vvEPA
United States . Environmental Monitoring Systems
Environmental Protection Laboratory
Agency Las Vegas NV 89114
EPA/600/4-84/075
April 1985
Research and Development
Characterization of
Hazardous Waste
Sites—A Methods
Manual, Volume I—
Site Investigations
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EPA/600/4-84/075
April 1985
CHARACTERIZATION OF HAZARDOUS
WASTE SITES--A METHODS MANUAL
VOLUME I
SITE INVESTIGATIONS
Patrick J. Ford
Paul J. Turina
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
EPA Contract No. 68-03-3050
EPA Project Officer
Charles K. Fitzsimmons
Advanced Monitoring Systems Division
Environmental Monitoring Systems Laboratory
Las Vegas, Nevada 89114
Prepared for
Lockheed Engineering and Management
Services Company, Inc.
Las Vegas, Nevada 89114
ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
LAS VEGAS, NEVADA 89114
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/600/4-84/075
2.
3. RECIPIENT'S ACCESSION NO.
PB85-215960
4. TITLE AND SUBTITLE
Characterization of Hazardous Waste Sites -- A
Methods Manual, Volume I-Site Investigations
5. REPORT DATE
i I 1985
Apri
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Patrick Ford, Paul Turina, GCA Corporation
8. PERFORMING ORGANIZATION REPORT NO.
). PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Monitoring Systems Laboratory
Office of Research & Development
U.S. EPA
Las Vegas, NV 89114
10. PROGRAM ELEMENT NO.
D109
11. CONTRACT/GRANT NO.
68-03-3050
12. SPONSORING AGENCY NAME ADDRESS
U.S. EPA-EMSL-Las Vegas
P.O. BOX 15027
Las Vegas, NV 89114
13. TYPE OF REPORT AND PERIOD COVERED
ProJ ect Report
14. SPONSORING AGENCY CODE
EPA/600/07
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Site investigations is the first of three volumes of a methods manual prepared to
give guidance on information gathering activities in support of the requirements
specified in the National Oil and Hazardous Substances Pollution Contingency Plan.
The National Contingency Plan contains a seven-phase approach to implementing the
authority of the Comprehensive Environmental Response, Compensation, and Liability
ACT (CERCLA). Each phase represents a level of response dependent upon the
situation, information must be obtained to determine the appropriate level of
environmental response.
Both remedial and enforcement actions under CERCLA require reliable site information.
This volume describes approaches to obtaining this information and follows a semi-
chronologicaI order through subsequent phases of the National Contingency Plan.
These steps range for preliminary data gathering, to site inspections, to large
field investigations.
KEY WORDS AND DOCUMENT ANALYSIS
DESCIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
18. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19. SECURITY CLASS (This Report)
UNCLASSIFIED
21. NO. OF PAGES
258
20. SECURITY CLASS (This page)
UNCLASSIFIED
EPA Form 2220_1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE ^
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CHARACTERIZATION OF HAZARDOUS
WASTE SITES--A METHODS MANUAL
VOLUME I
SITE INVESTIGATIONS
Patrick J. Ford
Paul J. Turina
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
EPA Contract No. 68-03-3050
EPA Project Officer
Charles K. Fitzsimmons
Advanced Monitoring Systems Division
Environmental Monitoring Systems Laboratory
Las Vegas, Nevada 89114
Prepared for
Lockheed Engineering and Management
Services Company, Inc.
Las Vegas, Nevada 89114
ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
LAS VEGAS, NEVADA 89114
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NOTICE
The information In this document has been funded wholly or in part by
the United States Environmental Protection Agency under contract number
68-03-3050 to Lockheed Engineering and Management Services, Inc. and
subcontract to GCA Corportation/Techno logy Division. It has been subject
to the Agency's peer and administrative review, and it has been approved for
publication. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
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FOREWORD
Under guidance from an Agency-Wide Steering Group, this manual has been
prepared by EPA's Office of Research and Development (ORD), primarily to provide
methods to Agency program, regional, and enforcement offices, and secondarily,
to provide guidance to states and contractors for characterization of hazardous
waste s i tes.
At the first meeting of the Agency-Wide Steering Group for the Development
of a Methods Manual for Characterization of Hazardous Waste Sites in August
1981, the scope of the planned Available Methods Manual was expanded from
sampling and analysis to site characterization. The steering group agreed that
samp I ing and analysis of hazardous wastes must be closely tied to samp I ing and
analysis strategy. Before methods can be useful, they must be related to the
purposes and objectives of sampling and analysis. Such an association leads to
the necessity of considering a I I aspects of hazardous waste site
characterization.
The objective of this manual is to provide field and laboratory managers,
investigators, and technicians with a consolidated source of information on the
subject of hazardous waste site characterization. The manual covers the range
of endeavors necessary to characterize hazardous waste sites, from preliminary
data gathering to sampling and analysis.
Because of the large number of subjects covered in this manual and the
need to provide detai led methodology in the areas of samp I ing and sample
analysis, this manual comprises three volumes:
Volume I - Site Investigations
Volume II - Available Sampling Methods
Volume III - Available Laboratory Analytical Methods
Volume I, the main text of the manual, discusses in somewhat general terms
the many aspects of field investigation, the intent being to provide a working
out I ine for the characterization process and to serve as a framework for the
subsequent volumes. In this respect, Volumes II and III can be thought of as
technical supplements to Volume I which build on the fundamental concepts and
principles laid down in that document.
Volume I, Site Investigations, is a composite of several works. Much of the
text was originally derived from the National Enforcement Investigation Center
(NEIC) April 1980 draft manual, "Enforcement Considerations for Evaluation of
Uncontrolled Waste Disposal Sites by Contractors" and supplemented with
i i i
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information contained in the Office of Emergency and Remedial Response (OERR)/
Ecology and Environment, Inc., June 1981, draft manual "Technical Methods for
Investigating Sites Containing Hazardous Substances." Throughout subsequent
drafts additional sources of material, either published or unpublished, were
used and are cited in the body of the text, where appl icable.
Volume I I, Aval I able Samp I ing Methods and Volume III, Aval I able Analytical
Methods are products of extensive literature and protocol review resulting in a
collection of proven procedures for sampling and analyzing hazardous wastes.
Both volumes are "Standard Methods" style manuals with Volume II organized by
media and Volume III further subdivided by specific compounds or classes of
compounds.
IV
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ABSTRACT
Site investigations is the first of three volumes of a methods manual
prepared to give guidance on information gathering activities in support of
the requirements specified in the National Oil and Hazardous Substances Pollu-
tion Contingency Plan. The National Contingency Plan contains a seven-phase
approach to implementing the authority of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). Each phase represents a
level of response dependent upon the situation. Information must be obtained
to determine the appropriate level of environmental response.
Both remedial and enforcement actions under CERCLA require reliable site
information. This volume describes approaches to obtaining this information
and follows a semi chronological order through subsequent phases of the National
Contingency Plan. These steps range from preliminary data gathering, to site
inspections, to large field investigations.
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VI
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CONTENTS
Foreword Hi
Abstract v
Figures ix
Tables ix
Acknowledgment x
1, Introduction 1-1
Statutory Authority 1-1
Administration 1-2
2, Administrative Procedures and Legal Considerations 2-1
Introduction 2-1
Investigative Conduct 2-1
Documentation 2-3
Qua I ity Assurance 2-17
Responses to Requests for Information 2-23
Entry 2-24
Zone Contracts 2-28
3, Safety 3-1
Introduction 3-1
Policy and Responsibility 3-1
Education and Training 3-3
Development of a Health and Safety Plan 3-4
Preliminary Onsite Evaluation 3-4
Standard Onsite Safety Practices. ... 3-7
Levels of Protection 3-10
Control at the Site 3-16
Work Zones 3-17
4, Preliminary Data Gathering 4-1
Introduction 4-1
Sources of Data 4-1
Data Needs 4-5
5, Site Inspection 5-1
Introduction 5-1
Ons ite Inspection 5-2
Offsite Inspection 5-4
6, Data Evaluation 6-1
Introduction 6-1
Options for Action 6-5
VI I
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CONTENTS (continued)
7. Field Investigations 7-1
Introduction 7-1
Preparation Of the Sampling Plan 7-2
Implementation of the Samp I ing Plan 7-30
8 . Bibl iography 8-1
9. Glossary 9-1
Append ices
A. Evidence Audit Checklists A-1
B. Potential Hazardous Waste Site Preliminary Assessment Form . . B-1
C. Potential Hazardous Waste Site Inspection Report C-1
D. Recommended Equipment Inventory D-1
E. Field Characterization of Hazardous Waste E-1
F. Packaging, Marking, Labeling, and Shipping of Hazardous Waste
Site Samples F-1
VI I I
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FIGURES
Number Page
1-1a Flow Diagram of the Superfund Site Management Plan 1-3
1-1b Flow Diagram of the Enforcement Site Management Plan 1-4
2-1 Sample Col lection Tag 2-6
2-2 Chain-of-Custody Form 2-8
2-3 Receipt for Sample Form 2-9
7-1 Organization of the Operations Area 7-22
TABLES
Page
6-1 Data Required for Evaluation 6-3
6-2 Comprehensive List to Rating Factors 6-6
7-1 Emergency Communications 7-31
7-2 Radio Capabilities and Limitations 7-32
7-3 Field-Expedient Communication Devices 7-33
IX
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ACKNOWLEDGEMENT
The project officer is indebted to the many contributions to this work.
Special acknowledgement must be given to Mr. Barrett Benson, NEIC, and Mr. Dave
Jackson, Ecology and Environment, Inc. who supplied the bulk of the draft material
initially used to develop the first draft of this manual.
Also to Mr. Rod Turpin, EPA/ERT-Edison and Mr. William Keffer, EPA Region
VII who provided significant portions of Section 7 and to Mr. Roy Murphy, OWPE,
and Mr. Richard Stanford, OERR, whose valuable input assisted in the development
of the organization and functional compatibi I ity of the document.
Finally, special thanks are given to members of the Steering Group who
provided guidance and information for this manual.
Barrett Benson
Michael Birch
Wi I I iam Blackman
John Bowman
Karen Burgan
Barbara Davis
Thomas Evans
Charles Fitzsimmons
David Friedman
Fred Haeberer
Robert Hannesschlager
Josephine Huang
Wi I I iam Keffer
Richard Kent
John Koutsandreas
National Enforcement
Investigation Center
Reg i on 4
National Enforcement
Investigation Center
Occupational Health and Safety
Staff
Office of Emergency and Remedial
Response
Office of Waste Programs
Enforcement
Office of Waste Programs
Enforcement
Environmental Monitoring Systems
Laboratory - Las Vegas
Office of Sol id Waste
Office of Emergency and Remedial
Response
Reg i on 5
Office of Monitoring Systems and
Qua I ity Assurance
Region 7
Occupation Health and Safety
Staff
Office of Monitoring Systems
and Qua I ity Assurance
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M. Douglas Lair Region 7
Eugene Meier Environmental Monitoring Systems
Laboratory - Las Vegas
Ted Meiggs National Enforcement Investigations
Center
Chuck Morgan Office of Waste Programs Enforcement
J. Roy Murphy Office of Waste Programs Enforcement
Kenneth Partymi Iler Office of Waste Programs Enforcement
Jim Poppiti Office of Solid Waste
Florence Richardson Office of Solid Waste
Cl iff Risely Region 5
Richard D. Spear Region 2
James Stiebing Region 6
Christopher Timm Office of Monitoring Systems and Quality
Assurance
Rodney Turpin Region 2
David Weitzman Occupational Health and Safety Staff
The following contractors have met with the Steering Group and have edited
and written much of the material in the Methods Manual.
Kevin Cabbie Lockheed EMSCO
Paul Fennely GCA/TechnoIogy Division
Patrick Ford GCA/TechnoIogy Division
Paul Friedman Ecology and Environmental, Inc.
RusseII PIumb Lockheed EMSCO
Paul Turina GCA/TechnoIogy Division
XI
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SECTION 1
INTRODUCTION
STATUTORY AUTHORITY
The control of hazardous substances and the prevention of the entry of
these substances into the environment is the objective of several acts passed
by Congress. Rules regulating various aspects of hazardous waste can be
attributed to the Toxic Substances Control Act (TSCA); the Clean Water Act
(CWA); the Clean Air Act (CAA); the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA); the Safe Drinking Water Act (SDWA); the Resource
Conservation and Recovery Act (RCRA); and in 1980, the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). RCRA and
CERCLA are the two that are most often associated with hazardous waste site
investigations.
RCRA was passed to control industrial and municipal solid wastes,
including sludges, slurries, etc., and to encourage the recovery of useful
materials and energy from these wastes. The act also called for a tracking
system to document the generation, transport, and disposal/storage of solid
wastes. The discovery of a large number of uncontrolled and abandoned
hazardous waste sites, such as at Love Canal, NY and Valley of the Drums, KY,
prompted a much greater emphasis on the hazardous nature of the wastes. The
regulations and resources of RCRA are now primari ly devoted to the control of
hazardous wastes, with a lesser emphasis on nonhazardous sol id wastes. So
great is the problem, that in 1980, legislation aimed at providing federal
money for the cleanup of inactive waste disposal sites was enacted. The
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
often called the "Superfund Act", provides regulatory agencies with the
authority to deal with inactive sites, funds to deal with hazardous waste
emergencies and a means to assign the I iabi I ity of cleanup to the responsible
parties. It also provides monies (Superfund) to pay for the mitigation of
hazards from abandoned sites when no responsible party can be found or when the
responsible party refuses to take action. In addition, it enpowers the
government to seek compensation from responsible parties to recover funds used
in mitigation actions.
Section 105 of the CERCLA requires that the National Contingency Plan
(NCR), developed under the Clean Water Act, be revised to include procedures and
standards for responding to releases of oi I and hazardous substances. The
revised plan reflects and effectuates the responsibilities and powers created
by the Act.
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Subpart F of the NCR, Hazardous Substance Response, establ ishes a seven-
phase approach for determining the appropriate extent of a response authorized
by CERCLA when any hazardous substance is released or there is a substantial
threat of such a release into the environment, or there is a release or
substantial threat of a release of any pollutant or contaminant which may
present an imminent and substantial danger to the public health or welfare.
Each phase presented below sets specific criteria to establish the need
for further action and progress into subsequent phases.
- Phase I - Discovery and Notification
- Phase II - Preliminary Assessment
- Phase I I I - Immed i ate RemovaI
- Phase IV - Evaluation and Determination of Appropriate Response -
PI anned RemovaI and Remed i a I Act i on
- Phase V - Planned Removal
- Phase VI - Remedial Action
- Phase VII - Documentation and Cost Recovery
This phased approach is the basis for implementation of all CERCLA -
authorized Hazardous Substance Responses.
ADM INISTRATI ON
The NCP provides for a broad base of authorities to act within its
guidance. In addition to the EPA and the U.S. Coast Guard, the Plan requests
and encourages States to undertake authorized actions, and directs the EPA to
provide funds to States (under cooperative agreements) for such actions.
The Plan does not specify the mechanisms for implementation of the seven
phases. The various EPA offices, primarily the Office of Emergency and Remedial
Response (OERR) and the Office of Waste Programs Enforcement (OWPE), as well as
the individual States each have developed programs specific to their needs in
accordance with the NCP.
Figure 1-1 i Ilustrates the series of tasks developed by OWPE and the
essentially parallel tasks developed by OERR to implement the Plan. OWPE is
charged with the enforcement of Phase VII - Documentation and Cost Recovery.
As such, their investigation will differ from OERR, who is focused on remedial
activities (Phases I-VI). Regardless of this difference in emphasis, the
efforts of both offices are directed toward meeting the criteria of the various
phases of the NCP. A common component of both programs is the need to gather
data. The U.S. Environmental Protection Agency has prepared a three-volume manual
to provide field and laboratory managers, investigators and technicians with a
consolidated source of information and guidance on data gathering procedures
including preliminary site assessment, sample collection, and sample analysis.
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Superfund Site Management Plan
M^^H
Negotiate
Consent Decree
1-3
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Enforcement Site Management Plan
Responsible
Party
Se»rch
Notice
Letter
Fmanoiel
Assessment
Enforcement
Record of
Decision
1-4
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This three-volume manual identifies available procedures, provides detailed
guidance for implementing these procedures, and provides a framework for
assessing research needs in the area of hazardous waste characterization method-
ology. The contents of each volume is summarized below.
Volume I. Site Investigations provides a management strategy for
undertaking an Investigation of a hazardous waste site.
Volume I I. Ava i IabIe Samp I i ng Methods provides a discussion of aval I able
sampling techniques and guidance on the appropriate use of each
technique.
Volume III. Available Laboratory Analytical Methods provides guidance on
preparation and analysis of hazardous waste samples and other
environmental samples that may be collected during a site
i nvest i gat i on.
Volume I, Site Investigations describes policies and procedures common to
all data gathering efforts, such as personal conduct, document control, and
quality assurance. Additionally, guidance is provided on the extent to which
safety precautions which must be considered. Subsequent sections provide a
framework for gathering the required information. They detail what information
is necessary, where that information can be found and how the information can
be acqu i red.
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SECTION 2
ADMINISTRATIVE PROCEDURES
INTRODUCTION
The understanding of certain administrative procedures and legal
considerations prior to the onset of onsite actions is paramount for successful
program management. The purpose of this section, therefore, is to present
topics such as investigative conduct, documentation and recordkeeping, quality
assurance, site entry, etc., from the viewpoint of Agency policy. Although
this discussion is based on EPA policy, it can serve as a guideline for anyone
conducting a hazardous waste site investigation. Where necessary, the
technical aspects of these topics will be addressed in subsequent sections of
this document.
INVESTIGATIVE CONDUCT
ProfessionaI ism
Personnel are expected to perform their duties in a professional and
responsible manner. Persons conducting hazardous waste site investigations must:
* develop and report the facts of an investigation completely,
accurately, and objectively;
* conduct themselves at all times in accordance with the regulations in
the EPA handbook Employee Responsibilities and Conduct (Title 40 CFR,
Part 3) or in other pertinent guidelines for personnel conduct;
* avoid, in the course of an investigation, any act or fai lure to act
which could be considered to have been motivated by reason of
personal or private gain; and
* make a continuing effort to improve their professional knowledge and
technical ski I Is.
Prohibited Actions
Attempted Bribery--
Money 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 whitewash a serious violation or
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condition, or to cause the withholding of damaging information or observations.
Investigative personnel must:
0 ask "What is this for?" if offered something of value;
0 explain politely, if the offer is repeated, that both parties to such
a transaction may be guilty of violating the Federal statutes;
0 not accept money or goods of any kind; and
0 immediately report the incident in detail to their supervisor.
Conflicts of Interest--
A conflict of interest may exist whenever an EPA employee has a personal
or private interest in a matter which is relevant 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 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 reprint
publication Employee Responsibilities and Conduct (Title 40 CFR, Part 3).
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 contractual or
financial relationship with EPA, which has interests that may be substantially
affected by such employee's official actions, or which conducts operations
regulated by EPA. Acceptance of food and refreshments of nominal value, such
as luncheon during a plant tour where the arrangements are consistent with the
transaction of officiaI-business, is an exception.
Good public relations and common sense require that personnel dress
appropriately for the circumstances. When conducting an offsite reconnaissance
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 3.
Pub I ic Relations
It is important that cooperation be obtained and good working relationships
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 derogatori ly of any person, regulatory
agency, manufacturer, or industrial product. All information acquired in the
course of duty is for Official Use Only.
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DOCUMENTATION
General
Hazardous waste site investigations generally involve several government
program offices, a number of private contractors, scores of individuals, and
often generate enormous volumes of information. This information must be
collected and maintained within a system that allows for precise and expedient
access. Further, it must protect all records as potential evidence that may be
required for enforcement actions. It is therefore imperative that a comprehen-
sive document control system be implemented during all phases of an evaluation.
For a number of years, EPA's National Enforcement Investigations Center
(NEIC) has provided guidance for the careful recording and tracking of all
information, data, and samples collected in support of an environmental
investigation, especially with respect to enforcement. This guidance can be
found in the NEIC Policies and Procedures Manual. EPA-330-78-001R, May 1978
(revised December 1981 ), which serves as the basis for this subsection as well
as Appendix D of Volume-ll.
The advent and current widespread use of personal computers further
enhances the usefulness and ease with which data can be managed in support of
enforcement actions and site characterization. Using either custom developed
software or currently available data base management software, computer
assisted document control systems have proven successful for handling, tracking
and manipulating large quantities of information with relative ease. Compared
to manual record keeping practices, these automated systems can be of great
utility. Although not meant to be a replacement for physical evidence (field
logs, tags, labels, etc.) these systems can alleviate tedious record searching,
sorting, and storage tasks and can provide quick and easy retrieval of
information with cross references to stored evidentiary material.
Document ControI
The purpose of document control is to assure that a I I project documents
issued to or generated during hazardous waste site investigations will be
accounted for when the project is completed. The purpose is achieved through a
program which makes all investigation documents accountable. This should
include serialized document numbering, document inventory procedures, and an
evidentiary filing system.
Accountable documents used or generated during investigations include:
• Project Work Plans,
* Project Logbooks,
* Field Logbooks,
* Sample Data Sheets,
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* Sample Tags,
* Chain-of-Custody Records and Seals,
* Laboratory Logbooks,
• Laboratory Data, Calculation, Graphs, etc.,
• Sample Checkout,
* Sample Inventory,
* Internal Memos,
* External Written Communication,
* Business Confidential Information,
• Photographs, Drawings, Maps,
* Quality Assurance Plan,
• Litigation or Enforcement Sensitive Documents, and
• Final Report.
Each document bears a serialized number and is listed, with the number, in
a project document inventory assembled at the project's completion. Volume II,
Appendix D, provides further discussion of Document Control/Chain-of-Custody
Procedures.
Serialized Documents--
All serialized documents are assigned to the Document Control Officer.
The Document Control Officer 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 Document Control
Officer wi I I maintain a I 1st of the serial ized project documents that were
issued to personnel for that project.
Project Logbooks--
The logbook of the team leader wi I I document the transfer of logbooks to the
individuals who have been designated to perform 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 inspect ion/invest!gat ion.
All logbook entries must be dated, legible, and initialed and contain
accurate and inclusive 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 or other terminology which might prove
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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.
Individuals must sign each logbook assigned to them.
Field Data Records--
Serialized Field Data Records (FDRs) 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 information
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
FDRs 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.
Sample I dent ificat ion--
All necessary serialized sample tags are distributed to field personnel by
the team leader or designated team member. Individuals are accountable for
each tag assigned to them. A tag is considered to be in their possession until
it has been fi I led 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 are accountable for all serially-numbered documents
including tags. Tags attached to those samples split with the source or another
government agency are accounted for on a Sample Receipt Record. Figure 2-1
illustrates an example of an acceptable sample tag.
Chain-of-Custody Records--
Each person involved with the sample must know Chain-of-Custody procedures.
The procedures should be included in the Project Plan or be published and
available to all personnel. Due to the evidentiary nature of sample collecting
investigations, the possession of samples must be traceable from the time that
samples are collected until they are introduced as evidence in legal proceedings.
To maintain and document sample possession, Chain-of-Custody procedures are
foI I owed.
Serialized Chain-of-Custody Records (e.g., Figure 2-2) are assigned and
accounted for in a manner similar to that used for sample tags. If samples are
transferred to the laboratory, the white original is filed in the laboratory's
designated security container. The carbonless copy of the Custody Record is
returned to the team leader. A similar procedure is followed when dispatching
samples via common carrier, mail, etc., except that the original accompanies
the shipment and is signed and retained by the receiving laboratory sample
custodian. The carbonless copy is retained by the team leader.
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Figure 2-1. Sample Collection tag.
2-6
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td ky (Sn««luitl
Rlttntd ky IS<|iMtuttl
N 1000
Figure 2-2. Chain-of-custody form.
-------
When samples are spl it with the source or another government agency, the
tag serial numbers from all splits are recorded on the Sample Receipt Form
(Figure 2-3). A copy of the receipt form will be provided for the receiving
agency and the original returned to the team leader.
When movies, slides or photographs are taken which show the effluent or
emission source inspection activities and/or any sampling of 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.
Samp Ie Custody -- A sample is under custody if:
it is in your actual possession;
it is in your view, after being in your physical
possession;
it was in your physical possession and then you locked it up to
prevent tampering; or
* it is in a designated and identified secure area.
-------
RECEIPT FOR SAMPLES
PROJ NO
PROJECT NAME
SAMPLERS lS,gn.lu,»>
Split Samples Offered
( ) Accepted ( ) Declined
SI* NO
1
DATE
TIME
J_
1
I
1
"1
I
u
•
s
'
S
-------
Field Custody Procedures--
* 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 fieldwork. As few
people as possible should handle the samples.
The sampler is personally responsible for the care and custody of the
samples until they are properly transferred or dispatched.
Sample tags shall be completed for each sample, using waterproof ink
unless prohibited by weather conditions.
During the course and at the end of the field work, the Team Leader
determines whether these procedures have been followed, and if
additional samples are required.
Transfer of Custody and Shipment--
* Samples are accompanied by a Chain-of-Custody Record. When trans-
ferring 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 mobi le laboratory, or to the permanent
laboratory.
Samples will be properly packaged for shipment and dispatched to the
appropriate laboratory for analysis with a separate signed Custody
Record enclosed with the shipment. Shipping containers will be
padlocked 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 fi lament tape or breaking the seal
to unwrap the tape. The seal is then signed. The "Courier to Air-
port" space on the Chain-of-Custody Record shall be dated and signed.
Whenever samples are spl it with a faci I ity or government agency, a
separate Sample Receipt is prepared for those samples and marked to
indicate with whom the samples are being split.
* Custody Seals. Custody seals should be made of 1" x 6" U.L. I itho tape with
security slots. This tape is backed with a very strong self adhesive so that
once stuck to itself it wi I I not come apart without breaking the seal.
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* All packages wi I I be accompanied by the Chain-of-Custody Record
showing identification of the contents. The original Record will
accompany the shipment, and a copy wi I I be retained by the Project
Leader.
* If sent by common carrier, a Bill of Lading must be used. Receipts
of Bills of Lading and shipping documents as we I I as a I I receipts
wi I I be retained as part of the permanent documentation.
Corrections to Documentation--
As previously noted, all original data recorded in logbooks, Field Data
Records, Sample Tags, Custody Records, Sample Receipt Forms, and other data
sheet entries are written with waterproof ink. None of the accountable
serial ized documents I isted 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 individual,
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 corrected 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, or a properly tagged sample was not transferred with a formal Chain-of-
Custody Record, a written statement is prepared detailing how the sample was
collected, and whether it was 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 or Document Control Officer and to the project fi le.
Document Numbering System and Inventory Procedure--
To provide document accountability to the appropriate individuals, each of
the document categories discussed above features a unique serialized number for
each item within the category. Logbooks, Field Data Records, Sample Tags,
Chain-of-Custody Records, and Sample Receipt Forms are serially numbered by the
Document Control Officer before assignment to the team leader. The logbooks
and Field Data Records 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. Documents are then listed on an inventory sheet.
Confidential Information--
EPA recognizes four classifications of confidential information. These
are: (1) Business Confidential, (2) Enforcement Sensitive, (3) Enforcement
Confidential, and (4) National Security Classification. Each is described
be Iow.
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Business Confidential--The environmental statutes specify EPA reporting
and recordkeeping requirements which in turn protect trade secrets and business
confidential information. However, EPA is extremely reluctant to accept this
type of information unless it is necessary for carrying out Agency functions
under these Acts.
In compliance with EPA regulations, an Agency request for Company
information, pursuant to statutory authority, will contain a statement allowing
the faci I ity to designate all or part of the information requested by the
Agency as business confidential by marking it according to Title 40 of the Code
of Federal Regulations (CFR), Part 2, Subpart B, Sections 2.201-2.309 [41
Federal Register (FR) 36902, September 1, 1976, as amended in 43 FR 39997,
September, 1978]. In addition to citing the appropriate reguI ation(s), the
request should state that:
1. The business may, if it desires, assert a business confidentiality
claim covering part or all of the information in the manner described
by 40 CFR 2.203(b), and that information covered by such a claim will
be disclosed by EPA only to the extent, and by means of the procedures,
set forth in those regulations; and that
2, If no such claim accompanies the information when it is received by
the EPA, it may be made aval I able to the pub I ic by EPA without further
notice to the business.
When conducting a plant evaluation, inspection, or reconnaissance, field
personnel should not accept business confidential information unless it is
essential in performing their responsibilities. When inspectors expect to
obtain or observe business confidential information, they should maintain
a separate logbook. When business confidential information is entered into an
inspector's logbook, the entire book and the portions containing the business
confidential information are marked. In those limited situations, the Company
should be requested to provide the Agency with a written statement identifying
the material which is entitled to business confidential treatment. In addition,
reasons must be given to substantiate the claim, including any supportive
technical data or legal authority. By statute, effluent and emission data are
not business confidential. Any business confidential information received in
the mail or hand-delivered shall be marked Business Confidential and handled
appropriately as outlined in the document control program.
A separate, locked file is maintained for the segregation and storage of
all business confidential and trade-secret information. Upon receipt by the
team this information is directed to and recorded in the Business Confidential
Inventory Log by the Document Control Officer (DCO). 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 its
security. Business confidential information may not be reproduced except upon
approval by and under the supervision of the DCO. 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
2-12
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system. Business confidential documents may not be destroyed except upon
approval by and under the supervision of the DCO. The team leader will be
notified prior to destruction of business confidential information. The DCO
shall remove and retain the cover page of any business confidential information
disposed of for one year and shalI keep a record of the destruction in the
Business Confidential Inventory Log.
Enforcement Sensitive--As defined by the Office of Enforcement Counsel-
Monitoring (OEC-M) materials considered to be enforcement sensitive include but
are not I imited to:
* Documents* discussing the strengths or weaknesses of the government's
or the opposing party's legal position.
Documents discussing the strengths or weaknesses in the government's
evidence or the strategy and scope of efforts for gathering of such.
Documents listing the names of potential witnesses and/or describing
other evidentiary material prior to discovery.
Documents discussing the strategy to be employed in litigation and
the t i metabIe.
Documents discussing negotiation or settlement strategy, including
do Ilar amounts.
A number of documents have already been designated "enforcement sensitive"
by the Office of Enforcement Counsel-Monitoring. When in the judgment of a member
of the Office of Sol id Waste and Emergency Response (OSWER) staff, a document
is believed to be potentially "enforcement sensitive," the document (or other
material) is to be submitted to the Director of the Office of Waste Programs
Enforcement (OWPE). The OWPE Director will then forward the document to the
Associate Administrator for OEC-M and to the General Counsel, requesting a
determination as to the "enforcement sensitive" nature of the material. OEC-M,
in consultation with the Department of Justice, will be the office responsible
for designating materials as "enforcement sensitive." No one else may apply
such a designation. However, such materials will be labeled "enforcement
confidential" by the OWPE while the OEC-M is considering whether the material
is "enforcement sensitive."
Al I OSWER "enforcement sensitive" materials will be stored in a safe
location OWPE. Each "enforcement sensitive" document will be so stamped at
the bottom of each page of the document. Where the material is not a written
document (such as a Lexitron disk or a tape) the jacket should be stamped
"enforcement sensitive."
*Note: The term "document" includes books, records, correspondence, memoranda,
papers, notes, computer printouts, tapes, floppy disks, evidence and similar
material. It covers originals, drafts, duplicates and copies. Materials may
be handwritten, printed, or machine encoded.
2-13
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No materials designated "enforcement sensitive" are to be retained anywhere
in the OSWER outside the designated secured area without the written consent of
the OWPE Director.
All "enforcement sensitive" materials will be placed in red folders. A
complete list of all materials contained in a particular folder shall be placed
in the folder. They will be grouped according to the enforcement case.
Access to these materials will be on a need-to-know basis. Assuming most
if not a I I such materials wi I I relate to specific open enforcement cases, the
OWPE Regional Coordinator, in consultation with an attorney will determine
immediately, or in the future as soon as a new case is opened, who should have
routine access to enforcement sensitive materials associated with that case.
This "routine access" list must be approved by the OWPE Director designee.
Once that approval is given, persons on the approved list will be able to
access the "enforcement sensitive" files through the procedures outlined below.
No one else may access the files without the instance-by-instance approval of
the OWPE Director.
Access to the "enforcement sensitive" fi les wi I I be control led by the
secretary to the OWPE Deputy Director. He/she will maintain a log which will
include a complete listing of materials within the safe, and space for time
(day and hour) dated sign-out and sign-in of "enforcement sensitive" materials.
Procedures will be established for including such information as the handling
of the materials by those who check them out, or whether the materials were
shown to anyone else, and whether they were xeroxed.
Word processor disks on which material determined to be "enforcement
sensitive" is stored must also be retained in the safe. Any office or person
whose duties include development of such materials should identify a disk which
will be solely dedicated to storage of "enforcement sensitive" materials.
Enforcement Confidential--This is an internal Office of Solid Waste and
Emergency Response designation for those documents whose security should be
assured. Enforcement confidential materials include but are not limited to:
Materials proposed for classification as enforcement sensitive but
not yet formally designated.
Scientific documents which have not yet had a peer review.
Preliminary working papers or analyses whose disclosure might cause
confusion or unnecessary public concern.
* Data which have not as yet been evaluated or analyzed.
* Internal memoranda expressing the personal views of various staff
from the agency whose disclosure may be harmful to open exchange
within EPA.
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In general these are materials which, if disclosed, may impair the Agency's
ability to freely and fully initiate or prosecute an enforcement action. It is
crucial that all parties understand that all cases may eventually go to trial,
and therefore, case material must be handled accordingly.
The protection afforded "enforcement confidential" materials will be much
less rigorous than that for "enforcement sensitive" materials. All "enforcement
confidential" materials must be kept in bar-locked files, or equally secure
areas. The OWPE Director or designee should inspect and approve such file
areas. Files may be kept in individual offices or work areas. A complete
listing of "enforcement confidential" materials must be compiled for each case.
This listing is to be maintained, and a copy retained, by the person in posses-
sion of the fi le. A copy of the I 1st ing should also be kept by the Chiefs,
Compliance and Technical Support Branches, and the Secretary to the Deputy
Director who will maintain the "enforcement sensitive" files.
National Security Confidential--The United States Government classifies
certain materials as confidential in order to protect National security. This
classification system has four designations:
1. For Official Use Only (FOUO)
2, Confidential
3, Secret
4, Top Secret
Higher classification status also exists, but those documents are never
handled by EPA. For a complete description of this system refer to the
Department of Defense.
Team Fi les--
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 clean (no handwritten comments) copies of documents for
their personal files only after persona I Iy ver i fy i ng that the original or
similar copy is in the team file. Documents that have been declared "Confi-
dential" 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.
Evidentiary F i le--
When the team has completed the project objectives, all inventoried file
documents are reviewed and submitted to the 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 document
cI asses. Atyp i ca I format is illustrated be Iow.
2-15
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A. Project Plan
B. Project Logbooks
C. Field Data Records
D. Sample Identification Documents
E. Chain-of-Custody Records
F. Sample Receipt Forms
G. Correspondence
1. Intra-office (Contractor)
2. EPA
3. Industry
4. Record of Confidential Material
H. Report Notes, Calculations, etc.
I. References, Literature
J. Sample (on-hand) Inventory
K. Check-out Logs
L. Litigation Documents
M. Miscellaneous - photos, maps, drawings, etc.
N. Final Report
Once deposited in the Evidentiary File, documents may only be checked out
through the Document Control Officer.
Reports--
AlI 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. If reports are for enforcement cases they are further labeled as
"Enforcement Confidential" unless a case attorney assigns a higher classifi-
cation. 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.
Evidence Audits--
Evidence audits may be conducted by Regional or Headquarters personnel,
NEIC, or by a Contractor Evidence Audit Team (CEAT) which is located in Denver,
Colorado. Evidence audits will be structured around the "Field Investigations
Audit Checklist" and "Document Control Audit Checklist" (Appendix A). Evidence
audits may examine procedures and records, at the field site, laboratories,
Regional Offices, or combinations thereof. (See "NEIC Procedures Manual for
the Evidence Audit of Enforcement Investigations by Contractor Evidence Audit
Teams," September 1981).
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QUALITY ASSURANCE
General
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 situa-
tion which may be encountered in the field or laboratory. 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 a field investigation.
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 qua I ity of the data be assured. Obtaining qua I ity 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 and implementation of comprehensive and well documented quality
assurance (QA) program. Decisions concerning sampling site selection, the
frequency of samp I ing, the number of samples to be collected, the procedures
involved in the collection, preservation and transport of samples, the calibra-
tion and maintenance of instruments, and the processing, verification and
reporting of the data must incorporate the concepts out I ined in the qua I ity
assurance program. If careful attention is not paid to these concepts, the
possibility of producing invalid data is highly probable. Such data wastes
resources, leads to bad management decisions, and confounds enforcement actions.
Management personnel and/or their representatives will coordinate the QA program
through the team leader.
Organization and Personnel
Management personnel must have a firm commitment to the production of
quality data and to quality performance by all employees. Moreover, this
commitment to qua I ity must be demonstrated by management and transmitted to a I I
of the personnel involved in an investigation or study.
Management is responsible for maintaining the resume and job description
of each person involved in the design, supervision, conduct or analysis of any
study or test involving hazardous waste. Such records should be maintained for
a period of 3 years following completion of any hazardous waste investigation.
This is important because resume 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.
Quality Assurance Program
Quality Assurance Plan-Scope--
The EPA agency-wide quality assurance policy states that every monitoring
and measurement project must have a written and approved Quality Assurance
2-17
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Project Plan. As defined, the QA project plan is a written document which
presents, in specific terms, the policies, organization, objectives, functional
activities, and specific QA and Quality Control (QC) activities designed to
achieve the data quality goals of a specific project or continuing operation.
Requirements call for a separate QA plan to be prepared for each specific
project or continuing operation (or group of similar projects or continuing
operations). It may be prepared as a section or an appendix of a project
specific technical plan (see Section 7) or as a stand alone document. The plan
should specify measurement activities and procedures which will be used to
document and report: precision, bias, representativeness, and completeness of
environmental measurements. It provides a line of communication for a given
project which will assist management personnel in maintaining a record of pro-
gress as we I I as an idea of the extent of any QA deficiencies that might exist.
All Quality Assurance Project Plans must be prepared in accordance with
"Interim Guidelines and Specifications for Preparing Quality Assurance Project
Plans," QAMS-005/80, December 29, 1980 prepared by the Office of Monitoring
Systems and Quality Assurance. In general, this specifies that the document
must be prepared using a document control format consisting of information
placed in the upper right hand corner of each page. This information should
consist of:
• Section Number
• Revision Number
* Date (of Revision)
* Page
It also specifies that the plan must address the following 16 essential elements:
1. Title page with provision for approval signatures
2, Table of contents
3, Project description
4, Project organization and responsibility
5, QA objectives for measurement data in terms of precision, accuracy,
completeness, representativeness and comparabi I ity
6, Sampling procedures
7, Samp Ie custody
8. Calibration procedures and frequency
9. Analytical procedures
10. Data reduction, validation and reporting
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11. Internal quality control checks and frequency
12. Performance and system audits and frequency
13. Preventive maintenance procedures and schedules
14. Specific routine procedures to be used to assess data precision,
accuracy and completeness of specific measurement parameters involved
15. Corrective action
16. Quality assurance reports to management
Responsibi I ities--
Intramural Projects -- Each Project Officer working in close coordination
with the QA Officer is responsible for the preparation of a written QA Project
Plan for each intramural project that involves environmental measurements.
This written plan must be separate from any general plan normally prepared for
the project. The Project Officer and the QA Officer must ensure that each
intramural project plan contains procedures to document and report precision,
bias, representativeness, accuracy and completeness of all data generated.
ExtramuraI Projects -- Each Project Officer working in close coordination
with the QA Officer has the responsibi I ity to see that a written QA Project
Plan is prepared by the extramural organization for each project involving
environmental measurements. The elements of the QA Project Plan must be
separately identified from any general plan normally prepared for the project.
The Project Officer and the QA Officer must ensure that each extramural project
plan contains procedures to document and report precision, bias, representative-
ness, and completeness of all data generated.
Plan Review, Approval and Distribution--
I ntramura I Proj ects -- Each QA Project Plan must be approved by the Project
Officer's immediate supervisor and the QA Officer. Completion of reviews and
approvals is shown by signatures on the title page of the plan. Environmental
measurements may not be initiated until the QA Project Plan has received the
necessary approvals, unless emergency response is necessary. A copy of the
approved QA Project Plan will be distributed by the Project Officer to each
person who has a major responsibi I ity for the qua I ity of measurement data.
ExtramuraI Proj ects -- Each QA Project Plan must be approved by the funding
organization's Project Officer and the QA Officer. In addition, the extramural
organization's Project Manager and responsible QA official must review and
approve the QA Project Plan. Completion of reviews and approvals is shown by
signatures on the title page of the plan. Environmental measurements may not
be initiated until the QA Project Plan has received the necessary approvals. A
copy of the approved QA Project Plan will be distributed by the extramural
organization's Project Director to each person who has a major responsibility
for the qua I ity of the measurement data.
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Data Generation
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.
Data Processing
To prevent introducing errors or losing or misinterpreting the data,
adequate precautions must be taken during the reduction and storage of data.
1. Checks wi I I be made at data hand I ing points between the analysts
determining the data values and the individual entering the data into
the data storage system.
* All data must be recorded clearly and accurately in field log-
books or on laboratory data sheets.
* All data must be transferred and reduced from field logbooks and
bench sheets completely and accurately.
* All field and bench records will be retained in permanent files.
* Whenever possible, data will be organized into standard formats.
2, A data storage and information system wi I I be capable of:
* Receiving all entered data:
* Screening and validating data to identify and reject outliers or
errors;
* Preparing, sorting, and entering all data into the data storage
files (which are either computerized or manual); and
* Providing stored data points with associated QA/QC "labels"
which can indicate the level of confidence or quality of the
data. These labels should possess the capability of:
indicating what QA/QC activities were included in the major
steps of the monitoring process;
quantitatively describing the precision and bias of the
analysis; and
making data available to users as required. Specific
requirements and procedures for the above aspects of data
processing will be described in Standard Operating
Procedures.
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Data Quality Assessment
The qua I ity of measurement data generated and processed wi I I be assessed
for precision, bias, representativeness, comparabi I ity, and completeness based
on Standard Operating Procedures and available external measures of quality
(e.g., audit materials).
EPA-approved and/or best aval I able methodology wi I I be used for data
qua I ity assessment.
Aspects of data qua I ity which wi I I be addressed are:
• Precision -- Standard Operating Procedures will contain a mechanism for
demonstrating the reproducibi I ity of each measurement process.
Examples of activities to assess precision are: rep I icate samples,
colocated monitors, and instrument checks.
* Bias -- Standard Operating Procedures will contain mechanisms for
demonstrating the systematic error of the measurement system.
• Traceability of Instrumentation -- Each measurement device will be
assigned a unique identification record indicating where and when
used, maintenance performed, and the equipment and standards used for
caI ibrat ion.
* Traceabi I ity of Standards -- Standards and each measurement device will
be calibrated against a standard of known or higher accuracy; when
possible, calibration standards will be traceable to available
standards of the National Bureau of Standards (NBS). If NBS standards
are not available, other available validated (primary) standards will
be used.
* Traceabi I ity of Data -- Data wi I I be documented to a I low complete
reconstruction, from initial field records through data storage
system retr i evaI.
• MethodoIogy -- If available, Federal reference, equivalent, or approved
alternate test methods will be used. Other methodology must be fully
documented and justified.
* Reference or Spiked Samples -- Recoveries shall be within predetermined
acceptance limits. Unacceptable recoveries are identified and
documented.
* Performance Audits --As per the EPA Performance Audit Programs.
• Representativeness, Comparability, Completeness -- Where appropriate,
statements on representativeness, comparabi I ity, and completeness
will be included.
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Report Preparation
A final report must be prepared for each investigation, including the
fo I Iow i ng:
* the names of the team leader, scientists, professionals, and technical
support personnel involved in the inspection of 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 composition
of the hazardous waste;
* a description of the methods and instrumentation, if any, used in the
i nvest i gat i on;
* 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
qua I ity of the data; and
* a description of a I I circumstances that may have affected the qua I ity
or integrity of the data.
The team leader is responsible for the final report. Corrections or
additions to a final report shall be written as an amendment by the team leader
Retention and Retrieval of Samples, Records and Data
Unti I transferred to the Deputy Project Officer or Document Control Officer,
all preliminary 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.
Raw data, documentation, protocols, and final reports must be retained by
the Document Control Officer for at least 3 years after the completion of the
final report.
Due to the varied considerations involved in establishing a QA plan
(relevant to each particular investigation) a general bibliography is provided
here, rather than at the end of this volume, in hopes that this wi I I better
assist and expedite the process formulation.
Additional Sources of Information
General Quality Assurance--
1. U.S. EPA (1976). "Quality Assurance Handbook for Air Pollution
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Measurement Systems," EPA-600/9-76-005.
2, U.S. EPA (1973). "Quality Control Practices in Processing Air Pol-
lution Samples," APTD 1132.
3. Juran, J. M., ed. (1974). "Quality Control Handbook," McGraw-Hill.
4, Inhorn, S. L., ed. (1978). "QuaI ity Assurance Practices for Health
Laboratories," American Public Health Association.
5, U.S. EPA (1979). "Handbook for Analytical Qua I ity ControI in Water
and Wastewater Laboratories," EPA-600/4-79-019.
6, U.S. EPA (1980). "Interim Guidelines and Specifications for Preparing
Quality Assurance Project Plans," QAMS-005/80.
Laboratory Faci I ities 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.
Sample Collection and Analysis--
1, U.S. EPA (1977). "Procedures Manual for Ground Water Monitoring at
Solid Waste Disposal Facilities," EPA 530/SW-61.
2, U.S. EPA (1979). "Qua I ity Assurance and Qua I ity Control Procedures
for Screening and Verification of Industrial Effluents for Priority
PoI Iutants."
3, U.S. EPA (1974). "Compl iance Monitoring Procedures," EPA 330/1-74-002.
4, Brown lee, K. A. (1965). "Statistical Theory and Methodology in
Science and Engineering," John Wiley and Sons, Inc.
RESPONSES TO REQUESTS FOR INFORMATION
EPA PoI i cy
The EPA policy concerning the release of information to the public aims to
make information about EPA and its work available, freely and equally, to all
individuals, groups, and organizations. This policy does not extend to infor-
mation relating to potential enforcement actions, to evidence, or to confiden-
tial data. When information is requested, personnel should immediately notify
their supervisor and/or legal counsel.
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Media Contacts--
Personnel should cooperate with representatives of the press, other
communications media, and interested groups. Information concerning the Agency
responsibi Ity for inspections and investigative activities can be given.
Questions concerning investigations of hazardous waste sites and enforcement
policy should be referred to-the Office of the Regional Counsel for response.
Disclosure of Official Information--
Requests, either written or oral, for inspection or disclosure of
investigatory records or confidential information, even those made under judicial
discovery procedures or the Freedom of Information Act, should be immediately
referred-to the Regional Counsel to obtain approval prior to the release of
information. Other information disseminated outside the Agency will be directed
through the appropriate Regional Office or Headquarters.
ENTRY
Various Federal environmental statutes grant EPA enforcement personnel
authority to enter and inspect facilities. The authority granted in each
statute is similar to that stated below, from Section 308 of the Clean Water
Act:
"(a)(B) the Administrator or his authorized representative, upon
presentation of his credentials -
(i) shall have a right of entry to, upon, or through any premises in
which an effluent source is located or in which any record required
to be maintained. . . are located, and
(i i) may at reasonable times have access to and copy any records,
inspect any monitoring equipment or method required . . ., and sample
any effluents which the owner or operator of such source is required
to sample . . . ."
For the specific requirements on conducting inspections and collecting
data pursuant to other particular Acts, see: Section 114 of the Clean Air Act;
Sections 8 and 9 of the Federal Insecticide, Fungicide, and Rodenticide Act;
Section 3007 of the Resource Conservation and Recovery Act; Sections 8 and 11 of
the Toxic Substances Control Act; Section 1445 of the Safe Drinking Water Act;
and Section 104 of the Comprehensive Environmental Response, Compensation and
Liabi I ity Act.
Section 3007(a) of RCRA and 104(e) of CERCLA authorize the Administrator
of duly designed officials to have access to and to copy a I I records to such
wastes and substances.
"For the purpose of developing or assisting in the development of any
regulations or enforcing the provision of this title, such officers, employees
or representatives are authorized--
"to enter at reasonable times any establishment or other place where
hazardous wastes are or have been generated, stored, treated, disposed
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of or transported from"; and
* "to inspect and obtain samples from any person of any such wastes and
samples of any containers or label ing 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
general rules are concerned with gaining consent.
* Official agency credentials must be presented to the plant represen-
tative authorized to give consent to an inspection of the faci I ity.
• 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 name of
the person giving consent, the time and date of the consent should be
noted in the field log. Consent must be requested for photography if
it is part of the investigation. See section 5, Photographs.
* Consent must be secured without any behavior which could be character-
ized 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 pub I ic 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, access to any
portion of the faci I ity to an inspector without a warrant may be
I imited at the discretion of the owner of the faci I ity.
• Consent may be given with "conditions". When such "conditional"
consent is proposed, guidance should be sought from the appropriate
Regional authority, prior to further activity. "Conditions" must be
accurately recorded.
If denied entry after the appropriate procedural steps have been followed,
ask the person the reason for denying entry and record the response in the
field logbook along with the date, time, and person's name. All events sur-
rounding the refused entry should be documented. Also, note such observations
about the appearance of the facility as are possible. Then contact the Office
of Regional Counsel at the Regional Office for instructions.
Warrants
In the event that entry is denied or consent withdrawn, the Regional
Counsel must be contacted. Normally the Regional Counsel will take the
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necessary actions to secure three separate documents and submit them to the
judge of magistrate in order to obtain a warrant, viz:
Application for a Warrant--
* Statement of statutory and regulatory authority for the warrant.
* Identification of the site or establishment desired to be inspected
(and, if possible, the owner and/or operator of the site).
* Summary of the factual background for the warrant as stated in the
affidavit.
Affidavit--
* The affidavit should contain consecutively numbered paragraphs which
provide detailed descriptions of the facts which support the issuance
of a warrant.
* 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.
* 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).
* An affidavit is a sworn statement which, therefore, must be either
notarized or personally sworn before the magistrate or judge.
Draft Warrant--
The content of the warrant varies depending 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.
* Civil specific probable cause warrants are based on some specific
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 proceedings. Therefore, this warrant will be used when
the inspection is being made in response to the discovery of a
potential or actual violation 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 civil probable cause
warrant (discussed below).
* Civil probable cause warrants are based on neutral administrative
inspection scheme; i.e., showing that "reasonable legislative or
administrative standards for conducting an .... inspection are
satisfied with respect to a particular establishment.", Marshal v.
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Barlow's Inc., 436 U.S. 307, 90 S. Ct. 1816 (1978). A warrant based
on a neutral administrative 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
cIosure inspection, etc.
Criminal warrants are obtained when the purpose of the inspection 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,
evidence of a criminal violation inadvertently discovered under a
civil probable cause warrant will be admissible in court. Therefore,
a criminal warrant will be used only where the Agency is reasonably
certain that criminal violations have occurred and that a search
will produce evidence of a crime.
Securing a Warrant--
The following procedures should be followed in securing a warrant:
When an inspector is refused entry, the inspector should leave the
premises immediately.
The inspector should then immediately contact the designated Regional
Counsel to inform him/her of the situation. The inspector should at
this time report any exigent conditions and clearly specify the time
frame required for the inspection. Normally a warrant will specify
that entry can occur only during reasonable hours (typically 8 a.m.
to 5 p.m.) and may be limited to a single specified day. If the
inspection will require additional days or extended operational hours
the counsel and the judge should be informed so that the warrant will
reflect those actions necessary to complete the investigation. Once
the time limit has expired the investigators cannot enter the premises.
The Regional Counsel will assist the inspector in the preparation of
the necessary documents.
* The Regional Counsel will arrange for a meeting with the inspector
and a U.S. Attorney. The inspector will bring a copy of the appro-
priate draft warrant and affidavits.
The Enforcement attorney should inform the appropriate Headquarters
Office of Legal Counsel of any refusals to enter and send a copy of
all papers filed to Headquarters.
* The attorney wi I I then secure the warrant and forward it to the
inspector and/or the U.S. Marshall.
Inspections with a Warrent should Comply with the Following--
* Use of Warrant to Gain Entry
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If there is a high probabi I ity that entry wi I I be refused even
with a warrant or where there are threats of violence, the
inspector should be accompanied by a U.S. Marshall.
The inspector should never himself attempt to make any force-
ful entry of the establishment.
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 Regional Counsel.
Conducting an Inspection
The inspection must be conducted strictly in accordance with
the warrant. If the warrant restricts the inspection to
certain areas of the premises or certain records, those
restrictions must be adhered to.
If sampling is authorized, all procedures must be carefully
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.
If records of property are authorized to be taken, the inspector
must provide receipts and maintain a written inventory, directly
on the warrant, of a I I items removed from the premises.
Procedure to be Followed Upon Completion of the Inspection--
1. Whoever executed the warrant must sign the Return-of- Service form
indicating on whom the warrant was served and the date served.
2 A copy of the warrant must be left with the person to whom the
warrant was served.
3, The executed warrant must be submitted to the U.S. Attorney for
formal return to the issuing magistrate or judge.
4. An inventory of any items which were taken from the premises must
be I isted on the warrant and submitted to the court, and the
inspector must be present to certify that the inventory is accurate
and complete.
ZONE CONTRACTS
Zone and Nationwide Support Contracts
The EPA has initiated a number of procurements on a national level which
provide for Architectural /Engineer ing, cleanup/removal and enforcement assis-
tance in support of hazardous waste site investigations and remedial actions.
Access to these services is usually initiated at the regional level and
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generally proceeds from a designated regional official (e.g., regional contract
project officer, site project officer, contracting officer) through EPA head-
quarters and on to the designated contractor. The contractor wi I I then respond
with a work plan type document, including their estimate of budget and schedule.
Upon approval of the work plan, the assignment or technical directive will be
i n i t i ated.
Obviously the procedures to be actually followed are much more complex
than indicated, in the above generic description, but it is far beyond the scope
(and need) for each of the individual contract parameters to be described in
this document. In addition, the exact nature of the tasks allowed under each
contract as we I I as the number of such contracts awarded is subject to future
change, and a detailed explanation here might only serve to confuse the issue
This description is therefore meant to merely recognize the existence of these
contract mechanisms, and it is recommended that the appropriate regional
office, and more specifically the regional contract project officer, be con-
tatted for details concerning the support contract in question.
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SECTION 3
SAFETY
INTRODUCTION
A major concern during hazardous waste site investigations is safety, both
for the general public and the site investigators. This section is intended as
an introductory overview of safety concerns and practices summarizing some of
the major safety issues and procedures. A more detailed discussion of the
provisions and requirements of a hazardous waste site Health and Safety Plan is
provided in other documents prepared by EPA.*
POLICY AND RESPONSIBILITY
The EPA is committed to providing all EPA employees with a safe and healthy
work environment at hazardous waste sites. The Assistant Administrators and
Reg i onaI Adm i n i strators have u11 i mate respons i b i I i ty for heaIth and safety
programs. Officers in Charge of Reporting Units (OICs) are responsible for
implementing health and safety programs. The Occupational Health and Safety
Designee advises and assists the QIC to develop, organize, direct, and evaluate
health and safety programs and coordinates all recordkeeping activities. The
Project Officer has the responsibility for preparing site specific safety plans
for hazardous waste sites and serving as a liaison between the Occupational
Health and Safety Designee and the Site Safety Officer. Although the Project
Officer selects the Site Safety Officer who is responsible for day-to-day
implementation of the site-specific health and safety plan, the Site Safety
Officer will be charged with implementing administrative policy for field work
specific to the site as determined by the above personnel and agency committees.
Ideally, the Site Safety Officer wi I I report to the Occupational Health and
Safety Designee rather than the Project Officer, to avoid conflicts due to
logistics of work schedules. EPA employees are responsible for complying with
the health and safety program established for hazardous waste site investigations.
Exposure to Toxic Substances
Toxic or chemically active substances present a special situation because
they can be inhaled, ingested, absorbed through the skin, or destructive to the
skin. They may exist in the air or, due to site activities, become airborne or
* Refer to Interim Standard Operation Safety Guides, revised September 1982, U.S.
Environmental Protection, Office of Emergency and Remedial Response (OERR).
Also Guidance Manual for Protection of Health and Safety At Uncontrolled
Hazardous Substances Sites, U.S. EPA, Center for Environmental Research Infor-
mation (ORD) (in draft, January 1983).
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splash on the skin. Ingested or inhaled, the substances can cause no apparent
i I I ness or they can kill. On the skin they can cause no demonstrable effects,
they can damage the skin, or they can be absorbed, leading to systemic poisoning
Two types of potential exposure exist:
* Acute -- Concentrations of toxic air contaminants are high relative to
the type of substance and its protection criteria. Substances may
contact the skin directly through splashes, immersion, air, etc.,
with serious results. Exposures are for relatively short periods of
t i me.
* Chronic -- Concentrations of toxic air contaminants are relatively low.
Direct skin contact is with substances that are of low dermal activity.
Exposures are over longer periods of time.
In general, acute exposure to chemicals in air is more typical in transpor-
tation accidents, fires, or releases at chemical manufacturing or storage
facilities. Acute exposures do not persist for long periods of time. Acute
skin exposures occur when workers must be close to the substances in order to
control the release (patching a tank car, off-loading a corrosive material,
etc.) or contain and treat the spilled material. Once the immediate problems
have been alleviated, exposures tend to become more chronic in nature as
cleanup progresses.
Chronic exposures usually are associated more with longer-term remedial
operations. Contaminated soil and debris may be involved, soil and ground
water may be polluted, or containment systems may hold diluted chemicals.
Abandoned waste sites generally represent chronic problems. As activities
start at these sites, however, personnel engaged in sampling, handling con-
tainers, bulking compatible liquids, etc. face an increased risk of acute
exposures to splashes, mists, gases, or particulates.
Acute and chronic exposures to toxic substances are one type of hazard.
Other potential worker exposure hazards are materials that burn, explode,
react, emit radiation, or cause disease. All can create life-threatening
situations.
At any specific site, the hazardous properties of the materials present
may be only a potential threat. However, the health and safety of response
personnel requires that the hazards at a site - real or potential-must be
characterized and appropriate preventive measures instituted.
Medical Survei I lance
Prior to any hazardous waste site investigation, a medical surveillance
program must be developed, established, and maintained to safeguard the health
of response personnel. This program has two essential components: routine
health care and emergency treatment.
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Routine Health Care--
Routine health care and maintenance should consist of at least:
1. Pre-employment medical examinations to establish the individual's
state of health, baseline physiological data, and ability to wear
personnel protective equipment. The frequency and type of examination
to be conducted thereafter should be determined by medical personnel
knowledgeable in the area of toxicology.
2, Arrangements to provide special medical examinations, care, and
counseling in case of known or suspected exposures to toxic substances.
Any special tests performed depend on the chemical substance to which
the individual has been exposed.
Emergency Medical Care and Treatment--
The-following items should be included in emergency care provisions:
1. Name, address, and telephone number of the nearest medical treatment
facility should be conspicuously posted. A person and/or directions
for locating the facility, plus the travel time, should be readily
avallable.
2, The faci I ity's abi I ity to provide care and treatment of personnel
exposed or suspected of being exposed to toxic (or otherwise hazardous)
substances should be ascertained. If the facility lacks toxicological
capability, arrangements should be made for consultant services.
3, All administration arrangements for accepting patients should be made
in advance with the facility.
4, Arrangements should be made to quickly obtain ambulance, emergency,
fire, and police services. Telephone numbers and procedures for
obtaining these services should be conspicuously posted.
5, Emergency showers, eye wash fountains, and first aid equipment should
be readily available onsite. Personnel should have first aid and
medical emergency training.
6. Provisions should be made for rapid identification of the substance
to which the worker has been exposed (if this has not previously been
done). This information must be given to medical personnel.
EDUCATION AND TRAINING
All personnel involved in hazardous waste site investigations must be
trained to carry out their response functions. Training must be provided in
the use of all equipment, including respiratory protective apparatus and
protective clothing; safety practices and procedures; general safety require-
ments; first aid; and hazard recognition and evaluation.
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Safety training must be a continuing part of the total response program.
Periodic retraining and practice sessions not only create a high degree of
safety awareness, but also help to maintain proficiency in the use of equipment
and knowledge of safety requirements.
Personnel dealing with hazardous waste sites must make many complex
decisions regarding safety. To make these decisions correctly requires more
than elementary knowledge. For example, selecting the most effective personnel
protective equipment requires not only expertise in the technical areas of
respirators, protective clothing, air monitoring, physical stress, etc., but
also experience and professional judgment. Only a competent, qualified person
(specialist) has the technical judgment to evaluate a particular site and
determine the appropriate safety requirements. This individual, through a
combination of professional education, on-the-job experience, specialized
training, and continual study, requires expertise to make sound decisions.
DEVELOPMENT OF A HEALTH AND SAFETY PLAN
A Health and Safety Plan must be prepared for each waste site
investigation. In practice, contractors and agencies involved in field
investigations shall have a generic Health and Safety Plan from which site-
specific Health and Safety Plans can be derived. This generic plan should be
of sufficient detail and quality that only a few revisions would be necessary
for each site.
In addition to standard operating field procedures, the Health and
Safety Plan will contain information that deals specifically with the site
being investigated. This plan will include any available information on the
site such as known or suspected contaminants, required levels of protection,
decontamination procedures, locations of the various zones of contamination,
and other pertinent information or modifications to standard procedure. All
personnel must be familiar with the standard operating procedures and additional
instructions found in the Safety Plan.
All personnel going onsite must be adequately trained and thoroughly
briefed on anticipated hazards, equipment to be worn, safety practices to be
followed, emergency procedures, and communications. Emergency planning is an
important part of the Health and Safety Plan. All personnel should be familiar
with emergency procedures: first aid equipment; water availability; rapid
notification of fire, police and emergency medical facilities; presence of
transport vehicles, fire fighting equipment and extra protective equipment.
PRELIMINARY ONSITE EVALUATION
The initial onsite survey is to determine, on a preliminary basis,
hazardous or potentially hazardous conditions. The main effort is to rapidly
identify the immediate hazards that may affect the public, response personnel,
and the environment. Of major concern are the real or potential dangers--for
example, fire, explosion, oxygen-deficient atmospheres, radiation, airborne
contaminants, containerized or pooled hazardous substances--that could affect
workers during subsequent operations. This preliminary evacuation will be part
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of the Site Inspection (Section 5) as well as the Field Investigation
(Section 7).
Organic Vapors and Gases
If the type(s) of organic substance(s) present at a site is known and the
material is volatile or can become airborne, air measurements for organics
should be made with one or more appropriate, properly calibrated survey
i instruments.
When the presence or types of organic vapors/gases are unknown, instruments
such as a photoionization detector (HNu Systems) and/or a portable gas chromat-
ography flame ionization detector (Century Systems OVA), operated in the total
readout mode, should be used to detect organic vapors. Until specific con-
stituents can be identified, the readout indicates total airborne substances to
which the instrument is responding. Identification of the individual vapor/gas
constituents permits the instruments to be calibrated and used for more specific
analysis.
Sufficient data should be obtained during the initial entry to map or
screen the site for various levels of organic vapors. These gross measurements
can be used on a preliminary basis to: (1) determine levels of personnel protec-
tion, (2) establish site work zones, and (3) select candidate areas for more
thorough qualitative and quantitative studies.
Higher than background readings on the HNu or OVA may also indicate the
displacement of oxygen or the presence of combustible vapors.
Inorganic Vapors and Gases
The ability to detect and quantify nonspecific inorganic vapors and gases
is extremely limited. Presently, the HNu photo ionizer has limited detection
capability while the Century Systems OVA has none. If specific inorganic are
known or suspected to be present, measurements should be made with appropriate
instruments, if available. CaI orimetric indicator tubes can be used if the
identities of the substances present are known (or can be narrowed to a few) and
appropriate indicator tubes are available.
Rad i at i on
Although radiation monitoring is not necessary for all responses, it
should be incorporated in the initial survey where radioactive materials may be
present—for example, warehouses or hazardous material storage facilities, or
abandoned waste sites.
Normal gamma radiation background is approximately 0.01 to 0.02 mil-
I iroentgen per hour (mR/hr) on a gamma survey instrument. Work can continue
with elevated radiation exposure rates; however, if the exposure rate increases
to 3 to 5 times above gamma background, a qualified health physicist should be
consulted. At no time should work continue with an exposure rate of 10 mR/hr
or above without the advice of a health physicist. EPA's Office of Air, Noise,
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and Radiation has radiation specialists in each Region, as well as at Head-
quarters; Montgomery, Alabama; and Las Vegas, Nevada, to assist.
The absence of gamma readings above background should not be interpreted
as the complete absence of radioactive materials. Radioactive materials
emitting lower energy alpha or beta radiation may be present, but for a number
of reasons may not cause a response on the gamma survey instrument. Unless
airborne, these radioactive materials should present a minimal hazard, but more
thorough surveys should be conducted as site operations continue to ascertain
the complete absence of all radioactive materials. See Section 5, Volume II -
Available Sampling Methods.
Oxygen Def i c i ency
At sea level, ambient air must contain at least 19.5 percent oxygen by
volume to be considered safe for personnel. At lower percentages, air-supplied
respiratory protective equipment is needed. Oxygen measurements are of
particuIar-importance for work in enclosed space, low-lying areas, or in the
vicinity of situations that have produced heavier-than-air vapors which could
displace ambient air. These oxygen-deficient areas are also prime locations
for taking further organic vapor and combustible gas measurements, since the
air has been displaced by other substances. Oxygen-enriched atmospheres are
considered dangerous due to the increased potential for fires.
Combustible Gases
The presence or absence of combustible vapors or gases must be determined.
If readings approach or exceed 10 percent of the lower-explosive limit (LEL),
extreme caution should be exercised in continuing the investigation. If
readings approach or exceed 25 percent LEL, personnel should be withdrawn
immediately. Before resuming any onsite activities, project personnel in
consultation with experts in fire or explosion prevention must develop pro-
cedures for continuing operations.
Visual Observations
While onsite, the initial entry team should make visual observations which
would help in evaluating site hazards--for example, dead fish or animals or
stressed vegetation; land features; wind direction; labels on containers
indicating explosive, flammable, toxic, or corrosive materials; conditions
conducive to splash or contact with unconfined liquids, sludges, or solids;
and other general conditions.
D i rect-Read i ng Instruments
A variety of toxic air pollutants, (including organic and inorganic vapors,
gases, or particuI ate) can be produced or released at hazardous waste sites.
Direct-read ing field instruments will not detect or measure all of these sub-
stances. Thus, negative readings should not be interpreted as the complete
absence of airborne toxic substances. Verification of negative result can
only be done by collecting air samples and analyzing them in a laboratory.
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STANDARD ONSITE SAFETY PRACTICES
The team leader is responsible for establishing, and adjusting as necessary,
safety precautions appropriate to the individual hazardous waste site being
evaluated, such as the use of self-contained breathing apparatus, etc. The team
leader ensures that all participants conduct their work in accordance with the
project Health and Safety Plan and applicable rules. The team leader is author-
ized to direct any employee to leave the site if the employee fails to observe
safety requirements or in any way creates a safety hazard.
Personnel Precautions
Personnel precautions include the following:
1. Eating, drinking, chewing gum or tobacco, smoking, or any practice
that increases the probability of hand-to-mouth transfer and ingest ion
of material is prohibited in any area designated as contaminated.
2. Hands and face must be thoroughly washed upon leaving the work area
and before eating, drinking, or any other activities:
3. Whenever decontamination procedures for outer garments are in effect,
the entire body should be thoroughly washed as soon as possible after
the protective garment is removed.
4. No excessive facial hair which interferes with a satisfactory fit of
the mask-to-face seal is allowed on personnel required to wear
respiratory protective equipment.
5. Contact with contaminated or suspected contaminated surfaces should
be avoided. Whenever possible, don't walk through puddles, mud, and
other discolored surfaces; kneel on ground; lean, sit, or place
equipment on drums, containers, vehicles, or the ground.
6. Medicine and alcohol can potentate the effects of exposure to toxic
chemicals. Prescribed drugs should not be taken by personnel on
response operations where the potential for absorption, inhalation,
or ingestion of toxic substances exists unless specifically approved
by a qualified physician. Alcoholic beverage intake should be
minimized or avoided during response operations.
7. There is an increased potential for fatigue and/or heat prostration
when wearing protective garments (due to dehydration, etc.).
Onsite Regulations
Onsite regulations include:
1. Entrance and exit must be planned and emergency escape routes delineated.
Warning signals for site evacuation must be established.
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2. Personnel should practice unfamiliar operations prior to implementing
the actual procedure.
3. Personnel onsite must use the "buddy" system when wearing respiratory
protective equipment. As a minimum, a third person, suitably equipped
as a safety backup, is required during initial entries.
4. During continual operations, onsite workers act as safety backup to
each other. Offsite personnel provide emergency assistance.
5. Communications using radios or other means must be maintained between
initial entry members at all times. Emergency communications should
be prearranged in case of radio failure, necessity for evacuation of
site, or other reasons.
6. Visual contact must be maintained between "pairs" onsite and safety
personnel. Entry team members should remain close together to assist
each other during emergencies.
7. Wind indicators visible to all personnel should be strategically
located throughout the site.
8. Ambient air must be monitored at regular intervals, either for total
vapor readings or for known or suspected specific contaminants.
Unsafe Situations
All employees are directed to bring to the attention of the most readily
accessible supervisor any unsafe condition, practice, or circumstance associated
with or resulting from hazardous waste site 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 opportunity. 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 units. All such actions must be coordinated
with and approved by the site management personnel. In cases where the hazard
is not immediate, the employee should consult the team leader regarding appro-
priate corrective measures. Application of this rule requires exercising good
j udgment and common sense by a I I empIoyees.
Safety Precautions during Sampling
Sampling methods are described in Volume I I--Aval I able Sampling Methods.
As a genera I-ru le, sampling equipment used on a hazardous waste site should be
disposable. Dippers, scoops, and similar devices for solids samples should be
left onsite, or placed in plastic bags for disposal or later decontamination.
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 is contemplated, the
tubing may be disposed of in other suitable containers or on the site. The
guiding safety principle is to prevent exposure of others to spilled or residual
waste materials.
Containers (drums, tanks, etc.) should only be sampled when necessary.
Opening drums or other sealed containers may be hazardous to sampling personnel
unless proper safety procedures are followed. Drums should be "shock-tested"
before sampling. Gases can be released, or pressurized liquids can be expelled.
A drum should not be removed or opened unless it can be ascertained "beyond
reasonable doubt" that the drum is structurally sound. Drums standing on end,
with bung up, may be opened by pneumatic impact wrench, operated from a safe
distance. Drums on sides may be opened similarly 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 accomplished. Barrels that have badly rusted
bungs or that cannot be sampled as above may be opened with a number of drum
penetrating devices. These include hydraulic cutters, back hoe-mounted puncture
spikes, or remotely operated drills. One such device, developed by the NEIC,
is a hydraulic penetrating device that inserts a tap into the drum. After
sampling, the tap can be disabled and left in the drum to prevent content loss.
In general, metal sample containers should not be used during hazardous
waste site investigations; if used, they must be grounded, preferably to the
drum or tank being sampled, while sample transfer is accomplished.
In any case where the presence of explosives is suspected or known, the
investigation should be terminated and the proper authorities contacted for
removal. In no event may team members knowingly handle explosives encountered
on dump sites.
Subsurface sampling at a hazardous waste site 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 dri I I rigs or other ignition sources.
Drilling into dump sites may cause discarded incompatible substances 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 drilling is not planned carefully.
Drilling at hazardous waste site investigations should be confined to the
periphery of the waste sites; the objective is to characterize the leachate
thay may be moving away from the site. If onsite subsurface sampling is
necessary, excavation should be accomplished by hand with spark-free equipment,
unless detailed geophysical information (i.e., ground penetrating radar,
magnetic surveys) has been obtained.
Dri I I ing may be preceded by sweeps with metal detectors having a sensi-
tivity to minimum depth of 10 feet, and dri I I ing must be I imited to areas where
the presence of buried drums or tanks is not indicated.
Ambient air samp I ing on a hazardous waste site must be accompl ished with
spark-free equipment if explosive vapors are present (most conventional hi-vol
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samplers are spark sources). All instruments or other electronic and electrical
devices employed on or around a hazardous waste site must be approved or
certified as inherently safe by Underwriter's Laboratory (UL) or Factory Mutual
Systems (FM) according to the provisions set forth by the National Electric
Code. Portable power sources or generators should also comply with the above
constra i nts.
LEVELS OF PROTECTION
Personnel must wear protective equipment when response activities involve
known or suspected atmospheric contamination, when vapors, gases, or partic-
ulates may be generated, or when direct contact with skin-affecting substances
may occur. Respirators can protect lungs, gastrointestinal tract, and eyes
(when full-face respirators are used) against air toxicants. Chemical-
resistant clothing can protect the skin from contact with skin-destructive and -
absorbable chemicals. Good personal hygiene limits or prevents ingest ion of
material.
Equipment to protect the body against contact with known or anticipated
chemical hazards has been divided into four categories according to the degree
of protection afforded:
* LeveI A -- Should be worn when the highest level of respiratory, skin,
and eye protection is needed.
* LeveI B -- Should be selected when the highest level of respiratory
protection is needed, but a lesser level of skin protection is
required. Level B protection is the minimum level recommended on
initial site entries until the hazards have been further defined by
onsite studies and appropriate personnel protection utilized.
• LeveI C -- Should be selected when the type(s) of airborne substance(s)
is known, the concentration(s) is measured, and the criteria for using
air-purifying respirators are met.
* LeveI D -- Should not be worn on any site with respiratory or skin
hazards. This level of protection consists primarily of a work uniform
providing minimal protection.
The Level of Protection selected should be based primarily on:
• Type(s) and measured concentration(s) of the chemical substance(s) in
the ambient atmosphere and its toxicity.
* Potential or measured exposure to substances in air, splashes of
liquids, or other direct contact with material due to work being
performed.
In situations where the type(s) of chemical(s), concentration(s), and
possibilities of contact are known, the appropriate Level of Protection must be
selected based on professional experience and judgment until the hazards can be
better characterized.
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While personnel protective equipment reduces the potential for contact
with harmful substances, ensuring the health and safety of personnel also
requires safe work practices, decontamination, site entry protocols, and other
safety considerations. Together, these protocols establish an integrated
approach for reducing potential harm to workers.
Level A Protection
Personnel Protective Equipment--
Level A protective equipment briefly consists of a fully encapsulating
chemical-resistant suit with pressure-demand, self-contained breathing apparatus
(SCBA) approved by the Mine Safety and Health Administration (MSHA) and the
National Institute of Occupational Safety and Health (NIOSH). Due to the wide
variety of types, materials, construction detail, permeability, etc., a
specialist should be consulted to select the most effective clothing. Known or
anticipated hazards and work functions also should be considered when making this
selection. This is the highest level of protection for entering a hazardous
waste site.
Criteria for Selection--
Meeting any of these criteria warrants use of Level A protection:
The chemical substance(s) has been identified and requires the highest
level of protection for skin, eyes, and the respiratory system based
on the following:
measured (or potential for) high concentration(s) of atmospheric
vapors, gases, or particulate, or
site operations and work functions involving high potential for
splash, immersion, or exposure to unexpected vapors, gases, or
particulate.
Extremely hazardous substances (for example: dioxin, cyanide
compounds, concentrated pesticides, Department of Transportation
Poison "A" materials, carcinogens, and infectious substances) are
known or suspected to be present, and skin contact is possible.
* The potential exists for contact with substances that destroy skin.
Operations must be conducted in confined, poorly ventilated areas
until the absence of hazards requiring Level A protection is
demonstrated.
Total atmospheric readings on the Century OVA System, HNu Photo ionizer,
and similar instruments (Volume II) indicate 500 to 1,000 ppm of
unidentified substances.
Guidance on Selection Criteria--
The fully encapsulating suit provides the highest degree of protection to
skin, eyes, and respiratory system if the suit material is resistant to the
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chemical(s) of concern during the time the suit is worn and/or at the measured
or anticipated concentrations. While Level A provides maximum protection, the
suit material may be rapidly permeated and penetrated by certain chemicals from
extremely high air concentrations, splashes, or immersion of boots or gloves in
concentrated liquids or sludges. These limitations should be recognized when
specifying the type of chemical-resistant garment. Whenever possible, the suit
material should be matched with the substance it is to project against.
The use of Level A protection and other chemical-resistant clothing
requires evaluating the problems of physical stress, in particular heat stress
associated with the wearing of impermeable protective clothing. Response
personnel must be carefully monitored for physical tolerance and recovery.
Protective equipment, being heavy and cumbersome, decreases dexterity,
agility, visual acuity, etc., and so increases the probability of accidents.
This probability decreases as less protective equipment is required. Thus,
increased probabi I ity of accidents should be considered when selecting a Level
of Protection.
Many toxic substances are difficult to detect or measure in the field.
When such substances (especially those readily absorbed by or destructive to
the skin) are known or suspected to be present and personnel contact is
unavoidable, Level A protection should be worn until more accurate information
can be obtained.
Examples of situations where Level A has been worn are:
Excavation of soil suspected of being contaminated with dioxin.
* Handling and moving drums suspected and/or known to contain substances
that were skin destructive or absorbable.
Level B Protection
Personnel Protective Equipment--
Level B personnel protective equipment briefly consists of pressure demand,
self-contained breathing apparatus (MSHA/NIOSH approved), chemical-resistant
clothing or coveralls with hood, chemical-resistant gloves and boots. The same
level of respiratory protection is provided as in Level A, but less skin protec-
tion is provided.
Criteria for Selection--
Meeting any one of these criteria warrants the use of Level B protection:
* The type(s) and atmospheric concentration(s) of toxic substances have
been identified and require the highest level of respiratory
protection, but a lower level of skin and eye protection. These
would be atmospheres:
with concentrations Immediately Dangerous to Life and Health
(IDLH), or
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exceeding limits of protection afforded by a full-face,
air-purifying mask, or
containing substances for which air-purifying canisters do not
exist or have low removal efficiency, or
containing substances which require that personnel wear air-
supplied equipment, but substances and/or concentrations do not
represent a serious skin hazard.
The atmosphere contains less than 19.5 percent oxygen.
Site operations make it highly unlikely that the small, unprotected
area of the head or neck wi I I be contacted by splashes of extremely
hazardous substances.
* Total atmospheric concentrations of unidentified vapors or gases
range from 5 ppm to 500 ppm on instruments such as the Century OVA
System or HNu Photo ionizer (Volume II), and where vapors are not
suspected of containing high levels of chemicals toxic to skin.
Guidance on Selection Criteria--
Level B equipment provides a high level of protection to the respiratory
tract, but a somewhat lower level of protection to skin. The chemical-resistant
clothing required in Level B is available in a wide variety of types, materials,
construction detail, permeability, etc. These factors all affect the degree
of protection afforded. Therefore, a specialist should select the most
effective chemical-resistant clothing based on the known or anticipated hazards
and/or job function.
Generally, if a self-contained breathing apparatus is required, Level B
clothing rather than a Level A fully encapsulating suit is selected, based on
the protection needed against known or anticipated substances affecting the
skin. Level B skin protection is selected by:
Comparing the concentrations of known or identified substances in air
with skin toxicity data.
Determining the presence of substances that are destructive to and/or
readily absorbed through the skin by liquid splashes, unexpected high
levels of gases or particulate, or other means of direct contact.
Assessing the effect of the substance (at its measured air concen-
trations or splash potential) on the smalI area of the head and neck
unprotected by chemical resistant clothing.
While Level B protection does not afford the maximum skin (and eye)
protection as does a fully encapsulating suit, a good quality, hooded,
chemicaI-resistant, one-or two-piece garment, with taped joints, provides a
reasonably high degree of protection. At most abandoned hazardous waste sites,
ambient atmospheric gas/vapor levels have not approached concentrations
sufficiently high to warrant maximum protection. In all but a few circumstances,
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Level B should provide the protection needed for initial entry. Subsequent
operations require a re-evaluation of the level of protection based on the
probability of being splashed by chemicals, their effect on the skin, or the
presence of hard-to-detect air contaminants.
Level C Protection
Personnel Protective Equipment--
Level C personnel protective equipment briefly consists of chemical-
resistant clothing or coveralls, with hood, and chemical-resistant gloves and
boots. Respiratory protective equipment consists of a full face, air purifying
respirator with an appropriate cannister or cartridges. The same level of skin
protection is provided as in Level B, however the respiratory protection is
limited to the air purifying respirator.
Criteria for Selection--
Meeting of a I I of these criteria permits use of Level C protection:
Measured air concentrations of identified substances will be reduced
by the respirator to at or below the substance's exposure limit, and
the concentration is within the service limit of the canister.
* Atmospheric contaminant concentrations do not exceed IDLH levels.
Atmospheric contaminants, liquid splashes, or other direct contact
wi I I not adversely affect the smalI area of skin left unprotected by
chemicaI-resistant clothing.
Job functions have been determined not to require self-contained
breathing apparatus.
* Total vapor readings register between background and 5 ppm above
background on instruments such as the HNu Photo ionizer and Century
OVA System (see Volume II).
Air wi I I be monitored periodically.
Guidance on Selection Criteria--
Level C protection is distinguished from Level B by the equipment used to
protect the respiratory system, while the same type of chemical-resistant
clothing is used. The main selection criterion for Level C is that conditions
permit wearing air-purifying devices.
The air-purifying devices must be a full-face mask (MSHA/NIOSH approved)
equipped with a canister suspended from the chin or on a harness. Canisters
must be able to remove the substances encountered. Quarter- or half-masks or
cheek-cartridge full-face masks should be used only with the approval of a
qualified individual, primarily due to the lower breakthrough volumes and
shorter service life for cartridges, and the increased risk of eye injury when
using quarter or ha If-face masks.
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In addition, a full-face, air-purifying mask can be used only if:
Oxygen content of the atmosphere is at least 19.5 percent by volume.
Substance(s) is identified and its concentration(s) measured.
Substance(s) has adequate warning properties.
Individual passes a qualitative fit-test for the mask.
* Appropriate canister/cartridge is used, and its service limit
concentration is not exceeded.
An air monitoring program is part of all response operations when atmos-
pheric contamination is known or suspected. It is particularly important that
the air be monitored thoroughly when personnel are wearing air-purifying
respirators (Level C). Continual surveillance using direct-read ing instruments
and air sampling is needed to detect any changes in air quality necessitating a
higher level of respiratory protection. See Section 5 and Volume II for guidance
on air monitoring.
Total unidentified vapor/gas concentrations of 5 ppm above background
require Level B protection. Only a qualified individual should select level C
(air-purifying respirators) protection for continual use in an unidentified
vapor/gas concentration of background to 5 ppm above background.
Level C protection (full-face, air purifying respirator) should be worn
routinely in an atmosphere only after the type(s) of air contaminant(s) is
identified and concentrations measured. The guideline of total vapor/gas
concentration of background to 5 ppm above background should not be the sole
criterion for selecting Level C. Since the individual contributors may never
be completely identified, a decision on continuous wearing of Level C must be
made after assessing all safety considerations, including the following:
The presence of (or potential for) organic or inorganic vapors/gases
against which a canister is ineffective or has a short service life.
The known (or suspected) presence in air of substances with low
Threshold Limit Values (TLV) or IDLH levels.
The presence of particulate in air.
The errors associated with both the instruments and monitoring
procedures used.
The presence of (or potential for) substances in air which do not
elicit a response on the instrument(s) used.
* The potential for higher concentrations in the ambient atmosphere or
in the air adjacent to specific site operations.
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Level D Protection
Personnel Protective Equipment--
Level D personnel protective equipment consists basically of work clothes
and boots. It is recommended that an escape mask be carried in the event of an
emergency.
Criteria for Selection--
Meeting any one of these criteria a I lows use of Level D protection:
* No hazardous air pollutants have been measured.
* Work functions preclude splashes, immersion, or potential for
unexpected inhalation of any chemicals.
Guidance on Selection Criteria--
Level D protection is primarily a work uniform, It can be worn in areas
where: (1) only boots can be contaminated, or (2) there are no inhalable toxic
substances.
CONTROL AT THE SITE
Activities at hazardous waste sites involving hazardous substances may
contribute to the movement of materials (contaminates) from the site to
unaffected areas. Response personnel working and equipment used around the
substances may become contaminated and carry the material into clean areas.
Material may become airborne due to its volatility, or the disturbance of
contaminated soil may cause it to become wind blown. To minimize the transfer
of hazardous substance(s) from the site, due to site activities, contamination
control procedures are needed.
A site must be controlled to reduce the possibility of: 1) exposure to
any contaminants present and 2) their transport by personnel or equipment from
the site. The possibility of exposure or trans location of substances can be
reduced or eliminated in a number of ways, including:
* Setting up security and physical barriers to exclude unnecessary
personnel from the general area.
* Minimizing the number of personnel and equipment onsite consistent
with effective operations.
* Establishing work zones within the site.
* Establishing control points to regulate access to work zones.
* Conducting operations in a manner to reduce the exposure of personnel
and equipment and to eliminate the potential for airborne dispersions.
* Implementing appropriate decontamination procedures.
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Additionally, efforts must be made to control access onto the site.
Decisions regarding the extent of the control efforts wi I I be made by the
On-Scene Coordinator, the Safety Officer, and the Project Officer. Most
situations will require a surrounding chain-I ink fence. In addition to limiting
access to the pub I ic, a fence wi I I reduce animal traffic and the movement of
litter, two important vectors of contaminant migration. During periods of
onsite activity, site control should be increased in response to the increased
hazards. The OSC must maintain a log book of all personnel entering and leaving
the site. In some instances this task may become extremely time consuming and
the responsibility could be delegated to a security firm.
Some sites may not warrant such extensive security, especially during
non-active phases, however control of site access is an important consideration
in the development and implementation of the site safety plan.
WORK ZONES
One method of preventing or reducing the migration of contamination and
for controlling unauthorized access to contaminated areas is to delineate zones
on the site where prescribed operations occur. Movement of personnel and
equipment between zones and onto the site itself would be limited by access
control points. By these means, contamination would be expected to be contained
within certain relatively small areas on the site and its potential for spread
minimized. Three contiguous zones are recommended:
* Zone 1: Exclusion Zone
* Zone 2: Contamination Reduction Zone
* Zone 3: Support Zone
Zone 1: Exclusion Zone
The Exclusion Zone, the innermost of three concentric areas, is the zone
where contamination does or could occur. All people entering the Exclusion
Zone must wear prescribed Levels of Protection. An entry and exit check point
must be established at the periphery of the Exclusion Zone to regulate the flow
of personnel and equipment into and out of the zone and to verify that the
establ ished entry and exit procedures are followed.
The outer boundary of Zone 1, the Hotline, is initially established by
visually surveying the immediate environs of the site and determining where the
hazardous substances involved are located; where any drainage, leachate, or
spilled material is; and whether any disco I orations are visible. Guidance in
determining the boundaries is also provided by data from the site inspection
indicating the presence of organic or inorganic vapors/gases or particulate in
air, combustible gases, and radiation, or the results of water and soil sampling.
Additional factors that should be considered include the distances needed
to prevent fire or an explosion from affecting personnel outside the zone, the
physical area necessary to conduct site operations, and the potential for
contaminants to be blown from the area. Once the Hotline has been determined,
it should be physically secured, fenced, or well defined by landmarks. During
subsequent site operations, the boundary may be modified and adjusted as more
information becomes available.
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Subareas Within the Exclusion Zone
All personnel within the Exclusion Zone must wear the required Level of
Protection. The designation of personnel protective equipment is based on
site-specific conditions, including the type of work to be done and the hazards
that might be encountered. Frequently within the Exclusion Zone, different
Levels of Protection are justified. Subareas are specified and conspicuously
marked as to whether Level A, B, or C protection is required. The Level of
Protection is determined by the measured concentration of substances in air,
potential for contamination, and the known or suspected presence of highly
toxic substances.
Different Levels of Protection in the Exclusion Zone might also be
designated by job assignment. For example, collecting samples from open
containers might require Level B protection, while for walk-through ambient air
monitoring, Level C protection might be sufficient. The assignment, when
appropriate, of different Levels of Protection within the Exclusion Zone
generally results in for a more flexible, effective, and less costly operation,
whi le sti I I maintaining a high degree of safety.
Zone 3: Support Zone
The Support Zone, the outermost part of the site, is considered a
noncontaminated or clean area. Support equipment (command post, equipment
trailer, etc.) is located in this zone, and traffic is restricted to authorized
response personnel. Since normal work clothes are appropriate within this
zone, potentially contaminated personnel clothing, equipment, and samples are
not permitted, but are left in the Contamination Reduction Zone until they are
decontaminated.
The location of the command post and other support faci I ities in the
Support Zone depends on a number of factors, including:
Access i b i I i ty: topography, open space available, locations of
highways, railroad tracks, or other limitations.
* Wind direction: preferably the support facilities should be located
upwind of the Exclusion Zone. However, shifts in wind direction and
other conditions may be such that an ideal location based on wind
direction alone does not exist.
* Resources: adequate roads, power lines, water, and shelter.
Zone 2: Contamination Reduction Zone
Between the Exclusion Zone and the Support Zone is the Contamination
Reduction Zone, which provides a transition between contaminated and clean
zones. Zone 2 serves as a buffer to further reduce the probabi I ity of the
clean zone becoming contaminated or being affected by other existing hazards.
It provides additional assurance that the physical transfer of contaminated
substances on people, equipment, or in the air is limited through a combination
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of decontamination, distance between Exclusion and Support Zones, air dilution,
zone restrictions, and work functions.
Initially, the Contamination Reduction Zone is considered to be a non-
contaminated area. At the boundary between the Exclusion and Contamination
Reduction Zones, decontamination stations are established, one for personnel
and one for heavy equipment. Depending on the size of the operation, more than
two stations may be necessary. Exit from the Exclusion Zone is through a
decontamination station.
As operations proceed, the area around the decontamination station may
become contaminated, but to a much lesser degree than the Exclusion Zone. On a
relative basis, the amount of contaminants should decrease from the Hotline to
the Support Zone due to the distance involved and the decontamination
procedures used.
The boundary between the Support Zone and the Contamination Reduction
Zone is called the Contamination Control Line, which separates the possibly low
contamination area from the clean Support Zone. Access to the Contamination
Reduction Zone from the Support Zone is through a control point. Personnel
entering there would wear the prescribed personnel protective equipment, if
required, for working in the Contamination Reduction Zone. Recentering the
Support Zone requires removal of any protective equipment worn in the Con-
tamination Reduction Zone.
Decontamination consists of physically removing contaminants and/or
changing their chemical nature to innocuous substances. How extensive
decontamination must be depends on a number of factors, the most important
being the type of contaminants involved. The more harmful the contaminant the
more extensive and thorough decontamination must be. Less harmful contaminants
may require less decontamination. Combining decontamination, the correct
method of doffing personnel protective equipment, and the use of site work
zones minimizes cross-contamination from protective clothing to wearer,
equipment to personnel, and one area to another. Only general guidance can be
given on methods and techniques for decontamination. The exact procedure to
use must be determined after evaluating a number of factors specific to the
site.
Initial Planning
The initial decontamination plan assumes all personnel and equipment
leaving the Exclusion Zone (area of potential contamination) are grossly
contaminated. A system is then set up to wash and rinse, at least once, all
the personnel protective equipment worn. This is done in combination with a
sequential doffing of equipment, starting at the first station with the most
heavily contaminated item and progressing to the last station with the least
contaminated article. Each piece of clothing or operation requires a separate
stat i on.
The spread of contaminants during the washing/doffing process is further
reduced by separating each decontamination station by a minimum of 3 feet.
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Ideally, contamination should decrease as a person moves from one station to
another farther along in the line.
While planning site operations, methods should be developed to prevent the
contamination of people and equipment. For example, using remote sampling
techniques, not opening containers by hand, bagging monitoring instruments,
using drum grapplers, watering down dusty areas, and not walking through areas
of obvious contamination would reduce the probability of becoming contaminated
and require a less elaborate decontamination procedure.
The initial decontamination plan is usually based on a worst-case situation.
During the site inspection specific conditions at the site are then evaluated,
including:
* Type of contaminant.
The amount of contamination.
Levels of protection required.
Type of protective clothing worn.
The initial decontam i nat i on system i s then mod i f i ed, eI i m i nat i ng unneces-
sary stations or otherwise adapting it to site conditions. For instance, the
initial plan might require a complete wash and rinse of chemical protective
garments. If disposable garments are worn, the wash/rinse step could be omitted.
Wearing disposable boot covers and gloves could eliminate washing and rinsing
both gloves and boots and reduce the number of stations needed.
Contamination Reduction Corridor
An area within the Contamination Reduction Zone is designated the
Contamination Reduction Corridor (CRC). The CRC controls access into and out
of the Exclusion Zone and confines personnel decontamination activities to a
limited area. The size of the corridor depends on the number of stations in
the decontamination procedure, overall dimensions of work control zones, and
amount of space available at the site. A corridor of 75 feet by 15 feet should
be adequate for full decontamination. Whenever possible, it should be a
straight path.
The CRC boundaries should be conspicuously marked, with entry and exit
restricted. The far end is the hotline - the boundary between the Exclusion
Zone and the Contamination Reduction Zone. Personnel exiting the Exclusion
Zone must go through the CRC. Anyone in the CRC should be wearing the Level of
Protection designated for the decontamination crew. Another corridor may be
required for the entrance and exit of heavy equipment requiring decontamination.
Within the CRC, distinct areas are set aside for decontamination of personnel,
restricted to those wearing the appropriate Level of Protection. All activities
within the corridor are confined to decontamination.
Personnel protective clothing, respirators, monitoring equipment, sampling
supplies, etc. are all maintained outside of the CRC. Personnel don their
protective equipment away from the CRC and enter the Exclusion Zone through a
separate access control point at the hotline.
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SECTION 4
PRELIMINARY DATA GATHERING
INTRODUCTION
Following discovery, a task is initiated to collect and review available
information about the known or suspected hazardous substance site or release.
The purpose of this task is to determine to the extent possible the magnitude
of the hazard, the source and nature of the release or potential release, and
the identity of a responsible party, in order to formulate response management
decisions.
This is accomplished through telephone and personal contacts with
knowledgeable persons, file searches, and analysis of aerial photographs.
The objectives are as follows:
* determine if any contamination problem exists;
* estimate potential severity of the problem and establish priorities
for further investigation;
focus the inspection and/or field investigation efforts on the proper
areas;
* discover potential hazards to field personnel, allowing them to take
proper safety precautions;
* incorporate whatever findings are available from previous studies of
the site; and
* 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.
SOURCES OF DATA
Loca I Contacts
Once a possible problem has been identified, the original source of that
information, whether private citizen or government official, should be asked to
name all persons who might have knowledge of the site in question. If the
original contact is a private citizen, the names of anyone who might be able to
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corroborate the report should be requested. When appropriate, 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 employee protection provisions under RCRA, Section 7001.
Government Fi les
After receiving a report of possible waste disposal problem, the
investigator should examine all appropriate government files. In EPA
Regional Offices, Regional Counsels and personnel in the Toxic Substances,
Drinking Water, Solid Waste, and Air and Hazardous Waste Materials Divisions
should be contacted for information. The investigator should rev lew all infor-
mation on the site or faci I ity that has been fi led in compl iance with RCRA or
CERCLA. State and local environmental and health agencies may have valuable
information regarding the site, disposal practices, and other technical matters.
If the operator has ever applled for a NPDES permit, the appl icat ion has con-
siderable data on wastes disposed at the site and facility design. If no NPDES
permit is held by the facility, a demonstration of discharges to surface waters
may justify a full enforcement investigation or enforcement action. Information
may also be available from state inventories of surface impoundments under the
Safe Drinking Water Act or of open dumps under the Resource Conservation and
Recovery Act. The U.S. Geological Survey (USGS) should be asked for information
on sites under study because it may have investigated ground-water pollution in
the area that could lead to the identification of its source. Also universities,
research institutes, consultants and contractors may provide useful data. If
the facility has applied for a state solid waste permit, information regarding
geology, hydrology, and soils may be available. State records of site inspec-
tions and enforcement actions should be requested. A state water quality
agency may have data on surface water and ground-water quality. 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 get highway directions to the site. Zoning or planning commissioners
may be able to provide detai led maps of the site and its environs.
The NEIC Information Services Branch provides extensive and comprehensive
technical information services to the EPA enforcement program in Headquarters
and the Regional Offices. More than 150 computerized data bases on a wide
variety of subjects, including chemistry, toxicology, engineering, business,
and economics are accessed. Examples of the kinds of information provided are:
1. Corporate information including subsidiaries, profit and loss state-
ments, officers, and previous environmental litigation.
2, Information on specific chemicals, such as toxicity, physical and
chemical properties, manufacturers and locations.
3, Ownership of property, operations, employees, etc.
The requestor should provide as much information as possible when
requesting assistance. All the information available about the site and
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potential responsible parties should be included in the written request. In
some cases, only the site name and location will be available. The requestor
should provide the name, address (if known), city (if known), and state. With
a site name and location, NEIC personnel may be able to identify an owner,
leasee, operator, etc. If the information is not available, the requestor
should check with the county clerk or registrar to determine who owns the
property. This information should then be forwarded to NEIC to update the
retr i evaI system.
Records of Generators
RCRA requires that generators complete manifests for each shipment of
hazardous wastes transported to a disposal, treatment or storage facility.
Copies of these manifests and a biannual summary must be filed with the regional
EPA office.
Treatment, storage and disposal facilities must file an application for a
permit in accordance with RCRA. These applications must detail the type and
quantity of material handled or expected to be handled and additional information
regarding the physical facilities. Permits wi I I specify record-keep ing, moni-
toring and maintenance requirements, descriptions of the process, construction
and design of disposal and storage facilities, and contingency plans.
Approximately 35 states are now authorized to administer and enforce
programs in I ieu of the Federal program pursuant with RCRA. In such cases,
states may institute operating requirements in addition to those designated by
RCRA.
The foI lowing I 1st contains the names and telephone numbers of the persons
and departments at each EPA regional office who can be contacted for this
information:
Reg i on I
Dennis Huebner - (617) 223-6883
Chief, State Waste Programs Branch
U.S. Environmental Protection Agency
John F. Kennedy Building
Boston, MA 02203
Reg i on II
Richard Baker- (212) 264-9881
Permits Administration Branch,
Management Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10007
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Reg i on III
Shirley Bulkin - (215) 597-4269
Waste Management Branch
Facilities Management Section
U.S. EPA
6th and WaI nut Street
Phi ladelphia, PA 19106
Reg i on IV
Rita Ford- (404) 257-3966
Waste Engineering Section
Residuals Management Branch
U.S. EPA
345 Court I an Street, N.E.
Atlanta, GA 30308
Reg i on V
Bi I I Miner - (312) 886-6135
Chief, Technical Permits and Compliance Section
U.S. EPA
230 S. Dearborn St.
Chicago, IL 60604
Reg i on VI
Dave Olschewski - (214) 767-8941
Chief, Technical Section
Hazardous Materials Branch
U.S. EPA
1203 Elm Street
First International Building
Dal las, TX 75270
Reg i on VII
Lynn Barrington - (816) 374-6531
Waste Management Branch
U.S. EPA
324 E. 11th Street
Kansas City, MO 64106
Reg i on VI I I
John Minkoff - (303) 837-6238
Waste Management Branch, Air and Hazardous Division
U.S. EPA
1860 Lincoln Street
Denver, CO 80203
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Reg i on IX
Bi I I Wi Ison - (415) 974-7472
Toxic and Waste Management Division
U.S. EPA
215 Elm Street
San Francisco, CA 94105
Region X
Betty Wiese - (206) 399-1260
Waste Management Branch
U.S. Environmental Protection Agency
1200 6th Avenue
Seattle, WA 98101
The Office of Sol id Waste maintains a data base of RCRA information and can
make this information available to the EPA regional offices. Much of this data
is accessible by computer.
DATA NEEDS
GeoIogy
Knowledge of local bedrock types and depths is important to the investi-
gation of a hazardous waste site, particularly where ground water is a source of
drinking water. Sedimentary strata (limestones, sandstones, shales) tend to
channel ground-water flows along bedding planes; flow directions may sometimes
be determined by the dip of the strata. Solution channels may develop in
I imestone or marble a I lowing 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 ground water along fracture zones. Depth to bedrock may
be an important factor in selecting the appropriate type of remedial action.
Sources of geologic information include USGS reports and files, state geological
survey records, and well drilling logs.
Overburden
Information concerning soil and overburden types and permeabilities is
very important in evaluating the potential for migration of contamination from
a waste management site. Highly permeable soils (i.e., 10-3 cm/see) may permit
rapid migration of pollutants, both vertically and horizontally, away from
containment areas. Rates of attenuation, retardation, degradation, and
transformation of pollutants in the unsaturated zone and underlying aquifers
are a function of soil chemistry, waste chemistry, and physical characteristics
of the so i I and waste.
CI i mate
Climate is also an important factor affecting the potential for contaminant
migration from a hazardous waste site. Mean values for precipitation, evaporation,
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evapotranspiration, and estimated infiltration will help determine the potential
for transport of pollution at a site, and the possibi I ity of pollutant transfer
from the site. Even in an arid region where little or no recharge to ground
waters usually occurs, an extremely wet year may have created a serious pol-
lution problem. In evaluating the pollution potential of a "nondischarging"
surface impoundment, calculating a water balance will show whether seepage is
occurring. The investigator should consult monthly or seasonal precipitation
and evaporation (or temperature) records. The maximum recorded or estimated
rainfall in a short period of time (24/48-hour or monthly) may be an important
factor in evaluating freeboard needed for a surface impoundment. Where airborne
contaminants may be a problem, it wi I I be important to determine prevai I ing
wind patterns and velocities. Climate and weather information can be obtained
from:
National Climatic Center
Department of Commerce
FederaI Bu i Id ing
Ashville, North Carolina 28801
FTS -- 672-0683
(704) 258-2850
Hydrology
The investigator will need information on the ground-water and surface
water hydrology at a site and for its environs. Depths to the water table and
any underlying aquifers, characteristics of confining layers, piezometric
surfaces (heads) of confined aquifers, aquifer head distribution, direction of
flow, existence of perched aquifers, and areas of interchange with surface
waters wi I I be vital in evaluating the pollution potential of a faci I ity.
Ground-water production in the area of the site should be investigated to find
depths of wells, pumping rates, and uses of the water. Sources of such
information include the USGS, state geological surveys, well drillers, and
state and local water resources boards. The list is also available at EPA
Regional Offices. Water quality for ground water and surface water, is available
from USGS via their automated NAWDEX system; for further information telephone
FTS: 928-6081 or (703) 860-6031.
All surface waters and dry water courses in the area should be investigated;
surface gradients on and 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. If pollution of
surface waters is suspected, collect base-line water quality data and stream
flow rates. Obtain information on NPDES permitted discharges in the vicinity
of the site under investigation. Useful information on surface waters can also
be topographic maps, aerial photography, and the NAWDEX systems.
Sensitive Environments
The investigator also needs to determine if the site is located in a
sensitive environment; e.g., inside or adjacent to wetlands, arctic, alpine,
desert, estuarine areas, or habitats of endangered species. In general, the
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potential for long-term environmental disruption, if a discharge or spi I I of
hazardous wastes should occur, must be determined.
Population at Risk
Before visiting a site, it is advisable to gather information about the
surrounding area. For the safety of those conducting a site visit, the names
and telephone numbers of police and fire departments responsible for that area
should be obtained. These departments also may be able to provide information
on violations of fire laws and safety codes, including records of incidents at
the site. The most important characteristics for determining the hazards in a
given situation are population densities 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 explosives, such as liquified natural gas, are stored near
the site.
Sources of drinking water in the area, both public and private, should be
noted. The investigator should try to obtain copies of analyses performed on
these water suppl ies and determine what treatment system is used by the pub I ic.
If the site area is serviced by a public water supply, determine locations of
water mains to assess the possibi I ity of contaminated ground water entering the
public water system. Likewise, information should be gathered on the local
sewer and storm drain systems to determine possible infiltration of illegal
discharge points. Land use near the site should be studied; types of crops or
livestock in the area should be noted, as well as information on the wildlife
or aquatic life in the area.
Suspected Contaminants
Information on what material was stored or uti I ized at the site is
invaluable for several reasons. Knowledge of the chemical properties
(volatility, volubility, reactivity and flammabi I ity, etc. ) of the material
onsite wi I I assist in the hazard ranking of the site, as wi I I knowledge of the
toxi logical effects of these materials. Further, if the characterization
proceeds through a Site Inspection or Remedial Investigation, such knowledge
will assist investigators in selection of proper levels of protection to reduce
the riske of exposure. In addition, it will assist the inspection and
investigation in resolving the impact of the site by concentrating efforts on
the appropriate vectors for contaminant migration. For example, if it is
discovered during the preliminary assessment that the operations at the site
dealt extensively with acid solutions and waste metals of low volati I ity,
the remedial investigation can be targeted on the hydrology of the site with
less concern for atmospheric dispersion.
Hazardous Waste Management Information
When no information on wastes is available from government sources, it is
necessary to proceed with a site inspection and field investigation without
background documents. However, it may be possible to hypothesize the kinds of
waste discarded at the facility. If a site contains municipal and industrial
wastes, it is probable that much of the waste comes from local industries.
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Local officials or the Chamber of Commerce may be able to provide information
on nearby industries operating during the period in question. At an onsite
faci I ity it may be possible to determine the type of waste present from the
plant personnel. Information on the composition of waste streams from various
industrial processes may be obtained from the Hazardous and Industrial Waste
Division of the EPA Office of Solid Waste in Washington, D.C.
Available Aerial Photographs
Aerial reconnaissance is an effective and economical tool for gathering
information on waste management sites.
For this application, aerial reconnaissance includes aerial photography
and thermal infrared scanning. Aerial photography is universally used for
gathering data during daylight hours. The thermal infrared scanning is
occasionally done during day I ight, but has greater uti I ity at night.
In general, aerial reconnaissance should be performed during a preliminary
i nvest i gat i on to obta i n data on:
extent of solid and liquid waste disposal/holding sites within
seIected fac i I i t i es;
casual disposal sites (sites in which control measures are lax or do
not exist);
* illegal or promiscuous dumping within industrial, state or municipal
facilities or at remote sites;
* unauthorized disposal of liquid waste at solid waste disposal sites;
* visible environmental effects resulting from disposal practices such
as spills, surface run-off patterns, surface leachate flow, impound-
ment leakage and damaged or stressed vegetation in the immediate
environs of disposal sites;
surficial geology such as faults in or near the sites;
storage container location;
container inventories;
waste disposal sites not directly visible or readily accessible from
the ground;
* facility design and operation, pertinent to the investigation;
* land use of site environs; and
* location of possible hazards to inspectors.
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Information on aerial reconnaissance and the aerial data processing
is available at these EPA offices:
Environmental Monitoring Systems Laboratory (EMSL-LV)
P.O. Box 15027
Las Vegas, Nevada 89114
(FTS) 545-2660
(702) 798-2660
National Enforcement Investigations Center (NEIC)
Bui Id ing 53, Box 25227
Denver, Colorado 80225
(FTS) 234-4650
(303) 234-4650
Environmental Photographic Interpretation Center (EPIC)
P.O. Box 1587
Vint Hill Farm Station
Warrenton, Virginia 22186
(FTS) 557-3110
(703) 347-6224
Each office maintains its own archive of aerial reconnaissance imagery
(photography and thermal scanner data) and has access to historical imagery
from other government agencies.
Archival Imagery--
Federal agencies have been using aerial photography for a variety of
purposes for several decades. Useable photographs less than five years old
will usually be available for a site. Frequently however, the scale will be
too smaI I to observe detai Is of the site without considerable magnification of
the imagery. In cases where it is important to gather information on the
locations, area I 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:
U.S. Geological Survey
EROS Data Center
Sioux Falls, South Dakota 57102
(FTS) 784-7151
(605) 594-7151
Commercial mapping companies in nearby cities may also have aerial photographs
available. There are approximately 200 such firms in the United States.
Photographs taken before 1950 are available from the National Archives.
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General Service Administration
National Archives
Cartographic Branch
8th and Pennsylvania Ave., N.W.
Room 2W
Washington, D.C. 20408
(FTS) 756-6700
(202) 756-6700
A list of available aerial photography can be obtained by requesting Special
List No. 25 "Aerial Photographs in the National Archives." Generally, the
requester must specify the geographical coordinates (latitude and longitude) of
the site when requesting aerial photographs. Information on the photography
available for a given site usually can be obtained through the above facilities
in less than 30 minutes. Standard orders for copies of photographs are proc-
essed within six weeks; priority requests require approximately one week at a
significantly higher cost. Photo interpretation is available through EMSL-LV
in coordination with EPIC and NEIC.
Preparation of Sketch Map--
The sketch map should uti I ize aval I able aerial photographs of the site and
reflect any updated information collected during the Preliminary Assessment.
In some instances the aerial photographs will be readily available and of
sufficient quality to be used instead of a sketch map. It is often convenient,
however, to have multiple copies of an easily reproducible site sketch map
which can be marked and drawn on as the investigation progresses.
Determination of Responsible Parties
Cleanup of uncontrolled hazardous waste sites is authorized by the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), known as Superfund. Either the Federal government or the responsible
parties will clean up the site. If the parties (or party) can be identified,
they may be required to either correct the problem or reimburse the Superfund
for the government's expense to correct the problem.
Responsible parties may include:
* owners of the site (past and present);
* operators of the site;
generators of hazardous substances, pollutants, or contaminants that
are stored, treated, or disposed of onsite; or
transporters of hazardous wastes.
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The responsible parties are liable* for
* costs** incurred by the Government or a state for investigations,
removals or remedial actions;
* any other necessary costs of response incurred by any other person;
and
* damages for injury to, destruction of, or loss of natural resources,
including the reasonable costs of assessing such injury, destruction,
or loss resulting from a release of hazardous substances
Guidelines to aid in the identification of responsible parties are
presented in "Procedures for Identifying Responsible Parties, Uncontrolled
Hazardous Waste Sites - Superfund", February 1983. At present this document is
available, only as a draft, through the NEIC in Denver, Colorado.
During the process of identifying responsible parties-including potentially
culpable individuals, interlocking relationships and ownerships, and financial
solvency -- it is essential to keep detailed records and notes of what is learned
during each step of identification. These records and notes, in addition to
providing additional or new leads, will document the EPA effort to identify
responsible parties. Documentation is particularly important should be respon-
sible party be identified after the government has spend Superfund monies to
correct problems. Also, documentation will be necessary if the party does not
agree that it is responsible or partly responsible for the problem at the
uncontrolled site.
All further activities including site inspections and field investigations
should aid in collecting evidence of responsible parties. In most situations
site characterization studies will run parallel with enforcement investigations
conducted by OWPE. Cooperation with this office or other evidence audit teams
is essential. All requests for responsible party searches should be coordinated
with OWPE and wi I I normally be performed by an enforcement contractor.
*Section 107.(a) of CERCLA (Superfund)
**Costs consistent with the National Contingency Plan, referred to in CERCLA
(Superfund)
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SECTION 5
SITE INSPECT!!
INTRODUCTION
The National Contingency Plan (NCP) mentions Site Inspections as being
important parts of both Phase II, Preliminary Assessment and Phase IV, Evalua-
tion and Determination of Appropriate Response - Planned Removal and Remedial
Action.
The major objective of a site inspection is to determine if there is any
immediate danger to persons living or working near the facility. Additionally,
the site inspection should provide the necessary information required for the
Hazard Ranking System (MRS).
The primary items addressed during the site inspection are:
- A determination of the need for immediate removal action;
- An assessment of the amounts, types and location of stored hazardous
substances;
- An assessment of the potential for substances to migrate; and
- Documentation of immediate threats to the public or environment.
The NCP states that "In general, the collection of samples should be min-
imized during inspection activities; however, situations in which there is an
apparent risk to the public should be treated as exceptions to that practice."
Time constraints during Site Inspections typically prevent elaborate
sample acquisition tasks and may therefore reduce the effectiveness of sample
collection in terms of information gain. The limited on-site time often can be
more effectively scheduled and utilized by other data gathering and documenta-
tion tasks.
A site inspection is usually conducted both offsite and onsite. It often
results in the collection of key evidence for immediate enforcement action and
identification of responsible parties. Site inspections should be thorough,
methodical, and well documented. In order to acheive this goal, the potential
Hazardous Waste Site Inspection Report, EPA Form 2070-13, July 1981, should be
completed (see Appendix C). In addition to summarizing the information col-
lected during the Site Inspection, this form contains all the information
needed to add a site to the automated Emergency and Remedial Response
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Information System (ERRIS) should it be required at this point. OERR operates
ERR IS as a central computerized tracking system for hazardous waste sites.
Chain-of-custody and document control requirements also must be followed. The
information collected previously during the preliminary assessment should be
thoroughly reviewed, and a strategy for the site inspection effort should be
developed and precisely implemented by the investigators.
ONSITE INSPECTION
General
The onsite efforts must closely follow the strategy developed before the
insepction began. The site inspection report should be completed to assure
that all the tasks are addressed. The objectives may include the following:
* determination of the need for emergency response;
determination of disposal practices and methods;
compliance with Federal, State and local regulations;
determination of the extent of contamination;
accounting of the amounts and locations of hazardous waste stored;
* determination of the potential for materials to migrate offsite;
determination of access control;
documentation or determination of imminent hazards;
remedies to bring the site into compliance;
* review of site records;
* inventory of drums or drum contents;
* mapping the site;
* determination of safety procedures for field investigation;
* determination of potential sampling sites for field investigation;
* sample collection during inspection;
* collection and preservation of evidence documenting criminal activity;
and
* verification of information collected during the Preliminary
Assessment.
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The site inspection strategy wi I I del ineate 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 site inspection, some modifications
in the strategy may be necessary when unforeseen circumstances arise.
Safety
During the site inspection, safety precautions are paramount to all other
considerations because the inspector will not have adequate knowledge of site
conditions. It is impossible to anticipate every hazard that could arise;
therefore, the inspector should use common sense, judgment, and experience.
Section 3 of this document provides guidance for establishing proper safety
procedures for site inspections.
Photographs
Photographs are important for documenting the cause and effect relationship
of hazardous materials migrating offsite as well as for providing visual proof
of potential hazards and/or criminal activities. Special attention should be
given to areas of apparent environmental damage and potential exposure to the
public. Photographs should be taken at every sampling location to verify the
written description in the field log book. When using self-contained breathing
apparatus, the face mask will make focusing the camera difficult; therefore, it
is recommended that a camera with an automatic focus sensor be used. In all
cases where photographs are taken, the following information must be recorded:
* time, date, location and, if appropriate, weather conditions;
* complete description or identification of the subject in the photo-
graph and reason why the photograph was taken;
the sequential number of the photograph and the film roll number; and
name of person taking picture.
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 rolI of fi Im and ask that it be developed and
sent to the FIT leader after review by the owner or operator. Care should be
taken to avoid photographing a patented process.
If si ides are taken, the developed si ides should be referenced to the
correct description in the field logbook. In many cases, processed slide
numbers wi I I not correspond to the number on the camera exposure counter.
When the photographs are developed, transcribe the information recorded in
the field logbook onto the back of the photographs. Photographs and negatives
are part of the project fi les and must be accounted for under the Document
Control and Chain-of-Custody procedures explained in Section 2 and Volume II,
Appendix D.
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Mapping the Site
The sketch map prepared during the Preliminary Assessment should be
verified, updated and expanded. Information gained during the onsite inspection
should be added to the map as soon as possible, preferably before leaving the
immediate area of the site. The map will become a primary aid for conducting
the Remedial Investigation. In many situations planning for this investigation
will be the responsibility of several people each directing a particular task.
Thus, the information on the map must be complete and tear to each user and
ideally, should not require further interpretation by its author. Symbols and
codes should be clearly explained in a legend attached to the map. The map
should provide the information needed for siting of command posts, decontamina-
tion and safety faci I ities. The location of uti I ities and the width and clear-
ance heights of gates and doorways should be marked on the map. If the sketch
map is not to scale, appropriate measurements should be made and noted, so that
features can be transferred later onto a scale map. Aerial photographs can be
very valuable aids to mapping sites.
Prel imi nary Samp I i ng
Site inspection efforts will not normally involve elaborate sampling;
however, safety requirements for onsite inspections (Section 3) usually include
the use of instruments capable of detecting hazards which are immediately
dangerous to life and health. They most commonly include, but are not limited
to the f o I I ow i ng:
• radiation survey instruments,
* combustible gas/vapor indicators,
* oxygen level indicators, and
* organic gas and vapor detectors.
Each of these general types of devices is fully discussed in Volume I I -
"Available Sampling Methods". In addition to their use as a personal monitoring
device, they can supply valuable information pertinent to planning for the
Remedial Investigation. It is virtually impossible for a single individual to
accurately survey a site with all four of these instruments and sti I I maintain
the level of documentation necessary. In practice, a site inspection usually is
carried out by teams of two or more, and because expIosimeters and oxygen
monitors are often combined into a single device, accurate and well documented
surveys are possible. In addition, when sufficient information is available,
one or more of these monitors may not be required or can be replaced by more
specific instruments where warranted.
Sampling during site inspections usually will be limited to grab samples
or screening samples in order to gather information for future sampling and
monitoring programs. At this point in the inspection, very little information
concerning the site may be known, and detailed sampling efforts could be wasted
or results misinterpreted. It may be required, however, to collect preliminary
samples during a site inspection. If this is the case, the appropriate sections
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of Volumes I through III should be consulted. It should be noted that if
sampling is required at this point, great care should be exercised to ensure
the safety of the pub I ic and personnel involved.
All samples collected from onsite should be considered to be potentially
high-hazard, and must be handled accordingly unless there is clear evidence to
the contrary. Onsite samples include contaminated soils or sludges, liquids
from onsite impoundments or pits, leachates, etc. Packaging and shipping
requirements for these samples are discussed in Section 2.
Generally, site inspection teams should not collect samples from closed
containers. The hazards and risks associated with opening such containers and
collecting aliquots demand safety precautions that require personnel and equip-
ment far in excess of a site inspection effort.
Pre-Sample Survey
During the onsite inspection, particular attention should be paid to the
areas that may warrant sampling during the Remedial Investigating. These
observations will assist the sampling teams in compiling the necessary equipment
needed during the conduct of the Remedial Investigation. The type of infor-
mation that may assist in planning sampling efforts associated with Remedial
Investigations is evident from the following questions.
Genera I:
• How rough is the terrain?
• How thick is the underbrush and ground cover?
* What is the apparent typical wind direction?
• How is the waste material arranged?
Surface Waters:
• How large are they? What are their approximate widths and depths?
* Are there currents?
* How steep are the banks and are they secure?
* Is the bottom rock/gravel or sediment/sand?
• Wi I I they flood or freeze?
Soi I :
* Is there surface vegetation?
• Does it appear to be landfill or rubble material?
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• Are there areas of exposed rock?
This list is by no means complete but exemplifies the type of information
that will, in conjunction with inspection reports, photographs, and material
from preliminary assessments, assist the Remedial Investigation teams in prepar-
ation for their tasks.
Inspection of Onsite Structures
Bui I dings--
The inspection of buildings and all above-ground structures must be con-
ducted with great care. The inspection should begin with a thorough evaluation
of the exterior of these structures. Particular attention should be paid to the
type of construction and the (construction) materials used. The inspection
should determine if power lines enter the building, and if so, look for a power
meter and observe it for current usage. A similar inspection should be made
for other utilities. Note all exits and their accessibility as well as windows
and ventilation. Finally, assess the overall structural stability.
Interior inspections will generally require additional safety precautions
and manpower not normally available. The hazards associated with entering a
structure require precautions against loss of contact with support personnel,
reduced visibility from poor or inadequate lighting, increased trip hazards and
obstructions, physical deterioration and structural failure as well as insuf-
ficient ventilation and resultant fire, explosion or toxic gas hazards.
In some instances where the building is currently in active use by onsite
personnel or the exterior inspection indicates sound construction and adequate
ventilation, entry is at the discretion of the On Scene Coordinator. Otherwise
interior inspections should be limited to observations from doors and/or
windows.
In any case, all windows and doorways should be surveyed (with monitoring
equipment) and the readings recorded. If it is then decided to enter the
building these instruments should accompany the inspectors.
Basins and Vessels--
Inspections of basins and vessels should verify structural dimensions and
note the number and location of input or discharge lines. Any manways, hatches,
or valve pits should be identified and monitored with the survey instruments.
If the structures contain a material, an estimate of percent full (look for
staff gauges or site glasses) and a description of the material should be
noted. A general assessment of structural condition also should be included.
Underground Tanks--
The presence of buried vessels is often only apparent upon discovery of
small standpipes or vents protruding above the ground surface. All such pipes
should be noted and marked with colored tape and/or flags. Closer investigation
of the immediate vicinity of the vents often uncovers hatches or valve pits.
Further investigation during the inspection should be limited to screening the
vents and hatch seals with an OVA, Hnu or other monitors.
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Leaving the Faci I ity
Before the onsite inspection is completed, the inspector should update the
site map, locating fixed reference points and key features. If samples are
collected, the sample locations should be marked on the sketch. An inventory
of visible drums should be made where possible and also located on the map.
When the inspection is completed, the inspector should notify the appro-
priate person at the site. If samples have been collected, RCRA and CERCLA
require that before leaving the site the inspector give the owner, operator, or
agent-in-charge a receipt describing the sample(s) and, if requested, a portion
of each sample equal in volume or weight to the portion retained. If such
split samples are provided, a Receipt for Samples form 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
samp I ing.
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.
If access to the site is control led by fencing and locked gates, the
inspectors must lock the gates when leaving. The date and time the gate was
locked should be noted in the field logbook. If left unlocked, an entry should
be made in the logbook stating the reason.
OFFSITE INSPECTION
General Environs
Population--
Information regarding population size and distribution should be available
from the preliminary assessment. In many instances this information, if
obtained from state or regional agencies will be somewhat dated. It is impor-
tant therefore to tour the area assessing the I ike I ihood of significant demo-
graphic changes. Recently constructed housing developments, apartments, schools
and public buildings may indicate that changes have occurred since the infor-
mation was pub I ished.
Land Use--
The same circumstances necessitating reevaluation of population information
hold true for land use studies. Substantial alterations in the immediate area
of the site can occur in a single year. Farmland can be developed into in-
dustrial parks, office or apartment complexes or other high population density
uses. Careful observations for signs of recent excavation such as roadway
construction or resurfacing, stream or bank improvements, trenching for sewer
or other utility installation are all critical. These situations can dramatic-
ally effect the sites hydrology, public access, animal population, as well as
many other aspects of a site which wi I I have impact on future remedial or
enforcement activities.
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SECTION 6
DATA EVALUATION
INTRODUCTION
Following and in many cases concurrent with the collection of preliminary
information, a data assessment is performed to ultimately assist in formulating
response management decisions affecting later stages of the investigation.
The data evaluation may also indicate data gaps which need to be filled either
by further background research or additional site inspections (or an initial
inspection if one has not yet been conducted). Following the completion of the
organization and review of all collected information, the site is then given
a ranking through the mechanism of EPA's Hazard Ranking System (MRS), and,
depending upon the magnitude of the resulting score, the site may or may not
be placed on the National Priorities List (NPL). All of this information is
ultimately used to choose a course of action concerning future remedial
activities.
The evaluation should encompass the scope detailed below:
* the existence (or nonexistence) of a potential hazardous waste
problem;
* probable seriousness of the problem and the priority for further
investigation or action; and
* the type of action or investigation appropriate to the situation.
Participants
Evaluation of the data by a team of specialists is desirable. Partici-
pants with some or a I I of the following professional and technical ski I Is
should be included in the process as appropriate: an environmental engineer
(environmental, civil, sanitary, chemical or industrial engineer), a geo-
hydrologist, a chemist, and an attorney are recommended. Personnel with skills
in the assessment of health effects of exposure to toxic or hazardous sub-
stances, engineering personnel with 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.
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Necessary Data
The data needed to evaluate the pollution potential of a hazardous waste
site can be roughly organized into the four categories presented in Table 6-1.
Each category can be defined generally as follows:
"Waste Characteristics" refers to factors describing the nature of the
substances, i.e., their immobility and persistence in the environment. "Waste
Management" answers whether the materials are adequately isolated and contained
or destroyed at the site. "Pathways" describes possible routes of material
movement offsite and must be considered as a function of time. "Receptors"
describes the sensitivity of the site environs to pollution. Data sets under
each heading provide a relatively limited amount of information; available
manufacturing process information should be factored into any decision. In
many instances, not all needed information will be available for initial eval-
uations; therefore, site inspection and field investigation efforts should be
focused on acquiring this missing information.
All of the collected data needs to be summarized in a fashion that ensures
completeness, uniformity and ready access. To accomplish this, it is sometimes
helpful to use a form or checklist as an organizational aid. The "Potential
Hazardous Waste Site Preliminary Assessment Form, EPA 2070-12, July 1981" (see
Appendix B) is an example of such a form which is useful for this purpose. It
is normally used to place site information in a format compatible with the
automated Emergency and Remedial Response Information System (ERRIS).
ERR IS is one of the two automated data systems developed by OERR to
inventory and later track National Priority List (NPL) sites. It is an auto-
mated inventory of all uncontrolled hazardous substance sites in the United
States which are known to the EPA. As such, it contains a multitude of infor-
mation concerning the site including location, description, summary of response
actions, enforcement status, site characteristics and regional input, etc. If
a site is placed on the NPL, information is transferred to the second data
system entitled Project Tracking System (PTS). The PTS is further updated on a
regular basis through regional input and is used to track planned and actual
activities for each NPL site.
Evaluation of Pollution Potential and Setting Priorities
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., ground water, surface water, air direct contact, and fire/
explosion. Under each item on Table 6-1 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.
In passing CERCLA, Congress recognized the need for a systematic approach
to setting priorities. Section 105(8) of the Act requires the President to
include criteria for setting priorities among releases and potential releases
of hazardous substances as part of the National Contingency Plan. The criteria
take into account the population at risk, the nature of the hazardous sub-
stances, the potential for contaminating drinking water supplies, the potential
6-2
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TABLE 6-1. DATA REQUIRED FOR EVALUATION
Waste Characteristics Waste Management
Toxicity (Sax toxicity)l»9>s«a»d
Ignitability (flash point or
NFPA numberjM.a.g
Reactivity1>a»(J»9>f
Corrosivityl»d
Infectivityl»9»s»a»d
Persistencel»9»s»a
Radioactivityi'Q.s.a.d
Solubilityl.a.d.f
Volatilityl.a.d.f
Leachate/runoff col lection and treat-
ment system^,s,9
Linears9
Site security^
Incompatible wastes3>d>f
Condition of containers^>9»s»a)d,f
Danger of fire or explosion due to
poor management practices3^,f
Inc i nerator performance/poI Iut i on
control devices3
Pathways
Receptors
Depth to ground water9
Soi I permeability9
Bedrock permeability9
Key:
lland
9ground water
ssurface water
"di rect contact
re/explosion
Population densityl»9»s»a»d
Proximity to surface drinking water
supplys»9
Proximity of drinking water we11s9
(continued)
6-3
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TABLE 6-1. (Continued)
Pathways
Receptors
Proximity to surface water bodys»9
Net precipitation9
Soi I thickness^
Proximity to nearest nonsite-related
bui Idingl >a»d>'
Zon ing,/1 and-use of adjacent
Zon inq./1 and-use of adjacent
»a >^ »'
Evidence of ground-water
contamination9
Evidence of air contamination3
Evidence of land contamination^
Key:
l|_and
9ground water
ssurface water
^direct contact
^fire/explosion
for direct human contact, the potential for destruction of sensitive ecosystems,
state preparedness and other appropriate factors.
In setting priorities, the investigator should be familiar with the fol-
lowing model developed specifically for evaluating these data. The general
characteristics of this model are summarized below:
Hazard Ranking System--
EPA in conjunction with the MITRE Corporation developed a method for
ranking facilities according to risks to health and the environment. It is
designed to address surface water, air, fire and explosion, direct contact,
and ground-water contamination. Three migration routes of exposure (see Table
6-2); ground water, surface water, and air are evaluated and the scores are
combined to derive a score representing the relative risk posed by the
facility. Two additional routes of exposure, (1) fire and explosion, and
(2) direct contact, are measures of the need for emergency action. The
routes are scored independently and the dependent nature of the variables
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TABLE 6-2. COMPREHENSIVE LIST TO
RATING FACTORS
Factors
Hazard code? Factor category
Ground Water
Surface
Air route
Migration
Fire and
Explosion
Route o Depth to Aquifier of Concern
Characterization o Net Precipitation
o Permeability of Unsaturated
Zone
o Physical State
Containment o Containment
Waste o Toxicity/Persistence
Characteristics o Hazardous Waste Quantity
Targets
o Ground-Water Use
o Distance to Nearest Well/
Population Served
Containment
o Containment
Waste o Direct Evidence
Characteristics o Ignitability
o Reactivity
o Incompatibility
o Hazardous Waste Quantity
o Facility Slope and
Intervening Terrain
o One-Year 24-Hour
Rainfall
o Distance to Nearest
Surface Water
o Physical
o Containment
o Toxicity/Persistence
o Hazardous Waste
Quantity
o Surface Water Use
o Reactivity/
Incompatibility
o Toxicity
o Hazardous Waste
Quantity
o Land Use
o Distance to Sensitive o Population within 4-
Environment Mile Radius
o Population Served/
Distance to Water
Intake Downstream
o Distance to Sensi-
tive Environment
(continued)
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TABLE 6-2. (Continued)
Factors
=======================================
Hazard Factor category
Ground Water
Surface
Air route
Di rect
Contact
cr>
Targets
• Distance to Nearest Population
• Distance to Nearest Building
• Distance to Nearest Sensitive
Environment
• Land Use
• Population Within 2-Mile
Radius
• Number of Buildings Within
2-Mile Radius
Observed Incident • Observed Incident
Accessibility
Containment
Toxicity
Targets
• Accessibility of Hazardous
Substances
• Containment
• Toxicity
• Population Within 1-Mile
Radius
• Distance to Critical Habitat
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is reflected by multiplying where appropriate. The system requires a great
amount of detailed information. If real data are not available, estimates
must be made. However, the final scores from estimates are adjusted lower
than scores obtained using known data, to represent the uncertainty inherent
i n est i mates.
The Hazard Ranking System (HRS) has been incorporated into the Federal
Register (Vol. 47, No. 137, Friday July 16, 1982/Rules and Regs. pg. 31219,
Subpart H, "Section 300.1) and is the only model currently used by EPA to
assess risk during hazardous waste site investigations. The HRS evaluates
the input parameters and yields a final "score". The magnitude of this score
will determine if the site will make the National Priority List and its
el igibi I ity for assistance under Superfund.
OPTIONS FOR ACTION
Upon completion of the preliminary data gathering phases, certain decisions
must be made concerning further actions needed at the site. Subpart F, 300.66
(a) of the NCP, makes provisions for the determination of appropriate action
when (1) the preliminary assessment indicates that further response may be
necessary, or (2) the On Scene Coordinator (OSC) requests and the lead agency
concurs that further response should follow an immediate removal action.
The NCP specifies the following alternatives when further action is
necessary:
- Planned Removal
- Remed i a I Act i ons
. Initial Remedial Measures
. Source Control Remedial Measures
. Offsite Remedial Measures
No Act i on Requ i red
When the evaluation indicates that the site has been operated and closed
properly, and further inspection is deemed not necessary, a report should be
prepared summarizing the data and conclusions. The report should include all
information collected including the rationale used to arrive at the decision
for no action. If any inspection or field investigation was conducted as part
of the data gathering activities, all data and resulting conclusions should
be incorporated.
PIanned RemovaI
As specified in Section 300.67 of the NCP, planned removals may be under-
taken when the lead agency determines that (1) there would be a substantial
cost reduction by continuing a response action undertaken as a result of an
immediate removal, or (2) when the public and/or the environment will be at
6-7
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risk from exposure to hazardous substances if the response to a release from
sites not on the NPL is delayed. EPA has further specified a number of criteria
in 300.67 for determining if a planned removal is appropriate.
These factors include:
1. Actual or potential direct contact with hazardous substances by near-
by populations.
2, Contaminated drinking water at the tap.
3, Containerized wastes that are known to pose a public health or envi-
ronmental threat.
4. Highly contaminated soil (largely at or near the surface) that pose
a public health threat or an environmental threat.
5, Serious threat of fire or explosion.
6, Weather conditions that may cause substances to migrate or pose a
threat to public health or the environment.
Each of these factors should be carefully considered prior to deciding on
a planned removal action. In addition, a planned removal cannot be initiated,
unless the Governor (or his designee) of the state affected requests the action.
Section 300.67(b) lists those factors which must be included in this request.
A planned removal action is terminated once the risk to public health or
the environment has been abated. Planned removals are therefore meant to
relieve an imminent threat to public health or the environment prior to the
implementation of a permanent remedy. In this regard, planned removals are not
to be confused with remedial actions which are responses (to NPL sites) that
are consistent with permanent remedy.
Remed i a I Act i on
Remedial actions taken at a hazardous waste site are those responses to
release of hazardous substances from NPL sites that are consistent with the
institution of a permanent remedy. The two general responses, initial remedial
measures and final remedial actions, include both source control and offsite
remedial actions. Initial remedial measures are taken to limit exposure or
threat of exposure to a significant health or environmental hazard and are
undertaken prior to final selection of appropriate remedial action. Conversely,
source control remedial actions and/or offsite remedial actions are conducted
after all data have been evaluated to select the most appropriate and feasible
alternative.
Initial Remedial Measures--
As previously discussed, initial remedial measures (IRM's) are taken
before final selection of the appropriate remedial action. They are intended
to limit exposure or threat of exposure to a significant health or environmental
hazard, provided such measures are cost-effective (300.68)(e)(I).
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The NCR further lists a number of criteria that should be reviewed before
initiation of an IRM. These factors include:
1. Actual or potential direct contact with hazardous substances by nearby
popuI at ions.
2, Absence of an effective drainage control system (with an emphasis of
run-on control).
3, Contaminated drinking water at the tap.
4, Hazardous substances in drums, barrels, tanks, or other bulk storage
containers above surface posing a serious threat to public health or
the environment.
5, Highly contaminated soils largely at or near surface, posing a serious
threat to public health or the environment.
6, Serious threat of fire or explosion or other serious threat to public
health or the environment.
7, Weather conditions that may cause substances to migrate and to pose a
serious threat to public health or the environment.
These factors need to be thoroughly reviewed prior to the determination of
the need for an IRM. In addition, an IRM cannot be implemented without com-
pl iance with 300.67(b) of the NCR. As with Planned Removals, this section
requires the Governor of the affected state, or his designee, to request the
action.
Final Remedial Action--
In order to select the most effective, economically feasible, and technically
sound alternative for permanent remedy, it will be necessary to evaluate all
available information about the site. To accomplish this, a series of defined
steps are taken which ultimately results in the selection of the most cost
effective alternative. It is far beyond the scope of this document to provide
guidance for performing these various steps. Detailed guidance available from
the appropriate EPA program offices will accomplish this task much more effec-
tively. The following synopsis of the various steps called for in the NCR is
therefore presented for convenience and does not reflect the differences in
approach taken by enforcement, or remedial action, driven investigations. The
basic steps involved include:
* Scoping Phase
* Remed i a I Invest i gat i on
* Feas i b i I i ty Study
* Design and Implementation
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In general, permanent remedies include the following two categories:
* Source control remedial actions, and
* Offs i te remed i a I act i ons.
A description of these actions, including the appropriate NCR citation, follows.
Source Control Remedial Actions -- As specified in 300.68(e)(2) of the NCR,
source control remedial actions may be deemed appropriate if a substantial
concentration of hazardous substances remain at or near the site or near the
area where they were originally located and inadequate barriers exist to retard
migration of substances into the environment. Source control may involve
containing the substances where they are located or transporting the substances
offsite. In order to determine whether and what type of action is appropriate,
the NCR further states that the following criteria be considered:
* "The extent to which substances pose a danger to public health, welfare,
or the environment. Factors which should be considered in assessing
this danger include: population at risk; amount and form of the sub-
stance present; hazardous properties of the substances; hydrogeological
factors; and climate."
• "The extent to which substances have migrated or are contained by either
natural or man-made barriers."
* "The experiences and approaches used in similar situations by state and
federal agencies and private parties."
* "Environmental effects and welfare concerns."
Source control remedial actions that might be considered include but are not
I i m i ted to:
* No act i on
* Conta i nment
* Pump i ng
* Col lection
* Diversion
* Complete removal
* Partial removal
* Onsite treatment
* Offsite treatment
6-10
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* In situ treatment
* Storage
* Offs i te d i sposaI
Offsite Remedial Actions -- In 300.68(e)(3), the NCR states it may be
appropriate in certain situations to take actions necessary to minimize and
mitigate the migration of hazardous substances and the effects of such migration.
These actions should be taken when it is determined that source control remedial
actions may not effectively mitigate the problem.
The NCR further specifies that the following criteria be considered to
determine the nature and type of offsite actions to be considered:
* "Contribution of the contamination to an air, land, or water pollution
problem."
* "The extent to which the substances have migrated or are expected to
migrate from the area of their original location and whether continued
migration may pose a danger to public health, welfare, or environment."
* "The extent to which natural or manmade barriers currently contain the
hazardous substances and the adequacy of the barriers."
* "The factors listed in paragraph (e)(2)(i) of this section."
* "The experiences and approaches used in similar situations by state and
federal agencies and private parties."
* "Environmental effects and welfare concerns."
Offsite measures which may be deemed appropriate after consideration of
the specified criteria include:
* Permanent alternative water supplies;
* Management of a drinking water aquifer plume;
* Treatment of drinking water; and
• Relocation of receptors.
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SECTION 7
FIELD INVESTIGATIONS
INTRODUCTION
The National Oil and Hazardous Substance Pollution Contingency Plan (NCP)
directly provides for sample acquisition and analysis during three of the seven
phases detailed in Subpart F, Hazardous Substance Response, those being:
- Phase III I mmed i ate RemovaI
- Phase IV Evaluation and Determination of Appropriate Response-Planned
Removal and Remedial Action
- Phase VI Remedial Action
Field Investigations, with respect to this document, involve actual sample
acquisition and associated support activities in the field. Field Investiga-
tions differ from Site Inspections (Section 5) both with respect to the extent
that they employ sample collection and the goals that they must meet. Whereas
the primary goal of a Site Inspection is to identify and document the presence
of hazards, the goal of a Field Investigation is to characterize the site for
anticipated remedial or enforcement activity.
A Field Investigation may be conducted in association with a number of
various tasks which must be performed by regulatory and enforcement agencies,
both Federal and State. Examples of tasks which may require Field Investiga-
tions are as follows:
- Remedial Investigation/Feasibility Studies as conducted by EPA, OERR
- Enforcement Remedial Investigations as conducted by EPA, OWPE
- Immediate Removal Actions as conducted by OERR or State Environmental
Agencies
In order to effectively uti I ize funds and limit exposure of field personnel
to onsite hazards, Field Investigations, regardless of their goals or office of
direction, must be designed to yield maximum information with minimum time on
site. Often a Field Investigation will involve several agencies and contractors
simultaneously. Effective use of these resources in a potentially hazardous
environment requires thorough planning and careful coordination.
The remainder of this section provides guidance in the effective preparation
of the Sampling Plan and its efficient implementation.
7-1
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PREPARATION OF THE SAMPLING PLAN
If after completing the Site Inspection (Section 5) and after reviewing
the background information of the Preliminary Assessment (Sections 4 and 6), it
is decided that a Remedial Investigation is needed, a comprehensive Sampling
Plan should be prepared. The Sampling Plan will generally be prepared by the
Project Manager. The Sampling Plan thoroughly details the course of the project
in terms of scope, logistics, and schedules. Among the items addressed in the
Samp I ing 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 including subcontracts; and
Chain-of-custody procedures.
A Safety Plan (see Section 3) and a QA Plan are prepared separately, but are
typically attached to the Sampling Plan as appendices.
The importance of the Sampling Plan cannot be overemphasized. The Plan
delineates manpower, equipment needs, schedules and logistics. The need for
additional equipment, contract services, or personnel must be determined far
enough in advance so that they can be secured expeditiously.
As appropriate, the Sampling Plan should be provided to the field team,
analytical staff, Quality Assurance Officer, Project Officer for any parallel
enforcement investigation, and other Regional personnel involved in the Project
at least four weeks before any specific field, laboratory, or consultant activ-
ity is undertaken. During the conduct of the project, some modifications to
the Plan may be necessary because of changing conditions. Before implemen-
tation, the Samp I ing Plan and any subsequent changes to it must be approved by
the Project Officer.
The remainder of this subsection deals with those aspects which must be
considered during the preparation of a Sampling Plan.
Samp I i ng Cons i derat i ons
Purpose and Objectives of Samp I ing--
The samples should provide the data to meet the objectives specified in
the Sampling Plan. The locations, types, and numbers of samples to be col-
lected should be determined from the site inspections and specified in detail
in the Plan. The objective of sampling is to acquire data which will assist
agency personnel in determining:
the identification of the hazardous waste or substances present at
the site, and
7-2
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* the occurrence and extent of hazardous substance migration.
The analysis of samples often provides a crucial portion of the evidence
used in subsequent litigation and is used in the development of appropriate
remedial action alternatives. In addition, this information will assist
enforcement personnel to prepare an Endangerment Assessment.
Hazardous waste sites are sampled to characterize the site for enforcement
or remedial work. The investigator must remain aware that any data collected
might be used in litigation and should always follow enforcement procedures
(chain-of-custody, etc.).
Computer Modeling--
Computer-based predictive models for the assessment of potential air emmis-
sions and ground-water contaminant migration are powerful and effective aids
in the determination of environmental impact. Consideration should be given to
the eventual use of such models during development of the Sampling Plan. An
understanding of the input data requirements of the models and their capabili-
t i es may i nfIuence the seIect i on of samp Ie Iocat i ons, coI Iect i on techn i ques,
and analysis and may actually enhance the general information yield.
Sample Categories--
Samples collected during site investigations generally can be classified
as environmental samples or hazardous samples. Hazardous samples are further
classified as "other than from closed containers" and "from closed containers".
Environmental samples contain concentrations of contaminants which have been
diluted due to runoff, mixing with surface and/or ground waters, weathering,
etc. Judgment by the Project Leader is essential in cases where runoff may
contain high concentrations of hazardous materials. If there is reason 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.
Sample Source I dent ificat ion--
The location of the source of each sample should be clearly defined in the
Sampling Plan. Whenever possible, sampling locations should be documented by
photographs. Every potential or priority sample location must be indicated on
the site sketch and described in detail in the Sampling Plan, specifying any
special safety requirements. For example:
Station 01: Environmental sample from onsite surface water impoundment.
Sample to be collected from top 6 in. 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 the entire depth with thief
7-3
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and place entire sample into container. SCBA and full
protective clothing must be worn.
A precise description of the sample location is important to insure that
field teams sample at the area of interest. Detailed and complete descriptions
of the exact location sampled wi I I be essential if the case proceeds to
I itigation.
Statistical Considerations
Genera I--
The underlying goal of any sampling campaign is to collect samples which
are representative of the media under consideration in relation to objectives
of the sampling program. In the "real world", however, especially when dealing
with hazardous waste site samples, collection of a truly representative sample
can be quite difficult if not impossible. Nonetheless, this fact should not
deter the investigator from making every attempt to realize this ultimate goal.
To assist in this endeavor, a sampling strategy should be developed which
details site location, number of samples to be collected, and the duration and
frequency of sampling. The selected strategy would be dependent upon a number
of factors, one of the most important being the variabi I ity of the Parameters
of interest (concentration) in space and time. This factor gives rise to the
need to address some basic statistical considerations to aid in the decision
making process surrounding sample strategy selection.
11 shouId be noted at th i s po i nt that the d i scuss i on that foI Iows i s an
overview of the theoretical approach for collecting a representative sample
based on general statistical considerations. For a detailed explanation of
sampling statistics, refer to any of the following reference sources used to
deveI op th i s sect i on:
* Harvey, R. P. Statistical Aspects of Air Sampling Strategies. In:
Detection and Measurement of Hazardous Gases; Edited by C. F. Cull is
and J. G. Firth. Heinemann Educational Books, London, 1981.
* Mason, B. J. Protocol for Soil Sampling: Techniques and Strategies.
U.S. EPA Environmental Systems Laboratory, Contract No. CR808529-01-2.
March 30, 1982. EPA-600/54-83-0020.
* Smith, R. and G. V. James. The Sampling of Bulk Materials. The
Royal Society of Chemistry, London. 1981.
* U.S. Environmental Protection Agency. Handbook for Sampling and
Sample Preservation of Water and Wastewater. EPA 600/4-82-029.
September 1982.
Media Variabi I ity -- Contaminant concentrations can vary considerably from
location to location within a specified study area or they can vary with time,
i.e., during the course of a normal workday/shift or a time period encompassing
several months or seasons. These variations are due to a number of factors or
combination of factors such as:
7-4
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* variations in the number of contaminant sources;
* variations in contaminant release rate;
* variations in contaminant dispersion from its release source; and
* length of time since release occurred.
When personal monitoring techniques are used, differences in individual worker
habits also may add to variations in collected samples. Factors include the
individuals proximity to contaminant sources, differences in the nature of
jobs/tasks between workers, and unique work habits.
The possibi I ity of contaminant variabi I ity is especially true for hazard-
ous waste site investigations. Areas of contamination may occur in localized
"pockets" scattered throughout the site. Types and concentrations of contami-
nants wi I I vary considerably from container to container or from area to area.
Sampling Strategies -- The selection of a sampling strategy is influenced by
a number of factors, two of the most important being project objectives and
statistical considerations. In relation to the former, the main objective of a
hazardous waste site investigation is to identify the compounds present and to
assess the extent to which these compounds have become integrated into the
surrounding environment. Sample analyses data may be needed for future liti-
gation and/or to provide a basis for remedial action. A sample must be as
representative as possible of the media in question and data obtained from the
analysis of the sample must be defensible. The best way to assure that these
requirements are met is to include a statistically based sampling approach as
part of the samp I ing strategy. The scope of a samp I ing effort must further
fall within the limitations of such resources as time, personnel, and available
funds, and these factors must be considered when establ ishing the overalI
strategy. For the purpose of this document, five sampling strategies are de-
tailed be Iow:
1 . Random Samp I i ng -- Random samp I ing uses the theory of random chance
probabilities to choose representative sample locations. Random sampling is
generally employed when little information exists concerning the material,
location, etc. It is most effective when the population of available sampling
locations is large enough to lend statistical validity to the random selection
process. Since one of the main difficulties with random sampling deals with
achieving a truly random sample, it is advisable to use a table of random
numbers to eliminate or reduce bias.
2 . Systemat i c Random Samp I i ng -- Systematic sampling involves the collec-
tion of samples at predetermined, regular intervals (sampling within a grid
square). It is the most often employed sampling scheme; however, care must be
exercised to avoid bias. If, for example, there are periodic variations in the
material to be sampled such that the systematic plan becomes partially phased
with these variations then errors can be introduced by implementation of the
systematic approach.
7-5
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A systematic sampling plan is often the end result of an approach
that was begun as random due to the tendency of investigators to subdivide a
large sample area into increments prior to randomizing.
3. Stratified Samp I ing -- Data and background information made available
from the preliminary site survey, from prior investigations conducted onsite,
and/or from experience with similar situations can be useful in reducing the
number of samples needed to attain a specified precision. Stratified sampling
essentially involves the division of the sample population into groups based on
knowledge of sample characteristics at these divisions. The purpose of the
approach is to increase the precision of the estimates made by sampling. This
objective should be met if the divisions are selected in such a manner that the
units within each division are more homogeneous than the total population. The
procedure basically involves handling each division separately with a simple
random sampling scheme.
4. Judgment Samp I ing -- A certain amount of judgment often enters into
any sampling approach used; however, this practice should be avoided when a
true random sample is desirable. Judgment approaches tend to allow investiga-
tor bias to influence decisions, and, if care is not exercised, can lead to
poor quality data and improper conclusions. If judgment sampling does become
necessary, it is advisable that multiple samples be collected in order to add
some measures of precision.
5. Hybrid Sampling Schemes -- In reality, most sampling schemes consist of
a combination or hybrid of the types previously described. For example, when
selecting an appropriate plan for sampling runs at a hazardous waste site, the
initial staging of drums might be based on preliminary information concerning
contents, program objectives, etc. (judgment, stratified sampling), and then
sampled randomly within the specified population groups (random sampling).
Hybrid schemes are usually the method of choice as they can a I low samp I ing from
a diverse population; but, by reducing the variance, can improve precision within
each subgroup.
Number of Samples -- More often than not, the number of samples collected
wi I I be dictated by the financial I imitations of a specific samp I ing campaign.
This is especially true for sampling hazardous wastes because, generally, most
of the aval I able funds are earmarked for the remedial phase of an effort.
Practicality and common sense must be exercised because onsite manpower costs,
packaging and transportation costs, and analytical fees can easily become
excessive. An excellent basis for sample plan management is the statistical
determination of the number of samples needed. It is generally necessary to
have some preliminary data available to increase the confidence in obtained
results; however, estimation of the needed values is an alternative. With
these data, the number of samples required to obtain a given precision with a
specific confidence level can be obtained from the following equation:
n = t02 S2/02 (1)
where n = number of samples
D = precision given in the specifications of the study
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S = sample variance
ta = two tailed t-value at an a level of significance and (n-1)
degrees of freedom
D is generally expressed in specified concentration units (i.e., ±10 yg/m^) and
ta is obtained from standard statistical tables. The sample variance will have
to be determined from preliminary or previous data or estimated from the
I itenature.
The above equation (1) can also be expressed in terms of the coefficient
of variation:
n = t 2 (CV)2/p2 (2)
a
where n = number of samples
CV = coefficient of variation (S/x" - expressed as a percent or
fraction)
x = = sample mean
p = allowed margin of error (D/x - expressed as a percent or
fraction)
ta = the two tailed t-value at an a level of significance and (n-1)
degrees of freedom
Since the t-value is dependent upon the number of degrees of freedom, it is
necessary to use an iterative approach to arrive at the number of samples to
use. Curves can be prepared that plot the number of samples against the
coefficient of variation and thereby eliminate the need for these iterations.
The use of this equation assumes that the population under study is normally
distributed and that less than 10 percent of all possible samples in the study
area are being collected.
Use of Equations (1) and (2) is not recommended without additional back-
ground and information on statistical experimentation and design. They are
listed here for illustration purposes only. For a detailed explanation of these
approaches, refer to the reference material cited at the beginning of this
section.
Duration and Frequency of Sampling -- The duration of a sampling program and
the frequency with which the samples are to be collected are dictated by a
number of factors: number of samples specified, predetermined length
of an investigation, anticipated variations over time (seasonal, meteorologi-
cal, etc.) objectives of the effort, safety considerations and available funds.
The statistical concepts discussed previously will assist investigators in
determining how often to sample and over what period of time. These concepts
should be maintained whenever possible; however, predetermined logistical and
judgmental criteria may influence these approaches. It is often beyond
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the control of the investigator to alter these factors; however, it is important
to reduce or eliminate bias when outlining an approach.
What to Sample
Unnecessary sampling should be avoided to reduce exposure of field person-
nel to hazardous materials. Sampling should be performed in a safe manner
using the methods presented in Volume II of this manual. If possible, samples
from each media which might be contaminated by hazardous materials--air, soils,
sediments, and water--should be taken to help establish risks.
Soi I and Sed iment--
The soils and sediments at a hazardous waste site can provide information
about the existence and extent of contaminant migration. Vertical migration of
contaminants may occur through soil strata into the ground water, with subsequent
lateral transport of pollutants.
Many of the soil and sediment samples collected are grab samples. Soil
samples should be collected from areas where dumping, spills, or leaks are
apparent. Sediment samples should be collected from areas upstream and down-
stream of the suspected contaminant entry and in areas where sediment deposition
is significant. Quiescent areas are likely locations for sediment deposition.
Because the soils or sediments may be saturated with contaminants, the samples
should be considered hazardous.
Samples usually can be collected readily from the first 18 inches
(depending on soil or sediment type) by relatively simple, manual techniques as
described in Volume II. Samples from greater depths usually require more elab-
orate equipment and are both more expensive and time consuming.
The samples can be analyzed directly for many of the priority pollutants
by various extractions or the soil can be leached and the leachate analyzed as
per the EP toxicity method.
Surface Water and Impoundments--
Surface waters on or adjacent to a suspected hazardous waste site can
yield significant information with minimal sampling efforts. Surface waters
can reveal the presence of contamination from any of several mechanisms, either
direct discharge, runoff, ground-water inflow, or atmospheric particulate
deposition.
If only a knowledge of the presence or absence of contamination in the
water is needed, the collection of grab samples will usually suffice. If the
water body is a stream, samples also should be collected from upstream and
downstream of the area of concern.
Additional monitoring of surface water is required of seeps, spills,
surface leachates, etc., both on and offsite. If the site has NPDES outfalls,
the discharges should be sampled.
More elaborate programs utilizing stream flow information and weather
conditions can further isolate inputs and the effects of both surface runoff
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and ground-water inflow, although this usually requires extended time frames.
The objective for monitoring surface impoundments is to assess the poten-
tial for ground-water contamination and to determine possible hazards if the
water should 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 atmosphere.
Water samples can be analyzed for all of the current EPA listed "Priority
Pollutants" by published methods. Other standard analytical protocols can be
utilized to supply additional information which may be indicative of contamin-
ation migration. Alkalinity, acidity, TOC, TOX, and COD are often excellent
indicators of contamination and can be used as screening techniques before
implementing the more costly Priority Pollutant analysis.
In situ measurements of pH, conductivity, temperature and dissolved oxygen can
serve to isolate areas of inflow or to assess relative variations around the
site. The immediate results and ease of operation of the appropriate instru-
ments make them valuable tools.
Ground Water--
Geohydrologic investigations at hazardous waste sites are a critical
aspect of any evaluation. The impact of a site on the ground water is a signif-
icant factor in the ranking generated by the Hazard Ranking System.
Ground-water contamination is usually difficult and costly to assess,
control, and clean. Since ground-water contamination may not be evident from
the surface, a contaminated aquifer may insidiously spread the area of impact of
a site well beyond its surficial boundary. If the aquifer supplies drinking
water to a population, the direct uptake of aquifer borne contaminants by
ingest ion can have severe health effects.
The subsurface is a unique heterogeneous environment. Gas exchange,
biological and other chemical reactions and conditions are quite different from
those on the surface. The ground water is usually well insulated from surface
temperature variations and thus its temperature is maintained at a rather
constant I eve I.
Exposure of ground water to surface conditions can cause significant and
rapid reactions as a result of increased light and oxygen, and changes in
temperature and pressure. This is true both of ground-water seeps and springs
as well as the discharge of wells. Gas exchange, microbial growth, and the
rate of many chemical reactions approximately double for every 10°C increase in
temperature, and the effect of sun I ight and the presence of oxygen can cause
equally dramatic and nearly instantaneous reactions.
Monitor wells sample a small part of an aquifer horizontally and verti-
cally depending on screen size, placement depth, pump rates and other factors
which affect the cone of influence at a well. The use of existing wells and
piezometers can introduce an additional problem due to materials contamination
and inadequate construction. Proper well construction requires significant
ski I I and expense and should not be attempted without consultations with an
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experienced geohydrologist. Interpretation of the results of analysis of
ground-water samples relies on the collection of representative water samples
and an accurate knowledge of the aquifer characteristics. General guidelines
for ground-water sampling can be found in the "Manual of Ground Water Sampling
Procedures" Scalf, McNabb et al., EPA-600/2-81-160.
In addition to the monitoring of the aquifer formations at hazardous waste
sites, significant information can be obtained by sampling the unsaturated zone
above the aquifer, called the vadose zone. Leachate from buried vessels or
otherwise contaminated water migrates through the vadose zone toward the water
table. Samples collected from the vadose zone can indicate the types of contam-
inants present and can aid in assessing the potential threat to the aquifer before
the leachate reaches it and is subsequently diluted.
Vadose zone soil sampling can be an effective addition to the geophysical
methods listed previously to aid in the placement of wells or piezometers. The
various types of vadose zone monitors can be used to collect water samples for
chemical analysis or to detect the direction and velocity of leachate movement.
Since these monitors are relatively inexpensive and simple to install, they can
begin supplying information before aquifer monitoring is initiated.
The types of vadose zone monitors, their applications in field investi-
gations, and their use in satisfying the requirements of the Resource Conser-
vation and Recovery Act are discussed in a more complete treatment of vadose zone
monitoring, "Vadose Zone Monitoring at Hazardous Waste Sites." (EMSL-LV KT-82-
018R Apri I 1983).
Geophysics--
In the designing of monitor we I I networks, the placement of we I Is has been
done mainly by educated guesswork. The accuracy and effectiveness of such an
approach is heavily dependent upon the assumption that subsurface conditions
are uniform, and that regional trends hold true for the local setting. However,
these assumptions are frequently invalid, resulting in non-representative
locations for monitor well placement. If an attempt is made to improve accuracy
by installing additional wells, the project may be thrown off schedule, and
costs will increase. Such delays are often unacceptable in rapid assessments
required at hazardous waste sites. At certain sites, there are also increased
safety risks associated with drilling into unknown buried materials, and the
risk of contaminating aquifers by the act of dri I I ing.
During the past decade, extensive development in remote sensing geophysical
equipment, portable field instrumentation, field methods, analytical techniques,
and related computer processing has resulted in a striking improvement in the
capability to assess hazardous waste sites. Further, many of these improved
methods allow measurement of parameters in the field with continuous data
acquisition at traverse speeds up to several miles per hour.
Some of these geophysical methods offer a direct means of detecting contam-
inant plumes and flow directions in both the saturated and unsaturated zones.
Others offer a way to obtain detailed information about subsurface soil and
rock conditions. This capability to rapidly characterize subsurface conditions
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without disturbing the site (much like nondestructive testing used in many
production facilities and test laboratories) offers the benefits of lower cost
and less risk, and provides better overall understanding of complex site
cond it ions.
Once a spatial characterization of the site is made by these methods, an
optimal direct sampling plan may be designed to:
* Minimize the number of drilling sites;
* Locate drilling and monitor wells at representative sites;
" Reduce risk associated with drilling into unknowns;
* Reduce overall project time and costs;
* Provide improved accuracy and confidence levels.
A good overview on the subject of geophysical methods for surveying
hazardous waste sites can be found in "Geophysical Techniques for Sensing
Buried Wastes and Waste Migration," prepared-for EPA by Technos, Inc. (available
from the National Water Well Association, 500 West Wilson Bridge Road, Worth-
ington, OH 43085). Six techniques are discussed in that report:
Ground Pentrating Radar
Electromagnetic
Res i st i v i ty
Se i sm i c Refract i on
MetaI Detect i on
Magnetometry
These six techniques were selected because they are regularly used and
have been proven effective for hazardous waste site assessments. The primary
tasks to which these methods can be applled include:
* Mapping of natural geohydrologic features;
* Mapping of conductive leachates and contaminant plumes (landfill
leachates, acids, bases);
• Location and boundary definition of buried trenches;
* Location and definition of buried metallic objects (drums, pipes,
tanks).
Air --
Ambient concentration of volatile and semivolati le organics, trace metals
and particular matter in the vicinity of a hazardous waste sites are of particu-
lar concern due to their potential impact on human health, welfare and the
environnment. Monitoring for these "fugitives" can provide important input
concerning the atmospheric path and dispersion of the release, the populations
at risk, source strength, and the extent of airborne migration pathways. In
this regard, air monitoring performed during hazardous waste site investigations
or inspections can be of three basic types: source evaluations, ambient surveys,
and personnel monitoring.
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Each of the above-mentioned air monitoring types can be conducted on two
distinct levels, areas surveys and detailed characterization efforts. The
former level involves the use of portable monitoring devices such as the OVA
or Hnu organic vapor analyzers, stain detector tubes or other monitors. Such
surveys provide an indication of the presence of various atmospheric hazards
for establishing levels of worker protection and also can provide information
essential to the second level of the investigation.
The goal of this second level investigation is to quantitatively assess
the impact of site atmospheric emissions. The preliminary survey effort along
with knowledge of the materials onsite will aid in determining the extent of
the program, both for what analyses are necesary and how many samples are
requ i red.
The selection of sampling and analyses methods requires close cooperation
between the project manager and the designated laboratory. Many sampling
methods are available. Their selection depends on the analytical capabilities
of the lab and the desired detection limits. Most methods involve the use of
pumps, anything from small personnel monitoring pumps to Hi-Vol samplers, to
draw measured volumes of air through a filter, impinger, or sorbent. Guidance
in methods selection can be found in Volume II - Available Sampling Methods,
Volume III - Available Laboratory Analytical Methods, and several other guidance
documents referenced below.
In addition to methods selection, considerable planning is required to
select the number of samples and the sample locations. Certainly these decisions
again depend on laboratory capabi I ities as we I I as a number of siting factors,
including:
1. Source Characteristics
2. Site Characteristics
3. Meteorological Considerations
4. Spatial Scale
5. Temporal Resolution
6. Traffic Distribution
7. Population and Housing Distribution
8. Background Concentrations
Source Characteristics
Emissions may emanate from the area undergoing excavation and/or
treatment at abandoned hazardous waste sites, surface impoundments, landfi I Is,
and land treatment faci I ities. The emissions enter the atmosphere at ground
level over an area with field dimensions. Insight into the transport and
dispersion of pollutants from an area source can be gained through the appli-
cation of the Gaussian plume dispersion model to the area source. Although
Gaussian plume dispersion is generally applied to elevated point source
releases, it is also valid in an area source situation.
Source characteristics may also be defined through direct measurement of
the source strength. Research is being conducted and information is available
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in the literature concerning a number of techniques that are useful for
determining emission rate measurements from landfills, surface impoundments
etc. Although more costly than modeling, certain applications may detect
that solid, emperical data be collected via direct measurements.
Site Characteristics
The shape and configuration of the area sources, along with the terrain
in and around the waste site, play a major role in monitoring network design,
Within the boundaries of the waste site, all area sources must be identified.
If workers will be in the immediate surroundings of an area source, this loca-
tion will be a prime candidate for monitoring. Measurements also should be
taken along the site boundaries, with a minimum of one monitor per major com-
pass direction (N, S, E, W). This will ensure that no oversight was make in
monitor site selection.
Beyond the site boundaries, the terrain features are of major importance.
Since the emissions enter the atmosphere at ground level, they are subject to
the local drainage flows and chaneling effects induced by the terrain. High
ground and open terrain also are vulnerable to air quality impact. A good
understanding of the terrain features and land use (e.g., locations of residen-
tial and commercial zones) will enter into the meteorological considerations.
Meteorological Considerations
The local meteorological characteristics are of particular importance in
siting monitors at waste sites. As with all air emissions, the transport
and dispersion of hazardous waste away from the site wi I I be dependent on wind
speed, wind direction, and atmospheric stability. Because the hazardous waste
emissions are ground level releases, meteorological parameters characteristic
of the first 10 meters above the surface wi I I best define the transport and
dispersion process.
In summary, the meteorological parameters of wind speed, wind direction,
and atmospheric stability must be considered in the monitoring site selection
process. Cl imatological data are available for stations throughout the United
States, and are quite useful. However, because hazardous pollutants are emitted
at ground level, the micrometeorology of the waste site must be considered care-
fully. This can be accomplished, to some extent, in a review by a meteorologist
of the cl imatological data and terrain maps of the region. Ideally, onsite
meteorological data should be used. If none exists, the network designed must
be based on the cl imatological data and micrometeorological analysis. Onsite
meteorology data should be collected from the start of the program, and used to
evaluate the initial monitor locations.
Spatial Scale
The objectives of air monitoring at hazardous waste sites necessitate
the consideration of two spatial scales. An onsite network must be designed,
and air quality in nearby residential and commercial areas must be monitored.
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The number and placement of the monitors wi I I be highly site dependent.
In general, there should be a monitor in all areas near sources where there is
a great deal of activity. In addition, there should be a set of monitors along
the site boundaries; the boundary line monitors will record effluent transport
and dispersion characteristics.
Beyond the waste site, considerations should be given to all commercial
and residential areas with a potential for plume impact. The high impact areas
will be identified by examining all siting factors including meteorological
considerations and proximity of the area to the waste site.
This enables prioritizing the use of the available resources so that all
high impact areas are monitored before those which have potentially less impact.
If initial readings show significantly high off-site levels or a shift from the
initially expected impact areas, monitor locations can be adjusted and/or the
base network reinforced.
Temporal Resolution
In scheduling the field program, the time dependence of emmission rate and
human activity must by considered. Volatile and semivolati le compounds will
evaporate from area sources at the highest rate when the ground temperature is
the warmest; sunny, summer afternoons possess the greatest potential for high
emission rates. Human activity on the site, e.g., excavation, peaks during
daylight hours. Therefore, maximum human exposure is most likely to occur on
warm summer afternoons. Consideration should be given to possible concentra-
tion buildup during nighttime conditions of lower wind speeds and potential
inversions.
Depending upon the compound, length of exposure is of concern. If the
critical exposure concern is short-term, summer, daytime monitoring is needed.
Estimates of long-term exposure demand an ongoing seasonal or annual monitoring
study.
Traffic Distribution
Streets and roadways are sources of possible interference with the
measurement of pollutants. If a monitor is located too close to the roadway,
the organic compounds in vehicle exhaust will be recorded by the monitor,
potentially interfering with the observations. This problem cannot always be
eliminated at waste sites undergoing excavation due to the large amount of
heavy equipment operating in the area; however, consideration must be given
To this concern wherever possible. Also, onsite roadway dust may have a
detrimental effect on sampling equipment. Generally, the roadways near the
area sources are unpaved. Therefore, the monitors must be sited far enough
from the roadway to limit problems with the collected samples and to prevent
instrument damage.
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Population and Housing Distribution
A primary objective of monitoring near hazardous waste sites is to protect
the health and safety of the public. Therefore, land-use maps of the immediate
(within 10 kilometers) area surrounding the waste site must be acquired and
studied. The land-use maps in conjunction with meteorological considerations
will identify which areas have the highest potential for human exposure. Also,
appropriate state and local officials should be consulted. There may be
neighborhood or commercial zones where complaints are common. If so, these
locations should be evaluated as monitor locations.
Laboratory Interface and Coordination
Once the types and numbers of samples have been decided upon, laboratories
must be chosen to process them. If the laboratory cannot process the number of
samples planned, within specified holding times, or provide the kinds of anal-
yses requested, either additional labs must be located or the sampling strategy
rev i sed.
The EPA has established the Contract Laboratory Program (CLP) to provide
necessary analytical services through a nationwide network of contract labor-
atories. The program is structured with a strong orientation towards the needs
of enforcement activities. Protocols and methodologies are designed by EPA to
provide data of known quality in strict accordance with quality assurance
procedures and chain-of-custody, and document control requirements. Although
primarily established to analyze samples collected under Superfund, the CLP is
currently implementing an accounting charge-back system to accommodate the
analytical needs of other programs. All programs utilizing these services
automatically receive the intensive quality assurance, chain-of-custody and
document control characteristics built in for generating data suitable for
litigation. In addition, users of the CLP avoid the administrative burden
involved in independently contracting for and managing analytical services on a
small scale. Data from these laboratories must be carefully screened, however,
to insure that the results fulfill the needs.
The provisions of the Contract Laboratory Program are detailed in a
document prepared by the EPA Sample Management Office entitled "User's Guide to
the EPA Contract Laboratory Program", August 1982. Additional information can
be obtained by contacting the Sample Management Office at 703/557-2490 or
FTS/557-2490.
After arrangements have been made to analyze the samples, further coordin-
ation wi I I be necessary to select sample containers, preclean ing requirements,
preservation techniques, labeling and shipping requirements, and schedules.
Volume III lists the volume, recommended container type and preservation
requirements for the various methods. More general guidelines are also included
in Appendix A of Volume II; however, these are only recommended procedures, and
all such matters should be coordinated with the designated laboratory.
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Transportation
Packaging and shipping of hazardous waste samples must comply with all
appropriate Department of Transportation regulations governing such materials
(49 CFR 172.101). Refer to Appendix F, Packaging, Marking, Labeling and Ship-
ping, for a detailed explanation of the required procedures. Refer to the DOT
regulations for updates and whenever clarification is necessary.
Organization of the Field Team
The field team's obvious function is to gather technical information to
document actual, potential and suspected current and historic releases of
hazardous materials. Specific strategy and objectives for incidents and sites
are contained in standard operating plans and site-specific work plans. The
techniques described in these plans are likely to include hazardous and
environmental sampling of all media, inventorying wastes, mapping areas,
drilling wells and excavation both on and off site.
There are a small number of incontrovertible guides for field teams which
have both technical and safety justifications. They are:
safety f i rst a I ways;
someone has to be in ultimate charge during all onsite operations;
and
all potential exposures to hazardous materials require a "buddy"
hookup system for onsite operations. "Buddy" system means two trainee'
personnel experienced in working together, who have confidence in
each other, and who are working in actual I ine-of-sight view of each
other.
There are some excellent rationales and systems for handling necessary
hazardous waste exposure situations in a manner which virtually eliminates
personnel exposure and offsite contamination. The one most commonly encountered
was developed from the U.S. Army Tech Escort Procedure as modified by Ecology
and Environment, Inc. (E and E). This system is based on the need to fill the
six roles which may be required for a field investigation team. It was devel-
oped for major sites and assumes adequate lead time and a series of checks and
balances on individual responsibilities on site.
The following addresses the duties and responsibi I ities of the six roles:
Project Team Leader,
Field Team Leader,
Site Safety Officer,
Contamination Reduction Corridor Operator/Equipment
Specia I ist,
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* Command Post Supervisor, and
* Initial Entry Party, Work Party, and Backup Team.
Project Team Leader--
The project team leader is primarily an administrator when not partici-
pating in the field investigation as field team leader or command post super-
visor. The project team leader is responsible for:
* all the team does or fai Is to do, however, some of this responsi-
bi I ity may be passed to the field team leader and site safety officer;
* preparation and organization of all project work;
* selection of team personnel and briefing them on specific assignments;
* obtaining permission to enter the site from the owner;
* coordinating with the field team leader to complete the work plan;
* completing final reports and preparation of the evidentiary file; and
* insuring that safety and equipment requirements are complete.
Field Team Leader--
The field team leader is responsible for the overall operation and safety
of the field team. This role can be filled by the project team leader or a
designated representative. The field team leader may join the work party. He
is responsible for:
* safety and safety procedure enforcement;
* field operations management;
* public relations/state and federal liaison;
* site control;
* compliance of field documentation and sampling methods with evidence
collection procedures;
* execution of the site work plan; and
* determination of the level of personal protection required (in
conjunction with the site safety officer).
Site Safety Officer--
The safety officer for the site has primary responsibility for all safety
procedures and operations on site. Ideally, the site safety officer will
report to the person responsible for safety in the Corporate or Agency organ-
ization rather than to the field team leader or project team leader. This
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allows two seperate lines of authority. It allows decisions related to safety
to be represented without conflicting with decisions related to the pressures
for accomplishing the investigation according to schedule. The site safety
officer remains half dressed in the appropriate level of protective equipment
to respond to emergencies. He or she stays on the clean side of the exclusion
area while monitoring the work party and site activities. The site safety
officer is also responsible for:
* updating equipment or procedures based upon new information gathered
during the site inspection;
* upgrading the levels of protection based upon site observations;
* enforcing the "buddy system";
• determining and posting locations and routes to medical facilities,
including poison control centers, and arranging for emergency
transportation to medical facilities;
• notifying local public emergency officers, i.e., police and fire
department, of the nature of the team's operations, and posting their
telephone numbers;
* controlling entry (if possible) of unauthorized persons to the site;
* entering the exclusion area in emergencies when at least one other
member of the field team is available to stay behind and notify
emergency services, and/or after he/she has notified emergency
services;
* examining work party members for symptoms of exposure or stress:
* determining the suitability of a team member for work in the exclusion
area, based on the team member's physical profile which is determined
by the health and safety program and the team member's current
physical condition; and
* Providing emergency medical care and first aid as necessary on site.
The site-safety officer has the ultimate responsibility to-stop any
operation that threatens the health or safety of the team or
surrounding populace.
Personnel Decontamination Station (PDS) Operator/Equipment Specialist--
The PDS operator/equipment specialist functions in two roles that do not
require concurrent attention. As the equipment specialist, he or she is charged
with:
* ensuring that all equipment is properly maintained and operating;
* inspecting all equipment before and after use;
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* ensuring that all required equipment is available; and
* decontaminating all personnel, samples and equipment returning from
the exclusion area.
The PDS operator/equipment specialist is responsible for design and setup
for the PDS and for preparing the necessary decontamination solutions to ensure
that chemical contamination is not transported into the clean area by inspec-
tion equipment, samples, protective clothing or personnel. Failure to properly
execute these duties reduces the effectiveness of the protective equipment and
threatens the rest of the field team. The PDS operator/equipment specialist
also manages the mechanics of removing contaminated clothing from the work
party and the proper disposal of discarded contaminated clothing and decontam-
ination solutions.
Command Post Supervisor--
The command post supervisor functions as the clearinghouse for communi-
cations. He or she does not enter the exclusion area to assist the work party
except for certain emergency situations. Should an emergency arise, the command
post supervisor notifies emergency support personnel by phone, radio, etc. to
respond to the situation. Depending on the team size and the nature of the
emergency, the command post supervisor may, in extreme situations, assist the
site safety officer in effecting a rescue. Usually, the command post supervisor
may be called upon to assist the PDS operator/equipment specialist in operating
the PDS during an emergency, and assist the site safety officer in emergency
medical measures. The field team leader may assume the position of command
post supervisor.
The command post supervisor is also responsible for:
* maintaining a log of communications and site activities such as
duration of work periods with respirators;
* sustaining communication and I ine-of-sight contact with the work
party;
* maintaining public relations in the absence of the field team leader;
and
* assisting the site safety officer and PDS operator/equipment
specialist as required.
Work Party and Backup Team--
Initial Entry Party -- The initial entry party enters the site first,
employing specialized instrumentation to characterize site hazards. Usually
the field team leader should be a part of the initial entry party to familiarize
him/herself with conditions and dangers associated with the site. The major
purpose of this team is to measure existing hazards and survey the site to
ascertain if the level of personnel protection determined from preliminary
assessment and site inspection must be adjusted.
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The initial entry party can consist of as few as two people if a wheel-
barrow or other device is used to transport all the instrumentation. Three or
four people are able to do the job more efficiently.
Work Party -- The work party performs the onsite tasks necessary to fulfi I I
the objectives of the investigation, e.g., obtaining samples or determining
locations for monitoring wells. No team member should enter or exit the
exclusion area alone. The work party consists of a minimum of two individuals,
and any work party should follow this buddy system. Besides the safety
considerations, it is much easier for two persons dressed in protective clothing
to perform such tasks as note taking, photographing, and sampling.
Backup Team -- Extensive assignments requiring long hours and large work
parties (more than five members) necessitate the use of a standby backup team.
The emergency response team is halfdressed in protective gear so that it can
quickly enter the exclusion area in the event of an emergency. This team is par-
ticularly valuable at dangerous sites where protective equipment produces
stress and heat loads on the work party.
Mitigating Considerations for Field Team Size Adjustments--
The system outlined above is reasonably comprehensive and basically fail
safe. It could be applied to nearly any situation assuming adequate notice and
resources were available. It does not, however, recognize the structure,
skills, resources and range of incidents encountered by Agency field teams.
All of the decision points, responsibi I ities and ski I Is out I ined above need
to be covered in any hazardous exposure situation, but there are numerous
factors which could cause the number of hands on scene to be legitimately
increased or decreased.
These factors are described below with examples:
* Contamination of Samples - Proper collection of environmental samples
for low detection limit analyses may require higher skill levels or
more numerous hands than the work plan would indicate.
* Physical Work - Sites or other activities which involve manual
col lection or core samples, use of Peterson dredges, and performance
of simi lar manual work may require a ski I Is mix and number of hands
not anticipated by the work plan.
* Cost Effectiveness - For longer distance trips where travel costs are
high, it may be desirable to consider overtime and additional per
diem for a smaller number of personnel than would normally be assigned
for a given job.
* Chain-of-Custody and Documentation Considerations - Collection of
enforceable data is essential. There are instances where additional
personnel are required on scene for witness purposes or to manage
such things as photographic documentation of data collection efforts.
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Logistics/AreaI Extent - There are frequently instances involving
such things as dye studies, releases to rivers, and searches for
leachate seeps where the terrain and physical distances involved
require additional manpower even when optimal use is made of portable
radio communications.
Problem Complexity/Skills Mix - Certain onsite situations require
additional personnel onsite with the proper academic background and
experience to evaluate the problems. Commonly this situation occurs
with releases of potentially toxic organics to shallow ground-water
regimes where many disciplines may need to interact to provide
competent assessments. At the same time, fortuitous combinations of
experience and skills onsite and effective communication with offsite
expertise may radically reduce optimal team size for any given
situation.
Other mitigating factors:
Safety - Responses to sulfuric acid spills, for example, may not
require the same resources as responses to a similar quantity of
dioxin or parathion.
Training - On-the-job-training is frequently employed to improve
ski I Is of entry level and less experienced employees. Oppor-
tunities for this type of training should be used as often as
possible where it is not perceived as wasting resources.
Time Constraints - Hurry up jobs are generally done more quickly
by more people.
Visibility - When extensive tourists or media are expected in
the vicinity, appropriate resources should be assigned to handle
these contacts without inhibiting technical operations.
Average Team Size for Normal Operations - There are general guidelines
for determining team size in terms of commonly encountered situations.
These team size discussions presented below are couched in terms of
the protective safety required.
Two-Person Team - The two-person team is the minimum for a
hazardous substance site investigation. The two-person team is
best suited for offsite surveys and inspections or for obtaining
environmental (nonhazardous, offsite) samples. Collection of
ground truth data for aerial photographic surveys, inspection of
files, or interviews can all be accomplished by the two-person
team.
Two-person teams are standard for initial responses to situations
where imminent hazards may exist. However, in this situation,
team members are generally more completely trained and equipped
for reducing the risk of accidental exposure. They are also
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instructed to uti I ize aval I able safety gear in a very conser-
vative approach to the hazards and are commonly backed up by
local government emergency units.
Three-Person Team - The three-person team can be employed on
sites requiring Level C protection and in some cases, on sites
requiring Level B protection. Level of protection requirements
are discussed in Section 3. This team is composed of a field
team leader; an individual fulfilling the combined functions of
PDS operator/equipment specialist, site safety officer, and
command post supervisor; and another individual to enter the site
with the field team leader.
The three-person team is used where extensive PDS procedures are
not required and where the liklihood of emergency rescue is low.
This field investigation team is best utilized in non-IDLH
(immediately dangerous to life and health) atmospheres where the
primary objective is to map, photograph, or inventory. Its use
assumes that at no time wi I I the work party be exposed to
hazardous situations.
Considerable care and thought are necessary before a three-person
team is employed on a site because each individual has numerous
responsibilities. In the event of an accident, the third member
does not enter the site to offer emergency assistance unti I he
has summoned outside assistance, and even then, only when he
feels rescue wi I I not endanger his own I ife.
Four-Person Team - Most Level B and some restricted Level A
operations can be conducted with a four-person team. These
operations would include work on active sites where facility
personnel are present or on inactive sites with potentially IDLH
atmospheres. The objectives of a four-person team at a site
requiring Level B or Level A protection might include sampling
ponds, soils, or open containers, and performing inspections at
sites known for poor housekeeping, i.e., where there is evidence
of spi I Is, leaks, etc.
The team consists of the standard two-person work party, a
combination site safety officer/PDS operator/equipment specialist,
and a command post supervisor who may assist in the PDS operation.
Because life-threatening hazards are assumed or known to be
present at a Level B or Level A site, it is essential that a I I
personnel be fully acquainted with their duties. During an
emergency, the command post supervisor stays in the support area
to maintain communication while the site safety officer/PDS
operator/equipment specialist enters the exclusion area to aid
the work party. Once the work party is in the contamination
reduction area, the command post supervisor can then offer
assistance at the PDS or provide fresh equipment from the support
area.
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Five-Person Team - The five-person team is minimum size for most
Level A and certain Level B operations or for operations where
percutaneous hazards are known to exist or where there is an
absence of historical information. The site hazards that require
Level A protection, combined with the limitation and stresses
placed on personnel by wearing Level A protection, necessitate
a full-time PDS operator/equipment specialist who can also serve
in emergency response. In the event of a serious emergency such
as a fire, explosion, or acutely toxic release, both the site
safety officer and PDS operator/equipment specialist may need to
enter the exclusion area dressed in Level A gear. The command
post supervisor remains in the support area to direct outside help
to the site and then assume the functions of PDS operator/equipment
spec i a I i st.
Teams of Seven or More - Certain hazardous substance sites
requiring sampling operations necessitate larger or alternating
work parties and additional support personnel in the contamina-
tion reduction area. The seven-person team employs the basic
five-person structure plus an additional work party for alter-
nating work loads. The eight-person team includes an additional
PDS operator/ equipment specialist to assist in the continuous
decontamination tasks involved with alternating work parties,
and to decontaminate and pack samples as they are received.
It is not unusual to employ teams of 12 where such tasks as drum
opening may require three work parties downrange working concur-
rently. This operation may involve teams to move the drums,
open the drums, and sample and then reseal under rigorous safety
procedures. Larger teams can be designed with additional work
parties and support personnel to safely gather the site data and
insure communication and site control.
Organization of the Operations Area
General Considerations--
The investigation of a hazardous substance site introduces the risk of
exposure of the field team and surrounding community to varying degrees of
hazard. One way to decrease the possibility of exposure is to organize an
operations area which includes a buffer zone around the site and a security
system that can control access to it.
The area regarded as contaminated or hazardous must be delineated and
isolated. The actual hazardous substance site can vary in area from a few
yards to several square miles. The extent of the site is initially established
from data collected during the preliminary assessment phase of the investigation.
The use of aerial photography is helpful in establishing the site
boundaries by identifying evidence of contamination such as:
the presence of drums, tankers, lagoons, ponds, or other areas which
contain hazardous substances;
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spills, leaks, puddles, leachate outbreaks or other evidence of
uncontained hazardous substances; and
the presence of distressed vegetation, previously noted odors, dis-
colored soil, parts of containers (i.e., drum lids, bungs) or other
indications of contaminants or deliberate dumping of containers.
Once the extent of the contamination or possible threats to the surrounding
community have been evaluated, the hazardous substance site can be delineate..
A buffer zone is added for additional safety, and the entire area (hazardous
substance site plus buffer zone) is regarded as "hot" or contaminated. This
zone is known as the exclusion area, which should be physically secured, fenced,
posted, readily identifiable by topographical boundaries, or marked in some
way.
The area surrounding the exclusion zone is considered clean or noncon-
taminated, and serves as the support area from which operations into the
exclusion area are conducted. Activities such as dressout in protective
clothing, equipment maintenance and repair, communications, liaison with
authorities and the media, and medical aid are conducted in the support area.
An area devoted to contamination reduction should be established between
the exclusion area and the support area. This zone exists for the decontam-
ination of personnel, equipment and samples returning from the exclusion area
and is designed to prevent movement of contaminated material into the support
area. Vehicles, equipment, structures, and personnel in the support area not
previously subject to exposure are protected by this practice.
These three zones - the exclusion area, the support area, and the contam-
ination reduction area - are the basic organizational blocks of an operations
area (Figure 7-1).
Exclusion Zone--
The exclusion zone contains those areas considered contaminated, possibly
contaminated, or capable of being contaminated in the event of fire, explosion,
or toxic release. A buffer zone is also included for additional safety. The
initial boundaries of the exclusion area are established from data collected
during the preliminary assessment and prior to site contact by any members of
the investigation team. This assessment should include the following basic
i nformation:
* types of hazardous substances present;
* quantity of hazardous substances present;
* type of storage containers used on site;
condition of storage containers;
toxicity, flammabi I ity, explosiveness, flashpoint/auto-ignition
point, and corrosivity of the material; and
presence or absence of radioactive materials.
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20°
20° ""^
Wind Direction
(ideal)
90°
90°
Wind Direction
(acceptable)
Contamination
Control Line
Access
• Control.
Point
Personnel Decon Station
(PDS)
Contamination •
Control Line f
Contamination
Reduction Area
(Hot?)
Command Post.
(CP)
NOTE: Distances are approximate and can vary.
Figure 7-1. Organization of the operations area
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This information is used to determine those areas that are contaminated or
probably contaminated.
The area of probable contamination delineates only a portion of the
exclusion area; the remainder is determined by the potential airborne hazard or
the hazard associated with fire or explosion. The potential for airborne
hazard can be insignificant during such activities as container inventory.
However, such activities as moving or opening closed containers, where the
possibility of container rupture and subsequent release of toxic materials is
dramatically increased, necessitate an expansion of the exclusion area so that
any surrounding populace is adequately protected. The extend of the expanded
exclusion area can be determined by calculations based on the toxicity of the
material, the estimated amount released in an accident, the wind speed and
direction, the volatility of the substance, changes in the temperature, and the
local terrain and surface drainage characteristics. The exclusion area should be
secured to prevent individuals from inadvertently entering the area. Fences,
barriers, warning signs, or security personnel may be employed.
Another factor that influences the size and shape of the exclusion area is
the type of work planned. Remedial actions often require that a number of
containers be moved, opened, sampled, resealed, staged awaiting laboratory
results, and then segregated according to waste type. These activities must
occur completely within the exclusion area. The area required can vary from a
few square feet to several acres; the exclusion area boundaries must therefore
be adjusted to account for all planned activities.
Subareas Within the Exclusion Zone--
All personnel within the Exclusion Zone must wear the required Level of
Protection. Personnel protective equipment is designated based on site-specific
conditions, including the type of work to be done and the hazards that might be
encountered. Frequently within the Exclusion Zone, different Levels of Protec-
tion are justified. Subareas are specified and conspicuously marked as to
whether Level A, B, or C protection is required. The Level of Protection is
determined by the measured concentration of substances in air, potential for
contamination, and the known or suspected presence of highly toxic substances.
Different Levels of Protection in the Exclusion Zone might also be desig-
natd by job assignment. For example, collecting samples from open containers
might require Level B protection, while for walk-through ambient air monitoring,
Level C protection might be sufficient. The assignment, when appropriate, of
different Levels of Protection within the Exclusion Zone generally makes for
more flexible, effective, and less costly operation, while still maintaining a
high degree of safety.
Contamination Reduction Zone--
The contamination reduction zone lies upwind of the exclusion area, between
it and the support area. The contamination reduction area provides an area for
the decontamination of personnel, equipment, and sample containers used within
the exclusion area, and for the execution of certain functions (air tank changes,
equipment staging, etc.) to assist the work party. The contamination reduction
area is initially established in an assumed clean area, but is considered to be
possibly contaminated as soon as the first items or people are processed through
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the personnel decontamination station (PDS). While some gross decontamination
may occur while the work party is in the exclusion area, most decontamination
will occur within the contamination reduction area. It should be noted that
provisions must be made to handle the decontamination solutions and other
materials generated as wastes during the onsite investigation. This usually
requires temporary secure storage until proper ultimate disposal at a permitted
fac i I i ty.
The boundary between the contamination reduction area and exclusion area
is known as the hot line. Everything within the hot line is considered contam-
inated. The hot line should be clearly delineated by flagging tape, engineer's
tape, paint, or other prominent, easily discernible marking devices. The
access control point is the only entrance to and exit from the exclusion area
used by team members, although other emergency exits should be established and
clearly marked on sites that are restricted or congested or where there is
possibility of fire or explosion.
Anyone crossing the hot line into the exclusion area must wear the proper
protective equipment. If a property owner, official, or other non-team indiv-
idual enters the area, the individual must be warned of the hazards he may be
facing. Individuals leaving the exclusion area must be processed through the
PDS. A separate PDS for samples can be established; a "mini-PDS" for the PDS
operators can also be establ ished nearer the support area so that they can
decontaminate themselves before entering the support area.
The boundary between the support area and the contamination reduction
area is known as the contamination control line. An access control point is
established for entrance and for exit to the contamination reduction area.
Personnel entering the contamination reduction area must be dressed in the
proper personal protection equipment for work in that area; people exiting
to the support area must have been properly decontaminated.
Initial Planning--
The initial decontamination plan assumes all personnel and equipment
leaving the Exclusion Zone (area of potential contamination) are grossly
contamination. A system is then set up to wash and rinse, at least once, all
the personnel protective equipment worn. This is done in combination with a
sequential doffing of equipment, starting at the first station with the most
heavily contaminated item and progressing to the last station with the least
contaminated arti Icle. Each piece of clothing or operation requires a separate
stat i on.
The spread of contaminants during the washing/doffing process is further
reduced by separating each decontamination station by a minimum of three feet.
Ideally, contamination should decrease as a person moves from one station to
another farther along in the line.
While planning site operations, methods should be developed to prevent
the contamination of people and equipment. For example, using remote sampling
techniques, not opening containers by hand, bagging monitoring instruments,
using drum grapplers, watering down dusty areas, and not walking through areas
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of obvious contamination would reduce the probability of becoming contaminated
and require a less elaborate decontamination procedure.
The initial decontamination plan is usually based on a worst-case situation.
During the site inspection specific conditions at the site are then evaluated,
includ ing:
type of contaminant;
the amount of contamination;
levels of protection required; and
type of protective clothing worn.
The initial decontam i nat i on system i s then mod i f i ed, eI i m i nat i ng unneces-
sary stations or otherwise adapting it to site conditions. For instance, the
initial plan might require a complete wash and rinse of chemical protective
garments. If disposable garments are worn, the wash/rinse step could be omitted.
Wearing disposable boot covers and gloves could eliminate washing and rinsing
both gloves and disposable boots and reduce the number of stations needed.
Contamination Reduction Corridor--
An area within the Contamination Reduction Zone is designated the Contam-
ination Reduction Corridor (CRC) . The CRC controls access into and out of the
Exclusion Zone and confines personnel decontamination activities to a limited
area. The size of the corridor depends on the number of stations in the
decontamination procedure, overall dimensions of work control zones, and amount
of space available at the site. A corridor of 75 feet by 15 feet should be
adequate for full decontamination. Whenever possible, it should be a straight
path.
The CRC boundaries should be conspicuously marked, with entry and exit
restricted. The far end is the hot line--the boundary between the Exclusion
Zone and the Contamination Reduction Zone. Personnel exiting the Exclusion
Zone must go through the CRC. Anyone in the CRC should be wearing the Level of
Protection designated for the decontamination crew. Another corridor may be
required for the entrance and exit of heavy equipment requiring decontamination.
Within the CRC, distinct areas are set aside for decontamination of personnel,
restricted to those wearing the appropriate Level of Protection. All activities
within the corridor are confined to decontamination.
Personnel protective clothing, respirators, monitoring equipment, sampling
supplies, etc. are all maintained outside of the CRC. Personnel don their
protective equipment away from the CRC and enter the Exclusion Zone through a
separate access control point at the hot I ine.
Support Area or Clean Area--
The support area is the outermost part of the site and serves as the
location for the command post and other support activities. After ensuring
that the support area is located in a non-contaminated area, the most important
considerations for the location of the support area include the following:
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Wind Direction and Speed
The support area should be upwind of the exclusion area. Ideally,
the support area wi I I be located such that the wind is blowing at 3
mi les per hour or more directly away from the support area toward
the exclusion area, with no more than 20° deviation in direction to
either side of a straight line between the support and exclusion
areas. Wind direction can shift because of local conditions (for
example, onshore and offshore breezes near the ocean, lakes or large
rivers, or upslope and downs I ope breezes in the mountains); changes
in the weather (thunderstorms, frontal passages); climatic conditions
(chinooks, Santa Ana winds); or local terrain and topography (swirling
and turbulence with increased wind speed). These conditions should
be evaluated during the preliminary assessment phase of the inves-
tigation, and plans made to compensate for wind shifts. While the
40 arc of wind variation represents the ideal, in actuality, up to
180° can be tolerated. This would place the wind blowing away from
both the hazardous substance site and the support area. This effec-
tively leaves the team leader with a 180° arc within which the support
area can be placed.
The location of existing access points to a site may make it necessary
to place the support area downwind of the site. This problem should
be addressed during the preliminary assessment phase. Other access
points can usually be obtained through the use of warrants, discus-
sions with property owners, and minor, easily repairable modifications
to barriers or fences. If an upwind location cannot be found, the
team leader may choose to locate the support area far enough downwind
from the hazardous area to a I low a decrease in the concentration of
airborne contaminants. Continual air monitoring and the wearing of
respiratory protection by all team members located within the support
area may be necessary. The resulting decrease in worker efficiency
must be weighed by the team leader before the decision is made to
locate the support area downwind. Wind direction indicators (4-ft
stakes with 18 in. of flagging tape) should be placed throughout the
operations area.
Line of Sight
Personnel in the support area should have visual contact with all
activities occurring within the contamination reduction area and the
exclusion area. However, where local topography restricts vision,
the team can use an observer in an elevated position (building, tree,
vehicle) or "floaters" (individuals who enter the exclusion area to
maintain I ine-of-sight, but who do nothing else). Another possibility
is to attach lightweight 4-foot-long poles with flags to members of
the work party.
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* Terrain
The support area should be located to take advantage of the terrain
so that:
Safe avenues exist to and from the exclusion area;
There is easy access to the support area for emergency vehicles;
The boundaries of the various site areas are keyed to easi ly
discernible landmarks;
Access to the site can be control led by the support area
personnel ; and
Shelter can be easily provided for returning work party members.
Additional considerations for the location of the support area include
susceptibility to lightning, proximity to power lines or other interferences to
communications, and sufficiency of space for all support area functions.
• Location of Water, Communications and Power
The PDS requires a sufficient water supply for cleaning and main-
tenance. Ideally, a clean, dependable water source will be located
in the support area (fire hydrants, community water system, etc.),
but water can be brought to the support area in clean 55-galIon drums,
fire department tankers, or a collapsible swimming pool filled and
left onsite. Alternately, ground water or adjacent lakes and streams
can be uti I ized provided they have been tested.
• Hopefully, the support area wi I I also have access to a telephone,
either existing or installed by means of a drop line brought onsite.
If the investigation wi I I involve more than a few days onsite, a
telephone is virtually a necessity and probably cost-effective. In
addition, electrical power for lighting, equipment maintenance,
laboratory work, and personal comfort is desirable, but not necessary.
A drop I ine can be brought onsite or a portable generator can be
used, if necessary. Again, long term operations will require more
elaborate preparations.
* Location of Inhabitants and Developed Areas
If the hazardous substance site is in a developed area, the boundaries
of the operations areas may have to be compressed to prevent including
inhabitants in the exclusion area or contamination reduction area.
Ownership of the property within the operations areas must be deter-
mined during the preliminary assessment, so that permission to use
the land can be obtained. It must be noted that an owner's right of
access to his/her property and his/her right to defend such property
from intruders are basic tenets of the law. Accordingly, the team
has little recourse in preventing property owners from entering an
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operations area located on their property. Skillful negotiations, or
the withdrawal of the team if health or safety is threatened, are
often the only alternatives available. In cases where the surrounding
community may be placed in danger from site operations such as con-
tainer movement or opening, a public evacuation should be considered.
Provisions for such situations should be included in the community
relations plan formulated as part of the sampling plan. Proper and
complete implementation of the community relations plan will ensure
that an active framework exists to reduce pub I ic anxiety and ensure
the i r safety.
Other Considerations--
The use of a three-zone operations area with carefully delineated boundaries,
access control points, and decontamination stations provides assurance against
the removal and distribution of contaminated materials from the exclusion area.
Such a system requires an adequate number of personnel and the proper equipment
to operate the system effectively and necessitates the expenditure of some time
to set up and break down. Under certain circumstances, a less exacting site
control system may be established and the decontamination procedures modified.
Onsite Analyses--
Frequently it wi I I be necessary or desirable to conduct certain analyses
in the field. These analyses may range from simple caI orimetric titrations
(sulfite, carbonate) or instrumental measurements (pH, conductivity) to complex
instrumentational analysis (PCB's, pesticide), that require elaborate onsite
laboratory space.
Onsite analyses should be conducted in the support area (clean area) in
order to limit the effects of inadvertent sample contamination, and to minimize
exposure of the analyst. In situations where precautions cannot ensure the
containment of hazardous materials, and testing may result in an accidental re-
lease onsite, analyses should not be conducted in the support area. This
situation may arise during certain drum compatibility and consolidation protocols.
Planning for the use of onsite laboratories must consider provisions for
utility hook up, control and disposal of generated and residual waste, and
facility decontamination upon termination. Additionally, the site safety plan
must address such laboratory operations and provide a means to alert other
onsite personnel in the event of accident or injury to the onsite laboratory
analysts.
The testing of potentially hazardous materials such as drum or impoundment
contents for compatibility or consolidation protocols is a common on-site
analysis program. Occasionally, these protocols can be employed directly
onsite without the need for a mobi le laboratory. Two characterization protocols
are presented in Appendix E. They include the specific equipment and materials
necessary for onsite implementation.
Recommended Equ i pment Inventory
Appendix D contains a suggested inventory of equipment needed for a variety
of hazardous site field operations. Since the collection of samples is a major
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field investigative activity, specialized sampling equipment is included. The
personnel safety equipment list is applicable to a wide range of field operations
Although no I 1st wi I I include everything that is necessary to perform a
field investigation, the Appendix D list is basic and includes the equipment
necessary to perform most field investigations. It is anticipated that this
inventory will be updated as hazardous site investigate technology advances.
Field Communications
Genera I--
A reliable field communications system is required to ensure rapid response
to emergency situations and to enhance the effectiveness of the field investi-
gation team. Just how complex the communications system should be is variable
and depends upon the task at hand, the nature of the hazard present, the terrain,
and types of other resources present. In most cases, the field team can use
public telephones to communicate offsite; (management center, hospitals, fire
department, etc.); however, a specialized network must be established for inter-
nal communications. Communications are complicated by the difficulties in
hearing and speaking that are created by protective equipment, the distance
involved at a work site, and logistics of communicating with a large group of
people.
The communications center is located in the command post and consists of
two networks: an external network, used primarily for obtaining offsite emer-
gency aid, and an internal network, used for both emergency and work-related
communications. At least two means of communication should be available in
each of the networks. Communication methods are limited solely by the resources
aval I able and the imagination of the team members.
ExternaI Network -- The external network is to maintain contact with the
surrounding community and the next higher level of authority of the field
investigation team. The external network must include the local emergency
services (fire department, police, sheriff, ambulance, emergency response
technicians, hospital) and can be expanded to include such elements as the
state police, the Treasury Department, or Armed Services Explosive Ordinance
Disposal units.
The external network is used primarily for summoning emergency aid.
Local emergency warning networks (severe weather, fire) should be accessed as
part of the external communications network. The external network must be
reestabl ished and tested each working day before any work commences in the
exclusion area. This event is recorded in the site log.
InternaI Network -- The internal network is used to maintain contact among
the various elements of the field investigation team. It is used to alert the
team to emergencies, to pass along safety information (weather conditions, time
downrange), to communicate data regarding the site, and to direct the activities
of the team. The primary elements in the network are the command post, the
downrange work parties, and the safety officer. If radios are used (and officer
resources permit it), each member of the work party, the safety officer, and
command post should be equipped with a radio. If resources are limited, the
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command post should have a radio that can be accessed by the safety officer and
the work party can share a radio.
The equipment used in the internal network should be tested each working
day before anyone is allowed to enter the exclusion area. If visual or audible
signals are used, the meaning of the various signals should be reviewed before
work commences. These events are recorded in the site log.
Emergency Communications System -- The emergency communications network is
made up of both the internal and external networks. The emergency network is
distinguished by the signals used, which are to be used solely in-emergency
situations. Table 7-1 presents these signals; others may be determined by the
team.
Means of Communication--
The various means used by the team to establ ish the networks are I imited
solely to the resources available and the imagination of the team. Regardless
of the type of communications device used, at least two means of communication
(a primary and backup) should be available on each network. This redundancy
provides that safety margin that could prove invaluable in an emergency.
Standard Telephones -- The feasibility of having a temporary drop line
installed should be investigated if lengthy operations are anticipated. A
messenger (local person) with a means of transportation and correct change or
access to a phone can be used in an emergency; each team member should also
know the location of the nearest phone and should have the necessary change. A
direct line to the local authorities (fire, police, poison control center,
hospital) can also be installed, when radio telephones are available.
Radios -- There are two basic types of commercially available radios useful
in hazardous substances investigations: citizen's band (CB) and FM radio.
Their capabilities and limitations are presented in Table 7-2. Any radio used
downrange must be intrinsically safe because of the possibility of encountering
an explosive atmosphere.
The Environmental Protection Agency currently uses both high- and low-band
FM radios. Standard radio procedures should be used at all times. These
include use of the phonetic" alphabet and call signs to ensure that all trans-
missions are clear and understandable.
Field-Expedlent Devices --As backup measures to telephone and radio, several
field-expedient measures are available. These include simple arm and hand
signals and noise-making devices such as bells and whistles. Remember that any
device used downrange must be intrinsically safe to avoid creating a spark in
an explosive atmosphere. The uses of such devices are discussed in Tables 7-1,
7-2 and 7-3.
IMPLEMENTATION OF THE SAMPLING PLAN
Field investigations are conducted after the offsite and onsite reconnais-
sance has been completed and all inputs, data, information, etc., have been
thoroughly assessed. The Sampling Plan will define and specify the scope,
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TABLE 7-2. RADIO CAPABILITIES AND LIMITATIONS
Rad i o Type
Capabi I ities
Limitations
Citizen's Band
(CB1
Base Stat i on
Handheld
40 Channels, power for
transmission to 25 miles;
cheap; maintenance fairly
easy. Often monitored by
local emergency services.
Up to 40 channels; 5 or
fewer channels more
common; usual range one
mile; cheap and readi ly
avai lable.
(Both Types)
Channels accessible
to anyone with com-
parable unit; often
subject to inter-
ference from local
traffic; not intrin-
sically safe for work
in explosive atmos-
phere.
Frequency
Modulated
fFM)
High Band
Low Band
Specific assigned fre-
quency for each user;
little interference; can
be made intrinsically safe.
Range of 1 to 10 mi les,
I ine of sight; anci Ilary
equipment can give user
ability to operate unit
enclosed in fully encap-
sulated suit.
As above, but range up to
25 miles.
(Both Types)
Expensive; ski I I
maintenance and
repa i r requ i red.
ed
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TABLE 7-3. FIELD-EXPEDIENT COMMUNICATION DEVICES
Dev i ce
Users
Audible
Compressed Air Horn
Vehicle Horn
Bell (cow bell, school bell)
Wh i stIe
Siren (hand cranked)
Other (hammer and
garbage can lid, etc.)
Megaphone
Pub I ic Address System
Sound Powered Intercom
Command post (CP) or
downrange party
CP only
CP or downrange
CP only
CP or downrange
CP or downrange
(NEVER use hazardous
waste container as
noisemaker)
CP only
CP only
CP or downrange (if
intrinsically safe)
Smoke, Flares or other
Pyrotechn i cs
Flags, Colored Panels
Signal Boards
Lights
Arm and Hand Signals
CP only
CP or downrange
CP or downrange
CP or downrange
(must be bright and
intrinsicaI ly safe)
CP or downrange
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TABLE 7-1. EMERGENCY COMMUNICATIONS
Emergency
Communications
Method Signal Meaning
Hand Signals Clutching throat Personal distress
Hand waved in circle Need assistance (if
above head downrange), or evac-
uate area (if given
to downrange person-
nel by command post)
Audible
wh i st I e ,
(Horn,
etc.)
Three short
f o 1 1 owed by
repeated
sounds
a pause,
Emergency exists;
evacuate downrange
area or send assist-
ance downrange
Radio Each team should develop a consistent,
unmistakable signal such as "Code Red" or
"Flash" to clear the communications channel for
emergency use
logistics, schedules, manpower, and equipment needs. The Samp| ing Plan should
be followed unless unforeseen circumstances warrant modification. The investi-
gation must produce data to verify that a problem exists or does not exist.
Environmental samples collected during the preliminary 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 preliminary assessment, and will be complete only when the objectives
of the Sampling Plan are met.
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 before (night before, for example) beginning the investigation.
The field investigation should be conducted methodically with all leads con-
firmed and documented in the logbook.
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OnsIte Safety
Implementation of the Safety Plan--
Before beginning any onsite activities, the Health and Safety Plan must be
implemented. All personnel must be part of the medical surveillance Program
and made aware of the provisions of the plan (Section 3). Upon arrival, the
operations area should be delineated and the decontamination and emergency
medical stations established.
Because safety is a high priority 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 others will
be performing and what protective clothing and safety precautions are required.
Sampling procedures (Volume II), and packaging and shipping procedures (Appendix
F, Volume I) 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 suggestions should be
implemented if the task wi I I 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 sampling, the team should be briefed and
suggest i ons so I i c i ted.
Field Testing for Onsite Safety--
The safety officer should conduct a preliminary onsite evaluation prior to
initiation of onsite activities. Additionally, he should monitor the site on a
periodic basis to evaluate the levels or worker exposure and the required
personal protection. These techniques are more fully addressed in Section 3
and in Volume I I.
Limiting Public Access--
Implementation of the project plan must emphasize safety not only for
onsite personnel but for the general pub I ic. Access to the site must be con-
trol led. Contact by the public with hazardous waste, or suspected areas of
contamination should be eliminated. Any public or private roadways or paths
into the site should be blocked to prevent inadvertent contact by passersby.
Depending on the extent of the site and the extremity of the action deemed
necessary, the limiting of public access to the site may require manned road-
blocks or evacuation of public and private buildings. Smaller sites should at
least be enclosed with a fence (i.e, 8 foot chain link with barb wire).
Approaches to the site from all directions should be clearly posted with
signs such as NO TRESPASSING, DANGER, HAZARDOUS AREA. Following establishment
of the site perimeters, entry to the site wi I I be control led by the project
leader from the command post. Again based on prior reconnaissance and specif-
ications of the project plan, controlled access can be maintained simply by
locking a gate or by employing round-the-clock guards with regular patrols
of the site interior and perimeter.
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Fire Risk, Access Lanes, Piles, Buildings--
Operations at many sites contain areas or structures or include activities
that are fire risks. For safety concerns alone, it is important to keep access
lanes open at all times. Clear access routes to and within the site must be
maintained for onsite worker safety and for emergency units responding from
offsite. Surface structures, buildings, debris, or waste piles should be
inspected, and if sufficient risk is present, appropriate areas should be made
off limits to normal operations. Emergency access/escape procedures for these
areas should be developed. Site survey instruments such as combustible gas/
vapor indicators radiation detectors, oxygen meters, or hydrocarbon analyzers
will assist in these evaluations.
Sample Col lection
Sample col lection at hazardous wastes sites is compl icated by two primary
factors. First, the presence of hazardous materials requires safety precautions
and a detailed and deliberate sampling plan. Second, the sensitivity of many
of the desired analyses requires careful sample collection to insure represen-
nativeness and to reduce cross contamination by other samples or the site
envi ronment.
Volume II in this series contains sampling methods which are particularly
suited to these situations. In some situations, however, more specific tech-
niques are available, and these may be required by the sampling plan.
Control of Contaminated Materials
Genera I--
For the purpose of this section, "contaminated materials" are defined as
any byproducts of a site investigation that are suspected or known to be con-
taminated with hazardous substances. These byproducts include such materials
as decontamination solutions, disposable equipment, drilling muds, well-
development fluids, and spi I I-contaminated materials.
The permitting procedures for hazardous site investigations are not clearly
defined at present. In the absence of a clear directive to the contrary by the
EPA and/or state government, it must be assumed that hazardous waste generated
during investigations must be handled in compliance with the requirements of the
Resource Conservation and Recovery Act (Public Law 94-580). In addition, there
may be state regulations that govern the generation, storage, transportation,
and disposal of hazardous wastes. Consequently, this section will describe
only the technical elements of the control of contaminated materials.
The project plan for a site investigation must include a description of
control procedures for contaminated materials. This plan would assess the type
of contamination, estimate the amount that would be produced, describe con-
tainment equipment and procedures, and specify storage or disposal methods. As
a general policy it is wise to select investigation methods that minimize the
generation of any contaminated materials. Handling and disposing of potentially
hazardous materials is often an expensive and dangerous operation. Until sample
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analysis is complete, it is assumed that all materials generated during the
investigation will be contaminated.
Sources of Contaminated Materials and Containment Methods--
Decontamination Solutions -- All decontamination solutions and rinses must
be assumed to contain the hazardous chemicals associated with the site unless
there are analytical or other data to the contrary. The solution volumes could
vary from a few gal Ions to several hundred gal Ions.
Used rinse solutions from the personnel decontamination station (PDS) are
best stored in appropriately marked 55-gallon drums (or equivalent containers)
that can be sealed until ultimate disposal at an approved facility. Larger
equipment such as backhoes and tractors should be decontaminated in an area
provided with an impermeable liner and a liquid collection system, such as
a berm-enclosed concrete pad with a floor drain leading to a buried holding
tank.
Disposable Equipment -- Disposable equipment which could be contaminated
during a site investigation typically includes rubber gloves, boots, broken
sample containers, laboratory-tissues, etc. These items are small and can
easily be contained in appropriately marked 55-gallon drums with lids. These
containers should be closed at the end of each work day and upon project
completion to provide secure containment.
Drilling Muds and Wei I-Development Fluids -- The installation of ground-water
monitoring we I Is often involves the use of dri I I ing muds and/or we I I-development
fluids that can result in the surface accumulation-of potentially contaminated
fluids requiring containment. The volumes of these products will vary and will
depend largely on the type and size of the we I I and the associated geo-hydrolog-
ical characteristics encountered. Experienced and reputable well drillers
familiar with local conditions and the well installation techniques selected
should be able to anticipate the types and sizes of containment structures
requ i red.
Drilling fluid (mud) and development fluids are mixed and stored in a
container commonly referred to as a mud pit. This mud pit consists of a suction
section from which drilling fluid is withdrawn and a settling section to which
dri I I ing fluid is returned. The fluid is pumped through hoses down the drill
pipe to the bit and back up the hole to the sett I ing section of the mud pit.
The mud pits may be either portable above-ground tanks which would easily
isolate the natural soils from the contaminated fluids, or stationary, suitably
lined, in-ground pits. If in-ground pits are used, they should not extend into
the natural water table.
When either an above-ground tank or an in-ground pit is used, a reserve
tank or pit should be onsite as a back-up system for leaks, spills, and
overflows. In either case, surface drainage should be such that any excess
fluid could be control led within the immediate area of the dri I I site.
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SpI I I-ContamInated Mater i a I s -- A spill is always possible when a site
investigation involves opening and moving containers of liquids. Contaminated
sorbents and soils resulting from spills will have to be contained. Small
quantities of spi I I-contaminated materials are usually best contained in drums,
while larger quantities can be placed in lined pits or in other impermeable
structures. In some cases onsite containment may not be feasible, and immediate
transport to an approved disposal site wi I I be required.
Disposal of Contaminated Materials--
Actual disposal techniques for contaminated materials are the same as
those for any hazardous substance, i.e., incineration, landfill ing, treatment,
etc. The problem centers around assignment of responsibility for disposal.
The responsibility must be determined and agreed upon by all involved parties
before the field work starts. If the site owner or manager was involved in
activities that precipitated the investigation, it seems reasonable to encourage
his acceptance of the disposal obligation. In instances where a responsible
party cannot be identified, this responsibility may fall upon the public agency
or private investigating organization.
Scheduled post-investigation site cleanup activities offer an alternative
disposal method. For example, if construction of a suitable onsite disposal
structure is anticipated, contaminated materials generated during the investi-
gation should be stored onsite for disposal with other site materials. In this
case the onsite containment structures should be evaluated for use as long term
storage facilities. Other site conditions such as drainage control, security,
soil type, etc. must be considered so that proper storage is provided. If
onsite storage is anticipated, then it should be ascertained that the contain-
ment structures "are designed for this purpose.
Photographs
Photographs or slides should be taken at every sampling location to verify
the written description in the field logbook. Procedures and requirements are
discussed in Section 5.
Cha i n-of-Custody
After collection and identification, the samples are maintained under the
chain-of-custody described in Section 2 of this Volume and in Volume II,
Appendix D.
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SECTION 8
BIBLIOGRAPHY
Benson, Barrett. Procedures for Identifying Responsible Parties--Uncontrolled
Hazardous Waste Sites--Superfund (Final Draft). U.S. Environmental
Protection Agency, Office of Legal and Enforcement Council. February
1982.
U.S. Environmental Protection Agency. Available Field Methods for Rapid
Screening of Hazardous Waste Materials at Waste Sites, Interim Report,
Class A Poisons. EPA 600/X-82-014. December 1982.
U.S. Environmental Protection Agency. Guide for Preparation of a Remedial
Action Master Plan (RAMP). Preliminary Draft. HQ-8201-01. March 1983.
U.S. Environmental Protection Agency. Interim Guidelines and Specifications
for Preparing Quality Assurance Project Plans. QAMS-005/80. December 29,
1980.
U.S. Environmental Protection Agency. User's Guide to the EPA Contract
Laboratory Program. August 1982.
U.S. Environmental Protection Agency. Enforcement Considerations for Evalua-
tions of Uncontrolled Hazardous Waste Disposal Sites by Contractors.
April 1980.
U.S. Environmental Protection Agency. NEIC Policies and Procedures. EPA
330/9-78-001-R, May 1978, Revised December 1981.
U.S. Environmental Protection Agency. NEIC Procedures Manual for the Evidence
Audit of Enforcement Investigations by Contractor Evidence Audit Teams.
EPA-330/9-81-003, September 1981.
U.S. Environmental Protection Agency. Technical Methods for Investigating
Sites Containing Hazardous Substances, Technical Monograph 1-29 (Draft).
Prepared for OERR by Ecology and the Environment. June 1981.
U.S. Environmental Protection Agency. A Protocol for Field Characterization of
Hazardous Waste (Draft). Prepared for Region VII by Ecology and Environ-
ment. March 1982.
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SECTION 9
GLOSSARY
ACCURACY: The degree of agreement of a measurement with an accepted reference
or true value. Accuracy is expressed as (1) the difference between the
two values, (2) a percentage of the reference or true value, or (3) a
rat i o of the two va I ues.
AUDIT: A systematic check to determine the qua I ity of operation of some
function or activity. Audits may be of two basic types: (1) performance
audits in which quantitative or qua I itative data are independently obtained
for comparison with routinely obtained data in a measurement system, or
(2) systems audits of a qua I itative nature that consist of an onsite
review of a laboratory's qua I ity assurance system and physical faci I ities
for sampling, calibration, and measurement.
BIAS: The difference between the mean measurement and the reference or true
value. A measurement of systematic error.
CAA: Clean Air Act, 42 U.S.C. 7401 et seq., as amended.
CASE MANAGEMENT PLAN [DOJ][OWPE]: A document prepared by a negotiation/
I itigation team which out I ines the program to be followed in a judicial
action. As a minimum it establishes the goals, further needs for investi-
gative or mitigative support; incorporates the findings of fact, provides
a schedule, and addresses a schedule.
CEAT: Contractor Evidence Audit Team
CERCLA: Comprehensive Environmental Response, Compensation and Liability Act,
PL 96-510, December 1980
CFR: Code of Federal Regulation
CLP: Contract Laboratory Program
COD: Chemical Oxygen Demand
TY RELATIONS PLAN (CRP): A plan for addressing local citizens' and
officials' concerns to a hazardous waste site and integrating community
relation activities into technical responses at sites to help prevent
disruptions and delays in response actions. Each CRP should include a
description of the background, history and community concerns of the site,
specific objectives of the community relations program, specific techniques
9-1
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to be used to achieve those objectives, workplan and schedule, and budget
and designation of staff who wi I I be accountable.
COMPARABILITY: A measure of the confidence with which one data set can be
compared to another.
COMPLETENESS: A measure of the amount of valid data obtained from a measurement
system compared to the amount that was expected to be obtained under
normal circumstances.
COMPLIANCE EVALUATION INSPECTIONS: Thorough reviews and inspections of
hazardous waste handlers. They involve a site visit to review and evaluate
conditions at the facility of the waste handler, and may involve an onsite
review of records, such as the waste analysis plan, the owner/operator
inspection schedule and log, the groundwater monitoring plan, closure
plans, and the contingency plans and emergency procedures. An evaluation
inspection does not involve sampling.
COMPLIANCE SAMPLING INSPECTIONS: Samp I ing efforts conducted independently of
compliance evaluation inspections, or concurrently with these inspections.
In general, samples might be taken of ground and surface water, waste
types and soil to determine the extent of contamination. These inspec-
tions may be triggered by compliance evaluation inspections, record reviews
or citizen complaints that identify possible problems.
Conceptual DESIGN/REMEDIAL DESIGN [OERR][OWPE]: An assignment process which
results in engineering plans, a schedule of implementation, materials,
requirements, design criteria, budget estimate to include operation and
maintenance safety plan for construction.
CWA: Clean Water Act, PL 92-500 as amended
DCO: Document Control Officer
DOJ : Department of Justice
DOT: Department of Transportation
DPO: Deputy Project Officer
EP: Extraction Procedure Toxicity Method: 40 CFR App. II, Apr. 8, 1983
EPA LEAD: The EPA has primary responsibility for planning and conducting either
part of or an entire removal or remedial action.
EPIC: Environmental Photographic Interpretation Center
EMSL: Environmental Monitoring Systems Laboratory
ENDANGERMENT ASSESSMENT [OWPE]: A report prepared as ordered by enforcement
personnel to summarize, either qualitatively or quantitatively, a specific
set of 6 factors in order to support a negotiation, administrative order
9-2
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or civil litigation. It can cause an IRM to be ordered. For NPL
sites it is a product of the RI/FS modified for enforcement.
ENFORCEMENT RECORD OF DECISION (EROD) [OWPE]: A decision made by the Assistant
Administrator of OSWER wherein the final remedy, or remedies, are chosen
for presentation to the defendant.
EOD: Explosive Ordinance Disposal
ERRIS: Emergency and Remedial Response Information System: ERR IS is an auto-
mated inventory of all uncontrolled hazardous substance sites in the
United States which are known to EPA. It contains data on the names and
locations of these sites, summary response and enforcement event status
information, alias names and locations, comments and optional regional
event and site characteristic data.
ERT: Environmental Response Team
FEASIBILITY STUDY [OERR]: A report evaluating alternative remedial tech-
nologies and alternatives on the basis of risk to public health, tech-
nology, cost, environmental concerns and institutional requirements in
order to identify the cost-effective action.
FEASIBILITY STUDY MODIFIED FOR ENFORCEMENT [OWPE]: See FEASIBILITY STUDY.
This modification for OWPE use, includes everything that the OERR FS
contains except it does not address Section 300.68(K) of the NCP (fund
balancing).
FDR: Field Data Records
FIFRA: Federal Insecticide, Fungicide and Rodenticide Act, PL 92-516 as amended
FINANCIAL ASSESSMENT [OWPE]: A series of searches and inputs which indicate
the net financial worth of a defendant(s). Corporate records, NEIC and
other sources are used to compile the data.
FIT: Field Investigation Team
FOLLOWUP: An inspection or other activity intended to verify compliance with
an enforcement action. A followup action may also be a re inspect ion to
review deficiencies noted in a previous inspection.
FR: Federal Register
HAZARD RANKING SYSTEM (MRS) [OERR]: A model developed and designed to provide
an estimate of the relative severity of a hazardous substance site. The
MRS computes a score for each candidate site from 1 to 100, which serves
as an input to the decision of whether the site should be included on the
National Priority List and if so, at what ranking compared to other sites
contained on the I ist.
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HAZARDOUS SUBSTANCE: Also sometimes referred to as hazardous waste, means (a)
any substance designated pursuant to Section 311(b)(2)(A) of the Federal
Water Pollution Control Act, (b) any element, compound, mixture, solution,
or substance designated pursuant to Section 102 of this Act, (c) any
hazardous waste having the characteristics identified under or listed
pursuant to Section 3001 of the Solid Waste Disposal Act (but not including
any waste the regulation of which under the Sol id Waste Disposal Act has
been suspended by Act of Congress, (d) any toxic pollutant listed under
Section 307(a) of the Federal Water Pollution Control Act, (e) any haz-
ardous air pollutant listed under Section 112 of the Clean Air Act, and
(f) any imminently hazardous chemical substance or mixture with respect to
which the Administrator [EPA] has taken action pursuant to Section 7 of
the Toxic Substance Control Act. The term does not include petroleum,
including crude oi I or any fraction thereof which is not otherwise spec-
ifically listed or designated as a hazardous substance under Subparagraphs
(a) through (f) of this paragraph, and the term does not include natural
gas, natural gas liquids, liquified natural gas or synthetic gas usable for
fuel (or mixtures of natural gas and such synthetic gas).
HWS: Hazardous Waste Site
IDLH: Immediately Dangerous to Life and Health
IMPLEMENTATION OF REMEDY [OERR][OWPE]: The process of carrying out the selected
remed i a I opt i on.
INITIAL REMEDIAL MEASURE (IRM): A class of actions that may be undertaken
during a remedial response to limit exposure or threat of exposure to a
significant health or environmental hazard or to stabilize an existing
situation at a site in order to permit the implementation of additional
actions. Examples of factors used determining if initial remedial measures
are appropriate and the associated action which may be taken include:
Actual or potential direct contact with hazardous substances
(measures might include fences, site security).
Substantial threat of fire or explosion or of a serious pub I ic
health hazard (measures might include drum removal).
Highly contaminated soils largely at or near surface (measures
might include temporary capping or removal of highly contaminated
soils from drainage areas).
An initial remedial measure is categorized as a "project" in the Project
Tracking System (PTS) data element hierarchy.
NATIONAL CONTINGENCY PLAN (NCP): Officially known as the National Oil and
Hazardous Substances Pollution Contingency Plan, outlines the responsi-
bilities and authorities for responding to releases into the environment of
hazardous substances and other pollutants and contaminants under the
statutory authority of CERCLA and section 311 of the Clean Water Act (CWA).
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NATIONAL PRIORITY LIST (NPL) : A list of at least 400 of the highest priority
releases or potential releases of hazardous substances, based upon State
and EPA Regional submissions of candidate sites and the criteria and
methodology contained in the Hazard Ranking System (MRS), in order to
allocate funds for remedial and planned removal actions.
NEIC: National Enforcement Investigations Center
NPDES: National Pollutant Discharge Elimination System
OERR: Office of Emergency and Remedial Response
QIC: Officer in Charge
ORD: Office of Research and Development
OVA: Organic Vapor Analyzer
OWPE: Office of Waste Programs Enforcement
PDS: Personnel Decontamination Station
PL: Pub I ic Law
POST-CLOSURE MONITORING [OERR][OWPE]: Al I activity after the cleanup to assure
that a threat no longer exists.
PRECISION: The degree of agreement between repeated measurements of one
property using the same method or technique. A measurement of the random
error.
PRELIMINARY ASSESSMENT [OERR]: A process of collecting and reviewing readily
available information about a known or suspected hazardous waste site, or
release, used to make a first effort to determine the magnitude of hazard,
source, nature of release and identity of responsible party. No field
work requ i red.
PRELIMINARY INVESTIGATION [OWPE]: A very short-term field study used to define
a problem at a non-National Priority List site. It involves the collecting
of field data sufficient to compi le a document simi lar to the Endangerment
Assessment for a National Priority List site or to support the Enforcement
Planning Effort.
PRIORITY SITE: A site that has been included on either the Interim Priority
List or National Priority List.
PROJECT TRACKING SYSTEM (PTS): The automated system developed by EPA to track
and provide information for oversight of remedial responses on the Interim
or National Priority List. The system includes a four-1 eve I data element
hierarchy consisting of: (1) "site" - one of the Interim or National
9-5
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Priority List sites; (2) "project" - initial remedial measure or remedial
action; (3) "activity"-remediaI investigation, feasi-
bility study, remedial design, or remedial construction; and (4) "task"-
e.g., fence construction, slurry wall design, etc.
QAO: Quality Assurance Officer
QA/QC: Quality ControI/Qua I ity Assurance
QUALITY ASSURANCE: The total integrated program for assuring the reliability
of monitoring and measurement data.
QUALITY ASSURANCE PROGRAM PLAN: An orderly assembly of management policies,
objectives, principles, and general procedures by which an agency or
laboratory outlines how it intends to produce quality data.
QUALITY CONTROL: The routine application of procedures for obtaining prescribed
standards of performance in the monitoring and measurement process.
RCRA: The Resource Conservation and Recovery Act, PL 94-590, October 1976
RECORD OF DECISION (ROD)[OERR]: A decision process wherein a final solution
for the remedy of an NPL site, handled by OERR, is chosen from a group of
options.
RECORD REVIEW: An examination of records and reports, independent of an inspec-
tion. It may occur either at the waste handler's office or at the State or
Regional offices. The examination may involve a review of reports submitted
by the handler, such as financial documents and groundwater monitoring
reports. It may also involve review of records kept by the handler, such
as tests and analyses performed by the facility, the facility's self-moni-
toring records, manifests, closure and post-closure plans, and contingency
plans.
REMEDIAL INVESTIGATION (RI)[OERR]: A field investigation ordered by OERR to
gather the data necessary to (1) determine the nature and extent of a
problem at a site, (2) establish clean-up criteria, (3) identify prelim-
inary remedial alternatives, and (4) support the technical and cost analyses
of the alternatives. The activities are structured and generally not
totally satisfactory for enforcement purposes.
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) MODIFIED FOR ENFORCEMENT
(OWPE): Designed by enforcement personnel, which in addition to the OERR Rl
confirms a source or capability, more fully defines the physical character-
istics of a site, and further defines the threat. One product of the
Investigation is the Endangerment Assessment.
REPRESENTATIVENESS: The degree to which data accurately and precisely repre-
sent a characteristic of a population, the variation of a parameter at a
sampling point, or an environmental condition.
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RESPONSIBLE PARTY: As defined by Section 107(a) of CERCLA includes "(I) the
owner or operator of a vessel (otherwise subject to the jurisdiction of
the United States) or a faci I ity, (2) any person who at the time of dis-
posal of any hazardous substance owned or operated any faci I ity at which
such hazardous substances were disposed of, (3) any person who by contract,
agreement, or otherwise arranged for disposal or treatment, or arranged
with a transporter for transport for disposal or treatment, of hazardous
substances owned or possessed by such person, by any other party or entity,
at any faci I ity owned or operated by another party or entity and containing
such hazardous substances, and (4) any person who accepts or accepted any
hazardous substances for fee transport to or treatment faci I ities or sites
selected by such person, from which there is a release, or a threatened
release which causes the incurrence of response costs, of a hazardous
substance, shall be liable for--(A) all costs of removal or remedial
action incurred by the United States Government or a State not inconsistent
with the National Contingency Plan; (B) any other necessary costs of
response incurred by any other person consistent with the National Con-
tingency Plan; and (C) damages for injury to, distraction of natural
resources, including the reasonable costs of assessing such injury,
destruction, or loss resulting from such a release."
RESPONSIBLE-PARTY SEARCH [OWPE]: An investigation conducted to trace the past
and present owners of a site and other parties involved with the operation
of the site. More detailed than the search done under a PA (Preliminary
Assessment).
SCOPING: An assessment of the type of problem presented by a release and an
initial determination of the type or types of remedial action that may be
appropriate to remedy the problem. There are three classes of remedial
actions: initial remedial measures, source control remedial action, and
offsite control remedial action. Scoping is undertaken during the planning
phase of a remedial action.
SDWA: Safe Drinking Water Act, PL 95-523
SCBA: Self-contained Breathing Apparatus
SITE: Also refers to a hazardous substance site or a hazardous waste site, is
an area of land {or conceivably, water) or a location at which hazardous
substances were stored, treated, disposed of, or placed, or otherwise
came to be located. This includes all contiguous land, structures, other
appurtenances, and improvements on the land, used for treating, storing,
or disposing of hazardous substances. A site may consist of several treat-
ment, storage, or disposal facilities (e.g., impoundments, containers,
buildings, or equipment). "Site" is also the highest level of the 4
levels specified in the PTS data element hierarchy.
SITE INSPECTION [OERR]: A field study involving the collection of sufficient
data to characterize the magnitude and severity of the hazard posed by a
site in order to score the site for the MRS. It may include sampling,
monitoring, land surveys, testing and other information-gathering
activities.
9-7
-------
SPECIAL INSPECTIONS: Inspections conducted where serious violations are sus-
pected. They may be triggered by citizen complaints or indications of
violations detected in other inspections. Inspector or inspectors may
spend a number of days samp I ing or reviewing the operation of the faci I ity.
STANDARD OPERATING PROCEDURE: An operation, analysis, or action whose mechanics
are thoroughly prescribed and documented and-which is commonly accepted as
the usual or normal method for performing certain routine or repetitive
tasks.
STATE LEAD: Means that a State has primary responsibility for planning and
conducting either part of or an entire removal or remedial action.
STATEMENT OF WORK (SOW)[OERR]: An element of a work assignment (WA) package
that specifies in detail the task and objectives to be performed by a
contractor. It should include a background summary of the release, defin-
ition of the problem, purpose of work, and description of the services to
be performed.
STUDY PLAN [OWPE]: A document, which presents the goals and specific activities
to be undertaken in a Remedial Investigation modified for enforcement or
an Enforcement Investigation. Contracted experts should help in the
preparation of this plan.
STS: Site Tracking System. Has been replaced by ERRIS, Emergency and Remedial
Response Information System.
SUMMARY INVESTIGATION [OWPE]: An enforcement process similar to the Preliminary:
Assessment which can incorporate previous studies by other agencies and
indicate the adequacy of existing data. Can be performed near the begin-
ning of an enforcement action when a non-National Priority List case is
given to EPA by a state. It also may be conducted later if a site comes
to enforcement from OERR. No field work required.
TASK [OERR][OWPE]: A discrete piece of work cited in a Statement of Work,
Work Plan or Technical Duty Description.
TECHNICAL DUTY DESCRIPTION (TDD)[OERR][OWPE]: A set of discrete tasks given to
the FIT contractor.
TLV: Threshold Limit Value: maximum 8-hour human exposure level.
TSCA: Toxic Substance Control Act, PL 94-469 as amended by PL 97-129
TSDF: Treatment, Storage and Disposal Facility
TOC: Total Organic Carbon
TOX: Total Organic Halogen
USGS: United States Geologic Survey
-------
WORK ASSIGNMENT (WA)[OERR]: A document containing a Statement of Work which
also includes an estimate of direct labor hours and required period of
performance.
WORK PLAN (WP)[OERR][OWPE]: A contractors submittal of a written response to
a WA defining the technical approach to a project, the budget and schedule.
Other documents enclosed are the Health and Safety Plan and QA/QC plan.
9-9
-------
APPENDIX A
EVIDENCE AUDIT CHECKLISTS
A-1
-------
FIELD CHECKLIST
Briefing with Project Coordinator
PROJECT NO.
PROJECT COORDINATOR
PROJECT LOCATION
TYPE OF INVESTIGATION
(authority, agency)
DATE OF AUDIT
SIGNATURE OF AUDITOR
Yes_ No_ N/A_ 1 . Has a project coordinator been appointed?
Comments:
Yes No N/A
Was a project plan prepared?
If yes, what items are addressed in the plan?
Comments:
Yes No N/A
3 . Was a briefing held with project participants?
Comments:
Yes No N/A
4 . Were additional instructions given to project par-
ticipants (i.e., changes in project plan)?
Comments:
Yes_ No_ N/A_ 5 . Is there a written list of sampling locations and
descriptions?
Comments:
A-2
-------
Yes_ No_ N/A_ 6. Is there a map of sampling locations?
Comments:
Yes_ No_ N/A_ 7. Do the investigators follow a system of accountable
documents?
If yes, what documents are accountable?
Comments:
Yes_ No_ N/A_ 8. Is there a list of accountable field documents
checked out to the project coordinator?
If yes, who checked them out?
Comments:
Yes_ No_ N/A_ 9. Is the transfer of field documents (sample tags,
chain-of-custody records, logbooks, etc.) from the
project coordinator to the field participants docu-
mented in a logbook?
Comments:
A-3
-------
FIELD CHECKLIST
Field Observations
Yes_ No_ N/A_ 1. Was permission granted to enter and inspect the
facility?
Comments:
Yes_ No_ N/A_ 2. Is permission to enter the facility documented?
Comments:
Yes_ No_ N/A_ 3. Were split samples offered to the facility?
If yes, was the offer accepted or declined?
Comments:
Yes_ No_ N/A_ 4. If the offer to split samples was accepted, were
the split samples collected?
Comments:
Yes_ No_ N/A_ 5. Is the offering of split samples recorded?
Comments:
Yes_ No_ N/A_ 6. If split samples are collected, are they documented?
If yes, where are they documented?
Comments:
A-4
-------
Yes_ No_ N/A_ 7. Are the number, frequency, and types of field mea-
surements and observations taken as specified in the
project plan or as directed by the project coordinator?
Comments:
Yes_ No_ N/A_ 8. Are field measurements recorded (pH. temperature,
conductivity, etc.)? Where?
Comments:
Yes_ No_ N/A_ 9. Are samples collected in the types of containers
specified in the project plan or as directed by the
project coordinator?
Comments:
Yes_ No_ N/A_ 10. Are samples preserved as specified in the project
plan or as directed by the project coordinator?
Comments:
Yes_ No_ N/A_ 11. Are the number, frequency, and types of samples col-
lected as specified in the project plan or as direc-
ted by the project coordinator?
Comments:
Yes_ No_ N/A_ 12. Are samples packed for preservation as per the sample
plan (i.e., packed in ice, etc.)?
Comments:
A-5
-------
Yes_ No_ N/A_ 13. Is sample custody maintained at all times?
Comments:
A-6
-------
FIELD CHECKLIST
Document Control
Yes_ No_ N/A_ 1. Have all unused and voided accountable documents
been returned to the coordinator by the team
members?
Comments:
Yes_ No_ N/A_ 2. Have document numbers of all lost or destroyed ac-
countable documents been recorded in the project
coordinator's logbook?
Comments:
Yes_ No_ N/A_ 3. Are all samples identified with sample tags?
Comments:
Yes_ No_ N/A_ 4. Are all sample tags completed (e.g., station no.,
location, date, time, analyses, signatures of sam-
plers, type, preservatives, etc.)?
Comments:
Yes_ No_ N/A_ 5. Are all samples collected listed on a chain-of-
custody record?
If yes, describe the type of chain-of-custody
record used.
Comments:
A-7
-------
Yes_ No_ N/A_ 6. Are the sample tag numbers recorded on the chain-of-
custody documents?
Comments:
Yes_ No_ N/A_ 7. Does information on sample tags and chain-of-custody
records match?
Comments:
Yes_ No_ N/A_ 8. Does the chain-of-custody record indicate the method
of sample shipment?
Comments:
Yes_ No_ N/A_ 9. Is the chain-of-custody record included with the
samples in the shipping container?
Comments:
Yes_ No_ N/A_ 10. Do the sample traffic reports agree with the sample
tags?
Comments:
Yes_ No_ N/A_ 11. If required, has a receipt for samples been provided
to the facility?
Comments:
Yes_ No_ N/A_ 12. If required, was the offer of a receipt for samples
documented?
Comments:
A-8
-------
Yes_ No_ N/A_ 13. If used, are blank samples identified?
Comments:
Yes_ No_ N/A_ 14. If collected, are duplicate samples identified on
sample tags and chain-of-custody records?
Comments:
Yes_ No_ N/A_ 15. If used, are spiked samples identified?
Comments:
Yes_ No_ N/A_ 16. Are logbooks signed by the individual who checked
out the logbook from the project coordinator?
Comments:
Yes_ No_ N/A_ 17. Are logbooks dated upon receipt from the project
coordinator?
Comments:
Yes_ No_ N/A_ 18. Are logbooks project-specific (by logbook or by
page)?
Comments:
Yes_ No_ N/A_ 19. Are logbook entries dated and identified by author?
Comments:
A-9
-------
Yes_ No_ N/A_ 20. Is the facility's approval or disapproval to take
photographs noted in a logbook?
Comments:
Yes_ No_ N/A_ 21. Are photographs documented in logbooks (e.g., time,
date, description of subject, photographer, etc.)?
Comments:
Yes_ No_ N/A_ 22. If a Polaroid camera is used, are photos matched
with logbook documentation?
Comments:
Yes_ No_ N/A_ 23. Are sample tag numbers recorded in the project co-
ordinator's logbook?
Comments:
Yes_ No_ N/A_ 24. Are Quality Control checks documented (i.e., cali-
bration of pH meters, conductivity meters, etc.)?
Comments:
Yes_ No_ N/A_ 25. Are amendments to the project plan documented (on
the project plan itself, in a project logbook,
elsewhere)?
Comments:
A-10
-------
FIELD CHECKLIST
Debriefing with Project Coordinator
Yes_ No_ N/A_ 1. Was a debriefing held with project participants
after the audit was completed?
Comments:
Yes_ No_ N/A_ 2. Were any recommendations made to project partici-
pants during the debriefing?
If yes, briefly describe what recommendations were
made.
Comments:
A-11
-------
DOCUMENT AUDIT CHECKLIST
PROJECT NO.
PROJECT LOCATION
FILE LOCATION
DATE OF AUDIT
SIGNATURE OF AUDITOR
Yes No
Have individual files been assembled (field in-
vestigation, laboratory, other)?
Comments:
Yes No
Is each file inventoried?
Comments:
Yes No
Is there a list of accountable documents?
Comments:
Yes No
Are all accountable documents present or accounted
for?
Comments:
Yes No
Is a document numbering system used?
Comments:
A-12
-------
Yes_ No_ 6. Has each document been assigned a document control
masher?
Comments:
Yes_ No_ 7. Are all documents listed on the inventory ac-
counted for?
Comments:
Yes_ No_ 8. Are there any documents in the file which are not
on the inventory?
Comments:
Yes_ No_ 9. Is the file stored in a secure area?
Comments:
Yes_ No_ 10. Are there any project documents which have been
declared confidential?
Comments:
Yes_ No_ 11. Are confidential documents stored in a secure
area separate from other project documents?
Comments:
A-13
-------
Yes_ No_ 12. Is access to confidential files restricted?
Comments:
Yes_ No_ 13. Have confidential documents been q arked or stamped
"Confidential"?
Comments:
Yes_ No_ 14. Is confidential information inventoried?
Comments:
Yes_ No_ 15. Is confidential information numbered for document
control?
Comments:
Yes_ No_ 16. Have any documents been claimed confidential under
TSCA?
Comments:
A-14
-------
APPENDIX B
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT FORM
-------
unoa sum
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vvEPA
Potential Hazardous Waste Site
Preliminary Assessment
-------
\
Preliminary Assessment
B-3
-------
vvEPA
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 1 • SITE INFORMATION AND ASSESSMENT
I. IDENTIFICATION
'01 STATE 02STTE
I. SITE NAME AND LOCATION
02 STREET. BOOTH NO . OK SPECIFIC LOCATION «NTWW>
04S'»TE 05Z»CODE CM COUNTY
07COUNTY 08 CO«S
CODE CIST
09COOIWNATES LATITUDE
LONGITUDE
o OWECTIONS TO SITE n
III. RESPONSIBLE PARTIES
01 OWNER r»«
Of TELEPHONE NUM8EP,
I )
07 OPERATOR r»«v«iiww*i*r«irf*Mi
12 TELEPHONE NUMBED
I )
13 TYPE Or OWNERSHIP ;ǥۥ on,
C A PRIVATE ~ B. FEDERAL
0 F OTHER
C C STATE CD COUNTY G E MUNICIPAL
CO UNKNOWN
14 OWNER OPERATOR NOTIFICATION ON FILE .««•• •>•«
C A RCRA3001 DATE RECEIVED i
C B UNCONTROLLEDWASTESTTEicriicuiMu DATE RECEIVED .
IV. CHARACTERIZATION OP POTENTIAL HAZARD
01 ON SITE INSPECTION
C YES DATE
C A. EPA C B EPA CONTRACTOR C C STATE
D E LOCAL HEALTH OFFICIAL D F. OTHER:
CONTRACTOR NAMEIS):
Q D OTHER CONTRACTOR
02 STE STATUS fCMO >w
C A. ACTIVE C B iiACTTVE D C UNKNOWN
03 YEARS OF OPERA TON
Q UNKNOWN
04 OESCRVnON Of SUBSTANCES POSSOLV PRESENT KNOWN OR AUEOED
05 DESCMPT1ON OF POTENTIAL HAZARD TO ENVltONUENT ANOiOR POPULATION
V. PRIORITY ASSESSMENT
Ot PROWTY FORNSPECTXMlCMc»» »I^»«MOT««
a A MOM a B UEDMW
VI. INFORMATION AVAILABLE FROM
03TELCPI
( I
04 PERSON RESPONSBU FOR ASSESSMENT
CM ORGANIZATION
07 TELEPHONE NUMIER
I )
WONTM 0*v Iftf
EPA FORM 2070-1217 e
B-4
-------
&EPA
POTENTIAL HAZAR
PRELIMINARY
PARTa-WASTI
POUS W4?TF SITf i IDENTIFICATION
ASSESSMENT oisl*n
02 SHE NUMBER
II. WASTE STATES. QUANTITIES. AND CHARACTERISTICS
01 PHYSICAL STATES iC>wei«r *« •**
C A «OUO C E SLURRY
C • KNVDCR. FHES _ F LIQUID
ZC SLUDGE
- n OTHER
CG GAS
'*"«'
m. WASTE TYPE
CATEGORY
SLU
OLW
SOL
PSD
occ
ioc
ACD
BAS
02 WASTE QUANTITY AT SHE
Tnnis
UDexrmtmK
03 MASTE CHAIUCTERSTICS T»<.»~»«».,
C A TOXIC L E SOLUBLE
C B CORROSIVE _ F MFECTOUS _ J
_ C RADIOACTIVE _ G FLAMMABLE - «
-' 0 PERSISTENT _ H ONITABLE
_
HIGHLY VOLATILE
EXPLOS VE
REACTIVE
L MCOMFATIBLE
K NOT APPLICABLE
SUBSTANCE NAME
SLUDGE
OILY WASTE
SOLVENTS
PESTICIDES
OTHER ORGANIC CHEMICALS
MORGANIC CHEMICALS
ACIDS
BASES
MES
HEAVY METALS
IV. HAZARDOUS SUBSTANCES 'S~ A.
01 CATEGORY
01 GROSS AMOUNT
D2 UNIT OF MEASURE 03 COMMENTS
0: SUBSTANCE NAME
03 CAS NUMBER
V. FEEDSTOCKS
CATEGORY
FDS
FDS
. fos
• FDS
04 STORAGE DISPOSAL METMOP 05 CONCE NTRATtOK
Ot ME ASURE 0^
CONCEM'RA'pQV
'£•• 4c#wi«i fcv CAS MkMMI
01 FEEDSTOCK NAME
02 CAS NUMBER
CATEGORY 01 FEEDSTOCK NAME
FDS
FDS
FDS
FDS
OJCASWMBfc
VL SOURCES OF INFORMATION .c««~«-~~<- . , ~~«« «*>..>» ~=«.
B-5
-------
PARTS
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
• DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
L DENTOCATION
02 SHI NUMBER
I. HAZARDOUS CONDITIONS AND MCBENTS
01 1 i GROUNDWATER CONTAMINATION
03 *DPULAHON POTENTIALLY AFFECTED .
OJ C OBSERVED {DATE
04 NARRATIVE DESCRIPTION
C POTENTIAL
- ALLEGED
01 - 8 SURFACE WATER CONTAMINATION
03 POPULATION POTENTIALLY AFFECTED .
01Z OBSERVED I DATE
04 NARRATIVE DESCRIPTION
Z\ POTENTIAL
C ALLEGED
01 Z C CONTAMINATION OF AIR
03 POPULATION POTENTIALLY AFFECTED
02 Z OBSERVEDIDATE
04 NARRATIVE DESCRIPTION
D POTENTIAL
Z ALLEGED
01 ~ 0 FIRE. EXPLOSIVE CONDITIONS
03 POPULATION POTENTIALLY AFFECTED
03 - OBSERVED (DATE
04 NARRATIVE DESCRIPTION
C POTENTIAL
~ ALLEGED
01 Z E DIRECT CONTACT
03 POPULATION POTENTIALLY AFFECTED
02 I OBSERVED (DATE
04 NARRATIVE DESCRIPTION
; POTENTIAL
~ ALLEGED
01 C F CONTAMINATION OF SOIL
03 AREA POTENTIALLY AFFECTED
02 Z OBSERVED IDATE
04 NARRATIVE DESCRIPTION
3 POTENTIAL
~ ALLEGED
01 C G DRINKING WATER CONTAMINATION
03 POPULATION POTENTIALLY AFFECTED .
02 I OBSERVED (DATE
04 NARRATIVE DESCRIPTION
C POTENTIAL Z ALLEGED
01 3 H WORKER EXPOSURE.1NJURY
03 WORKERS POTENTIALLY AFFECTED.
01Z OBSERVED IDATE
04 NARRATIVE OESCMPTION
; POTENTIAL
: ALLEGED
01 Z I POPULATION EXPOSURE/MJURY
03 POPULATION POTENTIALLY AFFECTED
02 C OBSERVED IDATE
04 NARRATIVE OESCRPTION
DPOTENTIAL
O ALLEGED
B>A FORM 20TO 12(741)
B-6
-------
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
ID£WTIFICATION
"' S7tT1 °' *"* ***"<
i. HAZARDOUS CONDITIONS AND INCIDENTS c
01 C J DAMAGE TO FLORA
04 NARRATIVE DESCRTTION
01 O K OAMAQE TO FAUNA
04 NARRATIVE DESCWTION <
Q ALLEGED
01 C L CONTAMINATION OF FOOD CHAIN
04 NARRATIVE DESCRIPTION
01 D M UNSTABLE CONTAINMENT QF_WASTES
03 POPULATION POTENTIALLY AFFECTED
02 a OBSERVED (DATE
04 NARRATIVE DESCRPTION
C POTENTIAL C ALLEGED
01 C N DAMAGE TO OFFSITE PROPERTY
04 NARRATIVE OESCRPT1ON
C ALLEGED
01 ~ 0 CONTAMINATION OF SEWERS STORM DRAINS WWTPt 02 C OBSERVED (DATE
04 NARRATIVE DESCRIPTION
_) L POTENTIAL C ALLEGED
01 ~ P ILLEGAL/UNAUTHORIZED DUMPING
04 NARRATIVE DESCRIPTION
02 r
.) D POTENTIAL C ALLEGED
OS DESCRWWN OF ANY OTHER KNOWN POTENTIAL OH ALLEGED HAZARDS
•1 TOTAL »OPUL*TION POTENTIALLY AFFECTED
IV COMMENTS
V. SOURCES Of MFONMATION ?
I S>»FCK»«30TO 1217-411
5-7
-------
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
General Information
The Potential Hazardous Waste Site, Preliminary Assess-
ment form is used to record information necessary to make
an initial evaluation of the potential risk posed by a site and
to recommend further action.
The Preliminary Assessment form Contains three parts:
Part 1 - Site information and Assessment
Part 2 - Waste Information
Part 3 - Description of Hazardous Conditions and include
dents
Port 1 - Site Information and Assessment contains all of
the data elements also contained on the Site Identification
form required to add a site to the automated Site Tracking
System (STS). It is therefore possible to add a site to STS at
the Preliminary Assessment stage. Instructions are given
below.
Part 2 - Waste Information and Part 3 - Description of
Hazardous conditions and Incidents are used to record specific
information about substances amounts, hazards, and targets,
e.g., population potentially affected, that are used in determin-
ing the priority for further action. Parts 2 and 3 are also con-
tained in the Potential Hazardous Waste Site, Site Inspection
Report form where they may be used to update, add, delete, or
correct information supplied on the Preliminary Assessment.
An Appendix with feedstock names end CAS Numbers
and the most frequently cited hazardous substances and CAS
Numbers is located behind the instructions for the Preliminary
Assessment.
General Instructions
1. complete the Preliminary Assessment form as com-
pletely as possible.
2. Starred items (*) are rewired before assessment
information can be added to STS. The system will not I ccept
incomplete assessment information.
3. To add a site to STS at the Preliminary Assessment
stage, write "New" across the top of the form and complete
items 11-01, 02, 03, 04, and 06, Site Name and Location, and
item 111-13, Type of Ownership.
4. Data items carried in STS, which are identical to
those on the Site Identification form and which can be added,
deleted, or changed using the Preliminary Assessmant form,
are indicated with a pound sign (#). To ensure that the Proper
action is taken, outline the item(s) to be added, deleted, or
changed with I bright color end indicate the proper action
with "A" (add), "D" (delete), or "C" (change).
5. There are two options available for adding, deleting,
or changing information supplied on the Preliminary Assess-
ment form. The first is to use a new Preliminary Assessment
form, completing only those items to be added, deleted, or
changed. Mark the form clearly, using "A", "D", or "C", to
indicate the action to be taken. If only date carried in STS are
to be altered, the Site Source Data Report may be used. Using
the report, mark clearly the items to be charged end the
action to be taken.
Detailed Instructions
Part 1 Site Information and Assessment
I. Identification: Identification (State and Site Num-
ber) is the site record key, or primary identifier,
for the site. Site records in the STS are updated
based on identification. It is essential that State
and Site Number are correctly entered on each
form .
*l-01 State: Enter the two character alpha FIPS code for
the state in which the site is located. It must be
identical to State on the Site Identification form.
*l-02 Site Number: Enter the ten character alphanumeric
code for sites which have a Dun and Bradstreet or
EPA "user" Dun and Bradstreet number or the ten
character numeric GSA identification code for fed-
eral sites. The Site Number must be identical to the
Site Number on the Site Identification form.
II. Site Name end Location: If Site Name and Location
information require no additions or changes, these
items are not required on the Preliminary Assess-
ment form. However, completing these items will
facilitate use of the completed form and records
management procedures.
#11-01 Site Name: Enter the legal, common, or descriptive
name of the site.
#ll-02 Site Street: Enter the street address and number (if
appropriate) where the site is located. If the precise
street address is unavailable for this site, enter brief
direction identifier, e.g., NW intersection I-295 &
US 99; Post Rd, 5 mi W of Rt. 5.
#ll-03 Site City: Enter the city, town, village, or other
municipality in which the site is located If the site
is not located in a municipality, enter the name of
the municipality (or place which is nearest the site
or which most easily locates the site.
#M-04 Site State: Enter the two character alpha FIPS code
for the state in which the site is located. The code
must be the acme as in item 1-01.
# 1 1 -0 5 Site Zip Code: Enter the five character numeric zip
code for the postal zone in which the site is located.
# 1 1 -0 6 Site County: Enter the name of the county, parish
(Louisiana), or borough (Alaska) in which the site is
located
#ll-07 Count y Code: Enter the three character numeric
FIPS county code for the county, pariah, or bor-
ough in which the site is located. (The regional data
analyst will furnish this data item.)
# 1 1 -0 8 Site Congressional District: Enter the two character
number for the congressional district in which the
site is located.
1 1 -09 Coordinates: Enter the coordinates, Latitude and
Longitude, of the site in degrees, minutes, seconds
and tenths of seconds. If a tenth of a second is in-
significant at this site, enter "0".
11-10 Directions to Site: Starting from the nearest public
reed, provide narrative directions to the site.
-------
Part 1 (continued)
PRELIMINARY ASSESSMENT
#lll-02
-03
-04
-05
III-06
#lll-08
-09
-10
-11
111-12
IV
IV-01
Responsible Parties
Site Owner: Enter the name of the owner of the
site. The site owner is the person, company, or fed-
eral, state, municipal or other public or private en-
tity, who currently holds title to the property on
which the site is located.
Site Owner Address: Enter the currant complete
business, residential, or mailing address at which the
owner of the site can be reached.
Site Owner Telephone Number: Enter the area code
and local telephone number at which the owner of
the site can be reached.
Site Operator: If different from Site Owner, enter
the name of the operator I t the site. The site oper-
ator is the parson, company, or federal, state,
municipal or other public or private entity, who cur-
rently, or moat recently, is, or was, responsible for
operation at the site.
Site Operator Address: Enter the current complete
business, residential, or mailing address at which
the operator of the site can be reached.
Site Operator Telephone Number: Enter the area
code and local telephone number at which the
operator of the site cart be reached.
Type of ownership: Check the appropriate box to
indicate the type of site ownership, If the site is
under the jurisdiction of an activity of the federal
government, enter the name of the department,
agency, or activity. If Other is indicated, specify
the type of ownership and name.
Owner/Operator Notification On File: Check the
appropriate box(es) to indicate that the notifica-
tion required by RCRA (3001) and/or CERCLA
(103c, Superfund) have bean received. If received,
enter the date(s) received. Check none if not re-
ceived.
Characterization of Potential Hazard
On Site Inspection: Check the expropriate box to
indicate that the site has bean inspected or visited
by EPA, a state or local official, or e contractor
representative of EPA or a state or local govern
ment. Enter the date of the inspection, Check the
appropriate box(es) to indicate who visited the site
or performed the inspection, If the site visit was per-
formed by a contractor, enter the name of the
company.
Site Status: Check the appropriate box(es) to indi-
cate the currant status of the site. Active sites are
those which treat, store, or dispose of waste. Check
Active for those active sites with an inactive stor-
age or disposal area. Inactive sites are those at which
treatment, storage, or disposal activities no longer
occur.
Years of Operation: Enter the beginning I nd ending
years (or beginning only if operations at the site are
on-going), e.g., 1878/1932, of waste treatment,
storage, and/or disposal activities at the site. Check
Unknown if the years of operation are not known.
Description of Substance Possibly Present, Known,
or Alleged: Provide a narrative description of
hazardous, potentially hazardous, or other sub.
stances present, or claimed to be present, at the site.
IV-05 Description of potential Hazard to Environment
and/or Population: Provide a narrative description
of the potential hazard the site poses to the environ-
ment and to exposed population or wildlife. If no
hazard, or potential hazard, exists, provide the basis
for that determination.
V. Priority Assessment
*V-01 Priority for Inspection: Check the appropriate box
to indicate the priority for further I ction or inspec-
tion. If no further I ction is required, complete the
Potential Hazardous Waste Site, Current Disposi-
tion form. The Priority for Inspection assessed must
be supported by appropriate data in Part 2 - Waste
Information and Part 3 - Description of Hazardous
Conditions and Incidents of this form. If no haz-
ardous conditions exist, Part 3 is not required,
VI. Information Available From
VI-01 Contact: Enter the name of the individual who can
provide information about the site.
VI-02 Of: If appropriate, enter the name of the Public or
private agency, firm, or company I nd the organi-
cation within the agency, firm, or company of the
individual named as Contact,
VI-03 Telephone Number: Enter the area code and local
telephone number of the individual namad as con-
tact
VI-04 Person Responsible for Assessment: Enter the name
of the individual who made the site assessment and
assigned the priority rating to the site. The parson
responsible for the assessment may be different
from the individual who prepared the form.
VI-05 Agency: Enter the name of the Agency where the
individual who mace the assessment is employed
VI-06 Organization: Enter the name of the organization
within the Agency.
VI-07 Telephone Number: Enter the area code and local
telephone number of the individual who made the
assessment.
VI-08 Date: Enter the date the assessment was made.
Part 2 Waste Information
*l. Identification: Refer to Part 1-1.
II. Waste States, Quantities, and Characteristics: Waste
States, Quantities, and characteristics provide infor-
mation about the physical structure and form of the
waste, measures of gross amounts at the site, and
the hazards posed by the waste, considering acute
and chronic health effects and mobility along a
pathway.
* 11-01 Physical States: Check the appropriate box(es) to
indicate the state(s) of waste present, or thought to
be present, at the site. If Other is indicated, specify
the physical state of the waste.
*ll-02 Waste Quantity at Site: Enter estimates of amounts
of wrote at the site. Estimates may be in weight
(Tons) or volume (Cubic Yards or Number of
Drums). Use as many entries as are appropriate;
however, measurements must be independent. For
B-9
-------
Part 2 (continued)
PRELIMINARY ASSESSMENT
@IV-01
@IV-02
@IV-03
@IV-04
IV-05
IV-06
example, do not measure the same amounts of
waste as both tons and cubic yards.
Waste Characteristics: Check all appropriate entries
to indicate the hazards posed by waste at the site.
If waste at the site poses no hazard, check Not
Applicable.
Waste Category: General categories of waste typi-
cally found are listed here. Enter the estimated gross
amount of the category of waste next to the appro-
priate substance name and enter the unit of measure
used with the estimate.
Gross Amount: Gross Amount is the intimate of the
amount of the waste category found at the site.
Estimates should be furnished in metric tons (MT),
tons (TN), cubic meters (CM), cubic yards (CY),
drums (DR), acres (AC), acre feat (AF), liters (LT),
or gallons (GA). Enter the estimated amount next
to the appropriate waste category.
Unit of Measure: Enter the appropriate unit of mea-
sure: MT (metric tons), TN (tons), CM (cubic meters),
CY (cubic yards), DR (number of drums), AC
(acres), AF (acre feet), LT (liters), or GA (gallons),
next to the estimate of gross amount.
comments: Comments may be used to further ex-
plain, or provide additional information, about par-
ticular waste categories.
Hazardous Substances: Specific hazardous, or
potentially hazardous, chemicals, mixtures, and
substances found at the site are listed hare. This
information may not be available at the Preliminary
Assessment stage. Substances for which information
is available are to be listed here. For each substance
listed those data items marked with an "at" sign
(@) must be included.
Category: Enter in front of the substance name the
three character waste category from Section III
which best describes the substance, e.g., OLW (Oily
Wrote).
Substance Name: Enter one of the following: the
name of the substance registered with the Chemical
Abstract Service, the common or accepted abbre-
viation of the substance, the generic name of the
substance, or commercial name of the substance.
CAS Number: Enter the number I ssigned to the
substance when it was registered with the Chemical
Abstract Service. Refer to the Appendix for most
frequently cited CAS Numbers, CAS Numbers must
be furnished for each substance limed. If a CAS
Number for this substance has not been assigned,
enter "999".
Storage/Disposal Method: Enter the type of storage
or disposal facility in which the substance was
found: SI (surface impoundment, including pits,
ponds, and lagoons), PL (pile), DR (drum), TK
(tank), LF (landfill), LM (landfarm), OD (open
dump).
Concentration: Enter the concentration of the sub-
stance found in samples taken at the site.
Measure of Concentration: Enter the appropriate
unit of measure for the measured concentration of
the substance found in the sample, e.g., MG/L,
UG/L.
Feedstocks
Feedstock Name: If feedstocks, or substances
derived from one or more feedstocks, are present
et the site, enter the name of each feedstock found.
See the Appendix for the feedstock list.
CAS Number: Enter the CAS Number for I ach
feedstock named. See the Appendix for feedstock
CAS Numbers.
Sources of Information: List the sources used to
obtain information for this form. Sources cited may
include: sample analysis, reports, inspections, offi-
cial records, or other documentation. Sources cited
provide the basis for information entered on the
form and may be used to obtain further information
I bout the site.
Part 3 Description of Hazardous conditions and Incidents
*l. Identification: Refer to Part 1-1.
II. Hazardous Conditions and Incidents:
11-01 Hazards: Indicate each hazardous, or potentially
hazardous, condition known, or claimed, to exist at
the site.
II-02 Observed, Potential, or Alleged: Check Observed
and enter the date, or approximate date, of occur.
rence if a release of contaminants to the environ.
ment, or tome other hazardous incident, is known
to have occurred. In cases of a continuing release,
e.g., groundwater contamination, enter the date.
or approximate date, the condition first became
apparent. If conditions exist for a potential release,
check potential. Check Alleged for hazardous, or
potentially hazardous, conditions claimed to exist
I the site.
II-03 Population Potentially Affected: For each haz-
ardous condition at the site, enter the number of
people potentially affected, For Soil enter the num-
ber of acres potentially affected.
11-04 Narrative Description: Provide a narrative descrip-
tion, or explanation, of each condition. Include any
additional information which further explains the
condition.
II-05 Description of Any Other Known, Potential, or Al-
leged Hazards: Provide a narrative description of
any other hazardous, or potentially hazardous,
conditions at the site not covered I bove.
III. Total Population Potentially Affected: Enter the
total number of people potentially affected by the
existence of hazardous, or potentially hazardous,
conditions at the site. Do not sum the numbers
shown for each condition,
IV. Comments: Other information relevant to observed,
potential, or alleged hazards may be entered here.
V. Sources of Information: List the sources used to
obtain information for this form. Sources cited
may include: sample analysis, reports, inspections,
official records, or other documentation. Sources
cited provide the basis for information entered
on the form and may be used to obtain further in-
formation about the site.
B-10
-------
APPENDIX
1. FEEDSTOCKS
CAS Number
1. 7664-41-7
2. 7440-36-0
3. 1309-64-4
4. 7440-38-2
5. 1327-53-3
6. 21109-95-5
7. 7726-95-6
8. 106-99-0
9. 7440-43-9
10, 7782-50-5
11. 12737-27-8
12. 7440-47-3
13. 7440-48-4
Chemical Name
Ammonia
Antimony
Antimony Trioxide
Arsenic
Arsenic Trioxide
Berium Sulfide
Bromine
Butadiene
Cadmium
Chlorine
C h ro m i te
Chromium
Cobalt
II. HAZARDOUS SUBSTANCES
CAS Number Chemical Name
1. 75-07-0
2. 64-19-7
3. 108-24-7
4. 75-86-5
5. 506-96-7
6. 75-36-5
7. 107-02-8
8. 107-13-1
9. 124-04-9
10. 309-00-2
11. 10043-01-3
12. 107-18-6
13. 107-06-1
14. 7664-41-7
15. 631-61-8
16. 1863-63-4
17. 1066-33-7
18. 7789-09-5
19. 1341-49-7
20. 10192-30-0
21. 1111-78-0
22. 12125-02-9
23. 7788-98-9
24. 3012-65-5
25. 13826-83-0
26. 12125-01-8
27. 1336-21-6
28. 6009-70-7
29. 16919-19-0
30. 7773-06-0
31. 12136-76-1
32. 10196-04-0
33. 14307-43-8
34. 1782-96-4
35. 7783-18-8
36. 628-63-7
37. 62-53-3
38. 7647-18-9
39. 7789-61-9
40. 10025-91-9
41. 7783-56-4
42. 1309-64-4
43. 1303-32-8
44. 1303-28-2
45. 7784-34-1
46. 1327-53-3
Acetaldehyde
Acetic Acid
Acetic Anhydride
Acetone Cyanohydrin
Acetyl Bromide
Acetyl Chloride
Acrolein
Acrylonitrile
Adipic Acid
Aldrin
Aluminum Sulfate
Allyl Alcohol
Allyl Chloride
Ammonia
Ammonium Acetate
Ammonium Benzoate
Ammonium Bicarbonate
Ammonium Bichromate
Ammonium Bifluoride
Ammonium Bisulfate
Ammonium Carbemate
Ammonium Chloride
Ammonium Chromate
Ammonium Citrate, Dibasic
Ammonium Fluoborate
Ammonium Fluoride
Ammonium Hydroxide
Ammonium Oxalate
Ammonium Si licoflu oride
Ammonium Sulfamate
Ammonium Sulfide
Ammonium Sulfite
Ammonium Tartrate
Ammonium Thiocyanate
Ammonium Thiosulfate
Amyl Acetate
Aniline
Antimony Pentachloride
Antimony Tribromide
Antimony Trichloride
Antimony Trifluoride
Antimony Trioxide
Arsenic Disulfide
Arsenic Pentoxide
Arsenic Trichloride
Arsenic Trioxide
CAS Number
14. 1317-38-0
15. 7758-98-7
16. 1317-39-1
17. 74-85-1
16. 7647-01-0
19. 7664-39-3
20. 1336-25-7
21. 7439-97-6
22. 74-82-8
23. 91-20-3
24. 7440-02-0
25. 7697-37-2
26. 7723-14-0
CAS Number
47. 1303-33-9
48. 542-62-1
49. 71-44-2
50. 65-85-0
51. 100-47-0
52. 98-88-4
53. 100-44-7
54. 7440-41-7
55. 7787-47-5
56. 7787-49-7
57. 13597-99-4
58. 123-86-4
59. 84-74-2
60. 109-73-9
61. 107-92-6
62. 543-90-8
63. 7789-42-6
64. 10108-64-2
65. 7778-44-1
66. 52740-16-6
67. 75-20-7
68. 13765-19-0
69. 592-01-8
70. 26264-06-2
71. 7778-54-3
72. 133-06-2
73. 63-25-2
74. 1563-66-2
75. 75-15-0
76. 56-23-5
77. 57-74-9
78. 7782-50-5
79. 108-90-7
80. 67-66-3
81. 7790-94-5
82. 2921-88-2
83. 1066-30-4
84. 7738-94-5
85. 10101-53-8
86. 10049-05-5
87. 544-18-3
88. 14017-41-5
89. 56-72-4
90. 1319-77-3
91. 4170-30-3
Chemical Name
Cupric Oxide
Cupric Sulfate
Cuprous Oxide
Ethylene
Hydrochloric Acid
Hydrogen Fluoride
Lead Oxide
Mercury
Methane
Napthalene
Nickel
Nitric Acid
Phosphorus
Chemical Name
Arsenic Trisulfide
Barium Cyanide
Benzene
Benzole Acid
Benzonitrile
Benzoyl Chloride
Benzyl Chloride
Beryllium
Beryllium Chloride
Beryllium Fluoride
Beryllium Nitrate
Butyl Acetate
n-Butyl Phthalate
Butylamine
Butyric Acid
Cadimium Acetate
Cadmium Bromide
Cadmium Chloride
Calcium Arsenate
Calcium Arsenite
Calcium Carbide
Calcium Chromate
Calcium Cyanide
Calcium Dodecylbenzene
Sulfonate
Calcium Hypochlorite
Captan
Carbaryl
Carbofuran
Carbon Disulfide
Carbon Tetrachloride
Chlordane
Chlorine
Chlorobenzene
Chloroform
Chlorosulfonic Acid
Chlorpyrifos
Chromic Acetate
Chromic Acid
Chromic Sulfate
Chromous Chloride
Cobaltous Formate
Cobaltous Sulfamate
Coumaphos
Cresol
Crotonaldehyde
CAS Number
27. 7778-50-9
28. 1310-58-3
29. 115-07-1
30. 10588-01-9
31. 1310-73-2
32. 7646-78-8
33. 7772-99-8
34. 7664-93-9
35. 108-88-3
36. 1330-20-7
37. 7646-85-7
38. 7733-02-0
CAS Number
92. 142-71-2
93. 12002-03-8
94. 7447-39-4
95. 3251-23-8
96. 5893-66-3
97. 7758-98-7
98. 10380-29-7
99. 815-82-7
100. 506-77-4
101. 110-82-7
102. 94-75-7
103. 94.11.1
104. 50-29-3
105. 333-41-5
106. 1918-00-9
107. 1194-85-6
108. 117-80-6
109. 25321-22-6
110. 266-38-19-7
111. 26952-23-8
112. 8003-19-8
113. 75-89-0
114. 62-73-7
115. 60-57-1
116. 109-89-7
117. 124-40-3
118. 25154-54-5
119. 51-28-5
120. 25321-14-6
121. 85-00-7
122. 298-04-4
123. 320-54-1
124. 27176-87-0
125. 115-29-7
126. 72-20-8
127. 106-89-8
128. 563-12-2
129. 100-41-4
130. 107-15-3
131. 106-93-4
122. 107-06-2
133. 60-00-4
134. 1185-57-5
135. 2944-67-4
136. 7705-08-0
Chemical Name
Potassium Dichromate
Potassium Hydroxide
Propylene
Sodium Dichromate
Sodium Hydroxide
Stannic Chloride
Stannous Chloride
Sulfuric Acid
Toluene
Xylene
Zinc Chloride
Zinc Sulfate
Chemical Name
Cupric Acetate
Cupric Acetoarsenite
Cupric Chloride
Cupric Nitrate
Cupric Oxalate
Cupric Sulfate
Cupric Sulfate Ammoniated
Cupric Tartrate
Cyanogen Chloride
Cyclohexane
2,4-D Acid
2,4-D Esters
DDT
Diazinon
Dicamba
Dichlobenil
Dichlone
Dichlorobenzene (all isomers)
Dichloropropane (all isomers)
Dichloropropene (all isomers)
Dichloropropene-
Dichloropropane Mixture
2-2-Dichloropropionic Acid
Dichlorvos
Dieldrin
Diethylamine
Dimethylamine
Dinitrobenzene (all isomers)
Dinitrophenol
Dinitrotoluene (all isomers)
Diquat
Disulfoton
Diuron
Dodecylbenzenesulfonic Acid
Endosulfan (all isomers)
Endrin and Metabolites
Epichlorohydrin
Ethion
Ethyl Benzene
Ethylenediamine
Ethylene Dibromide
Ethylene Dichloride
EDTA
Ferric Ammonium Citrate
Ferric Ammonium Oxalate
Ferric Chloride
B-11
-------
II. HAZARDOUS SUBSTANCES
CAS Number
138. 10421-48-4
139. 10028-22-5
140. 10045-89-3
141. 7758-94-3
142. 7720-78-7
143. 206-44-0
144. 50-00-0
145. 64-18-6
146. 110-17-8
147. 98-01-1
148. 86-50-0
149. 76-44-8
150. 118-74-1
151. 87-68-3
152. 67-72-1
153. 70-30-4
154. 77-47-4
155. 7647-01-0
156. 7664-39-3
157. 74-90-8
158. 7783-06-4
159. 78-79-5
160. 42504-46-1
161 115 32-2
162. 143-50-0
163. 301-04-2
164. 3687-31-8
165. 7758-95-4
166. 13814-96-5
167. 7783-46-2
168. 10101-63-0
169. 18256-98-9
170. 7428-48-0
171. 15739-80-7
172. 1314-87-0
173. 592-87-0
174. 58-89-9
175. 14307-35-8
176. 121-75-5
177. 110-16-7
178. 108-31-6
176. 2032-65-7
180. 592-04-1
181. 10045-94-0
182. 7783-35-9
183. 592-85-8
184. 10415-75-5
185. 72-43-5
186. 74.93-1
187. 80-62-6
188. 298-00-0
189. 7786-34-7
190. 315-18-4
191. 75-04-7
Chemical Name
Ferric Nitrate
Ferric Sulfate
Ferrous Ammonium Sulfate
Ferrous Chloride
Ferrous Sulfate
Fluoranthene
Formaldehyde
Formic Acid
Fumeric Acid
Furfural
Guth ion
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Hexachlorophene
Hexachlorcyclopentadiene
Hydrochloric Acid
(Hydrogen Chloride)
Hydrofluoric Acid
(Hydrogen Fluoride)
Hydrogen Cyanide
Hydrogen Sulfide
Isoprene
Isopropanolamine
Dodecylbenzenesulfonate
Keithane
Kepone
Lead Acetate
Lead Arsenate
Lead Chloride
Lead Fluoborate
Lead Fluoride
Lead Iodide
Lead Nitrate
Lead Staerate
Lead Sulfate
Lead Sulfide
Lead Thiocyanate
Lindane
Lithium Chromate
Malthion
Maleic Acid
Maleic Anhydride
Mercaptodimethur
Mercuric Cyanide
Mercuric Nitrate
Mercuric Sulfate
Mercuric Thiocyanate
Mercurous Nitrate
Methoxychlor
Methyl Mercaptan
Methyl Methacrylate
Methyl Parathion
Mevinphos
Mexacarbate
Monoethylamine
CAS Number
193. 300-76-5
194. 91-20-3
195. 1338-24-5
196. 7440-02-0
197. 15699-18-0
198. 37211-05-5
199. 12054-48-7
200. 14216-75-2
201. 7786-81-4
202. 7697-37-2
203. 98-95-3
204. 10102-44-0
205. 25154-55-6
206. 1321-12-6
207. 30526-89-4
208. 56-38-2
209. 608-93-5
210. 87-86-5
211. 85-01-8
212. 108-95-2
213. 75-44-5
214. 7664-38-2
215. 7723-14-0
216. 10025-87-3
217. 1314-80-3
218. 7719-12-2
219. 7784-41-0
220. 10124-50-2
221. 7778-50-9
222. 7789-00-6
223. 7722-64-7
224. 2312-35-8
225. 79-09-4
226. 123-62-6
227. 1336-36-3
228. 151-50-8
229. 1310-58-3
230. 75-56-9
231. 121-29-9
232. 91-22-5
233. 108-46-3
234. 7446-08-4
235. 7761-88-8
236. 7631-89-2
237. 7784-46-5
238. 10588-01-9
239. 1333-83-1
240. 7631-90-5
241. 7775-11-3
242. 143-33-9
243. 25155-30-0
244. 7681-49-4
245. 16721-80-5
246. 1310-73-2
247. 7681-52-9
248. 124-41-4
Chemical Name
Monomethylamine
Naled
Naphthalene
Naphthenic Acid
Nickel
Nickel Ammonium Sulfate
Nickel Chloride
Nickel Hydroxide
Nickel Nitrate
Nickel Sulfate
Nitric Acid
Nitrobenzene
Nitrogen Dioxide
Nitrophenol (all isomers)
Nitrotoluene
Paraformaldehyde
Parathion
Pentachlorobenzene
Pentachlorophenol
Phenanthrene
Phenol
Phosgene
Phosphoric Acid
Phosphorus
Phosphorus Oxychloride
Phosphorus Pentasulfide
Phosphorus Trichloride
Potassium Arsenite
Potassium Bichromate
Potassium Chromate
Potassium Permangenate
Propargite
Propionic Acid
Propionic Anhydride
Polychlorinated Biphenyls
Potassium Cyanide
Potassium Hydroxide
Propylene Oxide
Pyrethrins
Quinoline
Resorcinol
Selenium Oxide
Silver Nitrate
Sodium Arsenate
Sodium Arsenite
Sodium Bichromate
Sodium Bifluoride
Sodium Bisulfite
Sodium Chromate
Sodium Cyanide
Sodium Dodecylbenzene
Sulfonate
Sodium Fluoride
Sodium Hydrosulfide
Sodium Hydroxide
Sodium Hypochlorite
Sodium Methylate
CAS Number Chemical Name
249. 7632-0000 Sodium Nitrate
250. 7558-79-4 Sodium Phosphate, Dibasic
251. 7601-54-9 Sodium Phosphate, Tribasic
252. 10102-18-8 Sodium Selenite
253. 7789-06-2 Strontium Chromate
254. 57-24-9 Strychnine and Salts
255. 100-420-5 Styrene
256. 12771-08-3 Sulfur Monochloride
257. 7664-93-9 Sulfuric Acid
258. 93-76-5 2,4,5-T Acid
259. 2008-46-0 2,4,5-T Amines
260. 93-79-8 2,4,5-T Esters
261. 13560-99-1 2,4,5-T Salts
262. 93-72-1 2,4,5-TP Acid
263. 32534-95-5 2,4,5-TP Acid Esters
264. 72-54-8 TDE
265. 95-94-3 Tetrachlorobenzene
266. 127.18-4 Tetrachloroethane
267. 78-00-2 Tetraethyl Lead
268. 107-49-3 Tetraethyl Pyrophosphate
269. 7446-18-6 Thallium (I) Sulfate
270. 108-88-3 Toluene
271. 8001-35-2 Toxaphene
272. 12002-48-1 Trichlorobenzene (all isomers)
273. 52-68-6 Trichlorfon
274. 25323-89-1 Trichloroethane (all isomers)
275. 79-01-6 Trichloroethylene
277. 27323-41-7 Triethanolamine
Dodecylbenzenesulfonate
278. 121-44-8 Triethylamine
279. 75-50-3 Trimethylamine
280. 541-09-3 Uranyl Acetate
281. 10102-06-4 Uranyl Nitrate
282. 1314-62-1 Vanadium Pentoxide
283. 27774-13-6 Vanadyl Sulfate
284. 108-05-4 Vinyl Acetate
285. 75-35-4 Vinylidene Chloride
286. 1300-71-6 Xylenol
287. 557-34-6 Zinc Acetate
288. 52628-25-8 Zinc Ammonium Chloride
289. 1332-07-6 Zinc Borate
290. 7699-45-8 Zinc Bromide
291. 3486-35-9 Zinc Carbonate
292. 7646-85-7 Zinc Chloride
293. 557-21-1 Zinc Cyanide
294. 7783-49-3 Zinc Fluoride
295. 557-41-5 Zinc Formate
296. 7779-86-4 Zinc Hydrosulfite
297. 7779-88-6 Zinc Nitrate
298. 127-82-2 Zinc Phenolsulfonate
299. 1314-84-7 Zinc Phosphide
300. 16871-71-9 Zinc Silicofluoride
301. 7733-02-0 Zinc Sulfate
302. 13746-89-9 Zirconium Nitrate
303. 16923-95-8 Zirconium Potassium Fluoride
304. 14644-61-2 Zirconium Sulfate
305. 10026-11-6 Zirconium Tetrachloride
B-12
-------
APPENDIX C
POTENTIAL HAZARDOUS WASTE SITE
INSPECTION REPORT
C-1
-------
MMOiglon. DC 2O46O
»AFam 1OTO-13
My. 1M1
oEPA
Potential Hazardous Waste Site
Site Inspection Report
C-2
-------
Site Inspection Report
C-3
-------
ft r*r** *OTE»
oB*V ,„„.„,;
)T(AI MA7ARDOUS WASTE SITE J BCMWICATION
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01 DAHOF itf^tdtlON 02 >m STATUS OS VCAM Of OPCKATDN
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06 CHEF MSFCCTOM
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< 1 BTl NEMIUtMTATIVES MTIKVOVEO
t7«ocfMOM«oi« miiKOnanciMi
OWMWANT
IV. MFOMMTIOM AVAILAtU FKON
01 CONTACT
rnrii)«iiiincirni«aii rr«iiiiii«rirTi'»iii»»i
tKTTTlf Or OHQAMZATION
10TTT!£ 1 1 OAGAMZATION
I4TTTU ItAOCMCaS
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( )
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( )
( )
( 1
( )
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( )
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( I
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1 1 MATMJ) OONDmOMS
OtAOEMCV nOWWMZATION 07TtL£MONENO
UTIUPMONENO
( I
MDATC
/ 1
HONTta DAY *t«*
AKDM tOTB-ll (7-«l|
C-4
-------
- ___ _ POTENTIAL HAZARDOUS WASTE SITE
tfvFRCV SHE INSPECTION REPORT
^rs_l *-* PART 2- WASTE MFOMIATION
L BENTVICATION
oi*r»n
OiKTEMMEIt
i. WASTE STATES, QUANTITIES. AND CHARACTERISTICS
01 mrlCALITATfl lOuaMtMT' 01 WAITt OUAMTITV AT UTt
DA SOLD Ol*l»*ir «•»•-. " i
n • MM« «u n • m«i mra
QctujDoc oa ou
O A TOXIC DEMLUKf OlMOHLTVOLATXE
Oi oamaeNt nr.tncnout ojcnoavt
D c MOOACTIVE D 0 -i ninrniir O « Kt»CTtvt
OOFCRfSTtNT OH0*TA(Li O L MCOM»tTBU
OMNOTAWUCA1U
KL WASTE TVK
CATtOWT
SLU
otw
SO.
PSO
occ
oc
ACD
•AS
M£S
MCTAMf HAUC
SLUDGE
OXY WASTE
SOLVENTS
KSTOOES
OTHER ORGANIC CHEMICALS
MORGAMC CHEMCALS
ACIDS
•ASES
HEAVY METALS
01 OHMS AMOUNT
52 UWT OF MEA3UHE
03 COMMt NTS
IV. HAZARDOUS SUBSTANCES i» «»^ ........... ~.m«*~.
01 CATIOWV
01«U«STANC(«AUC
OaCAINUUKR
04 rroKAaEM»ocAi. MTOOO
OtCONCIMTIUTiaH
OOwSwWTOt.
V. FEEDSTOCKS ,to M~> •. buiMwn,
CATtOOMr O1 FCIOCTOCK HAUi
FDS
ros
FOS
FDS
OaCAINUMW*
CATtacwr
FOS
FDS
FDS
FDS
01FEBKTOCKNAUE
UCASNUUK'
VI. SOURCES OF INFORMATION «*.—»...•..... ..•»•. »^..»!» «^..
C-5
-------
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
L DENTFICATION
II *T«Tt 02 tn
I HAZAWOUS CONDITIONS AND WCDCMTS
01 D * QNOUNOWATEHCCMTAMMATIOM
03 POPULATION POTENTIALLY AFFECTED ,
OZO OBSERVED (DATE
O4 MARRATIVI DESeMPTlQN
DPOTENTIAL
D ALLEGED
01 O I SURFACE WATER CONTAMINATION
03 POPULATION POTENTIALLY AFFECTED _
02 D OBSERVED (DATE
04 NARRATIVE D£SCR*TION
O POTENTIAL
C ALLEGED
01 C C CONTAMMATION OF Af*
03 POPULATION POTENTUU.Y AFFECTED
08 2 OBSERVED (DATE
04 NARRATIVE DESCWPTON
' POTENTIAL
D ALLEOED
01 z o rft.ijo>i.osNf coNomoNS
03 POPULATION POTENTIALLY AFFECTED
OS D OeSERVED (DATE
04 NARRATIVE OESOMTTION
Q POTENTIAL
C: ALLEGED
01 C E 0«CT CONTACT
03 POPULATION POTENTIALLY AFFECTED
OZ 2 06SERVED IDATE
04 NARRATIVE DESCMPTION
CPOTENT1AL
C ALLEGED
01 C F CONTAMNATION OF SOU.
03 AKA POTENTIALLY AFFECTED
0! 3 OBSERVED (DATE
04 NARRATIVE OESCR*TION
D POTENTIAL
C ALLEGED
01 GG DRMKMG WATER CONTAMMATION
03 POPULATION POTENTIALLY AFFECTED _
02 a OBSERVED [DATE
O4 NARRATIVE OESCWTON
QPOTENTIAL
; ALLEGED
01 D H WORKER EXPOSUPC/MJURY
03 WOMKERS POTENTIAUV AFFECTED
02 D OBSERVED (DATE
04 NWWATTVC OESCMPnON
DPOTENTML
D ALLEGED
01 Dl POPULATIONEXPOSURE^NJURY
03 POPULATION POTENTIALLY AFFECTED
02 a OBSERVED (DATE
04 NARRATIVE DCSCRPTON
DPOTCNTML
D ALLEGED
C-6
-------
A __« WENTIAL HAZARDOUS WASTE SITE
£fr rrf\ »TE INSPECTION REPORT
^^ PART 3 -DfSCRIP TON Of HAZARDOUS CONDmONS AND INCIDENTS
I DCNTWCAT10N
01 (TATtlO? »Tl NUMMR
1. HAZARDOUS CONOITIONS AND MCDENTS c— .
01 n J OAUAOE TO FLORA Q2 Q OMEMen (OATF ._ _ | DPI
M NARRATIVE OESCPVDON
01 2 K DAUAOF TO FAUNA OS D OaSBKVED (OATf ._ | DP
M NAMWTNC OCaCRPTION i.i.i i i i i unii
O1 ZT L OO^TAUMATIQM OF PpOO CHAM Of £j OP$myEp (pATf ^___^^, 1 DP
M NAWUTIVE OESCmPTON
01 n " ""^TASl f CO"T *••'?'" O* «»^Tf 5 oj -| cqu»VF p (0»Tf | ro
QI ~ M PAUAQC TO O^FSTTE pno0f PJTY o? n OW^Bytp {DATE __^.^__,_— . .1 HP
M NARRATIVE geSCRTTION
OTENTW. O ALLEGED
OTEMTM1. D ALLEGED
OTENTIAL C ALLESEO
OTENDAL C ALLEGED
OTENTIAL C ALLEGED
Q1 r 0 COWTAUINATlONOf SSWEBS STQHMOHAINS HWtfTP. Q3 r OBSEHUf D inATT __ , ) f- POTEMTU1 C ALLEGED
CM NARRATIVE DESCRIPTION
01 - P 4^f QAi/iMAi.iTMll'l'if P r».,»»~C- 0? H f^Xf^P (O*TF ) n P
CM NARRATIVE OESCPJPTION
0$ K9CPJPTION OF ANY OTHER KNOWS POTENTIAL OR ALLEGED HAZARDS
• TOTAL ROPULATIOPJ POTENTIALLY AFFECTED:
IV. COMMENTS
v mnrrt o* nfttmfiTvm rj. ........... . , .... •», ^^.
C-7
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POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION
PART 4 • PERMIT AND DESCRIPTIVE INFORMATION
IBCNTVICATION
I PERMIT INFORMATION
01 TVH or Knur «iuco
DA.
OS
O1WMTNUMEK
OlMTIMUte MDMUTONOATt NOOMWNT*
DC
DD.
OE
co
OH. LOCAL
Cj NOME
w. SITE OEtcmmoM
D A. SUIVACC MKXMDMCNT
Ol WCS
O C. OMJMS. AWVE QHOUNO
D D TANK. ABOVE MOUNO
O E TANK. KLOW QIIOUNO
Of. LANDFILL
DO LAMDFAMM
DM OKNOUMP
Dl.OT>«B_
D A. MCCNEHAT1ON
D • UNOEHQMUNOMJECTIQN
O C. CHEMiCALWHYSCAL
O 0 MOLOQICAL
D I WASTE ON. mOCESSMG
D F. SOLVENT RECOVERY
O O. OTtCft RECYCLMOfflECOVEflY
DM.OTHEK
OtOTXR
DA.SUUMOSONSITE
IV. CONTAINMENT
01 OON1MMCMT Of WASTES rO»«
O A. ADEQUATE. SECUflE
DS
D C MA0EOUATF.
D D NSECURE. UNSOUND. DANGEROUS
V.ACCCSCWILITY
OIW«mUB.V m
-------
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
HOn I - WATER, DEMOGRAPHIC. AND ENVMONMENTAL DATA
l»ENT»ICATIO»*
OlttATIIMBTINUMKII
II fiATEJO* WT]
L ORJNMM WATIH SUPPLY
COMMUNITY
NON-COMMUNITY
SURFACE
A-D
C.D
WELL
S. D
O.D
A-D
0. D
AFFECTED MOMTOREO
• D C. D
E. O F. D
A..
I.
•. OROUNDWATER
01 MOUMmAim UK M MOMTY IBMI
DA. ONLY toatu HJK ufm*st
o»um*iia
mi ii
OOUMEKCUU. Miuyrmj.
ac
aieEmfraammfmnt*
.............. _ w
at MKCTCTI of amuMWATO nan
------ --
!?.*fl*«"
m
07roTiinui.TKii>
DYES
DNO
COMMENTS
IIMCHAIOEAMA
DYES
DNO
COMMENTS
rv. SURFACE WATER
O A NEKMVOM KCHEATXIN
ONNKH6 MATED SOURCE
D • MVOATION. ECONOMCAUY
MPORTANT RESOURCES
D C. COMMERCIAL. MOUSTRUU.
D 0. NOT CURRENTLY USED
AFFECTED
OBTANCETOSITE
. D
. D
. D
(mi)
V. DEMOGRAPHIC AND PROPERTY INFORMATION
OMEdlMUOFSfTE TWO 12) MLES OF StTE
A. S
•n«EEP)MLESOF»TE
NO OFf«OM~
w aStmoL To Ni «ISST off-an iuUHO
M nyuunoN wnw VCMTV or in *
•AnHiitore-11 rr4i!
C-9
-------
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
PART I - WATER. DEMOGRAPHIC, AND ENVIRONMENTAL DATA
L IHNTHCATION
01 r «Tl OJ VTf NUUK*
VL ENVIRONMENTAL INFORMATION
V Or UMbATuflATED ZONE tCNM* met
OA.10-'- tOrtammc D» iO-4-io-«e
DC. 10-4-10-'OPWMC DO GREATER THAN 10-«e
OA.MPENMEABLE O • W1ATIVELV MWMEASU D C RELATIVELY KMWAKC D 0 Vt*V PEflMEAlU
tmim in" mmtl tit'4 - te~*«»Mti tto'l- tt~'mr»»ti 4ftMMr*«t IO-'MMK;
-IW
-flU
M MCT PHECWTAT10N
07 O*C VCM 24 HOUA RMNFALL
-Wll
D«fCTIONOFBrTt>LOPE| TtRrVUNAVEIUUlEU.OPE
.* I I %
YtAH FLOOO'tAftl
kSTAL MQH HAZAMO A«A. KVCHtC FLOOOWAY
1 MTANCX TO HrlTlANM II tt
BtUARVC
OTrCR
11 OSTANCt TO CWTCAI. H*m*T •«
-*«n
ENDANGERED SPECKS .
1J LAND UK W MOMTY
INSTANCE TO
MCStOCHTIAL AMEAS: NATIONAL/ST ATI PARKS.
FORESTS. OR WILDUFE RESERVES
AOMCULTUML LANDS
AOLANO AOLAND
14 OUCNTTUN or WTf M IKUtTON TO WmOUNDMO TOPOOUMT
VI. KHMCU OF MFOMMTtON .
C-IO
-------
fim-T+m POTENTIAL HAZARDOUS WASTE SITE
*V FRA SITE INSPECTION REPORT
^^^' ** PA»T« -SAMPLE AND FOLD WFOWUATION
L DEMTmCATION
01 iTATtiui Wl rin^Brn
1. SAMPLES TAXIW
•AMPlfTVPE
•PBUWWATEB
SUrVACi WATER
WASTE
AVI
NUNOFT
•FV1
•OH.
veoeTATON
oncn
01 •MMBC*OF
•MVUSTMBI
03 SAMFtCS KMT TO
OlCSTMATtDCUTE
ICSULTS AVALA0L£
M, «LD MEAStNmDfTS TAKIN
01 rm
08 concurs
IV. PHOTOORAPHS AND MAPS
03MAM
OVES
DNO
I
M«N> » PlOnMMVi «^ MMMW
04 LOCATION OF tun
V. OTM£SF(£U;DiT« COU^CTEfli" T. • •-• ..-....•.
C-11
-------
~ __ _ POTENTIAL HAZAF
AtFW MTEINSPEC
m^*"1 ** PAHT7-OWNE
•.CMMCNTOWNCHtSJ
11 NAME
U CMS NUMBER
°"™ifT""~§l""""<"""
MCRV |D» STATE
01 NAME
37 a
MBCOOOE
fax*
UO+INUMBEK
USTPCETAimifSSiPO _ nn>..,
oe cm M STATE
81 MASS
MSB BODE
07 IT CODE
,„
urmcETAgmtss IPO •»)»••*>
osem M STATE
01 NAME
04 se coot
07 » COOt
02 C
OJ»..«tTAuu*£S*,»0 •«•><>. ./
ot cm os STATI
KSNUMBER
04 SC COM
07 Z» CCOt
M.MEVKXJS OWNEWS), !«..««•..
01 NAME
02B-XNUMKR
01 CTIUT AOORtSt f 0 S. »». - .,
OS On OSSTATt
01 NAME
07 Z
04 SC CODE
FCOOE
02 0*§ NUMBER
01SnVITAODMSSl«0 •• .ni.ff,
OS CfTV OS STATE
01 NAME
04 SC CODE
07 If COX
02O*BI«JMSCR
01 ITWTA«MUtffe »..«•».-,
psonr iMtTATt
04 SC CODE
07 » COM
'OQU? WASTE WTF l "»*TIF>C*TK>N
riON REPORT 01 "m <» «TE NUMBER
FMCNT COMPANY «,ii i.
OS NAME
OSD*BNUMKR
lOSTKEETAOORESicOfc, tnt •> i llSCCOOf
12 CTTf 11 STATE
OB NAME
14ZIPCOOE
CWOtBNUUKR
10STHE£TAOORtSSr»o •» wa» «ci 11BCCODE
12CnY 11STATE
14Z»COO€
. „
lOiriKETABOIIESSl'OO vor«c/ IIBCCOOt
12CTT 19STATE
OS NAME
149COOE
01 0»S NUMBER
10 STRHT ADOREUi" o •» •»«».««; nSCCCOt
12 CfTV 11 STATE
14VCODE
IV. NEALTV OWNEMS) .«...•. »—.~-«,
01 NAME
02 0»S NUMBER
alSTHfCTABORESSi'0 •» «»0« »i 04SCCOOE
OS CtTY 08 STATE
01 NAME
07 HP CODE
02 D»B NUMBER
UITKET ADDHUftr^O MM HFD«.«K J 94 Ht |MO£
OSCm 06 STATE
01 NAME
07 OPCODE
02 D*B NUMBER
OlSTKfTAJXXtESSl'O •».«>••*> 04 SC COOt
M cm lOt STATE
OT21PCODE
V. tOUHCtl Or HFQMtATION CT. .».•»•». mm , i i>i «^~i
•TA fOMU 1070.11 (T-* 11
C-12
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POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
PART • • OPf MATOR MTOMMATION
L DENTVICATION
OMMTOK'S LAMENT CMWANV
II ITHf n unfMIIII if.O tm.trof.m i
•. HWVWUI OKMATOM(S) «• ^ — •«. «— » -» • -*~ •— •
PREVIOUS OPBUTWIi' PARENT COMPANIES .«
UCHINUUMK
10N
1 D^iNUMICR
11 trttei HXmftt ire •». vet mi
KfTATt 1IZPCOM
MD^SNUUMEH
11 0** NUMBER
j men UCKU rf .0 «~ nre>. « /
MfTATI ntfOOOt
tttTATt ItZTCOOE
MTIAKOrOflUTION
MIWMCOFOWNCIIDUMMaTMiFEMaO
uacooe
C-13
-------
.__- POTENTIAL HAZAF
£>tn«V WTEINSPEC'
^"•* *» PARTt-atNEKATOIVnU
DOUfS WASTP RITP •• MNTITICATION
riON REPORT 01 "m " 1"1 "UM*"
•.OM-SfTtaCNCMTOII
.,N~
01 «n«T *wmS* IP c «- AM.. « I
MCfTr OSfTATf
orn
O4MCODE
recce
m. OFF«Tf OfNEMTONIS)
01 NAME
02 CH-i NUMttH
ABORtM i*e *w A««. MC.I
osomr lotttAtt
01 MAME
072
04 1C CODE
VOOOE
02 D+i P4UMMR
01 iTRTIT HDCMCII I' Li fci »ln • j |04tCCODE
o* OTV W if ATf
07 2V CODE
rv.TMNS^OirTEIKS)
01 NAME
01 NAME 02D*IMUMIER
03 STRUT ADDRESS f 0 ftM utoi.m I
04 BC CODE
OSCirv MITATE 07VCOOE
01 NAME 02 0-»»NUMBER
03 STWTT ADDRESS 9 0 •*. •«• «t ,
04 SC CODE
oecnv we rr ATI 07 v CODE
02 D*t NUMWM
MOT«CT ADDRESS »0«« uni.tfl
OSOTf OeSIATE
01 NAME
07 Z
02 0
01 STKCIT ADORE1S (» 0 Ml AW>«. « /
OSOTY »»TAT«
04 1C CODE
rcooE
*
04 1C CODE
OT IF COCK
01 NAME 02D*INUMUR
UTmtETADDREISire*. maim:,
04 SIC CODE
04CTTY lOeSTATI 07VCOOE
01 NAME 02 0->» NUMBER
O3 STWFT ADDRESS i>OMi Rn» «c I
04 SC CODE
MCTTV 00STATE 07VCOOE
V.«OWCE*OFMFCMMATION,c«^>~~... —».->..-., ^m,
C-14
-------
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
f ART 10>PAST RESPONSE ACTIVITIES
1 BCMTmCATIOM
91 (TAitiu tm ma
I PAST NBPOMK ACTTVTTM
01 O A WATE* mm.Y OLOKD
OS PATE.
03AOENCY .
01 D • TEftPOKAMY WATBI «jm.Y PNOMDED
02 DATE.
01AOENCY.
01 O C ftHMAKUT WATEfl ium.V MOWED
02DATC.
03AQENCY .
01 D 0 MiED MATBML NWOVEO
01 O t COMTAMNATED Kit. REMOVED
02 DATE.
MAOENCY .
01 O f WASTE MEPACMOEO
02 DATE.
01M3ENCY .
01 C o WASTE oefostD ELKWHEPE
OZMTE.
01 D H OH CTTE KMAL
OiOATE.
01 D I H SPU CtCMCAL •mEATMEKT
04DESCWDON
020ATE.
01 D j n amj PCXDOCAL IMEATMENT
02 DATE.
OlAOENCT .
01 O K M Wnj PHYICAl. THEATMENT
040EKMTTKM
02 DATE.
03AOENCY .
01 D L
02 DATE.
03AOENCY .
01 C M EMEWENCY WASTE TREATMENT
OtOESCMPTCN
02 DATE.
03 AGENCY .
01 Q W CVTOfT WALLS
C2C4TS.
01 O O EMEWENCV OKMOSUHFACE WATER HVEASKJN 02 DATE .
94
03AOENCV .
01 D f CUTOrT TflEMCHEMUMT
OIOATE.
OaAOENCY .
01 D O •UnuHFACC CUTOFF WALL
02 DATE.
03 AGENCY .
C-15
-------
6Ett
•OTEMTIAL HAZA"POM9 WASTf WTE -52IJit'SiTION
SITE INSPECTION REPORT 01 **** " "" "^ *"
1 PAST WSPOMSE ACnvtTKS m i , n
01 D * iAIWER WAULS OONBTBUCTED
040tKNpnoN
01 a * CAmNo/cmBwa
04OEKWTKM
01 D T WAX TAMCAOC NEMMED
WDEKwnoN
01 D U OWOUT CU«T A* CONSTRUCTED
MOESCNPnON
01 a v BOTTOM KAIS
04ocacnrnoN
01 cw OAScomo.
MOCaCWTXM
01 c x Kft cormot
MOUCNPTWN
01 . « UEACHATC nCATWCNT
o*t*x*rnan
01 C Z AKA tVACUATED
04DCSCNFT10N
01 O V ACCESS TO BtTENESTHCTEO
MOCSCWTION
01 C 2 tOKAATVK RELOCATED
MOESCWnON
01 D 3 OTHEB BtMtDIAl ACTMTCS
eODHTf AaAOBfY
o»n»T» „ MAflfMf.v
090»1* UAOEMCV
09MTT M|^lpirv
o»o»t» WAWICV
02MTT DlianfV
OSO*" MiOFNCV
o»n»f» , ,, tyttnnr.v
taoi-rt (Uiamcv
n?n»TT n»»o»icv
mnt-tr ., atumrv
OJ B»1T «1*0»JCV
tt. SOUHCM O^ MFOMAATION >
C-16
-------
SEPA
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
PART 11 • ENFORCEMENT INFORMATION
01 ITATllUBTEttJMEft
I. fMFOftCEMCNT MFOMMATION
«wr ACTION ones DMO
•. MMICfS OF MFOHMATWN am.
AfOW 1070-1*17411
C-17
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POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
General Information
The Potential Hazardous Waste Site, Site Inspection Re-
port form is used to record information collected during, or
associated with, an inspection of the site and other information
about responsible parties and past response activities.
The Site Inspection Report form contains eleven parts:
Part 1 - Site Location and Inspection Information
Part 2 - Waste Information
Part 3 - Description of Hazardous Conditions and Inci-
dents
Part 4 - Permit and Descriptive Information
Part 5 - Water, Demographic, and Environmental Data
Part 6 - Sample and Field Information
Part 7 - Owner Information
Part 8 - Operator Information
Part 9 - Generator/Transporter Information
Part 10 - Past Response Activities
Part 11 - Enforcement Information
Part 1 - Site Location and Inspection Information con-
tains all of the data elements also contained on the Site Identi-
fication and Preliminary Assessment forms required to add a
site to the automated Site Tracking System (STS). It is there-
fore possible to add a site to STS at the Site Inspection stage.
Instructions are given below.
Part 2 - Waste Information and Part 3 - Description of
Hazardous Conditions and Incidents are used to record specific
information about substances, amounts, hazards, and targets,
e.g., population potentially affected. Parts 2 and 3 are also
contained in the Potential Hazardous Waste Site, Preliminary
Assessment form. Information recorded on Part 2 and Part 3
during a preliminary assessment may be updated, added, de-
leted, or corrected on the Site Inspection Report form.
An Appendix with feedstock names and CAS Numbers
and the most frequently cited hazardous substances and CAS
Numbers is located behind the instructions for the Site Inspec-
tion Report.
A number of the data items collected throughout the Site
Inspection Report support the Site Ranking Model. The major-
ity of these data items are found in Part 5 - Water, Demo-
graphic, and Environmental Data.
General Instructions
1. Complete the Site Inspection Report form as com-
pletely as possible.
2. Starred items (*) are required before inspection infor-
mation can be added to STS. The system will not accept
incomplete inspection information.
3. To add a site to STS at the Site Inspection stage,
write "New" across the top of the form and complete items
11-01, 02, 03, 04, and 06, Site Name and Location, II-09 Co-
ordinates, and 11-10, Type of Ownership.
4. Data items carried in STS, which are identical to
those on the Site Identification and Preliminary Assessment
forms and which can be added, deleted, or changed using the
Site Inspection Report form, are indicated with a pound sign
(#). To ensure that the proper action is taken, outline the
item(s) to be added, deleted, or changed with a bright color
end Indicate the proper action with "A" (add), "D" (delete) or
"C" (change).
5. There are two options available for adding, deleting,
or changing information supplied on the Site Inspection Re-
port form. The first is to use a new Site Inspection Report
form, completing only those items to be added, deleted, or
changed. Mark the form clearly, using "A", '"D", or "C", to
indicate the action to be taken. If only data in STS are to be
I Itered, the Site Source Data Report may be used. Using the
report, mark clearly the items to be changed and the action
to be taken.
Detailed Instructions
Part 1 Site Location and Inspection Information
I. Identification: Identification (State and Site Num-
ber) is the site record key, or primary identifier,
for the site. Site records in the STS are updated
based on Identification. It is essential that State
and Site Number are correctly entered on each
form.
*l-01 State: Enter the two character alpha FIPS code for
the state in which the site is located. It must be
identical to State on the Site Identification form.
*l-02 Site Number: Enter the ten character alphanumeric
code for sites which have a Dun and Bradstreet or
EPA "user" Dun end Bradstreet number or the ten
character numeric GSA identification code for fed-
eral sites. The Site Number must be identical to the
Site Number m the Site Identification and Prelimi-
nary Assessment forms.
II. Site Name and Location: If Site Name and Location
information require no additions or changes, these
items are not required on the Site Inspection Report
form. However, completing these items will facili-
tate use of the completed form and records manage-
ment procedures.
#11-01 Site Name: Enter the legal, common, or descriptive
name of the site.
#ll-02 Site Street: Enter the street address and number (if
appropriate) where the site is located. If the precise
street address is unavailable for this site, enter brief
direction identifier, e.g., NW Jet I-295 & US 99,
Post Rd, 5 mi W of Rt. 5.
#ll-03 Site City: Enter the city, town, village, or other
municipality in which the the is located. If the site
is not located in a municipality, enter the name of
the municipality (or place) which is nearest the site
or which most easily locates the site.
#ll-04 Site State: Enter the two character alpha FIPS code
for the state in which the site is located. The code
must be the same as in item 1-01.
#l I-05 Site Zip Code: Enter the five character numeric zip
code for the postal zone in which the site is located.
C-18
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-%nlbndnwdt
DTE INSPECTION REPORT
•MI-06 Site County: Enter tht name of th* county, parish
(Louisiana), or po/ough (Alaska) in which tht tit*
it located.
«HI-07 County Codt: Entir th* thnt* character numeric
FIPS county cod* for tht county, parish, or bor-
ough in which the tit* it located. (The regional On*
analyst c*n fumith thit data item.}
«rl1-08 Site Congressional District: Enter in* two character
numbtr for tn* congressional district in which th*
lit* it tooted.
**ll-00 Coordinates: Enter th* Coordinetet, Latitude end
Longitude, of the site in degrees, minutes, secondt,
and ttntht of seconds. If attnthof a second * «*ig-
nifieentatthis tit*, enter "0" in th* tentht position.
4XI-10 Type of Ownership: Check th* appropriate box to
indictt* th* type of sit* ownership. If the the it
under the jurisdiction of en tctivity of the federal
government, enter the nem* of the dcpertment,
•gency, or ectivity. If Other it indicated, specify the
type of ownership end nem*.
HI. Inspection Information
'111-01 Oete of Inspection: Enter the date the inspection
occurred, or began for multiple day inspections.
* 111-02 She Status: Check the appropriate box(et) to indi-
cate the current status of the site. Active sites are
thoot which treat, (tor*, or dispose of wattes. Check
Active for those active sites with an inactive nor-
age or disposal art*. Inactive sites art those at which
treatment, storage, or disposal activities no longer
occur.
•111-03 Years of Operation: Enter th* beginning end ending
yean (or beginning only if operations at the site are
on-going), e.g.. 187671932, of site operation. Check
Unknown if years of operation are not known.
*l11-04 Agency Performing Inspection: Check the appro-
priate box(es) to indicate parties participating in the
inspection. If contractors participate, provide the
nameof thefirm(s).
111-05 Chief Inspector: Enter the name of the chief, or
lead inspector.
111-06 Title: Enter the Chief Inspector's title, e .g.. Team
Leader. FIT team.
111-07 Organization: Enter the name of the organization
where the Chief Inspector is employed, e.g.. EPA -
Region 4, VA State Hearth Dept., Environmental
Research Co.
111-06 Telephone Number: Enter th* Chief Inspector-sere*
cade and local commercial telephone number.
111-09 Other Inspectors: Enter the names of other parties
participating in the inspection.
111-10 Title: Enter the titles of other parties participating
ti the inspection.
MM 1 Organisation: Enter the names of the organizations
where other parties participating hi the inspection
•re employed.
111-12 Telephone Number: Enttr the area code end local
commercial telephone numbers of other parties par-
ticipating hi the Inspection.
111-13 Site Representetives Interviewed: Enter tht names
of individuals representing responsible parties inter-
vitwtd in connection with the inspection. Inter-
views do not necessarily occur during the inspec
tion.
111-14 Title: Enter the titles of the individuals interviewed.
ID-IS Address: Enter the business, mailing, or residential
addresses of the individuals interviewed.
111-16 Telephone Number: Enter the a re* code end local
commercial telephone numbers of the individuals
interviewed.
111-17 Access Gained By: Check the appropriate box to
indicate whether access to the site was gained
through permission or warrant.
III-IB Time of Inspection: Using e 24-hour clock, enter
the time the inspection btgan, *. g., for 3:24 p.m.
enter 1S24.
111-19 Weather Conditions: Describe th* weather condi-
tions during the site inspection, especially any un-
usual conditions which might affect results or obser-
vations taken.
IV. Information Available From
IV-01 Contact: Enter the name of the individual who can
provide information about the site.
IV-02 Of: If appropriate, enter the name of the public or
private agency, firm, or company and the organize-
tion within the agency, firm, or compsny of tht
individual named as Contact.
IV-03 Telephone Number: Enter the area code end local
telephone number of the individual named as con-
tact.
IV-04 Person Responsible for Site Inspection Report
Form: Enter the name of the individual who was
responsible for the information entered on the Site
Inspection Report form. Tht person responsible for
the Site Inspection Report form may be different
from the individual who prepared the form.
IVO5 Agency: Enter the name of the Agency where the
individual who is responsible for the Site Inspection
Report form • employed.
IV-06 Organization: Enter tht name of the organization
within the Agency.
IV-07 Telephone Number: Enter the area code end local
telephone number of the individual who is respon-
sible for the Site Inspection Report form.
IV-08 Date: Enter the date the Site Inspection Report
•of MI was prepared.
Pan 2 Watte Information
•I. Identification: Refer to Part 1-1.
II. Watte States, Quantities, and Chanckrinia: Watte
States, Quantities, end Characteristics provide infor-
mation about the-physical structure •"<* 1°m of the
waste, measures of gross amounts at the site, and
the hazards posed by the waste, considering ecutt
and chronic health effects and mobility along *
-------
Nrt 2 (continued)
SITE INSPECTION REPORT
Physical Sum: Cheek the appropriate box (as) to
Indicitt tht stated) of waste present at the »'te. if
Other is indicated, specify the physical lUt* of the
•11-01
'11-02 Watts Quantity tt Sitt: Enttr estimates of amounts
of waste at the sitt. Estimates may bt in weight
(Tom) or volume (Cubic Yards or Numbar of
Drums). Us* • ">•"¥ entries as art appropriate;
however. mMsunmtnts must bt independent. For
example, do not mamirs tht samt amounts Of
watte as both tons and cubic V*rds.
'11-03 Waits Charactaristici: Cheek all appropriate tntrits
to indicstc tht hazards POttd by wastt at tht r < If
wasta at tht sitt posas no hazard, chack Not *,4>li-
cable.
Ml. Want Category: Gtntral ctttgorias of wastt typi-
cally found art listed hart. Enter the estimated gross
amount of e ach category of wastt and the appropri-
ate unit of measure.
'111-01 Gross Amount: Gross Amount is the estimate of the
a mount of tht wastt cattgory found at the site.
Estimates should bt furnished in metric tons (MT),
tons (TN). cubic mtttrs (CM), cubic yards (CY),
drums (OR), acres (AC), acre feet (AF), liters (LT).
or gallons (GA). Enter the estimated amount next
to the appropriate wane category-
* 111-02 Unit of Measure: Enter the appropriate unit of
measure. MT (metric tons). TN (tons). CM (cubic
meters). CY (cubic vereh), DR (number of drums),
AC (acres). AF (acre feet), LT (liters), or GA (gal-
lons) next to the estimate of gross amount.
111-03 Comments: Comments '"•V be used to further ex-
plain, or provide additional information, about par-
ticular waste categories.
IV. Hazardous Substances: Specific hazardous, or
pottntially hazardous, chemicals, mixtures, and sub-
stances found at the site are listed hare. For each
substance listed those date items marked with an
"at" sign (& must bt included.
• IV-01 Category: Enter in front of the substance name the
three cheracter wastt category from Section III
which best describe the substance, e.g., OLW (Oily
Wasta).
•IV-02 Substance Name: Enter one of the following: the
name of the substance registered with tht Chemical
Abstract Service, the common or accepted abbrevia-
tion of the substance, the generic name of the sub-
stance, or commercial name of the substance.
•IV-03 CAS Number: Enttr the number assigned to the
substance when it was registered with the Chemical
Abstract Service. Refer to the Appendix for most
frequently cited CAS Numbers. CAS Numbers must
be furnished for each substance listed. If a CAS
Number for this substance has not bean assigned,
enter "999".
•IV-04 Storage/Dispose! Method: Enttr the type of storage
or disposal facility in which the substance was
found: SI (surface impoundment, including pits.
ponds, and lagoons). PL (pile). DR (drum). TK
(tank), LF (landfill), LM (Itndfarm). OD (open
dump).
IVO5 Concentration: Enter the concentration of the tut>'
stance found in samples taken at the sitt.
IV-06 Mtasure of Concentration: Enter the appropriate
unit of measure for the measured concentration of
the substance found in the sample, e.g., MG/L,
UG/L.
V.
V-01 Feedstock Name: If feedstocks, or substances de-
rived from one or more feedstocks, a re present »t
the site, enter the name of each feedstock found.
See the Appendix for the feedstock '"**•
V-02 CAS Number: Enter the CAS Number for each feed-
stock named. Set the Appendix for feedstock CAS
Numbers.
VI. Sources of Information: List the sources used to
obtain information for this form. Sources cited may
include: sample analysis, reports, inspections, off I-
cial records, or other documentation. Sources cited
provide the basis for information entered on the
form and may be used to obtain further information
about the site.
Pan 3 Description of Hazardous Conditions and Incidents
• I. Identification: Refer to p«rt 1-1-
II. Hazardous Conditions end Incidents:
11-01 Hazards: Indicate each hazardous, or potentiill y
hazardous, condition known, or claimed, to exist at
the site.
11-02 Observed, Potential, or Alleged: Check Observed
and" enter the date, or approximate date, of occur-
rence if a release of contaminants to the environ-
ment, or some other hazardous incident, is known
to have occurred. In cases of a continuing releaM,
• .g., groundwater contamination, enter the date, or
approximate date, the condition first became a p
parent. If conditions exist for a potential rele«e.
check potential. Check Alleged for hazardous, or
potentially hazardous, conditions claimed to e x ist a 1
the site.
11-03 Population Potentially Affected: For each hu-
ardous condition at the site, enter the number Of
people potentially a ffected. For Soil enter the num-
ber of acres potentially affected.
11-04 Narrative Description: Provide e narrative descrip-
tion, or explanation, of each condition. Include any
additional information which further explains the
condition.
11-05 Description of Any Other Known, Potential, or
Alleged Hazards: Provide e narrative description of
•ny other hazardous, or potentially hazardous, con-
ditions at the site not covered above.
III. Total Population 'otenMly Affected: Enter the
total number of people potentially affected by the
existence of hazardous, or potentially hazardous.
conditions at the site. Do not sum the numbers
shown for each condition.
IV. Comments: Other information relevant to observed.
potential, or alleged hazards may be entered here.
L-20
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Pert 3 (continued)
SITE INSPECTION REPORT
V. Sources of InfoimMion: Lin the sources uaed to
obtain information for this form. Sources eittd "My
Includl: sample «n«lyiii, nportt, impictions, offi-
cial records, or other documentation. SouroM cited
provide the bail for information entered on the
form end may be uaed to obtain further information
about the tite.
rVft 4 ffMifin tfifl DMcnptivo I HrOffeWvovi
• I. Identification: Refer to Part 1-1.
II. Permit Information
11-01 Type of Permit lamed: Cheek the appropriate
box(ei) to indicate the type* of permits issued to
the lite. If nate, local, or other types of environ-
mental permits have been issued, specify the type.
11-02 Permit Number: Enter the permit number for each
issued permit.
11-03 Dete Issued: Enter the date each permit was issued.
11 -04 Expiration Date: Enter the date a ach permit expires
or expired.
11-05 Comments: Enter any in formation which further
explains the types of permits issued or status of the
permits.
III. Site Description
* 111-01 Storage/Disposal: Check the appropriate box
-------
Pert S (aantinued)
SITE INSPECTION REPORT
111-03 Distance to Neerest Drinking Water Wtll: Enter the
distance in mite to tht neerest tenth, hundredth, or
thousandth (at needed to indicttt tht precision re-
quired) from tht *itt to tht nwren drinking wtttr
111-04
111-06
111-06
111-07
111-08
111-09
111-10
111-11
Otpth to Groundwater: Enw tht dtpth in feat to
groundwtttr.
Otpth of Groundwater Flow: Enttr tht ordinal
direction of groundwtttr flow, 1 4.. NNW.
Otpth to Aquiftr of Conctm:
*Mt to the tqurftr of eonctm.
IV.
Enttr tht dtpth In
Potential **u of Aquiftr: Enttr tht potential
yitU of tht aquifer in gtllom ptr dty.
Sol* Sourct Aquiftr: Chtck tht appropriate box to
indictt* tht tquiftr of concern it. or is not t sole
(ourct tquiftr.
Dttcription of Wells: Provide t narrative description
of wtllt in tht vicinity of tht lift, including utttge,
dtpth, and location relttivt to populttion and build-
ings.
Recharge ATM: Chtck tht tpproprittt box to indi-
cate tht site fc located in t rachtrgc trtt. Comments
providt tdditiontl informttion on tht rtchtrgt t ret.
Oftehtrgt Artt: Chtck tht tpproprittt box to indi-
cate tht (itt • locate) In t dischtrgt •"•»• Com-
mtntt providt tdditiontl Informttion on tht dis-
charge area.
Sudan Water
IV-01
Surface Water Use. Check the appropriate box to
indicate «.-f*c* water use in tht vicinity of the site.
Tht order of precedence is Reservoir, Recreation,
Drinking Water Sourct; Irrigation. Economically
Important Reserves; Commercial/Industrial; Not
Currently Used.
IV-02 Affected/Potentially Affected Bodies of Water:
Enttr the names of bodies of surface water affected,
or potentially • ffectad. by eontam inants from the
the. Lift the body of surface water nearest the she
first. For each body of water check Affected if con-
taminants have been identified in samples of the
wtttr. Enter the shortest distance from tht body of
water to the she in miles to tht nearest tenth, hun-
dredth, or thousandth (as needed to indicate tht
precision required).
V.
V-01
Demographic end Property Information
Total Population Within: Enter tht total population
within one (1) mile, two (2) milts, and three (3)
milts of tht litt. Distances are measured from site
boundaries. Population for tht purpoaas of tht Site
Inspection Report includes residents and daytime
workers and students but excludes transients in the
neighborhood or on local highways end roads. Whan
ejtimeting populttion from ttritl Photographs or
ether sources, the conversion facie* Is 3£ parsons
for each dwelling unit or 3 persons ptr acre in rural
V-02
Distance to Nearest Population: E Her in milts to
tht nearest tenth, hundredth, or thousandth (as
needed to indicate the precision required) tht dis-
tance from tht she boundary to the nearest popula
tion (one person minimum).
V-03 Number of Buildings Within Two (2) Miles of Site
Enttr tht number of buildings within two miles
from tht boundaries of the *'««
V-04 Distance to Nearest Off-Site Building: Enter the dis-
tance in milts to the nearest tenth, hundredth, or
thousandth (as needed to indicate the precision
required) from the tht boundary to the neerest
Off-tilt building.
V-OS Population in Vicinity of Site: Provide a narrative
description of tht nature of the population within
the vicinity of the site. Exemplts include rur»l
•rat, small truck farms, urban industrial ere*, densely
populated urban residential area.
VI. Environmental Information
VI-01 Permeability of Unsaturated Zone: Check the a P-
propriatt box to Indicate the permeability of the
earth material above the water table in the vicinity
of the she.
VI-02 Permeability of Bedrock: Chtck the eppropriate
box to indicate tht permeability of th« bedrock ,n
the vicinity of the she.
VI-03 Dtpth to Bedrock: Enter the dtpth to bedrock in
feet.
VI-04 Dtpth of Contaminated Soil Zone: Enttr tht dtpth
of tht contaminttad toil zone in ftet.
VI-05 Soil pH: Enttr the pH of the soil in the vicinity of
tht site.
VI-06 Net Precipitation: Enter net precipitation in inches.
If net precipitation is not known, subtract the aver-
age evaporation figure on the (JS. National Weather
Service map showing average annual evaporation in
inches from the (JS. Environmental Date Service
map showing mean annual precipitation.
VI-07 One Yttr 24 Hour Rainfall: Enter in inches the fig
ure for one year 24 hour rainfall.
VI-08 Slope: Enter the ptreaniaue of site slope, the direc-
tion of site slope, and the percentage of the sur-
rounding terrain average slope.
VI-09 Flood Potential: Enttr the boundary year for the
ftoodplein in which tht sitt is located. Sites flooded
annually are in a 1 (one) year floodplain. Other ex -
ample* include 10,20,50.100,500, e tc., indicating
the probability of flooding within that time period.
VI-10 Site is on Barrier Island, Coastal High Hazard Area.
Riverine Floodway: If site is located i" one of these
•rets, check this box.
VI-11 Distance to Wetlands: If applicable, enter the dis
tence in milts to the neerest tenth, hundredth. or
thousandth (as needed to indicate the precision re-
quired) from tht site to the doaest wetlands (five
ten minimum) for Estuerine end Other types of
wetlands.
VI 12 Distance to Critical Habitat: If applicable, enter tr:
distance in miles to the nearest tenth, hundredth, or
thousandth (as needed to indicate the precision re-
quired) from the she to the neerest critical habitat
C-22
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Part 6 IcontimMd)
SITE INSPECTION REPORT
of w endangered species. Enter the namelslofthe
endangered species.
VI-13 Land U«t in Vicinity: Enter the distance in miles to
the nearest tenth, hundredth. or thousandth (as
needed to indicate the precision required) to the
nearest Commercial/Industrial area; Residential
Am. National/State Parks, forms, or Wildlife Re-
terves; or Agriculture! Lands, Prim* Ag Land and Ag
Land. Prim* Ag Land is that crop, pasture, range, or
forest land which produoM the highest vitW in rela-
tion to inputt. Ag Land isthe remaining agriculture!
land, frequently comidered marginal.
VI-14 Description of Site in Relation to Surrounding
Topography: Provide a narrative description of sig-
nificant or unusual aspects of the surrounding top-
ography in relation to the site. Examples might in-
clude: site is in a valley surrounded on a M sides by
mountains, site is at edge of a river or stream which
floods frequently, etc.
VII. Sourees of Information: List the sources used to ob-
tain information for this form. Sources cited may
include: sample analysis, reports, inspections, offi-
cial records, or other documentation. Sources cited
provide the basis for information entered on the
form and '"•V be used to obtain further information
about the site.
Part 6 (ample and Field Information
•I. Identification: Refer to Part 1-1.
II. Samples Taken
11-01 Number of Sample Taken: Next to each sample
type enter the number of samples of that type
taken.
11-02 Samples Sent To: Enter the name of the laboratory
or other facility where the samples were sent for
analysis.
11-03 Estimated Date Results Available: Enter the esti-
mated date the results a re expected to be available.
III. Field Measurements Taken
111-01 Type: Enter the type, e .g., radioactivity, explosivitv.
organic vapor or gas detection and analysis, reagsnt
type gas detection. Of each field measurement taken.
111-02 Comments: Describe results of field measurements.
whether they were taken on or off site, and if appli-
cable, the type of disposal facility tatted, e .g.. drum.
surface impoundment, landfill.
IV. Photograph* and Map*
IV-01 Type: If photographs of the site have bean taken.
check the appropriate box(es) to indicate the type.
IV4)2 In Custody Of: Enter the name of th« organisation
or parson who has custody of the photographs.
IV-03 Maps: Check the appropriate box to indicate that
maps of the site area have been prepared or ob-
tained.
IV-04 Location of Maps: If site maps are available. Indi-
cate their location, a 4., Region 1 Air and Hazardous
Material* Division.
V. Other FMd Data Collected: Provide e narrative de-
scription of any other field data collected.
VI. Source* of Information: List the sources used to ob-
tain information for this form. Sources cited may
include: sample analysis, reports, inspections, ofii
cial records, or other documentation. Sources cited
provide the basis for information entered on the
form and may be used to obtain further information
about the site.
Part 7 Owner InfofWMlion
•I. Mentificetion: Refer to Part 1-1.
II. Current Owner(s) - Parent Company: Current
owner(s) a nd parent companies, for those owners
which are companies partly or wholly owned by «n
other company, provide locator information about
responsible parties. E*ch Part 7 provides space for
four (4) current owners and their respective parent
companies. If additional space is required, complete
another Part 7.
11-01 Name: Enter the legal name of the owner of the
site. The owner may be a firm, government agency,
association, individual, etc.
11-02 D&B Number: Where available, enter the owner's
D&B (Dun a nd Bradstreet) number. If the current
owner is a federal agency, enter the GSA identifier
tion code.
11-03 Street Address: Enter the business, mailing, or resi-
dential street address of the owner.
11-04 SIC Code: If a pplicable, enter the owner's primary
SIC Code.
11-05 City: Enter the city of the owner's business, mail-
ing, or residential address.
11-06 State: Enter the two character alpha F IPS code for
the state of the owner's business, mailing, or resi-
dential address.
11-07 Zip Code: Enter the five digit zip code for the
owner's business, mailing, or residential address.
11-08 Name: If the owner is a Pw^V or wholly owned
subsidiary of another company, enter the legal
name of the owner's parent company,
11-09 D&B Number: Enter the parent company's Dun and
Bradstreet number.
11-10 Street Address: Enter the business or mailing street
address of the parent company.
11-11 SIC Code: If applicable, enter the parent compeny's
primary SIC code. '
11-12 City: Enter the city of the parent company's busi-
ness or mailing address.
H-13 State: Enter the two character alpha F IPS code for
the state of the parent company's business or mail-
ing address.
11-14 Zip Code: Enter the five digit zip code for the
parent company's business or mailing address
III. Previous Ownerb): List previous owners in reverse
chronological order, i.e., most recent first. If addi-
tional space is required, complete another Part 7.
111-01 Name: Enter the legal name of the previous owner.
The previous owner may have been a firm, govern-
ment agency, association, individual, etc.
C-23
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Part 7 (continued)
SITE INSPECTION REPORT
111-02 D&B Number: Enter the previous owner's Dun e nd
Bradstreet number if available. If the previous
owner was a federal agency, enter the GSA identi-
fication code if available.
111-03 Street Address: Enter the business, mailing, or resi-
dential street address of the previous owner.
111-04 SIC Code: If a ppltceble. enter the primary SIC Code
Of the previous owner.
Ill-OS City: Enter the citV of the previous owner's busi-
ness, mailing, or residential address.
111-06 State: Enter the two character e Ipha FIPS code for
the state of the previous owner's business, mailing,
or residential address.
111-07 Zip Code: Enter the zip code of the previous
owner's business, mailing, or residential address.
IV. Realty Owner(s): Realty owner applies when the
owner leased to a nother entity property which was
used for the storage or disposal of hazardous waste.
List current or most recent first.
IV-01 Name: Enter the legal name of the realty owner.
The realty owner m«V be a firm, government agen-
cy, association, individual, etc.
IV-02 D&B Number: Enter the previous owner's Dun a nd
Bradstreet number if available. If the previous
owner was a federal agency, enter the GSA identifi-
cation code if available.
IV-03 Street Address: Enter the rMltY owner's business,
mailing, or residential street address.
IV-04 SIC Code: If applicable, enter the realty owner's
primary SIC Code.
IV-05 City: Enter the city of the realty owner's business,
mailing, or residential address.
IV-06 State: Enter the two character a Ipha F IPS code for
the state of the realty owner's business, mailing, or
residential address.
IV-07 Zip Code: Enter the zip code of the r**rty owner's
business, mailing, or residential address.
V. Sources of Information: List the sources used to
obtain information for this form. Sources chad
may include: sample a nalysis, reports, inspections,
official records, or other documentation. Sources
cited provide the basis for information entered on
the form and may be used to obtain further infor-
mation about the site.
**rt 8 Opeiator Information
M. MemHfcetion: Refer to Part 1-1.
II. Currant Operator-Operator's Parent Company In-
formation on operators is applicable when the
operator is not the owner.
11-01 Name: Enter the legal name of the operator. The
operator may be a firm, government agency, associa-
tion, individual, etc.
11-02 D&B Number: Enter the operator's Dun *nd Brad-
street number if available. If the operator n t f«d-
era! agency, enter the GSA identification code if
available.
11-03 Street Address: Enter the operator's business, mail-
ing, c residential street address.
11-04 SIC Code: If applicable, enter the operator's pn-
mary SIC Code.
11-05 City: Enter the city of the operator's business, mail-
ing. or residential address.
11-06 State: Enter the two character alpha F IPS code for
the state of the operator's business, mailing, or resi-
dential address
11-07 Zip Code: Enter the zip code of the operator's busi-
ness, mailing, or residential address.
11-08 Years of Operation: Enter the beginning and e nd i ng
years (or beginning only if operations a re on-going),
e 4., 1932/1948, of operation at the site.
11-09 Name of Owner: Enter the name of the owner for
the period cited for this operator.
11-10 Name: If applicable, enter the legal name of the
operator's parent company.
11-11 D&B Number: Enter the operator's parent company
Dun and Bradstreet number if available.
11-12 Street Address: Enter the operator's parent com-
pany business, mailing, or residential street address.
11-13 SIC Code: If applicable, enter the operator's parent
company primary SIC Code.
11-14 City: Enter the city of the operator's parent com-
pany business, mailing, or residential address.
11-15 State: Enter the two character a Ipha F IPS code for
the state of the operator's parent company business,
mailing, or residential address.
11-16 Zip Code: Enter the zip code of the operator's
parent company business, mailing, or residential
address.
III. Previous Operatord(-Previous Operators' Parent
Companies
111-01 Name: Enter the legal name of the previous opera
tor. The previous operator may be a firm, govern-
ment agency, association, individual, etc.
111-02 D&B Number: Enter the previous operator's Dun
and Bradstreet number if available. It the previous
operator was a federal agency, «nter the GSA Kjen.
tif ication code if available.
111-03 Street Address: Enter the previous operator's busi-
ness, mailing, or residential street address
111-04 SIC Code: If applicable, enter the previous open
tor's primary SIC Code.
Ill-OS City: Enter the city of the previous operator's busi-
ness, mailing, or residential address.
111-06 State: Enter the two character alpha FIPS code for
the state of the previous operator's business, mail-
Ing, or residential address.
111-07 Zip Code: Enter the zip code of the previous opere
tor's business, mailing, or residential address.
HI-OB Years of Operation: Enter the beginning and ending
years of operation for this operator at the site
111-09 Name of Owner: Enter the name of the owner for
the period cited for this operator.
C-24
-------
Part • (continued)
SITE MSPEI TION REPORT
111-10 Name: If applicable. enter the legal name of the
previous operator's parent company.
111-11 D&B Number: Enter the previous operator's perent
eompeny Dun a nd Bradstreet number If •reliable.
Street Addres: Enter the previous operator'! perent
company business, mailing, or residential (tract
111-12
111-13 SIC Code: If applicable, enter the previous opera-
tor's parent company primary SIC Code.
111-14 City: Enter the chy of the previous operator's
parent company business, mailing, or residential
address.
111-15 State: Enter the two character alpha FIPS code for
the state of the previous operator's parent company
business, mailing, or residential address.
111-16 Zip Code: Enter the zip code of the previous opera-
tor's parent company business, mailing, or residen-
tial address.
IV. Sources of Information: List the sources used to ob-
tain information for this form. Sources cited may
include: sample analysis, reports, inspections, offi-
cial records, or other documentat ion. Sources cited
provide the basis for information entered on the
form a nd may be used to obtain further information
about the she.
Part 9 Generator/Transporter I nformation
•I. Identification: Refer to Part 1-1.
II. On-Srte Generator: A company or agency, located
within the contiguous area of the site and generating
waste disposed on the site, is e ntered here.
11-01 Name: If there is an on-site generator, enter the
legal name of the on-site generator. The on-site gen-
erator may be a firm or government agency.
11-02 D&B Number: Where available, enter the on-site
generator's D&B (Dun and Bradstreet) number. If
the on site generator is a federal agency, enter the
GSA identification code.
11-03 Street Address: Enter the business or mailing street
address ol the on-site generator.
11-04 SIC Code: If applicable, enter the on-she generator's
primary SIC Code.
11-05 Chy: Enter the chy of the on-she generator's busi-
ness or mailing address.
11-06 State: Enter the two character alpha FIPS code for
the state of the on-the generator's business or mail-.
Ing address.
11-07 Zip Code: Enter the five digit zip code for the on-
site generator's business or mailing address.
III. Off-Site Generator(s):Those companies or agencies
off-she who have generated waste which has been
disposed at the site a re listed here.
111-01 Name: Enter the legal name of the off-she genera-
tor. The off-she generator may be a firm or govern
fnant agency.
111-02 D&B Number: Where available, enter the off-she
generator's D&B (Dun and Bradstreet) number. If
th* off-she generator is a federal agency, enter the
GSA identification code.
111-03 Street Address: Enter the business or mailing street
address of the off-she generator.
111-04 SIC Code: If applicable, enter the off-site genera
tor's primary SIC Code.
Ill-OS City: Enter th* crty of the off-she generator's busi-
ness or mailing address.
111-06 State: Enter the two character elpha FIPS code for
the state of the off-she generator's business or mail-
ing address.
111-07 Zip Code: Enter the five digit zip code for the off-
site generator's business or mailing address.
IV. Transporter(s): Those carriers who are known to
have transported weste to the site are listed here.
IV-01 Name: Enter the legal name of the transporter. The
transporter may be a firm, government agency, asso-
ciation, individual, etc.
IV-02 D&B Number: Where available, enter the trans
porter's D&B (Dun and Bradstreetl number. If the
transporter is a federal agency, enter the GSA iden-
tification code.
IV-03 Street Address: Enter the business, mailing, or resi-
dential street address of the transporter.
IV-04 SIC Code: If applicable, enter the transporter's pri-
mary SIC Code.
IV-06 City: Enter the city of the transporter's business,
mailing, or residential address.
IV-06 State: Enter the two character alpha FIPS code for
the state of the transporter's business, mailing, or
residential address.
IV-07 Zip Code: Enter the five digit zip code for the trans-
porter's business, mailing, or residential address.
V. Sources of Information: List the sources used to ob-
tain information for this form. Sources cited miy
include: sample analysis, reports, inspections,
official records, or other documentation. Sources
cited provide the basis for information entered on
the form and may be used to obtain further infor-
mation about the she.
Part 10 Past Response Activities
• I. Identification: Refer to Part 1 -1.
II. Net Response Activities
11-01 Past Response Activities: Check the eppropriite
box(es) to indicate response activities initiated
prior to the passage of CERCLA, December, 1980.
11-02 Date: Enter the start date (or approximate date) of
the activity.
11-03 Agency: Enter the name of the Agency responsible
for the activity.
11-04 Description: Provide a brief narrative description of
the activity,
III. Souroas of Inhumation: Lift the sources used to ob-
tain information for this form. Sources cited may
include: sample analysis, reports, inspections, offi-
cial records, or other documentation. Sources cited
provide the basis for information entered on the
form and may be used to obtain further information
about the she.
C-25
-------
SITE WSPECTION REPORT
*!•
11-01
11-02
11 EnfotwiMfit I
Mentification: Rtftr «° Pert 1-1.
Past ReQulatory/E nfbrcement Action: Check tht ap-
propriate box to indicate past regulatory or *n-
fotc«rn«nt Ktion «1 tht tetertl. tutt. or local tevtl
ntrttd to thii she.
Description of Federal. State. Local Regulatory or
Enforcement Action: Provide a narrative description
of regulatory or enforcement action to date. Do not
Include any enforcement action contemplated in
the process of development.
III. Souren of Information: Lilt the sources used to ob-
tain information for this form. Sources cited may
Include: ample analysis, report*, inspections, offi-
cial records, or other documentation. Sources c ited
provide the basis for information entered on the
form and may be used to obtain further informa-
tion about the site.
C-26
-------
APPENDIX
1. FEEDSTOCKS
GA9 Mamoar
1.796441-7
2.7440-364
.130944-4
.744049-2
.1337434
.31109494
.7729464 •
.106494
.7440434
10. 7792404
11.12737-274
12. 7440-474
13.7440494
CfcaMeaal Nana
Ammonia
Antimony
Antimony Trioxidl
Ananie
Anenie Trtoxlde
•orium Bulfida
•fomina
•utadiane
Cadmium
CMorina
Cnromrta
Chromium
Cobalt
CAtttamtar
14. 1317484
16. 7768-98-7
19. 131749-1
17. 7446-1
19. 7947414
19.7964-394
30. 1336-26-7
31. 7439474
22.74424
33. 91-30-3
34.7440434
36. 768747-2
36. 7723-144
ChamMMam.
Cupric Oxidl
Cuprfc 6urrate
CuproutOiidl
Ethylana
Hydrochloric Acid
Hydroaan Fluoride
LaadOik*
Mareury
Mathane
Mapihalnia
Nfcfcat
Nitric Ac id
CASMuneMr
37.7779404
39. 131049-3
39 11647-1
30. 10688414
31.1310-73-2
32.7646-784
33. 7772494
34.7964434
36. 10948-3
36. 1330-20-7
37.764645-7
38.7733424
PfcoaphonM
GhamiMl MMfM
fotauium Dtehromatc
•otawum Hydroxide
•wpylana
Sodium Diehromate
Sodium Hydroxide
Stannic Chloride
Stannoui Chloride
SuHuric Acid
Toluene
Xylana
Zinc Chloridi
Zinc Suifata
II. HAZARDOUS SUBSTANCES
1.76474
2. 94-19-7
3. 108-34-7
4.76464
6.60646-7
8.76-36-5
7. 107424
8. 107-13-1
9.124444
10.30940-2
11.1004341-3
13. 107-194
13. 10746-1
14. 796441-7
16.631414
16.1963434
17. 1066-33-7
19. 7799494
19. 134149-7
20. 101 92-304
21.1111-794
22. 12125424
23. 7768484
24.30)2454
26 13826434
36. 13125414
27. 1336-214
38. 6009-70-7
29. 19919-194
30.7773464
31. 13136-76-1
33. 101 96444
33. 14307434
34.1793464
36.7793-194
36.63643-7
37. 6243-3
38. 7647-164
38.7799414
40. 10025414
41.7783464
42. 1309444
43. 1303-324
44. 1303-38-2
46.7794-34-1
49. 133743-3
HHn««i IWIIV
Aojtaldahydi
AcaticAcid
Aottic Anhydride
Acatona Cyanehydrin
Acatyl Bromidt
Acatyl CMore*
Acrolain
Acrylonitrila
AdipicAcid
Aldrin
Aluminum Sulfate
AIM Alcohol
Ally! Chloridi
Ammonia
Ammonium Aeatata
Ammonium 9anioata
Ammonium Bicarbonata
Ammonium 6ichromata
Ammonium Bifluorida
Ammonium Biturlite
Ammonium Cartamna
Ammonium Chloridi
Ammonium Chromate
Ammonium Citrate, Dibat H
Ammonium Fluoborate
Ammonium Fluoride
Ammonium Hydroxide
Ammonium Oulate
Ammonium Sileoftuoridt
Ammonium SuHamate
Ammonium lurlide
Ammonium luHrte
Ammonium Tartmta
fuwnontum Thiocyahata
Ammonium Thioaurlata
AmylAeiajta
Aniline
Aflufnofty Tf iproffiidB)
Antimony Trichloride
Antimony Trrlluorlde
Antimony Tno*tidB)
Anenlc DteuHide
Ananie rVnntte
Anemic Trichloride
Ananie TrimMa
•a*e7«e» (••llleMi
47. 1303-334
46. 64242-1
49. 7143-2
60.95464
61 . 100474
62. 9948-4
83.100-44-7
64. 7440-41-7
65. 7717474
66. 778749-7
67. 13597494
88.123464
68. 84-74-2
90. 109-734
91. 107424
62.643404
63. 7789424
94. 1010844-2
66. 777644-1
66. 62740-164
67. 76-20-7
99. 13765-194
99. 692414
70. 2636446-2
71.7779444
73.13346-2
73. 93-25-2
74.166346-2
76.76-164
79.66-234
77.67-744
79.7793404
79. 108-90-7
90. 6746-3
81.7790444
83. 392148-2
94.7738444
96. 10101434
96.10049464
97. 944-19-3
99.14017414
99.66-724
90.1319-77-3
•k* 4«Wl_*BA*
ww*naa**i ••e>»ia»>
Ananie Triaulf ioi
9arium Cyanide
Bantam
BanmfcAckJ
Benionitrile
Banioyl Chloridi
Bantyl Chlorida
Ban/Ilium
Ban/Ilium Chloridi
Beryllium Fluoride
Ban/Ilium Nitrate
B utyl Aerate
n-Sutyl Phthalete
Butylamine
Butyric Acid
Cadimium Acetate
Cadmium Bromide
Cadmium Chloridi
Calcium Ananata
Calcium Ananita
Calcium Carbide
Calcium Chromate
Calcium Cyanide
Calcium Dodacylbantani
Burfonata
Calcium poch
Captan
Carbaryl
Carboturan
Corbon Diaulfidc
Carbon Tatrachloridi
CMordana
Chlorine
Oilnrntiimi"!
CMoroform
CMoroaurfonic Acid
Chlorpyrifoi
Chromic Acid
Chromic tu Hate
Chromoui Chloridi
Cooattow Formate
Cobaltoui Sutfamata
Coumaphoi
Craaol
«ama> naacne»e»i
92. 142-71-2
93. 12002434
94. 7447-394
96. 3251-234
96. 689346-3
97. 775848-7
99. 10380-29-7
98. 91642-7
100. 606-774
101.11042-7
102. 94-76-7
103.94-11-1
104. 60-29-3
106.333414
106. 1919404
107.1194454
108.117404
109. 25321-224
110.266-3819-7
111 26952-234
112.9003-194
113.76494
114.62-73-7
115.6047-1
116.10949-7
117.12440-3
119.25164444
119.51-284
120. 35321-144
121.9640-7
122.399444
123. 33044-1
124.27176474
126. 116-29-7
126.72-204
127.106494
126 663-12-2
129.100-41-4
130. 107-15-3
131.106434
132. 10746-2
133.604O-4
134.1195474
135.2944474
lift 7mc-AB.n
C-27
Cupric Acatate
Cupric Acatoai unite
Cupric Chloridi
Cupric Nitrate
Cupric OxeJete
Cupric Sulfate
Cupric Sulfati Ammoniated
Cupric Tartrau
Cyanogen Chloridi
Cyclone xene
2,4-D Acid
2j4-O Eitan
DOT
Diaiinon
Oicamba
Oichlobanil
Oiehlonc
Dichlorobeniane (all nomeril
Dichloropropane (all nomers)
Owhloropropane (all iiomen)
Oichloropropane-
Oichloropropana Mixture
2-2-Oichloroprooionic Acid
Dichlorvoft
Dialdrin
Diathylamine
Dimathylamine
Dinitrobaniana (all nomen)
Oinnropnenol
Dinitrotoluane (all ieomeril
Diquat
Diaulfoton
Oiuron
DodacylbannnaiuHonic Acid
Endaeulfan (all ieomert)
Endrin and Matatoolitai
Epiehlorohydrin
Ethion
Ethyl Sanrene
Ethylanadiamine
Ethylana Oibromide
Ethylana Oichloride
EDTA
Fame Ammonium Citrate
Fanic Ammonium Oxalate
Farric Chloridi
-------
II. HAZARDOUS SUBSTANCES
137. 7783404 Ferric Fluoride
136. 10421 464 Farrie Nitrata
136. 10028-224 Farrie Sultata
140. 1004549-3 Farrow Ammonium Sulfar
141.7768444 Farrow Chloride
142. 7720-78-7 Farrow Sulfatt
143. 206444 Fkmranthana
144. 60404 Formaldehyde
146. 64-184 Formic Acid
146. 110-174 Fumaric Acid
147. 8841-1 Furfural
148. 86404 Guthton
148. 76444 HaptKhlor
160. 118-74-1 Haxacnterobaniant
161.8748-3 Haxacnlorebutadiant
162.67-72-1 Hexachtorotlhana
IM ri ^^ men orofjniiu
(Hydrogen Chloride)
166. 7664-39-3 Hydrofluoric Acid
(Hydroatn Fluoride)
157.74404 Hydrogen Cyanide
168.7783464 Hydroatn Sulfide
169.78-784 Itoprene
160. 4260446-1 Itopropanolamint
Dadacylbemnaeulfonate
161 . 1 1 642-2 Kalthana
162. 143404 Kopona
163. 30144-2 Uad Aortan
164. 3887-314 Laad Araanata
166.13814464 Laad Fhioooratt
187. 778346-2 LMd Fluoride
188.10101434 Laadtodidt
169.16266484 Laad Nitrate
170. 7428484 Laad Staarata
171.1673940-7 LaadSutfata
172. 1314474 Laad Sulfide
173. 692474 Laad Tnweyanata
174.66494 Linden.
176.14307464 Uthkim Chromata
176. 121-764 MUthion
177. 110-16-7 Mafeic Acid
178. 108414 Male* AnhydrirJt
179. 203245-7 Marcaptodimathur
180. 69244-1 Mmuric Cyanide
161.10045444 Mmuric Nitrate
182.778346-9 Marcuric Sulfate
183. 692464 Mmuric Thiecyanata
164.10416-764 Ma row Strata
188. 288404 Mathyl Pamhion
189. 7786-34-7 Mavinptiet
180. 316-164 Maxacarcm
161. 7644-7 Monoethyiamin.
182. 74494 Monomathylamine
193. 300-764 Naltd
*p4. 91 *4iO*3 MipfttttctvM
185. 1338-244 Maphthanic Acid
186. 7440424 Nickel
187. 16699-184 Nickel Ammonium Sulfatt
188. 3721 146-5 Nicfcal Chloride
189. 1206448-7 Nwkal Hydroxide
200. 14216-76-2 Nicktl Nitrata
201 . 7786414 Nickel Sulfate
202. 769747-2 Nitric Acid
203. 88464 Nrtrobenitn.
204. 10102444 Nitrogen Dioxide
205. 25164-554 Nitrophanol Ull itoman)
206.132M24 Nitrotoluene
207. 3052S464 P araformaldehyde
21 1 . 8541 4 Phenamhreni
212. 10846-2 Phenol
213. 76444 Pnotaana
214. 7664-38-2 Phoaphoric Acid
215. 7723-144 Phoaphorw
216. 10026474 Phoaphorw Oxychloride
21 7. 13 14404 Phoaphorw Pentaaulf ide
218. 7719-12-2 Photphorui Trichloride
219. 7764414 Potaeeium Anenate
220. 1012440-2 Potaauum Anenite
221 . 777840-9 Potawum Bwhromatt
222. 7789404 Potaeeium Chroman
224. 2312-354 Propargite
225. 79494 Propionic Acid
226. 123424 Propionic Anhydride
227. 1336-36-3 Polychlorinaud Biphenyli
228.161404 Pota«ium Cyanide
229. 131048-3 Potaatium Hydroxide
230. 76464 Propylana Oxide
231. 121-294 Pyrathrint
232. 91 -224 Quinoline
233. 106464 Kttorcinol
234. 7446484 Selenium Oxide
235. 7761484 Silver Nitrata
236 763149-2 Sodium Artanate
237. 776446-5 Sodium Araanite
238. 10688414 Sodium Bichromate
239. 133343-1 Sodium Bifluoride
240. 7631404 Sodium Bnulfita
241.7776-114 Sodium Chromati
242. 143-334 Sodium Cyanide
Sulfonete
244 78B1494 Sodium FKioridt
245.16721404 Sodium Hydrotulf idt
246. 1310-73-2 Sodium Hydroxide
247. 7881424 Sodium Hypochtorit*
248. 124414 Sodium Mttfiylata
749. 7632404 Sod. titrate
250. 7658-784 Sodium Photprtait. Dibanc
251.7601-644 Sodium Phoephaie. Tribasic
252. 10102-184 Sodium Seleniie
283. 778946-2 Strontium Chromn.
254.57-244 Strychnine a nd Seiti
255. 1 004204 Styrane
256. 1 2771 48-3 Sulfur Monochloridt
267. 7664434 SuHurie Acid
258.93-764 2AS-T Acid
269. 2008464 2.4.5-T Aminei
260. 93-784 2.45-T Entn
261. 1356049-1 2,4 j-T Stilt
262, 93-72-1 2.4JB-TP Acid
263. 3253445-S 2.4,5-TP Acid Eiten
264. 72444 TOE
266 127-184 Tetrechloroeth* ne
267 7840-2 Tatra*rhyl Laad
268. 10749-3 Tatratthyl Pyrophoepheie
269,7446-164 Thallium (DSulfate
270. 10848 3 Toluane
271.800145-2 Toxaphana
272. 1200248-1 Trichlorobannne Ull norrwrt)
273.62484 Triehtorfon
274. 2632349-1 Trichloroathan. Ull nomtrtl
275.79414 Trfchloroethylen.
276.2516742-2 Triehlorophanol Ull i«omer»)
277.2732341-7 Triathanottmin.
Oodacy natu
278. 121444 Triathylamine
279 75-60-3 Trimathylamine
280. 64149-3 Uranyl Acetate
281.10102464 Uranyl N itrate
282. 131442-1 Vanadium Pantoxidt
283.27774-134 Vanadyl Sulfate
284. 108454 Vinyl Acetate
285. 75454 Vinylidene Chloride
286.1300-714 Xylanol
287 . 567444 Zinc Acatat.
288 52628-264 Zinc Ammonium Chloride
289. 1332474 Zinc 6orate
290. 7699454 Zinc 8romid.
291 . 3486-354 Zinc Caroonne
292. 764645-7 Zinc Chloride
293.557-21-1 Zinc Cyanide
294.778349-3 Zinc Fluoride
295.657414 Zinc Formate
296. 7779464 Zinc Hydrotulfitt
297. 7779484 Zinc Nitrett
298. 12742-2 Zinc Phenoltulfonau
299. 131444-7 Zinc Phoephidi
300. 16871-714 Zinc Silicofluoride
301. 7733424 Zinc Sulfate
302. 13746494 Zirconium Nitrate
303. 16923464 Zirconium Potauium Fluoride
304. 1464441-2 Zirconium Sulfate
305. 10026-114 Zirconium Tatrachloride
C-28
-------
APPENDIX D
RECOMMENDED EQUIPMENT INVENTORY
PERSONNEL CLOTHING AND EQUIPMENT
Items of personal clothing and equipment listed below are issued to each
member of the field investigation team. These items were designed to protect
team members from the elements and from hazards associated with working in
potentially dangerous environments:
* Boots (neoprene and safety with steel toe and shank),
Coveralls (chemical-resistant, cotton),
Ear plugs,
Glasses (safety and prescription),
Jacket (medium weight, and wind-breaker), and
Ra i n su i t.
Emergency Equipment
Emergency equipment is available in the field on a team basis in the event
that it is needed. These items are always carried on vehicles used in onsite
field investigations:
Emergency Oxygen Administrator,
Fire Extinguishers (assorted types and sizes),
First-Aid Kit,
Portable Eye/Face Wash Unit,
Stretcher,
* Wool Blankets, and
Wood SpI i nts.
D-1
-------
Respiratory Protection and Safety Equipment
Items of respiratory protection and safety equipment are maintained on
field vehicles or, when necessary, in a controlled temperature environment and
are issued as needed for onsite work. This equipment is critical to the welfare
of team members working on hazardous substance sites and must be carefully
maintained and inspected regularly:
* Air Escape Mask,
Air-Purifying Respirator (with assorted cartridges or canisters)
Air Tank Refill System,
Butyl Rubber Apron,
Butyl Rubber Booties,
Butyl Rubber, Neoprene, or Viton Gloves,
Chemical Protective Hood,
Coveralls (disposable),
* Fully Encapsuling Suit (butyl rubber),
' Life Vests,
Safety Harness (Swiss seat),
Self-Contained Breathing Apparatus (with extra tanks), and
Surgeon's Gloves.
Tools and Vehicular Equipment
The following items are included for their general utility in field
situations:
* Booster Cables (12 ft),
* Bow Saw (30 in.),
* Broom,
Curved-Back Wire Brush,
* Duckbi II Snips (12 in.),
" Electrical Tape,
D-2
-------
Grounding Rod,
Hacksaw (with blades),
Hammer (Ballpeen, carpenter's, machinists's, and 4-lb sledge),
Hatchet (13 in.),
Hose (garden 50 ft or more with nozzle),
Machete,
Measuring Tape,
Oi I Spout,
Paint (fluorescent),
Pick (25 in. nonsparking),
Pliers (8 in. diagonal cutting, 10 in. forged grooved joint, 8 in.
lineman's, 8 in. long nose, and 8 in. slipjoint),
Pocket Knife,
Reflectors (safety warning),
Rubber Mai let,
Safety Flares,
Sc rewd r i ve rs (asso rted),
Shovel (D-handle, round point, nonsparking),
Tire Pressure Gauge,
Too I Box,
Tow Chain (14 ft heavy duty),
Truck Jack,
Wooden Ma I let,
Wrecking Bar (nonsparking), and
Wrenches, Nonsparking (10 in. adjustable, bung, 10 in. locking, 10
in. and 18 in. pipe, lug, and 6-piece combination set).
D-3
-------
General Environmental Evaluation Equipment
The items listed below have uses related to the acquisition of data and
samples for the basic characterization of a site.
Soil and Sediment Sampling Equipment--
* Aluminum Foi I,
* Bucket Auger (3 in. with handle),
* Dredge,
* Labscoops (with handles),
* Plastic Jars (1 qt wide-mouth for metals),
* Pesthole Digger,
* Split Spoon Sampler, 2 in. x 1.5 in. diameter, 24 in. x 18 in.
length,
* Scoop (stainless steel),
• Shovel,
* Spatula (stainless steel, 8 in.), and
* Tape (Teflon).
Water Sampling Equipment--
* Automatic Dispenser (Pipetor),
* pH meter,
• Buffer Solutions (pH 4, pH 7 and pH 10),
* Container Brush,
* Conductivity Meter,
* Dissolved Oxygen Indicator (with probe for field use),
• Disti I led Water,
• Hip Boots,
* Nansen-Style Bottles (water sampling with case),
• Plastic Beaker (1000 ml),
D-4
-------
• Polyethylene Bags (8 in. x 12 in., 10 in. x 16 in., and 12 in. x 20
in.),
* Rope (nylon, 3/16 and 1/4 in.),
* Sampling Pump - Peristaltic,
* Sta i nI ess SteeI Safety Lab Can,
• Thermometer (yellow, 20-1100),
* Tubing (Silicone for above peristaltic pump),
• Tubing (Teflon, 1/4 in.),
• Wash Bottles (500 ml),
* Water Bailer (Teflon or stainless steel),
* Water Level Indicator (electric or tape),
* Well Pump (submersible), and
• Whirlpak Bags (4.5 x 9).
Air Sampling Equipment--
* Personnel Sampling Pumps (with adsorbent tubes and/or fitters and
impingers),
* Barometer Pressure Indicator,
* Carbon Absorption Tubes,
* CaI orimetric Tubes (length-of-stain),
* Temperature Indicator, and
* Wind Speed Indicator.
Special Environmental Evaluation Equipment
The items listed below have uses related to the acquisition of data and
samples for characterization of especially hazardous sites.
Ambient Site Characterization Equipment--
* Camera (35 mm and instant print),
* Passive Dosimeter/Samplers,
* Combustible Gas Indicator (with probe and calibrating test kit),
D-5
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* Metal Detector,
* Oxygen Indicator,
* Photoionization Detector (Portable),
* Portable Gas Chromatography,
* Radiation Dosimeter,
* Radiation Meter,
* Radiation Monitor (with audible alarm),
* Rangefinder,
* Resistivity Meter, and
* Surveying Equipment.
Hazardous Material Sampling Equipment--
* Brass Spoon(nonsparking),
• Drum Opener,
* Drum Sealer,
* pH Indicating Paper (wide and narrow range),
* Plastic Ba^s (assorted sizes with elastic closures; self-seaI ing not
recommended),
* Plastic Sheeting,
* Stoppers (solid rubber, assorted sizes to fit tubing),
* Tongs (wooden, disposable),
* Tubing (glass, 4-ft lenghts, 17 mm ID with No. 1 I-hole stopper),
* Tubing (Polyethylene, 4 ft lengths; 6 mm to 20 mm ID), and
* Wooden Doweling (assorted lengths).
Support Equipment and Office Supplies
The following list contains equipment and supplies necessary for setting
up and operating field command posts and decontamination areas:
D-6
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Sample Label Tags,
Chain of Custody Forms,
Bags (trash, plastic),
Binoculars (wide angle 7 x 35),
Buckets,
Brown Wrapping Paper,
Cellophane Tape,
Chaining Pin Set,
Cl ipboards,
Clips (paper and alligator),
Composition Book (numbered pages),
Dairy Brush,
Desk Stereoscope,
Detergents,
Engineer's Tape (12 ft),
Extension Cord,
Fiberglass Tape (lock type, open reel, 100 ft)
Flagging Tape,
Garbage Can (with top),
Ground Plastic Sheets,
Hand Calculator,
Lantern (rechargeable),
Level (hand, 2 X),
Magnetic Hangers,
Masking Tape (2 in. wide),
Note Pads,
D-7
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* Nylon Twine,
* Overhead Tarp (with rope and stakes),
* Pens, Pencils and Markers,
* Recorder (microcassette),
• Redwood Plugs (various sizes),
* Rope and Stakes (for cordoning off area),
• Rubber Bands,
* Scrub Brushes,
* Shower Curtain,
* Signs ("caution", "restricted area"),
* Sprayer (garden, 4-gallon),
* Stapler (heavy duty),
• Wash Tubs,
• Water Jugs (collapsible 5-gallon), and
* Wheelbarrow.
Shipping Supplies and Labels
Listed below are items used in the shipment of samples and equipment.
Such shipments are carefully regulated by the U.S. Department of Transportation
and must be prepared in accordance with DOT requirements to avoid legal pen-
alties. U.S. Environmental Agency sample chain-of-custody provisions must
also be kept in mind.
The reference for DOT specifications for shipping is the 49 CFR, partic-
ularly 172.101. The Bureau of Explosives Tariff No. BOE-6000 may also be
consuI ted:
* Air Bi I Is,
* Dry Ice (or water ice),
* Electrical Tape,
* Evidence Tape,
* Fiberglass Tape (I-in. and 2-in.),
D-8
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Foam Rubber,
Garbage Bags,
Ice Coolers (48 qt or 20 gallons), and
Labels
Corrosive
Danger - Pel igro
Dangerous When Wet
Empty
Explosive A, B and C
Flammable Gas
Flammable Liquid
Flammable Liquid N.O.S.
Flammable Sol id
Flammable Sol id N.O.S.
Hydrogen
Irritant
Limited Quantity
Limited Quantity (731 or higher)
Organic Peroxide
ORMA Dry Ice
Oxidizer
Poison
Poison A
Poison B
Poison Gas
Poison Liquid N.O.S.
D-9
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Radioactivity I , II and 111
This End Up
Masking Tape (2 in.),
Metal Paint cans (half gal Ion or gal Ion with lid and seal ing cl ips)
Official Sample Seal (U.S. EPA) (EPA Form 7500-2, R7-75),
Rubber Stopper (size 000, solid; for cooler drain),
Shipper's Certification for Restricted Articles, and
Vermicul ite.
D-10
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APPENDIX E
FIELD CHARACTERIZATION OF HAZARDOUS WASTE
One of the primary objectives of a hazardous waste site investigation
is to thoroughly determine the hazards and risks associated with the wastes.
Before such an assessment can be accompl ished, the composition of the wastes
and the hazardous properties that the wastes exhibit must be determined. In
past years, much of the emphasis in environmental analytical chemistry has
been directed toward reducing the detection limits for contaminants. Only
recently has attention been focused on activities where it becomes important
to have the abi I ity to characterize and analyze chemical wastes present in
concentrated form as is commonly found at hazardous waste sites. Many of
the procedures designed for the analysis of low level environmental samples
cannot be directly applied to the analysis of concentrated samples. There-
fore, new analytical procedures are being developed and current methods
are being modified to adapt to the needs of hazardous waste analysis.
Field characterization procedures which allow investigators to rapidly
screen, classify, and segregate unknown wastes are examples of techniques which
have been specifically developed with these needs in mind. Their purpose is to
provide immediate data which will allow onsite personnel to make decisions
regarding segregation of incompatible wastes, hazard potential, safety precau-
tions and future analytical needs. The procedures utilize portable instrumen-
tation and equipment. The procedures also employ analyses which are simple to
perform, and they allow for rapid sample throughput even under extreme condi-
tions. Two such procedures have been developed within the U.S. Environmental
Protection Agency, one through Region VII's Emergency Planning and Response
Branch in Kansas City, Kansas, and a second through the Environmental Response
Team in Edison, New Jersey. Although both procedures have similarities, there
are enough differences in technique and application to warrant presentation of
both , Basically the former procedure is completely field oriented and is
designed for screening a small number of samples at a time. The latter tech-
nique uses instrumentation and equipment requiring a "field laboratory" type
environment, and permits rapid screening of large numbers of samples. Both
techniques are useful in their own right, and it is up to the investigator to
determine which procedure (or combination of procedures) is best suited for
h is/her appl icat ion.
Region VII Field Characterization Procedure
Genera I--
In an effort to strengthen the capabilities of field investigation teams,
this field characterization procedure has been developed to enable personnel to
characterize hazardous substances at the time of sampling. The characterization
E-1
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process allows for incompatible wastes to be segregated and compatible samples
to be composite for more cost effective laboratory analysis. The field
characterization procedure is designed to interface with laboratory procedures
such as those being developed in Volume III. The information provided by the
field tests will help laboratory personnel determine the safety precautions
necessary to handle a sample, as well as to determine the additional analytical
needs.
The specific tests and characterization format discussed in this sect
are designed to be used in a field investigation capacity, where fewer than 25
samples will be collected for characterization in a given day. The character-
ization kit is fully self-contained with the exception of support equipment
such as a radiation meter, an organic vapor detector, and personal protective
equipment. A prototype test kit has been designed and consists of the equipment
listed in Table E-1 and the support equipment listed in Table E-2.
Safety Considerations--
There are numerous safety considerations which must be addressed before
collecting a hazardous waste sample and conducting this characterization pro-
cedure. Although a detailed discussion of safety measures to be followed is
not within the scope of this section, some general comments are warranted at
this time. Refer to Section 3 of this document and Volume IV for a detai led
treatment on the subject of safety. In general, the greatest risk to field
personnel exists from the time a closed container is opened to obtain a sample,
until the waste has been sufficiently characterized to assess its acute hazards.
All tests in this field characterization scheme are to be conducted in a
noncontaminated area on the upwind side of the site. The level of personal
protection may vary from site to site, but the level of protection in the
characterization area should always be equal to or better than the protection
worn in the sampling area. Respiratory protection is mandatory throughout the
characterization procedure. All contaminated sampling and characterization
materials, as well as protective gear, must be decontaminated or disposed of
properly. Some additional safety considerations, unique to specific tests,
will be addressed later in the procedure narrative.
Procedural Background--
The field hazardous waste characterization procedure is divided into
several parts, beginning with a site characterization section and proceeding
into sample acquisition and characterization of the wastes. Water soluble
liquids, water insoluble liquids, and solids are characterized in separate
sections of the procedure. This separation is made in order to allow the tests
in a section to be geared towards the characteristics of the waste which wi I I
be placed in that section. For instance, solids and liquids will require
different manipulation in order to perform the tests in the procedure, and
water soluble and insoluble wastes do not require all of the same character-
ization tests.
The tests included in this procedure have been restricted to those which
provide pertinent information on general physical and chemical properties,
waste compatibilities, and acute safety or toxicity hazards. It is not possible
to design a sample characterization procedure which always can provide the
E-2
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TABLE E-l. CHARACTERIZATION KIT INVENTORY
Xtea
Approximate price
• pads
bunsen burner
cheaicals
* cetic a eld
cadaiua nitrate
sodium a cetate
sodiu* hydroxide
sulfuric acid
copper wire, 20 gauge
cyanide detector tubes (Matheson/Ki tagawa)
cubltainers, 1 Liter
forceps
gloves
viton
PVC disposable
labels
lead a cetate paper (Fisher)
pencils t paper
peroxide indicator strips (EN Quant,
Sargent-Welch)
pH paper
full range strips (J. T. Baker)
full range kit (Fisher)
pipettes, disposable
2 «l
5 ml
10 ml
transfer
pipette fillers
automatic
siall
plastic bags
large
s*all
potassiu* iodide/starch paper (Fisher)
propane tank
spatulas
porcelain (Coors)
stainless steel, large
stainless steel, saall
specimen beakers
tackle box (UHCO 2080 UP8)
tape, transparent
test tube racks
therHOMeter
vials, 40 • I with septas
water, distilled
wipers, disposable
TOTAL
5.00/package
U.50/each
8.00/500 Ml
15.00/100g
10.00/SOOg
4.00/100g
8.00/5&0 ml
2.00/roll
15.00/package of 10
.50/each
3.00/each
3.00/each
26.00/pair
10.00/package of 100
5.00/package of 1000
7.00/box of 2000
1.00
10.00/package of 100
5.00/roll
12.00/box
20.00/package of 100
20.00/package of 100
20.00/package of 100
20.00/package of 1000
18.00/each
1.00/each
10.00/package of 50
5.00/package of 50
7.00/box of 2800
9.00/each
8.00/each
5.00/each
4.00/each
25.00/case of 500
65.00/each
1.00/roll
15.00/each
7.00/each
60.00/box of 100
1.00/gallon
2.00/box
4489.00
NOTE: Manufacturers or suppliers are not listed on items readily available
fro* • ost chemical or scientific suppliers.
E-3
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TABLE E-2. SUPPORT EQUIPMENT
I tern Approximate Price
Combustible gas indicator (MSA) $600.00
Fire extinguisher $50.00
Gas detector kit (MSA, Draeger, Matheson) $300.00
Organic Vapor Analyzer - GC (Analabs) $5,000.00
Personal protective equipment $200.00-2,000.00
Photoionization detector (HNu Systems) $3,500.00
Radiation meter $400.00
Total $10,050.00 - $11,850.00
information desired about every type of waste that might be encountered;
therefore, it is advisable to consider adding further tests or omitting tests
in order to satisfy the objectives of the waste characterization at each
individual site.
The procedure is designed to permit compatible wastes to be placed into
categories for composite analysis when desired and allow incompatible wastes to
be separated. Some typical waste categories are listed below:
* air react i ve wastes
* compatible sol ids,
* cyanides and suIf ides,
* inorganic acids,
* inorganic bases and neutrals,
" inorganic oxidizers,
* organic oxidizers,
* organic acids,
" organic bases and neutrals, and
* rad i oact i ve wastes.
Few sites wi I I contain wastes from a I I of the above categories, whi le some
sites may require the addition of other categories such as qas cyl inders or
explosive wastes. n any event, all information must be properly documented
using data sheets similiar to that listed in Figure E-1 .
E-4
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Sample Number: Ambient Temperature:,
Type of Container Collected From:
Markings on the Container:
Air Reactive: Poa. Neg. Radioactive: Pos. Neg.
Liquid Solid Other (Specify)
Appearance of Waste:
OVA or Hnu Reading: (attach chromatogram if applicable)
Ignitability (explain results)
Beilstein's Halogen Test: Pos. Neg.
Waste/water mixture (determine water reactivity, record liquids as soluble or
insoluble in water, estimate the percent solubility of solids):
pH determination:
Oxidizer Test: Pos. Neg. Peroxide Test: Pos. Neg._
Sulfide Test: Pos. Neg. Cyanide Test: Pos-
Comments:
Figure E-l. Hazardous waste characterization data sheet.
E-5
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Site Entry and Safety Characterization--
Site entry procedures wi I I vary on a case-by-case basis depending on the
nature of the site and how much is known about the site initially. Conservative
levels of protection should always be used until sufficient information is
obtained to deem the precautions unnecessary.
Several indispensable monitoring and survey instruments used in this
protocol are: an explosive atmosphere meter, an oxygen meter, a hand held gas
detection pump with hydrogen cyanide detector tubes, a radiation survey meter
and a portable flame ionization detector or photo ionization detector for
measuring organic vapor concentrations. Additional survey equipment (such as a
metal detector or additional gas detector tubes) may be necessary depending on
particular sites.
The organic vapor monitors discussed in this section are the Ana labs
Organic Vapor Analyzer (OVA) and the HNu photo ionization detector (HNu). The
OVA may be equipped with a gas chromatography (GC) option for added field
analysis capabilities. The HNu is a versatile, low maintenance monitoring
instrument. One must remember, however, that this instrument does not detect
several flammnable hydrocarbons, such as methane, ethane, and propane. Whenever
the vapor concentrations are above full scale for these instruments, a less
sensitive explosion meter must be employed. Volume I I--Aval I able Sampling
Methods--provides detai Is for the use of these instruments.
Visual Site Assessment--
The steps in this characterization phase are very broad and will differ
greatly from site to site. All pertinent meteorological information and geo-
logical characteristic should be recorded. A complete inventory of the site
may be conducted including the types and quantity of containers present. Any
customized containers or suspicious looking drums should be noted for special
handling and segregation. Evidence which indicates the toxicity of the waste
or potential hazards, such as dead plants and animals or bulging drums should
be recorded.
Sample Aquisition--
Great care is required when opening drums or any sealed container. Any
drum opening procedure should include some method for manually or mechanically
checking for shock sensitive wastes from a safe distance, before a drum is
opened to collect a sample. Separate samples should be collected for field
characterization and laboratory analysis. A maximum of 15 mi I I i I iters (ml) of
waste is needed for field characterization tests in this procedure.
Air Reactivity--The readily air reactive wastes should be discovered
during the opening or sampling procedure. The air reactive substances normally
require special packaging. The wastes may be stored under water or some other
liquid to prohibit air from coming in contact with the waste. They may also be
found in sealed ampules, correlated drums, stainless steel canisters, or
specially lined drums. Some chemicals such as white phosphorus or barium azide
react with the oxygen in the air. While others such as cesium or various metal
hydrides react with the moisture in the air (Windholz, 1976). Many of the air
reactive chemicals are explosive.
E-6
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There may be drums containing various amounts of laboratory chemicals
(lab-packs). Lab-packs will have removable lids and often contain chemicals
which are incompatible. Any specialized or suspicious looking containers
require special handling and should be suspected of containing reactive or
explosive wastes. Gas cylinders may be encountered and should be considered
for sampling or destruction on a case-by-case basis depending on the condition
of the cyl inders and the suspected contents.
Rad i oactIvIty--Once the waste is found to be compatible with the ambient
atmosphere, it is checked for radioactivity with a radiation survey meter.
Physical State--Much of the initial characterization is performed in
conjunction with the sampling operation. Determine if the waste is a liquid,
solid, semi-so I id, or heterogeneous mixture. This determination may be somewhat
arbitrary for some very viscous liquids or resins, but it is not crucial because
the same characterization tests are performed on both solids and liquids. If
the waste is a heterogeneous mixture, the solid and liquid phases may be separa-
ted for characterization. Any observable characteristics of the waste should
be noted at this time. From this point, the liquids and solids are character-
ized separately.
General Liquid Characterization--
The remainder of the waste characterization tests are to be performed at a
safe distance from the sampling area, in a noncontaminated area, but within the
decontamination line. The tests are to be performed on a portable table or
bench covered with plastic. The flame tests discussed below must be performed
in a separate location to minimize the chances of an accidental fire.
Immiscible Liquid Phases--Liquids are usually sampled with a "thieving
rod" or a similar pipette type instrument. The sample may be examined through
the glass rod for immiscible phases or other visual differences. If more than
one phase are present, they should be separated for individual analysis.
Often, if more than one phase are present, one wi I I be aqueous.
Flame Tests--The apparatus for the flame tests consists of a bunsen burner
fueled by a propane tank (Figure E-2). An inline pressure bleed assembly
should be added to prevent a dangerous pressure buildup in a rubber tubing.
This may be accomplished by placing a Tee-joint in the line and running a tube
from the Tee into a flask of heavy oi I or other low flammabi I ity viscous I iquid.
This wi I I a I low excess propane to bubble into the I iquid before much pressure
can build up in the tubing. The flame height must be adjusted with the propane
tank valve rather than the bunsen burner adjustment in order to prevent a
continual loss of propane. It may be necessary to construct a windbreak with
coolers or other nonflammable objects. A fire extinguisher should always be
kept close by when conducting these characterization tests.
The first flame characterization test to perform is a crude flammabi I ity
test with the waste. One or two drops of the waste are placed in a porcelain
spoon and held above the flame of a bunsen burner fueled by a portable propane
tank. The ignitability should be recorded as well as any other observations
such as flame color or sootiness. An indication of the composition of the
waste may be obtained from these observations. For instance, aromatic compounds
E-7
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oo
PRESSURE BLEED ASSEMBLY
BUNSEN
BURNER
BEAKER OF OIL OR
.LOW FLAMIBILITY VISCOUS LIQUID
PROPANE
TANK
Figure E-2. Flame test apparatus.
-------
generally produce a yellow sooty flame. If 110V current is available, a more
accurate flammabi I ity test could be performed with a Setaflash or comparable
flash point tester.
The Bei I stein's halogen test is also conducted at this time. A small two-
or three-looped coil is made in the end of a piece of 20 gauge copper wire.
The coi I is held in the edge of the flame unti I any green flame disappears.
Next, the wire coi I is a I lowed to cool and then dipped into the waste and
returned to the flame. A green flame wi I I indicate the presence of a halogen
(chlorine, bromine or iodine). Fluorine does not produce a positive result.
The green flame wi I I usually appear shortly after the bulk of the waste has
burned off of the coil. This test is surprisingly sensitive and is important
for identifying the presence of halogenated organics such as polychlorinated
biphenyls (PCBs) or chlorinated solvents. Under ideal conditions, PCBs have
been detected at concentrations below 200 mg/kg by this method. However, this
is not below the 50 mg/kg EPA action level for PCB disposal; therefore, a
negative result on this test does not rule out the need for laboratory screening
for halogenated organics.
There are several factors which may interfere with the Beilstein test.
Very volatile liquids may have a tendency to evaporate in the flame before
decomposition can occur, thereby producing a negative reult. Several non-
halogenated compounds have been stated to-also cause a green flame, such as
organic acids, copper cyanide, urea, and quinoline and pyridine derivatives
(Shriner, 1964).
Water Reactivity and Volubi I ity--PIace approximately 1 ml of the sample
in a 40 ml glass vial ,plastic specimen beaker, or similar flask, and carefully
add 1 ml of disti I led water whi le monitoring the temperature of the mixture.
A large temperature change, gas generation, ignition, or color change are all
indications of water reactivity and should be recorded as such. Slight tem-
perature changes indicate heats of solution and should not be attributed to
water reactivity.
Determine if the liquid is soluble or insoluble in water. A waste which
is soluble in water will be considered inorganic and characterized more com-
pletely in the next section, Inorganic Liquid Characterization. A waste which
is not readily soluble in water wi I I be characterized using procedures in the
section entitled Organic Liquid Characterization. Some organic solvents such
as acetone and alcohols are miscible with water but the mixing reaction that
occurs is usually easily detectable.
If the liquid is not soluble in water, record whether it is denser or
lighter than water. This can be an indication of the wastes composition, as
most halogenated organics are heavier than water and most hydrocarbons are
less dense than water.
Inorganic Liquid Characterization--
Headspace Check--Check for the presence of water soluble volati le organics
in the waste by test i ng the headspace above the sample with an OVA or HNu. If
E-9
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vapors are detected, further organic analysis in the laboratory or with the GC
mode of the OVA is advisable.
pH Determination--Test papers were selected as the method of pH determin-
ation for this procedure. The pH paper was chosen preferable to a more sensi-
tive pH meter because of the size, probe contamination problems, and long term
reliability problems associated with a pH meter.
To measure the pH, either immerse a portion of a strip of indicator paper
into the sample, or place a drop of the waste onto the paper. If the waste is
colored or dark and stains the paper, the desired pH color change can be seen
at the margin of the stained area or on the reverse side of the spot. For the
purposes of this characterization procedure, a pH of less than 3 is considered
acidic, a pH greater than or equal to 3 but less than or equal to 10 is termed
neutral, and a pH greater than 10 is considered basic.
Oxidizers and Peroxides--Strong inorganic oxidizers are detected with
potassiurn iodide (KI)/starch paper. Place a drop of the waste on a strip of
dry KI/starch paper and another drop on a strip of KI/starch paper which has
been previously moistened with buffer solution. [Buffer Solution: Dissolve
24.3 g of sodium bicarbonate (^362^02.3^0) or 14.6 g of anhydrous sodium bicar-
bonate (NaC2H3(h) in 40 mis distilled water. Add 48 mis of concentrated
acetic acid and bring solution to 100 ml with distilled water.] The development
of a purple to black stain on either strip indicates the presence of an oxidizer.
If the waste is dark and stains the paper due to its color, check for the
oxidizer stain around the perimeter of the spot or on the reverse side of the
indicator paper as was done with the pH paper.
An alternative method for detecting oxidizers is by measuring the oxidation.
reduction potential of a waste solution through the use of a pH-conductivity
meter (Turpin, 1981). This is a very sensitive method and may be considered
for use when a large number of samples are to be characterized and where elec-
tricity will be available. A modified version of this procedure can be found
under the heading, Emergency Response Team Waste Compatibi I ity Test Procedure
(Mod if led), later in this section.
When possible, peroxides in the aqueous solution are detected with EM-Quant
Peroxide Test Strips. Often the waste is too dark to a I low this test to be
performed reliably, but it can provide useful information when employable. To
perform the test, adjust the pH of 1 mi I I i I iter (ml) of the sample to between
a pH of 2 and 12 with sodium hydroxide (1.0N) or sulfuric acid (4:1) solutions.
Next, immerse the reagent portion of the strip in the sample for 5 seconds.
Remove the strip from the sample and observe the reagent pad for the formation
of a blue stain. The test is sensitive to a few parts per mi I I ion and the
boldness of the blue stain is representative of the concentration.
Cyanides and SuI fides--The neutral and basic liquids are now tested for
the presence of sulfide~or cyanide ions. To test for sulfide, place a drop of
the sample on a strip of dry lead acetate paper and a drop on another strip
pre-moistened with buffer solution. A black stain on either strip indicates
the presence of sulfide. If the sulfide test is positive, the sulfide should
be removed before the following cyanide test is conducted. This may be
E-10
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be removed before the following cyanide test is conducted. This may be
accompl ished by adding cadmium nitrate to a smalI amount of the sample and
swirling the mixture to precipitate cadmium sulfide. As a check on sulfide
removal, alternate adding small amounts of cadmium nitrate and repeating the
spot test until the test is negative.
The first cyanide test discussed is conducted through the use of Matheson-
Kitigawa Cyanide Ion Detector tubes. High chloride ion concentrations may
interfere with the detector tube test, therefore the waste is di luted by adding
8 mis of distilled water to a 0.5 ml sample. This should dilute the sample to
where effects from the interfering ions are minimal and the test is still
sensitive to less than 100 mg/l cyanide. After diluting the sample, score and
break the tips off of a Matheson-Kitigawa Cyanide Ion Detector tube and set it
in the sample. AI low the I iquid to rise into the column by capi Ilary action
and observe any color change in the tube. A deep blue color will indicate
the presence of the cyanide ion.
An alternative spot test method for detecting cyanide amenable to chlor-
ination and cyanogen chlorides (CNCI) is discussed in Standard Methods for the
Examination of Water and Wastewater (American Public Health Association et a I.,
1980). The procedure may be modified to facilitate screening concentrated
waste solutions rather than environmental samples for which the procedure
was designed.
A third alternative method for detecting sulfide or cyanide containing
wastes consists of using a Draeger or comparable gas detector pump and hydrogen
sulfide and hydrogen cyanide detector tubes. The detector tubes which are
chosen should contain reagents to remove interfering compounds. One or two
drops of sulfuric acid solution (4:1) is added to an equally smalI amount of
sample in a vial and the vapor space above the mixture is immediately tested
for H2$ and HCN. If both tests are negative, several more drops of sample and
acid solution are added and the test is repeated. The detector tubes may be
reused several times if the test results continue to be negative. Due to the
high toxicity or \\2$ and HCN, precautions must be taken to avoid breathing any
gases which may evolve from the sample.
Inorganic Liquid Laboratory Ana lysis--The nonreactive wastes which exhibit
like properties as shown by the previous tests may be composite for further
laboratory analysis when desired. Caution must be exercised when compositing
samples and close observation is necessary to detect any reactions between
the wastes.
The laboratory analysis of the water soluble I iquids wi I I vary depending
on the results of the field tests and what analytical equipment is available to
the laboratory. Preliminary tests could include total dissolved solids and
total organic carbon (TOC), followed by more detailed cation and an ion analysis.
The TOC procedure may show that additional organic analysis is necessary.
Tests specified in the Resource Conservation Recovery Act regulations, such as
EP, toxicity, or corrosivity may also be conducted (U.S. Environmental
Protection Agency, 1980).
E-11
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Organic Liquid Characterization--
Headspace Check--A majority of the I iquid organic wastes encountered at a
disposal site will contain volatile solvents or other volatile organics as a
significant portion of their volume. These chemicals are usually readily
detectable in the headspace above the sample with an OVA, HNu or other vapor
detection instrument. The concentration of the vapors above the waste is
recorded along with temperature of the sample at the time of the reading. An
experienced analyst, equipped with a GC-modified OVA or other portable GC and
standards of common solvents can further characterize the vapors and often
identify the major volatile components of the wastes. If there are no detect-
able vapors above the waste, it can be assumed to consist of nonvolatile
organics. For instance, PCB oils may not contain any volatile components.
Organic Oxidizers and Peroxides--Check for water insoluble oxidizers by
placing a drop of the waste on a strip of dry KI/starch paper and a drop on a
strip pre-moistened with buffer solution. A purple to black stain on either
strip indicates a strong oxidizer.
The organic peroxide test is performed with EM-Quant peroxide test strips.
This test can only be performed on relatively clear liquids. After immersing
the reagent portion of the strip in the sample for five seconds, the strip must
be moistened by breathing several times on the reagent pad. When a respirator
is worn this may be accompl ished by holding the strip below the exhalation
valve of the mask. Peroxides are indicated by a blue stain as in the inorganic
I iquid test.
pH Determination--A pH value is obtained for organic liquids by adding 1
ml of deionized water to 1 ml of the sample, mixing, allowing to separate, and
determining the pH of the water phase. The pH range for such solutions will
not be nearly as wide as for water-soluble wastes; therefore, to detect small
differences in pH values, accuracy in the pH determinations is important, cut-
off limits to designate the wastes as organic acids, neutrals, or bases cannot
be prestated in this procedure, because such designations would vary depending
on the range of pH differences, on the pH of the de ionized water before it is
added to the waste, and on the relative distribution of the pH values of other
samples tested from the site.
Organic Laboratory Ana lysis--Water insoluble wastes with similar properties
may be composite for laboratory analysis. Care must be taken to avoid com-
positing unlike or incompatible wastes. The Bei I stein positive and negative
wastes should not be mixed, in order to prevent the contamination of non-
halogenated organics with PCBS or other unwanted halogenated wastes.
Preliminary laboratory sample cleanup and analysis may include resin
column cleanup, thin layer chromatography, or an infrared scan. The heat
value, specific gravity, and sulfur content of the sample wi I I need to be
determined if wastes are being considered for disposal by incinerator. More
detailed volatile, base/neutral, acid, and pesticide analyses are possible
by gas chromatography/mass spectrometry (GC/MS), high performance liquid
chromatography (HPLC) or GC procedures. Alternative or additional analytical
E-12
-------
techniques may be used in the laboratory depending on what additional
information is needed and the aval I able laboratory facilities.
So I i ds Character i zat i on- -
Physical Characteristies--Often information will be evident about the
hazards of a waste by the way it is packaged and its physical characteristics
such as texture, color and density. If a-waste is packaged to exclude water,
as in plastic lined or water tight containers, it should be treated as a
water reactive waste until proven otherwise. Conversely, if a waste is moist
or contains water, it should not be a I lowed to dry out unti I sufficient tests
have been conducted to show that it is not explosive when dry. Record any
visual observations of the waste before proceeding into the characterization
procedure.
Headspace Check--Check for the presence of volati le organics in the waste
by testing the headspace above the sample with an OVA or HNu and record any
readings.
Flame Tests--The bunsen burner ignitability test discussed in General
Liquid Characterization is also performed on solids. Place a very small sample
of the waste on a porcelain spatula and hold it in the edge of the flame.
Record all observations, such as flammabi I ity, flame color, the amount and
color of residue left after burning, etc.
The Bei I stein's copper wire halogen test is conducted at this time if the
consistency of the waste is such that it wi I I adhere to the coi I of copper
wire. Remember to hold the wire in the flame until the green flame disappears
before repeating the test with the waste on the coil.
Water Tests--There often wi I I be sufficient moisture in the waste to
conduct some of the water dependent tests before water is added to the waste.
Try to get a pH determination by pressing the pH strip onto the waste with a
blunt instrument. If sufficient moisture is present, the water will soak into
the strip and the pH reading can be taken on the side of the strip which did
not come in direct contact with the sample. If the pH test is successful, the
oxidizer test may be performed in the same manner. Apply a dry strip and a
buffer solution moistened strip of KI/starch paper to the waste and check for
the development of a purple to black stain on the strips. A stain on either
strip indicates a strong oxidizer.
After the pH and oxidizer tests are attempted, carefully add approximately
1 ml of distilled water to 1 cubic centimeter of sample while monitoring the
temperature. Record any temperature change or signs of water reactivity such
as gas generation, violent churning, etc. Roughly estimate the percentage
volubility of the waste in water.
If the pH and oxidizer tests were unsuccessful on the dry solid, these
tests may be conducted on the waste/water mixture by the methods described for
inorganic liquids. The peroxide test will nearly always be impossible to
perform on the mixture due to the color of the solution,
E-13
-------
SuI fides and cyanides can be detected in the waste/water mixture by one or
more of the methods described for use on inorganic liquids.
Solids Laboratory Analysis--The solid samples which exhibit similar prop-
erties In the test results and have similar appearance and consistency may be
composite for laboratory analysis. The lab analysis should begin with deter-
minations of percent moisture and percent volati le sol ids, followed by further
inorganic and organic analysis as deemed necessary.
Characterization Procedure Summary--
Procedure Flow Diagram--A flow diagram outlining the major points in the
field characterization tests is shown in Figure E-3.
Site Entry and Safety Characterization --A I I background information about
the site is collected prior to site entry. Maximum personal protection is worn
during the initial site characterization.
Determine the percent of the lower explosive limit (LEL) of vapors in
the atmosphere with a combustible gas indicator while continually
monitoring the oxygen level.
Test for hydrogen cyanide with a Draeger pump and tubes.
Test for radioactivity with a survey meter.
Continually monitor with an organic vapor analyzer or photo ionization
detector.
Visual Site Assessment--
* Record the air temperature and other pertinent meteorological infor-
mation and geological characteristics.
State of containers (corrosion, bulging drums, etc.).
Other nonspecific information (dead plants or animals, vegetation
stress, labels on drums, etc.).
Sample Aquisition--Drum opening techniques and safety measures are not
within the scope of this procedure.
Air React i v i ty
Determine if the waste is air reactive.
* Rad i oact i v i ty
Test individual wastes for radioactivity.
* Phys i caI State
E-14
-------
SITE CNTKT MD SAFFPf OMMCTCRtZATIOM
VISUM. SITE ASSES9CNT
*QUI3
SMVLC MWtSITlOtt
1. «1r reactivity
2. radioactivity
3. phftlcal SUU
liquids
hysf
solids
6CHCML LIQUID OWMCTEtHZATION
1. Iwrisclblc phase separation
2. flane tests-lgnlUbllltr and SellsUln's
3. «ater reactivity and solubility
mttr soluble
\mter Insoluble
IWMGMIC IIOUIO
1. headspace check
2. pH determination
3. oildlters and peroxides
4. cyanides and sulfldes
ORGANIC LIQUID CHAMCTERIZATIOtt
1. headspace check
2. oxldlters and peroxides
3. pH deterwlnatlon
SOtIDS OWIWCTCRIZATIOII
1 physical characteristics
2 headspace check
3 flame tests-lgnllability and
tellsteln's
4 water reactivity
S pH determination
6 water solubility
7 oxldlzers
0 sulfldes and cyanides
Figure E-3. Flow diagram of the field characterization tests.
-------
Determine if it is a liquid, solid, semi so I id, or heterogeneous
mixture.
1. Li quid--go to the section entitled General Liquid
Characterization.
2, So I id--go to the section entitled So I i d Character i zat i on.
3, Semi so I id--go to the section(s) entitled General Liquid
Characterization or So I i d Character i zat i on.
4, Heterogeneous--separate phases if possible and go to the
section(s) entitled General Liquid Characterization or Solids
Characterization.
Liquid Character!zation--
Immiscible Liquid Phases
Check for multiphases. If more than one liquid phase is present,
it may be possible to separate and analyze the phases
individuaI ly.
* FIame Tests
Perform an open flame and/or a Setaflash ignitabi I ity test and
Bei I stein's copper wire halogen test.
* Water Reactivity and Volubility
Mix 1 ml of the waste with 1 ml of water to check for water
reactivity and water volubility.
1. Water reactivity: Record the temperature change when water is
added to the waste. Slight temperature changes indicate heats
of solution and should not be attributed to water reactivity.
Also, check for gas generation, color change, combustion, and
determine if the waste is denser or lighter than water.
2, Water volubility: A waste which is soluble in water will be
considered inorganic and characterized further in Inorganic
Liquid Characterization. Wastes which are insoluble in water
Will be considered organic wastes and further characterized in
Organic Liquid Characterization.
Inorganic Liquid Characterization--
* Headspace Check
Check for the presence of soluble volati le organics with an OVA
or HNu. If volati les are present, further organic analysis in
E-16
-------
the lab or with the gas chromatography (GC) mode of OVA may be
necessary.
pH Determination
Determine the pH of the waste with pH paper
1, pH <3 - acidic
2, pH >3 and <10 - neutral
3, pH >10 - basic
Oxidizers and Peroxides
Check for inorganic oxidizers with potassium iodide (KI)/starch
paper and peroxides with peroxide indicator strips.
Cyanides and SuIf ides
Check for sulfides and cyanides (several methods are discussed).
Inorganic Liquid Laboratory Analysis
Wastes with similar characteristics may be composite for
laboratory analysis.
1. Total dissolved solids and total organic carbon.
2, Cation and an ion analysis.
3, Organic analysis if necessary.
Organic Liquid Characterization--
Headspace Check
Check for the presence of volatile organics with an OVA or HNu.
If present, further volatile organics analysis with the GC mode
of the OVA may be desirable. If absent, the waste consists of
heavier nonvolatile organics.
Organic Oxidizers and Peroxides
Check for an organic oxidizer with KI/starch paper and peroxides
with peroxide indicator paper.
pH Determination
Check the pH of a deionized water shakedown of the organic.
Organic Laboratory Analysis
E-17
-------
The wastes of the separate organic groups may be composite with
the except i on of some v i scous wastes.
1. Infrared analysis for determining molecular structural
features.
2, Volati les, base/neutrals, acids, pesticides by GC/MS and
GC ,
So I i ds Character i zat i on--
• Physical Characteristics
Record color, texture, density, etc.
• Headspace Check
Check for the presence of volati le organics above the waste with
an OVA or HNu.
• Flame Tests
Perform the open flame ignitability test and Beilstein's copper
wire halogen test if possible.
• Water Tests
Carefully mix approximately 1 cubic centimeter of waste with 1
mi I I i I iter of distilled water.
1. Check the water reactivity parameters discussed during
Liquid Characterization.
2, Determine the pH of the waste/water mixture.
3, Roughly estimate the volubility of the waste in water.
4. Check for oxidizers with KI/starch paper.
5, Check for suIf ides and cyanides.
* Solids Laboratory Analysis
Sol ids with simi lar properties may be composite
1. Percent moisture and percent volatile solids.
2, Inorganic and organic analysis as deemed necessary.
E-18
-------
References--
1. American Public Health Association, American Water Works Association,
Water Pollution Control Federation. "Standard Methods for the Examination
of Water and Wastewater", 15th Edition. American Public Health Association,
Washington, D.C. 1980.
2, Christian, G. D. "Analytical Chemistry", 2nd Edition. John Wiley and
Sons, New York, NY. 1977.
3, Shriner, R. L., R. C. Fuson and D. Y. Cur in. "The systematic Identifi-
cation of Organic Compounds", 5th Edition. John Wiley and Sons, New York.
1964.
4, Turpin, R. D. and V. Frank. "oxidation Reduction Field Test for Use at
Hazardous Material Spills". U.S. Environmental Protection Agency,
Environmental Response Team, Edison, N.J. 1981.
5, U.S. Environmental Protection Agency, Waste Characterization Branch,
Off i ce of So I i d Waste. "Test Methods for Eva Iuat i ng So I i d Waste: Phys i caI/
Chemical Method", Office of Water and Waste Management, Washington, D.C.
1980.
6, Windholz, M., S. Budavari, L. Y. Stroumtsos and M. N. Fertig, ed. "The
Merck Index", 9th Edition; Mench and Company, Inc. Rahway, NJ. 1976.
Emergency Response Team Waste Compatibi I ity Test Procedure (Modified)
Overall Characterization Scheme--
Collected samples wi I I be characterized by following the scheme shown in
Figure E-4 and by using the procedures given in this section. The physical
description of the sample is a visual observation of color, physical state,
viscosity, number of phases, etc., in the sample and does not have a written
procedure. Careful records will be kept for each sample as it is tested. An
Analytical Report Sheet is shown in Figure E-5.
Safety is the prime consideration in characterizing the samples; efficient
handling to process the maximum number of samples is also important. To
accomplish both of these goals, it is recommended that analyses be conducted in
a "field laboratory" type environment located outside of the hot zone perimeter.
This can be a completely equipped mobile laboratory or a makeshift arrangement
set up specifically for the task at hand; in any event it should be organized
and arranged in such a way as to simulate a laboratory atmosphere. Work
stations should be assigned and organized to specific tasks, electrical power
conveniently located and adequate ventilation in the form of hoods or fans made
avallable.
Radiation Monitor ing--
Determine if the waste is radioactive by (1) screening drums as soon as
possible after staging and opening, or (2) screening samples as soon as received.
The available instrument is generally a gamma survey instrument which indicates
E-19
-------
TESTS TOR M.LSAMPLES
PHYSICAL DESCRIPTION
RADIATION MONITORING
VOLATILE VAPOR MONITORING
PH
WATER REACTIVITY
WATER SOLUBILITY
OXIDATION/REDUCTION POTENTIAL
FLAMMABILITY
pH-DEPENDENT TESTING
SAMPLES WITH pH k OR HIGHER CYANIDE
SAMPLES WITH pH 7 OR HIGHER SULFIDE
Figure E-4. Test sequence for characterizing hazardous wastes.
E-20
-------
ANALYTICAL REPORT SHEET
An«ly»t
Date
Sample/Drum No.
Water Reactivity Nonreactive
Reactive
Planmability
Flanable
Flaae Sustaining
Value
Cyanide
Sulfide
Poaitive
Potitive
Negative Paper
Nega t ive
Redox Potential Reducing Agent
Paper
Reference
Sample
Comment*
OVA Re ad inn
ppn
Nonflammable
Detector
Detector
Oxidising Agent
Analyat
HNu Reading.
ppn
Radioactivity,
•R/hr
Phv«ic«l Description
Solubility
Figure E-5. Sample analytical report sheet.
E-21
-------
in units of mi I I iroentgens per hour (mR/hr). Note that normal environmental
gamma radiation background is 0.01 to 0.02 mR/hr and that the routine worker
exposure rate should not be more than 2-3 times the background level.
Volatile Vapor Monitoring--
Determine the volati le vapor concentration of the waste:
* as soon as drums are staged and opened (sampler inlet positioned at
drum bung hole); or
* upon receipt of samples at the laboratory (container headspace
screening).
Two portable screening instruments have been identified for use in this pro-
cedure, namely the Gentry Organic Vapor Analyzer and the HNu Photoionization
Analyzer. Both instruments are useful as gen{eral screening tools; however,
they are subject to limitations which must be recognized to properly interpret
generated data.
• The instruments do not respond to a"l 1 substances that may be present.
* Different instruments (specifically different detectors) do not
exhibit identical responses to the-same compounds. '
* Extremely toxic substances such as phosgene, HCN, etc., are not
detected with these instruments.
• The response is a cumulative one indicative of all detectable
substances present.
pH Measurement--
* Equipment
Multiband pH paper with fixed indicator colors
50-mi I I i I iter glass beakers
Disposable glass transfer pi pets
* Procedure for Liquid Samples
1, Mark sample number near top of empty beaker with permanent
marker.
2, Record sample number in notebook.
3, Transfer approximately 5 mi I I i I iter of sample to a 50-mi Mil iter
beaker, using a transfer pi pet.
4, Dip multiband pH paper into sample, wetting all bands.
E-22
-------
5, If necessary, carefully wipe off excess sample.
6, Compare the reaction zone band with the fixed indicator color
bands to estimate the pH of the sample.
7, Record estimated pH in notebook and on Analytical Report Sheet.
8, Use this same sample a I iquot for Water Reactivity/VoIubi I ity
testing.
* Procedure for Solid or Tar-I ike Samples
1. Use the Water Reactivity sample aliquot for pH measurement,
after completing the reactivity/volubility testing.
2, Dip multiband pH paper into sample, wetting all bands.
3, If necessary, carefully wipe off excess sample.
4, Compare the reaction zone band with the fixed indicator color
bands to estimate the pH. This is considered an indirect pH
since water has been added to the sample.
5, Record the estimated pH, marking (ind.) for indirect measurement
after the value in the notebook and on the Analytical Report
Sheet.
Water React i v i ty/VoIub i I i ty--
* Equipment
50-mi I I i I iter glass beakers
500-mi I I i I iter polyethylene wash bottles
Disposable glass Pasteur transfer pi pets
Disposable tongue depressors
Deionized water at approximate temperature of samples
Foam plastic shaped to fit beakers. A thermocouple inserted in
the bottom of the plastic holder is connected to a Digimite
digital readout thermometer. Six beaker units can be
accommodated.
* Reactivity Procedure
1. Mark sample number near top of empty beaker with permanent
marker.
E-23
-------
2, Record sample number in notebook.
3, Transfer approximately 5 mi I I i I iters or 5 grams of sample to
beaker, using disposable pi pet or tongue depressor.
4, Insert beaker into holder and let equilibrate until temperature
readout is stable.
5, From a wash bottle carefully pour approximately 5 mi I I i I iters of
deionized water down the side of the sample-containing beaker so
it contacts the sample slowly. Have the hood door closed as
much as possible for safety.
6, Observe and record any visible reaction such as:
fuming or bubbl ing
color change
evolution of gas
temperature change
7, If any of Step 6 indications have occurred, classify sample as
"Water Reactive" and record temperature change in notebook and
on Analytical Report Sheet.
• Volubi I ity Procedure
1. Remove beaker from foam plastic holder and swirl to mix contents.
2, Observe beaker contents and classify in notebook and on
Analytical Report Sheet as follows:
Soluble--AI I of sample is in solution; only one phase
ex i sts.
Semi so Iuble--Part of the sample has dissolved in the added
water and/or colored the water phase. Two or more solution
phases or some undissolved solid can be seen.
Insoluble--None of the sample has dissolved in the added
water.
It should be noted that these classifications are based on the
analyst's judgment; they are not quantitative determinations of
solubi I ity.
Oxidatjon-Reduction (Redox) Potential--
* Equipment
E-24
-------
Disposable Specimen Containers with screw-on caps
Disposable glass Pasteur transfer pi pets
Disposable tongue depressors
pH/Mi I I ivo11 Meter (Orion Model 701A or equivalent)
Platinum Redox electrode (Orion Models 96-78 or 97-78 or
equ ivalent)
Electrode filling solutions:
a. Orion 90-00-01 (proprietary mixture of salts saturated with
si Iver)
b. Orion 90-00-11 (4M potassium chloride saturated with silver
chloride)
Reagents
Test Solution A--prepare by dissolving 0.392 grams of ferrous
ammonium sulfate in about 500 mi I I i I iters deionized water; add
2.8 mi I I i I iters 36N sulfuric acid and di lute to 1000 mi I I i I iters
with deionized water.
Test Solution B--prepare by dissolving 0.194 grams of potassium
chromate, previously dried at 120°C for 2 hours, in 500 mi I I i-
I iters deionized water; add 2.8 mi I I i I iters 36N sulfuric acid
and dilute to 1000 mi I I i I iters with deionized water.
The EMF values for the test solutions should be simi lar to those
shown below for silver/silver chloride reference electrodes. These
values should be checked periodically during sample analysis.
Test Solution Standard EMF
A (Oxidation Potential) 380 millivolts
B (Reduction Potential) 630 millivolts
Procedure for Oxidation Potential
1. Fill the electrode with 90-00-01 fi I I ing solution for low ionic
strength samples or 90-00-11 for high ionic strength samples.
Since most hazardous waste samples will have high ionic strength;
filling solution 90-00-11 should be used.
2. Place the electrode in a beaker containing Test Solution A and
turn the function switch to the millivolt mode.
E-25
-------
3, Record the millivolt reading in the Redox Reference Notebook and
on the Analytical Report Sheet. If the potential reading is 450
or higher, clean the electrode as directed in Preventive Main-
tenance, or replace it with another electrode which gives a
potential reading of 350-450 millivolts for Solution A.
4, Use the same reference reading for a batch of eight samples.
Then repeat Steps 1 and 2 above to obta i n a reference read i ng
for the" next batch of eight samples.
5, Mark the sample number near top of empty Specimen Container with
permanent marker.
6, Record sample number in notebook.
7, Transfer approximately 50 mi I I i I iters or 50 grams of sample
into the container.
8, Add 40 milliliters of Test Solution A.
9, Seal the container and shake vigorously for 15 seconds.
10. Let stand for 5 minutes.
11. Use a Pasteur transfer pi pet to transfer the aqueous phase to a
disposable beaker. If the aqueous phase cannot be readily
identified, add a few drops of water to the beaker and note
which phase it joins.
12. Place the electrode in the aqueous solution and turn the function
switch on the meter to the millivolt mode.
13. Record the millivolt reading in notebook and on the Analytical
Report Sheet.
14. Clean the electrode with a Kim-Wipe.
* Procedure for Reduction Potential
1, Follow the same procedure outlined above for Oxidation Potential,
EXCEPT use Test Solution B in Steps 2 and 3. Clean or replace
the electrode if the potential reading is above 700 mi I I ivolts
and consider 600-700 as an acceptable range of millivolt readings.
Flammabi I ity--
• Equipment
32-mi I I i I iters Wheaton vials
Aluminum heat block with holes dri I led to accept Wheaton vials
E-26
-------
and a dial thermometer
Hot plate capable of maintaining temperature of heat block at
60°C
Disposable glass transfer pi pets
SmaI I propane torch
Dial thermometer with appropriate range
* Procedure
1. Mark sample number near top of empty vial with permanent marker.
2, Record sample number in notebook.
3, Transfer approximately 5 mi I I i I iters of sample into vial using
transfer pi pet.
4, Insert vial into heat block so that sample number shows.
5, Let equilibrate for 3 to 5 minutes.
6, Pass propane torch across top of vial three or four times.
7, Record in notebook if sample ignites (flames) or pops.
8. As a final check on flammabi I ity, turn off the hood and pass the
propane torch across the top of the vials once more. Note
results and turn the hood on again.
9, Designate samples as follows:
Flammable--Sample pops and/or flames briefly.
Flame sustain ing--Sample sustains flame.
Nonflammable--Sample does not pop or flame.
Cyan ide--
Note: Only samples with a pH of 4 or higher will be tested for cyanide.
* Equipment
32-mi I I i I iters Wheaton vials with plastic caps
Disposable glass transfer pi pets
Disposable tongue depressors
E-27
-------
Cyantesmo test paper (Macherey-Nagel)
Dropping bottle of concentrated sulfuric acid
Drager hydrogen cyanide low range detector tubes and sampling
pump
Procedure--Cyanide Test Paper
1. Mark sample number on empty vial with permanent marker.
2, Record sample number in notebook.
3, Transfer approximately 5 mi I I i I iters or 5 grams of sample into
vial using pi pet or tongue depressor.
4, Add 2 drops of concentrated ^$04. This step should be conducted
under a hood or with other precautions against the release of
cyanide gas.
5, Fold test paper strip over edge of vial so it is held in place
by vial cap and extends into sample. Do this quickly so that
any gas evolving is tested.
6, Cap vial and swirl to mix.
7, Look for blue stain immediately or after 15 minutes.
8, Record in notebook and on Analytical Report Sheet that this is
the paper test and report results as follows:
Negative cyanide--if no stain appears.
Positive cyanide--if blue stain appears.
Uncertain cyanide--if stain of other color appears; describe
sta i n.
9, Test positive and uncertain cyanide samples with detector tubes.
Procedure--Hydrogen Cyanide (HCN) Detector Tubes
1. Place new detector tube in sampling pump following manufacturer's
instructions.
2, Mark sample number on empty vial with permanent marker.
3, Record sample number in notebook.
4, Transfer approximately 5 mi I I i I iters of sample into vial using
p i pet.
E-28
-------
5, Add ^504 dropwise, with swirling between each addition, to bring
pH to 5 or lower. Proper precautions should be made for the
potential release of cyanide gas.
6. Place detector tube over acidified vial and take appropriate
number of strokes on the pump.
7, Look at detector tube scale to see if HCN has been detected.
8. Record in notebook and on Analytical Report Sheet that this is
the detector test and record results as follows:
Negative cyanide--if no reading on scale.
Positive cyanide--if scale shows reading; include numerical
read i ng.
Note: Ammonia, chlorine, hydrogen sulfide, and sulfur dioxide
may interfere with detector tube reading if present at
adequate concentration.
SuIfide--
Note: Only samples with a pH of 7 or higher will be tested for sulfide.
* Equipment
32-mi I I i I iters Wheaton vials with plastic caps
Lead acetate test paper
Disposable Pasteur glass transfer pi pets
Disposable tongue depressors
Dropping bottle of concentrated hydrochloric acid (HCI)
* Procedure--SuIfide Test Paper
1. Mark sample number near top of empty vial with permanent marker.
2, Record sample number in notebook.
3, Transfer approximately 5 mi I I i I iters or 5 grams of sample into
vial using disposable pi pet or tongue depressor.
4, Quickly fold acetate paper strip over edge of vial and cap the
vial. Swirl liquid samples to wet paper.
5, Look for brown to black coloration on the test paper immediately
and again after 15 minutes.
E-29
-------
6, If no stain appears, add a few drops of HCI to the vial and cap
quickly. Swirl the contents and look for coloration Immediately
and after 15 minutes.
7, Record in notebook and on Analytical Report Sheet:
Negative H2$--if no stain appears.
Positive H£S—if brown or black stain appears.
Uncertain F^S—If stain of other color appears; describe
sta i n.
Calibration Procedures and Frequency--
Orion Model 701A pH/Mi I IIvolt Meter/Orion Redox Electrode 96-78--This
meter/electrode system is used to determine oxidation potential and is checked
three times dai ly, at the beginning, middle and the end of the working day.
The procedure used is as follows:
* Reagents
Electrode Filling Solution Orion 90-00-01 (proprietary mixture
of salts saturated with silver).
Check Solution A. Dissolve 4.22 grams potassium ferrocyanide
(l<4Fe(CN)5 . ^0) and 1.65 grams potassium ferricyannide
(K3Fe(CN)5) in 100 mi I I I I iters deionized water.
Check Solution B. Dissolve 0.42 grams potassium ferrocyanide
(K4Fe(CN)6 . 31^0), 1.65 grams potassium ferricyanide (l<3F
and 3.39 grams potassium fluoride (KF.2H20) in 100 mi I I i I iters
deionized water.
* Procedure
1, Ensure that the redox electrode is fi I led with the proper fi I I ing
solution.
2, Connect the electrode to the meter and set the meter function
switch to the millivolt mode.
3, Pour Check Solution A into a clean disposable beaker.
4, Place the electrode in the beaker and wait a short time for a
stable millivolt reading. The potential should be about 192
mi I I ivoIts.
5, Clean the electrode with a Kim-Wipe.
E-30
-------
6, Pour Check Solution B into a clean disposable beaker and take a
millivolt reading as soon as stable. The potential should be
about 250 mi I I ivolts.
7, If the Check Solution readings are not within ±10 percent of the
expected readings, clean the electrode using procedures in
Section 11 of this Plan.
Preventive Maintenance--
Orion Model 701A pH/mV Meter--Checkout and maintenance procedures given in
the manufacturer's manual wi I I be performed on a monthly basis and more
frequently if the analysts using the instrument identify any problem.
Orion Redox Electrode Model 96-78 or 97-78--Hazardous waste sample tend to
foul the electrode and cause the potential readings for test solutions to
become higher than acceptable. The routine electrode maintenance used includes:
1. Cleaning the electrode with a Kim-Wipe after every sample.
2, Reading the potential of two check solutions three times daily.
3, Changing the filling solution every day.
4, Cleaning the electrode with dionized water following the instructions
in the electrode manual when the Check Solutions show a problem.
5* Using a polishing strip on the sensing element when all other cleaning
methods fa i I.
References--
1. GCA/TechnoIogy Division. Qua I ity Assurance Project Plan: Onsite Character-
ization of Hazardous Waste Samples at Kingston, New Hampshire. Prepared
for Peabody Clean Industry, Inc. October 1981.
2, Princeton Testing Laboratory. Oxidation-Reduction Measurements Procedure
Field Test Kit. Princeton, New Jersey (undated).
3, Turpin, R. D., J. P. LaFornara, H. L. Allen and U. Frank. Compatibility
Field Testing Procedures for Unidentified Hazardous Wastes. In: National
Conference on Management of Uncontrolled Hazardous Waste Sites. Washington,
DC. October 1981 .
E-31
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APPENDIX F
PACKAGING, MARKING, LABELING, AND SHIPPING OF HAZARDOUS WASTE SITE SAMPLES
General Provisions
The basic sample types collected during hazardous waste site investigations
can be classified as follows: (1) environmental samples, (2) hazardous waste
site samples, and (3) hazardous waste/oil mixture samples.
Environmental samples are specifically exempt by Department of Transpor-
tation (DOT) regulations from hazardous categorization and may be shipped
according to procedures detailed later in this section. Other specific exemp-
tions may apply in other cases as with the use of special packaging for samples
[e.g., Label master, Inc.,* Package No. 38; Dow Chemical Company* Imbiber Pack
for shipment of Poison B, n.o.s. by United Parcel Service;* Air Shipment of 5
percent nitric acid in 25 ml ampoules (DOTE 8116); certain preservatives (April
11, 1979 and December 18, 1980 letters from Alan I. Roberts); and samples of
discharge subject to National Pollutant Discharge Elimination System (NPDES)
regulations (40 CFR 260.4a)].
If the shipper be I ieves that any sample contains a Department of Transpor-
tation regulated material, the sample must be packed and labeled according to
the requirements set forth in the DOT hazardous materials table shown in 49 CFR
172.101. When dealing with unanalyzed hazardous waste site samples, however,
the shipper wi I I usually not know if a sample contains a DOT regulated mate-
rial. If these samples cannot be classified as environmental samples or
exempted as previously specified, then they must be packaged, labeled and shipped
to ensure compliance with hazardous material transportation regulations.
The EPA recommended procedures** detailed later in this section meet the
DOT standard requirement for all packages as specified in 40 CFR 173.24. In
general, these standard requirements are as follows:
*Mention of the name of a particular corporation or product is not an endorse-
ment of that corporation or product.
**From National Guidance for Compliance with Department of Transportation
Regulations in the Shipment of Environmental Laboratory Samples, March 6, 1981
signed jointly by Deputy Assistant Administrators for Water Enforcement,
Drinking Water, Monitoring and Technical Support, and Water Regulations and
Standards.
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Genera I Packag i ng Requ i rements--
Each package used for shipping hazardous material s . . ..shall be so designed
and constructed, and its contents so limited, that under conditions normally
incident to transportation:
1. There wi I I be no significant release of the hazardous material
to the environment;
2, The effectiveness of the packaging wi I I not be substantially
reduced; and
3, There wi I I be no mixture of gases or vapors in the package which
could, through any credible spontaneous increase of heat or
pressure, or-through an explosion, significantly reduce the
effectiveness of the packaging.
General Packaging Requirements; Air Shipments--
In addition, shipments by air must also meet the requirements of 49 CFR
Section 173.6:
1 each package must be designed and constructed to prevent
leakage that may be caused by changes in altitude and temperature
during air transportation.
2. Inner containers that are breakable (such as earthenware, glass,
or brittle plastic), must be packaged to prevent breakage and
leakage under conditions normally incident to transportation.
These completed packages must be capable of withstanding a 4
foot drop on to sol id concrete in the position most I ike Iy to
cause damage. Cushioning and absorbent materials must not be
capable of reacting dangerously with the contents ....
3, For any packaging with a capacity of 110 gal Ions or less con-
taining liquids, sufficient ullage* must be provided to prevent
liquid contents from completely filling the packaging at 130°F
(55°C). 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 Ib/sq in. or no
less than the sum of the absolute vapor pressure of the contents
at 130°F (55°C) and the atmospheric pressure at sea level,
whichever is greater.
4. Stoppers, corks, or other such friction-type closures must be
held securely, tightly and effectively in place with wire, nylon
reinforced 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 sub-
stantial changes in temperature or pressure.
"Ullage is the gas/air space at the top of the bottle.
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General Transportation Requirements--
Transportation of samples is also regulated by DOT. Environmental samples
may be shipped by any means available with consideration being given to the
holding time requirements of 40 CFR 165. Unanalyzed samples from hazardous
waste sites may be transported by any rented car or truck, common carrier
truck, bus, rai I road, or by cargo only air carriers but they may not be trans-
ported by common carrier passenger air carrier. Prior arrangements with air
cargo companies may facilitate shipment. DOT regulations do not apply to
transportation by any government owned or operated vehicle, including aircraft;
however, EPA personnel will use the packaging procedures described below except
when a Bi I I of Lading with certification form is not required (see "Shipping
Papers").
Packaging, Marking, Labeling Requirements for Environmental Samples
Samples judged to be environmental samples should be packaged and shipped
by the following EPA recommended procedure:
1. Sample volume should be limited to the quantity necessary to conduct
the requisite analysis and the smallest appropriate container should
be 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 friction-type closures,
they must be held securely in place with wire or nylon reinforced
tape.
4, Samples which by EPA approved analytical methods are required to be
preserved with ice should be placed in sturdy plastic bags or con-
tainers which can be sealed to minimize ice water leakage. When dry
ice is used to preserve plant or animal tissue and the package is
to be offered for transportation by air, the packaging must be
designed and constructed to permit the release of carbon dioxide gas.
The air carrier should be notified well in advance of shipment. The
package should be marked "carbon dioxide, solid" or "dry ice" and
"frozen diagnostic specimens."
5, Shipping containers --A I I sample containers are to be placed inside a
strong outside shipping container. A metal picnic cooler (ice chest)
lined inside with hard plastic complies with the DOT drop test
requirement.* Care must be taken to secure the drainage hole at the
bottom of the cooler so that if a sample container or an ice bag
leaks, the contents cannot escape the shipping container through the
drain hole. The container should also be taped shut to achieve as
tight a seal as possible around the I id to prevent leakage should the
container be aceident Iy turned over.
"Tests conducted by the NEIC show that these coolers pass the 4-foot drop test.
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6. Glass containers--The container's screw-type lid must be tightened
before it is placed in the shipping container. In the shipping
container glass bottles should be separated by cushioning or absorbent
material (e.g., styrofoam, blotting paper or newspaper) to prevent
contact with other hard objects and prevent breakage. For example, a
I-gal I on glass bottle (organic sample) can be placed between two
carved out styrofoam sheets which secure the bottle at the top and
bottom. Small glass bottles (volatile organic samples) can be placed
inside a I-quart plastic cubic container with screwtype lids to
minimize breakage and contain leakage.
7, Plastic containers--Polyethylene bottles or cubic containers do not
require cushioning materials to prevent breakage but do need to be
protected from puncture by sharp objects. Caps are to be tightly
screwed on before the plastic containers are placed in the shipping
conta iner.
8. Ice can be placed in separate sealed plastic bags, or in large-mouthed
plastic cubic containers with screwtype lids. As an alternative,
sample bottles and ice can be placed together in a large sturdy plastic
bag which will provide an additional waterproof lining in the shipping
container. After all sample containers have been carefully arranged
and ice has been added, the plastic bag should be tightly closed with
wire, nylon reinforced tape or other positive means.
9, Place a copy of the chain-of-custody form in the shipping container
before closing and sealing it.
10. Close and seal the shipping container in the manner described above
under "Shipping Containers."
The shipping container must be marked "This END UP" and arrows indicating
the proper upward position of the container should be affixed. A sticker
showing the Agency program office's name and address must be placed on the
outside of the cooler.
Packaging, Marking and Labeling Requirements for Unanalyzed Samplings from
Hazardous Waste Sites
When a reasonable doubt exists as to sample class, function and labeling
requirements for sample transportation, DOT (49 CFR 173.2) indicates that the
material should be classified according to the following order of hazards:
1. Radioactive material
2, Poison A
3, Flammable gas
4* Nonflammable gas
5, Flammable I iquid
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6, Oxidizer
7, Flammable sol id
8. Corrosive material (Liquid)
9, Poison B
10. Corrosive material (solid)
11. Irritating materials
12, Combustible liquid (in containers having capacities
exceeding 110 gal Ions)
Samples taken onsite during an investigation of a hazardous waste facility,
blended waste oil facility, etc. are considered to be contaminated and hazardous;
they are to be handled as flammable liquid (or flammable solid) for shipping
and packaged accordingly. This is because the prioritized DOT classification
above established only radioactive material, Poison A, and gases as more haz-
ardous than flammable liquid. The possibility of radioactive materials in
samples is el iminated by the use of a radiation survey meter for personnel
safety when entering the site; it is extremely unlikely that Poisons A are
present on hazardous waste sites because most of them are gases or very volati le
liquids; gases are normally not sampled or shipped. Moreover, field flashpoint
testing to reduce the packaging requirements is both impractical and extremely
dangerous. Poison A packaging and shipping procedures are described later
in this section if they should be needed.
Packaging, Marking and Labeling Requirements for Flammable Liquid (or Flammable
Sol id) n.o.s.
1. Collect sample in an 8-ounce or smaller glass container with a
nonmetallic, Teflon-lined screw cap. Allow sufficient ullage
(approximately 10 percent by volume) so container is not full of
liquid at 130°F (55°C). This does not apply for samples collected
expressly for volatile organic analysis. If collecting a solid
material, the net weight must not exceed 1 pound.
2, Attach properly completed Sample Identification Tag to the sample
conta iner.
3, Tightly close sample container and place it in a 2-mi l-thick (or
thicker) polyethylene bag, one sample per bag. Sample tag should be
positioned for reading through the bag. Close the bag with a wire,
reinforced tape or other secure means.
4, Mark a metal can with the sample number and list the appropriate data
on a chain-of-custody form.
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5, Place the sealed bag inside the marked metal can with incombustible,
absorbent cushioning material (e.g., vermiculite or diatomaceous
[fuller's] earth) to prevent breakage, one sample per can. Pressure
close the can and use clips, tape or other positive means to hold the
lid securely, tightly and effectively closed.
6, Place one or more metal cans, surrounded with incombustible packing
material for stability during transport, into a strong outside container
such as a metal picnic cooler or a strong fiberboard box.
7, Place chain-of-custody form inside the shipping container before
closing and sea I ing.
8, Close and lock or seal shipping container.
9, Marking and Label ing--Use abbreviations only where specified. Using
the stickers prepared for this purpose or by hand printing, place the
following information on the shipping container: laboratory name and
address, "Flammable Liquid, n.o.s. ,* UN 1993", (if solid, use "Flam-
mable Solid, n.o.s., UN 1325"), "Limited Quantities" or "LTD. QTY.",
"This end up" or "This side up" and arrows. Also on the outside of
the container place the following labels: "Cargo Aircraft Only,"**
"Flammable Liquid" or "Flammable Solid" ("Dangerous When Wet" label
should be used if the solid has not been exposed to a wet environment).
10. Shipping Papers—Use abbreviations only where specified below.
Complete the Bill of Lading and sign the certification statement (if
the carrier does not provide one use the standard industry form) with
the following information in the order listed. A form may be used
for more than one shipping container (see attached examples).
"Flammable Liquid, n.o.s., UN 1993" (or Flammable Solid, n.o.s.,
Flammable Solid, UN 1325" as appropriate, "Cargo Aircraft Only'',**
"Limited Quantities" or LTD. QTY.," "Net Weight " or "Net Volume "
by item, if there is more than one sample can in the shipping container
(e. g., "24 at 6 oz. " rather than "144 oz.").
11. A team member must accompany shipping container(s) to the carrier
and, if required, open outside container(s) for carrier inspection.
*Us ing "Flammable" does not convey the certain knowledge that a sample is or
group of samples are in fact flammable, or indicate how flammable they are; it
is, rather, intended to prescribe the class of packaging in order to comply with
DOT regulations; "n.o.s." means not otherwise specified.
**Use this label only if the total quantity in the package exceeds 1 quart liquid.
Maximum net quantity in each package cannot exceed 10 gallons for flammable
liquids and 25 pounds for flammable solids.
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Packaging, Marking, Labeling, and Shipping Requirements for Flammable Liquid,
Corrosive, n.o.s.
If a sample exhibits corrosive properties, it must be packaged and shipped
as Flammable Liquid, Corrosive, n.o.s. RCRA defines an aqueous solution as
corrosive if the pH is <2 or >_12.5. DOT does not specify pH limits but uses
criteria based on a materials ability to produce skin rash or corrosion on
steel. Shipping requirements for materials that are corrosive are as follows:
1. Collect the sample in a I-quart glass container and close it with a
nonmetallic, Teflon-lined screw cap. Allow adequate ullage (about 10
percent by volume) so the container wi I I not be I iquid fulI at 130°F
(55°c).
2, Attach a properly filled out sample identification tag to the sample
conta iner.
3, Place the quart container inside a 12B fiberboard box with incombus-
tible, absorbent cushioning material (vermiculite or diatomaceous
earth). Polyethylene bags are not used for quart corrosive sample
bottles. Use tape to close the box, apply both "Flammable Liquid"
and "corrosive" labels and mark box "Flammable Liquid, Corrosive,
n.o.s., UN 2924," the laboratory name and address, "This side up" or
"This end up" and arrows.
4. Place the fiberboard box(es), surrounded with sufficient additional,
incombustible, absorbent cushioning material to absorb the contents
of broken containers, into a strong shipping container as previously
described.
5, Place a properly filled out chain-of-custody record form in the
shipping container; close and lock or seal the container.
6, A team member must accompany shipping container(s) to the carrier
and, if required, will open-outer container for verification of
inside packaging by the carrier's agent.
Packing , Marking, Labeling and Shipping Requirements for Samples Classified as
Poison A
Samples suspected of containing one of the liquids classified by DOT as
Poison A must be shipped in conformance to the following specifications (49 CFR
173.328):
1. Collect the sample in a polyethylene or glass container which has an
outer diameter smaller than the valve hole of a DOT Spec. 3A1800 or
3AA1800 metal cylinder for 2-25 pressurized gas. Allow sufficient
ullage (about 10 percent by volume) so it is not liquid-full at 130°F
(55°c). Seal the sample container as appropriate.
F-7
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2, Attach a properly filled out sample Identification Tag to the sample
container.
3, Using a string or flexible wire attached to the neck of the sample
container, lower it into a metal cylinder (DOT Spec. 3A1800 or
3AA1800) which has been partly filled with incombustible, absorbent
loose packing material (vermiculite or diatomaceous earth). Fill the
cyl inder to the valve hole with more of the packing material using
care to assure sufficient packing between the sample container and
the sides, bottom and top of the cylinder to prevent breakage. Drop
the string or wire into the valve hole. Use one cylinder for each
sample of Poison A.
4. Install the cylinder valve, use 250 ft-lb of torque (for a I-inch
opening) and replace the valve protector on the cylinder using Teflon
tape.
5, Marking and labeling the cyl inder--Use abbreviations only where
specified. Place the information below on the side of the cylinder
or on a metal tag wired to the valve protector. Use hand printing or
prepared labels.
"Poisonous* liquid, n.o.s., NA 1955" or "poisonous gas, n.o.s., NA
1955," laboratory name and address.
Place a "Poisonous Gas" label on the cylinder. A "Poisonous Liquid"
label may not be used, even if the sample is liquid.
6, Cyl inders may be shipped as is or several may be packed in an overpack.
A properly filled out chain-of-custody record form must be placed in
the shipping container or must otherwise accompany the shipment.
7, Mark and label the shipping container as follows: Use the same
labels and printing as on the cylinder (see No. 5 above) and in
addition mark the container "Laboratory Sample," "Inside Packages
Comply with Prescribed Specifications," and "THIS SIDE UP" or "THIS END
UP" and arrows should be placed on the outside in an appropriate
location.
8. Shipping papers--Complete the Bill of Lading and complete and sign
the certification statement (if the carrier does not provide one, use
the standard industry form). Use the following information in the
order given. A form may be used for more than one shipping container;
use abbreviations only as indicated.
*"poisonous" does not convey the certain knowledge that a sample is in fact
poisonous, nor how poisonous it may be; it is, rather intended to establish the
class of packaging being used to comply with DOT regulations.
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"Poisonous liquid, n.o.s., Poison A, NA 1955" or "Poisonous gas,
Poison A, n.o.s., NA 1955," "Limited Quantity" or "LTD QTY" "Lab-
oratory Samples," "Net Weight " or "Net Volume " (of
hazardous contents) by cylinder, if more than one cylinder is con-
tained in a shipping container and "Poison A" for hazard class. The
net weight or net volume must be placed just before or after the
"Poisonous liquid, n.o.s., NA 1955" or "Poison gas, n.o.s., NA 1955"
marking.
9. Materials classified and packed as Poison A may not be Shipped by
nongovernment aircraft. Unless samples are driven to the laboratory,
a team member must accompany the shipping container(s) to the carrier
and will, if required, open the shipping container for inspection
of the contents.
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