OOOR80108
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
ENFORCEMENT CONSIDERATIONS FOR EVALUATIONS OF
UNCONTROLLED HAZARDOUS WASTE DISPOSAL SITES
BY CONTRACTORS
April 1980
This is a revision and update of the draft
document "Information Package for Hazardous
Waste Investigation Workshops," September 1979.
11 r- n.,"Voiv-T'n*cS Protection Agency
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Chicago, Illinois 60604 ^^X^'
National Enforcement Investigations Center
Denver, Colorado
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FOREWORD
This document is prepared specifically for the guidance
and direction of Hazardous Waste Site Field Investigations
Contractor Teams (FIT). Although much of the material is
taken from other Procedures Manuals, Safety Manuals and
similar publications, the procedures prescribed have been
adjusted to accommodate to supervisory structures, contract-
ing protocols, and authorities that are particular to the
contracted investigations.
This draft will be updated and revised, as necessary,
within the immediate future. Suggested changes should be
forwarded through the Regional Deputy Project Officer.
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CONTENTS
I. PRELIMINARY ASSESSMENT 1-1
A. INTRODUCTON 1
B. INITIAL CONTACTS 2
C. GOVERNMENT FILES 2
D. ENVIRONMENTAL DATA 3
1. Geology 3
2. Soils and Overburden 4
3. Climate 4
4. Geohydrology 5
5. Surface Waters 5
6. Sensitive Environments 6
E. SITE ENVIRONS 6
F. HAZARDOUS WASTE MANAGEMENT INFORMATION 7
G. AERIAL PHOTOGRAPHY 7
1. Archival Imagery 9
2. Aerial Reconnaissance Techniques 10
3. Equipment 11
4. Management of Aerial Reconnaissance 12
II. INITIAL EVALUATION OF DATA II-l
A. INTRODUCTION 1
B. PARTICIPANTS 1
C. DATA REQUIREMENTS 1
D. EVALUATION OF POLLUTION POTENTIAL 2
E. SETTING PRIORITIES 4
F. AVAILABLE ACTIONS OR DISPOSITIONS 4
1. No Action Required 4
2. Inspection Required 5
3. Enforcement Action 5
4. Emergency Response 5
5. Notification of the Public 6
III. ADMINISTRATIVE PROCEDURES FOR SITE INSPECTIONS AND FIELD INVESTIGATIONS . . . III-l
A. WORK ETHICS 1
1. Professional Stature 1
2. Conflicts of Interest 1
3. Attire 2
4. Public Relations 2
5. Gifts, Gratuities, Favors, Luncheons, etc 2
6. Attempted Bribery 3
B. DISCLOSURE OF OFFICIAL INFORMATION 3
1. Requests for Information 3
2. Requests by State and Local Cooperating Officials 4
3. Confidential Information 4
C. DOCUMENT CONTROL 5
1. Serialized Documents 5
2. Project Logbooks 5
3. Sample Identification Documents 6
4. Chain-of-Custody Records 6
5. Evidence Audit " 7
IV. OFFSITE RECONNAISSANCE IV-1
A. PREPARATION FOR INSPECTION 1
B. INSPECTION 1
1. Areas of Concern 2
2. Sample Requirements 2
C. PHOTOGRAPHS 3
D. SKETCH MAPS 4
E. EXPOSED SOILS AND ROCKS 4
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CONTENTS (Continued)
V. SITE INSPECTION V-l
A. PREPARATION FOR INSPECTION 1
B. NOTIFICATION 1
C. STRATEGY DEVELOPMENT 1
D. SAFETY 2
E. ENTRY 3
F. WARRANTS 5
1. Application for a Warrant 5
2. Affidavit 5
3. Draft Warrant 6
4. Securing A Warrant 7
5. Inspections With A Warrant Should Comply With The Following 8
6. Procedures to be Followed Upon Completion of the Inspection 8
G. INSPECTIONS 9
H. HAPPING THE SITE 10
I. SAMPLING 10
J. PHOTOGRAPHS 11
K. LEAVING THE FACILITY 12
L. CHAIN-OF-CUSODY PROCEDURE 13
VI. PROJECT PLAN DEVELOPMENT VI-1
A. PREPARATION AND DISTRIBUTION 1
B. SAMPLE LOCATIONS 2
C. WHAT TO SAMPLE 3
1. Soil 3
2. Surface Water 3
3. Groundwater 3
4. Air 4
D. SAMPLE CONTAINERS 4
1. Environmental Samples 5
2. Unanalyzed Hazardous Waste Site Samples, Excluding Closed
Container Samples 6
3. Unanalyzed Hazardous Waste Site Sampler from Closed Containers 7
f.. DISPOSITION OF SAMPLES 7
f. TEAM BRIEFING 7
VII. FIELD INVESTIGATIONS VII-1
A. PREPARATION FOR INSPECTION 1
B. NOTIFICATION 1
C. SAFETY 2
D. ENTRY 2
f.. INSPECTIONS 2
f. FIELD TESTING 3
G. SAMPLING 3
H. PHOTOGRAPHS 4
I. CHAIN-OF-CUSTODY 4
VIII. CHAIN-OF-CUSTODY VIII-1
1. Sample Custody 1
2. Field Custody Procedures 1
3. Transfer of Custody and Shipment 2
IX. DOCUMENT CONTROL AND EVIDENCE AUDIT IX-1
A. SERIALIZED DOCUMENTS 1
B. PROJECT LOGBOOKS 1
C. FIELD DATA RECORDS - 2
D. SAMPLE IDENTIFICATION 2
E. CHAIN-OF-CUSTODY RECORDS 3
F. CORRECTIONS TO DOCUMENTATION 4
G. DOCUMENT NUMBERING SYSTEM AND INVENTORY PROCEDURE 4
H. TEAM FILES 5
I. EVIDENTIARY FILE 5
J. REPORTS 6
K. CONFIDENTIAL INFORMATION 6
L. EVIDENCE AUDITS 7
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CONTENTS (Continued)
X. PACKAGING, MARKING, LABELING, AND SHIPPING OF HAZARDOUS WASTE SITE SAMPLES ... X-l
A. GENERAL PROVISIONS 1
B. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS WASTE
SITE SAMPLES, EXCLUDING CLOSED CONTAINER SAMPLES 2
C. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS WASTE
SITE SAMPLES TAKEN FROM CLOSED CONTAINERS 5
XI. QUALITY ASSURANCE XI-1
A. INTRODUCTION 1
B. ORGANIZATION AND PERSONNEL 2
C. RECORDS AND REPORTS 2
1. Recording and Reporting of Study Results 2
2. Retention and Retrieval of Samples, Records and Data 3
D. BIBLIOGRAPHY 4
1. General Quality Assurance 4
2. Laboratory Facilities and Practices 4
3. Sample Collection and Analysis 4
XII. SAFETY PROCEDURES FOR HAZARDOUS WASTE SITE INVESTIGATIONS XII-1
A. INTRODUCTION 1
1. Purpose 1
2. Responsibilities 1
B. GENERAL SAFETY PRECAUTIONS 4
1. Unsafe Situations 4
2. Protective Gear 4
3. Radioactivity and Explosivity 5
4. Sample Handling 5
5. Forbidden Practices 6
6. Health and Training 6
C. SAFETY PROCEDURES FOR FIELD EVALUATIONS OF HAZARDOUS WASTE SITES 7
1. Information Review and Reconnaissance 7
2. Field Sampling 8
D. CLOTHING 10
E. LEAVING THE SITE 17
f. TRAINING 17
APPENDICES
A EVIDENCE AUDIT AND DOCUMENT CONTROL CHECKLISTS FOR HAZARDOUS WASTE SITE
INVESTIGATIONS
B CHECKLIST FOR INSPECTION
C ORGANIC AND INORGANIC POLLUTANTS FOR ANALYSIS IN HAZARDOUS WASTE SITE
INVESTIGATIONS
D LETTER OF UNDERSTANDING PROVIDED EPA BY DOT FOR ENVIRONMENTAL SAMPLES
E TRAINING OUTLINE
F POISON CONTROL CENTERS
FIGURES
Chain-of-Custody Record VIII-3
Sample Identification Tag X-3
Onsite Decontamination of Protective Clothing XII-11
Remote Removal of Barrel Bung XII-14
Remote Sampling XII-15
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I. PRELIMINARY ASSESSMENT
A. INTRODUCTION
The investigation of a potential or demonstrated environmental problem
at a waste disposal site is aimed at answering similar questions at all
stages (preliminary assessment, inspection, field investigation) of the
study. These can be divided into four basic areas:
What are the composition and characteristics of the wastes?
Are the wastes adequately immobilized or destroyed at the site?
By what routes can the wastes move off the site?
What effects could occur (or might have occurred) through the
discharge of waste?
In many cases, it will also be necessary to consider what steps are needed
to remedy the problem.
After a potential problem site has been identified, the first step is
to collect all readily available information prior to conducting a site
inspection. This is accomplished through telephone and personal contacts
with knowledgeable persons, file searches, and analysis of aerial photography.
The objectives are as follows:
1. Determine if an emergency exists;
2. Estimate potential severity of the problem and establish
priorities for further investigation;
3. Focus the inspection and field investigation efforts on the
proper areas;
4. Discover hazards to field personnel, allowing them to take proper
safety precautions;
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5. Incorporate whatever findings are available from previous studies
of the site and;
6. Develop an estimate of the kinds of resources needed to investigate
the problem.
This Chapter details the kinds of information needed and the sources
of information for accomplishing those objectives.
B. INITIAL CONTACTS
Once a problem has been identified, the original source of that infor-
mation, either private citizen or government official, should be asked for
names of all other persons who might have knowledge about the site in
question. If the contact is a private citizen, the names of anyone who
might be able to corroborate the report should be requested. When appro-
priate, witnesses should be asked to prepare affidavits in support of their
statements. If personal injury or property damage is claimed, ask for the
name and telephone number of the attending physician or insurance adjuster.
If the source of information is an employee of the facility under discussion,
it is advisable to inform that person of the employee protection provisions
of RCRA, Section 7001.
C. GOVERNMENT FILES
After receiving a report of a possible waste disposal problem, the
investigator should jxamine all available information in government files.
Within the EPA regional offices, contacts in the Toxic Substances, Drinking
Water, Solid Waste, and Enforcement Offices should be consulted for informa-
tion. State and local environmental agencies may have valuable information
regarding sites, disposal practices, and other technical data. In particular,
information on whether the operator has an NPDES* permit should be sought.
If the operator has applied for a permit, there may be considerable informa-
tion on the wastes disposed at the site and the engineering design of the
facility. If no NPDES permits are held by the facility, then demonstration
* National Pollutant Discharge Elimination System.
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of discharges to surface waters may suffice for initiating a full enforce-
ment investigation or enforcement action. In many cases, information may
be available from State inventories of surface impoundments under the Safe
Drinking Water Act (SDWA) or of open dumps under the the Resource Conserva-
tion and Recovery Act (RCRA). In some cases, the U.S. Geological Survey
(USGS) may have conducted investigations of groundwater pollution and found
that the source is a waste disposal facility. Thus, USGS should be consulted
for information on sites under study.
If the facility has applied for a State solid waste permit, a consider-
able amount of information may be available regarding geology, hydrology,
and soils. Records of site visits and State enforcement actions should be
requested. State water quality agencies may have data on ambient surface
water and groundwater quality. Precise geographical location of the facil-
ity (geographical coordinates in degrees, minutes, and seconds) is important
for obtaining aerial photography. In many cases the county registrar of
deeds will provide such information over the telephone; otherwise, they
will generally respond to a written request. The investigator should also
ask for highway direction to the site. Zoning or planning commissioners
may be able to provide detailed maps of the site and its environs.
D. ENVIRONMENTAL DATA
Geology, hydrology, climate and other environmental factors are keys
to evaluating the pollution potential of a waste management facility.
Sources of and uses for such information are described in the following
subsections.
1. Geology
Information on local bedrock types and depths may be important to an
investigation of groundwater pollution problems, particularly where pro-
ducing aquifers lie beneath the water table aquifer. Sedimentary strata
(limestones, sandstones, shales) tend to channel groundwater flows along
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bedding planes; flow directions may be determined by the dip in the strata.
Where limestones are present in humid climates, solution channels may
develop allowing very rapid transport of pollutants over long distances
with little attenuation. Igneous and metamorphic bedrock (granites,
diorite, marble, quartzite, slate, gneiss, schist, etc.) may permit rapid
transport of polluted groundwater along fracture zones. Depth to bedrock
may be an important factor in selecting the appropriate type of remedial
action. Sources of this information include USGS reports and files, State
geological survey records, and local well driller logs.
2. Soils and Overburden
Soil and overburden types and permeabilities are very important
factors in evaluating the pollution potential of a waste management site.
Highly permeable soils (i.e., 10~3 cm/sec) may permit rapid migration of
pollutants, both vertically and horizontally, away from containment areas.
Rates of attenuation of pollutants in the unsaturated zone and underlying
aquifers are a function of soil chemistry and physical characteristics. It
is often important to ascertain the availability and quality of local clays
in considering possible remedial measures. The USGS, the Soil Conservation
Service, Agricultural Extension Service Agents, State geological survey
records, local well drillers, and local construction engineering companies
may be able to supply such information.
3. Climate
Local climate may also be an important factor in the pollution poten-
tial of a facility. Mean values for precipitation, evaporation and ivapor-
transpiration, and estimated infiltration can be used as general indicators
of the potential for groundwater pollution at a site. In many cases ground-
water or surface water pollution has occurred due to unusally high amounts
of precipitation. Even in an arid region where little or no recharge to
groundwaters generally occurs, an extremely wet year may create a serious
pollution problem. In evaluating the pollution potential of a "non-discharg-
ing" surface impoundment, it may be expedient to calculate a mass balance
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to determine if seepage through the walls or bottom is occurring. For
these purposes, the investigator would find it necessary to consult monthly
or seasonal precipitation and evaporation (or temperature) records during
the period of operation. The maximum recorded or estimated rainfall for a
given period of time (24/48-hour or monthly) may be an important factor in
evaluating the amount of freeboard needed in a surface impoundment. Where
airborne contaminants may be a problem, it will be important to determine
prevailing wind patterns and velocities. Such information can be obtained
through:
National Climatic Center
Department of Commerce
Federal Building
Ashville, North Carolina 28801
FTS 672-0683
(204) 258-2850
4. Geohydrology
In most cases, the investigator will need to acquire information on
the groundwater hydrology of a site and its environs. Depths to the water
table and any underlying aquifers, characteristics of confining layers,
piezometric surfaces (heads) of confined aquifers, direction(s) of flow,
existence of perched aquifers, and areas of interchange with surface waters
will be vital in evaluating the pollution potential of a facility. Ground-
water use in the area of the site should be thoroughly investigated to find
the depths of local wells, pumping rates, and the ways in which the water
is utilized. Sources of such information include the USGS, State geolorical
surveys, local well drillers, and State and local water resources boards.
A list of all State and local cooperating offices is available from the
USGS Water Resources Division i Reston, Virginia 22092. This list has
also been distributed to EPA Regional Offices. Water quality data, in-
cluding surface waters, is available through the USGS via their automated
NAWDEX system; for further information: telephone FTS: 928-6081 or (703)
860-6031.
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5. Surface Waters
The locations of all surface waters or dry stream beds in the area
should be investigated, and surface gradients on an around the site should
be determined. If surface waters down-gradient from the site are used for
drinking, recreation, fishing, irrigation, or livestock watering, this
should be noted. Where pollution of surface waters is suspected, it is
advisable to collect available base-line water quality data and stream flow
rates. In addition, it may be necessary to get information on all NPDES
permitted discharges by other operations in the vicinity of the site under
investigation. Topographic maps, aerial photography, and the NAWDEX systems
(see above) of USGS can provide useful information on surface waters.
6. Sensitive Environments
The investigator also needs to determine if the site is located in a
sensitive environment; e.g., in a floodplain, inside or adjacent to wetlands,
in a recharge zone of a sole source aquifer, in an area of karst topography,
or in a fault zone. In general, the potential for long-term environmental
disruption, if a discharge of hazardous wastes should occur, must be deter-
mined.
E. SITE ENVIRONS
Before conducting a site visit, it is advisable to gather some infor-
mation about the area surrounding the site. For the safety of those con-
ducting a site visit, the names and telephone numbers of police and fire
department responsible for that area should be noted. Furthermore, these
departments may provide information on past incidents at the site under
investigation. Sources of drinking water supplies in the area, both public
and private, should be noted. In addition, the investigator should check
to see what analyses have been performed on these water supplies and request
copies of all data. It may be important to find out what kind of treatment
system is used by the public water supplier. If the area surrounding the
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site is serviced by a public water supply, it is important to determine the
locations of water mains these could be conduits for entry of polluted
groundwater into the public water system. Likewise, information should be
gathered on the local sewer and storm drain systems to determine possible
infiltration or illegal discharge points. The most important characteris-
tics for determining the hazards in a given situation are population densi-
ties and distances to residences, schools, commercial buildings and any
other facilities in the vicinity of the waste site which may be occupied.
The investigator should also try to determine if any flammables or explo-
sives, such as liquified natural gas, are stored near the site. General
land use of the environs should be studied; if crops or livestock are
raised in the area the types should be noted. It may be important to seek
information on the wildlife or aquatic life in the area.
F. HAZARDOUS WASTE MANAGEMENT INFORMATION
If no information on wastes is available from government sources, it
may be necessary to proceed with the site inspection and field investiga-
tions without benefit of background information. However, in some cases,
it may be possible to form a hypothesis on the kinds of waste present at
the facility. Where a landfill contains both municipal and industrial
wastes, it is probable that much of the waste comes from the local indus-
tries. If approximate dates of operation of the facility are known, local
officials or the Chamber of Commerce may be able to provide information on
industries operating locally during that time period. In the case of an
onsite (at the generator's site) facility, it may be possible to determine
the type of waste present. Information on the composition of waste streams
associated with various industrial processes may be obtained from the EPA
Hazardous and Industrial Waste Division of the Office of Solid Waste in
Washington, D.C. Other sources are the EPA Assessment of Industrial Hazard-
ous Waste Practices (14 industries covered) and Pollution Control in the
Organic Chemical Industry (Noyes Data Corporation). In gathering such
information, the "Hazardous Waste Site Survey Record" and the "Hazardous
Waste Site Identification and Preliminary Assessment" forms should serve as
models for the kinds of questions to be asked.
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G. AERIAL PHOTOGRAPHY
In most instances, aerial photography is an effective and economical
tool for gathering information on waste management sites. In general,
aerial photography should be acquired.
This should be done during the preliminary stages of an investigation
for the following reasons:
A considerable amount of information can be collected and
documented with a minimal amount of effort.
Air photos may pinpoint the locations of spills, discharges,
leaks, or damage, allowing inspectors to plan their observation
and sampling efforts.
Maps of the site and its environs can be prepared prior to
inspection.
Obvious hazards to inspectors may be observed without exposing
personnel to harm.
Some data may only be available through the use of air photos. Examples
would include information on past waste disposal practices (using archival
imagery) and reconnaissance of facility observations not directly visible
or accessible from the ground. The following are examples of information
available through analysis of air photos: facility design and operation;
surface drainage; spills; leaking containers; incinerator plumes; container
inventories, surface leachate springs from landfills; seepage at dikes;
surface water discharge points and plumes; vegetation damage; pipelines;
and land use of the site environs.
Information on all aspects of aerial photography and photo interpreta-
tion is available through the following EPA offices:
Environmental Monitoring Systems Laboratory (EMSL)
P.O. box 15027
Las Vegas, Nevada 89114
(FTS) 595-2969
or
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Environmental Photographic Interpretation Center (EPIC)
P.O. Box 1587
Vint Hill Farm Station
Warrenton, Virginia 22186
(FTS) 557-3100
or
National Enforcement Investigations Center (NEIC)
Building 53, Box 25227
Denver, Colorado 80225
(FTS) 234-4650
The first two offices also maintain their own photography archives and have
access to historical imagery not generally available. They can provide full
remote sensing services to governmental organizations.
1. Archival Imagery
Federal agencies have been using aerial photography for a variety of
purposes for several decades. In most cases, photography less than five
years old will be available for a given site, however, frequently the scale
will be too small to observe details of the site without considerable
magnification of the imagery. In cases where it is important to gather
information on the locations, area! extent, and historical development of
facility operations (e.g., the size and locations of old landfill cells);
archival photography can prove invaluable.
Archival photographs are available from the following sources:
National Cartographic Information Center
U.S. Geological Survey
Reston, Virginia
and
EROS Data Center
Sioux Falls, South Dakota
Photographs taken prior to 1950 are available from the National Archives.
Generally, the requester must specify the geographical coordinates (latitude
and longitude) of the site when requesting photography. Information on the
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photography available for a given site can usually be obtained in less than
30 minutes. Standard orders for copies of photographs are processed within
six weeks; priority requests require approximately one week at a signifi-
cantly higher cost. Photo interpretation is available through the EPA,
EMSL, EPIC, and NEIC.
2. Aerial Reconnaissance Techniques
There are five basic types of aerial reconnaissance techniques:
Light Aircraft
1. Observer Only
2. Hand-held Cameras
3. Enviro-pod
Reconnaissance Aircraft
4. Standard Aerial Photography
5. Special Remote Sensing Techniques
The simplest techniques use a light aircraft, available for charter at
many general aviation airports. If photographs for permanent records are
not needed, the aerial reconnaissance can be made by the inspector flying
as an observer. In most cases, however, photographs will be desirable.
These can be obtained economically by hand-held cameras. For small sites,
the inspector can usually serve as observer and photographer. For complex
sites two people are recommended, one serving as an observer and recorder
and the other as photographer. All photographs and visual observations
should be documented in a bound log book.
By making repeated passes over a site from different directions and at
different altitudes, it is possible to obtain a wide variety of photographs
with hand-held cameras. In general, these will be oblique (on a slant)
photographs, although nearly vertical photographs are possible. Oblique
photographs are very useful in showing overall details of a site, as well
as small details of specific facilities such as stacks of drums, spills,
tanks and treatment units. A disadvantage of hand-held photographs is that
it is nearly impossible to produce photographs with uniform scale across
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the image so that they can be used for mapping. Vertical mapping cameras
are necessary to produce uniform scale images.
The simplest technique for obtaining high quality photographs is the
Enviro-Pod. This is a capsule containing two 70 mm cameras that can be
attached to the underside of a light aircraft. One camera takes vertical
photographs and the other, forward oblique photographs. The unit, which is
portable and can be transported by airlines as baggage, produces high
quality photographs at a cost only slightly higher than the hand-held
camera. A disadvantage is that the Enviro-Pod is currently only certified
for attachment to a Cessna model 172M aircraft.
The best quality mapping photographs are produced by standard aerial
photography procedures, using specially equipped reconnaissance aircraft
with vertically mounted cameras. This technique produces most of the
aerial photographs used by surveying and mapping firms, for production of
topographic maps, and by various government agencies. Most large metropol-
itan areas have commercial aerial photography services available.
Generally, aerial mapping color photographs are originally in the form
of positive transparencies (a 35 mm slide is a positive transparency).
They are in rolls that may vary in width from 70 mm to 9 inches. Mapping
cameras can record overlapping photographs, which allows stereo viewing.
Good film resolution provides acceptable detail on prints as large as 16 to
20 inches. Since the scale is nearly uniform across the print, the print
can be used for site mapping.
Note: Until resolution of the Dow vs. EPA case, EPA investigators
and contractor personnel must consult the EPA Regional Enforcement Director
Prior to initiation of aerial imagery projects.
3. Equipment
For typical light aircraft reconnaissance, the inspector can be equipped
with a good quality single lens reflex 35 mm camera of the type frequently
used by amateur photographers. It should have interchangeable lenses and
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through-the-lens light metering. A telephoto lens is also desirable. A
standard 135 mm telephoto lens is the most economical and desirable single
lens. A more expensive but more versatile lens is a zoom telephoto with
variable focal lengths in the range of 70 to 210 mm. Typical costs of a
basic outfit are in the range of $400 to $800. Field experience with
hand-held 35 mm cameras suggests that the resolution of the photographs is
generally inadequate for use as evidence in enforcement cases.
A professional quality 70 mm camera provides greater flexibility in
the types of photographs than can be taken with a hand-held camera. The
larger film and better quality lenses provide image quality that allows
large prints to be made with excellent detail. The camera should be
equipped with several different length lenses and several film magazines to
allow quick film switching or loading. Cost of a basic outfit of this type
is in the range of $5,000.
The Enviro-Pod is available from the EMSL-LV field station (EPIC) at
Vint Hill, Virginia, at a basic cost of $3,500. Cameras are furnished by
Vint Hill. Eight EPA regional offices have purchased the units, and these
may be available for use on HWS investigations.
Light aircraft are available for charter at many general aviation
airports and most large commercial airports. A high-winged plane seating
three or four persons, such as the Cessna 172, is desirable to provide
adequate visibility and operating room. A pilot familiar with the area is
essential if the exact location of the site is unknown. The charter should
be made several days to weeks in advance to guarantee availability. If the
Enviro-Pod is to be used, this should be discussed in detail with the pilot
in advance.
4. Management of Aerial Reconnaissance
As previously indicated, aerial reconnaissance should be conducted in
the early stages of an investigation whenever possible. Exceptions to this
are situations where an immediate inspection is necessary or considerable
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information about the site is already available and the data indicates that
aerial photography would not enhance the safety or effectiveness of a site
inspection. Under these circumstances, the persons conducting an inspection
may choose to photograph the site in conjunction with the field inspection
using hand-held cameras.
A preferred approach is to photograph a number of sites on a single
mission. This minimizes costs and work in most cases. Generally, the
Enviro-Pod camera system will provide the best results relative to costs
using this approach. Costs for photography of six or more sites per day
will average between $20 to $50 per site, excluding in-house labor but
including aircraft charter and materials (film and printing).
Where a more sophisticated approach is indicated, the costs of typical
aerial mapping photography range from $500 to $2,000 per site, depending on
proximity to a contractor's base location, number of sites photographed on
one flight, and size of the site. Special remote sensing techniques avail-
able at NEIC, EMSL-LV, EPIC, and a few commercial firms can provide addi-
tional data on environmental effects of disposal sites. These techniques
include thermal infrared sensors and multi-band photography, and costs
range from $500 to several thousand dollars per site. Their use can best
be evaluated on a case-by-case basis through consultation with EMSL-LV,
EPIC, or NEIC.
Note: Until resolution of the Dow vs. EPA case, EPA investigators and
contractor personnel must consult the EPA Regional Enforcement Director
prior to initiation of aerial imagery projects.
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II. INITIAL EVALUATION OF DATA
A. INTRODUCTION
The initial evaluation of information concerning a site should be
performed after completion of the preliminary assessment. The purposes for
this initial evaluation are to determine the following:
the existance (or nonexistance) of a potential hazardous waste
problem;
the apparent seriousness of the problem and the priority for
further investigation or action;
the type of action or investigation appropriate to the situation.
This Section describes an approach to evaluating the potential hazards
at a waste disposal site and the available options for action.
B. PARTICIPANTS
Evaluation of the data by a team of specialists is desirable. Par-
ticipants with some or all of the following professional and technical
skills should be included in the process as appropriate: an environmental
engineer (environmental, sanitary, chemical or industrial engineer), geohydro-
logist, chemist, and an attorney are recommended. Personnel with skills in
assessing of health effects of exposure to toxic or hazardous substances,
engineering personnel wix.h the ability to assess appropriate remedies of
hazardous waste disposal sites, and biologists trained and experienced in
bioassay techniques (static and flow-through) may be needed.
C. DATA REQUIREMENTS
The data needed to evaluate the pollution potential of a waste manage-
ment site can be roughly organized into four groups, presented in Table II-l.
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"Waste characteristics" refers to those factors which describe the hazardous
nature of the substances involved, the mobility of the materials, and their
persistence in the environment. To evaluate "Waste Management" one must
answer the question of whether the materials are adequately isolated and
contained or destroyed at the site. "Pathways" describes the possible
routes of movement of materials offsite and may be considered as a function
of time. "Receptors" refers to the sensitivity of the site environs to
pollution. The components listed under each major heading represent a
relatively limited amount of information; if other information is available
this should be factored into any decisions reached. In some instances not
all the needed information will be available following the preliminary
assessment. Thus, the site inspection and field investigation efforts
should be focused on acquiring the missing information.
D. EVALUATION OF POLLUTION POTENTIAL
In evaluating the information on a specific waste disposal site, the
problem must be broken down into the various types of pollution or health
problems, i.e., groundwater, surface water, air, direct contact, and fire/
explosion. Under each item on Table II-l there is a key to relate that
item to a problem. The pollution potential for each problem type should be
evaluated separately on the basis of the relevant factors.
A list of major factors for evaluating groundwater pollution potential is
given below as an example:
WASTE CHARACTERISTICS WASTE MANAGEMENT
toxicity presence of leachate
infectivity collection system
persistence presence of liners
radioactivity condition of waste containers
quantity of wastes
solubility
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Table II-l
DATA REQUIRED FOR EVALUATION
WASTE CHARACTERISTICS
toxicity (Sax toxicity)
- l,g,s,a,d
Ignitability (flash point or
NFPA number) - f,l,a
reactivity - l,a,d,g
corrosivity - 1,d
infectivity - l,g,s,a,d
persistence - l,g,s,a
radioactivity - l,g,s,a,d,
quantity of waste - l,g,s,a
solubility - 1,a,d
volatility - 1,a,d
viscosity - 1,s
PATHWAYS
depth to groundwater - g
soil permeability - g
bedrock permeability - g
proximity to surface water body - s
net precipitation - g,s
soil thickness - g
evidence of groundwater
contamination - g
evidence of air contamination - a
evidence of land contamination - 1
WASTE MANAGEMENT
presence of leachate/presence runoff
collection and treatment system - l,s,g
presence of liners - g
site security - d,f
presence of incompatible wastes - a,d,f
condition of containers - l,g,s,a,d,f
danger of fire or explosion due to
poor management practices - a,d,f
incinerator performance/pollution
control devices - a
RECEPTORS
population density - l,g,s,a,d
proximity to surface drinking water
supply - s
proximity to drinking water wells - g
proximity to nearest non-site related
building - 1,a,d,f
zoning/land-use of adjacent area - l,a,d,f
zoning/land-use of adjacent area - l,a,d,f
endangered species or critical environ-
ments potentially effected - l,g,s,a,d
Key: 1 = land contamination; g = groundwater; s = surface water;
a = air pollution; d = direct contact; f = fire/explosion.
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PATHWAYS RECEPTORS
depth to groundwater proximity to drinking water wells
soil permeability critical environment (karst,
bedrock permeability fault lines, etc.)
net precipitation population density
soil thickness
evidence of groundwater
contamination
E. SETTING PRIORITIES
One primary function of data evaluation is the setting of priorities
for further action or investigation. A numerical rating system, based on
the factors listed in Table II-l is under development and should be avail-
able in the immediate future. Under such a scheme each element would be
assigned a rating on an arbitrary scale (e.g., 0-10), and multiplied by a
weighting factor. The sum of such scores would give a relative numerical
rating of problem severity. Priorities for further investigation or action
should be based strictly on the evaluation of the threat to public health
and the environment.
F. AVAILABLE ACTIONS OR DISPOSITIONS
After completing the evaluation of pollution potential and priority
ranking, the appropriate action or disposition must be determined. These
range from "no action required" to "emergency response".
1. No Action Required
When the results of the evaluation indicate that the site has been
operated and closed properly, and if an inspection is not deemed necessary,
then a report should be prepared summarizing the information and conclusions.
If an inspection is made confirming the background information, the report
should include the results and conclusions of the inspection.
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2. Inspection Required
When the results of the evaluation indicate that a potential pollution
problem exists, an inspection or field investigation should be performed.
Scheduling for these activities should be based on priorities and available
resources.
3. Enforcement Action
In some cases preliminary data will indicate a violation of one or
more Federal statutes, or that action under Section 7003, Imminent Hazards,
of RCRA is appropriate. Under those circumstances, an immediate site
inspection is recommended.
4. Emergency Response
Situations in which emergency actions are appropriate may be encoun-
tered at any stage of an investigation. Under those circumstances, the FIT
Leader must immediately contact the Deputy Project Officer. Some examples
of emergency situations are listed below:
any discharge or threat of discharge of a substance listed
in a reportable quantity to surface waters of the U.S. as
defined under "Navigable Waters of the United States", in
the Clean Water Act; see 40 CFR Part 117, Federal Register,
Vol. 44, No. 169, August 29, 1979;
a situation where there is a potential need for evacuation
of an area;
a release or potential release of a toxic vapor or gas;
a possible declared National Disaster (as defined in the
Federal Emergency Management Act).
The Oil and Hazardous Materials Coordinator will then contact other
Federal Agencies, State Agencies, and local government to evaluate the
situation or effect the appropriate remedies. The Uncontrolled Hazardous
Waste Site Coordinator will provide technical support to the Oil and Hazar-
dous Materials Coordinator where emergency action appears appropriate.
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5. Notification of the Public
If the data and background information indicates an immediate hazard
to the public, then the Regional Office should notify the public affected.
The hazard should be verified immediately with a reconnaisance inspection
of the site. Contact with the news media should be coordinated by the
Regional Office.
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III. ADMINISTRATIVE PROCEDURES FOR SITE INSPECTIONS
AND FIELD INVESTIGATIONS
A. WORK ETHICS
1. Professional Stature
Personnel are expected to perform their duties in a professional and
responsible manner. Whether EPA employees or contractor personnel, persons
representing EPA in the conduct of HWS investigations must:
a. Develop and report the facts of an investigation completely,
accurately, and objectively.
b. Conduct themselves at all times in accordance with the regulations
in the EPA handbook Responsibilities and Conduct for EPA Employees
(undated; available in all EPA Offices).
c. Avoid, in the course of an investigation, any act or failure to
act which could be considered to have been motivated by reason of
personal or private gain.
d. Make a continuing effort to improve their professional knowledge
and technical skills.
2. Conflicts of Interest
A conflict of interest may exist whenever an EPA employee has a personal
or private interest in a matter which is related to his official duties and
responsibilities. It is important to avoid even the appearance of a conflict
of interest because the appearance of a conflict damages the integrity of
the agency and its employees in the eyes of the public. All employees
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must, therefore, be constantly aware of situations which are, or give the
appearance of, conflicts of interest when dealing with others in or outside
of the government. For a detailed discussion of the situations and/or
activities which may result in conflict of interest, personnel are directed
to the publication Responsibilities and Conduct for EPA Employees (FR.,
Vol. 38, No. 73).
3. Attire
Good public relations and common sense require that personnel dress
appropriately for field inspections. When conducting an offsite reconnais-
sance where hazards should be minimal, contact with the public will occur;
therefore, regional policy relative to proper attire should be followed.
Onsite inspections will require that personnel be protected from unknown
hazards or toxic materials. Required protective clothing and breathing
apparatus are described in SECTION VI. PROJECT PLAN DEVELOPMENT.
4. Public Relations
It is important that cooperation be obtained and good working rela-
tionships be established when working with the public. This can best be
accomplished by using diplomacy and tact. Even a hostile person should be
treated with courtesy and respect. Personnel should not speak derogatorily
of any person, regulatory agency, manufacturer, or industrial product. All
information acquired in the course of duty is for official use only.
5. Gifts> Gratuities, Favors, Luncheons, Etc.
An EPA employee is forbidden to solicit or accept any gift, gratuity,
entertainment (including meals), favors, loans, or any other thing of
monetary value from any person, corporation, or group which has a contrac-
tual or financial relationship with EPA, which has interests that may be
substantially affected by such employee's official actions, or which con-
ducts operations regulated by EPA. Acceptance of food and refreshments of
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nominal value, such as luncheon during a plant tour where the arrangements
are consistent with the transaction of official business, is an exception.
6. Attempted Bribery
Money in varying amounts may be offered by persons whose activities
are being investigated. Offers are usually made by people unfamiliar with
EPA rules and regulations. Other offers may be blatant attempts to white-wash
a serious violation or condition, or to cause the withholding of damaging
information or observations. EPA, and contractor personnel representing
EPA, must:
a. Ask "What is this for?" if offered something of value.
b. Explain politely, if the offer is repeated, that both parties to
such transactions may be guilty of violating the Federal statutes.
c. Not accept money or goods of any kind.
d. Immediately report the incident in detail to their supervisor.
B. DISCLOSURE OF OFFICIAL INFORMATION
1. Requests for Information
a. EPA Policy
EPA has an "open-door" policy on releasing information to the publ'c.
It aims to make information about EPA and its work available, freely and
equally, to all interested individuals, groups, and organizations. This
policy, however, does not extend to information relating to potential
enforcement actions, to evidence, or to confidential data submitted by a
private party. When information is requested, personnel should immediately
notify their supervisor and/or legal counsel.
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b. Media Contacts
Personnel should cooperate with representatives of the press, other
communications media, and interested groups. Information concerning the
Agency's responsibility for inspections and investigative activities can be
given. Questions concerning investigations of hazardous waste sites and
enforcement policy should be referred to the Regional Enforcement Director
for response.
2. Requests by State and Local Cooperating Officials
State and local regulatory officials, cooperating with EPA in the
reconnaissance and investigations are permitted access to official informa-
tion, subject to approval by the appropriate EPA Regional Official. Although
personnel are not responsible for answering requests for the release of
confidential information, they should keep informed as to who is permitted
access to such information. Personnel should consult with their supervisor
immediately after receiving such a request.
3. Confidential Information
a. Confidential information can only be obtained and used by
authorized persons. If a request of confidentiality is made
by facility personnel during an inspection, the appropriate
DPO should be immediately notified to determine the necessity
for the information as well as the course of action.
b. All confidential information received shall be marked as
such and placed in a locked filing cabinet or safe.
i. Only personnel authorized by the Regional Administrator,
Division Director, or Branch Chief shall be allowed
access to the file.
ii. Copies of information marked "Confidential" should not
be made unless authorized in writing by the Regional
Administrator, Division Director, or Branch Chief.
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c. Requests for access to confidential information by any
member of the public, or a state, local, or Federal agency
shall be handled according to the procedures contained in
the Freedom of Information Act Regulations (40 CFR 2). All
such requests shall be referred to the responsible Regional
organizational unit.
C. DOCUMENT CONTROL
1. Serialized Documents
The purpose of a document control program is to assure that all
documents for a specific project are accounted for when the project is
completed. This program includes a serialized document numbering
system, a document inventory procedure, and a central filing system.
Accountable documents include items such as logbooks, field data
record, correspondence, sample tags, graphs, chain-of-custody records,
bench cards, analytical records and photos. Each document should bear
a serialized number and be listed, with the number, in a project
document inventory assembled at the project's completion.
All field logbooks, field data records, field laboratory logbooks,
sample tags and Chain-of-Custody records are numbered and assigned to
the FIT Leader for appropriate distribution and accountability .
2- Project Logbooks
The logbook of the team leader will document the transfer of other
logbooks to individuals who have been designated to perform specific tasks
on the project. All pertinent information should be recorded in these
logbooks from the time each individual is assigned to the project until the
project is completed.
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Logbook entries should be dated, legible, and contain accurate and
inclusive documentation of an individual's project activities. The logbook
must contain only facts and observations. Language should be objective,
factual, and free of personal feelings or other terminology which might
prove inappropriate. Entries made by individuals other than the person to
whom the logbook was assigned are dated and signed by the individual making
the entry.
Where appropriate, serialized Field Data Records (FDRs in the form of
individual sheets or bound logbooks) are maintained for each project. The
project leader numbers the FDRs with the appropriate project code. All
insite measurements and field observations are recorded in the FDRs with
all pertinent information necessary to explain and reconstruct sampling
operations. Each page of an FDR is dated and signed by all individuals
making entries on the page.
All project logbooks and FDRs are to be turned over to the project
leader and placed in the central file when a project has been concluded.
3. Sample Identification Documents
Assignment of all serialized sample tags to field personnel is re-
corded in the project leader's logbook. At no time are any sample tags to
be discarded. Immediately upon discovery, tags that are lost, voided or
damaged, or transferred on split samples, are noted in the appropriate FDR
or logbook.
4. Chain-of-Custody Records
All serialized Chain-of-Custody Records are assigned and accounted for
in a manner similar to that for the sample tags, as described above. When
samples are transferred from a field sampler or courier to field laboratory
personnel, the analyst, after signing, retains the original custody record
and files it in a safe place. The copy of the custody record is returned
to the project leader. A similar procedure is followed when dispatching
samples via commercial carrier, except that the original accompanies the
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shipment and is signed and retained by the receiving laboratory sample
custodian. Chain-of-Custody Procedures are discussed in detail in
SECTION VIII.
5. Evidence Audit
Adherence to chain-of-custody and document control procedures will be
periodically evaluated by an evidence audit. Such audits may be conducted
by Regional or Headquarters' personnel, or by the Contractor Evidence Audit
Team (CEAT) which is located in Denver, Colorado. Evidence audits will be
structured around the "Evidence Evaluation Checklist for Hazardous Waste
Site Investigations," and "Document Control Checklist for Hazardous Waste
Site Investigations" [Appendix A].
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IV. OFFSITE RECONNAISSANCE
A. PREPARATION FOR INSPECTION
Certain documents and data should be obtained and reviewed prior to
performing a reconnaissance or inspection. Review of the available back-
ground information is essential and is a logical first step in an investi-
gation. The scope and extent of the background information will vary with
the complexity of the project. In many instances, it will be necessary to
visit EPA Headquarters or Regional Offices, State, local or other Federal
agencies, site owners, generator and transporter offices to review and
obtain copies of pertinent file information. Examples of the types of
information which may be obtained during a background review include the
applicable laws and regulations, the status of current and pending litiga-
tion related to the project, Regional Office legal strategy, copies of
relevant permits and compliance schedules, past reports and data, types and
amounts of wastes disposed, methods of disposal or storage, sources of wastes,
geology/hydrogeology of the area, history of incidents, ownership structure,
and maps, sketches, or photographs of the area.
It is emphasized that the primary purpose of the review stage is to
familiarize personnel with the background of the work. Information obtained
during the review will often be used later in the conduct of the project,
and in preparing the report. Therefore, it is important to conduct the
most thorough and accurate review possible, early in the project development.
The background review may continue throughout the project to obtain needed
information.
B. INSPECTION
The purpose of the offsite reconnaissance is to obtain information,
data, and in some cases, to assess the magnitude of the problem and to
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develop the Project Plan for a field investigation. Data from the samples
and observations may provide evidence for immediate legal action, preclu-
ding the need for an intensive field investigation. Data collected and
observations noted may be used in the government's case; therefore, all
documents, notes and samples must conform to Chain-of-Custody and Document
Control requirements (see SECTION VIII). [Checklists for Evidence Audit
and Document Control are in Appendix A. Checklist for Inspection is in
Appendix B.]
1. Areas of Concern
The two primary items which should be investigated are actual and
potential pathways for hazardous or toxic material to migrate offsite and
the population at risk or environmental damage which may or has occurred.
Migration from the site can occur via runoff incidents, spills, groundwater
vectors, and airborne mechanisms. Obvious evidence includes vegetation
damage and structural deterioration and discoloration.
Migration from the site may also occur through indirect methods, the
most prevalent of which is uncontrolled human or animal contact onsite.
The access to the site must be investigated to determine the extent of
access control.
2. Sample Requirements
Three classes of samples are defined for purposes of hazardous waste
site investigations by EPA personnel or by personnel under contract to EPA.
These classifications and the associated labeling and shipping instruction^
[see SECTION X] are tentative, pending approval by the Department of Trans-
portation, and may be revised. The three classes are:
a. Environmental Samples (discussed below).
b. Hazardous Waste Site Samples Excluding Closed Container Samples
(discussed in SECTION VI).
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c. Hazardous Waste Site Samples from Closed Containers (discussed in
SECTION VI).
Environmental samples include surface runoff, groundwater, soil, sedi-
ment, biological and ambient air samples obtained offsite. In general, the
testing procedures and shipping requirements are designed for samples con-
taining less than 10 ppm of any single organic pollutant and less than 100
ppm of any single inorganic pollutant although the samples may well exceed
these concentrations. Investigative team leaders must exercise judgment,
such that if samples are suspected of containing substantially higher con-
centrations, they be treated as Hazardous Samples (see SECTION VI). Environ-
mental samples may be analyzed in approved EPA and contractor laboratories.
Project Officer or Regional hazardous waste program coordinator should
be notified so that drums can be moved by trained personnel.
Shipping and labeling of hazardous waste site samples is covered in SECTION X.
C. PHOTOGRAPHS
Photographs are important in documenting the cause and effect relation-
ship of hazardous materials migrating offsite, especially in the areas of
environmental damage and potential exposure to the public. Whenever samples
are collected, photographs should be taken to verify the written description
in the field logbook. In all cases where a photograph is taken, the follow-
ing information must be written in the logbook:
1. time, date, location and, if appropriate, weather conditions;
2. complete description or identification of the subject in the
photograph and reason why the photograph was taken;
3. the sequential number of the photograph and the file roll number;
4. name of person taking photograph.
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When the photographs are developed, transpose the information recorded
in the field logbook onto the back of the photographs. Photographs and
negatives are part of the project files and must be accounted for under
Document Control procedures.
D. SKETCH MAPS
Wherever possible, a map should be drawn prior to conducting the off-
site portion of an inspection using aerial photographs. If aerial photo-
graphy is not available, then a sketch map of the site environs must be
drawn in the field. The map should include all residences and other build-
ings in the vicinity of the site, drainage ditches, surface waters, known
water wells, general land use patterns, roads, and reference points (e.g.,
telephone poles and their serial numbers). All sampling points must be
noted on the map.
E. EXPOSED SOILS AND ROCKS
Frequently subsurface materials are exposed through stream erosion,
road cuts, and construction grading. If detailed soils, overburden and
bedrock studies of the site are not available, exposed materials should be
noted and described on sketch maps.
The description should include soil type (sand and clay content), bed-
rock types, depths, stratification, dip and evidence of fractures or fault
lines. A rough measure of soil elasticity and permeability can be obtained
by compressing a ball of wet soil in one's hands; highly permeable materials
will crumble instead of sticking together. It may be advisable to collect
samples of soils and rock for laboratory analysis of physical characteristics.
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V. SITE INSPECTION
A. PREPARATION FOR INSPECTION
As in the case with offsite inspections, extensive background review
is necessary to develop the scope of the investigation and to familiarize
personnel with available information and legal ramifications. The documents
and information which should be reviewed are discussed in SECTION IV.
OFFSITE RECONNAISANCE. The site inspection may be concurrent with or
follow immediately after the offsite reconnaissance.
B. NOTIFICATION
The inspection personnel must notify the appropriate person at the
site to be inspected and obtain permission to enter the property; written
notification is not required under the Resource Conservation and Recovery
Act (RCRA). Advance notice of an inspection is not necessary; however, an
official may not be present at an inactive site and advance notification
may be necessary. If the appropriate official is present onsite, permis-
sion should be obtained when the inspector arrives. Advance notification
should be cleared through the Deputy Project Officer. If the ownership of
an abandoned site cannot be determined, the Regional Office should provide
guidance for notification and entry.
C. STRATEGY DEVELOPMENT
After the background data has been thoroughly reviewed, the strategy
of the inspection should be developed and reviewed with the appropriate
personnel. The site inspection should yield sufficient information to
provide the data to properly assess the situation. In many cases, data
collected from the site inspection will be sufficient for enforcement
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actions or emergency remedial actions. Therefore, it is emphasized that
the strategy must define the objective and the scope of the investigation.
The strategy is essentially a mini-project-plan.
The objectives may include:
1. Determination of the need for emergency response;
2. Determination of disposal practices and methods;
3. Compliance with Federal, State and local regulations;
4. Determination of the extent of contamination;
5. Amounts and locations of hazardous waste stored;
6. Potential for materials to migrate offsite;
7. Determination of access control;
8. Documentation or determination of imminent hazards;
9. Remedies to bring site into compliance;
10. Review of site records;
11. Inventory of drums or drum contents;
12. Mapping the site;
13. Safety procedures for field investigation;
14. Determination of potential sampling sites for field investigation;
15. Sample collection during inspection.
The scope of the work will delineate how the work is to be accomplished
It is essential that all personnel involved agree on the scope of work to
meet the objectives. During the inspection, some modifications in the
scope of work may be necessary when unforeseen circumstances arise.
D. SAFETY
During the initial inspection, safety precautions are paramount to all
other considerations because the inspector will not have adequate knowledge
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of site conditions. It is impossible to anticipate every hazard that could
arise; therefore, the inspector should use common sense, judgment and
experience.
Extensive protective clothing may or may not be required onsite;
however, disposable shoes or shoe covers must be worn to minimize contact.
The project leader has the responsibility to decide whether to use addi-
tional protective clothing and equipment.
Specific safety procedures and equipment requirements are discussed in
SECTION XII.
E. ENTRY
Section 3007 of RCRA states that officers and employees of the EPA or
State are authorized "to enter at reasonable times any establishment or
other place maintained by any person where hazardous wastes are generated,
stored, or disposed of; to inspect and obtain samples from any person of
any such wastes and samples of any containers or labeling for such waste".
The inspector must present credentials to the appropriate person at
the site which indicate that the inspector is a lawful representative of
the Administrator of the EPA or State and is authorized to perform the
inspection.
If denied entry after the appropriate procedural steps have been
followed, ask the person the reason for denying entry and record the re-
sponse in the field logbook along with the date, time and person's name.
All events surrounding the refused entry should be documented. Also, note
such observations about the appearance of the facility as are possible.
Then contact the Deputy Project Officer (DPO) at the Regional Office for
instructions.
Section 3007(a), of RCRA authorizes the Administrator or duly desig-
nated officials to "have access to, and to copy all records to such wastes".
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"For the purpose of developing or assisting in the development of any
regulations or enforcing the provisions of this title, such officers or
employees are authorized
"to enter at reasonable times any establishment or other
place maintained by any person where hazardous wastes are
generated, stored, treated, or disposed of";
"to inspect and obtain samples from any person of any such
wastes and samples of any containers or labeling for such
wastes".
Unless a warrant has been obtained, inspections must be made with the
consent of the owner/operator or other person so authorized. The following
are general rules concerning gaining consent.
Official agency credentials must be presented to the plant
representative authorized to give consent to an inspection
of the facility.
Consent must be given by the owner of the premises or the person
in charge of the premises at the time of the inspection. The
person giving consent will be presented with a statement to sign
acknowledging his consent which will be retained by the inspector
and included in his inspection report.
Consent must be secured without any behavior which could be
characterized as coercive (either in a verbal or physical sense),
such as threats of punitive action.
Consent to the inspection may be withdrawn at any time. That
segment of the inspection completed before the withdrawal of
consent remains valid. Withdrawal of consent is equivalent to
refused entry. A warrant should be secured to complete the
inspection.
Consent is not required for observation of things that are in
plain view, i.e., that a member of the public could be in a
position to observe, including observations made while on private
property in areas that are not closed to the public, e.g., matters
observed while the inspector presents his credentials. However,
a warrantless inspector's access to any portion of the facility
may be limited at the discretion of the owner of the facility.
Consent may be given with "conditions". When such "conditional"
consent is proposed, guidance should be sought from the DPO,
Enforcement Director, or other appropriate Regional authority,
prior to further activity. "Conditions" must be accurately
recorded.
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F. WARRANTS
In the event that entry is denied or consent withdrawn, the DPO must
be contacted. Normally the DPO will take the necessary actions to secure
three separate documents and submit them to the judge or magistrate in
order to obtain a warrant, viz:
1. Application for a Warrant
a. Statement of statutory and regulatory authority for the
warrant.
b. Identification of the site or establishment desired to be
inspected (and if possible the owner and/or operator of the
site).
c. Summary of the factual background for the warrant as stated
in the affidavit.
2. Affidavit
a. The affidavit should contain consecutively numbered para-
graphs which provide detailed descriptions of the facts
which support the issuance of a warrant.
b. The factual description should recite or incorporate the
specific probable cause or neutral administrative scheme
which led to the particular establishment's selection for
inspection.
c. The affidavit must be signed by a person with personal
knowledge of all the facts contained therein (in refused
entry proceedings, this person would most likely be the
inspector denied entry).
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d. An affidavit is a sworn statement which, therefore, must be
either notarized or personally sworn before the magistrate.
3. Draft Warrant
The contents of the warrant varies based on the type of warrant sought
(discussed below). The warrant should be submitted in such a form that
the judge or magistrate merely has to sign it to make it valid.
a. Civil specific probable cause warrant - based on some speci-
fic reason to believe that the requirements of the statute
or regulations are being violated. A civil warrant should
be sought only where it can be accurately stated in the
affidavit that the purpose of the inspection is to find and
remedy the statutory violation through noncriminal proceed-
ings.
Therefore, this warrant will be used when the inspection is
being made in response to the discovery of a potential or
actual violation from from another source, i.e., a citizen's
complaint or through the report screening process. If
possible, such a warrant should be obtained rather than a
neutral administrative inspection scheme warrant (discussed
below).
b. Jivil probable cause based on neutral administrative
inspection scheme, i.e., showing that "reasonable legisla-
tive or administrative standards for conducting an ...
inspection are satisfied with respect to a particular estab-
lishment". Marshall v. Barlow's Inc., U.S. ,
90 S. Ct. 1816 (1978). A warrant based on a neutral adminis-
trative process can be issued only if the facility for which
the warrant is sought was selected for inspection through
this neutral process. Therefore, this type of warrant may
be used for regularly scheduled inspections, e.g., annual
inspections, post closure inspections, etc.
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c. Criminal warrant - obtained when the purpose of the inspec-
tion is to gather evidence for a criminal prosecution in
accordance with Rule 41 of the Federal Rules of Criminal
Procedure. This type of warrant requires a specific showing
of probable cause to believe that evidence of a crime will
be discovered. It should be noted that, ordinarily, evid-
ence of a criminal violation discovered under a civil prob-
able cause warrant will be admissible in court (see Section
IV, Exhibit 1, p. 2). Therefore, this type of warrant will
be used only where the Agency is reasonably certain that
criminal violations have occurred.
4. Securing A Warrant
The following procedures should be followed in securing a warrant:
a. When an inspector is refused entry, the inspector should
leave the premises immediately.
b. The inspector should then immediately contact the designated
Regional Enforcement Attorney to inform him/her of the
situation. The inspector should at this time report any
exigent conditions; i.e., dumping, etc.
c. The Enforcement attorney will assist the inspector in the
preparation of the necessary documents.
d. The Enforcement attorney will arrange for a meeting with the
inspector and a U.S. Attorney. The inspector will bring a
copy of the appropriate draft warrant and affidavits.
e. The Enforcement attorney should inform the appropriate
Headquarters Enforcement attorney of any refusals to enter
and send a copy of all papers filed to Headquarters.
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V-8
f. The attorney will then secure the warrant and forward it to
the inspector; and/or the U.S. Marshall.
5. Inspections with a Warrant Should Comply With the Following:
a. Use of Warrant to Gain Entry
i. If there is a high probability that entry will be refused
even with a warrant or where there are threats of violence,
the inspector should be accompanied by a U.S. Marshall.
ii. The inspector should never himself attempt to make any
forceful entry of the establishment.
iii. If entry is refused to an inspector holding a warrant
but not accompanied by a U.S. Marshall, the inspector
should leave the establishment and inform the Deputy
Project Officer.
b. Conducting The Inspection
i. The inspection must be conducted strictly in accordance
with the warrant. If the warrant restricts the inspec-
tion to certain areas of the premises or to certain
records, those restrictions must be adhered to.
ii. If sampling is authorized, all procedures must be care-
fully followed including presentation of receipts for
all samples taken. The facility should also be informed
of its right to retain a portion of the samples obtained
by the inspector.
iii. If records or property are authorized to be taken, the
inspector must provide receipts and maintain an inven-
tory of all items removed from the premises.
6. Procedures to be Followed Upon Completion of the Inspection
i. Whoever executed the warrant must sign the Return-of-
Service form indicating on whom the warrant was served
and the date of service.
ii. The executed warrant must be submitted to the U.S.
Attorney for formal return to the issuing magistrate or
judge.
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V-9
iii. An inventory of any items which were taken from the
premises must be submitted to the court, and the inspec-
tor must be present to certify that the inventory is
accurate and complete.
G. INSPECTIONS
The purpose of the site inspection is to obtain information, data, and
in some cases samples, to assess the problem and to develop the project
plan for a field investigation. If samples are collected, established
sampling methods and Chain-of-Custody procedures must be followed. The
data from the samples may be used in enforcement actions.
The investigation must be thorough. Do not attempt to rush through
the inspection. The inspection is complete only when the objectives are
met and the inspector is satisfied that all data and information has been
collected to assess the situation. A careful review of the field notes is
required before leaving the area to ensure that the objectives have been
met.
Before the inspection is completed, the inspector should prepare a
sketch of the site, in the logbook if possible, locating fixed reference
points and locations of disposal and storage. If samples are collected,
the sample locations should be marked on the sketch. Inventory of visible
drums should be made where possible and also located on the sketch. The
contents of the drums will probably be different than the contents specified
on the labels; nevertheless, the labels may provide useful information.
In addition to the drum inventory, the inspector should check for
sewers, and drains, spills or liquid disposal, and evaluate the runoff
potential. The potential for fires, explosions, and other imminent hazards
should also be evaluated. If the situation requires an emergency response,
the Oil and Hazardous Materials Coordinator in the Regional Office should
be contacted immediately. Observations of soils and exposed subsurface
materials should be made (see SECTION IV., E.). However, care should be
taken not to handle materials which may be contaminated [see Appendix B
checklist].
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V-10
H. MAPPING THE SITE
After the site has been visually inspected to determine the extent of
the problem, a sketch of the onsite area should be prepared with fixed
landmarks (power poles, buildings, etc.) established as reference locations.
Distances should be determined by measurement with a survey tape or hand-held
range finder, or combination of both. The range finder should be calibrated
by the inspector before measurements are taken. The survey tape may be
contaminated by contact with material onsite; therefore, the tape should be
disposed of or decontaminated upon completion of the inspection. Photographs
of various areas of the site will aid in preparing the final sketch.
The sketch is important when preparing the Project Plan for a field
investigation. Potential sample locations can be identified and reviewed
prior to the investigation, and field participants can become familiar with
the layout.
I. SAMPLING
All samples collected onsite are to be considered "hazardous samples"
unless there is reliable data to the contrary. Hazardous samples are
further classified according to containment.
a. Unanalyzed Hazardous Waste Site Samples, Excluding
Closed Container Samples
All onsite samples should be considered to be potentially high-hazard,
and must be handled accordingly unless there is clear evidence to the con-
trary. Onsite samples (other than those from closed containers discussed
t
in paragraph b.) include contaminated soils or sludges, liquids from onsite
impoundments or pits, leachates, etc. In general the testing procedures
and shipping requirements are for samples containing concentrations of 10%,
or higher, of any material other than Poison A. Onsite samples are to be
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v-n
shipped to the EPA/NEIC high-hazard laboratory* for preparation and initial
screening and subsequent shipment to the EPA Regional laboratory wherein
the samples originated.
b. Unanalyzed Hazardous Waste Site Samples From
Closed Containers
All samples taken from closed containers on hazardous waste sites must
be considered to be high-hazard and potential Poison A, unless there is
clear evidence to the contrary. The shipping and testing procedures for
these samples are designed to accommodate concentrations to 100%. Shipping
procedures are those specified for Poison A and are detailed in SECTION X.
Samples from closed containers are to be shipped to the EPA NEIC high-hazard
laboratory for preparation, screening, and subsequent shipment to the
Regional Laboratory in the EPA Region of origin, for detailed analysis by
that laboratory.
J. PHOTOGRAPHS
During the onsite reconnaissance photographs should be taken at vari-
ous locations to document conditions and provide visual proof of potential
hazards. Photographs should be taken at every sampling location to verify
the written description in the field logbook. When photographs are taken,
the following information must be written in the field logbook and then
transposed onto the back of the photographs.
1. Time, date, location and, if appropriate, weather conditions.
2. Complete description or identification of the subject in the
photograph and why photograph was taken.
* EPA, National Enforcement Investigations Center
Bldg. 53, P. 0. Box 25227
Denver Federal Center
Denver Colorado 80225
Attention: DPO
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V-12
3. The sequential number of the photograph and the roll number.
4. Name of person taking photograph.
If slides are taken, the developed slide should be referenced to the
correct description in the field logbook. In some cases, processed slide
numbers will not correspond to the number on the camera.
When using self-contained breathing apparatus, the face mask will make
focusing the camera difficult; therefore, it is recommended that a Polaroid
camera (or equivalent camera) with automatic focus sensor be used.
Permission to take photographs should be obtained from the owner or
operator of the site. If permission is denied, request that the owner/
operator or representative take photographs, review them, and send copies.
Another approach is to give him/her the roll of film and ask that it be
developed and sent to the FIT leader after review by the owner or operator.
K. LEAVING THE FACILITY
When the inspection is completed, the inspector should notify the
appropriate person at the site. If samples have been collected, RCRA
requires that prior to leaving the site the owner, operator, or agent in
charge must be given a receipt describing the sample(s) and, if requested,
a portion of each sample equal in volume or weight to the portion retained.
If split samples are provided, a Chain-of-Custody sheet should be completed
for the split samples and signed by the owner or agent. If air samples are
to be split, duplicate samples must be collected; this must be determined
prior to sampling.
If safety clothes or equipment have become contaminated, disposal may
be done onsite, provided that the disposal is acceptable to the owner or
agent and can be done safely.
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V-13
If access to the site is controlled by fencing and locked gates, the
inspectors must lock the gates when leaving if the owner or agent is not
onsite. An entry should be made in the field logbook of the date and time
the gate was locked. If left unlocked, an entry should be made stating the
reason.
L. CHAIN-OF-CUSTODY PROCEDURE
After collection and identification, the samples are maintained under
the Chain-of-Custody procedures described in SECTION III. ADMINISTRATIVE
PROCEDURES FOR SITE INSPECTIONS AND FIELD INVESTIGATIONS.
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VI-1
VI. PROJECT PLAN DEVELOPMENT
A. PREPARATION AND DISTRIBUTION
After completing the site inspection, and after sufficient background
information has been obtained and evaluated, a comprehensive Project Plan
should be prepared based on specific objectives and tasks. The Project
Plan will be prepared by the FIT Leader unless otherwise specified by the
Deputy Project Officer. The Project Plan thoroughly details the course of
the project in terms of scope, logistics, and schedules. Among the items
addressed in the Project Plan are:
objectives of the project;
summary of background information;
survey methods, including sampling locations, procedures,
analytical requirements, quality control program, etc.;
personnel and equipment requirements;
safety program and equipment.
The importance of the Project Plan cannot be overemphasized. The Plan
delineates manpower, equipment needs and logistics. The need for additional
equipment, contract services, or personnel must be determined far enough in
advance so th?t these can be secured expeditiously.
The Project Plan should be provided to the field team, analytical
staff, Project Officer for the Contractor Evidence Audit Team (CEAT), and
other Regional personnel involved in the Project at least two weeks before
any specific field, laboratory, or consultant activity is undertaken. If
no comments on the Plan are received during this period, it is assumed that
the Plan can be implemented. During the conduct of the project, some
modifications to the Project Plan may be necessary because of changing
conditions. The Project Plan should contain a statement that it is subject
to change.
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VI-2
B. SAMPLE LOCATIONS
The samples should provide the data to meet the objectives of the
Project Plan. The locations, types, and numbers of samples to be collected
should be determined from the site inspections. The two categories of
samples which can be collected are environmental samples and hazardous
samples. Hazardous samples are further classified as "other than from
closed containers" and "from closed containers" [see SECTION V]. Environ-
mental samples contain concentrations of contaminants which have been
diluted due to runoff, mixing with surface and/or groundwaters, weathering,
etc. Judgment by the FIT Leader is essential in cases where runoff may
contain high concentrations of hazardous materials. If reason exists to
expect higher concentrations in runoff or other surface samples, they
should be declared "hazardous." Samples collected from spills, drums,
tanks, or other vessels are defined as hazardous samples because of the
anticipated high concentrations of contaminants.
The location of each sample source should be clearly defined in the
Project Plan along with the distances from permanent reference points and
special safety requirements. Wherever possible, sampling locations should
be documented by photographs. The sample location must be indicated on the
site sketch. For example:
Station 01: Environmental sample from onsite surface water
impoundment. Sample to be collected from first
6 inches of water. Sample location 140 ft north
and 30 ft east of power pole No. 87389.
Station 02: Hazardous sample from opened drum marked "sodium
nickel cyanide". Drum located inside the onsite
warehouse building, against the wall, 3 ft west of
the north entrance marked "E-2". Collect the sample
over entire depth with thief and place entire
sample into container. SCBA and full protective
clothing must be worn.
An exact description of the sample location is important because it may be
necessary to identify the sample and location in court. Mistakes or uncer-
tainties may damage the Government's case.
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VI-3
The number of samples collected during field investigation depends upon
type of hazardous waste site being investigated, laboratory constraints, and
shipment problems. The laboratory constraints will often be the limiting
factor. Ten onsite samples should provide sufficient data to document the
hazards although additional samples may be required.
C. WHAT TO SAMPLE
The collection of hazardous samples should be minimized to reduce the
exposures to field and laboratory personnel. If possible, samples should be
collected of the air, soil, and water. Field personnel should review the
sampling guidance in SECTION V. Appendix C provides a listing of organic
and inorganic parameters which will normally be considered in hazardous
waste site investigations. The types of samples to be collected are as
follows:
1- Soil
Collect from areas where dumping, spills, or leaks are apparent.
Because the soil may be saturated, the samples should be considered
hazardous.
2. Surface Water
The objective for monitoring surface impoundments is to assess the
potential for groundwater contamination and to determine possible hazards
if the water would leave the site due to overflow or dike failure. Another
objective is to determine if there are volatile organic compounds which could
be released to the ambient air.
Additional monitoring of surface water is required of seeps, spills,
surface leachates, etc., both on and offsite. If the site has NPDES* out-
falls, the discharges should be sampled. Rivers, streams, etc., should be
sampled upstream and downstream from the site.
* National Pollutant Discharge Elimination System
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VI-4
3. Groundwater
A primary objective for monitoring land disposal sites is to check for
potential leachate contamination. Where a potential exists, an assessment
of the leachate problem must be made to determine the control strategies.
The monitoring at the site should meet the objectives to establish the
presence of contaminants and the need for further monitoring.
The groundwater monitoring should provide the following information:
depth to the water table;
the natural rate and direction of flow;
the locations of potential or actual recharge and
discharge area;
the types and innerconnection of the aquifers;
groundwater use in the vicinity.
Personnel should consult "Procedures Manual for Ground Water Monitoring at
Solid Waste Disposal Facilities" EPA/530/SW-611, August 1977.
4. Air
Ambient air monitoring upwind and downwind from the site is important
as this is a primary vector for hazardous substance to leave the site and
affect the population. Onsite air monitoring is required to assess the
exposure and effects to workers.
D. SAMPLE CONTAINERS
The following containers have been found suitable for samples collected
during hazardous waste site investigations.
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VI-5
1. Environmental Samples
a. Water samples for organics analyses are collected in glass
bottles equipped with teflon-lined screw caps. Water supply
and other samples suspected of containing residual chlorine
should have 0.008% Na2S203 added. These water samples are
to be preserved by cooling with ice to 4°C.
Use of analytical contract laboratories requires that dupli-
cate samples be collected for purgeables. Samples for
purgeables are collected in 40 ml glass vials equipped with
teflon-backed silicon septum screw caps. Bottles and septa
are washed with detergent, rinsed with organics free water
and dried 1 hour at 105°C.
Samples for extractables are collected in 1-gallon or four
1-liter glass bottles with teflon-lined caps. New bottles
and liners are rinsed with methylene chloride and dried by
vacuum or other safe means until no solvent remains. Pre-
viously used bottles are washed with detergent, rinsed with
organics free water, dried and sol vent-rinsed as above.
b. Water samples for metals analysis are collected in 1-liter
high-density polyethylene bottles with solid polyethylene or
polyethylene-!ined caps. Bakelite caps are to be avoided.
The bottles are cleaned with dilute nitric acid and washed
well with distilled or deionized water. The samples are
preserved with nitric acid to below pH 2. Nitric acid con-
centration must not exceed 0.15% if the samole is to be
shipped via air cargo.
c. Water samples for ammonia and TOC analyses are collected in
500 ml polyethylene bottles. The samples are preserved with
sulfuric acid to below pH 2. The samples are then stored at
4°C.
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VI-6
d. Water samples for pH and fluoride analysis are collected
in 500 ml polyethylene bottles and are stored at 4°C.
e. Water samples for cyanide analysis are collected in
1-liter bottles and preserved with sodium hydroxide to
pH greater than 12. The samples are stored at 4°C.
f. Water samples for sulfide analysis are collected in
1-liter polyethylene bottles and 0.04% zinc acetate
is added.
g. Soil or sediment samples are collected in wide mouth glass
jars equipped with teflon-lined screw caps. Samples are
preserved by cooling with ice or refrigeration at 4°C.
Bottles are cleaned with detergent, rinsed with tap water
and organics-free water.
h. Biological samples are wrapped in aluminum foil and frozen.
i. Clean resin tubes for the collection of air samples will be
supplied by the agency or contractor laboratory doing the
analyses.
2. Unanalyzed Hazardous Waste Site Samples, Excluding
Closed Container Samples
Both liquid and solid samples should be placed in glass jars with
teflon-lined screw cap lids. Eight-ounce wide-mouth round jars of clear
glass with screw-neck finish 'Kerr AC 802 supplied by VWR Scientific,
Catalog #16194-06-3) are recommended. These bottles can be centrifuged to
2000 rpm which facilitates phase separation in the laboratory prior to
analysis.
These bottles are cleaned by washing with detergent, rinsing with tap
and deionized water, followed by a methanol rinse. The bottles are then
baked in an oven at 300°C for one hour.
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VI-7
3. Unanalyzed Hazardous Waste Site Samples From Closed Containers
Samples from closed containers must, unless clear evidence to the
contrary is present, be handled as if Poison A is present. Such samples
should be placed in 40 ml or similar* glass bottles with Teflon-lined caps
(Pierce #13075 bottles with #12722 teflon-backed septa and #13219 caps or
equivalent).
E. DISPOSITION OF SAMPLES
"Environmental samples" are to be shipped to the contract laboratory
or EPA Regional Laboratory designated by the Deputy Project Officer.
Hazardous waste site samples are to be shipped, following telephone
notification, to:
EPA
National Enforcement Investigations Center
Building 53, Box 25227
Denver Federal Center
Denver, CO 80225
(303) 234-4656 - FTS 234-4656
Attn: DPO
The samples from closed containers will be screened and prepared in a
high-hazard laboratory for analyses in EPA Regional Laboratories. Follow-
ing this preparation, the extracts will be shipped to the Regional Labora-
tory of origin for analyses. As other high-hazard facilities become avail-
able, this procedure will be modified.
F. TEAM BRIEFING
Because safety is the prime consideration in conducting hazardous
waste site investigations, it is imperative that the team be fully briefed
before entering the site. Each member must know which activity he and the
Must fit in steel shipping cylinder.
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VI-8
others will be involved in, and what protective clothing and safety precau-
tions are required. The sampling procedure, packaging, and shipping proce-
dures should be reviewed and discussed. Background material should be
reviewed and the team informed of the suspected hazardous waste to be
sampled. The team should be encouraged to ask questions and their sugges-
tions should be implemented if the task will be made safer.
The team should be informed that independent actions are not allowed.
All mapping, sampling, and packaging, will be done at scheduled times; no
one is to wander onsite or offsite without the permission of the team
leader.
During the field investigation, if circumstances require deviation
from the procedures established in the project plan, the team should be
briefed and suggestions solicited.
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VII-1
VII. FIELD INVESTIGATION
A. PREPARATION FOR INSPECTION
Field investigations will generally be conducted after offsite and
onsite reconnaissances have been completed and all inputs, data, informa-
tion, etc., have been thoroughly assessed. The Project Plan, SECTION VI,
will define and delineate the scope, logistics, schedules, manpower and
equipment needs. The Project Plan should be followed unless some modifica-
tions are necessary when unforeseen circumstances arise. All participants
in the field team should be completely familiar with the project and their
responsibilities during the investigation. A briefing session should be
held just prior (night before, for example) to beginning the investigation.
B. NOTIFICATION
The team leader must notify the appropriate person at the site to be
investigated and obtain permission to enter the property; written notifica-
tion is not required under the Resource Conservation and Recovery Act.
Advance notice of an inspection is not necessary; however, as a general
rule, the owner or operator will not be present at an inactive site and
advance notice may be necessary. If the appropriate official is present
onsite, permission should be obtained when the team leader arrives.
Advance notification, if necessary, should be made by the Deputy Project
Officer.
In the event entry is denied, the team leader is to withdraw, notify
the DPO, and await further instructions.
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VII-2
C. SAFETY
All safety requirements (see SECTION XII) should be included in the
project plan. After the team has initially observed the site, the safety
requirements should be discussed and improvement or necessary modification
implemented. The team leader is responsible for ensuring that all safety
procedures are followed.
In a field investigation, potentially hazardous samples will fre-
quently be collected. Self-contained breathing apparatus (SCBA) and pro-
tective clothing may be required. All personnel are required to adhere to
the rules specified in the project plan.
D. ENTRY
The procedures for entry onsite for a field investigation are the same
as the procedures for a site inspection, SECTION V.
E. INSPECTIONS
The field inspection must produce data to verify that a problem exists
or does not exist. Environmental samples collected during the inspection
may provide insight as to contaminants present, but may also indicate that
problems are not significant. The field investigation should be designed
to confirm and/or refute the inspection results.
The field investigation should be conducted methodically with all
leads confirmed and documented in the logbook. Nothing should be assumed.
Sewers or drains should be traced with dyes or other tracers to determine
the discharge location. A runoff channel should be traced to its terminus.
Cursory sampling of the groundwater may not show contamination; therefore,
the geology of the site should be determined and the groundwater sampled at
strategic locations.
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VII-3
The field investigation will be complete only when the objectives of
the project plan are met. Checklist are provided in Appendix B.
F. FIELD TESTING
Before samples are collected, the site must be checked for radioactiv-
ity and explosivity. If radioactivity is greater than 10 milli-Roentgens/hr
(mR/hr) operations are to be halted until continued operations have been
recommended by an EPA radiation monitoring team. If explosive concentra-
tions of vapors are detected, all employees will be immediately evacuated,
the fire department notified, and the supervisor consulted for direction
regarding further operations.
The pH of all samples should be measured (litmus paper recommended) to
determine if the material is corrosive, neutral, or caustic.
G. SAMPLING
Sampling procedures should follow approved techniques appropriate for
the type of facility and waste, and they should be specified in the Project
Plan. Cross-contamination must be avoided; therefore, all sampling equip-
ment must be either thoroughly cleaned with soap and water, or solvent, or
used only once. For liquid wastes, if the equipment is cleaned and reused,
the sampling equipment should be rinsed thoroughly with the liquid waste
before a sample is collected. Stainless steel, glass, or other compatible
material should be used to collect the samples.
Extreme care should be used in collecting concentrated wastes (e.g.,
from drums). The team leader should discuss whether remote drum opening
procedures and equipment should be implemented. If a disposable thief is
used, it must be disposed of in the drum. The drum must be sealed after
sampling. Samples collected from an open drum or vessel may be toxic, and
vapors could be liberated if the surface film is broken or the contents are
disturbed. Samples of this type should be of minimal size consistent with
analytical requirements (see SECTION VI).
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VII-4
H. PHOTOGRAPHS
Photographs or slides should be taken at every sampling location to
verify the written description in the field logbook. Procedures and require-
ments are discussed in SECTION IV.
I. CHAIN-OF-CUSTODY
After collection and identification, the samples are maintained under
the Chain-of-Custody described in SECTION VIII.
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VIII-1
VIII. CHAIN-OF-CUSTODY
After collection and identification, the samples are maintained under
the Chain-of-Custody procedures. If the sample collected is to be split
with the owner or operator of the site, or other regulatory agencies, it
should be aliquoted into similar sample containers. Sample tags completed
with identical information are attached to each of the samples and are
marked as "Company Split" or "Split". If air samples are to be given to
the Company, then duplicate samples must be collected. The requesting
official is to be notified that the Company must reimburse the Government
for the materials used in sampling.
Each person involved with the sample must know Chain-of-Custody proce-
dures. The procedures should be included in the Project Plan or be published
and available to all personnel. Due to the evidentiary nature of sample-col-
lecting investigations, the possession of samples must be traceable from
the time the samples are collected until they are introduced as evidence in
legal proceedings. To maintain and document sample possession, Chain-of-Cus-
tody procedures are followed.
1. Sample Custody
A sample is under custody if:
a. It is in your actural possession, or
b. it is in your view, after being in you physical possession,
or
c. it was in your physical possession and then you locked it
up to prevent tampering, or
d. it is in a designated and identified secure area.
2. Field Custody Procedures
a. When collecting samples for evidence, collect only that
number which provides a fair representation of the media
being sampled. To the extent possible, the quantity and
types of samples and sample locations are determined prior
to the actual field work. As few people as possible should
handle the samples.
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VIII-2
b. The field sampler is personally responsible for the care
and custody of the samples until they are transferred or
properly dispatched.
c. Sample tags shall be completed for each sample, using
waterproof ink unless prohibited by weather conditions.
d. During the course and at the end of the field work, the
FIT Leader determines whether these procedures have
been followed, and if additional samples are required.
3. Transfer of Custody and Shipment
a. Samples are accompanied by a Chain-of-Custody Record (see
following page). When transferring the possession of
samples, the individuals relinquishing and receiving will
sign, date, and note the time on the Record. This Record
documents transfer of custody of samples from the sampler
to another person, to a mobile laboratory, or to the per-
manent laboratory.
b. Samples will be properly packaged for shipment and
dispatched to the appropriate laboratory for analysis,
with a separate signed Custody Record enclosed in each
sample box or cooler. Shipping containers will be pad-
locked or custody-sealed for shipment to the laboratory.
Preferred procedure includes use of a custody seal*
wrapped across filament tape that is wrapped around the
package at least twice. The custody seal is then folded
over and stuck to itself so that the only access to the
package is by cutting the filament tape or breaking the
seal to unwrap the tape. The seal is then signed. The
"Courier to Airport" space on the Chain-of-Custody Record
shall be dated and signed.
c. Whenever samples are split with a facility or government
agency, a separate Chain-of-Custody Record is prepared
for those samples and marked to indicate with whom the
samples are being split.
d. All packages will be accompanied by the Chain-of-Custody
Record showing identification of the contents. The
original Record will accompany the t,nipment, and a copy
will be retained by the Project Leader.
e. If sent by common carrier, a Bill of Lading should be
used. Receipts of Bill of Lading will be retained
as part of the permanent documentation.
* Custody Seals. Custody seals should be made of 1" x 6" U.L. lutho tape
with security slots. This tape is backed with a very strong self adhesive
so that once stuck to itself it will not come apart without breaking the
seal.
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VIII-3
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IX-1
IX. DOCUMENT CONTROL AND EVIDENCE AUDIT
The purpose of the document control requirement is to assure that all
project documents issued to or generated during hazardous waste site inves-
tigations will be accounted for when the project is completed. This program
includes a serialized document number system, a document inventory proce-
dure, and an evidentiary filing system.
Accountable documents used or generated during HWS investigations
include logbooks, field data records, correspondence, sample tags, graphs,
Chain-of-Custody records, bench and photographic prints. Each document
bears a serialized number and is listed, with the number, in a project
document inventory assembled at the project's completion.
Unless prohibited by weather, waterproof ink is used in recording all
data on serialized accountable documents.
A. SERIALIZED DOCUMENTS
All field logbooks, field data records, sample tags and Chain-of-Custody
records are assigned to the team leader (or FIT Leader). The team leader
is responsible for ensuring that a sufficient supply of documents is obtained
for an investigation and that these documents are properly distributed to
the appropriate personnel. The Deputy Project Officer (DPO) or Regional
Document Control Officer will maintain a list of the serialized project
Documents that were issued to personnel for that project.
B. PROJECT LOGBOOKS
The logbook of the team leader (or FIT Leader) will document the
transfer of logbooks to the individuals who have been designated to perform
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IX-2
specific tasks on the survey. All pertinent information must be recorded
in these logbooks from the time each individual is assigned to the project
until the project is completed. All logbooks are the property of EPA and
are to be returned to the Document Control Officer upon completion of the
i nspecti on/i nvesti gati on.
Logbook entries must be dated, legible and contain accurate and inclu-
sive documentation of an individual's project activities. Because the
logbook forms the basis for the later written reports, it must contain only
facts and observations. Language should be objective, factual and free of
personal feelings of other terminology which might prove inappropriate.
Entries made by individuals other that the person to whom the logbook was
assigned are dated and signed by the individual making the entry. Individ-
uals must sign each logbook assigned to them.
C. FIELD DATA RECORDS
Serialized Field Data Records (in the form of individual sheets or
bound logbooks) are maintained for each inspection or investigation and the
project code is recorded on each page. The Project Coordinator also numbers
the FDR covers with the appropriate project code. All in-situ measurements
and field observations are recorded in the FDRs with all pertinent informa-
tion necessary to explain and reconstruct sampling operations. Each page
of a Field Data Record is dated and signed by all individuals making entries
on that page. The Coordinator and the field team on duty are responsible
for ensuring that FDR's are present during all monitoring activities and
are stored safely to avoid possible tampering. Any lost, damaged or voided
FDRs are reported to the team leader (FIT Leader).
D. SAMPLE IDENTIFICATION
All necessary serialized sample tags are distributed to field person-
nel by the team leader (or designated team member) and the serial numbers
are recorded in the logbook. Individuals are accountable for each tag
assigned to them. A tag is considered in their possession until it has
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IX-3
been filled out, attached to a sample, and transferred to another individual
with the corresponding Chain-of-Custody Record. At no time are any sample
tags to be discarded and if any tags are lost, voided, or damaged, this is
noted in the appropriate FDR or logbook immediately upon discovery and the
team leader is notified. At the completion of the field investigation
activities, team leaders (or FIT Leaders) are accountable for all serially
numbered documents including tags, to the DPO or Document Control Officer.
Tags attached to those samples split with the source or another government
agency are accounted for in the same manner.
E. CHAIN-OF-CUSTODY RECORDS
Serialized Chain-of-Custody Records are assigned and accounted for in
a manner similar to that used for sample tags. If samples are transferred
to the laboratory by courier, the receiving party at the laboratory signs
the custody record and files the white original in the laboratory's desig-
nated security container. The courier returns the carbonless copy of the
Custody Record to the team leader. A similar procedure is followed when
dispatching samples via common carrier, mail, etc., except that the orig-
inal accompanies the shipment and is signed and retained by the receiving
laboratory sample custodian.
When samples are split with the source or another government agency,
the tag serial numbers from all splits are recorded on the Custody Record.
A copy of the custody record will be provided to the source or agency upon
request; and the white originals are returned to the team leader.
When movies, slides or photographs are taken which visually show the
effluent or emission source and/or any monitoring locations, they are
numbered to correspond to logbook entries. The name of the photographer,
date, time, site location, and site description are entered sequentially in
the logbook as photos are taken. Chain-of-Custody procedures depend upon
the type of film and the processing it requires. Once developed, the
slides or photographic prints shall be serially numbered corresponding to
the logbook descriptions and must be labeled.
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IX-4
F. CORRECTIONS TO DOCUMENTATION
As previously noted, unless prohibited by weather conditions, all
original data recorded in logbooks, FDRs, Sample Tags, Custody Records and
other data sheet entries are written with waterproof ink. None of the
accountable serialized documents listed above are to be destroyed or thrown
away even if they are illegible or contain inaccuracies which require a
replacement document.
If an error is made on an accountable document assigned to one indi-
vidual, that individual may make contemporaneous corrections simply by
crossing a line through the error and entering the correct information.
Any subsequent error discovered on an accountable document should be cor-
rected by the person who made the entry. All subsequent corrections must
be initialed and dated.
If a Sample Tag is lost in shipment, or a tag was never prepared for a
sample(s), or a properly tagged sample was not transferred with a formal
Chain-of-Custody Record, the following procedure applies. A written state-
ment is prepared detailing how the sample was collected, air-dispatched or
hand-transferred to the laboratory.
The statement should include all pertinent information, such as
entries in field logbooks regarding the sample, whether the sample was in
the sample collector's physical possession or in a locked compartment until
hand-transferred to the laboratory, etc. Copies of the statement are
distributed to the team leader, OPO or Document Control Officer and to the
project file.
G. DOCUMENT NUMBERING SYSTEM AND INVENTORY PROCEDURE
To provide document accountability to the appropriate individuals,
each of the document categories discussed above features a unique serial-
ized number for each item within the category. Logbooks, FDRs, Sample Tags
and Custody Records are serially numbered by the Document Control Officer
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IX-5
before assignment to the team leader. The logbooks and FDRs are usually
given a five-digit number, with the project code as the first three digits
followed by a two-digit document number. Sample tags and custody records
are labeled with a four-digit document number and the project code. All
documentation not covered by the above (logbooks, data sheets, graphs,
etc.) are uniquely and serially numbered using the project code as part of
the number.
H. TEAM FILES
After the team has completed its work for a particular investigation,
all documents generated from that project should be assembled in the team
file. Individuals may retain c 1ean (no handwritten comments) copies of
documents for their personal files but only after personally verifying that
the original or similar copy is in the team file. Documents that have been
declared "Confidential" may not be retained in personal files. The team
leader is responsible for assuring the collection, assembly, and inventory
of all documents relative to a particular project at the time the project
objectives are completed. The file then becomes accountable. Any records
leaving the file must be signed out.
I. EVIDENTIARY FILE
When the team has completed the project objectives, all inventoried
file documents are reviewed and submitted to the DPO or Document Control
Officer. By this time each document will have been labeled with a unique
serialized number as specified above. The Evidentiary File is formatted
according to the following document classes:
A. Project Plan
8. Project Logbooks
C. Field Data Records
D. Sample Identification Documents
E. Chain-of-Custody Records
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IX-6
F. Correspondence
1. Intra-office (Contractor)
2. EPA
3. Industry
4. Record of Confidential Material
G. Report Notes, Calculations, etc.
H. References, Literature
I. Sample (on-hand) Inventory
J. Check-out Logs
K. Litigation Documents
L. Miscellaneous - photos, maps, drawings, etc.
M. Final Report
Once deposited in the Evidentiary File, documents may only be checked
out through the Document Control Officer.
J. REPORTS
All draft reports are dated and numbered and are accountable. They
are stamped in red DRAFT REPORT FOR AGENCY REVIEW ONLY, DO NOT DUPLICATE on
the cover page. The team leader is responsible for delivery of all required
reports to the DPO. All draft copies of the report are to be returned to
the author. Once comments have been incorporated and the final report has
been prepared, all draft copies are destroyed. However, Regional Offices
may retain a copy of the draft report with their comments until they receive
the final report.
K. CONFIDENTIAL INFORMATION
Any information received by the team with a request of confidentiality
is handled as "Confidential". The request should be accompanied by supporting
justification. A separate, locked file is maintained for the segregation
and storage of all confidential and trade-secret information. Upon receipt
by the team this information is directed to and recorded in the Confidential
Inventory Log by the Document Control Officer. The information is then
made available to EPA personnel on a "need-to-know" basis, but only after
it has been logged out. The information should be returned to the locked
file at the conclusion of each working day unless the employee can guarantee
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IX-7
its security. Confidential information may not be reproduced except upon
approval by and under the supervision of the Document Control Officer. Any
reproduction should be kept to an absolute minimum. The DCO will enter all
copies into the document control system and apply the same requirements as
for the original. In addition, this information may not be entered into
any computer or data handling system. Confidential documents may not be
destroyed except upon approval by and under the supervision of the DPO.
The team leader will be notified prior to destruction of confidential
information. The DCO shall remove and retain the cover page of any con-
fidential information disposed of for one year and shall keep a record of
the destruction in the Confidential Inventory Log.
L. EVIDENCE AUDITS
As discussed in SECTION III, adherence to Chain-of-Custody and document
control procedures will be periodically evaluated by evidence audit. Such
audits may be conducted by Regional or Headquarters personnel, or by a
Contractor Evidence Audit Team (CEAT) which is located in Denver, Colorado.
Evidence audits will be structured around the "Evidence Evaluation Checklist
for Hazardous Waste Site Investigations" and "Document Control Checklist
for Hazardous Waste Site Investigations" [Appendix A]. Evidence audits may
examine procedures at the field site, in the FIT offices, laboratories,
Regional Offices, or combinations thereof. (See "Procedures Manual for
Contractor Evidence Audit Teams.")
All documents generated by contractor personnel, during any/all phases
of hazardous waste site investigations are the property of the United
States Government, and shall be made available for inspection, upon demand,
by the Deputy Project Officer, Document Control Officer, properly identified
members of the Contractor Evidence Audit Team (CEAT), or properly identified
members of the Evidence Audit Unit of the EPA National Enforcement Investiga-
tions Center.
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X-l
X. PACKAGING, MARKING, LABELING, AND SHIPPING OF
HAZARDOUS WASTE SITE SAMPLES
A. GENERAL PROVISIONS
Samples that are judged to be environmental samples may be shipped
according to letters of understanding granted EPA by DOT [Appendix D].
Other specific exemptions may also apply (e.g., use of Labelmaster, Inc.
package #38, or Dow Chemical Co. Imbiber Pack for shipment of Poison B,
n.o.s. by United Parcel Service),
The following procedures apply to samples collected from a hazardous
waste site (HWS), and which in the judgment of the Project Leader cannot be
considered to be "environmental" samples.
Unanalyzed HWS samples may not be fixed with any preservative
or preserved with ice or dry ice.
If a material identified in the Department of Transportation
(DOT) Hazardous Material Table (49 CFR 172.101) is known to be
contained in an HWS sample, that sample should be transported
as prescribed in the table.
Unanalyzed HWS samples may be transported by rented or common
carrier truck, bus, railroad, and by Federal Express Corporation*
(air cargo); but they may not be transported by any other common
carrier air transport, even "cargo only" aircraft. Those samples
taken from closed drums or tanks, however, must not be transported
by Federal Express. (See 1 and 2 in "Packaging, Marking and
Labeling Requirements for Unanalyzed Hazardous Waste Site Samples
Taken From Closed Containers" on p. X-5).
If samples are transported by any type of government-owned
vehicle, including aircraft, DOT regulations are not applicable.
However, EPA and FIT personnel will use the packaging procedures
described below except that the Bill of Lading with certification
form does not have to be executed (see "Shipping Papers" on p. X-4).
These procedures are designed to enable shipment by entities like Federal
Express,- however, they should not be construed as an endorsement by EPA
of a particular commercial carrier.
-------
X-2
Irrespective of type sample or container, after completion of the
analyses the contractor will repackage the original sample bottles
in the coolers or containers received, and return them to the
originating Regional office. The packages will be sealed and
shipped under custody procedures as they were received. Each
originating office should make arrangements with the contractor
through the Sample Management Office (VIAR) for the method of
return and payment for shipping charges within 30 days after
sample shipment. Organic extracts from the samples will be
shipped by the analytical contractors to EPA's EMSL/Las Vegas
office for archival storage.
B. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS
WASTE SITE SAMPLES. EXCLUDING CLOSED CONTAINER SAMPLES
1. Collect sample in a 8-ounce* or smaller glass container with
nonmetallic, teflon-lined screw cap. Allow sufficient ullage
(approximately 10% by volume) so container is not liquid full at
130°F. If collecting a solid materialv the container plus con-
tents shall not exceed one pound net weight.
2. Attach properly completed Sample Identification Tag (see following
page) to sample container.
3. Seal sample container and place in 2-mil-thick (or thicker)
polyethylene bag, one sample per bag. (Tags should be positioned
to enable them to be read through bag.)
4. Place sealed bag inside a metal can with incombustible, absorbent
cushioning material (e.g., vermiculite or earth) to prevent
breakage, one bag per can. Pressure-close the can and use clips,
tape or other positive means to hold the lid securely, tightly
and effectively.
* Large quantities, up to one gallon, taken from wells may be collected
if the flash point of the sample can be determined to be 73°F or higher.
In this case, such should be marked on the outside container (carton,
etc.) but only a single (one gallon or less) bottle may be packed in
an outside container. Ten percent ullage and requirement 2,5,6, and
7 below must also be followed. On the shipping papers state that
"flash point is 73°F or higher".
-------
X-3
SAMPLE IDENTIFICATION TAG
Project Code
Station No., 1 Month/Day/Year
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-------
X-4
5. Mark and label this container as indicated in No. 8 below.
6. Place one or more metal cans (or a single 1-gallon bottle; see
footnote on p. X-2), surrounded with incombustible packaging
material for stability during transport, into a strong outside
container, such as a metal picnic cooler or a fiberboard box.
7. Mark and label the outside container and complete shipping papers
as described below.
8. Marking and Labeling: Use abbreviations only where specified.
Place the following information on a metal can (or bottle),
either hand printed or in label form: laboratory name and address
and "Flammable Liquid, n.o.s", (if not liquid, write "Flammable
Solid, n.o.s.")-* Place the following labels on the outside of
the can (or bottle).
"Cargo Aircraft Only"; "Flammable Liquid"; if not
liquid, "Flammable Solid" ("Dangerous When Wet" label
should be used if the solid has not been exposed to
wet environment).
NOTE: If the cans are placed in an exterior container, both
that container and inside cans must have the same markings and
labels as above. "Laboratory Samples" and "THIS SIDE UP" or
"THIS END UP" should also be marked on the top of the outside
container, and upward pointing arrows should be placed on all
four sides of the exterior container.
Shipping Papers: Use abbreviations only where specified below.
Complete the carrier-provided Bill of Lading and sign the certification
statement (if carrier does not provide, use standard industry form)
with the following information in the order listed. One fora may be
used for more than one exterior container.
* Using "Flammable" does not convey the certain knowledge that a sample
is in fact flammable, or how flammable, but is intended to prescribe
the class of packaging in order to comply with DOT regulations; "n.o.s"
means not otherwise specified.
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X-5
"Flammable Liquid, n.o.s." (or "Flammable Solid, n.o.s", as
appropriate); "Cargo Aircraft Only"; "Limited Quantity" or
"Ltd. Qty."; "Laboratory Samples"; "Net Weight
or "Net Volume " (of hazardous contents), by item,
if more than one metal can is inside an exterior container.
The net weight or net volume must be placed just before or
just after the "Flammable Liquid, n.o.s." or "Flammable Solid,
n.o.s." description.
A Chain-of-Custody Record form [see SECTION VIII] should also be
properly executed, and included in the exterior container.
9. Unless samples are driven to the laboratory, a team member must
accompany shipping container(s) to the transport carrier and, if
required, open outside container(s) for freight inspection.
C. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS
WASTE SITE SAMPLES TAKEN FROM CLOSED CONTAINERS
1. This packaging, marking, labeling and shipping method provides
a worst-case procedure for materials classed as "Poison A"
(49 CFR 173.328). In the absence of reliable data which exludes
the possibility of the presence of "Poison A" chemicals or com-
pounds, these procedures must be followed.
2. These samples may not be transported by Federal Express Corpora
tion (air cargo) or other common carrier aircraft, or by rental,
non-government aircraft. (Samples may be shipped by ground
transport or government aircraft).
3. Collect sample in a polyethlylene or glass container which is of
an outer diameter narrower than the valve hole on a DOT Spec.
3A1800 or 3AA1800 metal cylinder. Fill sample container allowing
sufficient ullage (approximately 10% by volume) so it will not be
liquid-full at 130°F. Seal sample container.
4. Attach properly completed Sample Identification Tag (see p. X-3)
to sample container.
-------
X-6
5. With a string or flexible wire attached to the neck of the sample
container, lower it into a metal cylinder which has been partial-
ly filled with incombustible, absorbent, loose packaging material
(vermiculite or earth). Allow sufficient cushioning material
between the bottom and sides of the container and the metal
cylinder to prevent breakage. After the cylinder is filled with
cushioning material, drop the ends of the string or wire into the
cylinder valve hole. Only one sample container may be placed in
a metal cylinder.
6. Replace valve, torque to 250 ft-lb (for I inch opening) and
replace valve protector on metal cylinder, using teflon tape.
7. Mark and label cylinder as described below.
8. One or more cylinders may be placed in a strong outside container.
9. Mark and label outside container and complete shipping papers as
described below.
10. Marking and Labeling: Use abbreviations only where specified.
Place the following information on the side of the cylinder, or
on a tag wired to the cylinder valve protector, either hand-
printed or in label form.
"Poisonous Liquid or Gas, n.o.s"; laboratory name and address.*
Place the following label on the cylinder: "Poisonous Gas". (Poisonous
Liquid" label not acceptable here, even if liquid.)
Using "Poisonous" does not convey the certain knowledge that a sample
is in fact poisonous, or how poisonous, but is intended to prescribe
the class of packaging in order to comply with DOT regulations.
-------
X-7
Note: If the metal cylinders are placed in an outside container,
both the container and cylinders inside must have the same markings
and labels as above. In addition, "Laboratory Sample", and "Inside
Packages Comply With Prescribed Specifications" should be marked on
the top of the outside container. "THIS SIDE UP" marking should be
placed on the outside container and upward pointing arrows on four
sides.
Shipping Papers: Complete the shipper-provided Bill of Lading and
sign the certification statement (if carrier does not provide, use
standard industry form) with the following information in the order
listed. One form may be used for more than one exterior container;
use abbreviations only as specified:
"Poisonous Liquid, n.o.s,"; "Limited Quantity" or "Ltd. Qty.";
"Laboratory Samples"; "Net Weight " or "Net Volume
(of hazardous contents), by cylinder, if more than one cylinder
is inside an exterior container. The net weight or net volume
must be placed just before or just after the "Poisonous Liquid,
n.o.s" marking.
A Chain-of-Custody Record form [see SECTION VIII] should also be
properly executed and included in the container, or with the cylinder.
11. Unless samples are driven to the laboratory, a team member will accompany
shipping containers to the transport carrier and, if required, open
outside container(s) for freight inspection.
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XI-1
XI. QUALITY ASSURANCE
A. INTRODUCTION
Decisions concerning the control and management of hazardous wastes or
the need for enforcement actions must be based on analytical data generated
in agency, State, or contractor laboratories. Such management decisions
will be no better than the data upon which they are based. Therefore, it
is imperative that the quality of the data be assured. To obtain quality
data, data which are scientifically and legally defensible, and which have
the requisite levels of precision and accuracy with minimum expenditures of
resources, requires the development of a comprehensive and well documented
quality assurance (QA) program. Decisions concerning sampling site selec-
tion, the frequency of sampling, the number of samples to be collected, the
procedures involved in the collection, preservation and transport of samples,
the calibration and maintenance of instruments, and the processing, verifi-
cation and reporting of the data must incorporate a quality assurance pro-
gram. If careful attention is not paid to each of these items the possibil-
ity of producing invalid data is highly probable. Such data waste resources,
lead to bad management decisions, and confound enforcement actions. Deputy
Project Officers and/or their representatives will coordinate the QA Program
through the team leader.
The purpose of this Section is to provide general guidelines which
address the quality assurance procedures applicable to the evaluation of
hazardous waste sites. Due to the complex composition and heterogeneous
nature of many hazardous waste materials, these guidelines cannot discuss
every possible situation which may be encountered in the field or labora-
tory. Consequently, they are designed to encourage personnel involved in
hazardous waste investigations to give adequate thought and sufficient
planning to quality assurance measures, techniques and procedures before
initiating either a routine monitoring program or an enforcement investi-
gation.
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XI-2
8. ORGANIZATION AND PERSONNEL
Management Including DPO and FIT Leader, must have a firm commitment
to the production of quality data and to quality performance by all employ-
ees. Moreover, this commitment to quality must be demonstrated by manage-
ment and transmitted to all of the personnel involved in an investigation
or study.
Management is responsible for maintaining the resume and job descrip-
tion of each person responsible for the design, supervision, conduct or
analysis of any study or test involving hazardous waste. Such records
should be maintained for a period of three years following completion of
any hazardous waste investigation. This is important because resumes and
job descriptions are generally used in enforcement actions to demonstrate
the competency, training, and experience, of the personnel who performed
the studies under investigation.
As a part of the Project Plan (see SECTION VI), a quality assurance
plan must be developed. The quality assurance plan should contain, but not
be limited to, the following items:
Criteria used to select the sampling points at a given site.
Explain how the sampling points are determined, identified and
recorded.
Criteria used to select the sampling method and sampling device;
discussion of the representativeness of the samples.
Specification of sample containers and procedure for cleaning
sampling equipment and sample containers.
Cleaning of sampling equipment under field conditions.
Rationale for the sample preservation and storage conditions to
be used, maximum storage time and sample shipment conditions.
C. RECORDS AND REPORTS
1. Recording and Reporting of Study Results
-------
XI-3
All data generated, except those that are generated as direct computer
input, must be recorded directly, promptly, legibly and indelibly, and the
data entries must be signed and dated on the day of entry. Any change in
entries must be made so as to avoid obscuring the original entry, the
reason for such change must be stated, and the change and statement must be
dated and signed or identified at the time of the change.
A summary report must be prepared for each investigation, including,
but not be limited to, the following:
The names of the team leader, scientists, professionals, technical
and support personnel involved in the inspection or investigation;
the objectives and procedures stated in the approved study plan,
including any changes from the original study plan;
sampling site identification and description information available
at the beginning of the investigation as to the nature and compo-
sition of the hazardous waste;
a description of the methods and instrumentation, if any, used in
the investigation;
any deviations from the methods described in the approved study
plan, the reasons for the deviation and their impact on the
results;
a description of the quality control methods used to ensure the
quality of the data;
a description of all circumstances that may have affected the
quality or integrity of the data.
The team leader shall sign the final report. Corrections or additions
to a final report shall be written as an amendment by the team leader.
2. Retention and Retrieval of Samples, Records and Data
Until transferred to the DPO or Document Control Officer, all prelimin-
ary data, documentation, study plans, protocols, and final reports shall be
retained under storage conditions that minimize deterioration and facilitate
retrieval. An individual shall be identified as responsible for the stored
material, and only authorized personnel shall have access to it.
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XI-4
Raw data, documentation, protocols, and final reports must be retained
by the Document Control Officer for at least three years after the completion
of the final report.
D. BIBLIOGRAPHY
1. General Quality Assurance
1. U.S. EPA (1976). "Quality Assurance Handbook for Air
Pollution Measurement Systems," EPA-600/9-76-005.
2. U.S. EPA (1973). "Quality Control Practices in Processing
Air Pollution Samples," APTD 1132.
3. Juran, J. M., ed. (1974). "Quality Control Handbook,"
McGraw-Hill.
4. Inhorn, S.L. , ed. (1978). "Quality Assurance Practices for
Health Laboratories," American Public Health Association.
5. U.S. EPA (1979). "Handbook for Analytical Quality Control in
Water and Wastewater Laboratories," EPA-600/4-79-019.
2. Laboratory Facilities and Practices
1. U.S. EPA (1978). "Manual for the Interim Certification of
Laboratories Involved in Analyzing Public Drinking Water
Supplies-Criteria and Procedures," EPA 600/8-78-008.
2. Bicking, C., Olin, S., and King, P. (1978). "Procedures for
the Evaluation of Environmental Monitoring Laboratories,"
U.S. EPA, EPA 600/4-78-017.
3. Sample Collection and Analysis
1. U.S. EPA (1977). "Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal Facilities," EPA/530/SW-611.
2. U.S. EPA (1979). "Quality Assurance and Quality Control
Procedures for Screening and Verification of Industrial
Effluents for Priority Pollutants."
3. U.S. EPA (1974). "Compliance Monitoring Procedures,"
EPA-330/1-74-002.
4. Brownlee, K. A. (1965). "Statistical Theory and Methodology
in Science and Engineering," John Wiley & Sons, Inc.
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XII-1
XII. SAFETY PROCEDURES FOR HAZARDOUS WASTE SITE INVESTIGATIONS
A. INTRODUCTION
1. Purpose
This Section provides a basic framework for the safe conduct of haz-
ardous waste site (HWS) investigations. It is prepared for use by contractor
personnel. It is designed to provide guidance to program managers, supervi-
sors, FIT leaders, organizational safety officers, and individual investiga-
tors.
Clearly, every safety hazard associated with HWS investigations cannot
be anticipated; and accordingly, rules cannot be developed for every contin-
gency that could arise. Consequently, a practical safety program consists
of: (a) rules and adherence thereto, and (b) the application of common sense,
judgment, and technical analysis. All personnel are, therefore, required to
enforce and adhere to the published rules, but more importantly they are re-
quired to maintain a high level of safety consciousness. The latter involves
constant vigilance for unsafe or potentially hazardous conditions or prac-
tices, and immediate corrective action as necessary to ameliorate or avoid
the condition or practice.
HWS investigations, by their very nature, require extraordinary pre-
cautions to prevent loss of life, injury, or health hazard to investigators
and the public. This responsibility transcends all others related to HWS
investigations.
2. Responsibil ities
Responsibilities for implementing safe HWS investigation procedures,
and specifically for the requirements contained in this manual, are de-
scribed below.
-------
XII-2
a. Project Manager
The Project Manager is responsible for the overall effectiveness of
the safety program. Specifically, this includes appropriate emphasis; pro-
viding adequate manpower, equipment, and time resources to conduct an inves-
tigation safely; and appropriate disciplinary action when unsafe acts or
practices occur.
b. Occupational Health and Safety Officers
The organization Safety Officer may be appointed by the Project Manager,
or by the FIT Leader. He is responsible for overall coordination of safety
matters within the organization. He advises the program manager, first-line
supervisors, and project leaders regarding safety matters; recommends policy
on matters not specifically addressed by other rules, regulations, statutes,
or this manual; researches and disseminates information regarding known
hazardous conditions, practices, or standards; conducts a safety training
program for organization personnel; follows up on corrective actions; eval-
uates new procedures; maintains awareness of parallel programs; and gener-
ally monitors the HWS investigation safety program.
c. FIT Leaders
Team Leaders are responsible for maintaining a high level of safety
consciousness among the group supervised, and for implementing a strong
safety program within the unit. This broad general responsibility includes
ensuring that proper equipment is available and in working order; that
proper clothing is available and supplies are maintained; that employees
are adequately trained and frequently updated on pertinent safety matters;
and that appropriate corrective ana/or disciplinary actions are recommended
in cases of negligence in safety matters or violation of safety regulations.
Team Leaders are responsible for ensuring that HWS investigations are
conducted according to established safety procedures, rules, and regulations;
-------
XII-3
devising investigative techniques that enhance safety; taking particular
concern and appropriate precautions to prevent injury of employees and the
public; and initiating immediate corrective action when an unsafe procedure
or condition is noted.
d. Field and Laboratory Safety Coordinators
Safety Coordinators are appointed by Team Leaders. They are field or
laboratory personnel whose primary duties may be technical, but who are
responsible for overall safety of individual projects or operations. In
larger operations, the Safety Coordinator may devote full time to over-
seeing safety. Field Safety Coordinators are expected to: focus on the
hazards associated with particular projects and to assist the team leader
in developing the safety aspects of the project plan; continually review
safety matters during field operations; immediately call to the attention
of the team leader any unsafe condition or practice noted; and critique the
safety aspects of the project during debriefings or in follow-up reports.
Laboratory Safety Coordinators, similarly, focus on particular opera-
tions; conduct laboratory inspections; review procedures; and provide timely
advice and information to the team leaders. In controlled or regulated
laboratories, the Safety Coordinator reviews each operation to be performed
before that process is initiated.
e. Employees
All contractor personnel engaged in HWS investigations are required to
become thoroughly familiar with, and to conform to, the provisions of this
manual, and such other safety directives as may be considered appropriate
by the Project Manager, Organization Safety Officers, and FIT Leaders.
Personnel are encouraged to offer ideas, suggestions or recommendations
regarding any operational condition, procedure or practice, that may en-
hance the safety of affected personnel or the public.
-------
XII-4
B. GENERAL SAFETY PRECAUTIONS
1. Unsafe Situations
All employees are directed to bring to the attention of the most read-
ily accessible supervisor any unsafe condition, practice, or circumstance
associated with or resulting from hazardous waste site (HWS) investigations.
In cases of immediate hazard to employees or the public, any employee
on the scene should take all practicable steps to eliminate or neutralize
the hazard; this may include leaving the site. Followup consultation with
the team leader or on-scene Supervisor must then be made at the first oppor-
tunity. In such circumstances the team leader or supervisor must take, or
cause to be taken, the necessary steps to ensure that the investigation can
be completed safely. Such steps may include changes in procedure, removal
or neutralization of a hazard, consultation with appropriate experts, or
bringing in specialists such as Explosive Ordinance Disposal (EOD) units.
All such actions must be coordinated with and approved by the DPO. In
cases where the hazard is not immediate, the employee should consult the
team leader regarding appropriate corrective measures. Application of this
rule requires exercising good judgment and common sense by all employees.
2. Protective Gear
Protective headgear, eyewear, footwear, and clothing are to be worn at
all times on abandoned hazardous waste sites. Likewise, self-contained
breathing apparatus (SCBA) will be worn unless the ^.n-scene team leader has
determined that the ambient air may be safely inhaled. On-scene team leaders
should exercise informed judgment on protective gear requirements at active
sites, or in cases where sites have been repeatedly entered or occupied
without apparent harm. In any case where doubt exists, the safe course of
action must be taken. SCBA will be worn at all times when containers of
suspected hazardous materials are being opened, or when operating in build-
ings or other enclosed spaces suspected of containing hazardous substances.
-------
XII-5
3. Radioactivity and Explosivity
All suspect sites must be checked for radioactivity, explosivity, and
oxygen content during first entry onto the site. If 02 concentration is
less than 19%, SCBA must be used. Normal background radioactivity is approxi-
mately 0.2 milli-Roentgens per hour (mR/hr); however, activity of 10.0 mR/hr
is acceptable for the period of exposure associated with a hazardous waste
site investigation. Detecting levels of activity significantly greater
than normal background is cause for a very careful survey of the entire
site; if levels approaching 10 mR/hr are encountered, the advice of a
competent radiation health physicist must be sought before continuing
operations on the site.
*
If explosivity readings greater than 20% LEL (not 20% concentration,
which is frequently much higher than 20% LEL) are detected, very careful
survey of the area, including ground", waist-, and head-level readings,
must be made. Readings approaching or exceeding 50% LEL are cause for im-
mediately withdrawing personnel and notifying the fire department. The
team leader is then to be consulted for direction regarding further opera-
tions. Supervisors or managers are then to take, or cause to be taken,
actions necessary to safely resume the investigation.
4. Sample Handling
Samples of runoff, ambient air, or groundwater from an HWS, or pos-
sibly affected areas, may be moved directly into laboratories and handled
with normal safety precautions, unless the team leader determines that
special handling is appropriate. Team leaders should consult with the
receiving laboratory prior to departure from normal handling procedure.
Samples of liquids or solid materials removed from closed containers areas
are to be processed and diluted in a controlled, or regulated, laboratory
before analysis (see SECTION IV).
* LEL = Lower Explosive Limit
-------
XII-6
5. Forbidden Practices
The following practices are expressly forbidden during operations on
suspected or known hazardous waste disposal sites:
a. Smoking, eating or drinking while onsite and after com-
pleting investigation until decontamination is completed.
b. Ignition of flammable liquids within, on, or through impro-
vised heating devices (barrels, etc.)> or space heaters.
c. Entry into areas or spaces where toxic or explosive concen-
trations of gases or dust may exist without proper equipment
available to enable safe entry.
d. Conduct of onsite operations without offsite backup personnel.*
6. Health and Training
All employees who will engage in HWS field investigations or labora-
tory analyses must complete a comprehensive health examination, be shown to
be free of residual effects of exposure to hazardous materials, and be in
general good health and physical condition. The comprehensive examination
is to be repeated at intervals no greater than annually for so long as the
employee continues HWS investigative work. All employees engaged in HWS
field work or laboratory analyses will receive training in basic first-aid,
cardio-pulmonary resuscitation, and the use of protective clothing and equip-
ment [see Appendix E]. Management is responsible for providing training at
the earliest practicable time, and refresher training at appropriate intervals.
Project Managers and FIT Leaders are required to familiarize themselves
with the EPA Occupational Health and Safety Manual; 29 CFR 1910; 29 CFR 1960;
and EPA Accident Reporting Procedures.
* On-scene team leaders should exercise informed judgment regarding the
necessity for offsite backup at active sites, or in cases where sites
have been repeatedly entered or occupied without apparent harm. In any
case where doubt exists, offsite backup must be provided.
-------
XII-7
C. SAFETY PROCEDURES FOR FIELD EVALUATIONS OF HAZARDOUS WASTE SITES
The team leader is responsible for establishing, and adjusting as neces-
sary, the level of safety precautions appropriate to the individual hazardous
waste site (HWS) being evaluated such as use of SCBA, etc. The team
leader ensures that all participants conduct their work in accordance with
the study plan and applicable safety rules. He/she is authorized to direct
any assigned employee to leave the HWS if the employee fails to observe
safety requirements or in any way creates a safety hazard.
1. Information Review and Reconnaissance
Developing a safe plan of HWS investigation must be preceded by thorough
evaluation of existing data and a reconnaissance (see "Waste Disposal Site
Hazard Assessment Manual"). The information search may indicate possible
chemical hazards such as the presence of incompatible chemicals, toxic gases,
explosives, etc. Such indications will provide insight to specific safety
precautions needed. Similarly, a perimeter inspection or aerial imagery,
followed by an onsite reconnaissance, will reveal safety hazards requiring
special attention.
The safety precautions necessary in field investigations will normally
become more complex as the following order of tasks brings investigative
personnel progressively closer to actual contact with waste materials:
Environmental Measurements (Offsite)
(a) Ambient air
(b) Runoff
(c) Groundwater (existing wells)
(d) Peripheral test holes
Onsite Measurements (Accessible)
(a) Soil
(b) Spilled material
(c) Air
-------
XII-8
(d) Exposure (bioassay)
(e) Onsite wells
Onsite Measurements (Entry)
(a) Barrels
(b) Tanks
(c) Enclosed spaces
(d) Test holes
(e) Feed and process lines and valves
(f) Sewers and manholes
It follows that the safety considerations in design of the investiga-
tion indicate selection of investigative methods that will minimize hazards
to personnel and the public, and meet project objectives (i.e., enforcement
or cleanup).
The information review and reconnaissance should also include careful
examination of possible hazards to the public. Such hazards may include
contamination of groundwater supplies by drilling operations, release of
toxic gases, or explosion/fire. Any such hazards must be avoided or eli-
minated, or appropriate measures must be taken to protect the public and
public property. Any indication of the presence of explosives is to be the
basis for an initial investigation and appropriate followup by Army Explosive
Ordinance Disposal (EOD) personnel or police explosives unit.
Before entry on a suspect or known HWS, all investigative personnel
must know the locations and emergency telephone numbers for the nearest
medical facility, ambulance service, fire department, police department,
poison control centers [see Appendix F], and EPA Office contact.
2. Field Sampling
a. Clean Area
-------
XII-9
During operations on a suspect or known HWS, a "clean" area must be
established outside the area of suspected contamination. At least one
backup team member* will remain in this area to:
i. Assist in emergency removal of team members from the
HWS in the event of accident or injury. The backup
must have readily available protective clothing,
breathing apparatus and first-aid equipment.
ii. Assist in moving equipment, samples, and supplies.
iii. Provide communication to emergency units.**
iv. Assist in decontamination or removal of contaminated
clothing from the individuals emerging from the con-
taminated area.
v. As appropriate, prevent entry of unauthorized persons
to the HWS while operations are underway.
vi. Provide other assistance as necessary, but with the
primary objective of facilitating safe transfer of per-
sonnel and equipment to and from the contaminated area.
b. Sampling Equipment
As a general rule, sampling equipment used on an HWS should be dis-
posable. Dippers, scoops, and similar devices for solids samples should be
buried onsite, or placed in plastic bags for disposal or later decontamina-
tion. Liquid samples from barrels or tanks should be withdrawn in inert
tubing, such as glass, and the tubing should then be broken and abandoned
within the barrel or tank. If incineration or recycling of barrel contents
* On-scene Project Leaders may exercise informed judgment regarding the
need for offsite backup at active sites, or in cases where sites have
been repeatedly entered or occupied without apparent harm. In any case
where doubt exists, the safe course of action must be taken.
** Radio contact must be maintained when visual contact cannot be main-
tained.
-------
XII-10
is contemplated, the tubing may be disposed of in other suitable containers,
or buried on the site. The widely discussed Composite Liquid Waste Sampler
(or "Coliwasa") is unsuitable for use on HWS investigations because it is
extremely difficult to decontaminate under field conditions.
D. CLOTHING
Protective clothing must be worn by all assigned personnel while on a
suspected or confirmed HWS, until sufficient data has been acquired to enable
the team leader to make an informed judgment regarding the need. The team
leader must weigh the fact that fatigue and alertness on the part of the
team members is a significant safety factor. Protective clothing is cumber-
some, hastens the onset of fatigue, and limits stay-time. In the absence
of clear indications that work can proceed safely without protective clothing,
required items include: chemical-resistant pants and jacket, rubber boots,
protective gloves, hard hat or head cover, face shield or chemical safety
glasses.
Disposable and reuseable clothing is available, and each has advan-
tages and disadvantages. The presently available disposable clothing is
fragile, easily torn, and especially vulnerable during cold weather. The
"bootees" that are furnished with this clothing are highly vulnerable and
are of limited value on rough ground or for walking through snagging objects.
Reuseable clothing is available in much sturdier fabric and is generally
preferred. The disadvantage is the necessity for decontamination onsite,
or careful packaging, shipment, and later decontamination. The reusable
suits are worn with heavy rubber slip-on boots, which are easily decontami-
nated onsite with reagent solution (see following page).
Full-decontamination of reusable suits is accomplished in two steps.
The first step is performed onsite using a reagent solution selected before-
hand, based on limited knowledge of chemical and biological hazards on the
site at that time. After cleansing, protective clothing is turned inside
out, if feasible, and sealed in plastic bags for return shipment. The
second decontamination step is taken later, after enough of the sample has
-------
xn-n
ON-SITE DECONTAMINATION OF PROTECTIVE CLOTHING
-------
XII-12
been laboratory-analyzed to determine what decontamination reagents are
most suitable for each case. This second cleaning is then performed by
personnel wearing disposable safety clothing. Waste decontamination
solution from the second step should be treated as hazardous waste and
disposed of according to appropriate regulations.
d. SCBA/Respirators
Self-contained breathing apparatus (SCBA) must be worn onsite when:
i. Still air conditions prevail.
ii. Containers of unknown or known hazardous materials are
being opened.
iii. When in enclosed spaces, such as unventilated buildings
or rooms.
iv. Under any circumstances where free-flow of air uncontami-
nated by toxics is in doubt.
In cases where the team leader has determined that onsite work may
proceed without use of SCBA, participating personnel must carry respirators
having organic vapor protection cartridges, or combination cartridges or
five-minute escape hoods. An oxygen meter should be used to determine that
at least 19.5% oxygen is present in the area where respirators are to be
used. Respirators or escape hoods should be donned immediately upon experi-
encing breathing difficulty, dizziness or other distress, strong taste or
smell, or mere judgement that precaution is in order. Once respirators or
escape hoods have been donned, team members should withdraw from the site
pending a decision by the Project Leader regarding continued operations.
Cartridge respirators should not be relied upon for protection from organic
vapors for extended periods. Escape hoods are th( preferred equipment.
Remember:
Respirator cartridges for organic vapors function as adsorbants.
Once adsorptive capacity is reached, the cartridge no longer
functions.*
* See Pritchard, J., "A Guide to Industrial Respiratory Protection", NIOSH,
Cincinnati, Ohio, June 1976.
-------
XII-13
Cartridge respirators do not supply oxygen. They are of no use
in oxygen deficient atmospheres.*
d. Sampling Procedures
Sampling methods are described in the "Waste Disposal Site Hazard Assess-
ment Manual." As indicated under "Field Sampling" above, disposable sampling
equipment should be used wherever possible. The guiding safety principle
is to prevent exposure of personnel doing sampling, packaging, shipping,
analysis, and to prevent exposure of others to spilled or residual waste
materials.
Containers (drums, tanks etc.) should only be sampled when necessary
to meet enforcement or cleanup requirements. Opening drums or other sealed
containers may be hazardous to sampling personnel unless proper safety pro-
cedures are followed. Gases can be released, or pressurized liquids can be
expelled. A drum should not be moved or opened unless it can be ascertained
beyond reasonable doubt that the drum is structurally sound. Drums standing
on end, with bung up, should be opened by pneumatic impact wrench, operated
from a remote site (see following page). Drums on sides may be opened simi-
larly if it is possible to safely rotate the drum so that the bung is high.
If the bung can be removed, sampling contained liquids may be safely accom-
plished by glass tube, which is then broken and discarded within the barrel.
A barrel that has a badly rusted bung, or that cannot be sampled as above,
may be safely sampled with a hydraulic penetrating device (see page XII-15)
operated remotely. The device is then abandoned in place, and disabled to
prevent further withdrawal of liquids. Sealed or closed tanks should be
opened remotely, using ropes to lift hatches, etc.
In general, metal sample containers should not be us ;d on HWS investi-
gations; if used, they must be grounded, preferably to the drum or tank
being sampled, while sample transfer is accomplished.
* See Pritchard, J., "A Guide to Industrial Respiratory Protection", NIOSH,
Cincinnati, Ohio, June 1976.
-------
XII-14
Remote bung removal. Man in back-
ground, dressed in protective cloth-
ing, operates bung-removal equipment
on drum in foreground.
Bung-removal equipment; drum
on end.
Equipment closeup.
Remote bung-removal setup;
drum on side.
REMOTE REMOVAL OF BARREL BUNG
-------
XII-15
**'2 '^j^sy^y'"- *iJt'.-~u>3r>'?3i
Remote operation of penetrating
sampling device.
Drum attachment, connecting
tube, and hand-held activator.
Sampling device penetrating drum.
Remote sampling equipment.
REMOTE SAMPLING
-------
XII-16
In all cases of entry into closed containers, the local fire depart-
ment should be asked to standby. In any case wherein presence of explo-
sives is suspected or known, the DPO is to be consulted regarding proce-
dures to be followed. In no event may FIT members knowingly handle ex-
plosives encountered on dump sites.
Subsurface sampling of an HWS can also create hazards to employees and
the public, unless adequate safety precautions are followed. Biodegradation
of refuse in dumps produces methane and other explosive gases. The escaping
gases may be ignited by drill rigs or other ignition sources. Drilling
into dump sites may cause discarded incompatibles to be mixed and thereby
create reactive mixtures. Dump sites where leachate plumes are contained
on impervious strata may be interconnected with producing aquifers if drill-
ing is not planned according to competent groundwater technology and data.
Drilling in HWS investigations should be confined to the periphery of
dump sites, with the objective of characterizing the leachate that may be
moving away from the site. If subsurface sampling of dump sites is neces-
sary, excavation must be accomplished by hand, and with spark-free equipment.
All drilling associated with HWS investigations must be accomplished
under the responsible supervision of a competent geohydrologist, groundwater
geologist, geological engineer, or a person similarly qualified by experience.
Drilling must be preceded by sweeps with metal detectors having a minimum
10-foot range, and drilling must be limited to areas where the presence of
buried drums or tanks is not indicated. Test holes must be cased or plugged
when the investigation is completed. Drilling operations are not to be
initiated by FIT personnel without the express direction of the DPO.
Ambient air sampling on an HWS must be accomplished with spark-free
equipment if explosive vapors are present (most hi-vol samplers are spark
sources).
Samples from HWS must not be preserved, or "fixed," by the addition of
chemicals (see "Waste Disposal Site Hazard Assessment Manual" regarding
cooling of samples in ice chests or refrigerators).
-------
XII-17
HWS sample volume should be the smallest consistent with analytical
requirements. Sample containers must, to the extent possible, be clean and
free of spilled or residual waste material, on the exterior of the container,
prior to shipment (see SECTION X, "Shipment of HWS Samples").
E. LEAVING THE SITE
Procedures for leaving the suspect contaminated area must be planned
before entry. Provision must be made for: decontamination and safe packing
of protective clothing; burial or safe packing of disposable gear; handling
of samples and preparation of samples for shipment; transfer of equipment,
gear, and samples from the "contaminated" area to the "clean" area; etc.
Sequences will depend on several variables such as SCBA inside or out-
side of protective clothing but must be worked out in advance.
F. TRAINING
Personnel to be assigned onsite duties in HWS investigations must be
provided hands-on training on simulated sites, to achieve competence in the
safety and operational aspects. Preparation for onsite investigations must
include detailed briefings, particularly for inexperienced personnel. The
requirement for planning and carefully-thought-out sequences must be stressed.
-------
APPENDICES
A EVIDENCE AUDIT AND DOCUMENT CONTROL CHECKLISTS FOR
HAZARDOUS WASTE SITE INVESTIGATIONS
B CHECKLIST FOR INSPECTION
C ORGANIC AND INORGANIC POLLUTANTS FOR ANALYSIS IN
HAZARDOUS WASTE SITE INVESTIGATIONS
D LETTER OF UNDERSTANDING PROVIDED EPA BY DOT
FOR ENVIRONMENTAL SAMPLES
E TRAINING OUTLINE
F POISON CONTROL CENTERS
-------
APPENDIX A
EVIDENCE AUDIT AND DOCUMENT CONTROL CHECKLISTS FOR
HAZARDOUS WASTE SITE INVESTIGATIONS
-------
A-l
EVIDENCE AUDIT CHECKLIST
Field Investigations Audit
Project No.
Project Location^
FIT Team
Date
Signature
Yes
No
Yes
No
Yes
No
1) Has a project coordinator been appointed?
Comments
2) Was a project plan prepared?
Comments
3) Was a briefing held for project participants?
Comments
Yes
No
4) Were additional instructions given to project
participants?
Comments
-------
A-2
Yes No 5) Is there a written list of sampling locations
and descriptions?
Comments
Yes No 6) Is there a list of accountable field documents
checked out to the project coordinator?
Comments
Yes No 7) Is the transfer of field documents from the
coordinator to field participants documented
in a logbook?
Comments
Yes No 8) Are samples collected as stated in the project
plan or as directed by the cordinator?
Comments
Yes No 9) Are samples collected in the type of containers
specified in the project plan or as directed
by the coordinator?
Comments
-------
A-3
Yes No 10) Are samples preserved as specified in the project
plan or as directed by the coordinator?
Comments
Yes No 11) Are the number, frequency, and type of samples
collected as specified in the project plan
or as directed by the coordinator?
Comments
Yes No 12) Are the number, frequency, and type of measure-
ments and observations taken as specified in the
project plan or as directed by the coordinator?
Comments
Yes No 13) Are samples identified with sample tags?
Comments
Yes No 14) Are blank and duplicate samples properly ident-
ified?
Comments
Yes No 15) Are sample tag serial numbers for samples split
with other organizations recorded in a logbook
-------
A-4
or on a chain-or-custody record?
Comments
Yes No 16) Are samples listed on a chain-of-custody record?
Comments
Yes No 17) Is chain-of-custody documented and maintained?
Comments
Yes No 18) Are quality assurance checks performed as
directed?
Comments
Yes No 19) Are photographs documented in logbooks as re-
quired?
Comments
Yes No 20) Have any accountable documents been lost?
Comments
-------
A-5
Yes No 21) Have any accountable documents been voided?
Comments
Yes No 22) Have any accountable documents been disposed of?
Comments
-------
A-6
EVIDENCE AUDIT CHECKLIST
Laboratory Activities
Project No.
Project Location Date
Signature
Contractor Laboratory
Yes No 1) Is a project plan available to laboratory
personnel or have instructions been given
by the coordinator or supervisor?
Comments
Yes No 2) Were all samples collected during the field
investigation received by the laboratory?
Comments
Yes No 3) Are sample tags on all containers?
Comments
-------
A-7
Yes No 4) Are samples received by laboratory accompanied
by a chain-of-custody record?
Comments
Yes No 5) Can custody of samples be traced from the time
of collection to receipt by the laboratory?
Comments
Yes No 6) "Mere the samples received under custody?
Comments
Yes No 7) Was the shipping container properly secured?
Comments
Yes No 8) Is a laboratory custodian designated?
Comments
Yes No 9) Were sample tags and chain-of-custody records
checked to see that information matches?
Comments
-------
A-8
Yes No 10) Were samples logged in to the laboratory
record?
Comments
Yes No 11) Are samples stored In a secure area?
Comments
Yes No 12) Are samples stored in a way to maintain pre-
servation?
Comments
Yes No 13) Are sample holding time limitations satisfied?
Comments
Yes No 14) Do laboratory records demonstrate personnel
transferring and receiving samples in the
lab?
Comments
Yes No 15) Once analysis is completed, are sample tags re-
moved and incorporated into the permanent
record? ;-
Comments
-------
A-9
Yes No 16) Are analytical methods documented and
available to analysts?
Comments
Yes No 17) Are quality assurance procedures documented
and available to analysts?
Comments
Yes No 18) Are quality assurance procedures recorded as
required?
Comments
-------
A-10
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-------
Document Control Audit
A-n
EVIDENCE AUDIT CHECKLIST
Project No.
Project Location
File Location
Date
Signature
Yes
No
1) Have the individual files been assembled (field
investigation laboratory)?
Comments
Yes
No
2) Is there an inventory for each file?
Comments
Yes
No
3) Is ther a list of accountable field documents?
Comments
Yes
No
4) Are all accountable field documents present or
accounted for? (fill out additional checklist)
Comments
-------
A-12
Yes No 5) Is there a document numbering system?
Comments
Yes No 6) Has each document been assigned a document control
number?
Comments
Yes No 7) Are all documents listed on the inventory acc-
ounted for?
Comments
Yes No 8) Are there any documents in the file xvhich are
not on the inventory?
Comments
Yes No 9) Is the file stored in a secure area?
Comments
Yes >o 10) Are there any additional project documents which
have been declared confidential?
Comments
-------
A-13
Yes No 11) Are there confidential documents stored in a
secure area separate from the other project
documents?
Comments
Yes No 12) Is access to the confidential files restricted?
Cotonents
Yes No 13) Have the confidential documents been marked or
stamped "Confidential"?
Comments
Yes No 14) Is the confidential information inventoried?
Comments
Yes No 15) Is the confidential information numbered for
document control?
Comments
Yes No 16) Have any documents been claimed confidential
under TSCA?
Comments
-------
EVIDENCE AUDIT ACCOUNTABLE DOCUMENT CHECKLIST
Project No.
Project Location_
Document Type
Date
Numbers Issued
Signature
Document
\Tn.
00
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
Returned
Comments
Document
Ho
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
89
90
91
92
93
94
95
96
97
98
99
100
Returned
Comments
-------
APPENDIX B
CHECKLIST FOR INSPECTION
-------
B-l
CHECKLIST FOR INSPECTION
I. ADMINISTRATIVE
1. Facility Name:
2. Facility FIPs No:_
3. Address: (include county, state and zip code):
4. Location (Latitude, Longitude: attach map if available)_
Owner or Responsible Official
Name
Business Address_
Phone No. AC
Owner of Realty
Name
Business Address
Phone No. AC /
Facility Representative Interviewed
Name
Title
Phone No. AC /_
Inspector
Name
Title/Division
Phone No. AC /
9, Inspection Participants (names, affiliations, phone nos.)
10. Date and Time of Inspection
11. Weather Conditions
12. Credentials Shown: Yes ( ) No ( )
13. Entry Denied: Yes ( ) No ( ) By Mhom_
Reason(s) for denial
14. Photographs Allowed: Yes ( ) No ( )
Reason(s) for denying photographs
-------
B-2
II. SITE INFORMATION
1. Type of Operation
Generator:
a) On-site disposal ( )
b) Off-site disposal ( ): Location
Storage: Describe
Treatment/Disposal: Percent of Waste
a) Incineration: ( )
b) Landfill: ( )
c) Landfarm: ( )
d) Biological Treatment: ( )
e) Chemical Treatment: ( )
f) Deep Well Injection: ( )
g) Surface Impoundment: ( )
h) Other: ( )
2. Site Active? Yes ( ) No ( ) Partially ( )
% Active
3. Authorization
a) NPDES Permit No.
b) SPCC Plan
c) State Permits_
d) Air Permits
e) Other
4. Records Available Yes ( ) No ( )
-------
B-3
5. Types of Wastes and Amounts at site (record the source of
i nformati on )
6. Area of site (include dimensions)_
7. Depth to groundwater (if known)
8. Distance to surface water from site, name, directions and use:
9. Access Controlled: Yes ( ) No ( ) How
10. Buildings and uses
11. Geology of Area
a) Known Fault Zone
b) Karst Zone
c) 100-year Flood Plain
d) Regulated Floodway
e) Wetland
f) Critical Habitat
g) Recharge Zone
-------
B-4
III. FIELD EVALUATION FACTORS (REQUIRES NARRATIVE RESPONSE)
1. Evidence of Soil Contamination
2. Evidence of Spills
3. Evidence of Runoff
4. Potential of or Actual Air Emissions
5. Existing or Potential Erosion Problems
6. ' Ponding_
7. Evidence of Environmental Damage (vegetation, wildlife, fish,
etc.)
8. Evidence of charred areas, smoke, etc.
9. Potential for Groundwater Contamination
10. Adequate Maintenance and Operation of Runoff Collection and
Control Systems
-------
B-5
11. Sewers or drains and terminus of flow
12. Placarding of Trucks Comply with DOT Regs_
13. Contingency and Emergency Plan_
14. Fire and Safety Plans
15. Evidence of Pumps, Hoses and other Equipment for Potential
Bypassing
16. Conditions which Required Immediate Notification of Regional
Office for Action
17. Distance to Nearest Water Supply Well:
18. Proximity to Public Buildings and/or Residences
19. Remarks
-------
B-6
IV. STORAGE FACILITIES
1. Storage Area has Continuous Impervious Base: Yes ( ) No ( )
2. Storage Areas has a Confinement Structure: Yes ( ) No ( )
3. Evidence of Leakage or Overf1ow_
4. Estimate of number of barrels/containers
5. Inventory of contents on barrels/containers
6. Number of Storage Tanks and Contents
7. Evidence of Leakage, Corrosion or Bulging of Barrels/Containers/
Storage Tanks
8. Storage Tanks Diked Adequately
9. Venting Method of Storage Tanks
10. Storage of Incompatible Wastes
-------
B-7
11. Container Washing and Reuse Practices
12. Disposal Methods for Empty Storage Containers
13. Types and Amounts of Wastes Stored_
-------
B-8
V. INCINERATORS
1. . Records of Waste Received Verified with Trial Burn Records:
Yes ( ) No ( ). List Chemicals Incinerated
2. Monitoring Equipment Functioning Properly: Yes ( ) No ( )
3. Maintenance of Emission Control Equipment Adequate: Yes ( )
No ( )
4. Records of Maintenance Kept: Yes ( ) No ( )
5. Combustion Efficiency Monitored: Yes ( ) No ( ) Explain:
6. Temperature, Gas Flow Rate, Retention Time Calcnlations, Volume
of Combustion Zone Monitored: Yes ( ) No ( )
7. Waste Flow Rate Monitored: Yes ( ) No ( )
8. Waste Feed Cut-Off Device Functioning Properly: Yes ( )
No ( )
9. Stack Test Conducted: Yes ( ) No ( ). Agency or Con-
tractor
EPA Method
Results
Compliance: Yes ( ) No ( )
10. Disposal Method of Scrubber Liquor
-------
B-9
11. Disposal Method of Fly Ash Quenching Wastewater_
12. Disposal Method of Fly Ash
13. Scrubbing Media (e.g. water, caustic, lime)
14. Type of Scrubber (e.g. spray chamber, packed bed)
15. Mist Eliminator
16. Opacity of Stack During Inspection (Wet or Dry Stack)_
17. Opacity Limitations, Regulating Agency_
18. Stack Construction, Height, Diameter
19. Acceptable and Accessible Monitoring Ports, Platform, Safety
Rails
20. Electricity Available: Yes ( ) No ( ) 110V_
220V
21. Type of Incinerator: Single Chamber ( ) Multiple Chamber
( ) Other
22. Auxiliary Fuel Type Rated Fuel Capacity_
Rated Waste Flow Rate
23. Type of Burner
24. Combustion Temperature Monitored: Yes ( ) No ( )
-------
B-10
25. Permit Limitations and Regulatory Agency^
26. Equipment Manufacture, Age and Appearance of Equipment_
27. Other Emission Control Equipment Description_
28. Remarks
-------
e-n
VI. LANDFILL DISPOSAL
1. Evidence of Site Instability (Erosion, Settling, Sink Holes,
etc.)
2. Evidence of Improper Disposal of Ignitable, Reactive, or
Volatile Wastes
3. Evidence of Improper Disposal of Bulk Liquids,-Semi-Solids,
and Sludges
4. Records of Burial Cells, Contents and Survey Benchmark
5. Wastes Surrounded by Sorbent Material
6. Evidence of Ponding of Water
7. Runoff Diversion Structures Effectively Constructed and Main-
tained
8. Evidence of Improper and/or Inadequate Draining
9. Type of Leachate Collection System_
10. Leachate Monitored (Analyses)
11. Leachate Collection System Adequately Maintained
12. Gas Production in Landfill: Yes ( ) No ( )_
13. Method of Gas Venting
-------
B-12
14. Gas Monitored: Yes ( ) No ( ) Regulations and Regula-
tory Agency
15. Adequate Closure of Inactive Portion of Landfill: Yes ( )
No ( ) Describe
16. Groundwater Monitoring Wells: Yes ( ) No ( )_
17. Record of Groundwater Contamination
18. Depth to Groundwater Table and Flow Direction
19. Depth of Landfill
20. Containment Liners, Construction Methods
21. Pretreatment (Volume Reduction, Chemical Fixation, Blending,
Detoxification)
22. Waste Volumes
23. Earth Moving Equipment
24. Backcover Procedures
25. Co-disposal Practices
26. Odors
-------
B-13
27. Citizen Acceptance
28. Remarks
-------
B-14
VII. LANDFARMING
1. Area and Dimensions and Number of Cells for Disposal Site
2. Depth of Soil/Waste Material_
3. Underlying Contaminated Material and Thickness
4. Depth to Groundwater and Flow Direction_
5. Leachate Collection
6. Waste Application Rate_
7. Type of Waste Applied_
8. Discing Frequency
9. Reuse Period
10. Contaminated Runoff Disposal/Treatment Method
11. Uncontaminated Runoff Disposal Method
12. Runoff Diversion Structures Effectively Constructed and
Maintained
13. Remarks
-------
B-15
VIII. SURFACE IMPOUNDMENTS
1. Stability and/or Condition of Imbankments_
2. Evidence of Instability (Erosion, Settling, etc.)
3. Evidence of Disposal of Ignitable or Reactive Wastes_
4. Waste Compatible with Impoundment_
5. Records Checked for the Contents and Location of Each Impound-
ment
6. Estimated Freeboard
7. Integrity of Liner System_
8. Soil Type for Banks, Berms and Bottom
9. Monitoring Wells and Analysis of Groundwater
-------
B-16
10. Deoth to Groundwater and Flow Direction
11. Volatile Organic Disposal_
12. Amount or Volume of Wastes Discharged to Impoundment
13. Size of Impoundment(s) (height, width, depth)
14. Evidence of Solids Deposition and/or Buildup_
15. Evidence of Solid Material (Drums, etc.) in Impoundment^
16. Impoundment Aerobic ( ) Anaerobic ( )
17. Spray System for Aeration or Accelerated Evaporation
18. Access Around Impoundments Controlled_
19. Remarks
-------
B-17
IX. BIOLOGICAL TREATMENT
1. Types of Treatment: Activated Sludge ( ) Trickling Filter
( ) Lagoon ( ) Other
2. Types of Treatment Units Employed and Sizes (Attach Flow
Diagram) ' ' '
3. Wastes Treated and Volumes
4. Design Capacity (Avg & Max) Flow_
5. Wasteload (BOD, Solids, etc.)
6. Treatment Efficiency
7. Operation Characteristics (F/M, MLVSS, % Recycle, etc.)
8. Effluent Discharge Location_
9. NPDES Permit No. Is:uinq Agency_
Conditions
-------
B-18
10. NPDES Compliance ( ) Non-Compliance ( }
11. Discharge Monitoring Reports on File
12. Laboratory Conducting Self-Monitoring Analyses
13. Self-Monitoring Procedures Correct_
14. Bypassing Evident_
15. Remarks
-------
B-19
X. PHYSICAL-CHEMICAL TREATMENT
1. Types of Treatment (Describe)_
2. Types of Treatment Units Employed and Sizes (Attach Flow
Diagram)
3. Wastes Treated and Volumes
4. Design Capacity (Avg and Max) Flow
5. Waste Loading Rate_
6. Treatment Efficiency
7. Operation Characteristics
8. Effluent Discharge Location
9. NPDES Permit No. Issuing Agency-
Conditions
-------
B-20
10. NPDES Compliance ( ) Non-Compliance ( )
11. Discharge Monitoring Reports on File
12. Laboratory Conducting Self-Monitoring Analysis
13. Self-Monitoring Procedures Correct_
14. By-passing Evident
15. Remarks
-------
APPENDIX C
ORGANIC AND INORGANIC POLLUTANTS FOR ANALYSIS IN
HAZARDOUS WASTE SITE INVESTIGATIONS
Part 1 - Modified Priority Pollutants List
Part 2 - Inorganic Pollutants to be Measured in
Environmental Samples Collected During Waste Site Investigations
-------
APPENDIX C (Part 1)
C-l
Parameter
MODIFIED PRIORITY POLLUTANTS LIST
October 1979
Method No.
CAS No.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
acenaphthene
acrolein
acrylonitrile
benzene
benzidine
carbon tetrachloride
chlorobenzene
1 ,2,4-trichlorobenzene
hexachlorobenzene
1 ,2-dichloroethane
1 ,1 ,1-trichloroethane
hexachloroethane
1 ,1-dichloroethane
1 ,1 ,2-trichloroethane
1 ,1 ,2,2-tetrachloroethane
chloroethane
bis(2-chloroethyl )ether
2-chloroethyl vinyl ether
625
603,624
603,624
624
625
624
624
625
625
624
624
625
624
624
624
624
625
624
83-32-9
107-02-8
107-13-1
71-43-2
92-87-5
56-23-5
108-90-7
120-82-1
118-74-1
107-06-2
71-55-6
67-72-1
75-34-3
79-00-5
79-34-5
75-00-3
111 -44-4
110-75- 3
-------
C-2
19. 2-chloronaphthalene 625 91-58-7
20. 2,4,6-trichlorophenol 625 88-06-2
21. 4-chloro-3-methyl phenol 625 59-50-7
22. chloroform 624 67-66-3
23. 2-chlorophenol 625 95-57-8
24. 1,2-dichlorobenzene 625 95-50-1
25. 1,3-dichlorobenzene 625 . 541-73-1
26. 1,4-dichlorobenzene 625 106-46-7
27. 3,3'-dichlorobenzidine 625 91-94-1
28. 1,1-dichloroethene 624 75-35-4
29. trans-l,2-dichloroethene 624 156-60-5
30. 2,4-dichlorophenol 625 120-83-2
31. 1,2-dichloropropane 625 78-87-5
32. trans-1,3-dichloropropene 624
33. cis-1,3-dichloropropene 624
34. 2,4-dimethylphenol 625 105-67-9
35. 2,4-dinitrotoluene 625 121-14-12
36. 2,6-dinitrotoluene 625 606-20-2
37. 1,2-diphenylhydrazine 625 122-66-7
38. ethyl benzene 624 100-41-4
39. fluoranthene 625 206-44-0
40. 4-chlorophenyl phenyl ether 625 7005-72-3
41. 4-bromophenyl phenyl ether 625 101-55-3
42. bis(2-chloroisopropyl)ether 625 39638-32-9
-------
C-3
43. bis(2-chloroethoxy)methane 625 111-91-1
44. methylene chloride 624 75-09-2
45. chloromethane 624 74-87-3
46. bromomethane 624 74-83-9
47. bromoform 624 75-25-2
48. bromodichloromethane -624 69-4
49. fluorotrichloromethane 624 75-69-4
»
50. dichlorodifluoromethane 624 75-71-8
51. chlorodibromomethane 624 128-48-1
52. hexachlorobutadiene 625 87-68-3
53. hexachlorocyclopentadiene 625 77-47-4
54. isophorone 625 78-59-1
55. naphthalene 625 91-20-3
56. nitrobenzene 625 98-95-3
57. 2-nitrophenoV 625 88-75-5
58. 4-nitrophenol 625 100-02-7
59. 2,4-dinitrophenol 625 51-58-5
60. 4,6-dinitro-2-methylphenol 625 534-52-1
61. N-nitrosodiphenylamine 625 621-64-7
62. N-nitrosodipropylamine 625 86-30-6
63. pentachlorophenol 625 87-86-5
64. phenol 625 108-95-2
65. bis(2-ethylhexyl)phthalate 625 117-81-7
-------
C-4
66. benzyl butyl phthalate 625 85-68-7
67. di-n-butyl phthalate 625 84-74-2
68. di-n-octyl phthalate 625 117-84-0
69. diethyl phthalate 625 84-66-2
70. dimethyl phthalate 625 131-11-3
71. benzo(a)anthracene 625 56-55-3
72. benzo(a)pyrene 625 50-32-8
%
73. benzo (b) fluoranthene 625 205-99-2
74. benzo(k)fluoranthene 625 207-08-9
75. chrysene 625 218-01-9
76. acenaphthylene 625 208-96-8
77. anthracene 625 120-12-7
78. benzo(ghi)perylene 625 191-24-2
79. fluorene 625 86-73-7
80. phenanthrene - 625 85-01-8
81. dibenzo(ah)anthracene 625 53-70-3
82. indeno(l,2,3-ce)pyrene 625 193-39-5
83. pyrene 625 129-00-0
84. tetrachloroethene 624 127-18-4
85. toluene 624 108-88-3
86. trichloroethene 624 79-01-6
87. vinyl chloride 624 75-01-4
88. 2,3,7,8-tetrachlorodibenzo 613 1746-01-6
-p-dioxin
-------
C-5
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
al drin
dieldrin
chlordane
4,4'-DDT
4,4'-DDE
4,4'-DDD
endosulfan I
endosulfan II
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
a-BHC
b-BHC
d-BHC
g-BHC (lindane)
toxaphene
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625* '
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
608,625*
309-00-2
60-57-1
57-74-9
50-29-3
72-55-9
72-54-8
115-29-7
1031-07-8
72-20-8
7421-93-4
76-44-8
1024-57-3
319-84-6
319-85-7
319-86-8
58-89-9
8001-35-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
*Pesticides and PCB's are verified by Method 625 if detected at levels
adequate for analysis by 625.
-------
C-6
Method No. Reference
603 "Acrolein and Acrylonitrile - Method 603",
Federal Register, Vol. 44, No. 233, Monday,
December 3, 1979, p 69479.
608 "Organochlorine Pesticides and PCB's - Method 608",
Federal Register, Vol. 44, No. 233, Monday, Decem-
ber 3, 1979, p 69501.
613 "2,3,7,8-Tetrachlorodibenzo-p-dioxin- Method 613",
Federal Register, Vol. 44, No. 233, Monday, Decem-
ber 3, 1979, p 69526.
624 "Purgeables - Method 624", Federal Register, Vol. 44,
No. 233, Monday, December 3, 1979, p 69532.
625 "Base/Neutrals, Acids and Pesticides - Method 625".
-------
C-7
APPENDIX C (Part 2)
Inorganic Pollutants to be Measured in Environmental Samples Collected During
Waste Site Investigations
Elements to be identified and measured by Inductively Coupled Argon Plasma
Spectrometer.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
Aluminum
Chromium
Barium
Beryllium
Cadmium
Cobalt
Copper
Iron
Lead
Nickel
Manganese
Zinc
Boron
Vanadium
Calcium
Magnesium
Sodium
Minimum Reporting Level, ug/1
50
10
10
2
5
10
20
20
40
20
10
10
10
10
100
100
100
Elements to be identified and measured by Flame/Flameless Atomic Absorption
Spectrometer.
1.
2.
3.
4.
5.
6.
7.
Arsenic
Antimony
Selenium
Thai!ium
Mercury
Tin
Silver
Minimum Reporting Level, ug/1
10
20
10
10
1
20
20
Inorganic parameters to be identified and measured by other procedures.
Minimum Reporting Level, ug/1
1.
2.
3.
4.
5.
6.
Ammonia
Fluoride
Sulfide
Cyanide
PH
TOC
100
200
50
10
within 0.1
2,000
pH units
-------
APPENDIX D
LETTER OF UNDERSTANDING PROVIDED EPA BY DOT
FOR ENVIRONMENTAL SAMPLES
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
D-]
«
OFFICE OF ENFORCEMENT
MEMORANDUM
SUBJECT: Compliance with Department of Transportation
Regulations In The Shipment of Environmental
Laboratory Samples
FROM:
TO:
Deputy Assistant Administrator for
Water Enforcement (EN-335)
Deputy Assistant Administrator for Drinking
Water (WH-550)
Deputy Assistant Administrator for Monitoring
and Technical Support (RD-680)
Deputy Assistant Administrator for Water Planning
& Standards (WH-551)
Regional Administrators
Director-NEIC
Laboratory Directors
Department of Transportation (DOT) regulations covering
the transport of hazardous materials are contained in 49 CFR
Parts 170-179. EPA is affected by these regulations whenever
employees or age:-. .3 ship by commercial carrier those materials
designated as hazardous by DOT. The greatest impact of these
regulations falls upon programs which rely on commercial air
carriers for the rapid transport of environmental samples
with short holding times.
Pursuant to EPA Order 1000, the following information -
will serve as national guidance for the water media to assure
compliance with DOT regulations in transporting environmental
laboratory samples including: drinking water, ambient water,
treated effluent, biological specimen, sediment, wastewater
treatment plant and water treatment plant sludge and other
environmental laboratory samples.
-------
D-2
1. Unprcserved Samples of Drinking Water, Ambient
Water, Treated Effluent, Biological Specimen,
Sediment, Wastewater Treatment Plant and
VJater Treatment Plant Sludge
Normal unpreserved environmental laboratory samples
collected by EPA employees are not regulated under DOT
Hazardous Materials Transportation Regulations and may be
shipped using current EPA packaging and handling procedures.
2. Preserved Samples of Drinking Water, Ambient Water,
Treated Effluent, Biological Specimen, Sediment,
Wastewater Treatment Plant and Water Treatment
Plant Sludge
Table 1 lists the common preservatives and preservation
techniques used by EPA which are designated as hazardous
in DOT'S Hazardous Material Table, 49 CFR §172.101. When
samples are preserved in the recommended manner they may be
shipped as non-hazardous samples. Check with the appropriate
person designated pursuant to paragraph 6 of this memorandum
for the proper packaging and labeling procedures.
3. Other Samples
Some environmental samples collected by EPA employees,
such as untreated sewage and industrial process samples,
samples from spill investigations or sludges from some
industrial processes may contain concentrations of contam-
inants in excess of those normally encountered in preserved
or unpreserved samples of drinking water, ambient water,
Sewage sludge from publicly owned wastewater treatment
works and solid or dissolved material in domestic sewage or
in industrial discharges subject to NPDSS permit regulations
will be exempted from classification as hazardous waste under
draft regulations proposed by the Office of Solid Waste on
September 13, 1978.
2
Letter from Alan I. Roberts, Associate Director for
Hazardous Materials Regulation, Materials Transportation Bureau,
DOT, dated 4/11/79, (Attachment A) concurrs with this EPA procedu
For the purposes of this memorandum, samples of untreatet
wastewater or sludge from publicly owned wastewater treatment
works are considered to be "diagnostic specimens" and subject
to general packaging requirements specified in 49 CFR ',[173.24,
but excluded from the requirements for transportation of
etiologic agents as specified in 49 CFR 11173.387.
-------
treated effluent, biological specimen, sediment, wastewater
treatment plant and water treatment plant sludge. If such
samples are collected and shipped by air, and the sample
contaminant material may pose an unreasonable risk to health,
safety, or property when transported in commerce, the shipper
or employee must check for the technical name of the material
(if known) in the DOT Hazardous Materials Table. If the con-
taminant material is designated in DOT's Hazardous Materials
Table, and the concentration and/or volume of the contaminant
material meets the definition of the hazard class listed
for the contaminant, the sample must be shipped pursuant to
applicable DOT regulations. If the technical name of the
sample contaminant material is not known, the DOT regulations
place the burden on the shipper to determine if the sample
meets the definition of a hazardous material. In the case
of samples being forwarded to a laboratory for analysis, it
is assumed that the shipper would have some information
concerning the sample and, based on that information, be
able to make a reasonable determination whether or not the
sample is likely to be classified as a hazardous material.
When a reasonable doubt exists as to whether a sample is
subject to DOT regulations, the shipper should consult the
appropriate person with the responsibility for hazardous
materials transportation, designated pursuant to this
memorandum, as to the appropriate procedures to follow in
the shipment of the sample.
4. Reagents
Reagents which are designated as hazardous under
the DOT's Hazardous Material Table, 49 CFR §172.101, must
be shipped pursuant to the appropriate DOT regulations.
Nitric acid in any concentration is forbidden on passenger
carrying aircraft or railcars.
For investigations where nitric acid must be used
for metals preservation, means other than transport by
passenger-carrying aircraft or railcars must be used to
transport the acid to the site of investigation.
5. Training
An integral part of compliance with DOT's Hazardous
Materials Transportation Regulations is the institution of
an employee training program. EPA Water Media Program
Offices are presently investigating the applicability of
-------
D-4
*&*
14
-------
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D-5
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Attachment A
D-6
DEPARTMENT OF TRANSPORTATION
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION
WASHINGTON. D.C. 2O59O
APR 1 I 1979
REFER TO:
Mr. Jeffrey G. Miller
Deputy Assistant Administrator
for Water Enforcement
United States Environmental
Protection Agency
Washington, D.C. 20460
Dear Mr. Miller:
This is in response to your letter of March 2, 1979, concerning the
application of the Department of Transportation's (DOT) Hazardous Materials
Regulations for shipment of small quantities of vater samples containing
various reagents. Enclosure A to your letter was an application for
exemption in the event that is necessary, and Enclosure B to your letter
was a proposed memorandum to certain of the Environmental Protection
Agency's field activities involved in the various water-programs.
As you probably know, this Office recently issued an exemption to the
Environmental Protection Agency permitting the air shipment of analytical
standards consisting of sealed glass ampules of 25 ml capacity with
special overpack protection (DOT-E 8116, copy enclosed).' Of particular
concern to us in evaluating the data submitted to" support that exemption
was the potential hazards of permitting shipment by air of analytical
standards containing water solutions of nitric acid in concentrations of
up to 5% by weight. We were able to issue the exemption because of the
excellent packaging proposed to be used which virtually ensures that the
small volumes shipped by air in this manner would not pose a credible
transportation risk.
In reviewing your March 2 letter, we note and concur in the recommended
packaging described in your Enclosure B. However, after a review of the
available literature, we are of the opinion that water solutions of those
materials, in the concentrations described in Enclosure B, which are
represented at 49 CFR 172.101 by asterisked entries, do not meet any
of the hazard class definitions in the Hazardous Materials Regulations.
Ue are similarly of the opinion that the water solutions as described
in that enclosure of materials represented at 49 CFR 172.101 by non-
asterisked entries do not pose a threat to health and safety or property
when transported in commerce. Accordingly, we would take no exception
to those solutions as described being offered for transportation and
transported as not subject to the Hazardous Materials Regulations.
-------
D-7
In summary, the Hazardous Materials Pv.egulati.ons do not apply to the
following materials:
1. HC1 in water solutions at concentrations of 0.04% by
weight or less.
2. HgCl2 in water solutions at concentrations of 0.004%
by weight or less.
x
3. HN03 in water solutions at concentrations of 0.15% by
weight or less.
4. H2SO^ in water solutions at concentrations of 0.35% by
weight or less.
5. NaOH in water solutions at concentrations of 0.080% by
weight or less.
6. H3?0^ in water solutions at concentrations yielding a.
pH range between 4 and 2.
We remind you that the person who offers such materials for transportation
is responsible for ensuring that the concentrations are as represented.
Sincerely,
+ H
Alan I. Roberts
Associate Director for
Hazardous Materials Regulation
Materials Transportation Bureau
Enclosure
-------
Enclosure C
D-8
Recommended
Environmental Protection Agency Procedures for
Shioment of Environmental Laboratory Samples
The Environmental Protection Agency's (EPA) recommended
procedure for packaging environmental laboratory samples meets
the following Department of Transportation (DOT) standard re-
quirement for all packages as specified in 49 CFR Section 173.24:
(a) Each package used for shipping hazardous materials...
shall be so designed and constructed, and its contents so
limited, that under conditions normally incident to
transportation
(1) There will be no significant release of the
hazardous materials to the environment;
(2) The effectiveness of the packaging will not be
substantially reduced; and
(3) There will be no mixture of gases or vapors in
the package which could, through any credible spon-
taneous increase of heat or pressure,'or through an
explosion, significantly reduce the effectiveness of
the packaging.
In addition, shipments by air must meet the requirements at
49 CFR Section 173.6:
(a) Each package .... shall be so designed and constructed,
and its contents so limited, that under conditions normally
incident to transportation
(1) There will be no significant release .... materials
to the environment.
(2) Inner containers that are breakable (such as
earthenware, glass, cr brittle plastic), must be pack-
aged to prevent breakage and leakage under conditions
normally incident to transportation. These completed
packagings must be capable of withstanding a 4-foot
drop on solid concrete in the position most likely to
cause damage. Cushioning and absorbent materials must
not be capable of reacting dangerously with the
contents....
-------
D-9
(3) Fpr any packaging with a capacity of 110
gallons or less containing liquids, sufficient
outage (ullage) must be provided to prevent liq-
uid contents from completely filling the packaging
at 130° F, The primary packaging (which may include
composite packaging), for which retention of the
liquid is the basic function, must be capable of
withstanding, without leakage, an internal absolute
pressure of no less than 26 lbs./sq. inch or no
less than the sum of the absolute vapor pressure of
the contents at 130° F. (55° C.) and the atmos-
pheric pressure at sea level, whichever is greater.
(4) Stoppers, corks, or other such friction-type
closures must be held securely, tightly and effec-
tively in place with wire, tape, or other positive
- means. Each screw-type closure on any inside plastic
packaging must be secured to prevent the closure
from loosening due to vibration or substantial changes
in temperature.
EPA recommended packaging procedures for environmental
laboratory sample shipments are outlined below. Emergency or
unique pollution incidents or field logistics may require de-
viation from recommended EPA procedures, however the packaging
requirements of 173.6 and 173.24 must always be met. The
following general premises should be considered when packaging
any EPA environmental laboratory sample:
(1) Sample volume should be limited to the quantity
necessary to conduct the requisite analysis and the
smallest appropriate container should ba used.
(2) Plastic containers should be used unless EPA
approved analytical methods 'require glass.
(3) Plastic or glass containers should have screw-type
lids. If it is necessary to use stoppers, corks or
other suction-type closures, they must be held securely
-------
D-10
in place with wire or tape.
(4) EPA analytical methods recommend that samples be
preserved with ice at a temperature of approximately
4° C. Ice should be placed in sturdy plastic bags or
containers which can be sealed to minimize ice water
leakage. Where dry ice is required to preserve animal
tissue and the specimen is to be offered for transpor-
tation by aircraft, then it must be packed in packaging
designed and constructed to permit the release of carbon
dioxide gas. The airline should be notified well in
advance of shipment. The package should be marked
"carbon dioxide, solid" or "dry ice" and "frozen diag-
nostic specimens".
EPA Recommended Procedures
1. Shipping Container - All sample containers are to be placed
inside a strong outside shipping container. This container must
be able to withstand a 4-foot drop on solid concrete in the
position most likely to cause damage. A metal picnic cooler
lined inside vith hard plastic meets this test. Care must be
taken to secure the drainage hole at the bottom of the cooler
so that if a sample container leaks or ice water leaks through
the ice bag, the contents cannot escape through the drainage
hole. The container should be.taped shut in order to obtain
as much of a seal as possible around the lid to prevent any
-------
D-ll
leakage should the cooler be turned over.
The shipping container must be marked "THIS END
UP" and arrows which indicate the proper upward position
of the container should be affixed. A sticker containing
the agency program office's name and address must be
placed on the outside container.
2. Glass Containers - The container's screw-type lids
should be tightened before it is placed in the shipping
container. Glass bottles should be separated in the
shipping container by cushioning (e.g. styrofoam) or
absorbent material (e.g. blotting paper or newspaper) to
prevent contact with other objects and eliminate breakage.
For example, a 1-gallon glass bottle (organic samples) can
be placed in two carved out styrofoam sheets which secure
the bottle at the top and bottom. Small glass bottles
(volatile organic samples) can be placed inside 1-quart
plastic cubic containers with screw-type lids to minimize
breakage and contain any leakage.
3. Plastic Containers - Polyethylene bottles or cubic
containers do not require cushioning material to prevent
breakage but do need to be protected from punctures by
sharp objects. Caps should be tightly screwed on before
the plastic container is placed in the shipping container.
-------
D-T2
4. Ice can be placed in separate plastic bags and sealed,
or in large-mouthed cubic containers with lids. As an
alternative, sample bottles and ice can be placed together
in a large sturdy plastic bag which will provide an ad-
ditional waterproof lining to the shipping container.
After all sample containers have been carefully arranged
and ice has been added, then the plastic bag should be
tightly closed with wire, tape or other positive means.
-------
APPENDIX E
TRAINING OUTLINE
-------
E-l
U.S. ENVIRONMENTAL PROTECTION AGENCY
TRAINING OUTLINE FOR EMPLOYEES ENTERING SITES OF UNKNOWN TOXICITY
1. PURPOSE OF TRAINING
xo Ensure that EPA employees are aware of the hazards of their job and
that they perform their work in a manner where risk to personal
health and safety is reduced to the greatest extent feasible.
o Ensure that regard for the health and safety of the employees of
other agencies, the public, and the environment is maximal.
o To comply with all laws, rules, and regulations to safeguard the
health and safety of its employees, the public, and the environment.
o Increase the personal confidence of employees to react responsibly
and to handle emergency situations in a safe manner.
2. GENERAL FIELD SAFETY TECHNIQUES (Recommended 4 hours of instruction)
o Responsibilities
Site surveillance/observation/plan development
. Restricted zones
Safe zones
. Rules for VIP's
o Vehicles (cars, trucks, mobile labs, boats, aircraft, etc.)
. Inspection
Operation
. Mandatory rules, regulations, and orientation
Checklist
o Hazardous Materials in the Field
Hazards
Storage
Transportation (DOT requirements for common sample preservatives,
plus general "common sense" rules.)
-------
E-2
o Use of Field Equipment and Supplies
. Work Tools
Testing Equipment
Sampling Equipment
. Checklist
o Working Alone (Buddy System)
. Isolated Areas
Streams, Rivers, Lakes
Hazardous Waste Sites
. Hazardous Materials Spills, etc.
o Work Limitations
Weather (severe, inclement, hot, cold)
Fatigue
Hours of Work
3. PERSONAL PROTECTIVE EQUIPMENT AND CLOTHING (Minimum 8 hours instruction
o General
o Availability
o Respiratory Protection
Selection
. Fit
Donning and Use
o Personal Protection Apparel
Clothing (gloves, aprons, coveralls, etc.)
Disposable
Reusable
Totally enclosed suits
-------
E-3
Eye Protection
Foot Protection
Head Protection
Hearing Protection
o Limitations of Clothing and Equipment
o Decontamination of Clothing and Equipment
o Disposal of Contaminated Clothing and Equipment
o Hands on Practical Exercise w/Protective Clothing and/or
Equipment
4. EMERGENCY HELP AND SELF-RESCUE (Minimum 8 hours instruction)
o Recommended Supplies
o Principles of First Aid
. Restoration of Breathing
Control of Bleeding
Recognition and Treatment of Physical Shock
. Open and Closed Wounds and Burns
. Franctures and Dislocations
. Transportation
o Cardiopulmonary Resuscitation
o Availability of Emergency Services
Poison Control Centers
. Hospitals and Ambulance Services
. Army EOD,
. Local fire and police departments
-------
E-4
o How to Obtain Emergency Treatment in the Field
o How and when to file a report of accident/incident
o Employee Compensation Benefits
5. SAMPLING TECHNIQUES (Recommended 4 hours instruction)
o Hazards of Sampling
o Amount of Samples
o Containers for Samples
o Field Tests, Yes or No?
Radioactive
Explosivity
. Other
o Sample Security
o Packaging (DOT/EPA)
o Shipment (DOT/EPA
6. FREQUENCY OF TRAINING
o New or inexperienced employees should complete 24 hours of initial
training before beginning their duties, and at least 8 hours of
refresher training annually.
o Experienced employees should complete 8 hours of initial refresher
training and at least 8 hours of refresher training annually.
7. RECORD OF TRAINING
o A record of training should be maintained in the employee's official
personnel file.
-------
APPENDIX F
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