Duplicate samples for semivola-
tile and inorganic analytes and indicator parameters will be collected from at
least 5Z of the monitoring wells or at least two duplicates per site.
Analytical precision is discussed later in this section.
The DQO for this Program will be developed in two phases. The DQO presented
above define goals for Phase I of the Program. Using the data generated from
Phase I, more definitive DQO will be developed for Phase II of the Program.
The DQO are defined in terms of accuracy, precision, representativeness,
completeness and comparability of the data. These are discussed below.
3.2
Accuracy
Accuracy can be defined as how closely observed values conform to the true
value. Methods and goals that will be used to determine the accuracy of the
analyses are discussed below. These goals may change for Phase II based on
the outcome of Phase I analyses.
3.2.1
Organics Analysis
For organics determined by protocols in Attachments 1 and 2, recovery of
analytes from PE and spiked samples will be used to monitor accuracy. One set
of PE samples will be used for each site during Phase I. A set will consist
of blanks and spiked samples for volatiles and other organics (acids and
-------
Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 2 of 12
base/neutral extractables, pesticides/polychlorinated biphenyls (PCBs)
herbicides and dioxins). When possible, these samples will be prepared on
a site specific basis to mimic the expected composition of the environmental
samples as closely as possible.
The accuracy objectives for quantitative analysis will be expressed in terms
of recovery of PE sample and spike analytes. Percent recovery of analytes
will be determined as follows:
_ A , fc 0 Observed Concentration inn
Z Analyte Recovery - = -. x 100
3 J True Concentration
Analyte recovery data will be compared to that generated by the referee
laboratories and EMSL-LV. The results from the referee laboratories and
EMSL-LV will be used to establish target concentrations and control limits.
Control charts will be prepared for each spike compound. Warning and control
limits will be established. Laboratory values will be plotted on these
control charts to monitor analytical accuracy.
Surrogate compound recoveries from PE and field samples will be monitored to
ensure conformance with Program limits. Control charts will be used to
monitor average percent recovery per case and a continuing average fp.r the
project.
3.2.2 Inorganics
Accuracy for inorganics and indicator parameters will be monitored by
determining percent recovery for PE and spiked samples. Initially, one
inorganic and indicator parameter PE sample will be included with the samples
from each site.
Analytic recovery will be calculated by the same procedure used to calculate
percent analyte recovery for organic samples.
The inorganic PE samples will be prepared with appropriate levels of the
required compounds. Levels will be near or above contract required detection
limits.
Recovery limits for each PE parameter will be determined by the referee
laboratories and EMSL-LV. Control charts will also be maintained to monitor
contract laboratory results for inorganics.
Spike levels for inorganic analytes are presented in Tables 2 and 3.
3.2.3 Goals for Accuracy
Referee laboratory data and EMSL-LV sample data will be used to develop goals
for control limits and to monitor data acceptability for organic pollutant
analyses by gas chromatography/mass spectrometry (GC/MS). Presented in
Table 4 are actual surrogate and matrix spike recovery limits for the Contract
Laboratory Program (CLP) expressed as a percentage of the mean at the 95Z
confidence interval. These limits, derived from historical CLP data using the
same analytical methods that will be used in Phase I are required because of
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 3 of 12
Table 2
LABORATORY ANALYTE SPIKE LEVELS.FOR
METALLIC ANALYTES IN WATERU'
Element
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
For ICP/AA(b)
(Ug/L)
2,000
2,000
50
50
100,000
200
500
250
1,000
500
50,000
200
400
50,000
50
100,000
400
500
200
For Furnace AA Other
(ug/L) (ug/L)
50
20
5
20
1
10
50
200
(a) Amount to add prior to digestion/distillation choose amount
appropriate to method of analysis. Elements without spike levels
should be spiked at appropriate levels.
(b) Inductively coupled plasma emission spectroscopy/atomic absorption
spectrophotometry.
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Section No. 3.0
Revision No.2~
Date: September 30, 1986
Page 4 of 12
Table 3
LABORATORY ANALYTE SPIKE LEVELS FOR
INORGANIC AND INDICATOR ANALYTES
Analyte Spike Level (mg/L)
Cyanide 100
Sulfate 200, .
pH N/AU;
Total Organic Halide (TOX) 1
Purgeable Organic Halide (POX) 1
Total Organic Carbon (TOC) 10
Purgeable Organic Carbon (POC) 10
Chloride 250
Nitrate 1
Ammonia Nitrogen 10
Total Phenols . , 0.05
(a) N/A - Not Applicable.
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 5 of 12
Table 4
ACCURACY GOALS FOR ORGANIC SURROGATES AND MATRIX
SPIKE RECOVERY IN WATER SAMPLES
Fraction
VOA(b)
VOA
VOA
VOA
VOA
VOA
VOA
V°fb)
BNW
BN
BN
BN
BN
BN
BN
BN
BN
Acid
Acid
Acid
Acid
Acid
Acid
Acid
Acid ( .
Pest.(c)
Pest.
Pest.
Pest.
Pest.
Pest.
Pest.
Analyte
Toluene-Dg
4-Bromofluorobenzene (BFB)
1 ,2-Dichloroethane-D,
1 , 1-Dichloroethene
Trichloroethene
Chlorobenzene
To luene
Benzene
Nitrobenzene-D,
. 2-Fluorobiphenyl
Terphenyl-D. .
1,2, 4-Trichlorobenzene
Acenaphthene
2 , 4-Dinitrotoluene
Pyrene
N-Nitroso-di-n-
propylamine
1 , 4-Dichlorobenzene
Phenol-D
2-Fluorophenol
2,4, 6-Tribromophenol
Pentachlorophenol
Phenol
2-Chlorophenol
4-Chloro-3-methylphenol
4-Nitrophenol
Dibutylchlorendate
Lindane
Heptachlor
Aldrin
Dieldrin
Endrin
4, 4 ''-DDT
Accuracy (Z)
88-110
86-115
76-114
61-145.
71-120
75-130
76-125
76-127
35-114
43-116
33-141
39-98
46-118
24-96
26-127
41-116
36-97
10-94
21-100
10-123
9-103
12-89
27-123
23-97
10-80
24-154
56-123
40-131
40-120
52-126
56-121
38-127
(a) Volatile organic.
(b) Base/neutral.
(c) Pesticide.
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 6 of 12
the need to determine the significance of upgradient and downgradient mean
concentrations of contaminants. Inspection of reporting forms will be performed
to check for conformance with these limits. Because the composition of PE
samples will vary from site to site, compounds listed in Table 4 may or may
not be present in a PE sample.
For metals determined by protocols in Attachment 3, contract recovery limits
of 75-125Z are established. The laboratory is required to identify (by
flagging results with an R) those recovery values not falling within these
limits unless the sample concentration exceeds the spike concentration by a
factor of four or more. When this happens, the laboratory reports unf lagged
results at the observed recovery values.
Laboratory data will be checked for conformance to these criteria and to the
established DQO (90-110%). These limits may be updated as additional Program
data become available.
Recoveries for Laboratory Control Samples (LCSs) must be within 80-120%. If
recovery falls outside of this range, the analysis will be repeated. If
recoveries are still out of this range, analyses must be terminated until the
problem is identified and corrected. All samples associated with the
noncompliant LCS must be reanalyzed. Data from LCSs will be checked to ensure
that they fall within the required recovery limits.
Accuracy goals for the metallic analytes and inorganic and indicator
parameters are presented in Table 5.
3.3 Precision
Precision measures the replicability and repeatability of results obtained
from analyzing environmental samples. Methods to be used for monitoring
sampling and analytical precision are discussed below.
3.3.1 Organics
Analytical precision will be monitored using results from duplicate and/or
replicate surrogate spikes and matrix spikes (MS) and matrix spike duplicates
(MSD) . Precision limits for each surrogate and matrix spike compound will be
determined over the course of the Program and average precision goals
established. Tabular data and control charts with a central control line and
the warning and control limits will be developed for each surrogate compound.
Table 6 presents overall Program analytical precision goals for the various
surrogate compound fractions expressed as relative percent difference (RPD) .
This is calculated as follows:
I Dl - D2 I
where :
RPD - Relative Percent Difference
D. - First Duplicate Value (percent recovery)
D. - Second Duplicate Value (percent recovery)
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 7 of 12
Table 5
ACCURACY GOALS FOR METALLIC, INORGANIC
AND INDICATOR ANALYSES
Analyte Accuracy (Z)
Metallic Analytes, all methods 90-110
Cyanide 90-110
Sulfate 80-120
pH 90-110
Total Organic Halide (TOX) 80-120
Purgeable Organic Halide (POX) 80-120
Total Organic Carbon (TOC) 80-120
Purgeable Organic Carbon (POC) 80-120
Chloride 90-110
Nitrate 90-110
Ammonia Nitrogen 90-110
Total Phenols " 80-120
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 8 of 12
Table 6
PROGRAM GOALS FOR PRECISION BY SURROGATE
COMPOUND FRACTION
Average RPD
Fraction Limit
Volatile Organic 15
Base/Neutral 50
Acid 40
Pesticide 30
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
9 of 12
Precision for MS/MSD compounds will also be monitored by calculating the RPD
between the MS and the MSB. In the event that the spike is nonrecoverable in
one. of the two samples, the calculation will not be performed.
Limits for RPD have been established under the CLP for each MS compound and
will be used as guidance to monitor laboratory performance. Table 7 presents
average RPD limits for MS analytes. The goals presented in Table 7 will be
modified, if necessary, based on sampling and analytical results realized
during Phase I of the Program.
Precision limits will be continually updated as data from the sites are
received. Control charts to monitor precision are discussed in greater detail
in Section 8.3 of this QA Project Plan.
3.2.2 Inorganics
Precision will be monitored in the same manner for inorganic analyses as for
organic analyses except that results from duplicate sample analyses will be
used to calculate precision (rather than % recovery from spiked samples) .
Control charts with a central control line and upper warning and control
limits based on average RPD and standard deviation, respectively, will be
developed for each analyte. These analyses will be used to monitor the
precision of the sample data in terms of repiicability and repeatability.
Precision goals for metallic, inorganic and indicator parameter analyses are
presented in Table 8. These goals may be modified for Phase II analyses based
on results of Phase I efforts.
3.4 Representativeness
The representativeness of ground-water samples will be ensured in two ways.
First, all sampling will be done in accordance with established EPA guidelines
and procedures as outlined in Reference 1 (Sections 5.4.5, 6.0 and 7,5).
These guidelines and procedures have been developed to promote consistency in
ground-water sampling efforts and to help ensure that proper sampling and
sample handling procedures are followed and proper equipment is used.
Additionally, each facility's monitoring network will be evaluated to determine
if it is adequate for immediate detection of leaks from the regulated unit(s).
Before sampling activities are undertaken the monitoring network will be
thoroughly evaluated to ensure that:
The owner /operator has adequately characterized the site hydrogeology.
The background and downgradient detection monitoring wells have been
properly placed in regard to number, location, spacing and depth.
Monitoring wells have been properly designed and constructed.
Monitoring systems that meet these requirements will provide ground-water data
that is representative of the aquifer being evaluated.
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 10 of 12
Table 7
PROGRAM PRECISION GOALS FOR MATRIX SPIKE/
MATRIX SPIKE DUPLICATE ANALYSES
Fraction
VOA(3)
VOA
VOA
VOA
VOA,,, .
B/N(b)
B/N
B/N
B/N
B/N
B/N
Acid
Acid
Acid
Acid
Acid
Pest/c;
Pest.
Pest.
Pest.
Pest.
Pest.
Analyte
1 , 1-Dichloroethene
Trichloroethene
Chlorobenzene
Toluene
Benzene
1 , 2 , 4-Trichlorobenzene
Acenaphthane
2 , 4-Dinitrotoluene
Pyrene
N«-Nitroso-di-n-propy'lamine *
1 , 4-Dichlorobenzene
Pentachlorophenol
Phenol
2-Chlorophenol
4-Chloro-3-methylphenol
4-Nitrophenol
Lindane
Heptachlor
Aldrin
Dieldrin
Endrin
4-4 'DDT
Average RPD
Limit (%)
14
14
13
13
11
28
31
38
31
38
28
50
42
40
42
50
15
20
22
18
21
27
(a) Volatile organic.
(b) Base/neutral.
(c) Pesticide.
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 11 of 12
Table 8
PROGRAM PRECISION GOALS FOR METALLIC, INORGANIC
AND INDICATOR ANALYSES
Average RPD
Analyte Limit (Z)
Metals, all methods 30
Cyanide 20
Sulfate 20
pH 10
Total Organic Halide (TOX) 20
Purgeable Organic Halide (POX) 20
Total Organic Carbon (TOC) 10
Purgeable Organic Carbon (POC) 10
Chloride 10
Nitrate 40
Ammonia Nitrogen 10
Total Phenols ' 20
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Section No. 3.0
Revision No. 2
Date: September 30, 1986
Page 12 of 12
3.5 Completeness
Completeness for the Program will be monitored by both qualitative and
quantitative means.
A qualitative assessment will be made by comparing the results of a facility
monitoring effort with Che objectives and procedures that are presented is the
specific Project Plan developed for each site. This assessment will determine
on a qualitative level what objectives are met or unmet.
Completeness of sample data packages and Laboratory QC reports will be
evaluated qualitatively using checklists.
Completeness will also be evaluated in terms of the total number of samples
taken (from sample traffic reports) and the number of acceptable analyses
performed (from laboratory QC reports). The number of acceptable analyses
completed divided by the number of samples taken times 100 is an index of
completeness. The completeness goal for this Program is 90%. Site assessment
planning is incorporating this figure to ensure completeness in meeting
Program objectives.
3.6 Comparability .
9
Data will be generated under this Program using established EPA analytical and
sampling methods. The organic and inorganic IFB protocols used in the
Superfund CLP provide detailed instructions for sample preparation and
analysis, laboratory QA/QC, reporting, chain-of-custody and document control.
These protocols will be used in this program to provide analytical data
comparable to CLP data. Site specific sampling will be planned and conducted
in accordance with Agency general guidance provided in References 1 (Sections
6.0 and 7.0) and 2-4.
Conformance with this guidance for development of precision and accuracy
quality indicators will ensure that data generated under this Program are
consistent and comparable with data generated under other Agency programs.
These quality indicators also ensure comparability of data with data generated
in the past or future using similar or different sampling or analysis methods
and appropriate quality indicators.
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Section No.
Revision No.
Date: September
Page 1 of
4.0
30,
1986
3
4.0
SAMPLING PROCEDURES
The environmental samples to be collected under this Program are ground-water
samples from existing wells. This section provides a description of the
procedures that will be followed to collect these samples for analysis. Other
environmental samples may be collected as part of the facility evaluation
process, but are not addressed by this QA Project Plan.
4.1 Selection of Sampling Sites
4.1.1 Facility Selection
The selection of sampling sites is dictated primarily by the universe of
regulated treatment, storage and disposal units (landfills, surface
impoundments, land treatment units and waste piles) subject to the ground-
water monitoring requirements of 40 CFR Parts 264 and 265 Subpart F. A second
criteria used in the selection process is that the facilities receive
commercial wastes. A total of 58 facilities have been identified that receive
commercial- wastes and are subject to Subpart F requirements. The Ground-Water
Monitoring Task Force plans to evaluate all 58 facilities.
Evaluations will be conducted at the facilities based on their relative
priority ranking. Relative priority rankings will be established based on the
following criteria:
Ongoing or near-term planned evaluations by the state, region or
NEIC.
Receipt of Superfund wastes by the facility.
Volume and variety of waste at the facility.
Location and number of sites in each Region.
Seasonal weather conditions.
Selecting facilities with ongoing or near-term evaluations will serve to
integrate Task Force activities with state, region or NEIC activities and
minimize duplication of effort.
The priority given to the RCRA facilities that receive wastes from Superfund
cleanup activities is based on the Agency's plans to determine whether these
facilities are protecting ground-water resources adequately. If not, it may
be necessary in the future to move these wastes again at significant added
cost.
The remaining criteria (number of applicable facilities per region, volume and
variety of wastes managed in the unit(s) and seasonal weather conditions) will
be used in conjunction with the first two criteria to select and schedule the
site evaluations.
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Section No.
Revision No.
Date: September
Page 2 of
4.0
30,
1986
3
4.1.2
Monitoring Well Selection
Sections 4.0 to 6.0 of Reference 1 provides detailed guidance that will be
followed in developing site-specific sampling plans and performing on-site
sampling activities. These sampling plans will detail the specific sampling
procedures to be followed at each site.
Prior to sampling at a site the ground-water monitoring system will be evalu-
ated using guidelines provided in Reference 2 to determine if it is adequate
for immediate detection of leaks from the regulated unit(s). This evaluation
will:
1. Determine whether the owner/operator has adequately characterized
the site hydrogeology.
2. Determine whether background and downgradient detection monitoring
wells have been properly placed with respect to number, location,
spacing and depth.
3. Determine whether monitoring wells have been properly designed and
constructed.
Reference 2 provides the specific guidance which will be used in evaluating
the monitoring well system. If the monitoring well system is found to be
inadequate (i.e., incapable of providing representative samples) sampling will
not be performed or will bd postponed until needed corrective actions are
identified by the Task Force and implemented by the facility owner/operator.
In the event sampling by the Task Force is required, a site-specific sampling
plan will be prepared as part of the site-specific project plan prior to the
beginning of any well sampling at the specific site.
4.2
Ground-Water Sampling Procedures and Equipment
Ground-water sampling procedures and equipment to be used in the study are
described in Section 6.0 (pp. 6-1 to 6-20) of Reference 1 and are incorporated
here by reference.
Section 6.0 provides detailed information on:
Preliminary sampling activities (Section 6.1, pp. 6-1 to 6-2)
Well purging procedures (Section 6.2, pp. 6-2 to 6-8)
- Purging equipment selection
- Purging procedures
- Disposal of purged water
- Procedures for slow-recharging wells
Parameter-specific sampling requirements (Section 6.3, pp. 6-8 to
6-15)
- Hazardous substance list (HSL)
- Special HSL sampling and handling procedures
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Section No. 4.0
Revision No. 2
Date: September 30, 1986
Page 3 of 3
Well sampling procedures (Section 6.4, pp. 6-15 to 6-20)
- Selection of sampling equipment
- Procedures for sample collection
- In-situ measurements
In addition, procedure and equipment sampling guidance provided in References
2 and 5 will be followed, when applicable.
4.3 Sample Handling
Procedures to be followed in this study for handling samples are described in
Section 7.5 (pp. 7-7 to 7-17) of Reference 1 and are incorporated here by
reference. These include:
Use of containers available from the Sample Bottle Repository
Program
Container cleaning procedures
Sample preservation procedures
Chain-of-custody procedures '
Labeling and packaging procedures
Sample transportation procedures
Sample shipment scheduling procedures
In addition, sample handling guidance provided in References 6 and 7 will be
followed, where applicable.
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Section No. 5.0
Revision No. 2
Date: September 30, 1986
Page 1 of 2
5.0 SAMPLE CUSTODY
5.1 Introduction
Sample custody refers to tracking possession of a sample from the time it is
collected in the field through analysis and final disposition. A record of
sample custody (chain-of--custody) identifies in whose possession the sample
was at all times, thereby fixing accountability on traceability of the sample.
A chain-of-custody record ensures sample integrity. This minimizes the
possibility of someone tampering with samples and is necessary for legal
purposes. The chain-of-custody record for the ground-water samples collected
under this Program will provide the following information:
Sample identification number
Sample collector's signature
Date and time of collection
Place and address of collection
Waste sample descriptions
Shipper's name and address
Receiver's name and address
Signatures of persons involved in chain-of-possession
Inclusive dates of possession
The chain-of-custody record documenting this information includes, but is not
limited to:
Sample labels and tags
Sample seals
Field date sheets
Chain-of-custody forms
Bound field log books
Sample analysis request sheets
Analyst's logbook pages
Custody records
Sample tracking records
Bench sheets
Measurement readout records
Extraction and analysis chronicles
Computer printouts
Raw data summaries
Instrument logbook pages
Correspondence
Document inventory
Specific chain-of-custody. procedures to be followed during field and
laboratory operations are referenced in the following sections.
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Section No. 5.0
Revision No. 2
Date: September 30, 1986
Pa8e 2 of 2
5.2 Project Chain-of-Custody and Document Control Procedures
5.2.1 Field Sampling Operations
Specific chain-of-custody and document control procedures for field sampling
are presented in Section 4.4 (pp. 4-5 to 4-7) of Reference 1. Section 7.5
(pp. 7-9 to 7-13) of this reference describes the procedures by which the
chain-of-custody record will accompany sample shipments. The procedures and
forms described in the referenced sections will be used for all field sampling
operations.
5.2.2 Laboratory Operations
Laboratories are required to have in place a system for documenting:
Calibration procedures
Analytical procedures
Computational procedures
Quality control procedures
Bench data
Operating procedures, or any changes to these procedures
Laboratory notebook policy
Procedures for making revisions to technical procedure or documents must be
clearly defined, with the lines of authority indicated. Procedural revisions
are to be written and distributed to all affected individuals, thus ensuring
implementation of changes.
Laboratory chain-of-custody procedures must provide:
Identification of the responsible party (sample custodian) authorized
to: sign for incoming field samples; obtain documents of shipment
(e.g., bill of lading number or mail receipt); and verify the data
entered onto the sample custody records.
A laboratory sample custody log consisting of serially numbered
standard lab-tracking report sheets.
Specification of laboratory sample custody procedures for sample
handling* storage and dispersement for analysis.
All EPA contractor laboratories are required to have written SOPs which comply
with the specifications for chain-of-custody and document control procedures
described in Exhibit F (pp. 1-8) of the organics IFB (Attachment 1) and
Exhibit G (pp. 1-10) of the inorganic IFB protocol (Attachment 3).
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Section No. 6.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
6.0 CALIBRATION PROCEDURES AND FREQUENCY
6.1 Sampling Equipment
Routine sampling equipment calibration procedures and frequency are described
in Section 7.3 (pp. 7-4 to 7-5) of Reference 1.
6.2 Analytical Instruments/Equipment
Analysis of volatile and semivolatile organics will be by GC/MS, and analysis
of pesticides will be by GC with an electron capture detector (GC/ECD).
Detailed initial and continuing calibration procedures and calibration
frequencies for these Instruments are presented in Attachment 1, Exhibit E,
Section III, Parts 1 (pp. E-8 to E-21) and 2 (pp. E-22 to E-27).
Analysis of metals will be by AA or ICP, and analysis of cyanide will be by
titrimetric or spectrophometric means. Detailed calibration procedures and
calibration schedules for these instruments are presented in Attachment 3,
Exhibit E, Sections 1 (pp. E-3 to E-4) and 2 (pp. E-4 to E-6).
Parameters used as indicators of ground-water contamination (pH, specific
conductance, total organic carbon (TOC) purgeable organic carbon (POC);
purgeable organic halides /POX) and total organic halide (TOX)) and parameters
establishing ground-water quality (chloride, total phenols, nitrate, ammonia
nitrogen and sulfate) will be measured using the analytical procedures
described in Reference 6. For each procedure, Reference 6 also specifies an
instrument calibration procedure and a calibration frequency, and these will
be followed.
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Section No. 7.0
Revision No. 2
Date: September 30, 1986
Page 1 of 2
7.0
ANALYTICAL PROCEDURES
The sample preparation, storage, screening and analytical procedures which
will be used for volatile organics (purgeables), semivolatile organics
(extractable base/neutral and acid compounds) and pesticides are detailed in
Attachment 1, Exhibit D. Volatile and semivolatile organics will be analyzed
by GC/MS and analysis of pesticides will be by GC/ECD.
The analytical procedures which will be used for metals are detailed in
Attachment 3, Exhibit D. Metals will be measured by furnace AA spectro-
photometry, flame AA, ICP atomic emission spectrophotometry, ion
chromatography or cold vapor. Cyanide analysis will be by titrimetric, manual
or semi-automated spectrophotometric techniques.
The analytical procedures which will be followed for indicator parameters
(e.g., pH, specific conductance, TOC POC, POX and TOX) and ground-water
quality parameters (chlorides, total phenols, nitrate, ammonia nitrogen and
sulfate) include the following:
Methods currently presented in EPA SW-846 (Reference 6)
Methods proposed for inclusion in EPA SW-846 (e.g., Superfund-CLP
methods)
Methods required by NEIC
The specific methods to be used are presented in.Table 10.
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Section No. 7.0
Revision No. 2
Date: September 30, 1986
Page 2 of 2
Table 9
ANALYTICAL METHODS TO BE USED FOR INDICATOR
(INORGANIC) PARAMETER ANALYSES
Parameter EPA Method Number
Cyanide 9010
Sulfate 9036 (colorimetric)
9038 (turbidimetric)
pH (a)
Total Organic Halides (TOX) 9020
Purgeable Organic Halides (POX) (b)
Total Organic Carbon (TOG) 9060
Purgeable Organic Carbon (POC) (c)
Chloride 9252
Nitrate 9200
Ammonia Nitrogen 350.3
Total Phenols 9066
(a) Section 6.4.3, Reference 1.
(b) Method for Purgeable Organic Halides (POX) pp. 65-82,
EPA 600/4-84-008, Appendix A.
(c) Barcelona, M. 1984. TOC Determination in Ground
Water. - Groundwater, 22:18-23.
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Section No. 8.0
Revision No. 2
Date: September 30, 1986
Page 1 of 2
8.0 DATA REDUCTION, VALIDATION AND REPORTING
8.1 Introduction
This section describes the procedures that will be followed in:
Data reduction and interpretation
Quality control of data (date validation)
Data reporting
Procedures are indicated by major measurement parameter for sampling, analysis
and overall program evaluations.
Overall data flow for sampling and analysis is shown in Figure 2 of this QA
Project Plan and Figure 4.1 of Reference 1 (pp. 4-8). Data evaluation report-
ing is described in Section 8.4 below.
8.2 Data Reduction and Interpretation
8.2.1 Pesticides/PCBs by GC/ECD
The results of GC/ECD analyses for organics will be recorded and the data
reduced and interpreted using the procedures detailed in Attachment 1.
Exhibit D, Part IV, Section 3 (pp. D-110 to D-134).
8.2.2 Organics by GC/MS
The results of GC/MS analyses of organic compounds will be recorded and the
data reduced and interpreted using the procedures detailed in Attachment 1,
Exhibit D, Part IV, Section 1 (pp. D-64 to D-95) (purgeables) and Section 2
(pp. D-96 to D-109) (extractables).
8.2.3 Inorganics by Atomic Absorption
The results of analyses for inorganics (metals) by AA spectrometry will be
recorded and the data reduced and interpreted using the procedures detailed in
Attachment 3, Exhibit D, Section 3, Attachment 2 (furnace methods) and
Attachment 4 (flame methods).
8.2.4 Inorganics by Atomic Emission
The results of analyses for inorganics (metals by inductively coupled
plasma-atomic emission spectrometry) will be recorded and the data reduced and
interpreted using the procedures detailed in Attachment 3, Exhibit D,
Section 3, Attachment 3.
8.2.5 Cyanide
The results of analyses for cyanide in water will be recorded and the data
reduced and interpreted using the procedures detailed in Attachment 3, Exhibit
D, Section 3, Attachments 7 and 8.
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Section No. 8.0
Revision No. 2
Dace: September 30, 1986
Pa8e 2 of 2
8.2.6
Indicator Parameters
The results of analyses for the various indicator parameters will be recorded
and the data reduced and interpreted using the procedures detailed in
Reference 4.
8.3
Quality Contro'l of Data
Procedures described in this section will be followed to ensure data
integrity. Checklists and spot calculations will be used for qualitative and
quantitative evaluation, respectively, of information in all sample data
packages according to established EMSL-LV data audit protocols. Evaluation
will focus on conformance with protocols and SOPs (Attachments 1-3) and DQO
(Section 3.0) established for the program. An additional data audit will be
performed using performance evaluation samples and results of internal quality
control checks for overall program and laboratory QC over the life of the
program. This evaluation will use control charts to evaluate ongoing program
and laboratory precision and accuracy using procedures described in Section
12.0.
Precision and accuracy control charts will be developed and evaluated within
limits of data availability for:
within batch performance
between batch performance
within case performance
between case performance
overall laboratory performance
overall program performance
Program and laboratory performance relative to individual measurement
parameters will not be evaluated.
8.4
Data Reporting
Deliverables and data reporting procedures for sampling and analytical results
are specified in Exhibit B of Attachments 1 (organics) and 3 (inorganics) and
Reference 6 (indicator parameters).
Results of the data evaluation will be reported by case with summaries for
cumulative program performance. Data evaluation summary reports will be
provided to the Data Review Group of the EPA Hazardous Waste Ground-Water Task
Force Core Team.
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Section No. 9.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
9.0 INTERNAL QUALITY CONTROL CHECKS
Internal quality control focuses on monitoring performance of both analytical
laboratory and field sampling activities. This section describes the internal
(analytical and sampling) quality control checks that will be instituted for
this program.
9.1 Analytical Quality Control Checks
The analytical QC checks that will be used in performing trace organic
analyses are specified in Exhibit E of Attachment 1. These include:
1. Reference material analysis. This includes analysis of PE standards
and surrogate standards.
2. Reagent blank analysis.
3. Matrix spike analysis.
4. Matrix spike duplicate analysis.
Laboratory sample preparation procedures and reporting requirements for these
internal quality control checks are described in Exhibit D and B of Attach-
ment 1, respectively.
Reference materials analyses are used to check th?e accuracy of the analytical
procedures. Reagent blank analyses are used to establish analyte levels in
reagents, spike and blank sample analysis to establish analytical accuracy and
duplicate analysis to establish analytical precision. Organic matrix spike
and duplicate analyses will be performed at a frequency as specified in the
Scope of Work, Invitation for Bid (IFB) (Attachment 1).
Analytical QC checks that will be used for inorganic analyses are described in
Exhibit E of Attachment 3. Surrogate analysis will not be performed for
inorganic analyses, although similar QC check analyses will be performed using
analyte spikes. Laboratory quality control sample analyses will be performed
for inorganic constituents. Matrix spike and spike duplicate analyses will be
performed as specified in Attachment 3.
Analytical QC checks that will be used for indicator parameters are described
in Reference 6. Spike and spike duplicate analyses will performed as
specified in Attachment 2.
9.2 Sampling Quality Control Checks
The following quality control checks will be used for sampling operations:
1. Trip blanks
2. Field blanks
3. Equipment blanks
4. Field duplicates
Sampling blanks and duplicates and the procedures and schedule to be followed
in providing these checks are described in Section 7.2 (pp. 7-2 to 7-4) of
Reference 1.
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Section No. 10.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
10.0 PERFORMANCE AND SYSTEM AUDITS
10.1 System Audits
The system audit is a systematic check of a qualitative nature consisting of
an on-site review of a laboratory's quality assurance system and physical
facilities for sampling., calibration and measurement. System audits for this
program will be performed by EMSL-LV on a quarterly basis. Procedures to be
followed in performing the system audits are described in Exhibit E of
Attachments 1 (Section V) and 3 (Parts II and III).
10.2 Performance Audits
Performance audits provide a systematic check of laboratory operations and
measurement systems by comparing independently obtained data with routinely
obtained data. Procedures to be followed in performance audits of this
program are presented in Exhibit E of Attachments 1 (Section V) and 3 (Parts
II and III). Performance audit activities (sample preparation and scoring)
will be performed by EMSL-Cin initially on every site.
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Section No. 11.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
11.0 PREVENTATIVE MAINTENANCE PROCEDURES AND SCHEDULES
11.1 Sampling Equipment
Routine maintenance procedures and schedules for sampling equipment are
described in Section 7.3 (pp. 7-4 to 7-5) of Reference 1. All records of
inspection and maintenance vill be dated and documented in field logs.
11.2 Analytical Instrumentation and Equipment
Maintenance procedures and schedules for all analytical instruments and
equipment will be in strict accordance with the recommendations of the equip-
ment manufacturers. Routine operations (e.g., septum replacement, oil change,
lubrication, cleaning, etc.) will be performed by laboratory personnel as
needed. Specialized inspection and maintenance of major equipment items will
be performed by trained service personnel from the manufacturer in accordance
with instrument service contracts. All records of inspection and maintenance
will be dated and documented in laboratory record books.
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Page 1 of 7
12.0 SPECIFIC ROUTINE PROCEDURES TO ASSESS DATA PRECISION, ACCURACY AND
COMPLETENESS
12.1 Statistical Procedures for Assessing Precision, Accuracy and
Completeness of Measurement Data
12.1.1 Precision
Precision is a measure of the mutual agreement among individual measurements
of the same parameter under prescribed, similar conditions. Repeatability is
the variability (batch-to-batch) among measurements at different times of the
same measurement parameter at a laboratory. Replicability is the variability
(within batch) among repeated independent determinations of the same measure-
ment parameter by a laboratory at the same time under identical conditions.
Reproducibility is precision measuring the variability among results of
measurements of the same sample at different laboratories and for different
cases. A case for purposes of this Program consists of all samples collected
at one facility at one time.
The following statistical procedures will be used to calculate precision
attributes for this program:
Repeatability
a
x, - analyte/surrogate concentration for repeatability sample
x average concentration of analyte/surrogate
N * number of samples averaged
s- - standard deviation of the average
X
N
x * I x.
i - 1 1
N
2 N - 2
s - I (x. - x)
x 1 - 1 1
N-l
(3 V'2
s- - x
Nl/2
Replicability
data pair
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Section No.
Revision No.
Date: September 30, 1986
Page 2 of 7
x. - average of replicate pair
x - grand average of all replicate pair averages
s - standard deviation of grand average
X
k - number of replicate pair sets
- x
N
R - I R.
i - 1 i
N
X. * X . + X ,
k
x E x.
i - 1
k
2 k - - 2
£. f . £
s- » I (x. - x)
* i - I
k - 1
i
Sx " (sx
Reproducibility
x average value for case
s * standard deviation for the case average
x - grand average of case values
s- - standard deviation for the grand average
A
R « number of cases
_ N
x E x.
i - 1 X
N
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Pa8e 3 of 7
R
x I x
1 - 1
R
2 N - -2
8 - E (X. - X)
i - 1
N - 1
Sx
, 2 ,1/2
Sx" (S x}
12.1.2 Accuracy
Accuracy is the degree of agreement between the true value of the parameter
being measured (or accepted standard value) and the average of observations
made according to the test method, preferably by many determinations. To
estimate accuracy, reference values (e.g., performance evaluation samples) are
required. The following statistical procedures will be used for accuracy
determinations:
A. - percent of accuracy
0 observed concentration
T, - true concentration
N « number of check samples measured
A * average accuracy
Ai " =i x 100
i
N
A - Z A
i - 1 1
N
2 N -2
A - S
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Page 4 of 7
Recovery is an attribute related to accuracy which applies to analysis of
performance using spiked or performance evaluation samples. Statistical
procedures for analysis of recovery are as follows:
R, « analyte recovery (percent)
0 » observed values
B. background value
T, » true value
N " number of samples
A average recovery
Sp * standard deviation of the recoveries
(° ~
100
N - 2
R - Z (R T R)
i - 1
N - 1
2 N - 2
S/ = 2 (R. - Rr
i ' 1
N - 1
12.1.3 Completeness
Completeness will be evaluated by comparing the number of samples acquired for
analysis to the number of samples analyzed.
_ , . Number of Samples Analyzed . -_
Completeness, % r; r - T = *-: - T - ; T x 100
^ Number of Samples Acquired
A similar analysis will be performed on types of analyses requested for each
set of samples. Completeness of sample data packages will be qualitatively
evaluated using appropriate elements of the EMSL-LV performance evaluation
sample score forms.
12.2 Control Charts
Program and laboratory performance with respect to precision and accuracy of
analytical results will be evaluated using control charts. Procedures for
constructing control charts and evaluating performance outlined in Section 6.2
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Page 5 of 7
of Reference 8 will be employed. Means and standard deviations will be
calculated using the procedures outlined in Section 12.1 above for central
lines and control limits, respectively.
Lower warning and control limits will be established at two and three standard
deviations below the mean, respectively (accuracy). Warning and control
levels for upper control lines will be established at points above the mean
two and three times the standard deviation, respectively (precision and
accuracy).
12.3 Methods Used to Gather Data for Precision and Accuracy Calculations
Table 11 presents the relationship between the samples available for analysis
and their applicability for precision and accuracy calculations by data audit
category. This table is based on information provided in Attachments 1-3 and
Reference 6 on anticipated sample availability under the program. Anticipated
sample availability (frequency) is indicated in Table 12.
Data for evaluating completeness will be the information in the sample data
packages generated by the contract laboratories.
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Pa8e 6 of 7
Table 10
DATA SOURCES FOR PRECISION AND ACCURACY CALCULATIONS
Data Audit
Category
Replicability
Repeatability
Reproducibility
Accuracy
Recovery .
Surrogate , .
Spike MS/MSDU;
* *
* *
*
* *
* *
Field CM
Duplicate PEV '
*
* *
*
*
*
(a) Matrix spike/matrix spike duplicate".
(b) Performance evaluation samples.
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Section No. 12.0
Revision No. 2
Date: September 30, 1986
Page 7 of 7
Table 11
QUALITY ASSURANCE SAMPLE FREQUENCY
Sample Type
Sample Frequency
(a)
One Set Per Case
One Per Batch
All
Samples
Performance
Evaluation (PE)
Volatile Organic
Duplicate
Field Duplicate
(other than
volatile organics)
Matrix Spike/
Matrix Spike
Duplicate
Surrogate
Spike (organic samples
only)
(a) See text for source of information.
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Section No. 13.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
13.0
13.1
CORRECTIVE ACTIONS
Data Acceptability Limits that Trigger Corrective Actions
Initially, limits established as DQO for this program will be used to trigger
corrective actions regarding data acceptability. These limits will be
replaced with new limits based on actual performance as data accumulate under
the program to levels where statistical procedures can be used to calculate
warning and control limits. Once sufficient data are available appropriate
control charts will be constructed and procedures for assessing data
acceptability outlined in Section 6.2 of reference 8 will be followed.
It is assumed that contract laboratories have established and will use their
own limits for triggering internal laboratory corrective actions for the
types of analyses to be performed.
13.2
Corrective Actions to be Taken
Corrective actions under this program will be taken as a result of the
following QA activities:
Internal laboratory QA activities
EMSL-LV performance and system audits
Contractor data evaluations of case and laboratory performance
Corrective actions to be taken as a result of internal laboratory QA
activities are described in Exhibit E of Attachments 1 and 3, corrective
actions to be taken as a result of EMSL-LV audits and contractor data
evaluations will be initiated by the Task Force Data Review Group in
cooperation with EMSL-LV.
A corrective action program will be defined based on needs arising during
planned Phase 1 activities. Corrective actions to be taken under this program
will include requests for resampling, reanalysis, submission of missing data
or correction of other deficiencies.
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Section No. 14.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT LABORATORY
14.1 Laboratory Reporting Frequency and Format
Laboratory reporting frequency and format requirements are contained in
Section B of Attachments 1 and 3. Distribution of laboratory reports is
explained in Section B of Attachments 1 and 3, supplemental distribution is
indicated in Attachment 2.
14.2 Audit Results
Results of performance and system audits are reported on an annual basis by
the EMSL-LV (Quality Assurance Division Director) to the Office of Emergency
and Remedial Response. A report of QC data evaluation results for this
program will be submitted by the Contractor (ICAIR, Life Systems, Inc.) on a
case-by-case basis to the Task Force Core Team after concurrence with the Task
Force Review Committee. The contractor will also submit quarterly summaries
and a final summary of data evaluation results for all cases evaluated under
the program.
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Section No. 15.0
Revision No. 2
Date: September 30, 1986
Page 1 of 1
REFERENCES
1. Revised Draft Protocol for Ground Water Inspections of Hazardous Waste
Treatment, Storage and Disposal Facilities. PRC Environmental
Management, Inc./Versar, Inc.September, 1985.
2. Draft Ground Water Technical Enforcement Document. Office of Solid Waste
and Emergency Response, U.S. Environmental Protection Agency, March,
1985.
3. Groundwater Monitoring Guidance Manual for Owners and Operators of
Interim Status Facilities. EPA SW-963, Revised March, 1983.
4. Procedures Manual for Ground Water Monitoring at Solid Waste Disposal
Facilities. EPA SW-611, December, 1980.
5. RCRA Draft Permit Writer's Manual; Ground Water Protection. U.S.
Environmental Protection Agency, August, 1983.
6. Test Methods for Evaluating Solid Waste - Physical/Chemical Methods. 2nd
Edition, EPA SW-846, July, 1982.
7. Methods for Chemical Analysis of Water and Wastes. EPA 600/4-79-20,
Revised March , 1983.
8. Handbook for Analytical Quality Control in Water and Wastewater
Laboratories. EPA 600/4-79-019, March, 1979.
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ATTACHMENT 1
STATEMENT OF WORK
INVITATION FOR BID (IFB) FOR
ORGANICS ANALYSIS
(Not Included)
-------
ATTACHMENT 2
MEMORANDUM FROM LINDA HAAS BOYNTON,
GROUP LEADER, ANALYTICAL SERVICES
GROUP, TO SAS LABORATORIES DATED
APRIL 18, 1985 (AMENDED)
(Not Included)
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ATTACHMENT 3
INVITATION FOR BID (IFB) FOR
INORGANIC ANALYSES
(Not Included)
-------
U.S. Environment^ Protection Agency.
Region V, libr*ry
230 South Dearborn Street
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