United States
                Environmental Protection
                Office of
                Solid Waste
                Washington DC 20460
October 1986
                                                   PB87-107769
                Solid W*4
f/EPA
RCRA

Facility  Assessment

Guidance
                     REPRODUCED BY
                         U S DEPARTMENT OF COMMERCE
                             NATIONAL TECHNICAL
                            INFORMATION SERVICE
                            SPRINGFIELD VA 22161

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 RCRA FACHHV  \ M SSMrNT GHHIANCF
Permits and S t a t e Programs Division
       Office of Solid Waste
U.S, Environmental Protection Agency

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     I ho document w,v,  p r o p ,1 r ml  by the joint efforts  of  the  follo
i n,i i vitlu.il s ; Clem R a <, t a t ? n r  { ( u r rpn 1.1 y at EPA-OERR),  Have Fagan
,1-1,1 Pi.irsi Foss, OSW  -  PsMonfs  ,1 rul Strttp Programs  Division;  Mark
u11hprtson  and Howard  W-lsnn.  Office of Waste  Programs  Enforce-
ment, Tina  Kaneen,  Offim  of  Ueneral Counsel;  Retsy  Marcotte and
1 nm t.hprlpfn,  Sohotka  X  Company  Inr.

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                           TABLE  OF   CONTENTS

                                                                      Page
CHAPTER  ONE  -    INTRODUCTION

   I.   OBJECTIVES   AND  SCOPE   OF   THE   RCRA  CORRECTIVE
       ACTION   PROGRAM                                                1-1

  II.   PURPOSE  OF THE  RFA                                           1-2

 III.   SCOPE  OF  THE  RFA                                             1-3

  IV.   TECHNICAL   APPROACH                                           1-5

   V.   ORGANIZATION   OF  THIS   DOCUMENT                              1-9

CHAPTER  TWO  -   CONDUCTING  A  PRELIMINARY   REVIEW

        INTRODUCTION                                                  2-1

       A.    Purpose                                                   2-1
       B.    Scope                                                     2-1
       C.    Product                                                   2-2

  II.   GATHERING   PR   INFORMATION                                    2-2

       A.    Written   Information   and   Documents                     2-3
       B.    Meeting   with   Relevant  Individuals                     2-5
       C.    Collecting   Additional   Information                     2-6

 III.   EVALUATING  PR   INFORMATION                                   2-6

       A.     Investigating   Facility  Waste   Generation
            Processes                                                2-6
       B.    Identifying   SWMUs  and  Other   Potential
            Releases   of  Concern                                     2-7
       C.    Evaluating  the   Facility's  Release  Potential          2-8

   IV.   COMPLETING  THE   PRELIMINARY   REVIEW                         2-11

       A.     Identifying  Significant  Data  Gaps                     2-12
        B.    Focusing  the  Visual   Site   Inspection  and
            Samp ling  Visit                                          2-12
        C.    Documenting  the   Preliminary   Review                    2-13

 CHAPTER  THREE  -  CONDUCTING  A   VISUAL  SITE  INSPECTION

        INTRODUCTION                                                 3-1

        A.    Purpose                                                   3-1
        B.    Scope                                                    3-1
        C.    Product                                                    3-1

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                                                                    Page

 II.    PLANNING   THE   VISUAL  SITE   INSPECTION                      3-2

III.    CONDUCTING  THE  FIELD  ACTIVITES  DURING  THE  VSI           3-2

       A.   Obtaining   Visual  Evidence  of  Unit
           Characteristics                                         3-4
       B.   Obtaining   Visual  Evidence  of  Waste
           Characteristics                                         3-4
       C.   Obtaining  Visual  Evidence   of  pollutant
           Migration   Pathways                                     3-4
       D.   Obtaining  Visual  Evidence   of  Release                3-5
       E.   Obtaining  Visual  Evidence   of  Exposure
           Potential                                                3-5

 IV.    IV.  DETERMINING  THE  NEED  FOR  FURTHER  ACTION
       DURING  THE  RFA                                              3-5

       A.   Determining  the  Need  for  a  Sampling   Visit           3-6
       B.   Determining  the  Need  for   Interim   Measures           3-7
       C.   determining  the  Need  for  a  Remedial
            Investigation                                           3-7

CHAPTER  FOUR  -  CONDUCTING  THE  SAMPLING  VISIT

   I.    INTRODUCTION                                                 4-1

       A.   Purpose                                                 4-1
       B.   Scope                                                   4-1
       C.   Product                                                 4-2

  II.    DEVELOPING  A   SAMPLING   VISIT  PLAN                         4-2

       A.   Determining  the Need  for   Sampling  at  Facilities    4-2
       B.   Developing  a   Sampling   Plan                            4-4

 Ml.    PREPARING  FOR  THE  SAMPLING   VISIT                         4-8

       A.   Gaining   Facility  Access                               4-9
       B.   Community  Relations                                   4-10
       C.   Preparing  a   Safety   Plan                               4-1o
       D.   EPA   Oversight  of   Owner/Operator   Sampling
           Act i v i t i es                                              4-11

  IV.    CONDUCTING  THE  SAMPLING  VISIT                            4-11

       A.   Preliminary   Site   Activities                          4-11
       B.   Samp I ing   Procedures                                   4-12
       C.   Photography                                             4-12
       D.   Logbook                                                 4-13
       E.   Sample   Shipment/Sample   Analysis                      4-14
       F.   Decontamination/Demobilization                       4-14

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                                                                    Page

  V.    FINAL  RFA  RECOMMENDATIONS  FOR  FURTHER  ACTION            4~14

       A.    Making   RFA  Release  Determinations                    4-14
       B.    Making  Recommendations  for  Each  SWMU  or
            Group  of  SWMUs                                         4-15

 VI.    FINAL  RFA  PRODUCT                                          4-18

CHAPTER  FIVE   -   GROUND   WATER

   I.    INTRODUCTION                                                5-1

       A.    Purpose                                                 5-1
       B.    Scope                                                   5-1

  II.    CONDUCTING  A  PRELIMINARY  REVIEW  AND  VISUAL  SITE
       INSPECTION   OF   GROUND-WATER  RELEASE   POTENTIAL            5-2

       A.    Unit   Characteristics                                  5-2
       B.    Waste  Characteristics                                 5-7
       C.    Pol Iutant  Migration   Pathways                         5-9
       D.    Evidence   of  Release                                   5-9
       E.    Exposure  Potential                                     5-1o
       F.    Determining   the   Need  for  Additional
            Sampling   Information                                  5-11

 III.   COLLECTING  ADDITIONAL   SAMPLING   INFORMATION
        IN  THE SV                                                    5-14

       A.    Sampling  of   Existing   Ground-Water
            Mon itori ng  We I Is                                        5-14
       B.   Soi I   Sampl ing                                           5-17
       C.   Soil   Gas   Monitoring                                    5-17
       D.   Electromagnetic   Conductivity  Mapping                 5-19
       E.   Sampling  of  Domestic  Wells                            5-20
       F.   Installation  Of  New  Monitoring   Wells                 5-20

  IV.   MAKING  GROUND-WATER   RELEASE  DETERMINATIONS               5-21

 CHAPTER   SIX   -   SURFACE  WATER

   I.    INTRODUCTION                                                 6-1

       A.   Purpose                                                  6-1
        B.   Scope                                                    6-1

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                                                                   Page

 II.   CONDUCTING  A  PRELIMINARY  REVIEW  AND  VISUAL  SITE
       INSPECTION  OF   RELEASES  TO  SURFACE  WATER                  6-2

      A.   Unit   Characteristics                                   6-2
      B.   Waste   Characteristics                                  6-5
      C.   Pollutant   Migration  Pathways                          6-6
      D.   Evidence  of  Release                                    6-8
      E.   Exposure  Potential                                      6-9
      F.   Determining  the  Need  for  Additional   Sampling        6-10

III.   COLLECTING   ADDITIONAL  SAMPLING   INFORMATION  IN  THE  SV   6-12

      A.   Surface  Water   Sampling                                 6-13
      B.   Sludge  and  Sediment  Sampling                          6-14
      C.   Soi I   Sampl ing                                           6-14
      D.   Run-Off  Sampling                                       6-14

  IV.   MAKING  SURFACE  WATER   RELEASE   DETERMINATIONS             6-15

CHAPTER   SEVEN   -  AIR

   I.     INTRODUCTION                                                 7-1

      A.   Purpose                                                  7-1

  II.    CONDUCTING   A   PRELIMINARY   REVIEW   AND  VISUAL
       SITE  INSPECTION  OF  AIR  RELEASE   POTENTIAL                7-2

       A.   Unit  Characteristics                                   7-2
       B.   Waste   Characteristics                                  7-6
       C.   Pollutant   Migration  Pathway                           7-13
       D.   Evidence  of  Release                                    7-13
       E.   Exposure   Potential                                     7-14
       F.   Determining  the   Need   for   Additional
           Sampling    Information                                   7-15

       OBTAINING   ADDITIONAL  SAMPLING   INFORMATION               7-16

       MAKING   RELEASE  DETERMINATIONS                             7-18

CHAPTER   EIGHT -  SUBSURFACE  GAS

   I.    INTRODUCTION                                                8-1

       A.  Purpose                                                 8-1
        R.  Scope                                                   8-1

  II.    CONDUCTING  A   PRELIMINARY  REVIEW  AND  VISUAL  SITE
        INSPECTION  OF   SUBSURFACE   GAS   RELEASE  POTENTIAL         8-2

        A.  Unit  Characteristics                                   8-2
        B.  Waste  Characteristics                                 8-5
        C.   Pollutant   Migration   Pathways                         8-9

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                                                                    Page

       D.   Evidence  of  Release                                    8-10
       E.   Exposure   Potential                                     8-10
       F.   Determining   the   Need   for   Additional
           Sampling  in  the   SV                                     8-11

III.   COLLECTING   ADDITIONAL   INFORMATION  IN  THE  SV              8-12

  IV.    MAKING  SUBSURFACE  GAS  RELEASE  DETERMINATIONS            8-14

CHAPTER  NINE  -   SOILS

   I.    INTRODUCTION                                                9-I

       A.   Purpose                                                 9-1
       B.   Scope                                                    9-1

  II.    CONDUCTING   A  PRELIMINARY  REVIEW  AND  VISUAL
       SITE  INSPECTION  OF  RELEASES   TO  SOILS                     9-2

       A.   Unit   Characteristics                                  9-2
       B.   Waste   Characteristics                                 9-5
       C.   Pollutant  Migration   Pathways                         9-6
       D.   Evidence  of  a  Release                                 9-7
       E.   Exposure  Potential                                     9-7
       F.   Determining  the   Need  for  Additional  Sampling       9-8

 III.   COLLECTING   ADDITIONAL  SAMPLING   INFORMATION
        IN  THE  SV                                                   9-10

       A.   General   Information   on   Selecting   Sampling
            Locat i ons                                               9-10
       B.    Sampling  Methodology  and   Evaluation  of   Results     9-11

  IV.   MAKING  A   RELEASE   DETERMINATION                           9-12


APPENDIX  A  -  SAMPLE  RFA  REPORT  OUTLINE

APPENDIX  B  -  RFA   INFORMATION   SOURCES

APPENDIX  C  -  SAMPLE  LETTER   OF   REQUEST  FOR  OWNER/OPERATOR
                INFORMATION

APPENDIX  D  -  GAINING   FACILITY   ACCESS   WHEN   DENIED

APPENDIX  E  -  PHYSICAL  AND   CHEMICAL   PARAMETERS   FOR
                CONSTITUENTS   OF  CONCERN

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                      LIST OF E X H ! R I! S
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3{;t. ors tn Consider in Conduct inq RCAs
f ]nfor-m^t on Fvaluated On ring thp
t-pp* of 1 hp RFA
nf i'fHf !"'-)tantial for fi round Water
s rH>'< >-* o ' tMtiisrns of Release
Page
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         Monitoring  W^n  i'v*t. ion                          ^-^^

         r, h ? c k 1 i s t  f n r-  ^ r f \ . i n ft  W a t P r  R e 1 e a s e s               v-22

         Ranking  nf  '-)n*t  Pniential  for  Surface Water
         Release  and  M p f. h a n < s m s  of  Release                 6-4

         Checklist  for  Surface. Water Release            .   6-17

         Unit  Potential for  Air  Releases  and
         Mechani $m$  o fRelpase                            7-4

         Parameters  and Measures for Use  in Evaluating
         Potential  Air  Releases  of  Hazardous  Waste
         Constituents                                     7-7

         Hazardous  Constituents  of  Concern as Vapor
         Rel eases                .                         7-8

         Hazardous  Constituents of  Concern as
         Paniculate Releases                             7-10

7-6      Checklist  for Air Releases                       7-20

R-l      Unit  Potential  for Subsurface Gas Releases
         and  Mechanisms  of 'Release                        8-4

3-2      Subsurface Ras  Generation /Migration  in.  a
         Landfill                    *                    8-6

R-3      Subsurface Gas  Generation /Migration  from
         i!n1 1. s C1 osed  as l.andf 1 1 1 s                        8-7  .

fl-4      Checklist  for Subsurface Gas RP leases            8-15

a-]      Ranking of Unit Potential  for Soil  Release
         ar, d Mechanisms  ('f Release                        ^-3

q - ?      (''. h o r H i s t  forRe10^sestoSoils                  9-14

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                           CHAPTER  ONF

                           INTRO out now


     OBJECTIVES  AND  SCOPF  OF  THE  RCRA  CORRECTIVF  ACTION PROGRAM

     The  primary  objective nf  the RCRA  corrective  action program
   t f   clean  up  release  <* ?  h,-?ardous  waste or hazardous const it -
   \e  that  threaten  human  hp^lr.h  or  the environment.  The prog rani
   ' i  s  to  all  o p e r a t i n u  t '  s *> d  or  closing RCRA  facilities.

     the  1984  Hazardous  r>n-i c,niid Waste Amendments  (HSWAJ estab-
   hed  broad new  au th or i t. i P <;  in the  RCRA program  to assHt EPA in
   <>mp H sh i ng  these  ohj M t i v<^?, ,  These  new authorities are:

     15   3004 (u )  -  C o r re c it vfc  -jLL^^JAL-^JJl^iJjlMJ^
        Requires  that any permit issued after November 8, 1984,
        require corrective action for all  releases from solid
        waste management: units at the facility.   The provision
        also requires that owner/operators demonstrate financial
        assurance for any required corrective action, and allows
        schedules of  compl \ ance to be used in permits where the
        corrective action cannot be completed prior to. permit
        issuance.

              l! J~r_JillllJ n; 5 va t u s C .ojrr_ec t ijve Ac t i on Orders
        Provides authority to issue enforcement ordsrs to com.pel
        corrective .action or other response measures at  Interim
       .status facilities, and to take civil action against
        facilities for appropriate relief.

        30Q4(vJ ' Cor r_ec t i ve Ac t i on Beyond^ the Fad 1 i

        Directs EPA to issue regulations requiring  corr-ectlve
        action beyond the facility boundary where necessary  to
        protect human health and  the environment, unless  the
        owner/operator can demonstrate that he  1s unable  to
        obtain the necessary permission, despite his best efforts
        Until such regulations are promu 1 gated , corrective  action
        orders can be issued to require the necessary  corrective
        a r 1 1 p n 

     These authorities change the  focus of  the  RCRA corrective
action program from detecting and  correcting future releases  from
regulated units to cleaning  up problems resulting  from past  waste
management practices at RCRA facilities.   Prior to  passage' of  the
H S W A *  FPA's authority to r e q u i r e  corrective action  for releases
r,f ha7ardo-JS  constituents under RCRA was limited  to ground  water
releases from unit,*? that were covered  by RCRA  perm-Its.  Part ?64 ,

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Subpart F  provided the vehicle for requiring  corrective  action  at
these "regulated units*.   The post-HSWA program extends  RCRA
authority  to releases to  all  media and  all  units at RCRA facili-
ties and encourages the use of other authorities,  as  needed  or
appropriate, to help achieve corrective action objective;* at
those facilities,

     The RCRA corrective  action program consists of three phases:

     1,  The RCRA Facility Assessment (RFA) to identify  releases
         or potential releases requiring further investigation,

     ?.  The RCRA Facility Investigation (RF1) to  fully  charac-
         terize the extent of releases.

     3.  Corrective Measures (-CM) to determine the need  for  and
         extent of remedial measures.  This step includes the
         selection and implementation of appropriate remedies
         for all problems identified.

     This  guidance document describes the first phase of this
process iand  outlines procedures and criteria EPA  and State
personnel  should follow in conducting RFAs'at RCRA facilities.


1 i .   PURPOSE OF THE RFA

     The RCRA facility Assessment is a three-st.age process for:

     o  Identifying and gathering information on releases at
        RCRA facilities;
     o  Evaluating solid waste management units (SW^Us) and other
        areas of concern for releases to all media and regulated
        units for releases to media other than ground water;

     o  Making preliminary determinations regarding releases of
        concern and the need for further actions and interim
        measures at the facility; and

     o  Screening from further investigation those SWMUs which
        do not pose a threat to human health or the environment,

During the RFA, EPA or State investigators will gather information
on SWMUs and other areas of concern at RCRA facilities.  They will
evaluate this information to determine whether there are releases
that warrant further investigation or other action at these
facilities.  Upon completion of the RFA, Agency personnel should
have sufficient information to determine the need to proceed to
the second phase (RFI) of the process.

     All three steps of the RFA require the collection and analy-
sis of data to support initial release determinations:
                               1-2

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     o   The  preliminary  review  (PR)  focuses  primarily  on  eval-
        uating  existing  Information,  such  as  Inspection  reports,
        permit  applications,  historical  monitoring  data,  and
        Interviews  with  State personnel  who  are  familiar  with
        the  facility*

     o   The  visual  site  inspection  (VSI)  entails  the  on-site
        collection  of  visual  information  to  obtain  additional
        evidence of r-..M ease 

     o   The  sampling visit  (SV)  fills data gaps  that  remain  upon
        completion  of  the  PR  and VSI  by  obtaining sampling  and
        fi eld data .
III.  SCOPE  OF THE RFA

     Th i -.'. section addres&es;

     o  Releases covered In the RFA;

     o  Relation of the RFA to the CERCLA PA/SI;

     o  The extent and role of sampling 1n the RFA;  and

     o  Ro'les and responsibilities.

      -5 S -e' Qvered 1n t h e  R F A
     Ths RFA should identify all areas, of potential  release at
RCRA facilities and include the investigation of releases to all
media:  air, surface water, ground water, and soils.   However,
ground  water releases  from regulated units are not addressed 1n
the RFA.  EPA and/or State investigators should use  the full com-
plement of RCRA authorities to secure appropriate action.  These
Include 30Q4(u), 3008(h) 3004(v), 3013 and 7003.  It these
authorities are not sufficient to compel the desired action,
Agency  Investigators may wish to use other authorities, such as
CERCLA  106 or TSCA 7 authorities and should consult with EPA or
State offices responsible for administering these programs.

     The HSWA 3004(u) provision focuses on Investigating releases
from SWMUs at RCRA facilities.  Solid waste management units are
def i ned as :

     o   Any discernible waste management unit at a RCRA facility
        from which hazardous constituents might migrate, Irre-
        spective of whether the unit was intended for the manage-
        ment of solid and/or hazardous waste.

The SWMU definition includes:

     o   Containers, tanks, surface  impoundments, waste piles,
        land treatment units, landfills, incinerators, and
                                1-3

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        underground  injection wells,  Including tftose units defjnejl
        as  "ns$ujaited units" unjjr RCJTAT

      o  Recycling units, wastewater  treatment units and other
        units which  EPA has generally exempted from standards
        applicable to hazardous waste management units.

      o  Areas contaminated by "routine,  systematic, and deliber-
        ate  discharges" from process  areas.

 The  definition does  not include accidental spills  from production
 areas and  units  in which wastes have  not  been managed  (e.g.,
 product storage  areas).

      The  RFA will not routinely address  releases that  are  per-
 mitted  cr  required to be permitted under  other environmental
 programs  or  contamination  resulting  from  permitted discharges.
 where such  discharges are  of concern, RCRA personnel should  refer
 the  case  to  the  original permitting  authority.   If that authority
 does  not  take appropriate  action, EPA can exercise its authority
 under 3004(u),  3004(v)/3008(h ) or 3013.  Where the RFA
 identifies  contatftinati on requiring further Investigation,  RCRA
 staff should work on a  case-by-case  basis with the Regions and
 other EPA  permit programs  to develop  a  solution  to the contaml-
 nat^onproblem.

      The  RFA doss address  relen-es from  SWMUs to media other
 than  the  one covered by the unit's discharge  permit..   For  example,
 EPA  can use  3004{u)  or 3008(h)  to  control  the  release of volatile
 organic compounds from  NPDES-permitted  wastewater  treatment  units
 where there  is cause for concern.

      Relation of the RFA to the CERCLA  PA/SI

      The  CERCLA  PA/SI and  the RFA differ in  two  Important  respects.
 First,  the  CERCLA PA/SI focuses on the  potential for offslte
 exposures  from releases, while  the RFA  focuses on  Identifying
 specific  releases at RCRA  facilities  and considers the potential
 for  offsite  exposures primarily in determining whether to  require
 interim corrective measures.

      Second, the CERCLA  PA/SI was developed  primarily  as  a method
 for  scoring  facilities  to  determine  whether  they should be on  the
 CERCLA  National  Priority List  (NPL).  The RFA does not formally
 rank  or prioritize facilities.  The  RCRA program may use  the
 facfHty  management  planning  (FMP) process  to esaJ>71s)i State  and
 Regional  priorities  at  and among  RtHn faculties,  "The
provfefe A  fc&mwck  for aeterwtlniftg  spectfie  permitting
enforcement  actions   that should be taken at a facility and whfch
facilities EPA  should address  ffrst.   Information on potential
releases at a facility is  an  important input  into this  process.
However, it is  evaluated along with  other Information  on  the
facility's compliance and  permitting  status to establish  overall
program  priorities.
                               1-4

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     Ext an t and Role of S a tnp 11 n g

     , 'A purposely designed the RFA to be limited  1n  scope.
This guidance establishes a framework  to assist  t'PA  Investigators
In making preliminary release  determinations  that  are largely
based on existing Information  and best professional  judgment.   The
framework emphasizes the need  to focus data  collection  and  analysis
efforts  (1,e. sampling data)  on those data  that are  required  to
support  specific permit of enforcement order  conditions.   In
general, the stronger the case  that the Investigator  must  make
to compel an owner/operetor to  conduct an RP'I or to  convince  the
public that a SWMU does not pose a threat, the greater  the  amount
of Information he/she will need to collect 1n the  SV.

     The Agency recognizes that sampling needs will  differ  on  a
case-by- ase basis.  The extent of sampling  will depend on  the   _
amount and quality of Information gathered 1n the  PR  and VSI,  the
investigator's professional judgment regarding the amount  of  In-
formation necessary to support  an Initial release  determination,
and the  degree of owner/operator cooperation.

     Rebponsibll1ty for Conducting tnt RFA

     As  the program 1s currently set up, EPA  snd/or  the States
are responsible for conducting  RFAs.  Because of the  subjective
nature of these Investigations, the Agency believes  that 1t 1s
appropriatt for a regulatory agency to conduct the RFAs.  These
Initial  release determinations  will provide  the basis for  requiring
a number of potential follow-on activities ranging in scope from
no further action.to a full corrective action program.  EPA and
the States may use contractors  to assist them 1i conducting these
Investigations, but the regulatory agency retains  overall  respon-
sibility for the RF* decisions.

     In  some Instances, 1t m,sy be appropriate for the facility
owner/operator to perform certain sampling activities.  EPA
and/or the State should make such determinations on  a case-by-case
basis and should carefully review and approve plans  developed by
owner/operators and oversee field activities conducted by the
owner/operator,


IV.  TECHNICAL APPROACH

     All three steps of the RFA require the  Investigator to ex-
amine extensive data on the facility and specific units at the
facility,  These data can generally be divided  Into  five categories

     o  Unit characteristics;

     o  Waste characteristics;

     o  Pollutant migration pathways;

                                1-5

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     o  Evidence of release;  and

     o  Exposure potential.

Exhibit 1-1 provides a matrix of  these  categories  and  the  specific
factors that 1nvestlgators need  to consider  in  each  category.
The investigator will need to apply his/her  best  professional
judgment 1n examining these factors, how they interact,  and  their
effects on the  likelihood of  a release  and Its  significance.

     Exhibit 1-2 outlines the types of  information in  each  cate-
gory that Investigators are likely to obtain during  each  of  the
three steps 1n  the RFA.  In general, during  the PR,  the  investi-
gator will examine documents  and  other  written  materials  to
obtain information on the facility's location,  potential  environ-
mental receptors, cnaracteristies of the waste  handled at  the
facility as a whole.and managed  in SWMUs, the design and  operating
features of the SWMUs themselves, and evidence  of past releases.
This information will assist  the  investigator in  determining
which media and migration pathways are  of concern and  why.   The
Investigator will supplement  this Information with additional
evidence gathered during the  VSI  and samples taken during  the  SV.

     Specific factors 1n each category  that  must  be  considered
will vary depending on which  medium is  of concern.  For example,
land-based units are more likely  to have ground-water  releases
than aboveground units; surface  1upoundments are  more  likely to
have air releases than 1andf111s,  Certain wastis tend to  vola-
tilize and cause air releases, while other wastes are  soluble  in
water and tend  to migrate via surface or ground water*  A  facil-
ity's location  will determine which media are of  concern.   Surface
water releases  should not be  a concern  for facilities  that are
not located near surface water.   Types  of evidence and potential
receptors will  also vary by media.

     Each of the media-specific  chapters describes the factors 1n
each of the five categories th.at  Investigators  should  examine  for
the media of concern,  Each chapter 1s  organized  to follow the
three steps of  the RFA and is designed  to assist  the Investigator
in Identifying  releases for each  of the media of concern.

     The RFA Is completed when the  Investigator has  sufficient
Information to  make a determination regarding  releases or likely
releases at the facility and  the need for further Investigations.
Sometimes it will be possible to make this determination after
completing the  first two steps (the PR and VSI),  and a SV will
not be necessary.   In other cases, even upon completion of the
SV, the investigator may need to perform additional  follow-up
inspections or collect further sampling or other  Information  from
the owner/operator before making this determination.

     In general, when the RFA is completed, the Investigator
will have:
                                1-6

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          EXHIBIT 1-1



FACTORS TO CONSIDER IN CONDUCTING RFfts
Unit
Characteristics
type of unit

design features

operating prac-
tices (past and
present)

period of
operation

age of unit

location of
unit

general physical
conditions

method used to
close the unit






Waste
Characteristics
type of waste
place in the
| unit





















nig rat Ion and
dispersal char-
acteristics of
the waste

toxicologies!
characteristics

physical and
chemical
characteristics

































Migration
Pathways
facility's geo-
logic setting






facility's hy- j
dregeologic
setting

atmospheric
conditions

topographic
characteristics












Evidence of
Release
prior inspec-
tion reports

citizen
coff^ilaints
 ]

















monitoring data

visual evidence
e?g., discolored
soil, seepage,
discolored
surface water or
runoff.

other physical
evidence, e.g.,
fish Mils,
worker illness,
odors

sampling data


























Exposure
Potential
proximity to
affected pop-
ulation

proximity to
sensitive
envi roniuents

likelihood of
migration to
potential
receptors










1

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     o  Identified  all  potential  releases  of  concern;

     o  Identified  all  SWMUs;

     Q  Determined  which  areas  need  further  investigation  and
        and collected  sufficient  Information  to  focus  these
        investigations;

     o  Determined  which  areas  require Interim measures;

     o  Screened out releases  that  do  not  require  any  further
        Investigation;  and

     o  Referred permitted releases  to other  authorities,
        as appropriate.

     Upon completion of  the RFA,  the investigator  prepares a
report summarizing  his/her findings.  The  report should Integrate
the findings from all  three steps 1n the RFA  and Include  a de-
scription of the facility and  its waste management practices,
release Information for  all SWMUs or groups  of SWMUs and  other*
areas of concern, Campling plan and  results,  and final release
determinations and  recommendations.   This  report should clearly
indicate those areas of the facility that  require  further inves-
tigation in a RFI and  should contain information to focus these
investigations,  A  sample outline of an RFA  report 1s  presented
In Appendix A,

     Conducting an  RFA can present  an  opportunity  to gather
information on a facility which may be useful for*  purposes other
than making RFA determinations.  Regions or  States may choose,
for example, to collect  certain data on facility characteristics
and other site-specific  environmental  data as a means  of estab-
lishing programmatic priorities for corrective action*  Appendix
F provides a listing of some example data  elements which  could be
used for such purposes.


V.   ORGANIZATION OF THIS  DOCUMENT

     This document  contains nine chapters.  The second chapter
describes the PR process,  the third chapter  describes the VSI,
and the fourth chapter explains the SV.  In  addition, there are
five technical chapters that apply the technical approach out-
lined 1n chapters two, three and four to the  various media of
concern.- ground water, surface water, air, subsurface gas and
soi 1 .

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                           CHAPTER TWO

                 GONOUCTINQ A PRELIMINARY  REVIEW


I.    INTRODUCTION

*    Purpose

     This chapter describes how to conduct a preliminary review
(PR), the first step in the RCRA Facility  Assessment (RFA)  pro-
cess for Identifying releases or potential releases  at RCRA
facilities under the RCRA corrective action requirements.   The
PR  serves two primary purposes:

     (1)  To gather and ev>luate existing  Information on facili-
          ties 1n order to Identify and characterize potential
          releases; and

     (2)  To focus the activities to be conducted in the second
          and third steps of the RFA, the  visual site Inspection
          (VSI) and the sampling visit (SV).

B.    Icojgji

     DuMng the PR, EPA personnel will e aluate existing docu-
ments and, speak with relevant Individuals  (e*g.| ftfiRA Inspectors,
State and Federal permitting staff, itc)  1n order to Identify
areas at a facility which may be releasing hazardous wastes or
hazardous constituents posing a potential  threat *to huwan health
and the environment.  The PR W111 consider Information on the
entire facility, and w111 not be limited tc collecting and  eval-
uating Information covering the RC! A-'regul aled areas at the
facility.  In particular, the Investigator will identify and
gather Information on SWMUs and other areas where wastes have
been managed at the facility*

     While the scope of the PR will focus  on Identl fylnjj and
evaluating releases resulting from waste management activities,
the Investigator should consider documents he/sht finds which
provide Information on releases at the facility which may be
beyond the scope of the RCRA corrective action authorities,
These could Include releases subject to Investigation and remedi-
ation under CERCLA or TSCA authorities,

     The scope of the PR Includes Investigating release potential
to  all environmental media at the facility (with the exception
of  ground-water releases from regulated units):

     o  Ground water;
     o  Surface water;
     c  hi r;
     o  Soils ; and
     o  Subsurface (gas).

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     At complex facilities with many SWMUs,  It  may be more
practical  to evaluate groups of similarly located  or designed
StfMUs father than characterizing each unit separately.   Addi-
tionally,  Investigators should not focus solely on releases
from SMMUs, but should examine the full  facility for evidence
of spills  and/or other releases resulting from  waste management
activities which may not fit the definition  of  a SWMU release
(see definition of a SWMU on page l-4)4

     This  chapter describes how to conduct a PR at RCRA facili-
ties by:

     (I)   Collecting PR information;

     (2)   Evaluating PR information; and

     (3)   Completing the PR,

t,   Product

     At the end of the PR, the Investigator  will summarize  the
findings  of the PR.  Ho/she should document  the Information
sources evaluated, describe the potential releases of concern
Identified at the facility (especially all SWMUs), and make
recommendations that will focus subsequent activities in the
VSI and the SV,  The results of the PR w111  serve  as the founda-
tion of the RFA report, which will be revised at the end of  the
VSI and finalised following the SV,  A sample outline for an RFA
report 1s  Included as Appendix A.


II.  GATHERING PR INFORMATION

     the  first step In the PR Involves collecting  Information  on
a facility that will provide evidence of its potential for  release,
The success of the PR will depend to a great extent cm the  Inves-
tigator's  ability to collect relevant Informatics.  A PR may pro-
vide misleading results when significant sources of Information
are not considered {e*g., enforcement documents describing  known
releases,  relevant sampling or monitoring date, stc.)^  Ei*A
should plan each PR to ensure that all relevant sources of  Infor-
mation pertaining to a facility are examined.  Gathering dita  in
the PR will usually Involves

     (1)   Collecting documents and other written reports;

     (2)   Meeting with relevant individuals; rH

     (3)   Collecting additional information  from the
          o^ner/operator*

     The  PR focuses on evaluating information in the five basic
categories presented in the RFA information  matrix  (Exhibit  1-1).
                               2-2

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The matrix Illustrates the types  of  Information  in  each  category
(unit char idteHsties , waste characteristics,  pollutant  migra-
tion pathways* evidence of release*  and  exposure potential)  which
should be evaluated during the PR   It  should  be noted,  however,
that It Is difficult to obtain complete  data  for any  of  the  five
categories during the PR, and that  the  VSI  and SV will  provide
additional opportunities to collect  Information  during  the  RFA.

A .    Written Information and Documents

     This section briefly summarizes those  data  sources  which
have been found to be most useful 1n conducting  PRs to  date.  A
detailed discussion of all potentially  relevant  data  sources 1s
Included as Appendix 8 to this document*

     Four basic RCRA file sources and several  additional RCRA
documents typically contain the most useful  Information  during
the PR:

     (1)  RCRA permit applications;

     (2)  Facility SWMU response {RSI #3);

     (3)  RCRA Inspection reports;

     (4)  RCRA exposure Information reports;  and

     (5)  Additional RCRA sources,

Brief discussions on each ui these sources  follow.
     Part A and B permit applications or closure plans are avail-
able for all facilities 1n the permit pipeline arid addressed
under the corrective action program,^/ Although owner/operatt rs
develop these applications to support permitting or closure of
regulated units, they will usually contain Information oh other
areas of the facility relevant to the RFA.

     Part A permit applications provide information on the wastes
being treated, stored, and/or disposed 1n the regulated units at
a facility.  These forms can be useful 1n identifying the wastes
of concern at the facility, although  it should be noted that the
wastes disposed 1n old SWMUs may have different characteristics
than those currently disposed 1n regulated units, due to changes
in facility production processes or changes of ownership.  The
Part A will often provide a scale drawing showing the location of
all past treatment, storage, and disposal areas (27Q.13(h)),
which can be useful in identifying SWMUs and other areas of
concern .
     /  The proposed Codification Rule of March 28,  1986  Incorpon
ates Wsi 03 information  (described above) into permit application
requi rements 
                               2-3

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     A land disposal  Part B permit application provides extensive
hydrogeol ogle information related to the surf1c1a1  aquifer at  a
facility,  including a description of the facility's ground-water
monitoring system.  This Information 1s useful for  identifying
ground-water pollutant migration pathways and prior releases from
SWMUs at land disposal facilities.  However, this information  is
not likely to be available for storage and treatment facilities.

2     SMMU  Response (RSI .,1 Submission)

     The ReauthoH zat 1 on Statutory Interpretation (RSI  13) issued
by  EPA Headquarters required the EPA Regional Offices to request
owner/operators of RCRA fac11ltier to submit data on each SWMU at
their facilities.  The data owner/operators submitted in response
to  this request is usually helpful for identifying  SWMU* at a
facility.   However, many submissions have been found deficient,
and RCRA Investigators should not assume that these submissions
accurately identify all of a facility's SWMUs.  Other sources,
such as compliance inspection reports and the VSI should be used
to  verify  and augment the information contained in  the SWMU
response,
3,   Cgjnj)] iaj^
     Tr dm ..... E n t o, r emeli VljTtf e r s             ~~     ~

     RCRA inspection reports will often provide extensive infor-
mation on facility waste generation and handling practices, old
and new waste management units, and prior releases at the facility.
They ma/ also describe migration pathways and exposure points.

4.   Exposure Information Report

     Only facilities seeking permits for landfills and surface
impoundments are required to submit exposure information,  these
submissions provide Information on all  five categories If) the RFA
information matrix (Exhibit 1-1).  These reports can be Useful in
identifying pollutant migration pathways from the facility to
potential exposure points, and may also discuss the likelihood of
human exposure to hazardous constituents,

5.   Additional RCRA Sources

     o  Biennial Report  (265.75) -- The biennial report, prepared
        by the owner/operator  and submitted to the Regional
        Administrator, provides a description and the quantities
        of each hazardous waste received during the previous year,
        and the method of treatment, storage, or disposal for
        each waste.

     o  Operating Log (265.73) -- The  facility operating log
        provides a map displaying the  location and quantities  of
        wastes disposed  throughout the  facility,  It also provides
        reports of all incidents that  required implementation  of
        the Facility Contingency Plan.
                                2-'

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     o   RCRA  Masts  Manifest  (265.71)  '--  The  manifest  will  provide
        details  on  all  wastes  received  at  the facility after
        November 18,  1980.   Facilities  are  only  required  however,
        to retain manifest  for three years.

     o   Notice  to Local  Authority  (265.14)  --  The  owner/operator,
        within  90 days  after closure of a  disposal  unit,  must
        submit  to the local  land  authority  and  the  Region records
        of the  locations and quantities of  wastes  within  a  closed
        unit.  The  owner/operator  must  also  provide descriptions
        of the  types, locations,  and quantities  of  wastes in
        units closed  before  promulgation  of  the  Part  265  regula-
        tions *

R-    Qthsr Sources

     Many other sources can  provide  useful  information for evalu-
ating the likelihood  of releases  at  a  facility.   After the RCRA
sources outlined above, these are  likely  to contain the most
valuable Information:

     o   NTOES and CAA permits and  permit  applications;
     a   CERCLA PA/SI  Reports;
     o   Installation  Restoration  Program (IRP)  Reports;
     o   MRS Documentation;
     o   CERCLA RI/FS  Studies;
     o   CERCLA 103(c) Notifications;
     o   Aerial  Photographs;
     o   Other Federal/State  Agencies;  and
     o   TSCA/QSHA/NPDES Inspections.

A number of other sources may also provide some useful informa-
tion, although they will be  needed less often:

     o   SEMS  (Graphical Exposure  Modeling System);
     o   State/Local Well Permit Offices;
     o   Municipal/County/City Public Health Agencies;
     o   Local Well  Drillers;
     o   State/County  Road Commissions;
     o   Utilities;
     o   Local Airports/Weather Bureaus;
     9   Naturalists/Environmental  Organizations;
     o   Facility Employees;
     o   Colleges/Universities; and
     o   Interviews  with Local Residents.

It will not be necessary to look at each of  these  sources  1n all
situations, but  they can be examined as appropriate to help fill
information gaps.  All  the  data sources listed above  are described
more fully in Appendix  B.

B -   HeetJjig wi th R e 1 eyant  InJjI v 1 duaj s

     It will  be  useful  to meet with personnel from Sta* >, agencies
and other EPA program  offices  (e.g., NPOES permitting  program) in


                               2-5

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the Initial  stages of the PR.  Other EPA permitting programs may
have considerable historical  knowledge of a facility, Including
Information  on SWMU releases, Instances of non-compliance, facility
waste generation practices* and Inspection reports.  Early contact
with these groups can help ensure that all relevant Information
Is considered during the PR.

r '   Coll e e t |n a Ad d 1 1 1 o n a 1 In forma 1 1 on

     In situations where the  Investigator doe<; not find sufficient
information  concerning  the location or characteristics of a
facility's SVJM'Js to cotrnl^te  a PR > 1t may be necessary to request
additional Information  from the owner /operator .  Such requests
should be 1n the form of a letter In which EPA requests additional
Information  from the facility In order to comply with the HSWA
corrective action requirements.  Where necessary, EPA should cite
Us 3007 information gathering authority to obtain this infor-
mation,  These letters  should he as specific as possible to ensure
that the requested Information is submitted in a timely manner.
A  i ample letter is included as Appendix C.


!!!. EVALUATING PR INFORMATION

     The PR  focuses on  evaluating the information gathered du  Ing
its Initial  stages.  This section presents a framework for eval-
uating PR information in order to gain an understanding of 'the
facility's release potential.  This will involve three basic
steps:

     (1)  Investigating the facility's waste generation protepsest

     (2)  Identifying SWMUs and other potential releases of
         concern; and

     (3)  Evaluating the facility's -'elease potential.

A ,   jJl^MllJAll-JllL.ty.Jy -Jg Generation Prqcess&i
     It will be Important to understand the facility's overall
waste generation and management activities, both past and present
when evaluating how SWMUs and other areas of the facility have
been used to handle wastes and how they relate to the-% f aci 1 1 ty ! s
overall waste management system,  Whenever possible, the investi-
gator should determine what types o*" waste have been managed  at
the facility since it began operation in order to identify poten-
tial constituents of concern,

     As discussed in Section II of this chapter, RCRA compliance
Inspection reports may provide a useful source of information  on
manufacturi fig. processes , as will som.e NPDES permit  applications.
tn  some cases, Inspection reports may also discuss  where wastes
from previous manufacturing processes have been disposed at a
facility or may Include information on past releases.
                               2-6

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     The following example Illustrates the benefits  of investiga-
ting a facility's waste generation processes.   A secondary lead
smelting facility closed several  surface Impoundments that were
offlnally part of an NPOES wastewater treatment process.   The
Impoundments were clean closed by excavating to a depth determined
hy the concentration of lead in the soil.   The facility stated
that lead was the only constituent of concern  in these units.
Turing the PR, EPA Investigated the facility's production
processes and found that several  other metals  such as cadmi-im,
nickel  antimony, and barium might be mixed with the lead
wastes.  Based qn this information, EPA took soil samples for
f*ach of these other constituents of concern.

R.   Identifying SWMUsand Other PotentialReleases  of Concern

     Once the investigator has gained an understanding of the
facility's overall waste generation and management activities*
he/she should locate all areas with potential  releases of concern
on a map of the facility.  The map should Include all SWMUs Iden-
tified in the RSI #3 SWMU response, SWMUs described  1n other
documents, and other potential releases of concern,  e.g., spills
of hazardous waste or constituents from waste management activi-
ties.  In addition, the Investigator should locate on the facility
map other potential releases of concern which may be beyond the
scope of the RCRA authorities.

     The facility map will be  an extremely useful document
throughout the RFA, especially when conducting the VSI and the
SV.   in addition to locating SWMUs, 1t will often be possible
to Identify relevant migration pathways and potential exposure
points (e.g., rivers and nearby housing)  on this map.  Additional
releases of concern can be added to the map when identified  at
later stages 1n the RFA,, particularly the VSI.

     As discussed 1n the  Introduction, the definition of  a SWMU
Includes recycling units, wastewater treatment units  (such as
those regulated under NPOES),  and  other units which  EPA  has
generally exempted from P.CRA permitting standards.   Each  of
these units identified  at a facility  should be located on the
facility map as a SWMU.  Regulated land disposal units are also
treated as SWMUs, since they will  be  investigated for  releases
to media other than ground water In the RFA,

      Several information  sources will be  especially  useful, when.
identifying SWMUs and other releases  of concern  In  addition  to
th** RSI  13 submission.  Historical aerial photographs, such  as
those available  from EMSL or  EPIC, may  reveal  the presence of
past waste management areas which  have  become  overgrown  or
otherwise hidden.   In some  cases,  closed  landfills  and surface
impoundments cannot  be  distinguished  from ordinary  open  fields
and historical aerial photographs  can help  Identify  these units*
Appendix B provides  a more  detailed  discussion  on obtaining  and
evaluating aerial photographs.
                                2-7

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C.   Evaluating the Fad 11 tyjs Release Potent 1 al^

     Once the Investigator  has identified  potential  releases  of
concern at the facility,  he/she should determine the likelihood
of release at each location by evaluating  information gathered
in the initial steps of the PR.  It will  seldom be possible to
determine from one document that a  SWMU has released hazardous
wastes or constituents.  In most cases, the Investigator will
have to deduce the likelihood that  a release of concern has
occurred by evaluating Information  from numerous sources covering
the five categories of information  presented in Exhibit 1-1:  unit
characteristics, waste characteristics, pollutant migration path-
ways, evidence of release,  and exposure potential,

     The evaluation requires the investigator  to seek evidence
that a unit has released  or is likely to have  released.  The
investigator should make  deductions based  on various amounts  of
information on the wastes contained within a unit, the design/
operating characteristics of the unit, and the presence of con-
taminants in any of the pollutant migration pathways associated
with the unit.

     In some cases, the Investigator may have  actual evidence
that a unit released to a particular medium.  In other situations,
it may be necessary to draw connections between a constituent
identified in a unit, the likelihood that  this constituent could
have been released from the unit, and sampling data showing the
presence of the constituent in a migration pathway.  While this
deduction may not prove unequivocally that the constituent Identi-
fied in the environment originated 1n the  suspected unit, such
deductions will usually be sufficient to identify a release of
concern 1n the RFA.

     The investigator's ability to make deductions on the likeli-
hood of release will depend on the extent  of Information he/she
collects pertaining to the first four items 1n the RFA informa-
tion matrix: unit characteristics, waste characteristics* pollu-
tant migration pathways,  and evidence of release.  Information  on
exposure potential is not needed to determine  the likelihood of
release, but is important in determining the need for Interim
corrective measures due to immediate exposure  risks*  The kinds
of information to be considered in each of these  five categories
are described below.

1.   Unit Characteristics

     The design and operating  characteristics  of  a SWMU will
determine to a great extent its potential   for release.  Many
treatment, storage, and disposal units are designed to prevent
releases to the environment.   The  investigator should evaluate
the physical characteristics of each SWMU  or group of  SWMUs to
determine how they affect the  potential for releases.

     The media-specific chapters in this guidance provide detailed
discussions of how the design  and  operating characteristics of


                               2-8

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various types of SMMUs affect  their potential  for  releasing  to
each medium.  For example,  surface Impoundments  with  wl1-designed,
Intact berms for controlling overtopping  do  not  exhibit  a  high
potential for surface water releases.   EPA assumes,  however,  that
unllned surface Impoundments have a high  potential  for releasing
constituents to ground water.   Surface Impoundments  which  contain
volatile organic compounds  also exhibit a high potential  for  air
releases.  The Investigator should examine the characteristics  of
each SWMU based upon the discussions presented 1n  Chapters Five
through Nine In order to consider the  likelihood of  release  to
each of the environmental  media;   ground  water,  surface  water,
air, soils, ard subsurface  (gas).  Investigators will  often  find
situations where unit design characteristics suggest  that  a  SWMU
poses little or no threat  to the  environment from releases (e.g.,
Intact above-ground storage tanks).

?.    waste Characteristics

     In evaluating a SWMU's release potential, the fnvestlgator
should Identify the wastes  originally  or currently contained tn
the unit 1n order to link constituents observed  In the environ-
ment wtth those present 1n  the contaminant source.  The  Investi-
gator can usually deduce that a release has occurred when he/she
determines that a SWMU contained a constituent that has  been
observed in a pollutant migration pathway associated with that
unit.

     The Information gathered while Investigating the waste
generation processes at a facility will provide the basis for
this part of the PR.  In many cases, a facility will  ,nd1;cate how
it  managed many of Its waste streams,  e.g., off-sitb shipment,
disposal 1n a specific surface impoundment, or storage in a waste
pile.  When a particular waste stream can be traced to a particular
unit, the Investigator can generally assume all  of the constituents
present 1n that waste stream are also present 1n the unit.

     The Information gathered on facility waste generation
processes may often be useful 1n Identifying constituents other
than listed constituents of concern to RCRA.  For example, rapidly
decomposable refuse may produce methane when placed 1n landfills
under certain conditions.

     The Investigator should identify all of the hazardous con-
stituents which ma> be present 1n each SWMU or other  areas of
concern.  Some constituents will have a greater potential for
release  from one kind of SWMU than  another.  For example, the air
chapter discusses the likelihood that volatile organic constituents
will be  released from wastewater treatment  units.  The media-
specific chapters discuss the ways  in which constituent properties
can affect the likelihood of releases to  various media.

3.    Pollutant Migration Pathway

     The Investigator should evaluate existing information con-
cerning the likely pollutant migration pathways associated with


                               2-9

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each SWMU or release of concern,   in  cases  Involving environmental
data, the Investigator win  have  to demonstrate that 1t  is  reason-
able to deduce that a constituent observed  In the environment
originated at a specific SWMU or  location,  based upon knowledge
of the pollutant migration pathway.

     While some pollutant migration pathways are largely facility-
wide (e.g., ground water), the Investigator should evaluate the
importance of all pollutant  migration pathways (1e,, ground
water, surface water, air, soils, and subsurface gas) t..at  could
be associated with each SWMU and  then evaluate Information  on
their characteristics,  SWMUs which contain the same wastes and
are adjacent to each other may be grouped together during the  RFA.
It will often be possible to eliminate certain pathways  from con-
sideration for various SWMUs at this point  1n the PR.

     Different types of SWMUs will exhibit  different potentials
for releasing constituents to specific ml gratlon ..pathways .   The
investigator should determine which SWMUs are likely to impact
which pollutant migration pathways at the facility, and gather
specific information that will aid 1n determining the charac-
teristics of these pathways.  This part of the analysis also
provides a critical role in identifying potential exposure points
along various migration pathways, which 1s Important In evaluating
exposure potential for interim measures at the facility.

     The media-specific chapters provide Information to aid the
investigator 1n evaluating the physical characteristics of each
migration pathway of interest.   The investigator should consider;

     o  Potential routes of pollutant transport;

     o  Physical factors within  the pathway  that could  affect
        the  migration  of constituents (e.g.,  organic content  of
        soil for releases to soil  and ground  water,  or  prevailing
        wind patterns  for air  releases); and

     o  Other  factors  which could  affect the  fate  of constituents
        present  1n  a migration pathway,

4.   Evidence  of Release

     The  investigator  should examine  available  sources  of  Informa-
tion to  identify any  evidence  that constituents  have been  released
at  a  facility.   The  Investigator may  have  access  to direct  and
indirect  evidence  of  release,  both of which  may  help 1n making
determinations  of  release at  a facility.

     Direct  evidence  of  release  includes official  reports  of
prior  release  Incidents  (which may be  found  in  RCRA enforcement
or  permitting  documents,  other Federal,  State,  or  local government
documents,  facility  records,  RSI #3  responses,  etc.),  visual
evidence  clearly showing  a  release incident, or sampling data
that  clearly identifies  a releasing  SWMU  (e.g.,  surface water
samples  for  a  specific constituent in  a  clear run-off  pathway).


                               2-10

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Indirect evidence of release Includes  sampling  data  taken  along
relevant migration pathways which,  when  linked  together  with  waste
composition data, can support a deduction concerning the
likelihood of release from a specific  unit at  the  facility.

     The VSI, which 1s described 1n Chapter Three,  1s generally
an excellent source of both direct  and Indirect evidence on
releases.  Stained soils 1n a well-defined drainage  pathway  below
a unit can provide direct evidence  of  release;  stressed  vegeta-
tion may provide Indirect evidence  of  release.

     The media-specific chapters describe the  types  of evidence
that are Important for releases to  each  of the  environmental
media.  For example, visual sightings  of seepage along a stream
bank provide evidence of both a ground-water release and a sur-
face water release.  The Investigator  should refer to the  section
on evidence of release 1n each of the  media-specific chapters.
In all cases, the Investigator should  use best  professional  judg-
ment 1n assessing the strength of any  Information  source In
providing evidence of release.

S.   Exp o su._r e __Poten11 a 1

     The Investigator should evaluate  available Information  on
the location, number, and characteristics of receptors that  could
be affected by continuing releases  at  the facility.   These recep-
tors Include human populations, animal populations  (particularly
any endangered or protected species),  and sensitive environments.
This Information will be most useful 1n helping the Investigator
determine the need for Interim corrective measures  at the facility
to alleviate especially high risks  of  exposure.  The Investigator
should refer to the RCRA 3008(h) Correctl ye Actl on Ordets Lnterlm
Heasures Guidance for "leTafts on when  alvd liow to Implement interim
measures.

     The media-specific chapters provide  Information on what
receptors are likely to be  affected by releases to  each of the
media.


 IV.  COMPLETING THE PRELIMINARY REVIEW

     The Investigator's ability to determine that a  release may
pose a threat to  human health or the  environment will Increase
with the quantity  and quality  of Information gathered 1n  the
RFA.  By the end  of  the PR,  the Investigator will usually have
 Identified many  of the potential releases  of concern  at the
 facility, and will have made  a  preliminary  evaluation concerning
the  likelihood  that  a  release  of concern  has occurred at  each
SWMU. group  of  SWMUs,  or  other  potential  areas  of concern.

     The next phase  of the  RFA, the VSI,  provides additional
evidence to  help  the  Investigator  determine which units or
areas of concern  require:  additional  Investigation  In a sampling
visit.  Interim  measures,  further Investigation  1n an  RF1, or  no


                                2-11

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 further  action.  The  Investigator will usually consider the
 following  factors before proceeding with the VSI:  1) Identi-
 fying  significant data gaps, 2) focusing the next two steps of
 the  RFAt and  1)  beginning the RFA report.

 A.    1 dn11 f%jng S1 g n 1 f 1 c a n t Data Ga p s

      Depending upon the quaMty of Information gathered during
 the  PR,  tht  Investigator m?y have a strong Idea concerning the
 likelihood of releases from SWMUs or  other areas of concern
 Identified In the PR.  In many cases, however* the Investigator
 will  be  missing  Important Information on a potential release or
 unit  of  concern  (e.g., Information on the wastes handled
 w1thin the unit).

      In  such  cases, 1t may be necessary  to make a formal request
 for  additional Information from the owner/operatar.  As stated
 earlier, Investigators may need to cite  the RCRA 3007  Informa-
 tion authority when making this request.  The  letter should be
 extremely  specific  1n order to ensure that the owner/operator
 clearly  understands what Information  has been  requested (see
 Appenril x C ) .

 B.    Focusing the Visual Site  Inspection and Sampling Visit

      One of  the  primary purposes  of the  PR 1s  to provide the
 Investigator with an  understanding of the waste management
 activities  at the facility, enabling  him/her to focus subsequent
 observations 1n  the VSI and the SV to the greatest extent
 possible.   Because  all  facilities will  undergo a PR  and a  VSI,
 emphasis will be placed on the quality  of the  Information
 gathered In  these two stages.   If the conclusions drawn from  a
 PR and VSI  are not  based upon  sufficient Information, 1t 1s
*J ikely that .owner/operators or the public will challange/permlc
 conditions or enforcement  orders  developed to  compel further
 actions  at the  facility.

      The Investigator should  evaluate the  Information gathered  1n
 the  PR on  each  SWMU or  potential  release of  concern, and deter-
 mine whether: 1) 1t 1s  likely  that the  unit  has  released,  2)  1t
 1s unlikely  that the  unit  has  released,  3) there  1s  Insuffi-
 cient evidence  at  this  stage  to  assess  the likelihood of  release,
 or 4) a  release  could threaten  human  health  or the  environment.
 The  VSI  will orovlde  more  useful  Information  1f  the  Investigator
 conducts 1t  w1t!i these  preliminary  determinations  1n mind*
 While 1t 1s  :oo  early to  draw conclusions  at  the  end of the  PR,
 1t will  often be possible  to  screen  out  units  from  further con-
 sideration at the  end of  the  VSI.   During  the  PR,  the  Investigator
 may  Identify units  that  are  not  likely  to  h^ve releases of concern.
 These units  should  be Inspected  carefully  1n  the  VSI before  deter-
 mining thft  they need no  further  Investigation or  action.

      The Investigator can  also make  preliminary  recommendations
 concerning the  need for  collecting  additional  sampling  data  1n
 an SV.  It will  often be  possible to  Identify  units  or  locations
 where sampling  data can help  1n  making  determinations  of  release.

                                2-12

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Recommendations on sampling locations made 1n the PR should be
checked for appropriateness during the VSI.   In general, the VSI
and SV should provide the additional  Information needed to fill
data gaps Identified during the PR.

C.   Documin11 .n fr the Pre 11 m 1 n a r y Review

     The Investigator should  document the fi,H1ngs of the PR by
beginning the RFA report, which will  summarize the complete RFA
process,  The Investigator w11l Incorporate  the results of each
step of the RFA Into this report, resulting  1n a complete docu-
ment providing recommendations concerning: 1) the need for an RFI
at the facility, 2) the need  for Interim measures at the facility,
or 3} the need for no further action  at the  unit/facility at
this time.

     At the end of the PR,  the report should document Information
sources, Identify SWMUs and other areas of potential release on a
facility map, and contain preliminary evaluations of the likelihood
of release at each locations.  This Information will be used
throughout both the VSI and the SV.

     A sample outline of an RFA report 1s Included as Appendix A,
                               2-13

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                         CHAPTER  THREE

              CONDUCTING A VISUAL SITE  INSPECTION


I.   INTRODUCTION
                                          V

A,   Pjj.rp.ojjB

     The visual  site inspection (VSI)  1s  the second  step  of the
three-step RFA process for Identifying  releases at  RCRA facilities
1n the corrective action program.  The  VSI  W111 focus  on  Identify-
ing SWMUs and collecting visual evidence  of release  at facilities
to assist EPA 1n recommending further  steps 1n the  corrective
action process.   The major purposes of  the  VSI Include;

     (1)  Visually Inspecting the entire  facility  for  evidence
          that releases of hazardous wastes or constituents have
          occurred and Identifying additional  areas  of concern;

     (2)  Ensuring that all SWMUs and  areas of concern have been
          Identified;

     (3)  Filling data gaps Identified  1n the PR}  and

     (4)  Focusing recommendations concerning the  need for a
          sampling visit, interim measures, an RFI,  or no further
          action at a facility.

     By the end of the VSI, the Investigator will  be able to
determine at which locations it will be necessary  to collect
additional environmental samples 1n a sampling visit (SV).  In
some cases, 1t w1H be possible to screen a unit from further
Investigation or to recommend further Investigation 1n an RFI
without conducting additional sampling, thus completing the RFA,

B.   Scope

     The VSI will Include the entire RCRA facility and can extend
beyond the property boundary in certain cases,  The VSI should
focus on Inspecting the discernible SWMUs at the facility.  How-
ever, the Investigator may Inspect areas outside the facility
boundary to determine 1f a release has migrated offslte.  The  VSI
will generally be limited to collecting visual evidence of poten-
tial releases (1*e., photographic documentation),  although 1t  may
be appropriate 1n some cases to conduct air monitoring for safety
purposes 1n the VSI.

C.   Product

     Visual evidence gathered during the VSI will  support  the
initial Information gathered during the PR  on  the likelihood  of
release at specific locations  1n the facility.  This  Information
should be evaluated along with the original Information collected

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during the PR and Integrated Into the draft RFA  report.   Initial
determinations on the likelihood of release at  the  facility
should be revised accordingly.   Typical  VSIs will  result  in
substantial  documentation of facility characteristics,  which
should be Integrated Into the RFA report.


II.  PLANNING THE VISUAL SITE INSPECTION

     The VSI 1s a relatively simple procedure and  should  not
require a great deal of time to plan and execute.   In general,  the
site inspection activities can  be completed in  one  day,  although
there may be some extremely large facilities which  will  require
more time,

     The PR provides most of the information needed to  prepare
for conducting the VSI,  During the PR, the Investigator  will
identify potential areas of release on a facility  map,  and make
preliminary evaluations of the  likelihood of release at each  loca-
tion.  The Investigator should  rely upon this map  when  conducting
the VSI, documenting any unusual observations on the map  and  1n a
1oghook.

     The VSI will usually be the Investigator's first visit to
the facility during the corrective action process.   Therefore,
the investigator  should develop a site safety pUn prior  to
conducting the VSI which outlines the need  for personal safety
devices {e.g., respirators, protective clothing, etc.)  while
conducting the field activities.  The exact content of each
safety plan will  vary by site,  depending on the complexity of the
site and on the Investigator's  planned activities,   tPA personnel
should participate 1n an Agency-sponsored safety eoufse prior to
conducting a VSI.  Safety preparation Is discussed further 1n
Chapter Four  (see "Preparing for the Sampling Visit") and Appen-
dix E ,

     The VSI will probably  be the owner/operator's first experience
with the new RCRA corrective action  program as well,  the Investi-
gator  should contact the owner/operator to  schedule a date for
the VSI.  At this time, he/she should also  request a meeting with
representatives  from the facility prior to  cortductlrtg the field
activities.  This meeting will  provide the  Investigator with an
opportunity  to explain  the  various  steps of the corrective action
process to the owner/operator, and  to answer any of the owner/
operator's questions about  the RFA  or the  corrective action
program.  During  this meeting^ the  investigator should discuss
with  the owner/operator  the  proposed safety  plan and Incorporate
his/her recommendations  in  the safety plan  prior to conducting
the VSI.


 III.  CONDUCTING  FIELD ACTIVITIES DURING THE  VSI

      Once the  investigator  has made  the arrangements for  conducting
the VSI and  has  completed the  PR,  he/she should conduct the  field


                               3-2

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activities.  The owner/operator will  usually  accompany  the  Inves-
tigator around the faellHv,

     During the VSI, the Investigator should;

     o  make visual  observations of SWMUs  and  other  areas  of
        concern at the facility;

     o  Identify on  a facility map aU  areas  of concern;

     o  document al 1 observations 1n  a  field  logbook;

     o  take photographs of all SWMUs,  potential  releases,  and
        other locations of Interest;  and

     o  monitor for vapor emissions where  appropriate  to  protect
        the investigator's safety.

     One of the primary purposes of the RFA w111  be  to  allow  the
investigator to Identify potential releases of concern  not  Identi-
fied during the PR.   The VSI  also provides the Investigator with
an opportunity to Inspect the entire facility for potential
releases of concern and to gain Insight into  facility  management
pract1ces.

     The Investigator will focus 1n the VSI on Identifying and
characterizing SWMUs, as defined In the Introduction*   The 3004{u)
corrective action permitting authority requires that corrective
action be  addressed at all SWMUs,  In some cases, however, he/she
will Identify spills or other releases from waste management
activities which may require corrective action.  These should
also be Inspected fully 1n the  VSI,

     Finally, there may be situations where releases of concern
from manufacturing processes or product storage areas  may  be
observed during the VSI.  The  Investigator should document and
photograph the presence of these releases.  It may be necessary
1n some cases to use CERCLA or  TSCA  Investigative or enforcement
authorities to address these releases*

     Field activities  should be photographed carefuly to document
all  visual observations.  This  will  be especially Important at
facilities where the VSI  represents  the last step In the RFA.
For  additional discussion of photographic  documentation proce-
dures,  refer  to Chapter 4, Section III.C.

      The Investigator  should obtain  Information on each poten-
tial  release  based  upon the five  categories of Information shown
In the  RFA  Information Matrix  (Exhibit  1-1): unit characteristics,
waste  characteristics, pollutant  migration pathways, evidence  of
release, and  exposure  potential.   The  following sections briefly
describe some  of the types of  Information  that may be  found in
each  of these  categories.
                               3-3

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A,   Qhtttlrtltia liiual Evidence of Unit Characteristics.

     The VSI can provide useful Information on unit character-
istics at RGRA facilities.  Observations concerning the Integrity,
location, and design of a unit can provide a great deal of Infor-
mation on thi likelihood that H has released*  For example,
above-ground tanks can be Inspected for the Integrity of seams and
for the presence of adequate secondary containment.  The Investi-
gator may be able to screen from further Investigation an above-
ground tank where these factors, In conjunction with the other four
categories* appear to be adequate to determine that no release of
hazardous wastes or constituents has occurred or Is occurring.

     Surface Impoundments should be Inspected for the adequacy of
berms, overtopping controls, and devises for the control of vola-
tile emissions*  Landfills should be Inspected for the presence
of runoff corttrolsi erosion around the un1t and the potential
for partlculate releases posing concern,   Irt genera! * 1t W111 not
be possible to visually assess these units for ground-water releases
during the VSI.  However, the Investigator should note any signif-
icant visible deterioration of containment liners.

B,   Obtaining Vlsu.j.1 Evidence of Kaste CMraclerl sties

     In general i 1t will not be possible to obtain a grlat deal
of Information during the VSI on waste charaetiMsties,  In cases
where the types of waste handled 1n a unit are not known* 1t will
seldom be possible to determine their eharaeteMstles threup,
visual observation.  These will be determined primarily during
the sampling visit ($V).  There will be sonte unusual eases,
however, wrtere the Investigator may find tanks or drums with
  jhels Indicating that they contain hazardous wastes or qonstl*
tuents.  These locations  should be documented carefully during
the VSI.

c.   Obtain Ing V1 s u a 1 E v 1 d e n c e o f P o 11 u.t a nt M11 r it Ian Itiiiw&y s

     The VSI will provide useful  Information  on potential
pollutant migration  pathways at the facility.  Facility charac-
teristics that  can facilitate  the movement  of releases  from the
Immediate area around a  unit but  have not  been Identified pre-
viously on  the  facility  map will  aften  be  apparent  during the
VSI.  For example, erosion gullies  at the  base of  landfills  or
surface 1mpoundments~"w111 provide direct  pathways  for  surface
water and soil  releases  from thef.e  units.   These  pathways will  be
especially  visible after  a recent precipitation event;  whenever
possible, VSIs  should bp  conducted  soon after such  events to  help
Identify these  runoff pathways.
                                3-4

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     The Investlgator should locate all  potential  migration path-
ways of concern on the facility map,   These win  be important
areas for sampling should 1t be necessary to conduct a SV at
these units*  In  addition, the Investigator should correlate
photographs of these pathways and their  documentation on the map
whenever possible,

D.   ObtjilHltig Visual Evidence of Release

     The Investigator should Inspect  the entire facility for
visual evidence of release.  While 1t will  not always be possible
to determine conclusively that a release has occurred based on
visual evidence,  such evidence can provide  a strong Indication
that one has occurred.  Visual evidence  of  release, coupled with
Information Indicating that a unit contained hazardous consti-
tuents, will often be sufficient to compel  further Investigation
In an RF!.

     The Investigator should look for obvious signs of release,
such ssr discolored soils, dead vegetation  or animals, etc*  The
media-specific chapters describe 1n detail  the types Of visual
evidence that may be apparent at various types of waste management
units.

E.   Obta1 ntng VItual Evidence .of Ixta&yre PjiMtial

     The VSI will provide only limited 1 nf oirmititin OH eapfcsure
potential at the facility.  The VSI should Include an Investiga-
tion of the area around the facility to deterilfte 1f there arS
potential off-site releases and documenting ivldeftfee Of such
releases.   In most casts, the PR will have Identlfiid whether
there are nearby residences, streams, and lakes*  At a minimum,
the  VSI should note any locations not Identified  1rt the PR where
the  public  could be exposed to releases.


IV.  DETERMINING THE NEED FOR FURTHER ACTION DURING THE RFA

     The results of the VSI should bf Incorporated  1nttt the draft
RFA  report  begun upon completing the PR.  The results of the  PR
and  the VSI together will provide sufficient evidence for  each
potential release of concern to determine either:,1) the need  for
a  sampling  visit  (SV) 1n  the RFA, 2) the need for Interim  measures,
3}  ,,ne need for further Investigation In an RFl,  or 4) the  need
for  no further action,   it  1s crucial that the Investigator document
the  results of the VSI 1n a concise and thorough  manner  In  the
RFA  report.  These data,  together with  Information  obtained during
the  PR, must be sufficient  to support decisions regarding  the
necessity of additional action at the facility, and are  likely
to  be closely  scrutinized or possibly challenged*   As stated
previously, the RFA  report  will be the  primary legal  document
supporting  the Agency's  Initial corrective  action  activities  at
the  facility.  Incomplete,  contradictory,  or  obscure  Information
1n  the RFA  report may Jeopardize the Agency's position.
                                3-S

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     Thi following sections discuss each of the possible recommen-
dations that can be made after completing the PR and the VSI,

A,   DetgrMitHfifl the Need for a Sampling Vjsjt

     By the end of the VSt, the Investigator will  have collected
Information on eacH potential release of concern and w11l  have
made a prel 1?n1 nary evaluation concerning the 11ke11hood of release
at each location.  He/she will also have Identified Important
data gaps that Interfer with the ability to make an enforceable
determination of release potential.  In many cases, the Investi-
gator will  recommend the collection of new environmental samples
from the facility during the'RFA to support his/her recommenda-
tions for further action during the RCRA corrective action process.

     The need for sampling at specific units will  depend upon
several Important factors, Indudlngr the complexity of the unit
and environmental setting, the quantity and quality of Information
gathered during the PR And VSI, the preliminary recommendations
for further action at the facility, and the cooperatlveness of
the owner/operator.  The Investigator must consider these factors
and rely upon his/her professional Judgment 1h determining when
and where'It will be useful to co'lect samples 1n the S.V.

     The preliminary recommendations for further action at a
facility can play an Important role 1n determining thg need for
and extent of sampling 1n the sv.  If the Investigator believes
that a SWHU may have a release he/she may want to cdllefct samples
in the SV to support the decision to require further Investigation,
Sampling conducted during a SV can be an Important supplement  to
Information gathered during the PR and VSI, and provide the docu-
mentation necessary for developing enforceable permit conditions.

     On the other hand, If the Investigator believes It is unlikely
that a SWMU has released or that other areas actually present
problems, he/she may make a preliminary r-eeommendatf(SH tHat the
unit will not need Investigation 1n an RFI.   It will often be
useful to support this recommendation with appropriate environ-
mental samples at the unit which will demonstrate thit there  1s no
evidence that a release of concern 1s present,  this will provide
valuable evidence to support  the Investigator's recoftimendatlcn
should It be contested In a public hearing,   It 1s Hfeely to  be
just as Important to sample at units which will not rfequlre an
RF! as at those .,'here one will be  required.

     There will be situations where the Investigator mafc8 a  pre-
liminary recommendation that  a unit should be  Investigated in  an
RFI without actual sampling data demonstrating  a release,  in  some
cases, 1t may be possible to  make  this  recommendation without
taking additional samples In  a SV,  More typically, however^  the
Investigator will take samples at  these units  1n order  to demon-
strate that a release has occurred.  More enforceable permit
conditions or enforcement orders can be developed  when  supported
by sampling evidence.
                               3-6

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     Taking environmental samples will be especially important
when the Investigator believes the owner/operator will be unlikely
to cooperate lit conducting an RFI at the facility.  When the
owner/operator's cooperativeness is questionable, the investigator
should usually take samoles to support recommendations for further
slips 1n the corrective action process, in ease these recommenda-
tions are contested 1n an administrative hearing,  Even the most
cooperative owner/operator, however, can challenge permit condi-
tions which are not supported by strong evidence.

B   Determining the Need for Interim Measures

     The investigator can recommend Imp1ementat'on of interim
measures at any time during the RFA, although he/she may not
have sufficient information prior to the VSI to'make this recom-
mendation.  Interim measures should be conducted at the facility
whenever there may be a significant risk of Immediate exposure
resulting from. re1eases at the facility.  Interim measures typically
i-.iclude such actions as repacking damaged drums, requiring safety
precautions for workers at the facility, or fencing off areas of
concerts near the facility.

     Details on planning and implementing Interim measures can be
found in the RC|A |3Q08(h) Corrective Ac11 dfi .Qr-decs....LfttAr?.tft fteas-
ares Bu1dan&e"TBraft]  Tiie TfTvestigator. sHpdld tnHsylt fctl'-ts
TFocumerTt wfien aef fir-mi n1 ng the need for such Immediate actions a*
a facility.  Interim measures are applicable to a fsfelllty Whether
it Is conducting corrective action under -3009(h), 3Qd4(uh or
3Q04(v).

C .   Piterml n 1 n g the Need for a Retned 1 a 1 investl tatlon

     Releases and likely releases that are Identified during the
RFA as requiring further Investigation w111 be fully character-
ized during the remedial Investigation phase of the RCt^M correc-
tive action process.  The RFI will be conducted by the owner/
operator and may be an extremely resource Intensive activity.
For this reason, it will be necessary to ensure that recommenda-
tions for RFIs at facilities are supported by sufficient evidence
collected during the PR, the VSI, and the SV.   In most Situations,
the investigator will choose to collect  samples at questionable
units in order to support recommendations at the nd of the RFA.

     There will be cases, however,, where! the Investigator will
recommend an RFI for particular units without collecting additional
samples in an SV.  This will usually take place at facilities
where it was possible to evaluate a large amount of high quality
evidence of release during the PR and VSI.  In these cases, the
existing evidence of release must be sufficient to stand alone,
without supplemental sampling, in justifying an RFI.  EPA should
collect additional sampling data whenever necessary, to develop
strong enforceable permit conditions.
                               3-7

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                           CHAPTER FOUR

                  CONDUCTING THE SAHPL1N6 VISIT


t,   INTRODUCTION

A,   Purpose

     The sampling v sit (SV) Is the third step of the three-step
RFA process  designed to Identify releases at RCRA facilities.
The SV focuses on collecting additional sampling Information to
fill  data gaps that remain upon completion of the PR and VS1 to
enable the Investigator to make release determinations In the  RFA,

     By the end of the SV, the Investigator will have completed
the first phsse of the RCRA corrective action process, and should
have Identified all releases or potential releases requiring
further Investigation at a facility.

B.   Scope

     The scope of the SV 1s limited.  It 1s EPA's objective to
focus the collection and analysis of new sampling data 1n making
preliminary release determinations* and rely upon existing Infor-
mation sources Identified in f.he PR and technical judgments as
much as possible.  By identifying specific areas where new Infor-
mation is needed during the PR and VSI, 1t should be possible  to
conduct focused, limited SVs that will enable the Investigator
to identify releases.  EPA will dsfer major new data gathering
efforts to th RCRA Facility Investigation (RFI) phase of the  cor-
rective action process.

     As discussed previously, the RFA should examine each SWMU or
group of SWMUs at a facility.  It will seldom be necessary to
investigate each SWMU in a SV, as the PR and VSI will often pro-
vide sufficient information to make release determinations.

     The extent of the SV at a facility will vary on a case-by-
case basis, and will depend upon the amount and quaMty of Infor-
mation gathered in the PR and VSI.  The Investigator's professional
judgment regarding the amount of information necessary to make an
initial release determination will influence the exterit of the
SV,  These determinations should consider a number of factors
Including the degree of owner/operator cooperation and the
regulatory action planned for requiring further action.  While
investigators are encouraged to minimize the amount of sampling
conducted during the SV, certain situations may require extensive
sampl1ng.

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     As discussed  1n Chapter One,  Regions  may  rely  under  special
c1 rcumstances upon facility  owner/operators  to develop  a  sampling
plan and to conduct  sampling and  analysis  activities  during  the
SV.  In these cases, the Regions  should  review and  approve  the
owner/operator activities to ensure the  quality of  the  new  data.
This chapter describes these oversight  responsibilities.

     This chapter  provides guidance to  the Investigator on  the
following aspects  of an SV;

     (1)  Developing a sampling plan;

     (2)  Preparing  for the  sampling visit;

     (3)  Conducting the sampling  visit; and

     (4)  Making final RFA recommendations for further  action.

C    Product

     The results of  the SV should  be Incorporated Into  the  draft
RFA report begun after the PR and  VSI  activities.  Because  the
objectives of the  SV are to  fill  data  gaps Identified previously
and to assist the  Investigator 1n  making final recommendations  at
the facility, 1t should be a straightforward matter to  Integrate
the SV findings Into the RFA report.


II.  DEVELOPING A  SAMPLING PLAN

     One of the major p'Tposes of the  PR and VSI is to  make a
preliminary assessment of the need for further Investigation at
locations of concern throughout the facility and to focus the SV.
This section describes the major factors In developing  a sampling
plan:

     (1) How to determine the need for collecting sampling
         Information during an SV; and

     (2) How to develop a sampling plan for the facility where
         appropriate.

A.    Determining the Need for Sampling at Fad 11 ties

     The need for additional sampling of potential  releases of
concern will vary on a case-by-case basis, and the Investigator
should rely upon best professional judgment in determining  when
it  will be appropriate.  The investigator may choose to sample  In
these situations:

     o  to collect  additional information to suppport a determlna
        *1on that  a unit or facility does not need an RF I;
                               4-2

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     o  to collect additional  Information  when  the  Investigator
        1s unsure whether a release has  occurred;  and

     o  to collect additional  Information  to  confirm a  determina-
        tion of release and to compel  an owner/operator to  begin
        an RFI (or some other  further  action).

     In some cases, the Information gathered  In the PR  and  VSI
may provide sufficient evidence to Indicate the need for an RFI  at
a facility, or conversely, that no further action  1s necessary  at
a facility.  For example, if previous  ground-water  monitoring
results clearly Indicate that  an old,  closed  landfill  has released
hazardous constituents to a surficlal  aquifer,  the  Investigator
will have sufficient evidence  to compel  the owner/operator  to
conduct an RFI at the unit, and it will  not be  necessary to conduct
additional sampling.  Facility records reviewed during  the  PR may
indicate that an old, closed surface impoundment never  contained
hazardous constituents, and ground-water monitoring data Indicate
that the SWMU has not released.  In this case,  also, 1t would not
he necessary to take samples to support  a  determination that no
further action 1s necessary at this time.

     In many cases, the Information gathered  1n the PR  and  VSI
will not be sufficient to enable the investigator  to determine
conclusively that a SMMU has or has not  released.   For  example,  a
facility may have clean closed a surface Impoundment several
years ago that once contained  sludges  analyzed  to  be marginally
EP toxic for a heavy metal.  It may not  be clear whether or not
the Impoundment released constituents  to the  ground water 1n the
past, or whether any contaminated soil remains  which could  leach
contaminants to the ground water.  It  may be  necessary  to sample
the soils around the closed unit or to sample the  ground water
(from existing wells) downgradient from the unit 1n order to
identify a release.

     Sampling may also be necessary at SWMUs  where records  do  not
Indicate what wastes were disposed in  them.  Old landfills  and
surface Impoundments without information on prior  wastes may
require sampling; however, due to the  danger  involved when  coring
or drilling Into o7d waste, this 1s best left for  an RFI.

     In cases such as the previous one,  the Investigator may
determine, based upon best professional  judgment,  that  a release
is likely to hsve occurred at  a unit.   At facilities with coopera-
tive own,.*"/operators, 1t may be possible to move directly to an
RFI without collecting new sampling Information, even though the
evidence does not conclusively indicate that  a  release has  oc-
curred.  However, at some facilities,  it may  be necessary to
conduct sampling 1n the SV 1n  order to confirm or deny the  pres~
ence of a release before moving further in the  corrective action
process.
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B.   Developing a Sampling Plan

     The sampling plan will  be the primary  document  directing  the
collection of additional  Information  1n  the SV.   When  the  Inves-
tigator determines that sampling 1s necessary  at  a  facility,  1t
will  be Important to clearly specify  the data  that  are required
and the reasons for obtaining 1t.  Investigators  should remain
focused on the objectives of collecting  additional  Information at
each  unit, because the choice and extent of sampling locations,
methods, and parameters will be critical to their ability  to  make
meaningful release determinations.

     The sampling plan should be developed  to  collect  evidence
the Investigator needs to make a release determination at  a  SWMU,
group of SWMUs, or other locations of concern.  This may Involve
collecting direct evidence  (e.g., air samples  from above or
around a surface Impoundment) or Indirect evidence (e,g, ground-
water sampling at a well  downgradlent from  the SWMU) of a  release.
In most cases, the investigator will  collect samples from  the
waste source and/or from an environmental medium, and  based  upon
knowledge of the pollutant migration  pathway,  deduce the likelihood
that  the constituent originated 1n the SWMU.

     The sampling plan may be developed  by  EPA,  a contractor,  the
owner/operator, or a combination of these,  depending upon  the
situation.  In all cases, EPA should  review and  approve the
sampling plan carefully before Initiating sampling activities.
Even  1n cases where EPA develops the  sampling  plan, It 1s  Impor-
tant  to review the plan 1n order to ensure  that  1t meets Its
Intended objectives.  Due to the cost and time Involved 1n an SV,
H may be necessary to revise sampling plans several times through
an Iterative process before finally oeglnnlng  work.

     The remainder of this  section describes how toi

     (1) determine the extent and locations of sampling at the
         facility;

     (2) determine sampling methods and  parameters;

     (3) format the sampling plan; and

     (4) review sampling plans.

1,   Pete r mIn1n g t he Ex tentand Locations
     of SampTTn g at Tfte Fac 11 fTy~"

     Once the Investigator  has determined the need to  collect
additional Information at various SWMUs or other areas of concern,
he/she will need to determine how much  sampling will  be necessary.
As stated previously, Headquarters encourages the Regions and
States to limit the amount  of sampling  Information collected
during the SV to that necessary to support a  release  determination.
                               4-4

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Because of thi time and personnel  required  t
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Agency w11l rqu1re strong data when defending Its  actions  1n  a
public hearing,

2.   Choosing SaniplIng Methods and Parameters

     The Investigator should choose appropriate sampling methods
and parameters during the SV 1n order to obtain meaningful  sam-
pling results.  The sampling plan should specify what  methods  and
parameters will bt used at each sampling location at the facility.
It should also specify the number of samples to be  taken at each
sampling point (sampling SOPs and QA/QC guidelines  are discussed
later 1n this chapter).  The media-specific chapters describe
many of the sampling methods which w111 be most valuable during
the SV and the criteria for choosing them.

     In general* 1t will be possible to choose sampling techniques
and parameters which provide Information on the unit ranging from
general Indications of a release to precise, quantitative evidence
of a release.  In some cases, It may be appropriate to take
screening level measurements (e.g., a VQC measurement  with  an  hNU
photolonlzer), while In other cases H may be necessary to  sample
for specific  organic or Inorganic compounds.  As stated previously,
sampling for  specific compounds will generally provide the  most
useful results during the SV.  Thfs will aid In developing  a
more defensible Remedial Investigation Plan,

     Sampling for Indicator parameters such as total organic
halogens (TOX), conductivity, or pH may be useful when the
Investigator  has little or no Idea what wastes may have been
released to a medium.  However, these parameters can give only
limited Information a/id will not provide sufficient evidence of
release 1n most cases.  Whenever possible, 1t will  be advantageous
to Identify the constituents of concern at each SMWU arid sample
for those specific parameters.

     The Investigator should choose those sampling methods that
will provide  the most usable results.   In some cases, there may
only be one method appropriate for sampling a specific medium
(e.g., the presence of methane 1s normally monitored w,1th a
combustible gas meter).  However, there will be cases where
several methods may provide evidence of release.

     For example, when  Investigating ground-water releases from
old landfills where existing monitoring wells ar present, the
Investigator  should sample the ground  water  1n order to Identify
releases.  However, existing monitoring wells may not always be
located sufficiently close to SWMUs to  provide meaningful data  on
releases.  In these cases, It may be necessary to take a number
of soil samples around the unit  and/or  1n the unsaturated  zone
beneath the landfill 1n order to Identify evidence  of releases.
Alternatively, there may be  Instances  where  electromagnetic
conductivity  (EM) testing or soil gas  testing will  provide useful
screening  level Information  on prior releases  at such units.
Finally, there may be unusual situations  where the  Investigator
                               4-6

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will need to drill new ground-water monitoring wells in order to
obtain Information on ground-water contamination.   The Investigator
should be familiar with each of the potentially appropriate
sampling techniques and choose the best ones for each situation,
The media-specific chapters provide details on how to choose
appropriate sampling techniques.

3,   FQrmit f Q r S ampj 1 n g Plan

     The sampling plan should be clear and understandable and
present logical actions for meeting the sampling objectives
at each SWMU, group of SWMUs, or other locations of concern.  The
Investigator should organize the sampling plan to Identify the
actions to be taken at the facility*  Depending upon the facility
characteristics* It may be appropriate to organize 1t by location
or by sampling technique.  ?or example, there could be sections
for each SWMU that describe all of the sampling activities asso-
ciated with 1t; alternatively, there would b a section on soil
sampling that Identifies all of the locations and methodologies
for sampling the soil throughout the facility.

     The sampling plan should Include Information on each of the
following factors:

     o  Field operation

        The sampling plan should discuss the sequence for conducting
        the field activities.

     o  S imp 11 ji g 1 oea 11 ons / r a t j o ni a Le

        As precisely as possible, the sampling plan, should Iden-
        tify the location of each sample.  A site map should be
        prepared to guide the Investigator to the appropriate
        locations.  Specific sampling methods, the number of
        samples, the parameters being sampled, and a description
        of the objtctlves for each  sampling activity should  be
        Included 1n the sampling plan.

     o  AJTajjftHa 1 requirements

        The sampling plan should discuss the technique and level
        of detection that will be used to analyze each sample.

     o  Sample _hand 11 njt

        Sample preservation and other handling practices  should
        be described.
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    o  Quil 11* iMtiuPJtnAt/gut 1 Ity eont ro 1

       Tha plan should Identify the number and type of quality
       asiufinei samples, specifically the number of blanks,
       duplieatis, or spikes that will bi taken.  The specific
       QA/QC  guidelines to be followed 1n this program are to
       be stipulated by each Region,

    0  iplppint decontamlnation

       The sampling plan  should Identify the  reagents and any
       special procedures associated with equipment decontamina-
       tion*

    o  Chjiln  of custody

       All samples collected  (Including blanks and  spikes) must
       be maintained under cha1n-of-custody  procedures.  Chain-
       of-custody  minimizes  the potential for damaging or losing
       samples before they are analyzed.  Chalrt-of-custody tracks
       the possession of  a sample  from  the time  of  col lection,
       through all transfers  of custody, to  when  it Is received
       1n the laboratory, where internal laboratory ehain-of-
       custody procedures take over*   Investigators should gen-
       erally follow  regional  protocols for  chain-of-Custody
       procedures.

4.    Revi tw i ft g a  SafflP 1 1 n gP. 1 aji

     The  investigator  should  review the  sampling  plan  carefully
to  ensure  that it  meets  EPA's  objectives at each  unit  being
sampled.   The  Investigator should  be  sure thft appropriate  sampling
methods and  locations  are  selected, and  that  the  ixtiftt of  sam-
pling  is  appropriate  for  the  determinations that  are made at  each
sampling  location.   This  will  be especially Important  when  the
owner/operator or  an  EPA  contractor develops  the  Sampling plan;
however,  even  when  the  EPA investigator  develops  th sampling
plan,  it  will  be  useful  to review  the plan  in order  to ensure Its
completeness.

     The  sampling  plan  also  describes the  level  of effort required
to  conduct the proposed  sampling  strategy.   This  information
is  usually presented  in  terms of  person/hours for each sampling
technique or  SWMU  Investigated, and may also  include an  estimate
of  the elapsed time and  the  total  costs.


III. PREPARING FOR THE  SAMPLING VISIT

     The  Investigator should  plan  a number  of activities  prior to
initiating the SV activities  at a  site.  Once the sampling plan
has been  completed, reviewed, and  finalized,  the Investigator can
make plans to begfn the  ons1te activities.   These plans  will
1nclude:
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     (1)   Gaining  facility  access;

     (2)   Handling commufHty  relations  (1f  appropriate);

     (3)   Pfepi^ng a  safety  planj  and

     (4)   Specifying EPA oversight  of  owner/operator  sampling
          activities.

A.   QalnlfitEMU 1 ty  Access

     Prior to conducting the  field  work,  the Investigator should
contact the owner/operator  to schedule  a  time for the 3V  team
to enter  the site  and  perform the necessary field activities.
Although  EPA staff may already be coordinating activities for  the
RFA with  the owner/operator,  the appropriate regional person
should contact the owner/operator to verify dates and describe the
nature of the field actlv1t1es--samp1e col lection, photographic
documentation, facility Inspection, and/or  Instrument monitoring.

     If the owner/operator  1s responsible for collecting  artd
analyzing the satnples, then the EPA official ihould ddntaat the
owner/operator to schedule  a date to overset thi flild activities.
The agency should send the  sampling plan and proGidufis for
performing the sample collection to thi owrtif/ipirater suffi-
ciently ahead of time for htm to obtain the ippfipflate support*
If EPA Is collecting and analyzing the sawiplis, IPA Should offer
the owner/operator a split  of all samples coltietid*   If  thi
owner/operator wllhfs to hive splits, IPA should IftStfujst Him to
provide analytical sample bottles for the splits*

     After completing these arrangement?, IPA sheuld Sirtd a
letter to the owner/operator confirming th? dates arid field
activities.   If access  Is denied, Appendix D provides guidance
on how to obtain  access to a facility.

     In some  cases It may be necessary to access  adjacent or
nearby properties  1n order to conduct a visual Infpietlen or
collect samples.   SPA should provide verbal as wilt  as written
notification  of the dates and nature of the work  to  owners of
these  properties.

     Although the  RCRA  Investigator 1s authorized to  Inspect  a
facility  and  collect  samples and photographs, the owner/operator
can require  the Investigator to  conduct the  Inspection and  sample
collection  activities to protect his legitimate  rights.   The
adm1ss1b111ty of  data 1n court may  later be  challenged 1f data
are collected In  violation of the  owner/operator's constitu-
tional rights.  The owner/operator  can observe  Inspection  activi-
ties,  unless  he Interferes with  the safe,  or  technically  sound,
conduct at  the  sampling visit.
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     The ownef7Gp:efafor has the right to request confidential
treatment of Confidential Business Information (CBI),  Ordinarily,
environmental monitoring data are not confidential.  If data
deemed confidential by the owner/operator are needed to properly
evaluate the facility, then the Investigator should include a
precise description of the confidential  data In the field log
book.  The investigator should Instruct  the owner/operator to
follow up with a letter Identifying the  confidential data and
explaining the reason why the data are business confidential*
EPA regulations governing treatment and  handling of confidential
data are delineated 1n 40 CFR Part 2, Subpart B, Sections 2,201
through 2,309.

B-   C orom.u.n 1 t,yr .tflla 1 1 on s

     If 1t 1s necessary to conduct field activities 1n or near
residential or non*1 ndustrl al business areas, then the agency
should contact the appropriate local officials ahead cif time*
ft is difficult to remain unobtrusive while conducting site
inspections, particularly 1f field workers are wearing protective
clothing.  Moreover, the presence of "official" people collecting
samples can c'iuse  alarm.  In some cases* 1t Will Be difficult fco
prevent th1? but prior, well-handled eeifiwynity eorttact can rttlfilmlze
the alarm,

     The Office of Sdlld Waste Is preparing guidance on community
relations that w1H be available later this year*  thi dtfcurtent
will provide specific guidance on when and how to  Implement a
community relations prdgram  at RCRA  facilities.

C.   P r e B M 1 fin. a S a f My .P.I an

     Agency personnel should prepare a safety plan  for each sam-
pling visit 1n accordance with appropriate IPA guidance!  the
safety plan 1s usually prepared last and 1s tailored t
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     o  Describe Known Hazards  and  Risks
     o  1.1st Key Personnel  and  Alternates
     o  Identify livjls of  Protection to  be  Worn
     o  Identify Work  Areas
     o  identify Access Control  Procedures
     o  06161*1111 fJieontamlnation Procedures
     o  DeseHtis Site  Monitoring Program
     o  Identify Special  Training    julred
     o  Describe Heather-Related Precautions

     EPA personnel  should participate 1n  an  Agency-sponsored
safety course before visiting a  site,

0.   EPA QyerslgAt  .of  Owner/Operator Sampling Activities

     The sampling visit plan should Include  provisions for EPA
oversight when the  owner/operator conducts  the sampling activities.
The level of IPA involvement will depend  upon the extent of
sampling, tHe complexity of the  1tif and  the eoeperitlveness of
the owner/operator*  In some cases, IPA may  believe that the
owner/operator can  be  counted on to provide  reliable results*  in
such situations* 6PA oversight  of the sampling activities Way Be
limited to presence at the  facility during  one dly of the siatfipt 1ng
only.   In other cases, 1t may be necessary  to provide IPA presence
at the facility it  ail times during the limptlrtg  activities*   The
investigator sheuld tafce splits  of  all samples ealliited by the
owner/operator,


IV.  CONDUCTING THE SAMPLIM6 VISIT

     The Investigator  way begin  the site  activities once heVsHe
has completed all of the preliminary activities*   fHef sawpllng
visit  involves gaining access to the site,  performing the sampling
activities, taking  photographs  of all activities* keeping the SV
portion of the logbook, preparing samples  for shipment and analysis,
and, finally, decontam1nat1on/demob111*at1on.

A.   PreUjnlnary Site  Activities

     The Investigator  should meet with the owner/operatar prior
to entering the facility to conduct sampling'*  fhi Ifivestlfator
will already have conducted a VSI*.  therefore, the otfrtSrVoperator
should have some understanding of the corrective action process
from the Initial meeting with the 1nvest1gator(s)  However, the
Investigator should be prepared to answer questions concerning
his/her plans for sampling,  In cases where the otfner/operator
will conduct the sampling, the Investigator can frtake the arrange-
ments  to accompany  him/her at this time.   In addition, the Inves-
tigator should offer to provide the owner/operator with duplicate
samples,
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     This In^iitifttor should fallow the sampling plan once he/she
has gained ifeif is to the facility*  Tha sampling plan should
describe all df the Sampling locations, methods, and procedures
to be followed*  If, for any reastin, 1t 1s necessary to diverge
from the sampling plan, changes should be documented carefully.
             s^ of who performs the sample collection, continuous
monitoring for vapor emissions 1s needed to detect air releases
from sampl1rtg\iet1 vltles .   If the owner/operator 1s collecting
the samples* EPA/State Investigators should document precisely the
sequence of sampling activities, the procedures and Instruments
used, and describe the samples (Including location, depth,
appearance, etc*).

     The EPA Regional offices have developed SQPs for most SV
sampling tasks under the CERCLA PA/SI program*  In addition* EPA's
Office of Waste Programs Envorcement (QSiiPf) has developed the
RCRA Ground jUtt r M.gn .1 toMng Tech n .1 Ml.lMilMMiliJL JJJJ J Mft &* 4? ? M ~
ijjent (fE6b)ta provide guidance on well iptillaflcm attd Saljillrig
procedures; EPA/SH-846 also provides sampling aM arfilysls pffoee-
dures for media rfievant to the SV*  Nr the iSsi pari| Ihise
SOPs are applicable to SCRA field af>.1Vlt1*S*. If fHe SdPf ars
not applicable of appropriate fur. the partleultf field iellvHy,
then a new SOP should be developed*  Whire rtiodlf Uftlps tb
existing SOPs are made*, they should be noted In ths field 1gbotik*

C.
     Investigators should use regular 3Smm cameras for talMng
photographs,  they Should not use filters, as tHf| tertd ts dis
color the picture Shd may unfairly bias the result bf iikiffg
leachate seeps or lagoons look different from fell Mlfeh  tne
Investigator should Identify and record 1n the flilasssk the
exact type of camera (Including 1*d, number), fili .H*i** N"5
ASA 200), and the lens used.  Photographs taken witH UrtUSual
lenses (e.g*, wide-angle) are not admissible in
     Photographs should be taken to document the p|1t1on of
the facility and procedures used 1n Inspection  activities*
Particular emphasis should be placed on matters Identified 1n
the work plan.  Types of pictures that should be tafclfif  Include
     o  Representative overall p1cture{s)  of  facility*
     o  Posted signs Identifying ownership  of  facility;
     o  Evidence of releases--leachate  seeps,  pools,  discolored
        water, or strained  soils;
     o  Individual unl ts--lagoons ,  drums,  landfills,  etc.;
     o  Visual evidence of  poor  facility maintenance;
     o  Adjacent land use;  and
     o  Area that unauthorized persons  can  easily  access.
                                4-12

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o.
     Ths 1e|bo0k ii ; ^rhaps the most important document produced
during the V  It serves as a basis for integrating the SV
results intti the ftFA report, most importantly, supporting the
work done arid rfsults obtained in any future legal  proceedings
under ftCRA Or
     A unique logbook should be developed for each site and each
v'sit to the site.  Logbooks should be bound and each page sequen-
tially numbered.  Entries into the logbook should be chronological
-- a time notation ;shou1 d introduce each entry.  The logbooks
should be maintained with indelible ink.

     The following types of entries should be made in the logbook:

     o  A11 personnel on site during each phase of the on site
        work;

     o  All instruments used during the field work with unique
        idehtif ication numbers;

     o  Description o^ film used;

     o  Description of the weather and changes in the weather;
                                                    
     o  Material  observations related to Items identified In the
        work plan;

     o  Results of field measurementsdistances t instrument
        readings, well measurements, locations-,

     o  Factual descriptions of structures and features --well Is
        and well  construction, units, contiinment sf fuetures ,
        buildings, roads, topographic and gfeomorpMc features,
        locations;

     o  Signs of  contam1nation--ony discharges,  discolored  sur-
        faces, dead  or stressed vegetation;

     o  Sketches  of  facility layout, structured  features  and
        points, of  contamination;

     o  Map of facility showing point and direction of photo-
        graphs;

     o  Location  and  time of each  sample; and

     o  Any other  relevant  items.
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E   S aMii ii ih Iftilifii/lAftfil e Ana ly s 1 s

     Uport eomplitloh of the dnslte work EPA or the owner/operator
should deliver- ill samples to the laboratory for analysis,  SOPs
covering siiiplf shipping are available In each of the regional
offices or 1H IF'A safety training manuals.  T>  time Involved  In
analyzing samples can vary from 40 days to tht^e to four months.

F .   DecoJMiitvall on /Demob 11 1 zat1 on

     Decontamination of persons and equipment occurs not only  at
the completion of all field work but each time persons exit the
site, Including rest breaks.

     In many cases, decontamination may be very simple, e.g.,
removing dispossbte coveralls and washing field hoists.  Decon-
tamination after  sampling activities will usual ly Irtel tide decon-
tamination of field persons, and sampling and field equipment.

     A11 clothing and support materials that wilt n0t be reused
should be containerized either for transport and eventual off-site
disposal or for on-site disposal.


V,   FINAL RFA RECOMMENDATIONS FOR FURTHER Aef!0
     The final task in the RFA  proetss  1s  tti nsal|e
concerning the need for further  aetiofis  sit  iHt  fielliiy*   These
recommendations include:   (1) taking no  further  leiHgrij  (2)  fetiri- 
ducting an RF1 to Identify the  rate and  extent  erf  fflfl^fs from
SWHUs, groups of SWMUs . or other  releases  of e$ftfce"fnj  l|)  planning
and implementing interim measures  at the facility;  0j-  |4)  referring
the further Investigation  and control of permitted
or other unusual releases  to other erivl ronmentii  profraW
The Investigator will have completed the RFA sflly  sftif
dations have been made which cover all  potential  re*1iISe!$
concern Investigated in the RFA;
     In order to make  these  reciommendations,  the
may matte determinations  concerning  the  Ilkenfjs^cj  of f-eiliase
for some SMMUs after completing  the PR  and  VSt .   !H  dINr eases ,
it will not be oossible  to, make  determinations  until satlpHng
results from the* SV have  been  evaluated,   We  discuss y|1ow how to
make final release determinations  at  the  end  of  the  RM arid how
to make recommendations  for  further action.

A ,   Making RFA Release  Determinations

1 .   Evaluating Sampl ing  Results from SV  Act! vltles

     The first step in making  an RFA  release  determination will
require the investigator  to  use  best  professional  judgment in
evaluating the sampling  results  from  the  SV.   This evaluation
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should be straightforward as long as  the sampling plan was  devel-
oped correctly, e.g., sampling points were selected to provide
       additional  evidence to support this determination.
     After the laboratory completes Its analysis,  the Investigator
can evaluate the validity of the analytical  results from the
*ampl1ru, activities.   When EPA conducts the  sampling, preliminary
review of analytical  data Involves ensuring  that all  dellverables
required by the CLP ar<* Included In the data package, checking
that all forms are completed within the requirements  of the
contract,, ar
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to Identify one constituent that 1s  present  1n  both a  SMMU  and  In
the migration pathway to support a release determination.
The Investigator does not need to demonstrate with  statistical
confidence thit the SWMU has released  during the RFA.

B.   HaMng Recommendations for Each ShlMU or Group  of  SWMUs

     The final step 1n the RFA will  entail making recommendations
co  ernlng the need for further Investigations  under the corrective
action authority, based upon the release determinations  described
above.  This section describes each  of the four possible recommen-
dations below: no further Investigation, Investigate further 1n
an Rrl, plan and Implement interim corrective measures,  and refer
the control of a permitted release to  another environmental
program office,

i.   No Further Invest,1 gat Ion

     Investigators may conclude that a SHMU, a  grouping  of  SWMUs,
or an entire facility does not require further  Investigation
based on the Information available from the PR  and  a visual In-
spection.  In some cases 1t will be advisable to collect some
sampling and analytical data to confirm that a  unit or area has
not created a release that poses a threat to human  health and the
environment.  For many SWMUs, the determination that- no  further
Investigation 1s necessary will be relatively simple and straight-
forward .

     Some units will have design and operating  characteristics
which will effectively prevent releases to the  environment.  For
example, a wastewater treatment unit way have a cover to prevent
the release of VOCs to the air; such a unit would not require
further Investigation for air releases,

     SWHUs which never contained constituents of concern will
not require further investigation.

     It is also appropriate to eliminate certain units from
further study on the basis that they clearly have not released
hazardous wastes or constituents Into the environment.  Examples
of such units Include elevated tanks and, 1n some cases, surface
level storage tanks.  In the case of aboveground tanks,  unit
design and operation, plus the inspector's direct knowledge 0f
the facility, can provide sound evidence that the unit has not
caused a significant release.  It will rarely be possible  to make
such determinations for landfills and surface impoundments.  More
explicit information as to making a "r,o further action*  determina-
tion is presented In the media-specific chapters.
                               4-16

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2.   Investigate Releases Further 1n
     a RCRA Remedial  InvestTgatlon

     T'/ie Investigator should recommend that  a  SWMU or other
release be Investigated further 1n an RFI  when he/she identifies
a SWMU with a likelihood (or documented evidence)  of a release
which may pose a potential  threat to human health  and the environ-
ment.  He/she should  describe each SMWU and  the relevant  environ-
mental media which should be Investigated  1n the RFI,  It will be
Important 1n focusing the RFI to determine which media are of
concern for etch SWMU or potential release.

     There are situations where the facility as a  whote poses a
problem and where 1t  1s difficult to distinguish between  Individ-
ual  SWMUs as sources  of contamination.  In these cases, ft may be
more efficient to refer the entire facility  to the RFI and require
the owner/operator to Investigate the facility as  a whole.

3,   Adopt Interlm Measures

     The RFA should result 1n a recommendation to  adopt Interim
measures at the facility when the Investigator believes Immediate
action should be taken to protect human health or  the environment
from releases.  The Investigator should evaluate the severity of
the release and the proximity of potential receptors when assessing
the need for interim corrective measures.

     Temporary corrective measures may be  appropriate 1n  situa-
tions where there is  a release of hazardous  wastes or constituents
Into the environment  that is currently affecting or will  affect
target populations or sensitive environments and the release may
be temporarily or permanently arrested by  some type of interim
solutIon*

     The RCRA 3008(h) Corrective Action Orders Interim Measures
Guidance fcfraft) provides Tetail s on appropriate actions  to take
in situations where immediate action is needed.  Examples of
interim measures include: fencing a facility 1n order to prevent
direct contact with wastes; or stabilizing weak dikes to prevent
further surface water releases from Impoundments.   It Is  Important
that these units should be investigated further 1n an RFI 1n  order
to determine the adequacy of the Interim measure and/or to design
a permanent solution.

4.   Refer Permitted Release to Other Program Offices

     Permitted releases which may either directly or indirectly
be posing a threat to human health or the  environment should  be
referred to the State or Federal program office that Issued the
permit.  EPA has not developed guidelines  on such referrals,  thus
they should be conducted as necessary on a case-by-case basis.
When the other program office cannot or will not Investigate  or
control the release,  the investigator may  recommend that the
units be investigated in an RFI and/or that interim measures  be
Initiated.


                               4-17

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     When the RFA Identifies  contamination  resulting  from permit-
ted discharges or discharges  requiring permits  that  require
further Investigation 1n an RFI,  EPA will work  on  a  case-by-case
basis with the Regions and other  EPA permit programs  to  develop  a
solution to the contamination resulting from the  discharges.   For
example, when frequent violations of NPOES  permits 1n the past
have resulted 1n an accumulation  of hazardous materials  In stream
sediments, the RCRA Investigator  should work with  the NPDES  auth-
ority to develop a solution to the contamination.


V!.  FINAL RFA PRODUCT

     The final RFA report will document the activities undertaken
In the PR, VSI, and SV.  Many documents will be generated during
the SV, Including a sampling plan, safety  plan, sampling results,
an evaluation of the sampling results, and  release determinations
and recommendations for each unit.  All of  this Information
should be compiled Into the RFA report for  future reference
during further phases of the corrective action program.   Appen-
dix A provides a sample outline for the RFA report.
                               4-18

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                           CHAPTER FIVE

                           GROUND WATER
I.   INTRODUCTION

A.   Purpose

     This chapter provides technical  Information to support  the
Investigation of releases to ground water, with the exception of
releases from regulated units, during the RFA.   While Chapters Two
through Four provide general guidance on conducting an RFA,  this
chapter focuses OP specific factors unique to the ground-water
medium that should be considered by the Investigator.

B.   SjJjJM!?

     The scope of the RFA, discussed 1n Chapter One, extends to
all operating, closed, or closing RCRA facilities.  The Investi-
gator should evaluate the likelihood that a facility may have
releases to the ground water, with the exception of "regulated
units" (land disposal units that received wastes after July  26,
1982).  Releases to ground water from regulated units should be
addressed 1n permits according to the requirements of Subpart F
of Part 264 (or corresponding State regulations), rather than
through 3G04(u).  The Investigation of ground-water contamina-
tion from regulated units will not be part of the RFA.

     It 1s not the purpose of the RFA to Install Subpart F mon-
torlng wells 1n order to detect conclusively the presence of a
release.  It will usually be sufficient to demonstrate that  there
1s a likelihood of release from a specific unit to the ground
water 1n order to require further Investigations,  The Investi-
gator should rely upon best professional judgment when estab-
lishing evidence of release to ground water.

     This chapter 1s organized to reflect -the separate phases  of
the RFA process.  The first section describes the technical
factors that should be considered during the PR and VSI.  The
second section describes the technical approach to obtaining
additional sampling Information 1n the SV for ground water,  and
shtJild be consulted along with Chapter Three on conducting a
sampling visit.  The final section discusses factors to consider
when making release determinations for ground water  at the end  of
the RFA.  This section also presents options for  further Investi-
gation of ground-water releases to be evaluated at the end of  the
RFA.

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II.   CONOUCTINS A PRELIMINARY REVIEW AND  VISUAL  SITE
     INSPECTION OF SBQUND-WATER RELEASE  POTENTIAL

     This section presents technical  Information related  specif-
ically to the ground-water pathway to be  considered  when  conduct-
Ing  the preliminary review and visual site inspection.   Accordingly,
this section 1s organized to reflect the  primary goals  of the  PR
and  VS! described 1n Chapters Two i/jd Three:

     o  Identifying and describing potential  threats  to ground
        water at RCRA facilities; and

     o  Making a preliminary assessment  of the need  for further
        Investigations  at these facilities.

     This section reflects the Importance of  the five categories
of information to consider 1n conducting  RFAs presented 1n Exhibit
l-l.   It presents technical Information  specific to  the ground-
water pathway covering  the five areas and technical  Information
to help the Investigator determine when  additional  sampling will
he necessary 1n an SV to Identify ground-water releases.   The
section discusses each  area separately:

     (1)  Unit characteristics;

     (2)  Waste characteristics;

     (3)  Pollutant migration pathways;

     (4)  Evidence of release;

     (5)  Exposure potential; and

     (6)  Determining the need for additional sampling Information.

     This Information will be relevant to the evaluation of
written documents 1n the PR and Information gathered tn a VSI.
Consult Chapters Two and Three for general guidance  on How to
conduct PRs and VSIs.

A.   U n11 C Ear act er1s 11c s

     The design and operating characteristics of a unit will
determine to a great extent Its potential for releasing hazardous
constituents to ground  water.  Many  treatment,  storage, and
disposal units are designed to prevent releases to the environ-
ment.  The Investigator should evaluate the unit characteristics
of each SMWU or group of SMMUs at a  facility to determine Us
potential for releasing hazardous constituents  to ground water.

     The general potential for ground water contamination from
any unit depends, to a  great  extent, upon  its nature and function.
This concept 1s reflected  In  RCRA hazardous waste regulations.
For example, ground ^ater monitoring 1s not a requirement for
                                5-2

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container storagt units* while monitoring 1s required for land-
based units.  Therefore, 1n evaluating the likelihood of ground-
water releases from a unit, the Investigator should assess  each
unit based upon:

     o  An understanding of the overall  potential  of the unit
        to cause ground water releases;

     o  An understanding of the primary  mechanisms by which
        releases may occur from the unit; and

     o  An assessment of unit-specific factors which, singularly
        or 1n combination, Indicate the  relative likelihood of
        ground water releases from the unit*

     The Investigator should first consider the relative potential
of the unit to release.  Exhibit 5-1 presents a generalized rank-
ing, 1n rough descending order, of different types of units and
their overall potential for causing ground-water contamination,
It lists the most common mechanisms by which ground-water releases
can occur from each unit type.

     Exhibit 5-1 provides only a very theoretical  sense of the
relative potential for units to cause ground water releases.
Unit-specific factors should be evaluated In determining whether
further ground water Investigations are  needed for a particular
unit.

     The following unit-specific factors should be evaluated 1n
assessing a SMMU for ground water releases;

     {15  Unit design;  ,
     (2)  Operational history; and
     (3)  Physical Integrity of the unit.

     In making a unit assessment, the Investigator should consider
ways In which the above factors may combine to suggest whether or
not releases have occurred.  For example, examination of an above-
ground tank may reveal evidence of soil  contamination adjacent to
the unit-  However, the operational history of the unit reveals
that the tank has been 1n operation for only six months, the tank
1s 1n good condition, and records Indicate that the contamination
occurred as a single, relatively small overflow event.  Considera-
tion of all of these factors Indicates that, despite the evidence
of soil contamination, likelihood of a release to ground water Is
very remote, and furtiier remedial Investigations for ground water
may not be necessary.  The factors listed above are discussed  1n
more detail below.
                               5-3

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                           EXHIBIT 5-1

            8ANKIN8 OF UNIT POTENTIAL  FOR  GROUND  WATER
                RELEASES AND MECHANISMS  OF RELEASE
     Unit
          Release Mechanism
Class IV Injection

  Well



Surface Impoundment
Landfll 1
Land Treatment Unit
Underground Tank
Waste Pile
Class 1 Injection
  Well
Spillage or other releases from waste
handling operations at the well head
Escape of wastes from well casing
Wastes are Injected directly Into the
subsurface
Migration of wastes/constituents through
liners (1f present) and soils
Damage to liners
Overflow events and other spillage outside
the Impoundment
Seepage through dikes to surface and/or
subsurface

Migration of leachate through llnsrs
(1f present) and soils
Precipitation runoff to surrounding
surface and subsurface
Spills and other releases outside the
containment area from loading/unloading
operations

Migration of constituents through the
unsaturated zone
Precipitation runoff to surrounding
surface and subsurface

Tank shell failure
Leaks from piping and ancillary equipment
Spillage from coupling/uncoupling
operations
Overflow

Leachate migration through liner
(1f present) and soils
Precipitation runoff to surface/subsurface

Spillage or other  releases from waste
handling operations  at the well head
Escape of wastes from well casings
Migration of wastes  from the Injection  zone
through confining  geologic strata to upper
aqulfers
                               5-4

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                         EXHIBIT -1  (Continued)

              RANKING OF UNIT POTENTIAL FOR GROUND MATER
                  ALIASES AND MECHANISMS OF RELEASE
     Unit Typt
           Release Mechanism
In-ground Tanks
Container Storage
  Unit
Above Ground Tank
Inci nerator
o Overflow
o Tank wall failure
o Leaks from ancillary equipment
o Spillage from coupling/uncoupling operations

o Spills from containers/container failure
  subsequent migration through liner or base
  (If any) and soils
o Precipitation runoff from storage areas

o Overflow
o Shell fallure/corrosion
o Leaks from ancillary equipment
o Coupling/uncoupling operations

o Spillage or other releases from waste
  handling e*r preparation activities
o Spills due to meehanleai failure
                                   55

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1.   Unit Ms 140

     Evaluation of the unit's design should focus on the following
areas:

     o  The unit's capacity and dimensions;

     o  Materials, design, and construction of a unit;

     o  Any engineered features designed to prevent
        releases to ground waters and

     o  The adequacy of such features.

     The capacity and dimensions of a unit affect the potential
for a release 1n several  ways depending upon the unit type. A
large volume* shallow surface Impoundment 1s more likely to have
a release than a smaller capacity unit*  The shallow depth with
the large volume Indicates that there 1s a large surfaca area on
the bottom of the Impoundment.  Most releases occur through the
bottom by exflltratlon through a clay Itner or through leaks 1n  a
synthetic liner.  The larger the bottom surface, ths greater the
likelihood that bottom leaks or exflltratlon will oeeur.

     Some units have engineered features that will reduce the
potential for a release to ground water.  Landfills with double
liners and a leachate collection systtw will tte much less likely
to have a release to ground water than do either land-*based units
without liners or with single clay liners.  Some features In-
stalled to prevent ground water releases have different abilities
to do so effectively.  For example, single clay liners do not
prevent releases, but they delay the movement of leachate through
the less permeable clay layers,

2"   Operational History

     During the PR, the Investigator should evaluate the unit's
operational history for Information that Indicates a release to
ground water may have occurred.  Operational factors that may
Influence the likelihood of ground water releases Include;
                     PJt_ IJlJLUfl-lJL'  Units that have been managing
                        "~~
            -.._-   _      -
        wastes for long "p~e~rTodl T of time usually have a greater
        likelihood of releases than units that have been opera-
        ting for short periods of time.  For example, an under-
        ground tank that has been In service for six months will
        have a much smaller likelihood of leakage due to corrosion
        than will a twenty-year eld underground tank.

     0  Operational status.  In some cases, the operational
        status of a storage unit (e.g.  closed, Inactive, decom-
        missioned) may have an effect on the relative likelihood
        of a ground water release.
                               5-6

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     0  jUtftfcitiM. -M& $AMf&&    Proper  maintenance,  regular  Inspec-
        tlbns,  and  procedures  for  ensuring  waste  compatibility
        with tile  Wit #ay  Indicate that  a unit  Is  unlikely  to have
        re1isd  (this Is  particularly true for storage  units
        sweh it tanks and  container storage areas).   Evidence of
        gottd trperatlonal  practices way be available  from owner/
        operator  records,  and/or  visual  observation  or historical
        Inspection  reports.   Conversely*  poor  operating  practices
        (e.g*,  underground tanks  that  are never leak  tested or
        Inspected Internally,  storage  of  open  containers of
        wastes) way Indicate relatively  greater potential  for
        ground  water releases.

3.    PhyslEtL Integrity of Unit

     During the VSI, the Investigator  should examine  the physical
condition erf the unit for  Indications  of  releases  that may  contami
nate ground witer.   Deterioration of above-ground  tanks  should
reveal obvious  signs of rust,  corrosion and spills.   Records of
recent leak Inspections may also  be available  for both  above and
below ground tanks, and these should be reviewed as  part of the
PR,

     It ts likely to be difficult to evaluate  the physical  Integ-
rity of many land*6atsed units.  However,  dikes around surface
impoundments #*y show signs such  as crumtllrig^ sluiflng, and
Infiltration around the toe, suggesting that the Inttfrlty of the
impoundment Is  Questionable*  In  general, the  Investigator can
assume that most urillned landfills and surface Impoundments have
leaked to ground water.
     The investigator should attempt to Identify the wastes
handled at a facility and originally contained within a 1^0 or
group of SWMUs during the PR,  In the PR, the Invtfsf ffitor will
try to connect information on waste types, hydrdfeeto^H charac-
teristics, and ground-water contamination to determine whether
or not a SWMU, or group of SMMUs, or other areas of concern at
RCRA facilities have released constituents to the ground water*
This section describes technical factors to consider when Identi-
fying waste characteristics relevant to ground "-water releases,
It also discusses physical /chemical properties that will affect
the release potential of wastes and their subsequent transport in
ground water,

     The tendency for different hazardous constituents to migrate
from a given unit or area, through the unsaturated zone, and Into
the ground water, will depend upon: the amount of waste present,
its physical state  (i.e., liquid or solid), and the physical and
chemical properties of thet constituents and the geologic materials
Many of the constituents In Appendix VIII are essentially Insol-
uble in water  {at neutral pH) and/or bind tightly to soil par-
ticles, reducing their tendency to migrate in ground water.  The
                               S-7

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Investigator SHiuid consider the potential  mobility  of the wastes
1n a unftg 1ft eoibinit loft with previously  described  unit-specific
factors, when assessing the likelihood of  release.

     The mobility of organic constituents  can be expressed quan-
titatively by the sorptlon equilibrium coefficient  (Kjj).   The
value of Kd depends upon the organic content of the  soil  and the
constltuent-ipeelf 1c soil adsorption coefficient (!W).  In most
cases, 1t dill be wore useful to estimate  the relative mobility
of a constituent by considering only the Inherent mobility of the
constituent * expressed by Koc; the Investigator will seldom have
access to Information on the organic content of soils at  a facility

     Pew Roc values have been estimated for specific constituents;
however, the octanol-water partition coefficient, (Kow),  can be
used as an Indicator of KqC.  Appendix E presents Koc and log
(Kow) values for many constituents of concern for ground-water
releases.  Because these are log values, chemicals  with Kow values
of more than two can be considered relatively Immobile; a value of
less than one Indicates that the constituent 1s relatively mobile.

     There are several limitations on using this measure  of mobil-
ity.  As stated above, actual constituent  f*ibb1l1ty  depends upon
the organic content of the soil. Which will not be known  In most
cases.  In addition, other geologic factors fe*g*,  faults, frac-
tures, solution cavities) may provide operi chaftrtels for this
migration of contaminants which could mike the application of the
concept of waste mobility Inappropriate In these SltuaHorts*  The
presence of other wastes 1n a unit may also substantially alter
the mobility of a constituent*

     Hazardous metals and Inorganic compounds may also be rela-
tively mobile 1n ground water (e.g., arsenic and cyanides are
extemely mobile constituents).  Their mobility will  depend upon
the pH of the wastes and the ground water, the o*1datidfi-ridet1on
potential of the ground water, and the Hgands present fOf complex
formation (e.g., the presence of carbonate ions In the ground
water will support the formation of relatively Immobile metal
complexes), and the geologic factors discussed above*  THe geo-
chemistry of the materials underlying the facility will affect
constituent mobility by  governing the presence of these llgands
(e.g., carbonate Ions will generally predominate In limestone
aquifers).

n.   Pollutant Migration Pathways

     The Investigator should evaluate any available Information
pertaining to the  hydrogeolog1c characteristics of a  facility
1n order to determine the pollutant migration pathways associated
with ground-water  releases during the PR.  This Information,  such
as the direction and magnitude of ground-water flow,  soil charac-
teristics, depth to ground waters aquifer media, and  climate,
may play a major role In Identifying ground-water releases at  a
facility.  The Investigator should rely on best professional
                               5-8

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judgment and 3ti
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during the PR arid VSt,  Several  eonsiderations on how to look for
evidence of release are discussed 1n Chapters Two and Three.

     Direct evidence of release  to ground water may Include
official reparts of prior release Incidents, such as a major  tank
car spill to the ground or documentation tHat a surface Impoundment
has released to ground water (e*g some states used to permit
releases to ground water through their NPDES permitting process).

     Indirect evidence of a release from the facility or a specific
unit at the facility will usually entail Information on general
ground-water eontami nat 1 on.  Whi*n the Investigator identifies
indirect evidence of a SWMU release of this type, It may be
necessary to determine which SWMUs are likely to have released
the relevant constituents by evaluating the pollutant migration
pathways (hydrogeoiogie characteristic*1 and the waste character-
istics at the facility, as discussed previously.

     VSIs may detect releases to other media, particularly soils,
that may indicate a high probability that contaminants have
migrated to the ground water.  Evidence of Soil contamination,
either through visual or sampling data, can provide an indication
tnat a release to ground water has occurred.

     At some facilities, ground-water sampling data may be
available from wells at the facility, off-site wells* or from a
spring near the facility.  Other facilities may Have fto grsund-
water monitoring Information relevant to the Oversll facility,
At these facilities, the investigator should consider available
data on soil contamination or results of Soil gas monitoring.
Electromagnetic conductivity surveys may provide evidence  of
release for ionlr. species,

     At facilities with ground-water monitoring data, these data
may indicate that hazardous constituents could  have migrated  from
the facility.  However, the Investigator will still rtied to eval-
uate the facility's  units, waste,  and migration pathway charac-
teristics,  in order  to  support the  possibility  that the consti-
tuents  originated from  SWMUs at  the  facility.

.   Exposttre Potent 1 a 1

     The investigator  should evaluate available  Information  on
the location, number,  and  characteristics  of  potential  receptors
that could  be affected  by  ground-water  releases  at  the  facility.
These  receptors  include  human populations,  animal  populations
(particularly any endangered or  protected  species),  and sensitive
environments,

     Exposure potential  Information  will be  used  primarily in
helping  the  investigator  determine  the  need  for interim corrective
measures at the  facility  In  order  to  address  instances  of  ground-
water  contamination  posing  especially high  risks  of exposure.
Types  of exposure  information of concern include:
                                5-10

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     o  The proximity of the unit/facility  to  downgradeent
        drinking water and Irrigation welH;

     o  The potential for use of the aquifer  as  a drinking  water
        source; and

     o  The potential effect of aquifer discharges to nearby
        surface water.

f.    OeterpJ Mng the Heed for Addi1 i ona 1  Samp 11 no In format ion

     The investigator may not be able to determine whet^e**  a
yround-water release from a unit/facility has  occurred or Is
likely to have occurred based upon existing data and the factors
described previously.  In these situations, he/she should consider
whether conducting a sampling visit to obtain  additional evidence
and fill data gaps will be needed in making a  determination.  In
this section,, we present:

     1)  General information on factors to consider In determining
         th need for additional sampling information;

     2)  Factors to consider in selecting sampling parameters; and

     3)  An example to illustrate this discussion.

I.    SeneraJ Information_on Oeterminjjxg the Heed for Samp! 1ng

     $t some facilities existing monitoring wells may be present
which could detect contamination from SMMUs at the facility.
Existing analytical data from such wells may. however, be  inadequate
or unreliable.  In such situations, new analytical data way be
useful in waking release determinations.  The following 11st
presents situations where additional sampling data could be
helpful in  4etc;*t1 nl ng if a release has occurred:

     o  Available data are outdated, generally when data are
        over one year old;

     o  The analytical methods use4 were inappropriate,
        particularly  if methods with very high detection levels
        that may obscure significant releases were used;

     o  QA/QC was of  unknown levels or non-existent;

     o  QA/QC  Information available  (e.g. contaminated  field/
        trip blanks)  suggests that  available  data may  be invalid;'

     o  The parameters monitored do not correspond to  the  waste
        constituents  suspected  from the release,  due  to  factors
        such as quantity and mobility, For example,  SC/MS
        priority pollutant  scans are available  to detect a
        release o* those chemicals, however,  the  waste  contains
        metallic cyanides and  there  is no data  on either metals
        or  cyanide in  the available sampling  data;


                                5-H

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     o  The available  data  are not  of  a  rigorous  QA/QC  level  or
        may be questioned for  other reasons,  and  it  1s  anticipated
        that the  facility will challenge any  permit  condition  or
        enforcement  order requiring an RFI;  and

     o  The available  data  are based on  samples  taken  from
        wells which  were not adequately  oriented  to  detect a
        release from a specific unit and better  wells  have
        since been installed or located  but  not  sampled.  It  is
        not routine  to require that wells be  Installed  during
        an RFA.

2.   SeJec11Qn of Sampling Parameters

     Knowledge of the  wastes that may  be potentially released
from a unit Is the starting point when identifying sampling
parameters. However, many facilities have incomplete or no data
on the wastes deposited over time.   When little  is known of the
wastes managed in the  unit, gas chromotography/mass  spectrometry
(GC/NS) scans of various constituent groups  (e.g., volatlles)  are
often a good starting  point.  Investigators  should select the
parameters to be analyzed for based on the facility-specific
information available  and on the Investigator's  professional
j udgment

     When a waste source is hazardous  due to EP  Toxldty, the
metals of concern are: arsenic, barium, cadmium, chromium, lead,
mercury, selenium, and silver.

     The volatile SC/MS scan  identifies chemicals that are charac-
teristic of solvents and lighter petroleum products (e.g., gasoline).
Many of these compounds are readily found 1n the environment  from
releases from various  waste sources.  Because they are very vola-
tile, older wastes may no longer contain these constituents since
they may have been released by evaporation into the air.  The
indicator parameter, TOX, Identifies the presence of halogenated
organics.   If TOX levels have been  identified, a volatile scan
should be helpful in Identifying the specific compound released.

     Acid extractable compounds may be  present In heavier petro-
learo feedstocks, and certain  industrial processes (e.g.,  penta-
chlorophenol from wood preserving).  Some compounds (e.g., phenol,
pentachlorophenol , 2-chlorophenol)  are  commonly found from many
waste sources including organic waste treatment sludges.  Phenol
and the mono halogenated phenols biodegrade readily 1n most soil
and surface water environroents.

     Base/neutral compounds can often be found in wastes  from
industries  such as organic  chemicals, plastics, and synthetic
fibers manufacturers.   The pesticide scan ioentifles pesticides
that are found specifically in pesticide was*.es and products  from
the agricheraica1  industry.
                               5-12

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3.   Example

     An Illustration cf a situation 1n  which  sampling  would  be
called for 1s if follows:  An unllned  surface Impoundment,  con-
structed twenty years ago from naturally occurring  site  material,
1s located at a facility close to homes withdrawing water  from
domestic wells.  The onslte soils are  high  1n clay  content,
although they also contain abundant cobbles wh^ch would  Interfere
with adequate compaction.

     The Investigator determines that  the Impoundment  has  not
received any wastes in the last five years; however, the pre-
viously deposited waste material has never  been removed.  The
wastes are Identified as unspecified waste  oils from unknown
sources and wastas containing lead and  cadmium.  While monitoring
wells have been installed, the monitoring data collected from
them only measure Indicator parameters  (e.g., pH,  conductivity,
TOX and TOC).  Only one parameter (TOC) showed an  Increase over
background.  In addition, State sampling data from  off-site
domestic wells detected significantly  elevated levels of lead  and
copper,, However, the sampling protocol  collected samples directly
from the resident's tap, making 1t possible that the contamination
originated in the domestic plumbing system.

     Because of the unit's design, construction method,  and age,
the Investigator may strongly suspect  that  a release has occurred.
While monitoring data exist, Indicator parameters  are not ade-
quate to identify potential releases of heavy metals.  The one
elevated parameter, TOC, suggests that orgnnlcs way have been
released from the oily wastes.  However, elevated  T0C values do
not conclusively Indicate contamination from man-made sources,
and may result from natural sources.

     In this scenario, the Investigator should probably call for
additional ground-water sampling from existing wells to find
constituent-specific evidence of release not provided by the
indicator parameters.  He/she would probably sample both on-s1te
and off-site wells for lead, cadmtum,  add extractables, and the
base/neutral priority pollutants.

     The add extractables and base/neutral priority pollutant
scans would be appropriate since they can  Identify many of the
constituents commonly found 1n petroleum oil based wastes
(especially since the composition of the wastes was largely
unknown).  While It might be possible to identify other constit-
uents at the site (e.g., VOCs), the investigator would  probably
limit the sampling parameters to those most likely to be present.
Because of the high cost and delay  associated with analyzing
sampling results, the investigator  should  attempt to limit the
selection of sampling parameters to those  most likely to result
In an ident 1f1 cat 1 on-of  a release from.
                                5-13

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HI. COLLECTING ADDITIONAL SAMPLING INFORMATION  IN  TH*  SV

     This section presents technical  Information  related  specific-
ally to th* ground-water pathway to be  considered when  collecting
additional sampling Information fn  the  SV.   The  Information
presented here should be used to help the  Investigator  meet  one
of the primary goals of the SV;

     o  To collect additional sampling  Information  to  fill  data
        gaps Identified 1n the PR and VSI  leading towards  a
        release determination.

     For each sampling method discussed,  this section  describes:
1) the general kinds of situations  1n which 1t will  be  appropriate
to employ a specific technique, 2)  technical  Information  on  how
to conduct the sampling, and 3) specific  details  to be  considered
when evaluating the sampling results.  We  do not  provide  the
actual SOPs on the sampling techniques  here, although  we  do
reference the relevant manuals.

     The choice of appropriate sampling methods  will  have a  large
impact on the cost and usefulness of the  SV.  The Investigator
should be confident when developing and reviewing the  sampling
plan that the procedures chosen will  meet  the needs of  the RFA,
while not resulting 1n the collection of  unnecessary data.  We
discuss the following five sampling methods which may  be  of  use
when investigating ground-water releases  1n the  RFAt

     (1)  Sampling of existing ground-water monitoring wells;

     (2)  Soil sampling;

     (3)  Soil gas monitoring;

     (4)  Electromagnetic conductivity mapping;

     (5)  Sampling of domestic wells; and

     (6)  Installation and sampling of new ground-water
          monitoring wells.

A,   Sampling of Existing Ground-Water. Monitoring Wells

     The  Investigator should  sample existing groun'-water moni-
toring wells when they may provide useful data on contamination
resulting from facility-wide  releases.  As dfscussed 1n the
previous  section, the Investigator may decide to sample wells
when the  most recent data are  outdated, when the laboratory
analysis  procedures are unknown or questionable, or when the
sampling  parameters were  Inadequate.  The Investigator may  also
choose to sample existing wells to provide EPA with data of  its
own when  the only available  data was collected by the owner/
operator.
                               5-14

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     The procedures for sampling monitoring wells have been de-
scribed extensively 1n many available documents.  The Investigator
should rtly upon tHs/her best professional judgment when collecting
samples at txlstfng wells.  Well configurations at SWMUs should
be adequate to detect releases from these units.  Before collecting
additional Information, the Investigator should ascertain the
adequacy of an existing monitoring system.  He/she should evaluate
the locations of wells 1n relation to the specific SMMUs or other
areas of concern.  In many cases, a facility's monitoring wells
will have been Installed to detect contamination resulting from
regulated units, and will not pick up releases from other units
or areas of concern.  Exhibit 5-2 depicts three examples of moni-
toring well systems, one that would be adequate for detecting
SWMU releases and two that would be Inadequate.

     After assessing the adequacy of well locations, the Investi-
gator should evaluate data on well construction and design 1n
order to determine Its adequacy.  While data from properly con-
structed wells may be of higher quality, 1t will not be necessary
to ensure that existing wells meet the stringent requirements
discussed 1n the I|CRA Sroynd'gater Monitoring Enforcement guidance:
RCRA SrQund-water^^^ftoTfnj^ IgJLfiugLJc aj |"/Q^ct1iiM guidance
0 oc UWenV ( TE6D ) V  The 1 n v e s t 1 g aTo r~ s 0 u f ~d u s e b t s t professfonal
judgment In evaluating sampling data based upon the quality of
the ex1 st1 ng wel H.

     Sampling of ground-water monitoring wells 1n the RFA should
be conducted by trained personnel.  EPA has developed numerous
guidance manuals on appropriate sampling procedures.  These
manuals may be consulted for specific field procedures:

     o  ground Water Technical  Enforcement 6u1 dance jQcument
        Draft, August 19@5   "

     o  RCRA Draft Permit Writer's Manual: Sround-Water
                a n * October "1983   :   '  !    :     "    ^
     o  Manual for_<^o,und~Wat^r         ?P^ ^ "9 Proef durts ,
        '~    '       ^                                 ~
     o  R e^v i s e d D r a f t P r o t o c o I  f o r G round - M a t e r  Ins Pf_ct_1 o n s
                            r                e and" "~B is p"o"$ j
                                              '           ~"
     The Investigator should  refer  to  Chapter  Four  for  specific
recommendations on QA/QC*  chat n-of -custody ,  safety,  and
decontaatf nation procedures  to  be  followed  1n  the  field.   In
genera), th@ OA/QC and sampling procedures  followed  by  the
Investigator should be appropriate  to  the  Intended  use  of the
data.  For example, 1f the  Investigator  anticipates  that  the
owner/operator may contest  EPA's  sampling  results 1n court,  1t
would be advisable to use  more stringent procedures.
                                  15

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                                              EXHIBIT 5^

                                        HOKli0JtS WELL  LOCATION
           Case One
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     Tht Invtstifitor should use best professional  judgment 1n
evaluating sampling results collected 1n the SV, based upon
sound geologic and bydrogeologlc principles.  General  guidance
on evalutlng sampling results 1s presented 1n Chapter  Four.

ft*   Soil Sampling

     The Investigator may choose to sample soils at the facility
1n order to gain an understanding of the likelihood of a release
to ground water,  ?4any constituents, when released to  soils, will
further migrate Into the surfldal aquifer.  The potential  for
migration to the ground water will depend upon the properties of
the relevant constituents and the site geology (this Is discussed
in greater detail 1n Section II of this chapter).  Soil sampling
will be especially useful In situations where a facility lacks
ground-water monitoring data or the ground water 1s deep.

     Sampling locations should be chosen to provide the most useful
Information.  For example, the Investigator may want to determine
whether constituents have migrated from a closed surface Impoundment,
Stratified sampling around the unit, and where possible, underneatn
the unit, may be helpful 1n  detecting constituent concentration
gradients Indicative of migration.   In other cases, the Investigator
may simply wish to confirm that a release  Incident occurred, such
as a spill, by sampling the  locution where the suspected Incident
took place.  Technical details on how to sample soils  1s provided
in Chapter Eight of this guidance.

c*   Soil 6js Monitoring

     Soil gas monitoring can be used to detect the presence  of
volatile organic compounds  (VOC's) 1n ground water and will  be
especially useful 1n cases where  existing  ground-water monitoring
systems  are Inadequate to  detect  these  contaminants.   This  tech-
nique,  developed and used  extensively by  EPA's  Environmental
Response Team  (EftT), detects the  presence  of VOC's 1n  the  unsat-
urated  zone and  provides a  good Indication  of  subsurface soil
and/or  groundwater contamination.   In addition, this  method  can
provide  same-day  results during a  field  Investigation  and  will
cost substantially less  per  sample than  well drilling  and  SC/MS
analysis.

     Soil gas  monitoring should be performed by  trained  personnel.
The  following  document  describes  1n  detail  standard procedures
for  conducting  soil  gas  monitoring at waste  sites:

     Lappala,  E  and  S.  Thompson,  "Detection  of Sround-Water Con-
     tamination  by Shallow Soil Gas  Sampling  1n  the Vadose Zone
     Theory and  Applications."  Proceed 1 ngs  ofLJJh\e;..JMJ\%Jt
     C o n f e r e n c e  o n Hanageme n t  of""ITncontro 11 ^edT'IfaTFrdousT Waste
     TTTeT, "Washington,  D.c.,
                                5-17

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     The following description of soil  gas  monitoring  procedures
1s Intended to assist the permit  writer 1n  recognizing those
situations where Its use would be appropriate,  and  to  enable
him/her to oversee Its Implementation  by a  contractor  or  the
owner/operator.

     When ground water or soils have been contaminated by VQG's,
gaseous components of these compounds  will  be present  in  the
Interstitial pore spaces of the soil matrix,  and  are known as
soil gas.  By sampling the gas 1n this Interstitial  space and
analyzing 1t for VOC's with a portable gas  chromatograph  In the
field or In the laboratory with a SC/MS, the  presence  of  soil
and/or ground-water contaminants  can be Indicated.

     First, the Investigator must make a vertical  hole In the
soil through which the gas samples can be drawn.   A hole  can  be
made to a depth of five feet with a solid spring  steel single
piston slam bar (1.75m x 16.7 mm diameter).  Threaded  four foot
sections can be added to the slam bar when  holes  deeper than  five
feet are desired.

     After the hole has been made, the slam bar should be removed
carefully to prevent the walls of the hole from coTlarpslng.  The
investigator should then Insert a stainless steel  sampling tube
Into the hole.  In order to prevent soil from clogging the sam-
pling tube, a Teflon tube, slightly longer than the sampling
tube, should be Inserted Into the sampling tube*   The Teflon tube
should be just wide enough to hold a small  nail 1n Its end, so
that the nail head Is wide enough to cover the end of the stain-
less steel sampling tube*

     The sampling tube should be Inserted Into the hole, nail  end
first;  when the sampling tube has been Inserted to the desired
depth, the Teflon tube can be removed, causing the nail to drop
to  the bottom of the hole.  The sampling tube should then be
removed 6 to 12 Inches to ensure that soil  gases will enter
freely.  Finally, top dirt should be packed around the tube to
minimize inlltratlon of ambient air from the surface.

     Soil gas will be pulled from the sample hole using a S1l1an
pump.  ERT  recommends evacuating five to seven gas volumes prior
to  farapHng the hole.  For a i/4" hole about 10' deep and a
pumping rate of three liters/minute, this evacuation  should take
about  15 seconds.

     The gas in the well can be collected and sampled using three
different methods.  The simplest involves attaching a portable
photoioni zat ion detector (e.g., Hnlf) to the stainless steel tube,
using  a short  piece of Teflof. tubing.  The HnU provides  Indica-
tions  of the total organic vapor concentration within the  hole
calibrated  to  a benzene standard.   This method does not  provide
the  investigator with information on individual compounds  present
in  the soil, but may provide a sufficient indication  of  contami-
nation to suggest the llkehood of a release.
                                5-18

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     Thi HnU should be calibrated properly prior to use.   A back-
ground reading of 1 to 2 ppm (as benzene)  may result from soil
moisture.  Once the HnU reading has stabilized,  usually after 4
to SO seconds, the reading should be recorded.

     Tedlar bags ctn also be used to collect  soil  gas  for field
analysis with a portable photolorHzatlon gas  chromatograph (e.g.,
Photovae) or laboratory analysis with a cryogenic trapping capil-
lary column gas ehromatograph/mass spectrometer.  The  Tedlar bag
should be filled with about 200-700 ml of  vapor  from the  borehole,
and analyzed within no more than 48 hours.  This technique has
the advantage that Individual compounds may be detected,  provid-
ing more detailed sampling data during the SV.   One disadvantage
Involves uncertainties concerning the Interaction of the  Tedlar
bag and the gas being collected.  However, the quality of the
data will be higher than that obtained using  an  HnU,

     The most accurate technique for sampling and ani.!ys1s will
involve the use cf sorbent tubes (e.g., Tenax, Chromosorb, etc.)
to collect gas samples for laboratory analysis by SC/MS,   Because
contaminants collected on sorbent tubes maintain their Integrity
for a longer period (14 days) than those collected with Tedlar
bag*;, it may be advantageous under some circumstances to use them
to collect soil gas samples.  The chief disadvantage of this tech-
nique involves the necessity of analyzing the sappfes 1n a labora-
tory, adding time and expense to the monitoring procedure.

     Soil gas monitoring can be effective 1n detecting VOC's 1n
soil gas which have a vapor pressure greater than xylene (5 mm
Hg),  Vapor pressures of a number of constituents of concern are
listed In Appendix E  for further reference*  This monitoring
technique does not provide a direct  Indication  of the concentra-
tion of contaminants  In ground water or soil.   The  relationship
between soil and ground-water concentrations and soil gas concen-
trations will depend  greatly upon the organic content of the soil
and the octane!-water partition coefficient of  the  Constituent  of
concern.  The technique will provide the  Investigator with evidence
of subsurface contamination, which will usually be  sufficient  to
indicate the need for an RFI at the  locations of concern,

D.   Electromagnetic  Conductivity Mapping

     Geophysical techniques  have gained acceptability In the last
five years for the  Identification  of waste releases to both  ground
water and soils, as well as  for the  sensing of  burled wastes.
This section briefly  discusses one  of these techniques,  electro-
magnetic conductivity mapping  (EM),  which may be useful  during
the RFA,
                                     
     EM surveys  can provide  an Indication of ground-watar  contam*
1nat1on at sites with relatively  simple,  well-defined  hydro-
geologies  (e.g., shallow,  relatively  uniform sand  and  gravel
aquifers).  This technique measures  changes  1n  the  conductivity
of the  subsurface materials  at a  site,  which may depend  upon the
                                5-19

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composition of the subsurface soils, and/or the presence of
dissolved eofttamlftaftts In the ground water.

     EM surveys provide 1so-conduct1vlty contours at  a site,
Indicating the movement of contaminants from a source.  While
this technique does not provide Information on either the types
of constituents present, or their concentrations, 1t  can provide
indirect evidence of a release.  However, It will primarily
Indicate only the presence of Ionic constltutents In  ground water.

     Conducting IM surveys requires qualified personnel  and
expensive equipment, although 1t will be a relatively Inexpensive
method when using experienced contractors In the SV   This section
does not provide technical Information on how to perform an EM
survey.

     The Investigator should be cautious when evaluating the  re-
sults of an EM survey, due to the potential for Interference  from
unusual geologic conditions at the site.  Different geologic
materials have different conductivities (e.g., moist  clays have  a
higher conductivity than do dry sands)*  At facilities with
complex hydrogeologle characteristics, the results of EM surveys
could provide a false Indication of contamination where non-homo-
geneities 1n the subsurface media reveal differences  1r conduc-
tivity.  The difficulties associated with analyzing these data
represent the major drawback to using this technique.

E   Sampling of PQme $tic Hells

     In certain unusual cases, the Investigator may choose to
sample domestic wells 1n order to Identify releases from the
facility.  This will be especially Important when the Investigator
believes that a contaminant plume originating at the  facility
could pose an Imminent threat to human health or the  environment
near the facility.  Sampling data taken from domestic weflls could
provide sufficient evidence to suggest the need for Immediate
interim corrective measures at a facility (e.g., such as counter-
pumping, or provision of an alternate drinking water  supply).

     Sampling residential water supplies could alarm affected
residents.  Because of this potential for community reaction*
domestic wells should only be sampled when the Invastigator has
strong evidence to suggest the presence of a threiit.

     When sampling domestic wells, it 1s Important to run the
water to remove any standing water within the distribution system.
It is also important to take the samples prior to any in line
treatment systems {e.g., water softeners).

F.   Installation Of New Monitoring Hells

     In unusual situations, EPA may find that new monitoring
wells should be installed during the RFA in order to obtain
useful ground-water data.  While this should not be necessary at
                               5-20

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most facilities* it may be appropriate where ground-water  data
are wholly Inadequate, where other sampling techniques  do  not
provide sufficient Information on the site, or if the owner/operator
is recalcitrant and the investigator suspects that a  release  has
occurred.
     In most cases such as that presented above,  the investigator
should rely upon information collected during the RPA to demon-
strate that a release may have occurred,  and recommend that  the
facility conduct an RFI,   However, this may not be possible  when
dealing with recalcitrant owner/operators.  As a  last resort,
the investigator can recommend that new wells be  installed.

     Procedures for installing new wells  should be based upon
accepted hydrogeologic principles and best professional  judgment.
New wells should conform to standards described in the TESO  or
Subpart F.  Their locations should be chosen based on knowledge
of site hydrogeology and best professional judgment,


IV.  MAKING GRQUNO-WATIR RELEASE DETERMINATIONS

     The final task 1 .-> the RFA process 1s to make determinations
of release potential Uiroughout the facility and  to make recommen-
dations for further action to address these potential releases.
In making release determinations, Investigators should evaluate
the relevant information on unit characteristics, waste charac-
teristics, site hydrogeology, and any evidence available from
sampling and analytical data.  Potential  for exposure of receptors
to contaminated ground water may also be a consideration In  making
conclusions for further action.  If on the basis  of the Information
and evidence available to the investigator, and his/her best pro-
fessional judgment, it can be reasonably determined that there
is, or is likely to be, a release of wastes or hazardous constituents
to ground water which merits further 1nvest1g*t1om/efttffcter1zat1on,
or an immediate Interim remedy, the owner/operator should be
required in the RFI to conduct these necessary actions.  It  should
often be possible, from the information gathered  1n the RFA, to
be able to specify 1n some detail the nature of the investigations
to be conducted; i.e., the area to be given further subsurface
Investigation, the constituents to be monitored for, the general
area to be monitored for, and other elements of the ground water
characterization program

     It should be understood that it Is not necessary to prove in
an RFA that ground-water contamination has occurred from SWHUs at
a facility.  Confirming the presence of a release will often be
the initial phase of a follow-on RFI investigation.

     Exhibit S-3 is a checklist that should help the investigator
evaluate specific factors to identify ground water releases  and
determine the relative effect on human health and the environment.
In identifying releases, the investigator should consider the
types of information presented in Exhibit l-lt which are high-
lighted in this checklist.


                               5-21

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                           Exhibit  5-3

               6Hiki1st  for  Sround Water  Releases


Ident i fy 1 ng Seleasts

l.   Potential  far Ground  Mater Releases

    o   Unit type and  design

       -  Does the unit  type  (e.g., land-based)  Indicate th$
          potential for  release?

          Does the unit  have  engineered  structures  (e.g.,
          liners, leschate collection systems,  proper
          construction materials)  designed to prevent
          release's to ground  water?

    o   Unit operation

          Does the unit's age (e.g., old unit)  or
          operating status (e.g.,  inactive, active)
          indicate the potential for release?

          Does the unit have  poor  operating procedures
          that increase the potential for release?

          Does the unit have  compliance problems that
          indicate the potential for a release to
          ground water?

    o  Physical condition

          Does the unit's physical  condition Indicate the
          potential for release (e.g., lack of structural
          integrity, deteriorating liners, etc.)?

    o  Loeational  characteristics

          Is the facility located  on permeable soil
          so the release could migrate through the
          unsaturated soil zone?

          Is ths  'acuity located in an arid area with  less
          inr.ltrat  -n of rainwater  and therefore with  less
               rM?' for downward migration of any release?
          Does t.i* distance from a unit or area to the upper-
          most aquifer Indicate the potential for release
          (e.g., the waste lies within the aquifier)?

          Does the rate of ground water flow greatly
          inhibit the migration of a release from the
          facility?

          Is the facility located in an area that recharges
          surface water?

                               5-22

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                     Exhibit  5-3  (continued)

               Checklist  for  Ground  Water  Releases
    6   Waste  eharact -ri sties

          Does  the  waste  exhibit  high  or  moderate  character-
          istics  of mobility  (e.g.,  tendency  not to  sorb  to
          soil  particles  or organic  matter  In  the  unsaturated
          zone)?

          Does  the  waste  exhibit  high  or  moderate  levels  of
          tox1c1ty?

          Does  the  waste  exhibit  hazardous  characteristics
          (e.g.*  lower high pH)?

2 .   Evidence  of S r o iu m d M a t e r^  R e 1 e a s e s

    o   Existing ground-water  monitoring systems

          Is  there  an existing system?

          Is  the  system adequate?

          Are there recent analytical  data  that
          Indicate  a release?

    o   Other  evidence of  ground water  releases

          Is  there  evidence  of contamination  around
          the unit  (e.g., discolored soils, lack  of or
          stressed  vegetation) that  indicates the
          potential for a release to ground water?

          Does local well water or soring water sampling
          data indicate a release from a facility?

Determining the Relative Effect Qf the Release t>n  Human
                             "   !      ~        ""      "~
1,  Exposure Potential

    o  Conditions that indicate potential exposure

          Are there drinking water well(s) located near
          the facility?

          Does the direction of ground water flow
          indicate the potential for hazardous consti-
          tuents to migrate to drinking water wells?

          Does the ground water discharge to a surface
          water  body with recreational  use or that supports
          fish or any endangered species?
                               5-Z3

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                           CHAPTER  SIX

                          SURFACE  MATER
I.   INTRODUCTION

A.
     This chapter provides  technical  Information  to  support  the
investigation of SWMU and other releases  to surface  water  during
the RFA.   While Chapters  Two,  Three,  and  Four provide  general
guidance  on conducting RFAs,  this chapter focuses on specific
factors unique to the surface  water media that should  be  con-
sidered by the investigator.

     This chapter has been  organized  to reflect  the  separate
phases of the RFA process-

     o  Conducting a preliminary review of existing  information
        related to releases to surface water;

     o  Inspecting the facility to obtain evidence of  release;

     o  Collecting additional  sampling information in  the  SV;  and

     o  Making final release  daterminations .

     The  first section describes the technical factors that  should
be considered during the PR and VSI,   The second  section  describes
the technical approach to obtaining additional sampling information
in the SV for surface water,  and should be consulted along with
Chapter Four on conducting a  SV,  The final section  dtscussss
factors to consider when making release determinations to surface
water at  the end of the RFA,   This section also discusses  the
options for further investigation to be evaluated at the  end of
the RFA for surface water releases.

B.   Sc_ojje

     The  investigator should  evaluate all RCRA facilities for
releases  to surface water that pose an actual or potential threat
to human  helath and the environment.   These releases may  include
surface water discharges permitted or required to be permitted
under the NPOES program.  In  these cases, the investigator should
attempt to make an initial  characterization of the potential
problem.   However, he/she should usually refer the further inves-
tigation  and control of these discharges to the NPOES permitting
authority, rather than addressing them through RCRA  authorities
[3008(h), 3004(u), or 3004(v)1.  EPA is developing more specific
guidance  on how to make these referrals.

-------
     In most cases surface water investigations will  relate to
run-off front specific SWWUs.  However, there may be situations
where general facility run-off may be Impacting human health and
the environment.  The 3008(h) corrective action authority allows
the Investigator to address these situations*


it,  CONDUCT1HG A PRELIMINARY REVIEW AND VISUAL SITE
     INSPECTION OF RELEASES TO SURFACE WATER

     This section presents technical information related specifi-
cally to the surface water pathway to be considered when conduct*
4?ig the PR and VSI,  Accordingly, this section has been organized
to reflect the primary goals of these steps as described in
Chapters Two and Three:

     o  Identifying aid describing potential threats  to surface
        water at RCP.A fact] Hies; and

     o  Diking a preliminary assessment of the need for a SV or
        other actions at these facilities.

     This section reflects the importance of the RFA  information
matrix (Exhibit 1.1} for evaluating the likelihood of releases to
surface water in the PR,   It describes each of the five types of
information described in this matrix as 1t applies to the surface
water pathway.  In addition, this section provides technical
information to help the Investigator determine when additional
sampling will be necessary in a SV to Identify surface water
releases.  The factors discussed are as follows:

     (1)  Unit characteristics;

     (2)  Waste characteristics;

     (3)  Pollutant migration pathways;

     (4)  Evidence of release;

     (5)  Exposure potential; and

     (6)  Determining the  need for additional sampling Information

     This Information will be relevant to the evaluation of
written documents in' the PR and information fathered  during the
VSI.  Consult Chapters Two and Three for general guidance on
conducting PAs and VSIs,

A    UnitCh a r a c te r1st 1c s

     The design and operating characteristics of a SMHU will
determine to a great extent its potential for releasing hazardous
constituents to surface water.  Many treatment, storage, and
d.sposal units are designed to prevent releases to the environment
                               6-2

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The Investigator should evaluate the unit character1stics of each
SMMU or group of SWMUs at a facility to determine their potential
for releasing hazardous constituents to surface water.

     As with the other media, the likelihood that a SWMU has con-
taminated surface water or a surface water drainage pathway 1s
largely dependent on the nature and function of the unit.  For
example, open units that contain liquids (e.g., surface Impound-
ments) have a greater potential for release than closed landfill
cells that have been properly capped.

     Exhibit 5-1 loosely ranks commonly observed SWMUs In a de-
scending order on the basis of their potential for having releases
that may cause surface water contamination.  It 1s Intended to
provide a general sense of the relative potential! for  units to
cause chese types of releases,.  The investigator''1 T1 . also ftsed-
to evaluate unit-sped f 1 c factors Irs determining the $0tefttfal
for release from a particular unit.        .    '"

     The major unit-specific factors the infef'tfgator'should
evaluate are discussed below.              '        '  "' -

I,   Unit design                               ,  '  <'

     The Investigator should determin^ whether the-tin ft has
engineered features (e.g., run-off control sy^tews) that are
designed to prevent releases from the ynit. ' If such  features;
are in place, the investigator should evaluate whether they are
adequate (In tents of capacity* engineering*;. tc.} to  prevent
releases,  A landfill, for example, i"'ajf\^S've bersss to  control
run-off, but the berms way not be adequate t$  contain  run-off  -
daring periods of peak rainfall.  In adJ\tioh, a  surface fmsou&cf"
ment or open tank with insufficient freeboard  $y  not  be able -to
prevent overtopping that could occur bet^se df wave  action
during storm events,                     \

2.   Operational history
                                           \
     During the PR and VSI, the investigator. should' ex.im.ine the
unit's operating history to obtain information that indicates
releases have taken place.  There are several'  operational  factors
that influence the 11 kali hood  of  release.

                  .^^-...^^^^....^.^*  Units that  have  been  operat-
                  fuf "pe"rTod"s""of	"tTnve are  generally  wore  likely  to
        have releases than new units.
        -n.--;,.-..^ll^AL^lH^^LA^JLJJA.JJ-   fin  sowa  ^85$,,  the operat
        ing' status of  a  unft  TeTgT7~c1 osed s  inactive,  etc.) may
        have an  effect on  the  relative likelihood of release.
                                6-3

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                           EXHIBIT 6-1

       RANKING OF UNIT POTENTIAL FOR SURFACE WATER RELEASE
                    AMD ME:HAHISMS OF RELEASE
          Type
Surface Impoundment
La fulfi
Waste Pile
Land Treatment Unit
Container Storage
Area

Above-ground Tank
In-ground Tank
 Incinerator
             Release Mechanism*
Mass  i and IV
Injectfon Well
o Releases from overtopping

o Seepage

o Migration of run-off outside the unit's
  run-off collection and containment system

o Migration of spills and other releases
  outside the containment area from
  loading and unloading operations

o Seepage through dikes to surrounding
  areas (e.g., soils, pavement, etc.)

o Migration of run-off outside the unit's
  run-off collection and containment system

o Migration of spills and other releases
  outside the containment area from
  loading and unloading operations

o Migration of run-off outside the
  containment area

o Migration of run-off outside tlie
  containment area

a Releases from overflow

o Leaks '. rough tank shell

o Spills  from coupling/uncoupling
  operations

o Releases from overflow

o Spills  from coupling/uncoupling
  operations

o Spills  or other releases from waste
  handling/preparation activities

o Spills  due  to mechanical failure

o Spills  From waste  handling  opera-
  tions at the well  head
   The two  remaining solid  waste management  units;  waste  transfer
   stations, and 
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    o   OpsratInf gfoeedurts.   Maintenance  and  Inspection  records
        shouTi f iidfcate whether a  unit  1s  11ke1y  to  have  released.
        Units that are Inspected regularly  and  properly maintained
        art less likely to have releases  than  units  that  have
        been poorly maintained.

3.   Physical condition of the  u^1t

     During the VSI, the  Investigator  should  examine the  units
for evidence of releases  or characteristics that  could  cause
releases.  For example, when  Inspecting a  surface Impoundment,
the Investigator should determine  whether  the  earthen dikes  are
structurally sound to prevent  releases.  Cracks,  slumping  or
seeps around the toe In these  dikes  way cause  releases  to  the
surface water drainage pathway.

B.   w_a_srt e C h a r a c t e r 1 s 11 c s

     The Investigator should  attempt to Identify  the wastes
originally contained within a  SWHU or  group of  SWWUs during  the
PR,  In the PR the Investigator wtll  try  to  connect Information
on waste types, the surface water  drainage pathway,  and  evidence
of surface water, sedlwent, or  soil  contamination to demonstrate
the likelihood that specific  SWMUs,  groups of  SMWUs, or  other
areas have released constituents to  the surface water.   This
section describes technical factors  to consider when Identifying
waste characteristics relevant  to  surface  water* releases.   It
also discusses physical/chemical properties that  will affect  the
release potential of wastes and tHelr  subsequent  transport 1n  the
surface water drainage pathway.

     Information on constituents and their properties can aid  the
investigator 1n Identifying migration  pathways of eoncitrn and
sampling locations 1n environmental  wedla.  For example,  knowing
that the waste primarily contains  heavy metals, which have a  ten-
dency to precipitate and settle, the Investigator can look for
evidence of a release 1n the  sediments around the point of dis-
charge Into a river and plan  on taking samples of the t0tto
sedlwent.

     Constituents, depending  on their properties, will tend to
migrate 1n different forms and  at  different fates fn the pathway.
Some constituents which are  highly soluble,  will dissolve 1n
water and be transported within the water column.   Insoluble
constituents can be transported Into surface water  by suspension
from turbulent run-on/run-off.   Other generally Insoluble waste
constituents are lighter than water and will  fee transported on
the surface, forming oily  sheens.   Hazardous metals and inor-
ganics (e.g., arsenic and  cyanides)  may be relatively mobile 1n
water, depending upon the  pH  of the wastffis and the  surface water,
the oxidation-reduction potential  of the surface  water (this
will be most important 1n  the  lower layers of deeper lakes), and
the llgands present for complex formation.  Hard  surface water,
                               8-5

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due to the 0r*tac* of higher concentrations of carbonate ions,
will support tit* formation of relatively Immobile metal  complexes.
These metal complexes form precipitates, which will settle out
with
     The tendency of organic constituents to adsorb to soils can
&e expressed quantitatively by the sorptlon equl Vtbrlum coeffi-
cient (X^),  the value of K^ depends upon the organic content of
thft suspended sediments and the constituent-specific *o1l  adsorp-
tion coefficient (Koc).  Constituents sorbed onto soil and sediment
part leu lates way enter the surface water pathway as suspended
materials In run-off.

     The Investigator will seldom have access to Information
of\ organic content of soils and sediments at a facility; Instead
it will be more useful to estimate the relative mobility of a
constituent ss expressed by koc.  Few koc values have been est-
imated for specific constituents; however, the octanol -water
coefficient, (Kow) can be used as an indicator of Koc.  Appendix
 presents Koe and log (Kow) values for many constituents of con-
cern,  Because these are log values, chemictls with Kow values of
more than two can be considered relatively immobile; these consti-
tuents will usually settle In stream sediments.

     The water solubility of constituent chemicals can be obtained
from several chemical handbooks (e.g., Handbook ftf Chemistry
and Physics, CRC Press).  Many water soluble chemicals (e.g.,
phenol, dimethylamlne) are also readily biodegradable &y lite
numerous organisms Indigenous to surface water*.  Thfs character-
istic will make 1t difficult to Identify past releases ef tHse
cheml cats-*

     In addition, knowledge of constituent properties can provide
information on the potential for Intermedia transfers frost* surface
water to other ed1a.  For example. If a waste source contains a
high percentage of QCs, the Investigator may be concerned that
releases to surface water will volatilize and result  in an air
release*  Intermedia transfers may also occur to soils, *nd
ground water from the surface water pathway.  The user should
refer to Individual media-specific chapters for guidance on
Investigating releases to these media,
     The investigator should evaluate any available Information
pertaining to t*te surface water drainage pathway at a  facility
in order to determine the pollutant migration pathways associated
with surface water releases during the PR.  This Information will
play a wajor role In Identifying surface water releases at a
faclil ty.
     In easss wne^e the Investigator  finds  little dlre'ct evidence
of a release ta surface water  (e.g.,  direct evidence  of  overtop-
ping from a surface Impoundment onto  soils), he/she should make
                                  6-5

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deductions on the likelihood of release  by  Unking  Information
on waste characteristics,  the pollutant  migration  pathway,  and
indirect evidence of release (e.g.,  environmental  sampling  data
showing contamination of surface water,  soils  1n  drainage  pathways,
or stream seeH<**ts).  It  will  be easier to demonstrate  that  a
contaminant oHftnated at  a particular SWMU when  the  Investigator
can show that, based on the characteristics of the  surface  water
drainage pathway, a release from the particular SWMU  would  be
likely to result 1n the observed contamination,

     In characterizing surface  water release pathways,  the  Invest-
igator should Identify any drainage  pathway(s) leading  from
the unit of concern to surface  water.   Topographic  maps  provide
information on the slope of the Intervening terrain between the
units of concern and downgradlent surface water,  which  1s  helpful
in determining the route run-off follows to surface water.   These
maps may also help 1n locating  surface water bodies.

     Upon entering surface water, the  transport of  the  constituents
in the surface water pathway 1s highly dependent  on the  type of
surface water body.  The three  major classifications  of  surface
water are:  rivers and streams, Impoundments (e.g., lakes,  bays,
etc.) and estuaries (Including  wetlands).

     Contaminants entering rivers and  streams will  tend  to be
transported downstream.  However, as discussed earlier,  heavy
metals are likely to settle out with sediment.  Also, VOCs entering
a turbulent stream may volatilize Into the air.

     Constituents entering Impoundments or estuarlne systems will
tend to pollute areas near their discharge points because  these
water bodies are relatively slow moving and are not likely to
transport the constituents significant distances.

     The Investigator also should look for any effect that permit-
ted discharges (e.g., H'POES, dredge  or fill) may have on environ-
mental pathways,  For example,  a NPOES discharge may be releasing
ftCRA constituents not covered by the permit, causing downstream
contamination.  In addition, the Investigator should consider the
possibility that waste 1n NPOES units  or 1n other permitted
discharges may be releasing to ground  water or air.

     Finally, the Investigator should  consider possible Intermedia
transfers to surface water.  He/she  should consider the potential
for releases from soil and/or ground water (ground water discharge)
to affect the surface water pathway.

     In sum, the Investigator should use his/her knowledge of the
constituents In the waste, the drainage patterns leading from the
unit to surface water, and the effect  of different surface water
bodies on the transport of various constituents, to Identify areas
to look for evidence of release.  He/she should also use this
knowledge to specify appropriate sampling  points.
                               6-7

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0,
     The Investigator should examine any available  sources  of
Information to Identify evidence that constituents  have  been
released to the surface water at a facility.   The  Investigator
should evaluate both direct and Indirect evidence  of  release
collected during the PR.  General  considerations  on how  to  look
for evidence of release are discussed 1n Chapters  Two and Three,

     Direct evidence of release to surface water  may  Include
official reports of prior release Incidents,  such  as  a major  tank
car spill to the ground or documentation that a surface  Impound-
ment has released to surface water.  Indirect evidence will
usually entail Information from surface water quality monitoring
data, Including visual observations of aquatic stress (e.g.,  fish
kills) from water contamination.  When the Investigator  Identifies
indirect evidence of this type, 1t may be necessary to determine
Us source at the facility by evaluating the  pollutant migration
pathways and the waste characteristics at the facility.

     The Investigator should examine available sources of  Infor-
mation and use recent visual observations obtained during  a
site Inspection to Identify any evidence that hazardous  constit-
uents have released from SWMUs at the facility to surface  water.

     NPOES. files are particularly useful 1n Identifying  historical
releases to surface water or determining the  likelihood  of  current
releases.  NPOES personnel that are familiar  with the facility  can
often obtain Information on past releases. Other key sources
of Information Include: RCRA Inspection reports, CIRCLA  reports
(e.g., PA/SI), and discussions with the State agency responsible
for fisheries and wildlife management,

     Due to the Intermittent nature of many surface water  releases,
the VSI 1s particularly Important.  The Investigator should
examine the site and nearby surface water for physical evidence
of release and focus on trying to obtain evidence of releases 1n
areas between the unl-, and the closest surface water body.   The
Investigator should look for visible evidence of uncontrolled
run-off.   If releases have occurred or are occurring at  a  unit,
there Is likely to be evidence around the unit that Indicates a
release 1s taking place.  In addition, 1f the facility 1s  located
adjacent to surface water, the Investigator should examine  the
surface water for evidence of releases.  During the VSt , the
Investigator should look for:

     o  Observable contaminated run-off or leachate seeps;

     o  Drainage patterns that Indicate possible run-off from
        units at the facility;

     o  Evidence of wash-o'jts o* floods,, such as highly eroded
        soil, damped trees, e t c  ;

-------
     o  Discolored  soil,  standing  water,  or  dead  vegetation
        along drainage  patterns  leading  from the  unit;

     o  Discolored  surface  water,  sediment or dead  aquatic
        vegetation;

     o  Evidence of  fish  kills;

     o  Unpermltted  point source discharges;

     o  Units (Including  old  fill  material that  1s  now  considered
        hazardous waste)  discharging  1n  surface  water;  and

     o  Permitted discharges  that  are of concern,  e.g.*  downstream
        contamination resulting  from  permitted discharges;
        release of  RCRA constituents  to  surface  water;  NPDES
        units/discharges  causing contamination problems  In  other
        media (e.g., air, ground water).

E-   E x po s u r e P o 1 1 n t 1 a 1

     The Investigator should  evaluate available  Information  on
the location, number, and characteristics of potential  receptors
that could be affected  by surface  water  releases  at the. facility,
These receptors Include human populations, arrival  populations
(particularly any endangered  or  protected species), and  sensitive
envl ronments .

     Potential receptor Information will be  used primarily  In
helping the Investigator  determine the need  for  Interim corrective
measures at the facility  In order  to  address Instances  of surface
water contamination  posing  especially high  risks of exposure.

     The Investigator should  evaluate the likelihood for receptors
to be exposed to hazardous  constituents  through  releases to
surface water 1n order  to assess the  severity of release.  If
receptors are currently being exposed to a  release or have  a  high
potential for being exposed,  then  the Investigator should consider
recommending Immediate  corrective  measures  (e.g., run-off control
measures) to Hm1t  or eliminate  exposure to  the  release*

     The types of information that are useful 1n evaluating  the
potential fof human and environmental receptors  to be exposed  to
surface water releases  are  discussed below.
     Human receptors can be exposed to the release via their
use of surface water.  The Investigator should determine the use(s)
of the surface water body of concern (e.g., no use, commercial  or
1r>dustr1als Irrigation, fisheries, commercial  food preparation,
recreation, or drinking).  A release Is more likely to signifi-
cantly Impact human health 1f the surface water 1s being used as
a source of contact recreation (e.g., swimming) rather than being
                               6-9

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used for Industrial  of * eowtretal  purposes.   Information on the
location 0f tfty drlnfclrrf of Irrigation water Intakes  Is usually
listed tn ptttilfe r*eord$ which may  be obtained from  the local
haalth
2.    n v f f e ff iftt i 1  f e c f p I o r s

     Constituents In a release to surface water may contact sen-
sitive habitats (e.g., a highly productive biological  community,
or a habitat of rare or endangered plants or animals).  The
Investigator should locate any sensitive habitats 1 n the surface
voter pathway.  This Information can generally be obtained by
talking with State Msh and wildlife Management Agencies and
local environmental groups.  In some cases, reports such ai-
envl ronmental Impact studies have been prepared for the area.

F.   OetefjBlnlng the Need for Additional Sampling

     In the surface water medium, Investigators may often find
that existing data on a release from a unit 1s unavailable or
insufficient.  In cases where historical Information and visual
observations are not adequate to determine If a surface water
release from a unit has occurred or 1s likely to have occurred,
he/she should consider whethir additional sampling wd analysis
^ould help In talcing a determination.  !n this section, we
present ;

     &  Seneral Information on factors to consider fn deter-
        mining the need for additional sampling 1 nf or wit ton;

     o  Factors to consider 1n selecting sampling  parameters;
        and

     o  An example to Illustrate this discussion.

1 ,   Seneral. Information on Determining The Need far Sampling

     The following are example situations where additional analy
tical data would be helpful 1n determining 1f a release has
occurred:

     o  During visual Inspections,  Indirect evidence of a
        release  (e.g., oil  slicks,  foam) have been observed,
        and  chemical analysis may Identify the unit causl.ig
        the  release; and

     o  Existing surface water monitoring  data or  available
        Information suggest a release, and more data will
        either confirm the  release  and/or  Identify the  unit
        of concern.
                                6-10

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               fff
     Knowledge of the wastes that may be potentially released
from a unit Is tWe starting point when Identifying sampling
parameters. Hwf&ver, many SVfMUs have Incomplete or no data on the
wastes deposited over time.  When little 1s known of the wastes
managed 1n the unit, gas chromotography/mass speetrometry (SC/MS)
scans such as acid extractables or base/neutral extractables be-
come a good starting point when selecting parameters for analysis
in surface water and sediments.

     When a wsstt source is hazardous due to EP Toxidty, the
metals of concern are arsenic, barium, cadmium, chromium, lead,
mercury, selenium, and silver.  The following metals precipitate
readily under many naturally occurring conditions and can be
found in sediment analysis: cadmium, lead, nickel, and zinc.

     The volatile SC/MS scan identifies chemicals that are charar-
teMstlc of solvents and lighter petroleum products (e.g., gaso*
line),  Many of these compounds are readily found In the environ-
ment from releases from various waste sources.  Because they are
very volatile, and surface water bodies (particularly rivers artd
streams) have the capacity to release these constituents via
evaporation into the air, evidence of these chemicals may be very
difficult to obtain.  It is not recommended to afnalyie surface
water bodies for these constituents unless a release Is current
or on-going,  leachtte samples and run-off, If avtlliWeg are
more ammenable to retaining evidence of volatile eefnstlttreht
releases.

     Add extract able compounds may be present !,i heavier petro-
leum feedstocks, and certain industrial processes fef, penta-
chlorophenol from woffd preserving).  Some  of those camp&ands
(e.g., phenol, pentaehlorophenol, 2-chlorophenol} are present  In
common aste sources, including P0TW discharges.  Piewo'l and the
mono-halogenateu phenols blodegrade readily in most soil and
surface water environments.

     Base/neutral compounds can often be  found 1n wastes from
industries such as  plastics and  synthetic  fibers manufacturers.
The pesticide scan  Identifies pesticides  that  are found  specif-
ically in pesticide  wastes  and products from the agrlchemisal
i ndustry.

     When collecting surface water and sediment  samples,  It  may
be valuable to sample an up-stream site for the  same chemical
parameters t'.iat will be  analysed  in the area of  the  suspected
release.  There will often  be a  high potential for  other waste
sources  (e.g., PGTWs, industrial  NPDES discharges)  to contaminate
surface waters with  the  same  constituents  under  investigation  in
the RFA.
                                6-11

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3.   Exajtglff

     An flTcfftration of a situation in which sampling would be
called for is t's follows;  A waste pile of thickened and filtered
wastewater treitmtnt sludges from an electroplating operation has
been stockpiled on a cement pad for almost ten years.  Visual
Inspection of the waste pile shows that there are no on-site
controls to prevent run-on and run-off.  In fact, channels  are
observed leading downgradient from the pile, reaching a medium
sized stream about 200 yards sway.

     The waste pile contains both copper and nickel from the
electroplating process. The sludge was formed by the treatment
of wastewaters containing copper cyanide and nickel cyanide by
the additiort of lime to form insoluble precipitates.  Analysis
of current sludge samples shows significant levels of cyanide.
There is no-data on the cyanide levels in the ten year old
waste pile.  There is no water quality data from the stream
on the parameters of interest (e.g., copper, rriefcel, Or cyanide).
Fish kills were reported on the stream eight or more years  ago.
There have been no recently documented fish (tills.

     In this scenario, the investigator should probably call
for sampling to find constituent-specific evidence of a release
to surface water*  Cyanide, being mobile in wattfi ts anticipated
to be leached out of the waste pile,and dispersed down stream
during storm events.  Any evidence of a release mast be preserved
in the soil and setffment.  Therefore, the sampling program centers
around copper and nickel analysis frt the soils and sediments*
Soil sampling is recommended for the low spots in the drainage
where run-off may have formed puddles.

     The investigator should take sediment samples Of the stream
bottom, and analyze them for copper, nickel, and cyanide*
Because cyanide is soluble and degradable in small guffntltles in
the sediments and soils, it may not be found fit the Sediments or
remain in the water. Because of the high cost and  dttiy asso-
ciated with analyzing sampling results, the investigator may
attempt to limit the selection of sampling parameters to thos.e
most likely to result in an identification of a  release.


III. COLLECTING ADDITIONAL SAMPLING INFORMATION  IN THE SV

     This section presents technical information  related specifi-
cally to the surface water pathway  to  be considered when collect-
ing additions) sampling  information in the SV.   Accordingly, the
information presented here should be used to help  the investigator
meet one of the primary  goals of  the SV:

     o  To collect additional sampling information to fill  data
        gaps identified  in the PR and  SVI.
                                6-12

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     Per etch fffpllfig method discussed, this section describes:
1) the fen*ft) fcfrWs ef situations In which it will  be appropriate
to employ a sptftffe teehni^ut, 2) technical  Information on how
to conduct th/e tiwpHrtf, and 3) specific details to  be considered
when evalttStfWf tfi* sampling results.  This section  does not pro-
vide the actail SOPs on sampling techniques,  but references
relevant manuals*

     The choice of appropriate sampling methods will have a large
impact on the cost and usefulness of the S.   The Investigator
should be confident when developing and reviewing the sampling
plan that the procedures chosen will meet the needs  of the RFA,
while not resulting 1n the collection of unnecessary data.  This
section discusses the following four sampling methods which may
be of use:

     (1) Surface water sampling;

     (2) Sediment sampling;

     (3) Soil sampling; and

     (4) Run-off sampling,

A.   Surface Mater Samel Ing

     It 1s Important to select sampling locations fdr surface
waters prior to actual sample  collection since Idcttfaft will
often affect the choice of sampling equipment.  Selection of
sampling location depends on Surface water body type  (e*g. pond
or stream), flow rate, depth,  and width.   In practle*,  safety and
physical access limitations will  often  affect  sample  locations.

     Surface water samples can be collected  dlrfctTy  &'y submerg-
ing the sample bottle.  However,  It  is  preferable to  ate  a  sample
collection container  (e.g., beaker), properly  cleaned ind of
appropriate material, to avoid contaminating the outtfde  of the
bottle used to transport the sample  back to  the laboratory.

     It 1s often necessary to  collect  samples  away  fro* the
shore.  If a plume 1s  visible,  samples  should be taken wfthtr*  the
plume.  A telescoping aluminum pole  with an  adjustable  fceaSter
clamp attached to the end is the  easiest device to  use  to reach
sampling locations  several feet  off-shore.   The collection  vessel
or the  sample  bottle  1s held by  the  clamp.   Samples  can be  trans-
ferred  to appropriate bottles  for shipment back to  the  laboratory.
Surface water  samples should be  preserved  and  cooled  to 4C prior
to shipment to the  laboratory.   The  laboratory  may  provide  the
preservatives  within  the bottles.   These cannot be  used for
direct  sampling.
                                6-13

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8.   SVitrfitt &M Sfe(t latent Same ling
     Sediment or sludge can usually be sampled by using a
stainless Steel scoop or trier,  Where sediment has a shallow
liquid layer above 1t, 1t may be scooped by a pond sampler or
preferably with a thin-tube sampler.  This device 1s preferred
because It causes less sample disturbance and will also collect
an aliquot of the overlying liquid, thus preventing drying or
excessive sample oxidation before analysis.

     If the sludge layer 1s shallow, less than 30 centimeters,
corer penetration may damage the container liner or bottom.  In
this case, a Ponar or Ecfeman portable dredge can be used since
these samplers can generally only penetrate a few centimeters.
Of the two samplers, Ponar grab samplers can be applied to a
wider range of sediments and sludges.  They penetrate deeper and
seal better than the spring-activated Eckman dredges, especially
in granular substrates.

     When sampling, the investigator should consider a number of
additional factors.  For Instance, because streams, lakes, and
impoundments generally demonstrate significant variation in
sediment composition resulting from distance from inflows, dis-
charges, or other disturbances, the investigator should document
exact sampling locations by means of triangul at ion with stable
references on the banks of the stream or lake.  In addition, the
Investigator may have to modify or not use some devices .described
above If rocks, debris and organic material in the sediment
complicate sampling.

     EPA's publication, C h ar ac t e r 1 z a tl o n of Hazaj'&Cttts
Maste S-1tfts-A Methods Ha n.tt'a\T 'Volume IT7 JvallifeM "Simp llrtfl
tfethgds . f Iconcf Etf'f f on 8 pages 2-f toT-llT, describe these
sampTTng f e elf n Tq He s In greater detail.

C.   Soil Sampling

     If run-off or leachate samples cannot be obtained  directly
(e.g.,  lack of precipitation), soil samples can be taken within
gullies or other run-off channels to identify contamination.
Results showing contami nated soil in a run-off pathway will  indi-
cate the potential for a surface water release.  Constituents
found i rv drainage pathways may confirm the presence of  contaminated
run-off,  The identification of a release to soils and the appro-
priate  sampling protocol is coveted in Chapter Seven, Soils.
D.   R u n^p_f Jf S amp Ujlg

     Sampling of run-off and leachate seepage involves several
technical difficulties and will be less common  in the ftFA.  The
major criteria used tu determine how and where  to sample  include:
obtaining a representative sample, safety of the personnel  con-
ducting the sampling, and the  timing of sample  collection with
the high precipitation necessary to create  run-off  or infiltration
                               6-14

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and seepage, laefc of precipitation during the sampling program is
the major obstacle to obtaining run-off samples.

     Due to the differences in run-off patterns between facilities,
no one sampling method is considered reliable for obtaining a
representative sample at every location.  The investigator will
need to use professional judgment when designing site-specific
sampling plarts.  When sampling sheet run-.off or small leachate
streams, a weir may be used to enable the liquid to spring free
of the surface to provide a sufficient volume for the parameter
analysis..  These, samples should be collected as grabs and all
parameters should be taken within a short period of time (i.e.,
1 ess than IS fti nutes),

     The best method for manually collecting samples is to use
the actual sample container that will be used to transport the
sample to the laboratory.  This wil 1 prevent the contamination of
samples by the use of a collection device,  The collection
container should be properly cleaned.

     Samples for oil and grease analysis SfrouTd be collected dir-
ectly from the run-off,,  The Investigator should avoid, using
collection vessels whe'h transferring oil awd grease samples since
oil residue will adhere to the vessel and may rfot be transferred
with the sample to the container.

     Care should be taken to avoid collecting leaves and debris  in
the vessel.  The sample can then be transferred to the appropriate
container.  Some laboratories will add the preservatives directly
to the sample containers and other laboratories will have the
sampling team prestrve the samples.  The investigator should
use appropriate methods to preserve run-off samples.  Leachate
samples, which are generally considered to be hazardous samples
rath&r than environmental samples, should not be preserved.  SM
846, Test MethQds, for Evaluating Solid Waste -  Ph^stial Ch.e.mtea-1
          .                               ,
Methl?  "is t   "ft'sf reference f oFTaTardOus
             ^sls of Water and ;itfaste_s is a good r*fereWce~TFr
p r e s e rv a f To"n t e e h n f q .  e s for r u nof f Tamp 1 e. s .

     In evaluating results, it is very important to determine if
representative samples ^ere obtained and appropriate sampling
methods were used to collect parameters.  QA/QC protocol for
sampling is described in Chapter Four.


IV,  MAKING SURFACE WATER RELEASE DETERMINATIONS

     This section summarizes information that the investigator
should consider **hef* making release .determinations in the  surface
^ater pathway,                            .  
                               6-15

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and seepage. Lack of precipitation during  the  sampling  program 1s
the major obstacle to obtaining run-off  samples.

     Out to the differences  1n run-off patterns  between facilities,
no one sampling method Is considered reliable  for obtaining a
representative sample at every location,  The  Investigator will
need to use professional judgment when designing s1te~speif1c
sampling plans.  When sampling sheet run-off or  small  leachate
streams, a weir may be used  to enable the  liquid to spring free
of the surface to provide a  sufficient volume  for the  parameter
analysis.  These samples should be collected as  grabs  and all
parameters should be taken within a short  period of time (I.e.,
less than 15 minutes).

     The best method for manually collecting samples is to use
the actual sample container  that will be used  to transport the
sample to the laboratory.  This will prevent the contamination of
samples by the use of a collection device.  The  collection
container should be properly cleaned.

     Samples for oil and grease analysis should  be collected dir-
ectly from the run-off.  The Investigator should avoid using
collection vessels when transferring oil and grease samples since
oil residue will adhere to the vessel and may not be transferred
with the sample to the container.

     Care should be taken to avoid collecting leaves and debris 1n
the vessel,  The sample can  then be transferred  to the appropriate
container.  Some laboratories will add the preservatives directly
to the sample containers and other laboratories  will have  the
sampling team preserve the samples.  The Investigator  should
use appropriate methods to preserve run-off samples.   Leachate
samples, which are generally considered to be hazardous samples
rather than environmental samples* should not be preserved.  SW
846, T e st Hethoids for Evaluating 5olid Haste - Physleal C h e m 1_ca 1
MethodjT'n^^
C hemflSlAna lys 1 s of .Mat e r. and Hastes is a good reference  for
p r' e s"IEi r-7a tTo rit ec "tiin f qui e"sif or r u n-oTf sa mp 1 e s.

     In evaluating results, 1t Is very,  important to determine 1f
representative samples were obtained and appropriate sampling
methods were used to collect  parameters.  QA/QC protocol  for
sampling is described in Chapter Four.


IV.  MAKING SURFACE WATER RELEASE DETERMINATIONS

     This section summarizes  Information that the  investigator
should consider when making release  determinations  1n  the  surface
water pathway.
                                6-15

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     Chapter Four presents  the general  procedure  to  be  followed
when making release determinations  1n  the  RFA,   This  involves:

     o  Evaluating sampling results from the  SV;

     o  Integrating facility information gathered in  the  PR,
        VSI, and the SV;

     o  Determining the likelihood  of  release at  the  facility;  and

     o  Making recommendations concerning  the need for  further
        i nvesti gations .

     The Investigator should rely upon Information available  and
his/her best professional  judgment  when making  release  determina-
tions In the surface water  pathway.  As stated  1n Chapter Four,
it will often be necessary  to make  deductions on  the  likely
origins of surface water contamination 1n  the RFA when  there  is
evidence of such contamination.  In order to  do this, the Inves-
tigator should be able to demonstrate  that:  1)  the constituents
identified in the surface water or  sediments  were present 1n  the
specific unit or group of units; and 2) the  pollutant migration
pathways at the site support a determination  that a  constituent
leaking from a specific unit or group  of units  would  be likely  to
migrate to the surface water of concern.  The Investigator should
rely upon best professional judgment in making this  determination.

     Further Investigations to establish the  presence of, and
character of, surface water (and/or sediment) contamination
problems, and the sources of such contamination,  should be required
of the owner/operator when  information or evidence Indicates  that
there is or is likely to be releases from the facility to the
surface water body which poses an actual or  potential threat  to
human health or the environment.

     Exhibit 6-2 is a checklist that should  help the Investigator
evaluate specific factors to Identify surface water releases
and  determine the relative effect on human health and the en-
vironment.  In Identifying releases, the Investigator should
consider the types of information presented  in Exhibit 1-1
which are highlighted in this  checklist.
                               6-16

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                           EXHIBIT  6-2

               Checklist  for Surface Water  Releases
o  Unit Design and Physical  Condition
                                                     i

      Are engineered features (e.g., run-off control  systems)
      designed to prevent releases from the unit)?


      Does tb.e .operational history of the unit Indicate that a
      release has taken place (e.g., old, closed or Inactive unit,
      not Inspected regularly, improperly maintained)?


      Does the physical condition of the unit Indicate that re-
      leases may have occurred ( e.g., cracks or stress fractures
      1n tanks or erosion of earthen dikes of surface Impound-
      ments)?


o  Release Migration Potential


      Does the slope of the facility and Intervening terrain
      indicate potential  fexr release?


      Could surface run-off from the unit  reach the nearest
      downgradlent surface water body?

                                                         /
      Is the  Intervening  terrain characterized by  soils and
      vegetation that  allow overland migration  (  e.g., clayey
      soils,  and sparse vegetation)?


      Does data  on one-year 24-hour  rainfall  Indicate  the  poten-
      tial for area storms to cause  surface  water  or  surface
      drainage contamination  as  a  result  of  run-off?
                                6-17

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                       EXHIBIT  6-2  (cont.)

               Checklist  for Surface Water  Releases
o  Waste Characteristics


      Is the volume of discharge high  relative  to  the  size and
      flow rate-of the surface water body?


      Do constituents in the discharge tend  to  sorb  to sediments
      (e.g., met ats)?


      Do constituents in the discharge tend  to  be  transported
       downstream?                              ,
                                    \

   -  Oo waste constituents exhibit moderate or high characteristics
      of persistence (e.g., PCBs, dloxlns,  etc.)?


   -  Do waste constituents exhibit moderate or high characteristics
      of toxleity (e.g., metals, chlorinated pesticides, etc,)?


o  Evidence of Release


       Is there direct evidence (e.g., sampling data;  observed
       contaminated run-off)?


      Is there Indirect evidence (e.g., discolored son , dead
      vegetation)?
                               6-18

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                          CHAPTER  SEVEN

                               AIR
I.   INTRODUCTION
                      *
A,   Purpose

     This chapter provides technical  Information  to  support  the
Investigation of air releases during  the  RFA.   While Chapters  Two
Three, and Four provide general  guidance  on  conducting  an  RFA,
this chapter focuses on specific factors  unique to the  air medium
that should be considered by the Investigator.

     In Investigating the potential  for air  releases during  the
RFA, the Investigator should focus his/her attention on operating
units.  Operating waste management units  have  the greatest poten-
tial for air releases because they actively  expose wastes  to the
air on a continuous basis.  In Investigating air releases, EPA
personnel should take safety precautions  1n  order to reduce  their
exposure to on-s1te emissions.  Safety precautions are  discussed
In Chapter Four*
                                                       f
     Wastewater treatment units, such as  those in treatment
trains regulated by NPOES, can cause  significant volatile  air -
emissions.  The Investigator should address  potential ilr  releases
from these units 1n the RFA.
               -t
     This chapter is organized to reflect the  separate  phases of
the RFA process:

     o  Conducting a preliminary review of existing information;
     o  Conducting a visual site Inspection;
     o  Collecting additional sampling information in a SV; and
     o  Making release determinations.      *
         /irst section describes the technical factors that should
be considered during the PR and VSI.  The second section describes
the technical approach to obtaining additional sampling information
in the SV for air, and should be consulted along with Chapter
Four on conducting a SV.  The final section discusses factors to
consider when making air release determinations at the end of the
RFA.  This section also presents options for further Investigation
of air releases to be evaluated at the end of the RFA.
                               r.

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 .    COHOUCTIN0 A PRELIHINARY  REVIEW  AND  VISUAL
     SITE INSPECTION OF  AIR  RELEASE  POTENTIAL

     This fiction presents technical  Information  related  specifi-
cally to the air pathway to  be considered when  conducting the  PR
and VSI,  Accordingly,  this  suction  has  been  organized  to reflect
the primary go^ls rf these phases  zf  the  RFA  described  1n Chapters
Two and Three:

     o  Identifying and  describing potential  threats  to air  at
        8CRA facilities; and

     o  Making  a preliminary assessment  of the  need  for a SV or
        other actions at these facilities.

     This section presents technical  Information  specific to the
air pathway covering thi five  types  of Information described 1n
Exhibit 1-1, and technical Information to help  the Investigator
determine when  additional sampling will  be necessary  1n a SV to
Identify air releases.   We will discuss  these six types of Infor-
mation separately:

     (1)  Unit  characteristics;

     {2}  Waste characteristics;
                                   /
     (3)  Pollutant migration pathways;

     (4)  Evidence of release;

     (5)  Exposure potential ;  and

     (6)  Determining the need for additional sampling Information.

This Information 1s relevant to the evaluation  of written documents
1n the PR and Information gathered 1n the VSI.

A,   Unjt C h aira c t e r 1,stJj:s

     The design and operating characteristics of a SWHU will
determine to a great extent their potential for releasing hazardous
constituents to air.  While the Investigator should evaluate all
SWMUs  for air releases, including NPDES units,  the Investigation
should focus on operating units.  As previously mentioned, opera-
ting units have the greatest potential for air releases because
they actively expose wastes to the air on a continuous basis.
Wastes in closed, Inactive units will have a lower potential to
cause  air releases.  There may be some exposure to the air 1f a
cover  has eroded or broken do-nn, but air  releases resulting from
these  situations are likely to be negligible (I.e., undetectable).

     When assessing the potential  for releases, the key factors
to examine Include:
                               7-2

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     0   Unit  slit.   The  size  of  a  unit  determines  the  mass  of
        p'ot'Irtt'faT  contaminants available  for  release.   Volatil-
        ization  rates  are  likely to  be  larger  from open  units
        (e.g.,  surface Impoundments  and open  tanks}  with  large
        surface  areas.

     o   Purpose  of the unit  (treatment, storage,  or  disposal?*
        ingeneral* units  In  which active treatment  Is occurMng
        have  the greatest  potential  for air  releases.   In many
        cases,  treatment is  designed to promote  volatilization  of
        constituents.   In  other  cases,  this  1s  not the main
        purpose  of the treatment method 1n use.   However, the
        resultant  mixing and  movement of  wastes  leads  to  high
        volatilization rates.

     o   0 es 1 9.n._ o f _the  unit.   Units In which  wastes are 1n direct
        contact  with the atmosphere  have  a higher potential for
        releases than  closed  or  covered units.

     o   Current  operational  status.   The  nature  of air releases
        Is such that the majority of the mass  available for
        release will be released shortly after the waste 1s
        placed 1n the unit.  Thus, as mentioned,  operating units
        are of greater concern than closed units.   This 1s par-
        ticularly true for unit types and wastes  for which vola-
        tilization 1s Important,  Units with potential  partlculate
        releases may continue to release contaminants well after
        closure, especially If the unit has been  poorly maintained,

     o  Unit specif1c factors.  There are specific design and oper-
        atTo n aT f a c t o r s a s s oc1 a t e d with each unit  type which are
        useful In evaluating the potential for release*  These
        factors are summarized 1n Exhibit 7-1.

In addition to considering the Individual unit sizes, the Investi-
gator should be aware of the totaj area used for  solid waste
management at a facility.  AlWotTgh Individual units may have
undetectable releases, the total release from a facility can be
significant.  Exhibit 7-1 lists specific considerations for par-
ticularly Important unit types.

     In assessing a unit's potential for air release, the Inves-
tigator should be aware of the Importance of Interactions between
the various unit characteristics listed above and the character-
istics of the wastes placed 1n the unit.  It Is Important to
examine how these two factors combine to result 1n an air release.
For example, a facility may have several large operating surface
Impoundments, suggesting a potential for large air releases.
However, 1f the facility 1s a steel manufacturer  treating only
spent pickle liquor In these ponds, 1t 1s unlikely any air
release will occur because the hazardous constituents 1n the
waste are non-volatile, soluble metals.
                               7-3

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                           EXHIBIT 7-1

                 UNIT POTENTIAL FOR AIR RELEASES
                    AND MECHANISMS OF RELEASE
Unit Type
Characteristics and Mechanisms of Release
Operating Surface
Impoundments
   Wastes directly exposed to atmosphere
   promotes vapor phase emissions
   Large surface areas and shallow depths
   promote Increased volatilization
   Mechanical  treatment methods (such as
   aeration) Increase volatilization
Open Roofed Tanks
   Wastes directly exposed to atmosphere
   (promotes vapor phase emissions)
   Mechanical treatment or frequent mixing
   will Increase volatilization
Landfi 1 1 s
   Volatilization of vipor phase constituents
   through the sub-surface and dally/permanent
   cover
   Poor or no dally cover Increases volatili-
   zation
   Open trench fill operations allow direct
   exposure of waste to atmosphere
   Volatile gases transported by convection
   of blogenlc gases released via routine
   landfill venting (particularly Important
   In sanitary/hazardous mixed fills)
   Partlculate releases generated by machinery
   during filling operations
   Partlculate releases due to wind erosion of
   cover and/or exposed wastes
Land Treatment Units
   Wastes normally In direct contact with
   atmosphere
   Application techniques which maximize waste
   contact with atmosphere, such as surface
   spreading or spray 1 rMgatlon ' promote
   Increased volatilization
   Partlculate releases due to wind erosion
                               7-4

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                     EXHIBIT 7-1  (Continued)

                 UNIT POTENTIAL  FOR  AIR  RELEASES
                    AND MECHANISMS  OF  RELEASE
Unit type


    -, Piles
Characteristics and Mechanisms of Release
   Participate emissions from uncovered
   waste piles
   Location of waste pile 1n open area with
   no erosion protection promotes participate
   generation
   Waste handling activities on and around
   pile Increase emissions
   Volatile emissions are likely to be rare,
   but can occur based on waste composition
Drum Storage Areas
   Vaporization from drums frequently left
   open to atmosphere or from poorly sealed
   drums
   Vapor emissions from areas containing
   leaking drums
Covered Tanks
o  Volatile releases from pressure venting,
   poorly sealed access ports, or Improperly
   operated and maintained valves and seals.
Inclnerators
o  Stack emissions of partlculates
o  Stack emissions of volatile constituents
   High temperatures may cause volatilization
   of low vapor pressure organles and metals
o  Volatile releases via malfunctioning valves
   during Incinerator charging
Non-RCRA Wastewater
Treatment Ponds and
Tanks
   Low concentration wastes may volatilize
   due to large surface area and active waste
   treatment.  Releases can be significant
   due to generally large treatment
   capacities
Other Design and
Operating Practices
    Inadequate spill collection systems promote
    Intermittent air releases
    Lack of vapor collection systems for use
    during container/tank cleaning operations
    Absence of dust suppression or partlculate
    control measures
                               7-5

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                                  EXHIBIT  7-2

              PARAMETERS  AND  MEASURES  FOR  USE  IN  EVALUATING
          POTENTIAL AIR RELEASES  OF  HAZARDOUS  WASTE  CONSTITUENTS
    Emission and Haste
A, Vapor Phase Emissions

    Dilute Aqueous Solution^/
Units or Concern.!/
Surface Imp.,
Tanks, Containers
   -- Cone. Aqueous Solution^/     Tanks,  Containers,
                                   Surface Imp,
    Immiscible Liquid


    Solid




8. Partlculate Emissions

   -- Solid
Containers, Tanks
Landfills, Waste
Piles, Land Trt.
Landfills, Waste
Piles, Land Trt.
Useful Parameters
   and Measures
Solubility,
Vapor Pressure,
Partial Pressure,^/
Henry's Law

Solubility,
Vapor Pressure,
Partial Pressure,
Raoults Law

Vapor Pressure,
Partial Pressure

Vapor Pressure,
Partial Pressure,
Octanol/Water
Partition Coeff.
 Particle Size
 Distribution,
 Site Activities,
 Management Methods
        V  Incinerators are not specifically listed on this table be-
   cause~~of the unique Issues concerning air emissions from these
   units.  Incinerators can burn all the forms of waste listed 1n this
   table.  The potential for release from these units 1s primarily a
   function of incinerator operating conditions and emission controls,
   rather than waste characteristics.

        /  Although the octanol/water partition coefficient of a con-
   stituent 1s usually not an Important characteristic 1n these waste
   streams, there are conditions where it fan be critical.  Specif*c-
   ally, 1n waste containing high concentrations of organic partlcu-
   lates, constituents with high octanol/water partition coefficients
   will adsorb to the partlculates,  They will become part of the sludge
   or sediment matrix, rather than volatilizing from the unit.

        /  Applicable to mixtures of volatile components.
                                      7-7

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                                  EXHIBIT 7-3
              HAZARDOUS CONSTITUENTS OF CONCERN AS  VAPOR  RELEASES
  Hazardous Constituent

Acet aldehyde
Acroleln
AcrylonitM le
Allylchloride
Benzene
Benzyl chloride
Carbon Tetrachloride
Chlorobenzene
Chloroform

Chloroprene
Creosols
Cumene (isopropylbenzene)
1,4-dichlorobenzene
1,2-dichloroethane
Oichloromethane
Oioxin
Eplchlorohydrin
Ethyl benzene
Ethylene oxide
Formaldehyde
Hexachlorobutadiene
Hexachlorocyclopentadi ene
Hydrogen cyanide
             RCRA Waste Codes
K001.U001
K012
K011,K012,K013,U009
F024.F025
F024SF025,KOOI,K014,K019,K083,K085,K103,K105
K015,K085,P028
FOOl,F024,FOH5,KOl6fK016,K020,K021K073,U2ll
F001,F002,F024,F025,K015,K016,K085,K105
F002,F024,F02S,K009,K010,K016,K019,K020,K073,
K021,K029,U044
F024.F025
F004.U05H
U055                            ;
F002,F024,F025,K016,K085,K105,U072
K018,K019K020tK029,K030K096,F024fF02S,U077
F001,F0024F024iF025,K009,K010K021,Ud80'
F020,F021,F022,F023,F028
K017,K019,K020,U041                     .
F003
Uli.5
K009,K010,K038,KQ40,U122
F0249F025,K040,K016,K018,K030,U128
F024,F025,KQ32tK033,K034,U130
F007,F009,F010,K013,K060
                                       7-8

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                               EXHIBIT 7-3 (cant.)
              HAZARDOUS CONSTITUENTS OF CONCERN AS VAPOR RELEASES

  H&zardoys Constituent	RCRA Maste Codes     	
Hydrogen flourlde
Hydrogen sulflde
       anhydride             K023,K093,U147
     i] acetate
                             U100
Naphthalene                  FQ24,F025,KQQ1,K035,K060,KQ87,U165
Nitrobenzene                 F004,K025K083,K103,U169
                             K001,K022K087U188
                             P095
         anhydride           K016,KQ23,K024,K093fK094>U190
                blplieriyls    K085
   Apoelor 1242
   Aroelor 1248
   Apoe,1of 1254
   Araclor 1?0
P ropy 1 toe
t,l,2,2~tetrach1orðane    F024,F025,K016,K019,K020,K021,K030,K095,K096,U209
Tftrachloroethylftne          F001,FOQ2,F024,F025,K016,K018tKl09,K020,K021,U210
                             F005 ,F024,F025,K015,K036,K037,U220
                             F001fF002,F024,F025,K019,K020K028,K029K073,K095,
                             K096,U226
                             F001fF002,F024,F025,K016,K018,K019KOZO,U228
V1nyichloride                K019,K020tK023,K029,K028,FOH4,F025tU043
                             F003,F02^,K019,K020fF024,K029,UO?8
                                       7-9

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                          EXHIBIT 7-4
  HAZARDOUS CONSTITUENTS OF CONCERN AS PARTICULATE  RELEAStS
Hazardous Constituent
   Arsenic
          RCRA Waste Codes
0000,0004,K060,K021,K084,P010,
POH.P012
   Asbestos
U013
   Beryl 1ium
0000,0006,P015
   Cadmi urn
DOOQ,D006,FQQ6fFQ07,FQQ8,FQ09,
F061.F062, F064tFQ6S,F067,FQ68,F069
   Chromium
0000,0007fF006,F007tF008sF009F002
F064.F069.F086,
   Lead
0000,0008,F006,F009K003K044,K048,
K052,K061K062,K064tK069 K086.P110
   Mercury
D008.K071.K106
   Nickel
F006.F007.F008.F009
                             7-10

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higher the concentration of a  particular  constituent  present
in a wn1t the greater 1s Its  potential  for  air  release.   However,
the Intrinsic potential  for a  constituent  to volatilize  depends
on chemical  and physical properties  that  vary greatly between
different constituents.   Accordingly,  a  highly concentrated
solution of one constituent may result In  a  lower  release  potential
than a dilute concentration of another constituent.

     Constituent-specific physical  and chemical  parameters *re
very Important Indicators of the potential  for a vapor-phase
release*  The parameters most  Important  when assessing the v"a-
t1!1zat1on of a constituent Include  the  following:

     0  MatemsoIMb 111 ty.  The solubility In water Indicates  the
        maxfmurn eoncentratlon  at which a  constituent  can dissolve
        1n water at a  given temperature.   This value  can help
        the Investigator estimate the  distribution of a  constituent
        between the dissolved  aqueous  phase 1n the unit  and the
        undlssolved solid or Immiscible  liquid phase.  Considered
        1n combination with the constituent's vapor pressure. It
        can provide a  relative assessment of the potential magni-
        tude of volatilization of a  constituent from  an  aqueous
        environment.

     0  Vapor pressure.   Vapor pressure measures the  pressure of
        v a por in equ 1T1 br 1 um with a  pjire liquid.  It  1s  best used
        1n a relative sense; constituents with high vapor pres-
        sures are more likely  to have  releases than those with
        low vapor pressures, depending on other factors  such as
         elatlve solubility and concentrations (1*e.  at high
        concentrations releases can occur even though a
        constituent's  vapor pressure 1s relatively low).

     o  Octangl /water partH1 on coef f1c1 ent.  The octanol/water
        partflTon coefficient  TndTcrtes the tendency of an organic
        constituent to sorb to organic constituents 1n the soil
        or waste matrices of a unit.  Vapors with high octanol/
        water partition coefficients will adsorb readily to.organic
        carbon, rather than volatilizing to the atmosphere,  This
        Is particularly Important 1n landfills and land treatment
        units, where high organic carbon contents In soils or
        cover material can  significantly reduce the release
        potential vapor phase constituents.

     o  Part 1 a1 p re s s u re.   For constituents  1n a mixture, partlcu-
        larly in a solid matrix, the partial pressure of a consti-
        tuent will be more  significant than the pure vapor pressure.
        In general, the  greater the partial  pressure, the greater
        the potential  for  release.  Partial  pressures will be
        difficult to obtain.  However* when waste characterization
        data is available  partial pressures  can be estimated
        using methods commonly found  1n engineering and environ-
        mental science  handbooks.
                               7-11

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     o  Henry's  Law constant.   Henry's  lar  constant  is  the  ratio
        of the vapor pressure  of  a  constituent  and  Its  aqueous
        solubility  (at  equilibrium).   It  can  be used  to assess
        the relative ease with which  the  compound may be  removed
        from the aqueous  phase via  vaporization.   It  Is accurate
        only when used  concerning low concentration  wastes  1n
        aqueous  solution.  Thus 1t  will  be  most useful  when the
        uiiit being  assessed Is a  surface  Impoundment  or tank con-
        taining  dilute  wastewaters   Generally, when  the  value  of
        Henry's  Law constant 1s less  than 1QE-7 atro-m^  the  consti-
        tuent will  not  volatilize from  water.   As the value In-
        creases  the potential  for significant  vaporization  Increas
        es, and  when it is greater  than iOE-3  rapid  volatilization
        will occur.

     0  RaoultJs Law -   Raoult's  Law  can  be used  to  predict re-
        leases from concentrated  aqueous  solutions  (I.e.  solutions
        over 10% solute).  This will  be most  useful  when  the unit
        of concern  entails container  storage  tank  storage, or
        ti atment of concentrated waste streams.

     For solid wastes,  Im1sc1ble  liquids, and  wastes disposed  of
in landfills, land  treatment,  or  waste  piles,  thtrt  are no  simple
measures that can be used to assess the potential  for volatiliza-
tion of a constituent.   The Investigator will  need  to consider  the
appropriate chemical, physical, and unit  parameters,  and  then  use
his/her best judgment 1n determining  the potential  for release,

2.   Particulate Emissions

     Exhibit 7*4 lists  hazardous  constituents that  are of special
concern for particulate air releases.  Particulate  emissions from
solid waste management  units can contain organic material,  heavy
metals, or both.  The heavy metals  shown in Exhibit 7-4 are pre-
dominantly associated with participate releases, although both
arsenic and mercury may be present  as vapor phase releases  due  to
their relatively high vapor pressures.   Similarly,  the organic
compounds shown in Exhibit 7-3 may also be found adsorbed or bound
to soil and/or other participate matter releases.

     In general, there  will be fewer facilities with particulate
emissions.  However, at some facilities particulate emissions  may
be very significant (e.g., discharges from a lead smelter)  and
threaten the safety of  on-site workers and EPA personnel  during a
site visit.

     The likelihood of  particulate releases at hazardous waste
management facilities is generally associated with landfills,
land treatment units and/or waste piles.  The potential for
particulate releases is governed by different parameters than
those that affect vapor-phase  releases.

     For particulate releases, the size distribution of the
particles  In the release plays an  important role in  both
dispersion and actual exposure.  Large particles will  settle out


                               7-12

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of the 1r wore rapidly than swill  particles,  thus  they  will  not
travel as far off-site or be diluted as much by  dispersion.   Very
small particles (I.e., those that are less than  5 microns  1n
diameter), are considered to be resplrable and thus present  a
greater health hazard than larger particles.  The Investigator
should examine the source of the partlculate emissions  to  obtain
Information on particle size.

     The primary mechanism for generating partlculate releases at
hazardous waste facilities 1s wind erosion.  In  general, the
unit's location will affect the potential for the wind  to  erode
wastes 1n the unit.  The unit's location and orientation with
respect to the prevailing winds and large structures on-slte  will
determine the unit's vulnerability to wind erosion  and  the poten-
tial for partlculate releases.  Agency personnel should determine
the location of SWMUs of concern with respect to prevailing  winds
and the use of wind screens (both natural and mart-made) and  dally
covers to determine the unit's vulnerability to wind erosion.

C.   Pollutant Migration Pathway

     The Investigator should Identify the migration route(s)  for
potential air releases 1n-order to Identify:

     o  The locations along the route where target  populations
        may be exposed to the release; and

     o  Locations to sample for evidence of release (e.g., south
        or north edge of the unit), where no evidence of release
        exists, but the Investigator believes, based on unit and
        waste characteristics, that releases may occur.

      In Identifying air pollutant migration pathways, the investi-
gator should determine the direction of the prevailing winds
around the facility, and characterize the geography (e.g.* narrow
valleys and urban areas containing large buildings, or artificial
canyons) along the wind pathway*  Using this Information, he/she
should be able to Identify upwind and downwind sampling locations
and target populations that may be exposed  to air  releases along
their migration route.

     The investigator may be able to obtain some of this Information
from  local weather data bases as part of the PR.   Most of this
information, however, will probably be collected during the  VSI.

0.    Evidence of Release

      The investigator should examine any available  sources,of
information to identify evidence that constituents  have been
released to the air at a facility in a proportion  that  poses  an
actual or potential threat to human health  and  the  environment.
General considerations on how to look for  evidence  of release  are
discussed 1n Chapters Two and Three.
                                7-13

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     Direct evidence of air releases will Include the following;

     o  A1r sampling/monitoring data associated with a particular
        unit (e.g., samples taken from above a NPDES unit; moni-
        toring data required under a Clean A1r Act permit);

     o  Visual evidence of participate releases from a unit;

     Indirect evidence of release Includes the following:

     o  Evidence of contamination around the facility that may have
        resulted from an air release (e.g., accumulated partlculate
        emissions from a smoke stack or landfill/waste pile);

     o  On-slte air monitoring data gathered under the OSHA program;

     o  Records of citizen complaints associated with the facility
        concerning odors, headaches, nausea, or observed partlculate
        releases.
r
     During the vlusal site Inspection, the Investigator should
 identify any evidence that hazardous constituents have released
 or  are continuing to release from SWHUs at the facility to the
 air.  During the visual site Inspection he/she should confirm the
 presence of units of concern and look for evidence of partlculate
 emissions  from units.  Although the Investigator may occasionally
 smell vapor-phase releases, 1n most cases, these releases will  be
 difficult  to Identify without samples.  Procedures for collecting
 additional sampling Information are discussed  1n Section  III.

 E.   Exposure Potential

     The Investigator should evaluate available  Information on
 the location, number, and characteristics of potential receptors
 that could be affected by air releases at the  facility*  Human
 receptors  are of primary concern for air  releases.   Potential
 receptor Information will be used primarily In helping the  Inves-
 tigator determine the need for Interim corrective measures  at the
 facility In order to address Instances of air  contamination
 posing especially high risks of exposure.

     Population density and distance from the  source are  the  pri-
 mary factors  in determining the significance of  a potential
 exposure.  Distance should be measured from the  un1t(s)  containing
 the waste  rather than from the facility  boundary, although  total
 facility emissions  from all SWMUs should  also  be kept  in  mind.
 Most Importantly, the Investigator  should consider  the density  of
 the population  residing near the site, as well as transients  such
 as  workers 1n factories, offices, restaurants, motels, or  students.

     The most significant exposure  potential will occur  In  situa-
 tions when there is a high population density  very  close  to the
 site.  However, because concentrations can  be  quite  high,  even
 low density populations 1n such close proximity  to  the site are
                                7-14

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of concern.  Dispersion can significantly reduce  concentrations
as distance from a site Increases.   Thus, the significance  of
high population density at larger distances  from  the  site 1s
reduced.

     The Investigator needs to consider the  relationship between
distance, concentration, and population density in evaluating  the
significance of an exposure potential.   An additional  factor  to
consider Is the population located along the line of  the most
predominant wind direction at a site.   Becaus.e the RFA 1s pri-
marily concerned with continuous releases, populations located
along this line downwind of the site are more likely  to receive
significant exposures than populations  located along  other  vectors.

     If the investigator determines that units at a facility  are
releasing large volumes of unsaturated  hydrocarbons,  he/she may
need to consider population density over a much larger area*
These constituents contribute to the formation of photochemical
smog and ozone, which, in combination  with other  regional pollu-
tant releases, can cause significant exposures over a wide
geographic area.

F.   Determining the Need for Additional SamplingInformation

     If the investigator determines, based on his inspection  of
the unit, that there is a significant  potential for the unit  to
be releasing substantial quantities of volatile constituents  and
in consideration of the proximity of receptors, he/she may choose
to sample to determine conclusively whether an air release 1s
occurring which merits further Investigation^  We discuss in  this
section;

     (1)  General information on factors to consider  1n determining
          the need for additional sampling information; and
                                                        *">>-'"
     (2)  Factors to consider in selecting sampling parameters.

1.   General Information on Determining  the Need for  Sampling

     The Investigator should use his/her best professional  judgment
in determining when a unit may be releasing hazardous constituents
to the air.  In some situations, a unit  may exhibit a strong  poten-
tial for air releases, based upon unit and waste characteristics,
but the  investigator wants to confirm this with  additional data.
This may be necessary in situations where the owner/operator  has
not cooperated with EPA, and he/she may  contest  an EPA  request to
conduct  further investigations by denying the presence  of  air
releases.
                                7-1S

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 2,    Selection  of  Sampling  Parameters

      In  selecting  sampling  parameters, the  investigator should
 consider those  constituents  he/she  believes to be of concern at
 the  facility.   These  constituents are discussed  1n detail earlier
 1n  this  chapter*   In  general,  the Investigator will be able to
 confirm  a release  when  one  constituent has  been  shown to release,
 and  therefore,  the number of parameters considered should be as
 limited  as possible.

      In  many  cases, the  investigator will be able to confirm or
 deny the presence  of  an  air  release by sampling  for VOCs with an
 indicator device.   However,  these devices can miss episodic re-
 leases.   These  devices  (e.g.,  OVA and HNU)  measure the concentra-
 tion of  volatile  organUs in the air, and thus provide a screening
 level  technique for identifying  releases.   These sampling methods
 are  discussed  further 1n Section III.


 III. OBTAINING  ADDITIONAL SAMPLING  INFORMATION

      This section  presents  technical information related specifically
 to  air releases to be considered when collecting additional
 sampling information  1n  the  SV.  The information presented here
 should be used  to,  help  the  Investigator meet one of the primary
goals of the  SV;                                                           :

      o  To collect additional  sampling information to fill data
         gaps  identified  in  the PR and VSI,  leading towards final
         release determinations.

      For each  sampling  method discussed,  this section describes:           '
 1)  the general  kinds  of  situations  1n which It will be appropriate         j
 to  employ a specific  technique,  2)  technical information on how            j
 to  conduct the  sampling, and 3)  specific  details to be considered
 when evaluating the sampling results.  This section does not               !
 provide  the actual SOPs  on  sampling techniques here,  although  it           j
 does reference  the relevant  manuals where possible.                        I

      The choice of appropriate sampling methods  will  have a large          !
 impact on the  cost and  usefulness of the  SV.  The Investigator             \
 should be confident when developing and reviewing the sampling             j
 plan that the  procedures chosen  will meet the needs of the RFA,            I
 while not resulting 1n  the  collection  of  unnecessary  data.

      We  describe  several sampling techniques that will be appro-
 priate for identifying  air  releases during  the RFA:

      (1)  Indicator techniques (OVA and HNU};

      (2)  Draager  tubes; and

      (3)  Monitoring  stations wltiv  Tenax  tubes.
                                7-16

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i.   indicator Techniques (OVA and HNU)
                        >
     The most common air sampling technique  will  Involve  the  use
of portable air monitoring Instruments which measure  total  organic
constituents present In the air at the sampling  point.  The two
most commonly used devices are the organic  vapor analyzer (OVA),
and the HNU photolonlzatlon detector.  The  OVA detects  the  pres-
ence of organic compounds In air with  a  flame 1on1zat1on  detector,
while the HNU detects organic compounds  with a photo1on1zat1on
detector.   While these units provide  somewhat different  results,
this discussion will be limited to the HNU;  most of the discussion
will be applicable to use of the OVA,

     The HNU provides the Investigator with  a quick and simple
method for determining the presence of organic compounds  1n the
air, and for providing a general Indication  of their magnitude.
When evaluating the likelihood of releases  at wasttwater  treatment
tanks, the Investigator should hold the  HNU  as close as possible
to the unit and wait for the meter to  equilibrate,  The Instrument
provides a reading of organic vapor concentration 1n terms  of
parts per mil Hon.

     The Investigator should be aware  that  both of these  Instruments
are calibrated to measure accurately only one volatile constituent;
the HNU 1s calibrated for benzene, while the OVA 1s calibrated
for methane.  Thus, when encountering  other organic constituents,
the meter may Indicate either higher or  lower concentrations  of
that constituent than are actually present.   The Investigator
should consider that these Instruments provide general Indications
on the presence of volatile organlcs,  not quantitative evidence.
However, an HNU Indication of organic  vapors at a site may be
sufficient to compel further Investigations at that untt.

2.   D r a e ge r Tubes

     When the Investigator seeks more detailed Information on the
presence of-organic  constituents  1n the air, Oraeger tubes can be
useful for measuring specific constituents.  This sampling tech-
nique shares the advantage of the HNU and OVA In that Oraeger
tubes are a portable, field technique, which does not require
laboratory analysis*

     Oraeger tubes contain a sorbent material encased In a small
glass tube, through  which an air  sample 1s  pulled with a hand-
held pump.  The sorbent material  has been chemically-treated
to  turn  a color when the  specific constituent of concern 1s
present  1n the air.  The  length  of the stained material  Indicates
the concentration  of the  constituent 1n the  air; the tube  contains
a calibrated scale  for  reading  concentration  1n parts per  million
iMrectly off of the  tube.
                                7-17

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     Oraeger tubes have several  advantages over the Indicator
techniques discussed above.   Because they are constituent-specific,
they provide a better Indication of the toxldty posed by an air
release.  They also will provide a more accurate measurement of
the constituents of concern, since there 1s no problem based upon
the calibration to one constituent.  However, Oraeger tubes are
not available for all volatile constituents of concern.  They are
also slightly more difficult to use, 1n that the Investigator
should carry around Draeger tubes for each of the potential
constituents or vapor classes of concern at the site.  Still,
they should be considered extremely portable.

3.   Monitoring Stations with Tenax Tubes

     In some situations, the Investigator may find It necessary
to Install a stationary monitoring station for making more quan-
titative determinations of air releases at a site.  This air
monitoring will Involve the use of Tenax tubes to collect organic
constituents, and subsequent laboratory analysis of thes*
constituents with a GO/MS,  This sampling technique will seldom
be necessary during the RFA, primarily due to Its technical
difficulty, and because the simpler techniques described here
will generally provide sufficiently useful results,

     The Investigator should consult with qualified professionals
familiar with the use of air monitoring devices, when he/she
believes that more quantitative evidence of a release will be
necessary 1n the RFA.


IV.  MAKING RELEASE DETERMINATIONS

     The final task in the RFA process 1s to make determinations
of release potential throughout the facility and to make recommen-
dations for further action to address these potential releases.
This section summarizes Information that the Investigator  should
consider when making release determinations In the air pathway.

     Chapter Four presents the general procedure to  be followed
when making release determinations during the RFA.   This involves:

     o  Evaluating sampling results from the SV;

     o  Integrating facility Information gathered 1n  the PR  and
        the VSI;

     o  Determining the likelihood of release at the  facility;  and

     o  Making recommendations concerning  the need for  further
        1nvestigations.
                                7-18

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     The Investigator should rely upon his/her  best  professional
Judgment when making release determinations  1n  the  air pathway,
In order to make a release determination,  the  Investigator will
probably have to dimenstrate that a unit  of  concern  contains
constituents that have & potential  for vapor-phase  or participate
release.  In most casts, this Information  on constituent  release
potential along with some Indirect  evidence  of  release (e.g.,
odors, observed partlculate releases,  facility-wide  sampling
data) will prov sufficient to make an adequate release determin-
ation.  However, In certain cases,  1t  will  be  necessary to obtain
existing or new direct evidence of  release that links constituents
Identified through sampling with constituents  In the unit.

     Exhibit 7-5 1s a checklist that should  help th Investigator
evaluate specific factors to Identify  air  releases.   In Identifying
releases, the Investigator should consider types of  Information
presented 1n Exhibit 1-1, which are highlighted In  the checklist.
                               7-19

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                         EXHIBIT 7-5

                  CHECKLIST FOR AIR RELEASES
o  Unit Characteristics

      Is the unit operating and does 1t expo,a wastes  to the
      atmosphere?

      Does the surface area of the unit create create  a potential
      for air release?


o  Does the unit contain waste that exhibits a potential for
   vapor phase release?

      Does the unit contain hazardous constituents of  concern as
      vapor releases?


o  Does the unit contain waste and exhibit site conditions that
   suggest a potential for partlculate release?

      Does the unit contain hazardous constituents of  concern as
      partlculate releases?

      Do constituents of concern as partlculate releases (e.g.,
      smaller, Inhalable partleulates) have potential  for release
      via wind erosion, reentralnment by moving vehicles, or
      operational activities?


o  Evidence of A1r Release

      Is there direct evidence of  release from the unit  (e.g.,
      air sampling data; observed  partlculate releases)?

      Is there Indirect evidence of release from  the unit (t.g.,
      evidence of contamination around the  facility that may have
      resulted from an air release; OSHA monitoring data; citizen
      compHants regarding health  problems, odors, or  observed
      partlculate releases)?

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                          CHAPTER EIGHT

                          SUBSURFACE  GAS


I.   INTRODUCTION

A.   Purpose

     This chapter provides technical  Information  to  support  the
investigation of releases of subsurface  gas  during  the  RFA,
While Chapters Two, Three, and Four provide  general  guidance on
conducting RFAs, this chapter focuses on  specific factors  unique
to subsurface gas releases that should be conslderd  by  the Inves-
tigator.

B.   Scope

     In the RF^, Investigators should determine whether releases
of subsurface gas have occurred at a  facility.   In  general,  EPA's
primary concern 1s to determine whether  there are gas releases
that could reach explosive levels 1n  on-s1te or off*s1te buildings.
Therefore, the primary constituent of concern 1n  the subsurface
gas investigation is methane, due to  Its  explosive  properties and
frequency of detection 1n subsurface  gas.

     As with other media, the Investigations that roy be required
1n an RFI to determine the nature and extent of 'Subsurface gas
releases will be very resource Intensive  for both the owner/operator
and for the Agency,  Therefore, the Investigator  should also
identify 1n the RFA those units/facilities that do  not  require
further Investigation for subsurface  gas  releases*

     This chapter has been organized  to  reflect the  separate
phases of the RFA process:

     o  Making a preliminary assessment  of subsurface gas
        releases in the PR;
     o  Obtaining evidence in a VSI;
     o  Collecting additional sampling Information  1n a SV;  and
     o  Making release determinations.

     The first section describes the  technical  factors  that  should
be considered during the PR  and VSI.   The second  section describes
the technical approach to obtaining additional  sampling Information
in the SV for subsurface gis releases, and should be consulted
along with Chapter Four on general guidance  to be followed in
conducting a SV.  The final  section discusses factors to consider
when making release determinations of subsurface  gas releases.
This section also presents options for further Investigation of
subsurface gas releases to be evaluated  at the end  of the  RFA.
                                r"
                                ;

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II.   CONDUCTING A PRELIMINARY REVIEW AND VISUAL  SITE
     INSPECTION OF SUBSURFACE GAS RELEASE POTENTIAL

     This section presents technical information related specif-
ically to subsurface gas releases to be considered  when  conduct-
ing  the PR ind VSI.  Accordingly, this  section has  been  organized
to reflect the primary goats of these steps  in the  RFA:

     o  Identifying and describing potential  threats  from
        subsurface gas at RCRA facilities; and

     o  Making a preliminary assessment of the need  for  and
        extent of sampling required.

     This section presents technical information specific to this
pathway covering the five types of information described in
Exhibit 1-1, ,-nd technical information  to help the  investigator
determine when additional sampling will be necessary  in  a SV ,,0
identify subsurface gas releases.  The  section discusses these
six  types of information separately:

     (1)  Unit characteristics;

     (2)  Waste characteristics;

     (3)  Pollutant migration pathways;

     (4)  Evidence of release;

     (5)  Potential receptors; and

     {6}  Determining the need for additional sampling
          information.

     This information will be relevant to the evaluation of
written documents  in the PR and  information gathered In  a VSI.

A,   Un.1jt_ Cha racterisjjjcs

     The design and operating characteristics of a unit will
determine to a great extent its  potential for releasing methane.
The investigator should evaluate  the unit characteristics of each
SWMU or group of SWMUs at a facility to determine their potential
for contributing to the generation  and release  of methane in
subsurface gases.

     The general potential  for subsurface gas releases  from a
SWMU depends, to a great extent,  upon  the nature and function of
the unit.  The investigator should  assess each  unit based upon;

     o  An understanding of the  overall  potential of the unit
        to cause subsurface gas  releases;
                               8-2

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     o  An understanding of the primary mechanisms  by which
        rtl#sts may occur from the unit;  and

     &  An tsstssment of unit-specific factors  which, singularly
        or tn combination with each other, Indicate the relative
        likelihood of subsurface gas releases from  the un1t

     Tht Investigator should first consider the relative potential
of the unit to release.  Exhibit 8-1 presents a generalized  rank-
ing, 1r rough descending order, of the different types of SWMUs  and
their oviftfl potential for causing subsurface  gas  releases,  and
* listing df tht most common mechanisms by which these releases
cin occur frow tach unit type.

     It should b understood that Exhibit  8-1 provides only  a
tho**tt1e;il stnst of the relative potential of  these units to cause
rtleaset*  Untt*p-*c1f 1c factors should be evaluated In determining
        further Investigations are needed  for a particular unit.
     Only tw$ typi&s of solid waste management units are of
concern In tht subsurface gas Investigation due to their poten-
tial far gtnft1ni mtthane or other subsurface gases of concern.
thKSt units Include -active and closed landfills and units that
have been closed as landfills.  Each Is described more fully
totl ow?

     Q  UMflVls.  Landfills are the most likely SWMUs to
        1 1 n t Fa" 1 tl subsurface gases resulting 1n * release.  The
        underground deposition of decomposable refuse with or
        without hazardous constituents provides a large source
        of fis an<$ a driving force that can carry other gases
        venting to tht atmosphere and/or migrating horizontally
        as a subsurface gas.  Closing landfills with Impermeable
        caps without venting systems retards the release of these
        lndf1U gases as surface emissions*  In these Instances,
        i large percentage of those gases migrate laterally
        through soils along confining barriers such as ground
        water tables, clay layers, synthetic liners, and compacted
        evtrs.  This migration could cause significant accumula-
        tions of potentially explosive gas 1n facility structures
        or 1n buildings off-site.

     o  Un1 ts c 1 ose  as 1 andfj 1 Is .  Inactive SWMUs that have been
                    ^
        closed as landfils may generate subsurface gases.  These
        sites Include closed surface Impoundments or waste pl.es
        containing decomposable or volatile wastes with In-place
        Impermeable covers.  Similar to landfills* gases generated
        1n sites closed as landfills may migrate laterally, pos-
        sibly causing significant accumulations.  However, closed
        surface Impoundments and waste piles generally contain
        small quantities of decomposable and volatile wastes and
        are at shallow depths.  Thus, significant gas migration
        and subsequent subsurface gas releases are less likely
        for these units than for landfills.
                                   8-3

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                           EXHIBIT 8-1

                UNIT POTENTIAL FOR SUBSURFACE 6AS
                RELEASES AND MECHANISMS OF RELEASE
Unit Type

Closed Landfills
o Lateral  migration of methane beneath
  landfill cap to on-slte or off-site
  structures.

o Migration of methane through conduits
  to on-s1te or off-site structures.
Active Landfills
o Lateral migration of methane beneath
  landfill cap to on-s1te or off-site
  structures
Closed Water Piles
o Lateral migration of methane beneath
  landfill cap to on-s1te or off-site
  structures.
Closed Surface
  Impoundments
o Lateral migration of methane beneath
  landfill cap to on-s1te or off-site
  structures.
                                8-4

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     Other SWMUs are unlikely to have subsurface  gas  releases
because gases generated 1n the units are more  likely  to  vent  to
the atmosphere than to concentrate 1n the unsaturated soil.
Barriers (e*g*, paving, compaction, or Installation  of covers  for
closure), can permit some lateral migration  to occur  from  these
units.  Senerally, however, this lateral migration  will  be limited
to the extent of the barrier.  Shallow SWMUs will  also have a
lower potential for releasing methane, since availability  of
oxygen will Interfere with the anaerobic conditions  supporting
methane generation.

     Although depth 1s one of several considerations  for deter-
mining the potential for releases, the type  of SMftU  establishes
potential migration pathways and the waste characteristics create
the driving force for subsurface gas movement.  Exhibits 8-2  and
8-3 Illustrate some potential pathways from  a  few types of SWMUs.
The Investigator should consider the characteristics  presented
here when evaluating the likelihood of a SWMU  to  release methane.

**   Haste Characteristics

     The Investigator should attempt to Identify  the wastes
originally contained within a SWMU or group  of SWMUs during the
PR, in order to determine their potential for  generating methane.
The investigation for methane 1s different than Investigations
for releases to the other media discussed 1n this guidance, In
that the constituent of concern 1n this chapter 1s generated  1n
the unit, rather than merely a waste present from a treatment,
storage, or disposal activity.  Therefore, the Investigator
should determine whether wastes conducive to the  generation of
methane are present 1n SWMUs at the facility.

     Anaerobic decomposition of organic wastes generates large
volumes of methane gas under the proper conditions.  When methane
is generated in SWMUs, the potential exists for it to accumulate
under pressure and to migrate from the  unit, thereby posing a
significant risk of explosion.  The methane may also be mixed
with other volatile hazardous constituents present In the unit,
and may Increase the potential hazard associated  with the accumu-
lated gas.

     Conventional solid waste refuse and biological  sludges
are the primary waste type of concern for generating methane gas.
The volume of  gas produced 1n the  unit  depends upon  both the
quantity and types of refuse present.   Units may either contain
primarily  refuse or a mixture of  refuse  and hazardous wastes.
Units where refuse has been  codisposed  with hazardous wastes may
pose the most  serious threat, because of the potential  for other
volatile hazardous wastes to be mixed with the methane.

     Higher volumes of methane will  be  generated at  units con-
taining larger quantities of refuse.  The volume of  gas generated
also depends upon the age of the  unit, and how  long the  waste has
been in the unit*  Methane generation will Increase  slowly after
waste emplacement to a maximum neneratlon rate which will slowly
decline as the waste decomposesl   The active  lifetime for methane

                               8-5

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                                                EXHIBIT 8-2

                            SUBSURFACE GAS GEWERAI10N/MIGRATI0 IK A LANDFILL
09
a*
                                             SftOWtDWATER TABLE

-------
                                            EXHIBIT 8-3



              SUISWFACE  6AS GEKERATiOH/HiSRATION FROM UNITS  CLOSED AS LANDFILLS
                                        SURFACE IflPOUKDMENT CLOSED AS LANDFILL
                                     ^*rtrr|IM*lffw'

                                         . * -  ' .-!
                                                   COVER S9IL
                                                   F	~  	 yb"v<
                                             HAZARDOUS
                                             LIQUIDS/SLUDGES
                                            : -in** iir.-un.8' lir." nt:
OB
I
UNSATURATED

   SOIL

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generation from units closed as landfills  depends  primarily upon
the amount of precipitation Infiltrating  Into  the  waste.   Land-
fills 1n the arid Southwest will  generally produce methane for
20-30 years, while landfills 1n the humid  Southeast may  only
generate methane for 4*5 years after waste emplacement.   Landfills
with higher moisture content provide a  more suitable environment
for bacterial degradation.

     The temperature of waste at  the time  of emplacement  can also
affect the methane generation rate.  Wastes placed 1n landfills
1n the winter at temperatures below 10 C  may  not  generate methane
for up to 5 years, even in climates with  warm  summers, due to the
Insulating properties of the waste.  The  waste can remain at tem-
peratures low enough to effectively Inhibit bacterial decomposition
for several years,  The types of  refuse disposed In the  unit can
also affect the rate of methane generation.  Descriptions of the
two types of refuse that can generate methane  and  a brief discus-
sion of other wastes that may mix with  methane follow:

     0  Rapid Decomposable Refuse.  Rapid  decomposable wastes
        w111 produce methune at h1gh rates under the proper
        conditions.  These wastes Include  organic  sludges from
        wastewater treatment facilities,  food  wates, garden
        wastes, and other vegetable matter (e.g.,  grass  clippings,
        tree trimmings, etc.).  The high  concentration of readily
        degradable organic compounds 1n these  wastes provides in
        Ideal energy source for the anaerobic  organisms  that
        produce methane.

     o  Slow Decomposable Refuse.  Slow decomposables will not
        produce the Immediate high volumes of  methane possible
        with the rapid decomposables.  However, they will produce
        methane at lower rates In the unit over a  longer  period
        of time, and thus also pose a substantial  threat.  Slow
        decomposables Include paper, cardboard, wood, leather,
        some textiles, and several other  assorted  organic ma-
        terials.  Slow decomposables are  commonly  a Targe percen-
        tage of municipal refuse, and should be present 1n large            I
        quantities If the SWMUs contain municipal  refuse*                  }
                                                                           I
                                                                           -i
     o  Other Wastes of Concern.   Volatile organic wastes disposed          J
        in the unit or concern for subsurface gas  releases may              f
        volatilize Into the pockets of methane gas produced by              :
        refuse decomposition and  Increase  the  hazard associated
        with the gas.  This situation could occur where liquids
        such as solvents have been disposed of 1n  landfills or
        waste piles 1n high concentrations.  These compounds are
        not likely to migrate from the unit unless methane 1s
        present to act as a carrier.  However, certain volatile
        compounds would be likely to form mixtures with  methane
        where wastes are codlsposed.  The volatile wastes and
        waste constituents of concern for subsurface gases are
        the same as those that have the potential  for air
        releases.  These are listed 1n Exhibit 7-2.
                               8-8

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C,   Pol 1 utatnt HI grat 1 on Pathways

     The  Investigator should evaluate any available Information
pertaining to the  hydrogeologlc characteristics  of a facility
In order  to determine the pollutant migration pathways  associated
with subsurface gas releases during the  PR,   As  stated  previously,
methane can accumulate under pressure within  certain types of
units, and then migrate from that  unit through  the subsurface  due
to the force of this pressure.

     Certain natural conditions and engineered  structures can  act
as barriers that Impede the migration or conduits that  promote
the migration of subsurface gas.  For example,  venting  systems
can prevent subsurface gas migration, while  underground utility
lines can promote  migration.  We describe below several factors
that can  affect the migration of subsurface  gas:

     (1)   Natural  barriers and conduits; and

     (2)   Engineered barriers and  conduits.

1.   Natural Barriers and Conduits

     Gas migration can be Impeded  by various  geologic barriers.
A soil's effective porosity and permeability are perhaps the most
important natural  barriers to gas  migration.   Porosity 1s a
function of soil type, moisture content, and  weathering.  Permea-
bility 1s determined by soil type.  Tight, uniform solid such  as
clays, at least to the depth of the unit, are good barriers.
Sandy soil will likely encourage venting of gas to the atmosphere,
thus preventing horizontal migration*  Climatic conditions such
as precipitation or  freezing can also affect gas migration.  Both
factors tend to reduce the porosity of surface  soils preventing
upward (;as migration.      "          -

     Gas migration can also be  Impeded or prevented by hydrologlc
barriers such as surface water, ground water, and  saturated soils*
Subsurface gas does  not penetrate  ground water  and  surface water.
Thus, 1f there 1s  a  lake or perennial stream between the unit and
any structure, migration 
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2.   Engineered Barriers and Conduits

     Some facilities my have engineered  structures  which  either
intentionally or unintentionally impede the  migration  of  subsurface
gas.  Engineered barriers Include:

     o  Synthetic liners that effectively contain  wastes;
     o  Slurry walls that border landfill units;  and
     o  Gas control  or venting systems.

The Investigator should review documents  on  the design and opera-
tion of these systems and inspect the  systems to  confirm  that
they are functioning properly.  Subsurface gas control systems
are almost exclusively associated with  disposal sites  for
municipal-type waste rather than for hazardous waste*   These
systems are probably only present at hazardous waste facilities
where municipal waste is codisposed with  hazardous waste  or where
a sanitary landfill  is operating at the same site.

     Gas migration from SWMUs may be facilitated  by man-made
structures located within the facility or near the property
boundary.  Examples  of engineered structures which may act as
conduits include:

     o  Underground  power transmission lines;
     o  Sewer and drainage pipes; and
     o  Underground  telephone cables*

     Gases migrating from a SWMU may enter the gravel-backfilled
trenches surrounding these structures and travel  great distances
to buildings or other engineered structures, resulting 1n a
potential hazard.   It may be useful to Inspect the facility blue-
prints and check with utilities to the extent that these  tasks
were not completed during the PR or VSI  in order to ensure that
no structures are present that could Increase the likelihood of
gas migration to on- and off-site receptors.

D,   Evidence of Release

     The Investigator should examine any available sources of
information to  Identify evidence that subsurface gas has  migrated
from a facility.  Most evidence of subsurface  gas releases will
usually be limited  to official reports of explosions  at or near
the facility.   In some cases, there may  be sampling information
taken from vents placed near the units Indicating the presence of
methane in a  unit.  Under most circumstances,  the Investigator
should assume that  units containing methane will pose a threat
for migration and potential explosion.

E.   Exposure Potential

     The investigator should evaluate  available information on
the location, number, and characteristics, of  buildings that
could be affected by subsurface gas releases  at the facility*  As
stated at  the beginning  of  this chapter,  the  RFA will focus


                                8-10


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primarily on the potential  for methane to migrate to on-s1te and
off-site buildings*  Typically, methane can migrate up to 1000
feet from Us source, although 1t could travel  further under Ideal
conditions*

     Potential receptor Information will  be used primarily to
help the Investigator determine the need  for Immediate corrective
measures at the facility 1n order to alleviate  potentially high
risks of explosion attributable to methane migration.  In general,
Immediate actions may be necessary when the Investigator encounters
buildings with exploslmeter readings above 25*  of the LEL (lower
explosive Hm1t).  The investigator should Identify those structures
that may be located close enough to a source of methane to warrant
further Investigation, and in some cases, sampling.

F.   Determining the Need for Additional  Sampling In the SV

     If the Investigator determines, based on his Inspection of
the unit, that there 1s a significant potential for the unit to
generate methane, and that the site geologic and hydrogeologfc
conditions may promote migration,'he/she may choose to sample to
determine conclusively whether methane has been released.  Vie
discuss 1n this section:

     (1)  General Information on factors to consider 1n determining
          the need for additional sampling Information;

     (2)  Factors to consider 1n selecting sampling parameters;  and

     (3)  An example to Illustrate this discussion.

1.   General Information en Determining the Need for Sampling

     The following 11st presents several  situations 1n which the
investigator may find it useful to obtain additional sampling
Information during a SV:

     o  To Identify explosive levels of methane 1n structures; to
        Identify the need for emergency action;

     o  To confirm adequate operation of a landfill gas venting
        system;

     o  To Identify the presence of refuse 1n  units with unknown
        waste composition; and

     o  To confirm the presence of toxic constituents mixed with
        subsurface gas.

     The Investigator should  use best professional judgment 1n
determining when a SWMU may be a source of subsurface gases.
When he/she believes that a unit contained decomposable wastes,
and believes that the site conditions could facilitate methane
                               8-11

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migration, It nay be appropriate to sample for methane at appro-
priate locations.  These are described 1n detail  1n Section
III of this chapter.

2.   Selection of Sampling Parameters

     As stated previously, methane will  be the primary constituent
of concern for Investigations of subsurface gas releases.  There-
fore, the Investigator will usually sample for methane when
identifying releases.

     However* under certain unusual situations (e.g., units where
large quantities of refuse were codlsposed with hazardous wastes),
1t may be necessary to Identify the presence of other potentially
hazardous constituents 1n subsurface gas.  In these cases, the
potential constituents of concern will the same as those Identi-
fied as potential constituents of concern for air releases,  The
Investigator should refer to Chapter Seven of this document for
guidance on Identifying and sampling these constituents of concern,

3.   Example

     An Illustration of a situation 1n which sampling would be
called for follows: An electroplating facility previously dis-
posed some of Us electroplating sludges along with refuse gen-
erated at the facility 1n a medium-sized landfill (2 acres).  The
company closed the landfill five years before the RCRA Investi-
gator began conducting the RFA.  They closed the landfill by
Installing a clay cap with a vegetative cover.

     The Investigator found records of the past use of the land-
fill durina the PR, and recognized a potential methane generation
problem.  After requesting a facility diagram from the owner/oper-
ator, the Investigator discovered a telephone Hne running from
off the facility boundary, underneath and adjacent to the landfill,
towards one of the facility structures.   The investigator recog-
nized the underground telephone line to be a potential conduit
for any methane migrating from the closed landfill.

     Because the telephone Hne entered a facility structure, the
Investigator would decide to take explosimeter readings within
the structure of concern.  However, because the absence of methane
in the facility structure does not necessarily prove the absence
of methane, the Investigator also decides to take several soil
gas measurements around the perimeter of the landfill, in order
to identify the presence of methane at the unit boundary.


III. COLLECTING ADDITIONAL INFORMATION IN THE SV

     This section presents technical Information related specific-
ally to subsurface gas releases to be considered when collecting
additional sampling Information 1n the SV.  The Information
presented here should be used to help the investigator meet one
of the primary goals of the SV:


                               8-12

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     o  To collect additional  sampling  Information  to  fill  data
        gaps Identified  1n  the PA,  leading  towards  final  release
        determinations.

     For each sampling method  discussed,  this  section  describes:
1) the general  kinds of  situations  1n which  1t  will  be appropriate
to employ a specific technique, 2)  technical  Information  on how
to conduct the  sampling, and 3) specific  details  to be considered
when evaluating the sampling results.   This  section does  not
provide the actual SOPs  on  the sampling techniques  here.   However,
It references the relevant  manuals.

     The choice of appropriate sampling methods will have a large
Impact on the cost and usefulness of the  SV.   The Investigator
should be confident when developing and reviewing the  sampling
plan that the procedures chosen will meet the  needs of the RFA,
while not resulting In the  collection of  unnecessary data.

     One example of a sampling technique  that  will  be  appropriate
for Identifying subsurface  gas releases during the  RFA Is the
combustible gas meter (exploslmeter) measurement.  Considerations
on how to use this device and on evaluating Its results follow
below.

I,   Combustible Gas Meter

     Methane field monitoring can be performed with combustible  gas
meters In buildings, sewers, or 1n the  soil.  A combustible gas
meter will provide a reliable determination of combustible gas
concentrations.   It will not Indicate whether or not the combust-
ible gas detected 1s actually methane: gas, although, If the waste
1n the unit could generate  methane, 1t  1s likely that  the meter
1s detecting methane.  Any significant  gas reading (whether 1t 1s
methane or not) Is of concern.

     Combustible  gas meters usually Indicate the percentage of
the lower explosive limit  (LEI) of  the  atmosphere being monitored.
The LEI Indicates the lowest concentration of methane In air
which could result  1n combustion, or 1n severe cases,  an explosion.
EPA guidelines under CERCLA consider 25% of the  LEL to be  an
action threshold; the Investigator  should evacuate immediately
when readings higher than  25X  of the LEL are obtained.

     Reported experience Indicates  0 to 100 percent of the  lower
explosive limit detection  to be accurate with hotwire catalytic
combustion principal Instruments.   However, many users prefer
Instruments with  the capability of  determining both the  0  to  100
percent LEL and the percent methane present when the  concentra-
tion exceeds 100  percent LEL  (I.e., 5  percent methane).   Dual
scale Instruments  are available for this application.  Typically,
the 0 to  100 percent gas scale  uses a  thermal  conductivity  sensor.

     The  carbon dioxide  1n  landfill-generated  gas  1s  reported to
Interfere with the  thermal   conductivity sensor,  so  the Investigator
should  not  assume  that  readings above  100 percent  LEL  are  accurate.


                                8-13

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Some of the single scale 0 to 100 percent  LEI Instruments  can
also be fitted with air dilution tubes or  valves  to allow  readings
of the percent gas when the concentration  1s  above the  LEI.
Instructions on the use and calibration of these  Instruments
should be obtained from the manufacturer.

     Monitoring 1n a facility structure (e.g., buildings,  sewers,
existing monitoring wells, gas vents)  should  normally be done
after the building has been closed overnight  or for a weekend,
and when the soil  surface has been wet or  frozen  for several
days.  Monitoring  or sampling should be done  1n confined areas
where gas may accumulate, such as basements,  crawl spaces, near
floor cracks, attics, around subsurface utility connections,  and
in untrapped drain lines.

     Soil gas monitoring can be performed  to  Identify the  potential
for methane releases at a unit.  The Investigator will  normally
drill shallow wells of a minimal diameter  (2") and Insert  the
monitoring device  1n the hole.  There will be some time delay
due to the slow movement of gas through the soils and Into the
wel 1 


IV.  MAKING SUBSURFACE GAS RELEASE DETERMINATIONS

     The final task In the RFA Is to make release determinations
and recommendations concerning the need for further Investigation
(e.g., an RFI).  While subsurface gas problems may not occur at
a  large  number of facilities, where they are encountered, they
may pose extremely high risks to the Investigator and facility
empioyees.

     Exhibit 8-4 1s a checklist that should help  the Investigator
evaluate specific factors to  Identify subsurface  gas releases, or
to  Identify sites that have a high potential   for  gas release and
gas migration to on-slte or off-site buildings.   In Identifying
releases,  the Investigator should consider the series of  factors
described  in the chapter and highlighted  1n the checklist to
determine  the potential for release.  The primary factors Include:
whether  or not the unit contains waste that generates methane, and
the po'jntlal for migration through the subsurface.
                                    8-14

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                           Exhibit  8-4

              Checklist  for Subsurface  Gas  Releases




I.   Potential  for Subsurface Gas  Releases


    o  Does the unit contain *aste  that generates  methane  or
       generates volatile constituents  that may be carried by
       methane (e,g., decomposable  refuse/volatile organic wastes)?


    o  Is the  unit an active or closed  landfill or a unit  closed
       as a landfill (e.g., surface Impoundments and waste piles)?


2.   Migration  of Subsurface Gas to  On-s1te  or Off-site Buildings


    o  Are on-s1te or off-site buildings close to  the unit?


    o  Do natural or engineered barriers prevent gas migration
       from the unit to en-sit:- or  off-site buildings (e.g* low
       soil permeability and porosity hydrogeologle barrfr$/1 1ners,
       slurry  walls, gas control  systems)?


    o  Do natural site characteristics or man-made structures
       (e.g.,  underground power transmission lines, sewer pipes/
       sand and gravel lenses) facilitate gas migration from the
       unit to buildings?


3,   Evidence of Release


    o  Does sampling data  Indicate a release of concern?
                               8-15

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                           CHAPTER NINE

                              SOILS
I.   INTRODUCTION

A.   P u_r p.p s e
     This chapter provides technical  Information to support the
    ktlgatlon of releases to soils during the RFA.  While
    ters Two, Three, and Four provide general guidance on eonduc-
     RFAs, this chapter focuses on specific factors unique to the
     i ii i a bi> Q |
investigation
Chapters

soil  medium that should be considered by the investigator
     This chapter has been organized to reflect the separate
phases of the RFA process:

     o  Conducting a preliminary review of Information on soil
        releases;
     o  Conducting a visual Inspection of the facility;
     o  Collecting additional  sampling Information 1n the SV; and
     o  Making release determinations*

     The first section describes the technical factors that
should be considered during the PR and VSI.  The second section
describes the technical approach to obtaining additional sampling
information In the SV for soils, and should be consulted along
with Chapter Four on conducting a SV,  The final section discusses
factors to consider when making final release determinations to
soils at the end of the RFA.

     It should be understood thatjj^ls not the objective of an
RFA to Identify all areas of contaminated suil at a facility, and
to require further 1nvest1ga1ton for all contaminated soil areas.
Investigators should focus on identifying soil contamination
which, through direct contact jf humans or other potential
receptors, or by leaching or otherwise migrating to othes* media
such as ground water or surface water, poses a threat to human
health and the environment.  Not all soil contamination poses
such risks; Investigators should only focus on areas of ro11
contamination which clearly have the potential for causing serious
environmental problems.

B.   Scope

     During the RFA, the  Investigator should evaluate the likeli-
hood that the facility has releases to soils which pose a threat
to human health and the environment.  While 1n most cases this
will relate to contamination from specific units, there may be
situations where other sources  of soil contamination may be
Impacting human health and the  environment.

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II.   CONDUCTING A PRELIMINARY REVIEW AND  VISUAL
     SITE INSPECTION OF RELEASES TO SOILS

     This section presents technical Information  related  specifi-
cally to the soil medium to be considered when  conducting the  PR
and  VSI.  Accordingly, this section has been organized  to reflect
the  primary goals of these processes described  1n Chapters Two
and  Three;

     o  Identifying and describing potential releases  to  soils at
        RCRA facilities; and

     o  Making a preliminary assessment of the  need for and ex-
        tent of sampling required.

     This section presents technical details on each of the five
types of Information described In Exhibit 1-1:

     (1)  Unit characteristics;

     (2)  Waste characteristics;

     (3)  Pollutant migration pathways;

     (4)  Evidence of release; and

     (5)  Exposure potential.

In aodltlon, technical Information  1s provided  to help the Inves-
tigator determine when additional sampling will be necessary 1n a
SV to Identify soil releases.  Each area 1s discussed separately.

A,   Unit Characteristics

     A unit's design and operating  characteristics of a SMWU will
determine to a great extent Us potential for releasing hazardous
constituents to  soils.  Many treatment* storage, and disposal
units are designed to prevent releases to the environment.  The
Investigator should evaluate the characteristics of each SWMU or
group of SWMUs at a facility to determine their potential for
releasing hazardous constituents to soils.

     As with other media,  the likelihood that a SWMU h.as contam-
inated soils 1s  largely dependent on the nature and function of
the unit. Therefore, each  SWMU or grouping  of similar units
should be evaluated for Its potential  to release constituents
that may contaminate surrounding soils. The unit evaluation
should be based  upon:

     o  An understanding of the  Inherent design characteristics
        and features that  might cause  the unit to have a  release
        to surrounding soils;
                                9-2

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                           EXHIBIT 9-1
            RANKING OF UNIT POTENTIAL  FOR  SOIL  RELEASE
                    AND MECHANISMS OF  RELEASE
     UnU Type
Surface Impoundment
Landfill
Waste Pile
Land Treatment Unit
Container Storage
Area
Above-ground Tank
In-ground Tank
Incinerator
Class I and IV
Injection Well
             Release Mechanism
o Releases from overtopping
o Seepage
o Migration of run-off outside the unit's
  run-off collection and containment system
o Migration of spills and other releases
  outside the containment area from
  loading and unloading operations
o Seepage through dikes to surrounding
  soi 1 s
o Migration of run-off outside the unit's
  run-off collection and containment system
o Migration of spills and other releases
  outside the containment area from
  loading and unloading operations
o Migration of run-off outside the
  containment area
o Migration of run-off outside the
  containment area
o Releases from overflow
o Leaks through tank shell
o Spills  from coupling/uncoupling
  operations
o Releases from overflow
o Spills  from coupling/uncoupling
  operations
o Spills  or other releases from waste
  handling/preparation activities
o Spills  due to mechanical failure
o Spills  from waste handling  opera-
  tions at the well head
   The two remaining solid waste management units; waste transfer
   stations, and waste recycling operations generally have mechanisms
   of release similar to tanks.
                               9-3

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     o  An understanding of the primary  mechanisms  by  which  the
        releases may occur from the unit and  the  potential  for
        this lelease.

     When assessing the likelihood of releases  to soils  from a
un1t the Investigator should Initially  consider  the  relative
potential of the unit for a release.  For example,  an  above-ground
tank located directly on soil has a greater  potential  for  a
release than does the same tank raised two feet above  a  cement
pad with adequate curbing.  Exhibit 9-1  presents  a  generalized
ranking of the different types of SWMUs  and  their potential  for
having releases that contaminate surrounding  soils.  Exhibit 9-1
also lists the mechanism for release associated with  each  unit
type.
     The major unit-specific factors the Investigator  should
evaluate are discussed below.

1.   Unit design

     The design factors of the unit, Including  Its  capacity and
dimensions, can Indicate the potential for a  soil release.  For
example, an undersized above-ground tank will be more  susceptible
to overtopping than an adequately sized  unit.

     Features designed to reduce or eliminate release  should also
be considered. Some features are better  able  to eliminate releases
than others.  A triple-lined landfill with a  leachate  collection
system will be less prone to subsurface  releases than  a  single
clay-lined surface Impoundment.

2.   Operational history

     The Investigator should evaluate the unit's operational
history  for Information which Indicates  that a  release may have
occurred. Operational factors that may  Influence the potential
for a release Include:

     o   The length of service life of the unit*  Older units will
        have a greater potential for a  release,  particularly due
         to failure of liners or control  equipment  than newer units.

     o   Operational status  (Active,  Inactive, closed)
     o  Operational procedures such
        Inspections and records.  A
        likelihood of leaks, spills

3.   Physical Condition of Unit
            the VSI
                                    as proper maintenance, regular
                                    well  maintained unit has less
                                    or equipment failure.
     Dur1n<
evidence of releases
                     Investigator should examine the units for
                     "ir characteristics that could cause releases
For example, when examining a surface Impoundment, he/she should
determine whether the earthen dikes are structurally sound and
capable of preventing releases.  Cracks, slumping, or seeps
                                9-4

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around the toe In the dike may show evidence that the unit's
condition may cause releases to the surrounding soils.

B"   Haste Characteristics

     The Investigator should attempt to Identify the wastes
originally contained within a SWMU or group of SWMUS during the
PR.  In the RFA,  the Investigator should try to connect Informa-
tion on waste types, unit characteristics, and evidence of soil
contamination to demonstrate the likelihood that specific SWMUs
or groups of SWMUs have released constituents to the soils.  This
section describes technical factors to consider when Identifying
waste characteristics relevant to soil releases*  It also discusses
physical/chemical properties that affect the release potential
of wastes and their subsequent transport 1n soils.

     Information on wastes 1s usually available 1n Part A permit
applications, Inspection reports, and facility operating records
reviewed during the PR.  The Investigator should compile specific
Information on waste characteristics 1n order to assess not only
the potential for a release to soils, but also to Identify the
chemical form that the hazardous constituent might take In the
soil environment, and to determine 1f a contaminant found 1n  a
soil release can be expected to migrate to other media.

     Constituents tend to migrate 1n different forms and at dif-
ferent rates 1n the soil medium, depending upon their properties.
Some Appendix VIII constituents are Insoluble 1n water and bind
tightly to soil particles, thus minimizing their migration poten-
tial.  Therefore, 1t 1s Important to evaluate a waste's mobility
1n order to determine Its potential for dispersion In soils and
its tendency for transfer to other media.  Releases of organlcs
may behave very differently than metals 1n the soil environment.

     Hazardous metals and Inorganics (e.g., arsenic and cyanide)
may be relatively mobile.  Other Inorganics and metals (e.g.,
lead) are less mobile depending upon the pH of the wastes, and
the ligands available nn soil for complex formation,

     The mobility of organic constituents can be expressed
quantitatively by the sorptlon equilibrium constant (Kd),  The
value of KH depends upon the organic content of the soil and the
constituent-specific soil adsorption coefficient (Koc).

     The investigator will seldom have access to Information on
organic content of soils at a facility; Instead It will be more
useful  to estimate the relative mobility of a constituent as
expressed by Koc.  KQC values have been calculated for only a
small set of hazardous constituents; however, the octanol-water
coefficient as expressed by (Kow), can be used as an Indicator  of
Kd.  Appendix E presents Koc and log(Kow) values for most consti-
tuents of concern.  Because these values are log values, chemicals
with Kw values of more than two can be considered relatively
Immobile.  Values less than one are considered to be mobile.
                               9-5

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     The volatility and blodegradabU1ty of constituents can also
be Important In Identifying whether contaminated soil  can act as
a transfer medium.  For example highly volatile components of a
past release may no longer be present  for detection 1n a sampling
program.  Readily biodegradable components also may not be present,
although certain degradation products  may Indicate that a release
has occurred,

C.   Pollutant Migration Pathways

     The Investigator should evaluate  during the PR available
Information pertaining to potential soil migration pathways at a
facility.  Contaminated soils can transfer chemicals to ground
water by leaching, to surface water by contaminating run-off, and
to air by the suspension of contaminated particulars*  This
Information will play a major role 1n  Identifying the potential
for Intermedia transfer of releases during the PR.

     The Identification of migration pathways associated with
soil releases will be most Important when the soil 1s being
evaluated as a transfer medium.  Basic to any evaluation of
pathways for soils 1s the assessment of site geology, soil type,
and climate.  This evaluation relies on standard Information
usually available during the PR for each site,  The primary
climatic effect that should be determined 1s the annual rainfall*
Sites located 1n regions with high annual or seasonal precipitation
will have a greater potential for releases to spread through the
soil or to the other aqueous media.  Conversely, very arid regions
may be susceptible to wind-borne distribution of contaminated
soil partlculates.

     The Investigator should evaluate the site's topography and
look for low lying areas where spills may collect.  He/she should
also estimate the proximity of the unit 1n question to surface
water, particularly locations within flood plains.

     The underlying geology of a site should be determined In
order to evaluate the potential of soils to transfer contaminants
to that medium.  Soil characteristics that are to be evaluated
are dependent upon underlying geology.

     The determination of site-specific soil characteristics will
be useful when determining the Impact of a potential soil  release.
Soils are characterized by particle size, ranging from  large sand
particles, to silt, to the small clay colloids.   Loams  are  soils
where these particles are found In various percentages.   Releases
will be distributed through sandy soils more readily than  through
clays.  Clays usually have an associated attraction for certain
chemicals since they are weakly Ionized.

     The organic content of soils will  also affect  their  ability
to bind or blodegrade certain chemical  releases*  This  Informa-
tion 1s available for most sites from USGS or  State Soil  Conserv-
ation Service soil maps.   Interpretive  data are usually  available
                                9-6

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along with the map.  General  Information will  often be Included
on the depth of a soil  layer.

D.   Evidence of a Release

     During the PR, the Investigator should examine available
sources of Information  to Identify evidence that constituents*
have been released to soils at a facility.  The Investigator
should evaluate both direct and Indirect evidence of release
during the PR.  Chapter Two outlines general  considerations on
looking for evidence of releases.

     The VSI 1s particularly useful  for Identifying releases to
soils.  Stressed vegetation can Indicate the likelihood of a soil
release.  Direct evidence of soil releases Includes:

     o  Evidence of olllness or slick on soils; and

     o  Discoloration from background soil color.

     Direct evidence of a release may also Include official
reports of prior release Incidents, such as a major tank leak
onto the ground.  Indirect evidence of a release to soils may be
provided by ground-water monitoring data that show contamination.
When the Investigator Identifies Indirect evidence of this type,
1t may be possible to determine the source of the release by
evaluating the pollutant/soil migration pathways and the waste
characteristics at the  facility.  Soil sampling data may exist at
some facilities, although this will  not be likely, since there
are no requirements for soil monitoring.

     There are likely to be Instances of soil contamination that
cannot be linked directly to units at a facility.  Areas that
were used to handle wastes In the past but are now unused may
have contaminated soil.

E.   Exposure Potential

     The Investigator should evaluate available Information on
the location, number, and characteristics of potential receptors
that could be affected by releases to soils at the facility.
These receptors Include human populations, animal populations
(particularly any endangered or protected species), and sensitive
envlronments.

     While it Is not within the scope of the RFA to estimate the
risk associated with a release to soils, 1t 1s Important to Iden-
tify any potential for direct exposure to the release.  Informa-
tion on the potential for direct exposure Include:

     o  The security of the facility.  Is access to the site
        prevented by adequate fencing or barriers?
                               9-7

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     o  Tht proximity of the unit/facility to children, specifi-
        cally to schools and play grounds*

     If the migration of chemicals from soil  releases to other
media has been Identified, the sections In this Guidance on
releases to those media should be refered to  1n order to determine
exposure potential to constituents released and transfered to
other media.

     The Investigator should evaluate the severity of the release
to soils along with the potential for direct  exposure.  If recep-
tors are currently bc*1ng exposed to highly contaminated soils or
have a high potential for being exposed, the  Investigator should
consider recommending Immediate corrective measures to limit
access and direct exposure.

F.   Determining the Need for Additional Sampling

     The Investigator may not be able to determine whether a
release to soils from the unit has occurred,  since existing data
may be unavailable or Insufficient.  In cases where historical
Information and visual observations are not adequate to determine
if a release from a unit to soil has occurred or Is likely to
have occurred, he/she should consider whether additional sampling
and analysis would help make a determination.  In this section,
we present;

     (1)  General Information on factors to consider In deter-
          mining the need for additional sampling Information;

     (2)  Factors to consider In selecting sampling parameters;

     (3)  An example to Illustrate this discussion.

*   General Information on Determining the Need for Sampling              i
                                                                           t
     Soil sampling during the SV will generally be confined to
surface soils or to shallow coring using hand equipment.  Because
of the relative ease 1n obtaining soil samples, 1n some cases,
soil sampling may be used to obtain Information on releases to
ground water where existing wells may not be adequate and new
well placement 1s beyond the scope of the RFA.

     The following are situations where soil sampling data could
be useful:

     o  Visual examination reveals an area at a facility where
        unspecified wastes were applied 1n liquid form for several
        years.  Facility 1s situated on sandy soils with rapidly
        moving ground water, with nearby drinking water wells
        located apparently downgradlent.  Sampling data would
        reveal presence of and types of constituents  1n the soil,
        which If positive could trigger additional ground water
        Investigations.
                                9-8

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     o  Ground-water data downgradlent front an above-ground tank
        Indicates contamination from Us wastes.   No record of
        a spill exists and the unit appears structurally sound,
        however, the observed contamination should have migrated
        to the ground-water through the soils.

     o  Drainage patterns show that runoff from a landfill  tends
        to collect 1n a low lying area. Constituents expected to
        be released sorb to soils and contamination of the  run-
        off can be verified.

2.   Selection of Sampling Parameters

     Knowledge of the wastes that may be potentially released from
a unit Is the starting point when Identifying sampling parameters.
However, many SWMUs have Incomplete or no data on the wastes
deposited over time.  When Uttle Is known of the wastes managed
in the unit, SC/MS scans for volatlles, add extractables or
base/neutrals become a good starting point when selecting param-
eters for analysis 1n soils.

     Metals are also of concern under RCRA.  If a waste source 1s
hazardous due to EP Toxlclty, the metals of concern are a smaller
subset: arsenic, barium, cadmium, lead, mercury,  selenium,  and
silver.  The following metals precipitate readily under many
naturally occurring conditions and may be detected 1n soil  anal-
ysis: cadmium, lead, nickel and zinc.

     The volatile 6C/MS scan Identifies chemicals that are  charac-
teristic of solvents and lighter petroleum products.  Because
they are volatile, they can evaporate from soil releases Into the
air.  Evidence of these chemicals may be difficult to obtain In
older releases.

     The acid extractables (I.e., phenols) may be present In
heavier petroleum feed stocks and certain Industrial processes
(e.g. pentachlorophenol from wood preserving).  Phenol and  the
mono-halogenated phenols blodegrade 1n a soil environment.
Pentachlorophenol 1s very persistent.

     Base/neutral compounds can often be found 1n wastes from
Industries such as the plastics and synthetic fibers manufacturers
The pesticide scan Identifies pesticides that are found 1n  pesti-
cide wastes and products from the agrlchemlcal Industry.

     All monitoring data should be coordinated with the unit
specific Information available on the potential for constituents
to be released to soils and the Investigator's professional
judgment.
                               9-9

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III. COLLECTING ADDITIONAL SAMPLING INFORMATION IN  THE  SV

     This section presents technical  Information related  specifi-
cally to the soils medium to be considered when collecting addi-
tional  sampling Information 1n the SV,   Accordingly,  the  Informa-
tion presented here should be used to help the Investigator meet
one of the primary goals of the SV:

     o  To collect additional sampling Information  to fill data
        gaps Identified 1n the PR and VSI.

     For each sampling method discussed, this section describes:
1) general situations where 1t 1s appropriate to employ a specific
technique* 2) technical Information on how to conduct the sampling,
and 3) specific details to be considered when evaluating  the
sampling results*  This section does not provide the  actual SOPs
on the sampling techniques.  However, 1t references relevant
manuals.
                                                            large
     The choice of appropriate sampling  methods  will  have  a  lai
Impact on the cost and usefulness  of the SV*   The  Investigator
should be confident when developing and  reviewing  the sampling
                         chosen will meet the  objectives of  the
                         1n the collection of  unnecessary  data.
                         at surface, shallow depths,  and special
                         are warranted.
plan that the procedures
RFA, while not resulting
We discuss soil sampling
cases where deep samples
A.   General Information^ on Selecting Sampling Locations

     The Investigator should use best professional Judgment 1n
determining appropriate locations for soil sampling.  During the
visual site Inspection, pertinent topographic features should be
located.  These features Include drainage patterns, fill areas,
eroslonal and deposltlonals areas.  Any surface run off, seeps,
springs and the proximity to surface water and wet areas should
also be noted.  Releases from a unit will seek the lowest area.
Such low spots may be deposltlonal areas for any released chemicals
and would be the best location to start any subsequent sampling.
Topographic maps are helpful.  Strategically locating the sampling
areas  should minimize the number of samples necessary a  J the
effort for their collection.

     After Identifying the areas designated for soil sampling,
the exact location of the sample area and the specific sample
location should be recorded on a site map.  Soil sampling will be
generally completed by using surface samples and hand equipment.
Surface soil sampling should be conducted 1n deposltlonal areas
since  these areas tend to have higher concentrations of  released
constituents.  This 1s valuable for the screening  function  of the
RFA, but these levels are not Indicative of the overall  area
conditions.  The extent of a release will be determined  under the
RFI.
                                9-10

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     The depth of the sample (e.g., surface, one foot below
surface) should be recorded In a field log book.  When Identify-
ing metal constituents from a release, 1t may be Important to
consider soil type since many have natural background levels  of
certain Havy metals.

B.   Sampling Methodology and Evaluation of Results

     Soil sampling will usually be done using hand equipment  such
as stainless steel spoons, scoops, shovels, hand auger and small
diameter push tubes.  This equipment 1s available for sampling at
shallow depths? however, when soil Is difficult to penetrate,
even shallow sampling may require power equipment such as augers.
Shelby sampling tubes or thin wall push tubes can be used by  both
hand and power equipment.  Stainless steel components are recom-
mended for these tubes.  Soil samples are extruded from the tubes
for logging and for selective sampling.  Tive tubes can also be
capped and sent directly to the laboratory for analysis.

     Surface sampling of soils can be done with a stainless steel
spoon or scoop.  Brass, leaves and other debris should be scraped
off the surface prior to sampling.  Shallow samples can be col-
lected by digging a hole with a shovel or post hole digger, then
removing all loose soil from the hole and sampling with a stain*
less steel spoon at the desired depth*  For densely packed soils
or deeper soil samples, a soil auger may be used.  The sample 1s
extruded and 100 to 200 grams of the sample 1s transfered to a
250 ml container.  A label 1s attached with required  Information
and the depth of the sample, and Its location Is recorded In the
field logbook.

     Soil samples are collected In wide-mouth glass jars equipped
with Teflon-Hned screw caps.  These samples require  no preserva-
tion or  refrigeration.  Tape the 1 id securely and mark with
collector's  Initials.  Carefully pack the samples with the appro-
priate chaln-of-custody forms.  Chapters  six and seven of the
"Revised Draft Protocol for  Ground-Water  Inspections  at Hazardous
Waste Treatment, Storage and Disposal Facilities11 October 1985,
are a good reference for these soil sampling techniques*  Charac-
terization of Hazardous Waste Sites -  Hethods Manual. Volume
II. AyafTTbTe Tampllng Methods Is  also""a  good reference for more
efetaTl on soil sampling ieehnlques.

      If  it is necessary to  sample  soils at depths greater than  18
Inches,  sampling with  power  equipment can be done.   It may be
Important to  sample at lower depths when  the release  1s very
mobile and not of recent occurrence.  The  Investigator may suspect
that the release has moved  several  feet below the surface and
that  surface  sampling  may  no  longer show  evidence of  the  release.
Split barrels or  piston-type  samplers will  be most  useful  in
these situations.   These methods  are  based  on ASTM  01586-67(1974),
"Method  for  Penetration  Test  and  Split Barrel Sampling of  Soils'8,
and ASTM D1587-74.  Thin  Walled  Tube Sampling of  Soils.
                                9-11

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     The sampling of soils at depths greater than 4 feet can be
accomplished by the use of test pits and trenches.  The size of
the pits and trenches will vary, but should be large enough to
permit the entry of personnel, under strict safety requirements.
The excavation of the pits Is performed most commonly by a back-
hoe.  Because of the equipment Invoked, sampling from a pit will
seldom be appropriate 1n the RFAt a  >ough this method may bit
applied in certain circumstances when It 1s valuable to make *
visual In situ Inspection.  This technique may be applied 1n
situations where the Investigator suspects that the release may
be In pockets distributed both horizontally and vertically through-
out the soils, and may not be detected readily by sample borings,

     Once the pit or trench has been opened, It should be stabil-
ized by sloping the walls or by the use of shoring material.
Sampling then occurs at designated spots by using scoops, shovels
or hand augers,  All pertinent Information on pit location and
sample location within the pit should be recorded 1n the field
logbook.  Photographs are a valuable aid when Identifying the
exact location of a sample within a pit or other subsurface
visual evidence of contamination*

     The exact depth and construction of a test pit should be
designed by a field geologist or soils scientist.  Sufficient
space on site should be maintained for placement of removed
material.  After sampling* backfill material should be returned
to the pit under the direction of the field geologist or soils
scientist.


IV,  MAKING A RELEASE DETERMINATION

     The final task 1n the RFA 1s to make determinations of release
potential throughout the facility and to make recommendations for
further action to address potential releases.  This section
summarizes Information that the Investigator sh >.0d consider when
making release determinations for the soils meoi.*

     Chapter Four presents the general procedure to be followed
when making release determinations at the end fo the RFA.  This
involves:

     o  Evaluating sampling results from the SV;

     o  Integrating facility  Information gathered 1n the PR,
        V5I, and SV to determine the likelihood of release at the
        facility; and

     Q  Making final recommendations concerning the need for
        further Investigations.

     The Investigator should  rely upon his/her best professional
judgment and available Information when making determinations as
to whether or not contaminated soils pose a potential or actual
                               9-12

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threat to human health and the environment.   Further  Investigations
should be required 1f It 1s determined that  exposure  of receptors
1s occurring or 1s likely to occur through  direct contact  with
contaminated soils, or 1f there 1s a likelihood that  contaminated
soils are causing contamination of ground  water or other huimn
health or environmental  problems.

     Exhibit 9-2 1s a checklist that should  help the  Investigator
evaluate specific factors to Identify releases to soils and  to
determine the effect on human health and the environment*  When
Identifying releases, the investigator should consider the series
of characteristics described 1n the chapter  and highlighted  in
the check list that determine the potential  for releases to  soil
from units of concern.  These characteristics Include:  the  unit
type (e.g., above ground tank), the unit's  containment systems
(e.g., liners), and the unit's design capacity.  Also, factors
such as the unit's age, condition, the quality of Its operating
procedures, and whether or not the unit has  a record  of compliance
problems may Indicate the potential for a  release*
                               9-13

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                           EXHIBIT 9-2
                 CHECKLIST FOR RELEASES TO SOILS

I dentjfy1ng Re1 eases
Potential for Soil Releases from the Unit
o  Unit type and design
   - Does the unit type (e.g., landbased) Indicate the potential
     for release?
   - Does the unit have engineered structures (e*g., liners,
     proper construction material) designed to prevent releases?
o  Unit operation
   - Does the unit's age (e.g., old unit) or operating status
     (e.g.. Inactive) Indicate the potential for release?
   - Does the unit have poor operating procedures that Increase
     the potential for a release?
o  Physical condition
   - Does the unit's physical condition Indicate the potential
     for release  (e.g., lack of structural Integrity)?
o  Site characteristics that affect the ability for soil to act
   as a transfer media
   - Is the soli  particle size large  (e.g.* sand) such that the
     migration of releases through the soil can readily occur?
   - Is the soil high 1n organic material that may either bind or
     blodegrade certain chemical releases?
   - Is the soil  layer shallow (e.g., less than six feet)?
   - Is high annual rainfall characteristic of this climate?
      Is the unit located near a body of water  (e.g., 1n flood
      plain)?
      Is runon and runoff from the unit controlled?
                               9-14

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        APPENDIX A




SAMPLE RFA REPORT OUTLINE

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                                APPENDIX A
                        SAMPLE RfA REPORT OUTLINE

I.   Conducting the Preliminary Review

     A.   FactXIty Waste Generation and Manufacturing Process Description
     B.   General Background on Environmental Setting
     C.   Location* and Characteristics of SWMUs and Other Potential
          Area* of Concern
          1.   Facility Map Identifying SWMUs and Potential Areas of Concern
          2.   SWMU Information (for each SWMU or location of concern)
               a.   Unit Characteristics
               b.   Waste Characteristics
               c*   Pollutant Migration Pathways
               d.   Evidence of Release
               e*   Exposure Potential
     D.   Identifying Data Gaps and the Need for Additional Owner/Operator
          Information

II.  Conducting the Visual Site Inspection

     A.   Description of VSI Activities and Observations
     3.   Update SWMU Information Based Upon VSI Results
     C.   Conclusions and Recommendations for Further Action at Each
          SWMU/Location
          1.   No Further Action
          2.   Conducting a Sampling Visit
          3*   Conducting a RCRA Facility Investigation
          4,   Implementing Interim Measures

III. Conducting the Sampling Visit

     A*   General Description of Sampling Objectives
     B.   Sampling Plan for SV
     C.   Results of Sampling Visit
     D.   Conclusions and Final UFA Recommendations  for Further  Action at
          Each SWMU/Locatlon

APPENDICES

     A.   Visual Site Inspection Logbook
     B,   Photographic Documentation of VSI
     C   Sampling Visit Logbook
     D.   Photographic Documentation of SV
     E.   Sampling Visit Safety Plan

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     APPENDIX B



INFORMATION SOURCES

-------
                            RFA I8FORMATIOH SOURCES


This appendix provides detail* on the many sources of Information whclh may be
useful during the RFA, particularly the preliminary review.  Most of these sources
will be readily available to Regional/State staff.  This section provides a brief
description of Che contents of each source and Information on how to obtain them,


X.   RCRA Sources	*..,	*	...*...*..**..*...**   B-1

     1.  Permit Applications	*......   B-l
     2.  RSI 13 Submission (SWMU Response)	   B-l
     3.  Compliance Inspection Reports/Information from
         Enforcement Orders	...**.,	   8-2
     4.  Exposure Information Report..*.**..**..*..*.*..*.*..*	   B-2
     5,  Other RCRA Sources	......I*.*.**.,*..*..,*...*.....   8-2


II.  CERCLA Sources	   B-2

     I.  CERCLA PA/51. Reports	   B-2
     2.  HRS Documentation.	   B-3
     3.  CERCLA RI/PS Studle	   B-4
     4.  CERCLA 103(C) Notifications	,	*	   B-4


III. Other federal Environmental Program Sources.	...*..**..*..,   B-4

     1.  NPDES Permits and Permit Applications......	   B-4
     2.  Clean Air Act Permits and  Permit Applications.*..**..*.,*..*,   B-4
     3.  TSCA/OSHA Inspections.....	...	   B-5
     4.  Department of Defense Installation Restoration
         Program  (IRP) Reports........................t.......	   B-5


IV.  Other Miscellaneous  Sources...*......	*..*.*..*..*'.* *..*   B-5

     1.  Aerial Photography	   B-5
     2.  State/Local  Well Permits.	   B-6
     3.  U.S. Geological  Survey and State Hydrogeologic  Maps.*...*..*..,   B-6
     4.  U.S. Soil Conservation Service Soil  Maps....*..*..*,.,*..*,..*.   B-7
     5.  GEMS (Graphical  Exposure Modeling  System).	   B-7
     6.  Municipal/County/City Public Health  Agencies	*	    B-7
     7.  State/County Road Commissions....,	*....	*	    B-7
     8.  Utilities.	*	,    B-8
     9.  Local Airports/Weather Bureaus..*.,,*..*.	*..*    B-8
     10. Naturalists/Environmental  Organ!cations*...	*..*..*...*..    B-8
     11. Employees	...........*........    B-8
     12. Colleges/Univers 1 ties.	...*....   B-8
     13. Interviews With  Local Residents		    B-8
      14* Standard Reference  Texts.	   B-9

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                            UFA INFORMATION SOURCES


I.   RCRA Sources

     I*  Perait Applications

     ?'.rt A notification* and Part B applications for pcraits contain a sizable
amount of information on the facility design and physical characteristics of the
surrounding area*  This information will sometimes apply to both unregulated
releases fro* regulated units and releases froo unregulated ("old") units, and
should prove invaluable at many facilities in assessing the potential for old
units to contaminate ground water.  If the facility ia seeking only an above-
ground storage facility permit, however* the permit application data nay not
provide ouch information useful in evaluating an "old" landfill*

     Part B appllcatlona may not characterize the lower aquifers if they are not
connected to the uppermost aquifer.  If the application data are inadequate to
properly aaaess the impacts to ground water, the information may need to be
developed through other sources discussed later*

     In addition to relevant data on the facility at a whole, the permit applica-
tion also provides information that can be used to evaluate the potential for
unregulated releases from regulated units, specifically surface water and air
releases.  Most of the pertinent data/relate to the deaign and maintenance of the
unit will be contained in the application*  Part B permit applications for land
disposal facilities will also provide information on whether actual releases
have occurred.

     It la important to evaluate well placement when reviewing ground water
monitoring data for regulated units.  In some cases the location of existing
monitoring wells may make It difficult to determine if contamination results
from the regulated unit, an unregulated unit, or both*  Review of the analytical
data must be coupled with data on well location and ground water flow to posi-
tively Identify the source of the observed release*

     The Regional offices and/or the State offices will have copies of the
permit applications for the facilities within their Jursidietion*

     2.  RSI 13 Submission (SWMU Response)

     The data submitted in response to the Reauthorizatlon Statutory Interpreta-
tion (RSI 13), dated February 5,  1985 from Jack W.  McGraw, should  provide  Infor-
mation on the type and location of SHMUs, and information  on the quantities  and
types of wastes disposed in the SHMUa.  These submissions, however, may  be  incom-
plete or inaccurate, and should not be relid upon solely  to identify and charac-
terize SHMUa*  In many cases, the owner/operator  was unclear which  units  to
consider SHMUs, and the historical information on wastes disposed  in them may not
have been readily available to the owner/operator.

     The SWMU response will be Available  to  Regional  RCRA  personnel*
                                       B-l

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     3  Ccmpiinc Inspection Reporta/Information from Enforcement Orders
     Compliance Inspection Report* are available for most RCRA facilities.
These report* contain useful information on site management practices,  Bonitor-
ing data, and unit condition* end should help in identifying problem unit*  and
releases for possible sampling.  Cooprehensive BOO!coring evaluation* (CME's),
which evaluate ground water moinltoring system* at the facility, nay provide an
indication of whether prior release* have occurred at the facility*  Frequent
violations of operating standards nay indicate prior releases.  SODS RCRA in-
spection reports will contain detailed information on the management practices
at the facility, suggesting the wastes most likely to be found on site.

     Enforcement actions at facilities may result in enforcement orders*  Re-
ports of these actions may provide useful information on releases at a site.
In many cases, the investigator may be able to obtain information on unregulated
units from results of investigations required in enforcement actions,

     These reports will usually be kept on file in Regional and State offices
with Jurisdiction over the facility.

     4.  Exposvra Information Report

     The 1984 Hazardous and Solid Waste Amendments require owner/operators to
submit an exposure information report (EIR) to describe the likelihood of expo-
sure resulting from waste disposal activities*  Only facilities seeking operat-
ing permits for landfills snd surface impoundments are required to submit EIR*.

     EIRs will be available at Regional/State offices for facilities within their
Jurisdiction*

     5,  Other RCRA Sources

     Several additional RCRA sources may provide useful Information during the
RFA,  These sources will all be on file at the Region/State office for facili-
ties within their jurisdiction.

     o  Biennial report
     o  Operating log
     o  RCRA waste manifest
     o  Notice to local authority
     o  ACL requests


II.  CERCLA Sources

     1.  CERCLA PA/SI Reports

     Almost IS percent of  the  facilities seeking RCRA Part  B  peralt* have  re-
ceived CERCLA inspections.  The site inspection  reports  for these facilities
can provide a considerable  amount of information on  facility  and  unit  design
and management, waste characterization, and  pollutant dispersal pathways,
particularly for SWHUs and  inactive units*   They may also have limited informa-
tion about target populations.  The exact amount of  information provided in
each report will depend on  the amount  of  information available at the  time the
report was completed.


                                       B-2

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     The CBRCLA SI report is likely to provide tea* information for the  follow-
    categoriest

     o  Facility design/management practices
          titling of 8HNU operations, facility layout;
          Discussion of conditions of identified SWMUs;  and
          Detiign specifications for SWNUo (when available).

            .. characteristics
            Type and quantity of waste received to the extent known

     o  Pollutant dispersal pathways
          Analytical data on "observed releases" from the facility;
          Geology, topography, hydrogeology, climate of the area (if unit could
            be releasing to ground water);
          Climatic data (e.g. precipitation, wind data); and
        *  Facility topography as it relatea to surface drainage patterns.

     o  Receptor characteristics
          Size and characteristics of nearby populations and sensitive environ-
            ments potentially exposed through air, surface water, and ground
            water routes*

     In addition to reviewing the final SX report, thai person conducting the RCRA
preliminary assessment should also examine the CERCLA site file*  These files
contain supplementary information used to evaluate the site under CBRCLA.  These
files include such items as:

     o  Field log book for the SI
     o  Trip reports for the 01
     o  Records of communication
     o  Miscellaneous historical data/reports

     Except for the first item, the exact contenta of the file will vary depend-
ing upon  the type of information available and the data collection procedures
used at the time of the CERCLA SI.

     The  CERCLA PA/SI reports will be on file in  the Superfund division of
Regional/State offices with jurisdiction over the facility.

     2*   HRS Documentation

     Some subset of the sites that have undergone CERCLA  PA/Sis have  been scored
using the Regard Ranking System (HRS),  Information on target populations and
sensitive environments should be available  for each of the  routes  scored.  The
most frequently scored routes are surface wster and ground  water*   This document
may identify potential locations of concern for the RFA,  though it may not
be comprehensive.

     The  Regional CERCLA program offices have copies of all CERCLA RRi  reports
and files.
                                       1-3

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     3.  CERCLA M/fSStudies.

     Again, some subset of the site* that hav* been given an HRS score will have
been subject to a ramadlal investigation/feasibility study (RI/PS).  If 00, thaca
reporta will characterize in great datall: ale, surface water, ground water and
aoil contamination, aa wall aa populations actually or potentially affected by
these releases.

     Tha Regional CERCLA program office have copiaa of all CERCLA RI/PS raport*
and filea.

     4.  CTRCLAJt03(e> Notifications

     Son* aitaa may have information available on waataa diapoaed of at the
facility from a CERCLA 103(c) notification, which provides information on all
reportabla quantitiaa.  In the early atag of tha CERCLA prograa, owners or
operators of waata management facilities and transporters were required to
notify EPA of places where CERCLA hazardous substancaa had bean disposed.  EPA
reviewed approximately 9000 notifications representing approximately 2000
sites, after accenting for redundant reporting.  If tha facility filed * CERCLA
103(c) notification, and no other aouree of information is available, thia
source may provide a record of past disposal operations, such aa information on
types, locations and volumes of waata disposed.

     The reviewer should contact tha Regional CERCLA coordinator to sea if a
CERCLA i03(c) notification exiats for the facility.


Ill, Other Federal Environmental Program Sources

     1.  NPDES Permits and Permit Applications

     The National Pollutant Discharge Elimination Program  (NPDES)  regulates the
discharge of all pollutants into tha waters of tha United  States.  Many RCRA
facilities also have NPDES permits  for  their wastewater discharges, and will
have submitted permit applications  and  uaually received permits.   These parmit
applications may provide a large amount of detail on tha types of  waste generated
at  tha facility, and soae historical data on how these waataa were disposed in
tha past*

     The investigator should contact tha Regional or State NPDES office in order
to  obtain copiaa of pertinent pen .its and/or parmit applications*

     2,  Clean Air Act Permits and  Parmit Applications

     Sooa RCRA facilities will have air emissions  requiring stationary source
controls under the Clean Air Act.   These  permits and permit application*  may
provide useful Information on waste generation at  tha  facility.  Tha baghouse
emission control dusts from some  facilities  (e.g.,  secondary laad  smelting
facilities)  are listed hazardous wastes and must be disposed in accordance with
RCRA.  Tha Clean Air Act  permits  and permit  applications  should be consulted  at
the appropriate facilities.

     Tha  investigator  should  contact the Regional/State air permitting office
for Information on permitting at  these  facilities.


                                       B-4

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     $.  TSCA/OIHA Inspections

     The Toxic Subataneas Control Act (TSCA) regulates the dispoal of PCBa and
PCI equipment,  lo MMM cases the responsibility for conducting TSCA inspections
is merged with the ftC&A inspection program.  In other eases, these inspections
*ra conducted by  different unit within EPA*  TSCA inspection film may have
usful data OB how much and where disposal and storage of PCIs has takan place
at a particular facility.

     the Occupational Safety and Health Administration (OSHA) inspection raporta
ay identify the type* of miteriala handled by a facility and may alto establiah
whether the owner or operator hag a hiatory of violations.  Violation hiatoriea
can indicate a facility'a propenaity for releaaea that might be subject to cor-
rective action*

     For information on TSCA activities at t facility, the investigator should
contact the Regional toxic aubatances office*  For indorsation on OSHA inspee-
tiona, the investigator should contact:

     Occupational Safety ftnd Health Administration, Federal Agency Program
     202-523-6027
                                                      /

     4.  Dejpartjpnt of Defense Installation Restoration Proflraa (IRP) Reports

     The Departnsnt of Defense has been conducting  corrective action prograa
at its facilities, entitled the Installation Restoration Program (IRF)t for
approximately ten years.  This program was developed to characterize and remed-
iate contamination at SOD facilities, and is similar to the Superfund program.
The IRP program is organised into four phaaes:  Phase I, which is similar to
the RFA; Phaae XI, which is similar to a CERCLA Remsdial Investlgationi Phase
III, which is similar to a CERCLA Feasibility Study; and Phase IV, which is the
design/construct phast of the program*

     All OOD faeilitiea should have a completed Phase I report, which will be
very useful during the RFA at these facilities.  Many of the facilities   11
also have a completed Phase IX report, which will also be of great use during
the RFA.  Each branch of the armed forces has a separate office coordinating
their IRP work.  The investigator should contact the following offices in order
to obtain copies of XRP reports:

     o  U.S. Air Force: Occupational and Environmental Health Laboratory (OEHL)
     o  U.S. Army: U.S. Army Toxic and Hazardous Material*  Agency  (DSATHMA)
     o  U.S. Havy:  Naval Facilities Engineering Command  (NavPEC)   .


IV.  Other Miscellaneous Sources

     1.  Aerial Photography

     Aerial photography, especially historical aerial  photography,  can be  a
valuable tool in a prelimary assessment*   Historical aerial photography  can
provide the following types of information:

     o  The location of past disposal units;
     o  The location of releaaes;


                                      1-5

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     o  Evidence of existing or past vegetation stress;
     o  Potential route* for contamination migration;
     o  Location and numbers of target population*; and
     o  Land uae in eh* area.

     A number of RCRA cites that vere evaluated under CERCLA have had both
historical and recent aerial survey analysis,  the RCRA reviewer should contact
his/her regional coordinator for aerial photography*  These coordinators have
acee through ORD/EMSL/LV to an index of sites that have had aerial photo-
graphic analyses.

     If an historical analysis and current overflight do not exist, they can b*
requested through the regional coordinator*  EMSL has a computerized system
which accesses the major sources of extensive aerial photography including
libraries, archives, and the U.S. Geologic Survey*  EMSL can use this to order
copies of the photographs, analyze the photographs for relevant features end
prepare a bound copy of the analysis*  In most cases, historical aerial photo-
graphy will suffice for the purposes of the RCRA RFA.

     The usefulness of current aerial photographs Is BOre Halted.  They nay be
able to Identify vestiges of old disposal practices, current vegetation damage,
and surface drainage patterns.  Infrared photographs may be useful in identify-
ing areas of strained vegetation.  They can also accurately locate target
populations.  However, much of this information may  be readily ascertalnable
from a visual inspection of the facility*  Accordingly, requests for overflights
should be requested only when there are no other source* of the data*

     2.  State/local well permits

     Moat states require well drillers to obtain well  installation permits*
This source, if available, can provide the most reliable information on the
number of households using well water in a particular  area*  These offices can
often identify the aquifer from which individual wells draw and the construction
of individual wells, Including diameter*  This information can also help  in
identifying the closest downgradlent wells that have the appropriate well
construction characteristics for sampling.

     This information is usually kept on file in state environmental program
offices, or say be found at county  public works departments*

     3.  U.S. Geologic Survey and State Hydrogeologle  Maps

     The U.S. Geologic Survey  (USGS) and state geologic surveys may have  detailed
maps characterizing  the hydrogeology at locations  of RCRA  facilities*   Many of
these maps will supplement  the ground-water  characterisation found in  Part B
applications, and  for storage and treatment  facilities, may provide  the most
available source of  hydrogeologic information.

     The USGS also has a aeries of  geological atlases  providing data on geology
and soils.  These  maps can  cover areas as small as one quadrangle  (a 7*5  minute
map), which is approximately  6  by 8 miles.   These  maps can also provide data  on
soils and rock types underlying facilities which may be helpful if data provided
by the  applicant are incomplete or  unavailable.  This  may  be  especially useful
for evaluating larger facilities.
                                       B-6

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     086S hydrologieal maps provide information on ground water yield, toll
traneailselvlty and location of USGS valla (for monitoring water level*).  This
type of nap may aaalat tha reviewer ia undaratandlng the relationship between
land baa4 unite: nd dapth to ground watar, location of ground water recharge
araaa, pravailing regional flow, and ground watar dlacontinuitiaa (if the ownar
or operator haa not already providad thia type of information)*  Thaaa map* are
also available for araaa aa email a* 7-1/2'.

     Thaaa maps can ba obtained by contacting tha local USGS office, or in tha
caaa of atata maps, tha local atate survey office.

     4.  U.S. Soil Conservation Service Soil Mapa

     US. Department of Agriculture Soil Conservation Service (SCS) offices nap
aoil type* and permeabilities at a reaolution extending down to 2 acre* in aome*
cases*  Thaaa aapa typically characterise aoil type to a depth of aix feat, and
the backup intonation uaed to develop theaa maps may evaluate soils to greater
deptha.  Thia backup inforaation is alao available through the local SCS.

     5.  GEMS (Graphical Exposure Modeling Syatag)

     EPA haa acceea, through each of the regional office*, to a computerized
system with the capability to identify the nweber of individual! within a
specific radiua of a facility.  Thia ayataa ia readily available and can provide
reliable inforaation on population* potentially at rlak from air relaaaes*
When coupled with data on ground uae pattarna, it can alao quantify target
populations drinking ground watar.

     6.  Municipal/County/City Public Health Agencies

     Municlpal/county/city public health egeneiea or departments can provide a
wealth of inforaation on the typee of unita located at a particular facility
and the waataa routinely received at the aite*  Fire oarahalla can provide
loforoation on tha nature of any firaa or exploaiona that have occurred at the
facility.  Inforaation on incident* and alte management prncticaa can aaalat in
determining if any releaaea have occurred or are likely to tccur aa a result of
poor facility management.  These ageneiea maintain their raeorda and files for
a  number of years and often provide the only other aouree of  information  on
"old" unita.

     Even if these files contain little information, employees who have worked
with the local agency or fire department for a number  of years,  often know a
lot about the aite or when- to  obtain additional information*

     7.  State/County Road Coamisaiona

     Core samples of soils end  rocka underlying a proposed  road  are  often
analyzed during  the engineering and planning stages  of road construction.
Records of  these analyses are usually retained and available through most
State/County road commissions.  This Information can provide useful data, where
none or  little are otherwise available,  to evaluate  the potential  for contami-
nants to migrate through soils  and  ground  water, and possibly to determine
where to aample.  This  source will  not  be  used routinely during the UFA.
                                       B-7

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     a.

     Utilltiee may be able to provide extremely reliable and up-to-date popula-
tion data*  They can identify the number of households using public water sup-
plies, both ground water and surface water*  They can also Identify the location
of public water wells and intake*.  This information is necessary not only to
determine the affected population but may also help identify possible locations
for sampling. It will not usually be necessary to use this source during the RFA.

     9.  Local Airports/Weather Bureaus

2    These organisations maintain accurate historical records of the local cli-
mate.  This information is essential in evaluating the potential and direction
that contaminants could migrate through the air and the rate that contaminants
could migrate through the ground water and surface water routes.  Contaminants
can be expected to migrate faster through the ground water In areas with higher
precipitation.  Wind direction(s) is essential in identifying downwind targets
for air releases.  Temperature is essential to evaluate the propensity for
materials to volatilize.  The amount of rainfall, especially during peak periods,
can alao indicate the likelihood that contaminants will migrate overland to
surface water.

      10.  naturalists/Environmental Organisations

      Local environmental groups can provide information on the presence and
location of wildlife and endangered species*  They often have access to indi-
viduals or Information which  can identify  the nesting grounds for animals.
They  can also identify any other sensitive environments.

      11.  Ean>loye*g

      Employees  at the facility, both current and former, may b* able  to provide
information on  facility design and management as well aa information  on the
types of wastes received at  the facility*  It may b* difficult to obtain  owner
or  operator permission to Interview  current employees.  For former  employees,
it  may be difficult  to identify a knowledgable  and  reliable individual.   When
Interviewing  former  and current employees, the  investigator should  be sure to
understand the  employee's motivation for providing  the  information  and should
find  out why  former  employees no  longer work at the facility.   ,

      12.  Colleges/Universities

      The  biology departments of  local  colleges  and  universities  may have informa-
tion  on the  location of  sensitive environments*  In some  cases,  graduate student
reports and  publications  have carefully mapped  the  location of  nesting grounds
and migratory pathways.   Such studies  can be valuable in identifying the impact
of  releases  on target environments.   The geology or agriculture departments of
 local colleges and universities  may have Information characterizing the local
geology and  hydrogeology.   This  can include maps of the area and studies evalu-
ating the permeabilities of soils.

      13.   Interviews with LocalResidents

      As a last resort,  local residents can be a source of information on a
 facility.   Sometimes, long-term residents know a considerable amount about the


                                       B-8

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klad of operation* conducted at a. facility and the type and amount of waste
received at  facility.  In general, this source of information should b
avoided to prevent any undo* or premature slam.

     14.  Standard Eraft. Suparfund Public Health Evaluation Manual^ Prepared
    for U.S. EPA, Office of Eanrgncy and Remedial Kesponaa, December 18,
    1985.
            Ground-wtr Hydrology and Monitoring Hall Construction

 I,  Freeze, R. Allan, and John Cherry, Groundwater, Pr*ntic*-Rsll, 1979.

 2.  U.S. EPA, Office of Waste Programs Enforcement, RCRA Ground-Water
    MonitoringTechnical EnforcetientGuidance Document. Draft. August. 1985,

 3.  Johnson Division, Groundwater and Wells. 2nd  *d,t 1986*


         Hazardous Waste Site Characterization, Sampling, and Analynis

 1.  U.S. EPA, Environment; al Monitoring Systems Laboratory, Character! gat ion
    of Hazardous Waste SitsA Methods Manual. Volume I-Sitalnvestigatiooe,
    Volume IIt Available Saapling Method^s  and Volume III. Available Laboratory
    Analytical ttethods.EPA76007~84yQ75t April 1985.

 2.  U.S* EPA, Office of Emergency and Remedial Response, Guidance on
    Remedial  Investigations Under CERCLA. May  1985.

 3.  U.S. EPA,  Test Kathode for  evaluating Solid  Waste. Physieal/Chenieal
    Methods,  EPA SW-846, July  1982.

 4.  Standard  Methods for the Examination of Water and Wastewater, 16th
    Ed., American  Public Health  Association,  1985.


                                 Personal Safety

 1.  American  Conference of  Governmental  Industrial  Hyglenists,  Threshold
    Limit Values and Biological  Exposure Indices  for 1985-86.  1985,
                                       B-9

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2.  National Institute of Occupational Safety and Health/Occupational
    Safety and Health Administration, NIOSH/03HA Pocket Guide to Chemical
           , U.S. Government Printing Offle**
3.  U.S. EPA, Of fie* of Emergency and Remedial Response, Standard Operat ing
    3a*ety Cuidaa. Ediaon, NJ, 1984.


                     Toxlcological Properties of Chemicals

I,  Sax, Irving, d., Dangeroua Properties of Industrial Materials, 6th d.,
    Van Noatrand Reiahold, 1984,

2.  National Institute of Occupational Safty and Health, Registry of Toxic
    Effects of Chcaieal Substances. U.S. Government Pri nt ing Of f ice , ( annual ) .

3.  Clayton, G.D. and P.E. Clayton, Patty's Industrial Hygiene and Toxicology.
    3rd ed.,Vols. 1-3, Wiley Inters ctenee, 1979.

4,  IGF, Inc., Draft, Superfund Public Health Evaluation Manual. Prepared for
    U.S. EPA3 Office of Emergency and Rsaedial Response, December 18, 1985.
                                       B-10

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         APPENDIX C









SAMPLE LETTER OF REQUEST FOR




 OWNER/OPERATOR INFORMATION

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Dear Sirs:
     As we have discussed In our recent telephone conversations, the
Plant has been selected by EPA as a subject for testing EPA's draft guidance,
RCRA Facility Assessment Guidance.  The preliminary assessment (PA) is the
first phase in the process of determining whether solid waste management units
(SWHU's) are releasing hazardous constituent!! to the environment and require
corrective action.

     After reviewing EPA files on the	 Plant, a list of questions
regarding additional information has teen developed.  It is anticipated that
the requested information exists in your files.  An attempt was made to keep
the requested information to a minimum in order to avoid impacting your effort
in preparing the Part B application.

     The following information is requested:

1.  Provide elevations of all SWMU units and/or identify the 100-year fioodplain
    for the enjEijre facility property.

2.  Provide any available information (dates, quantities, materials, locations)
    on past spills in the production area.

3*  Spill tanks are shown on Figure B-l of ________ subaittal, but are not
    mentioned in the text.  Explain the purpose of the tanks and provide chemical
    information on the material stored in the tanks.  If this unit does not fit
    the definition of a solid waste management unit, explain why.

4,  For the New Trash Incinerator (Unit l,A.}, indicate whether a permit has
    been issued by the 	m.,-mwi,,.m_..mjim ^*r Pollution Control Board.  Provide a
    copy of the permit if it has been issued.

5.  For the Waste Treatment Sludge Incinerator (Unit I.C.), provide the start-
    up date and planned closure date.  Describe plans for treating or disposing
    of sludge after closure of the Incinerator.

6*  For the Waste Treatment unit (Unit 3), provide the following:

    i)    A description of the modifications in plan operations which,  when
          combined with amendments fto the ___-w^-_ hazardous waste  regulations.
          hsvfe rendered the wastewatar non-hazardous since November 1,  1983.

    ii)   The start-up date for the original vastewater treatment  unit  (the
          "pre 7/82" unit), and any available description of wastawaster  treat-
          ment and sludge disposal prior to  the start-up of  this unit.

    Ill)  Any available data concerning the  hazardous constituents present  in
          the sludge trow the wastewater treatment plant unit  prior to  November
          1, 1983.
                                      C-l

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7.   For the Haste Recycling Operations (Unit 4),  provide  the following:

     1)   A nap showing th* location c' each recycling unit and associated
          storage tank and piping.  The nap should be on a scale of one-inch
          equal to not more than 200 feet.

     ii)  An explanation of disposal and/or treatment of residues for each
          recycling unit.

8.   Provide the exact locations of the land farm areas and delineate boundaries
     where possible.  Clarify how many land farm areas nave been used in the past.

9.   Provide any available information on the chemical composition of the sludge
     that has been applied to the land farms in the past.

10.  For the Storage Tanks (Unit 8), provide the following:

     I)   A nay showing the location of each tank and associated piping.  The
          map should be on a scale of one-inch equal to not wore than 200 feet.
          A map combining the Waste Recycling Operations (Unit 4), as requested
          above, with the storage tanks is acceptable*

     11)  For each tank, indicate if any secondary containment exists.  A "yes"
          or "no" response will suffice.

     ill) Describe the leak test performed, frequency and  date of last test for
          each tank.

     iv)  For each tank identified as having been found to leak, provide any
          available information describing the approximate period of leakage
          and estimated volume of leaked wastes.

     v)   For the tanks identified which may have been used in the past for
          solid waste storage, indicate which tanks are underground, elevated
          or at surface level.

ii.  Clarify how many landfills exist or have existed at the facility.  Delineate
     boundaries of each landfill (where possible).  If any other landfills are
     identified, describe what materials were disposed of in these landfills.

12.  Provide gny available information (dates, quantities, materials, locations)
     on past spills at the facility that were reported to the National Response
     Center (or the   	.-^^.^ Department of Health) as required under CERCLA*
                                      C-2

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                        APPENDIX B



             GUIDANCE OM OBTAINING  ACCESS  TO

              A RCRA FACILITY IF ACCESS  FOR

              A SITE INVESTIGATION  IS DENIED
[SOURCE MATERIAL FROM:   U.S.E.F.A.  HAZARDOUS WASTE GROUND
 WATEE TASK FORCE, "REVISED DRAFT PROTOCOL FOR GROUND-WATER
 INSPECTIONS AT HAZARDOUS WASTE TREATMENT, SfORAGS AND
 DISPOSAL FACILITIES",  JUNE 1985]

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                GUIDANCE OH OBTAINING ACCESS TO A 1OU FACILITY
                  FOR A SITE INVESTIGATION IF ACCESS IS DENIED

IS an investigator la denied access to a facility to conduce  ale* Investigation,
th following procedural steps mac be followed.

                                                                              
Upon Denial of Access

   1.   Upon denial of access, thoroughly document the event, noting tlae,
        dat*f and facility personnel encountered. *

   2.   A*k for reason of denial of access to facility.

   3,   If th pro b lea la beyond the investigator 'a authority, augjeit that Che
        owner/operator contact an attorney to obtain legal advice regarding
        his/her responsibility for providing facility access under Section 3007
        of
    &    If entry it still denied, exit fccm the premises and docusMtnt
         any observations aade pertaining to the denial, particularly any
         suspicions of violations being covered up.

    S.    Report all aspects of denial of entry to the U.S. EPA Office of
         Regional Counsel for appropriate action, which nay  include help
         in obtaining a search warrant. **
Conducting & *it  Investigator under a  search warrant will differ  froe a noraal
inspection.  Th following procedures should be coaplied  with  in these
situations:

Developmnt of a Search Warrant

    I.    An EPA Office  of  Regional Counsel attorney  will assist the investigator
         in the preparation of the documents necessary  to  obtain a  search warrant
         and will arrange  for a see ting  with him/her and a U.S. Attorney*   The
         Investigator should bring a copy of the appropriate draft  warrant  and
         affadavlts to  the meeting*

    2.    The U.S. EPA  Office of Regional Counsel  attorney will infora Ch
-------
tfo of  Warrant Co Gain Entry

   1.   fh* iavestigator should never attempt to oak* any forcful satry of the
        facility.

   2.   If th*ra is a high probability that entry will be refused evea with a '
        warrant or wh*r there are threats of violence, the investigator should
        b aceoapaniad be a U.S. Marshall.

    3.  If entry is refused to an investigator holding a warrant but not
        accompanied by a U.S. Harshall, the investigator should leave the
        facility and infers the U.S. EPA Office of Regional Counsel*

Use of a Varrant to Conduct the Investigation

   1.   the investigation oust be conducted strictly in accordance with the
        warrant*   If the warrant restricts the investigation  to certain areas
        of th premises or to certain records, chose restrictions oust be
        followed.

   2.   If sampling is authorized, all standard procedures must be carefully
        fallowed including presentation of receipts for all Jaaples taken.  The
        facility should also b informed of its right  to retain a portion of
        the sapu? obtained by che Investigator  (split samples).

   3.   If records or property are authorized  to  be taken, the investigator must
        provide  receipts to the owner/operator and maintain an inventory of all
        itoB  removed fron the premises.

   4.   In accordance with the warrant, th investigator should take  photographs
        of all areas where violations are suspected.   Photographs should also
        b taken at each sampling location as  a quality control procedure.

For further guidance regarding denial of facility access consult  the  National
Enforcement  Investigation Cancer. (303) 236-5100
                                        0-2

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                  APPENDIX E



             PHYSICAL AND CHEMICAL

          PARAMETERS  FOR CONSTITUENTS

                  OF CONCERN
[THE ATTACHED HAS PREPARED BY ICF, INC,, FOR THE
 OFFICE OF EMERGENCY AND REMEDIAL RESPONSE, EPA,
 AND FOUND IN "DRAFT SUPERFUND HEALTH ASSESSMENT
 MANUAL", MAY 1985]

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     7.4OI et
c
c
J
I
     t. out MI?  c
                                   c
                                   B
                                     6. oar -us
                        1. 9M -IMl   A
                        l.tMfMiO   M
                                   r
                              NA
     9.S2flll   A
     i.OOC-Od   C
     7.2JII-UB   0
      .6Of-ll9  A

      !olt-IO  A

      !lK>rMHl  I
      .IMMtIHI  1
      .IOC-III  C
      .>ai-iii  c
      .iKirmi  c
                         .IMMT-MJ  [
                         .frlH*7  I
                         .OOf*UI  A
                        . UfMII  A
                                                            8.7111*11]   A   t.SII*U^  A
                                                            I, Bill-111   A
                                                            J . till *IIH
                                               t
                                    II.IMIlMUl  t
                                    b. illl -IW  A
                                    U 1NII MMI  
      c
      c
 7.7  ft
 7.7  ft
IfciHI  ft
              96iMKI  C
                 i.2  ft

                 Illl  ft
                41  ft
                 1. t  ft
              lltlttMl  C
                 NA
                      ft
                6.6  ft
                1. i  ft

                 8}  C
               Ul.'j  C
            13BIMNHI  C
               IIHMI  ft
                      C
                      c
            16OOWMI  C

                 Ml  ft

               13.9  C
                 fcl   c
                1.7  C
                1711  ft
                ? *   ft

               61IN}   ft

                 *,||   ^
                HO   ft
             IMMMMI   C
                3IU   C
                SOU   ft

                 It   ft
                                                                                                        7IKHHNI  C
                                                i.JO
                                               -e.22
            1.10
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            6ill6
            6.06
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            6.S6
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            1.50
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            0.38
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                                                                         C
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 1. IU
-M-?l  J
-O.IH  I
 3.78  B
 11.11  I
 0.2*1  C
                                                                                                                      2.IB  B
                                                                                                                      -2.UB  B
                                                                                                                       O.IHI  I
                                                                                                                       1.NS  A
                                                                                  KA
                                                                                  .16  a
                                                                               -t.ua  a
                                                                               -i.01
       A
       C
       C
       B
       C
       A
       A
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                                                                  *.6I   A


                                                                  1.91   I
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                            I   II
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 *.2  N
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   19   H
 6.9   II
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(1.63   II
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                 II  I
                19  II
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                111  II
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-------
                                                                     1 AtHfll J C-l
                                                                     (Ludt ItllMd)
                                                                                                          Dale Prepared:   BBCfMflJLJI.. .J9J}
  m
   i
  fVJ
II
                           MUM
         Cyanide*
              BarisiB Cycnida
             - CatciMM Cyan Ida
                       Cyanide
                         Cfetorid*
                         CyBitld*
            -  MitKel  Cy*md
               PatasftiMt Cyanid*
               FatiifcfcliMi Silver Cya
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             SoUM  Cyanide
            -- line Cyanid*
         Cy c I Oftto ipha* J d*
         GOO
         IMH
         B0I
         I , ? . / . t-D i fettiiumy rera
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              99
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              221
             111
             111
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                    1 . UOt *ltfc
              304   I.101-01
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                      . llll OI
                      .(Mil 2
                      211*02
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                   6.1IH*U1
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                   2.OMtt*
                   *. 601 *01
,2. fill *OJ
2.0UI*OJ
1.941-01
                    H. t/l
                   9. 601 -111
                   I.Mil nil
                   i'. 4l 

                   1. IMH *II6
                              K
                              i
                              t
 1.119 *II9
 I.Otil -III
 1.OUt-02
 4.IMH-1)1
                                                                 6,201*02  f
C
C
C
          C
          a
          H
          J

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          a
                !.fKMT*IH  J
                          1
 C
 C
 A
 a
 a
 a
 c
 a

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                                   6.4UO06
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5.901-02

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2.
I.I
                                                                               2.4r-0?

                                                                               1.4^1*01
                                                                               6.80I-OI
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           C
           A
           a
                                  l.UOC-fO   C
                                  I.OOCHMI   a

                                  i.oor-04   c
                                  1.001*00   c
                                  2,2afOO   C
                                  t.lat+eo   c
                                             c
                         A
                         A
                         A
                         A
                         A
                         C
                         C
C
G
C
                                                                                          i
                                                                                          t
                                             I
                                             a
                                                        NA
           NA
     r.9i*i-ub
     6. em-os
     4. Ili-t*
     1.641-0*
     1.281 - til
           NA
     I. ill-ItS
     1. Ill-ui
           NA
     2.821-III
     1.911-ill
     1.491-01
     2.899-01
     3. Hill -02
     .46t-0l
     1.481-111
     2.011-01
     2.141-06

     i.aar-o*
                                                 2.111-01
                                                 I. lOt-01
                   i.nat-u;'
                         NA
                         NA
                   I.Kit-Ufa
                         NA
                         NA

                         NA
                   9.?l-llli
                   l.
-------
                                                                     C-l
                                                                                                  Date  rrpred:
  j mo i Ity I mm i not /0lMm/nc
  . !?~lt**nif *|*Mi*trecfi
   3 ~8i I i rofoonf
  . i-Oin II rwio luena
B i prop? I n 1 1 rotMi I iw
I ttiytfeew/VM
tlNylviw O*broa) fCGC}
fth^lviw Oaitfa
i Ihy l**MStfciwuro
l-l
ferric Os*trn
f
f
I luut
fonutdetiyte
furaic Ac: id
Cfycol Itlwrt
      Konoetliyi Cttar
   -- 2-1 ihuxyaihanai
   -- ltfiylM Clyeol.
                 Glycol,
                 ftMr
                 Ctycol.
                  Ctlwr
i    s
Hup t ccti I or  ffMixl4*
lie  arti I o robcn/*fM
               !|>lt#-H:tt*cM0rcyc luito

                          -O
 602-01-7
 121-14-2
 619-15-8
 606-20-2
 610-19-9
 88-85-?
 I?1-9I-I

 122-66-7
 67!-64-;
 106-89-6
 64-17-5
 62-50-O
 1OO-4I-4
 106-91-4
 75-21-8
90W4-66-4
206-44-fl
86-71-7
7/82-41-4
50-00-0
64-88-4
765-J4-4
    NA

U1-90-0
t10-80-5

11(-76-2
109-86-4
                                                   III f -98-2
                                                   ^6-44-8
118-74-I
87-68-1
77-47-4
319-84-6
319-85-7
58-89-9
319-66-6

7O-141-4
                                                 fllYStCAI.  CIHNICAI, AND lAll OAIA
                                                  Mtl
                                                 Weight
                                                                         Water
                                                                                        Vapor
                                                                                       Pressure
                                   Meiiry* &  I ew
                                                                  ??*
2U2
116
 NA
 30
 46

 NA

114
 90

118
 76
                                                   If 4
                                                   389
                                                  ?6f
                                                  ?71
                                                                 ?*>!

                                                                 407
                                                                                                    HOC
                                                                                                   1*1/9}
                                                                           ti9
                                                                           tew
                                                                          itttt
                                                                          BCI
                                                                        i. JM *;il
                                                                        4.4UI-II3

                                                                        t'. 241 06

                                                                        t. tl 6
                                                                        4. 701 HI.?
 108
  60
  60
  74
 168
 198
 184
 IB?
 18?
 18?
 16?

 240
  88
                                                                 130
                                                                  93
                                                                  46
188
 44
                                                                 117   3.311*08
                                                                        5.6IM nil
                                                                        3. ill) MI}

                                                                        l.l?i*ilj

                                                                        i!oai MH
                                                                        5.fKif *HI
                                                                        4.311 *05
                                                                        5. Ifil o
9.901 OJ
6.OOI O4
t.OOI*06
3.6
                                                                       t. eioi MM,
                                                                       1. 7UI *OB
      I. ant
      1.5HI
      6. (Nil
      t. 'Mil
      ?. till
      1.611
      ?. 4111
      I.IUH
      3. 141
      ',. IHH
      4.00!
0
ft
a
a

i
j
c
c
a
c
0
8

J
a
t>
c
c
j

a
A
J
8
r
          A
          C

          *

          H
                                                                       t.fMii*a6   r
                                                         1.0411*06  K
     -01  c
     -til  c
     -111  A
     -01  A
     OO  A
     INI  
     -111  c:
     INI  t:
      III  C
     nt  t;
     -iij  i
                                                                        i.95f too  a
                                                                                  B
               6. IOC*OO  C


               t'. 491-05  C

               5.IOC-O1  C

               1.801-02  C
                                                                        ).99COI
                     2.601-05
                     4.001-01
                     l.57t*OI
                                                                                      l.tiUi^W)
                                                                                      t.Jt*03
    3.(MM-04

    2!001*00
    8. (Kit-02
    2.5OI-O5
     .HOT-07
     . 6IH -04
      Hit -05
2.
1.
I.
           a
           a
           c
           c
           a
           c
           a
           A
           B
           a
    5.OOC-O6  A
    7. IOC-114  C

    I.OOf+OI  C
    4.MlIltt  f
    l.97f>OI  
                                                                       4.OUI-MI
c
c
A
A
A
c
c
c
c
c
                I . t* ~V
                      NA

                liottt'U/
                      NA
                7.90I-M7
                      NA
                4.491 -!>
                6.451-IU
                      NA
                5.O9I -lift
                      NA
                1.2/I-H6
                      NA
     1.0/!-'>
     1.4/E HI;
     J.4?l-09
     6.9?f-06
     3. 191 -I)'*
     4.461 -o'i


     6! 731-04
     7.561-05
                                                                                                           NA
                                                                                                    6.461-06
                                                                                                    9.8/l-Uf
6.19I-U4
4.191-04
6.611-M
4.571*00
I. 371-0?

4^471 -Hi

?.O7I -7
?.4>l-l
      NA
                    I ID Ml  ft
                  4760MO  C
                     05  ft
                     0.2  ft

                     O.I  C
                      C
                16.6  C
                  51  ft
                  45  C
                  84  ft
                  92  C
                  94  ft

                 3.5  ft
                 4*0  ft
                 416  C
                  15  C
                  IO  ft
                 2.2  ft
                 J-fl  ft
                iiuu  c
                  44  C
                 2.2  ft
                  67  ft
                 O.I  ft

              38000  C
               71INI  C
              6.94  a
             -1.32  
             2.42  a

             -0.68  C
              1.62  r
              2. 7O  C
              1.5O  C

              2^110  C
              ?.?a  a
              2,1*0  C
              2.29  B
                                                                                                                                O
                                                                                                                                0
             O.O1
             3.60
             2.90

             0.15
            -O.32
             0.21
             3.15

            -Oi22
            -0.66
                                         4.90
                                         4.20
       a
       a
       c
       c
       a
       j
       A
       a
       a
                                                  i
                                                  o
                                              ,8  M
                                              ,8  M
                                              ,8  H
                                              ,8  H
                                              ,8  H
                                                                                                                               JO  C
                                                                                                                               25  H
                                                                                                                                              O  I
                                            1I5O  N
                                            1300  U
                               3.6

                               O. I
iToaii  c

 J9UO  O
29IMMI  C
 4MNI  C
 38011  C
 3AIHI  C
 lomi  G
 6WMI  J:
?INNNI  t
9IOOO  ft
                               o.oo  r
                              -O.54  I
                              -1.55  8
                                                       o.oo  r

                                                       O.OO  f
4.40  C
2.70  C
5.21  A
 .78  A
 .04  A
 .90  C
 .90  C
 .911  C
 . 10  C
 .60  C
 .54  I
                                          0
                                          O
                                                                                                                                                   V,

                                                                                                                                                   pi
                                                                                                                                                                 LJ
15700  H
14400  V
 869O  H
  2. B  M
  4.3  N
  1)0  H
  110  H
  (JO  II
  I JO  II
  a;  M
                                                                                                                                                  I J
                                                                                                                                                  O-

-------
rn
                     C-J
             iCunt i iw*d |

 niVSICAi , CHI H 1C**,  AHO f ATI  OA(A

  Heiii!    Water          vaper
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                 C
               feat
      Nickel  and
      Nitric  Oxtc
      Niiroten/eoa
      Nitri9ulyclilornal(5tf
      7701-06-0
      193-19-4
      7f-60~o
      t4010-li-0
      70-79-4
      120-40-I
      101-40-0

      7019-9^-1
      140-44-2
      121-74-7
      1019-96-4
      7019-91-6
      7019-97-6
     620-06-0
     70-07-1
     70-91-1
     t110-21-0
     00-62-6
     290-00-0
 Acid 90-70-6
     46-09-1
Hft* 10i-tO-0
     600-91-4
     46-00-2
     0409-00-0
         ^4-7
     40-07-1
     404-60-2

     91-49-0
     700G-02-0
     10102-01-9

     IOIO7-00-O
     614-41-7
     100-74-0
     9M-44-2
     99-44-0
     600-91-4

     B7-06-4

     04-01-0
     4U-06-6
     100-94-2
     6?-10-0
     7BU1-4I-2
     100-B2-I
     11)6-16-1
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                                           IIO'*b-l
    1?
    10
 46
 60

091
012
207

llu
 44

201

 40
 72

100
263
201
260
   102
    66

   110

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  2411
  179
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   10
  lift
                                                         47
                                                        ?;
       1.011 *U0
       0. I M *itl
         9.9UI-U1
2.inn nil
6.001*01
           1*04


           *U2
       .001*06

       . JM-tll

       ! 001 tot

       .IMM MM
       .(MM MIJ
      9. UM *OO
           B
           B
 1.041*02   t
C
A

f
L
        1. III! -02   C
                                                              1.MH
                   
                   A
                                                                             I.OUf-IU
1.601-00


O.OOC*UO

O.OM-O4


2.00C-01

0.)ic*nj
                       9. IOC-06
                                                                             t.2ir*oi
              I.IOC-91



              t.IOC-00

              6.0OE-OO

              1.0tC-01
                                  C
                                  J

                                  1
                                  a
B
A

I
1
                               B
                               B
                B   2.46C-0*  B
                    O.OOC00  0

                C  * 1. 4OC-OI  B
              a
              a
              a
              c

              A

              A
                                       1.011*02  B
                                       /. 'ta -INI  A
                                                                                            I./1I-W9
                   4.10I-1D
                         NA
                         MA
                   1.241-1?
                         NA
                         MA
                         HA
                                            NA
                                            MA
                                            MA


                                      0. OUl -41?
                                      ?. 701 -dV


                                      2. Oil-III
                                   MA
                                   NA
                                   MA
                                   NA

                                   NA
                                                                                           4.211-119
                                                                                           6.2)t-6
                                         NA
                                   i.ttt-ua
                    MA
              6.101 -110

                    NA
              1.491 -l"
                    MA
              0.401-U7
                                         NA
                                   I.O/J -111
                                         NA
                                   S. S.'l -114
                                                                                                 MA
                                                                     U.I  ft    -1.00  B
                                               1600000  c
                                                    21  ft
                                                                                                            91
                                                           ft
                                                           ft
                                                                                                            V
                                                  ft
                                                  ft
                                   ft
                              060  ft
                                  O.I  ft

                                  2.4  ft
                                             110  ft
                                             61  ft
                                             1)0  ft
                                             16  C
                   0.0  6j

                 I SIMHI  ft
                 JWUU  ft
                 41000  C
                                                                                                                f.
                                                                                                           90   ft
                                                                                                          10.2   C
                                                       ft
                                                       t:
                                                                                                        1MIMIU
                                                       6.40
                                                       1.69
                              2.66  B
                              2.00  B
                              o.yy  a
                                                                2.A9  J
 0.94  B
 0.26  A

 0.79  f
 1.9t  f
                                       -J.1  B

                                       -8.2)  B


                                        1.17  B

                                        2'07  B
-tf.09  a
-1.06  B

 4. 19  f
 4.04  a
    4  C

 *.06  A
-o. 19  a
 9.06  A
                                                                                                                                 BM
                                                     -o.oa
                                                      0.00
                                                      0.66
                                                  B
                                                  A
                    C

                49  M

                 0  f

              1140  N
                    It
                                                                     07  M
2124  M

 770  C

261O  C

 1.0  M
                                                      6.OO  C    1OOOOO  C

-------
 So Je lit USB  end
    -- Si*ni
    -- Sinoirttc
 Silver end  Co|sunti*
 ?,!,*. 9- H.IM (Uinitin}
 1,1.1.?- i
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                                       119-91-J

                                      616-21-*
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 7V69-4

8-06-2

 16-11-I
 126-I?-?
 12-il-l

7*40-61-I

?40-6?-2
7V-MI-4
9V-4/-6
108-IS-1

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                                                               MlMlltl C-S
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                                                                                                     Dili- Prttparvd:
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                                                    Mti!
                                                   Weight
                      Ma l ft r
                    Holitbi 1 tly
                                      VfMf
                              Ihtnry* *  j av
               IIM
              Vjt
              3i*
               168
               168
               t66
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              111
              111
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              191
                                                    W.I
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 6. MM
 7.1NII
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    ill   J
    HI}   A
    HI2   A
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                    APPENDIX F





EXAMPLE DATA ELEMENTS FOR FACILITY PR IORITIZATION

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                            APPENDIX F

        EXAMPLE DATA ELEMENTS FOR FACILITY PRIQKITIZATION


l*   Khat 1s the net recharge of the facility area?


2.   What 1s the distance from the unit to the aquifer below the
     TFnTtf?  If actual  depth Is unknown, circle closest approxima-
     tion of depth from ranges given below:

     Feet:  0-5   5-10   10-30   30-50   50-75   75-100   100 +


3,   What 1s the slope of the surface topography within the
     facility boundary?  Circle closest approximation of slope
     from ranges given below:

     % Slope:   0-2   2-6   6-12   12-18   18+


4,   How deep 1s the soil layer beneath the facility?
     (Use soil references cited in RFI guidance,)


5.   Is there a surface water body downgradient that  is within
     two miles of the unit?

     If yes, what 1s the distance betwen the surface  water body
     and the unit?


6.   For land disposal facilities (that should have  Information
     on hydraulic conductiv1ty hydraulic gradient,  and effective
     porosity Included in their Part  B permit applications),
     calculate the time of travel (TOT) to the *acH1ty boundary
     and the nearest drinking water well downgradlent.  Refer to:

     CH teri a f or I den11 fy 1 ng Are as of Vu 1 nerab 1 e  Hy d r o ge o 1 Oj}y _-
     FnteT 1m FjjnaY, J u ne 1W51  the time of  travel calculation
     was developed by the U.S.  EPA Office of Solid Waste as  a
     tool to be used in a s s e s s1n g the  v u1n e r a b1V11y  o? g round
     water  in different hydrogsolog1c  settings.

     The  following steps should  be  completed when  calculating TOT

     a)  What  is  the calculated  or  average velocity  (V)  of  ground
         water flow below the  facility?   (Refer to criteria  dt*>d
          above.)

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     b)   What  1s  the  distance  to:

         1)   facility boundary?
         2)   nearest  downgradient  drinking  water  well(s)?

         What  1s  the  TOT  for:

         1)   time tu  facility  boundary?
         2)   time to  nearest  downgradient  drinking  water  well(s)?
             (Refer to Criteria  cited  above.)


7.    For facilities other than land  disposal  facilities,  facilities
     ToTated on karst. terrain  or fractured  bedrock:

     If  a rapid ground water  velocity  1s  suspected,  collect data
     on  hydraulic gradient, hydraulic  conductivity,  and  effective
     porosity in  order to calculate  TOT  from the  unit  to  1)
     facility boundary and 2)  nearest  drinking water well.


8*    What is/are the waste constituent(s )  of concern?   If unknown,
     provide available information on  the  following aspects of
     the waste to allow reasonable inferences to  be drawn on what
     constituents are present.

     a)   Suspected classes of compounds  (e.g., organic solvents,
         1norgani cs , etc  );

     b)   Waste streams (e.g., pickle liquor);

     c)   Manufacturing process(es) tfhlch  produced waste.


9.    Are there any active production wells near the unit or
     7a~c~i lity?   If yes:

     a)   What  is the distance between  the unit and the production
         well (s)?

     b)   What  is the production capacity of the well(s}?

     c)   How old is  the un1t(s}?

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join ML
        DOCUMENTATION
        PAGE
  KCKA  Facllltv Assessment Guidance
                                                                     t. xi (><
                                                                       Oclobcr.  1986
                                                                      10.
                                                                      II. C"ftt(C) x O'irKfQ)

                                                                      CO

                                                                      fOl
 11. n*rln Offnlt(l*r* nd
  Office of Solid Vvaste/F.PA
  ioi  M ;;tn-ft, s.w.
  Washington, D.C.  20A60
 It. tJM>Mmn
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