9285.9-26A
EPA540/R-94/107
PB95-963214
MRS DOCUMENTATION RECORD TRAINING
Site Assessment Branch
Hazardous Site Evaluation Division
Environmental Protection Agency
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Documentation Record Training Course Agenda
DAY 1--Morning
Duration
Section 1: Introduction
0:15 -Trainers/attendees introduction
0:20 -Pre-test
0:10 -The role of the documentation record in site assessment
0:10 -Introduction to guidance materials
0:15 -Break
Section 2: Review and organization of site information
0:15 -Getting started
0:15 -Organization of site information
0:15 -Preliminary HRS scoring
0:15 -Identifying data gaps and major issues
0:15 -Break
Exercise 1: Review and organization of site information
1:00 -Organize site information by pathway and list sources (references provided)
0:30 -Summarize pathways not evaluated (cover sheet)
1:00 Lunch
DAY 1-Afternoon
Duration
Section 3: Writing the documentation record
0:10 -Selecting a format
0:10 -Documentation requirements
0:10 -References
0:10 -Common problem areas
0:10 -The site summary
0:10 -Assembling the completed HRS package
0:15 -Break
Exercise 2: Documentation record writing
1:00 -Characterize sources (section 2.2)
0:15 -List hazardous substances (section 2.4.1)
0:45 -Calculate source hazardous waste quantities (section 2.4.2)
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DAY 2-Morning
Duration
Section 4: Overview of the NPL listing process
0:05 -Regional quality control
0:05 -Headquarters quality assurance review
0:05 -Proposal to the NPL and public comment period
0:05 -NPL listing
Exercise 3: Quality assurance and public comment review
0:45 -Review ground water pathway description (section 3.0)
0:15 -Break
0:30 -Review likelihood of release (section 3.1)
0:30 -Review waste characteristics (section 3.2)
0:30 -Review targets (section 3.3)
0:15 -Break
Conclusion
0:20 -Post-test
0:20 -Pre-test/post-test review
0:20 -Questions and answers
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Section 1
Introduction
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The Site Assessment Process
Discovery
CERCLI5
Preliminary
Assessment
(PA)
Site
Inspection
(51)
Hazard
Ranking
System
Score
Site Evaluation Accomplished
(Information Provided to States and
Other Regulatory Authorities)
National
Priorities
List (NPL)
Listing
•(Removal and Enforcement Action May Occur at Any Stage
Section 7, Page 1
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The NPL Listing Process
EPA region identifies site as NPL candidate.
Region develops MRS scoring package.
EPA region conducts QC review and submits scoring package
to EPA HQ.
EPA HQ conducts QA review, and site is proposed to the NPL.
Site undergoes 60-day public comment period, and EPA HQ
evaluates and responds to comments.
Site listed as final on the NPL, dropped, or reproposed.
90-day period to enter legal challenge to listing of the site.
Section 7, Page 2
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The MRS Scoring Package
MRS documentation record (hard copy/disk).
MRS scoresheets (hard copy/disk; from PREscore).
Complete copies of references and maps.
RCRA status documentation or aggregation memo, if applicable.
NPL site narrative summary.
Section 1, Page 3
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The Documentation Record
Explains and records the EPA's basis for assigning the MRS site
score.
Is available for public review and comment.
Must be legally defensible.
Section 1, Page 4-
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Introduction to Guidance Materials
MRS rule: 40 CFR 300, Appendix A.
MRS Guidance Manual: Interim Final, November 1992.
Regional Quality Control Guidance for NPL Candidate Sites,
December 1991.
MRS preliminary resolutions.
WordPerfect File: electronic documentation record format.
PREscore Users Manual and Tutorial, Version 2.0, July 1992.
Section 1, Page 5
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Section 2
Review and Organization of
Site Information
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Guidance on MRS Package Preparation
Please turn to section 3.1, page 21, of
the MRS Guidance Manual.
Section 2, Page 1
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The Task
What you start with...
What you deliver..
Cover Sheet
Scoring Sheets
Documentation
Recurd
References
Section 2, Paae 2
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Bringing Order Out of Chaos
This briefing is organized around the following tasks:
A. Read all site information.
B. Take notes and organize them by source or pathway,
C. Keep a running score.
D. Identify sources and significant pathways.
E. Gather maps and diagrams.
F. Identify MRS data gaps.
When you document a site, you'll move back and forth
between these tasks.
Section 2, Page 3
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Read All Site Information
Start off with the PA and SI reports to get a sense of:
- What has been done?
- How well it has been done?
- What is important about the site?
Read all of the PA and SI references.
- The PA and SI narrative reports are secondary references,
You'll need to quote from the primary references.
Review the CERCLA file.
- Are there useful tidbits that were missed by the PA and
SI?
- Is there contradictory information that must be resolved?
Section 2, Page 4-
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Take Notes and Organize Them
Horror Story 1:
The pile of documents you've read is 28" deep. Somewhere
in there is a vital fact you read, but you can't remember just
where. What do you do?
- Dummy through the documentation without it.
- Read everything again until you find it.
- Vent your frustration on an unsuspecting coworker.
Horror Story 2:
So you've scribbled 43 pages of notes to avoid horror
story 1. Now how do you pull it all together into an HRS
documentation record?
Section 2, Page 5
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Take Notes and Organize Them (Continued)
Organize your notes by HRS source and by HRS pathway and
factor.
- File cards that can be sorted.
- Blank copy of the HRS documentation record.
- PREscore or an electronic database.
Include a note on where the information came from, both
document and page number.
- You'll also need a clean copy of each reference you expect
to use.
Include a note on the quality of the information.
Keep notes on any discrepancies or conflicting information.
Section 2, Page 6
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Take Notes and Organize Them (Concluded)
3.3.1 Nearest Well
bend in
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Section 2, Page 7
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Keep a Running Score
Back-of-the-envelope scoring will focus your attention on the
MRS implications of the information you are gathering.
- Is a number "at risk" because it lies near a breakpoint on
an MRS table?
- The more important an item of information is to the score,
the firmer the quality of information should be.
- "Killer issues" are those that can drop the score under
28.50.
The attempt to score the site will also focus attention on
what information is still missing.
Section 2, Paqe 8
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Identify Sources and Significant Pathways
Identify all known sources and characterize each, insofar as
data are available.
- Source characterization requires considerable information.
Be sure to take notes on all the information required in the
MRS documentation record.
Please turn to page 43 of the MRS
Guidance Manual.
Section 2, Page 9
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Identify Sources and Significant Pathways
(Concluded)
Focus your efforts on the significant pathways
Please turn to section 2.2, page 11, of
the HRS Guidance Manual.
Please turn to section 3.4, page 31, of
the HRS Guidance Manual.
Some SI reports have missed the most significant pathway.
Section 2, Page 10
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Gather Maps and Diagrams
The variety and quality of maps will be discussed later.
For now, photocopy maps or diagrams from technical
reports.
- Sources, the site, geological formations, surface water
bodies, locations of targets.
Obtain other maps such as USGS 7.5-minute topographic
maps, tax assessors parcel maps, geological cross sections,
and Wetland Inventory Maps.
Obtain aerial photographs to show historical and current site
conditions.
Section 2, Page 11
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Identify MRS Data Gaps
Review each MRS factor for completeness of documentation
Discussion question:
What elements of information will you need to have on
hand to document the distance to the nearest well?
Section 2, Page 12
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Identify MRS Data Gaps (Concluded)
Are any data of inadequate quality?
- Pay particular attention to the significant pathways and to
data that are important to the site score.
- Look at all data against the breakpoints in the MRS tables.
- Look for conflicting assertions or for differences in the
numbers that are reported.
- Review the analytical data carefully for all critical samples.
The identification of data gaps will focus further information-
gathering.
Section 2, Page 13
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Site Eligibility Issues
The issue of site eligibility should have been resolved during
the PA and the SI.
Please turn in the Regional Quality
Control Guidance to section 2.1, page 9.
States, tribes, and contractors: If you identify an eligibility
issue, contact your EPA SAM immediately.
Section 2, Page 74
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MRS Scoring Issues
Sometimes the site conditions simply don't fit the MRS or the
MRS guidance very well.
When this happens, the procedure is:
- Discuss the issue in-house with MRS experts.
- Discuss the issue with your EPA regional contact.
- The EPA region can present the issue to the EPA HQ
regional coordinator.
- If the issue is still not resolved, the region can prepare an
Issue Submittal Form (Regional QC Guidance Manual,
appendix C). The EPA MRS Core Group meets monthly to
resolve issues.
Section 2, Page 15
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In Summary...
Read, organize, rough out scores, and identify data gaps,
- Develop a plan for closing the data gaps.
Watch for eligibility issues that haven't been caught.
Ask for guidance for special cases.
Section 2, Page 16
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Section 3
Writing the Documentation Record
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Notes on the Final Product
The MRS score begins at zero and rises as you present evidence
that supports a higher score.
Every assertion of fact must be referenced and every
professional judgment presented with a clear, documented
rationale.
You are writing for the general public...which includes everyone
from local citizens to lawyers and consulting engineers.
Weave the facts together into a "story" that states EPA's case
for placing the site on the NPL.
Section 3, Page 1
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Elements of Writing
A. Choose a documentation record format.
B. Describe and present sources.
C. Describe and present pathways.
D. Weave technical information and MRS factors
E. Choose and prepare maps and figures.
F. List and cite references.
G. Copy and attach references.
Section 3, Page 2
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Choose a Documentation Record Format
The WordPerfect format:
Spell checker.
Comment/Instruction blocks.
Modifications to the WordPerfect format.
Other formats:
PREscore with a supplemental WordPerfect document,
Section 3, Page 3
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Describe and Present Sources
Use terminology for source type, description, and
containment directly from the MRS rule and the MRS
Guidance Manual.
Assign a name and stick with it.
Describe the boundaries of the source and show locations on
a map.
List hazardous substances, pollutants, or contaminants.
Describe source containment using MRS terminology.
Summarize the information for the appropriate tiers for
hazardous waste quantity.
Discuss additional potential sources that were not quantified
in the Source Description section.
Section 3, Page 4
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Describe and Present Pathways
Document all significant pathways.
Qualitatively describe the rationale for not evaluating the
other pathways, components, or threats.
Use the WordPerfect format and MRS guidance to help you
present information.
Section 3, Page 5
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Weave Technical Information and HRS Factors
Translate report information into HRS terms.
Use HRS terminology and reference the HRS rule frequently.
• Carefully document rationale behind professional judgements.
• Be technically accurate, but remember you're writing for the
layman.
• Provide calculations for HRS factor values in text or as
references (e.g., hazardous waste quantity, target
apportionment).
• Do not hide, conceal, or deliberately omit information,
especially if it conflicts with information in another reference.
Section 3, Page 6
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Choose and Prepare Maps and Figures
Refer to appendix D of the Regional QC Guidance.
Choose a base map.
Maps should be reproducible, legible, and to scale.
Use USGS topographic maps as references and submit
originals with the documentation record.
Present pathway-specific maps.
Refer to maps within the text of the documentation record
Aerial photographs may be useful.
Section 3, Page 7
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List and Cite References
List only the references you use In the documentation record.
Be sure to use all references that EPA might need to
justify listing the site.
Every assertion of fact must be referenced in the
documentation record. Example: (Ref. 9, p. 43; Ref. 24,
p. B-158).
Use a recognized style for the list of references in the
documentation record.
The MRS rule is always Reference 1 and the Superfund
Chemical Data Matrix (SCDM) is always Reference 2.
References should be numbered sequentially as they appear
in the documentation record.
Section 3, Page 8
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Copy and Attach References
For publications and reports, copy the title page, the table of
contents, and the full chapter or section cited to provide the
reader with the context from which the statement was made
Attach a copy of each reference unless it is widely available.
Submit copies free of all hand-written notes or
comments.
• Keep a clean copy of each reference free of ink and
highlighters for future reproduction.
Section 3, Page 9
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Common Problem Areas
Source aggregation.
Referencing.
Maps and figures.
Aquifer interconnection
Analytical data quality.
Background levels.
Section 3, Page 10
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Prepare an NPL Site Summary
The NPL site summary is a one-page summary of the site that
accompanies the MRS package. It is not a part of the documentation
record, but is what the public most frequently sees.
• Prepare the NPL site summary last.
• Refer tc appendix E of the Regional QC Guidance for
directions on preparing NPL site summaries.
Refer to appendix F of the Regional QC Guidance for
directions on naming NPL sites.
Section 3, Page 17
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Section 4
Overview of the NPL Listing Process
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Overview of the NPL Listing Process
SITE DISCOVERY
MRS
Documentation!
Record
I
CERCLIS
PA
I
SI
MRS
SCORE
NPL
Regional QC Review
EPA Headquarters QA Review
Proposed Listing to the NPL
Final Listing to the NPL
Section 4, Page 1
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Regional Quality Control Review
The HRS Package QC Checklist
The Regional NPL Coordinator:
Reviews NPL eligibility issues.
Checks accuracy.
Evaluates documentation and ensures legibility.
Ensures that every statement of fact is referenced.
The Regional Branch Chief:
Signs and facilitates first HRS package submittal to
Headquarters.
Section 4, Page 2
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Headquarters Quality Assurance Review
After regional QC is complete, the EPA region submits the package
(with references) to EPA HQ and the package undergoes an in-
depth QA review.
The purpose of the QA review is to :
ensure correct the application of the MRS rule and guidance to
the site-specific information;
ensure that the MRS package contains all necessary information
and is appropriately presented to support a successful EPA
rulemaking; and
ensure accuracy and consistency in MRS application among the
EPA and State offices participating in scoring sites.
Section 4, Page 3
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Headquarters Quality Assurance Review (Continued)
The QA review identifies both minor and major issues.
Minor issues include:
Mathematical errors.
Incorrect referencing.
Illegible photo copies.
Typographical or transcription errors.
Poor map quality.
Major issues include:
Technical errors due to inadequate PAs or Sis.
Background samples and site attribution.
Similarity of samples.
Documentation of observed release criteria.
Geologic description and definition of aquifers.
Documentation of targets.
Interpretation of guidance.
Section 4, Page 4
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Headquarters Quality Assurance Review (Concluded)
At the conclusion of the review, a QA letter is drafted.
The purpose of the QA letter is to provide a list of factors to be
settled so that the site can be proposed to the NPL.
The QA review is reiterative; several rounds of QA may occur and
several QA letters may be drafted.
Sites that score > 28.5 are proposed to the NPL.
Section 4, Page 5
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Site Proposal to the NPL
Sites are placed on the NPL in a two-step process:
• First, sites are proposed and public comments are solicited.
60-day public comment period.
EPA HQ evaluates and responds to comments, watchful of
new information or alternate interpretations that could
affect the site score.
Historically, 60% of the proposed sites receive comments
from the public.
• Second, sites still meeting the scoring criteria after
consideration of comments are listed in a Final Rule.
90-day period to initiate a legal challenge to final listing.
Section 4, Page 6
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Site Proposal to the NPL (Concluded)
EPA intends to issue four Federal Register (FR) notices per year.
Two proposals (February and August).
Two finals (November and May).
The process is based on continuous package submission;
review is done on a first-come, first-served basis.
Section 4, Page 7
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MRS DOCUMENTATION RECORD
TRAINING
EXERCISES 1-3
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Exercise 1: Review and Organize Site Information
Review References 1 through 6, attached to the back of the enclosed documentation
record. Remember, start by reviewing the SI (Ref. 4) to get an overview of the site.
During your review, make notes on facts that characterize sources or that could be
used to document factor values. Create a list of sources, with notes on each, and a
separate list of notes for each of the four pathways. Be sure to record the reference
number and page number for each fact noted. Divide these tasks among the merrU ^rs
of your group, if you like.
The attached references have been summarized. Any missing references (Ref.3) or
reference sections (Ref.4, appendices A, B, and C) may be assumed to be extant and
valid.
Exercise 2: Documentation Record Writing
Use References 1 through 6, attached, to complete the Source Characterization
section of this documentation record (cover pages and sections 2.2 through
2.4.2.1.5). As you move through each section of the documentation record, refer to
the cross-referenced copy of the WordPerfect format. This format contains directions
(in shaded blocks) and refers to appropriate sections of the SAB guidance materials
(in italics).
Exercise 3: Quality Assurance and Public Comment Review
The class will be divided into three groups for this exercise; the regional QC team, the
Headquarters QA team, and the PRP public comment team. All three teams will
critically review the completed sections of this documentation record (sections 3.0
through 3.3.4, ground water pathway).
The focus of each team's review will be as follows:
• Regional QC team: Ensure that all of the requirements contained in the
Regional QC Guidance Manual have been met. Complete the MRS package QC
checklist (p. 5) found in the manual.
• Headquarter QA team: Ensure that the HRS rule has been properly interpreted
and applied, and that the documentation record and attached references
legitimately support each factor value.
• PRP public comment team: Identify all errors and shortcomings in the
documentation record. Try to find "killer issues" that would prevent the EPA
from listing the site.
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HRS DOCUMENTATION RECORD—REVIEW COVER SHEET
Name of Site:
Contact Persons
Site Investigation:
(Name) (Telephone)
Documentation Record:
(Name) (Telephone)
Pathways, Components, or Threats Not Evaluated
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HRS DOCUMENTATION RECORD
Name of Site:
EPA Region: Date Prepared:
Street Address of Site:
County and State:
General Location in the State:
Topographic Map:
Latitude: Longitude:
Scores
Air Pathway
Ground Water Pathway
Soil Exposure Pathway
Surface Water Pathway
HRS SITE SCORE
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WORKSHEET FOR COMPUTING HRS SITE SCORE
1. Ground Water Migration Pathway Score (S8W)
(from Table 3-1, line 13)
2a. Surface Water Overland/Flood Migration Component
(from Table 4-1, line 30)
2b. Ground Water to Surface Water Migration Component
(from Table 4-25, line 28)
2c. Surface Water Migration Pathway Score (S.w)
Enter the larger of lines 2a and 2b as the pathway score.
3. Soil Exposure Pathway Score (S.)
(from Table 5-1, line 22)
4. Air Migration Pathway Score (SJ
(from Table 6-1, line 12)
5. Total of Stw2 + S.w2 + S.2 + S.2
6. HRS Site Score Divide the value on line 5
by 4 and take the square root
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REFERENCES
Reference
Number Description of the Reference
1. U.S. Environmental Protection Agency, Revised Hazard Ranking System.
Final Rule, 40 CFR 300, App. A, December 14, 1990.
2. U.S. Environmental Protection Agency, Superfund Chemical Data Matrix, 9
March 1993, 833 pp., p. B-ll, B-15, and B-17. (See following pages.)
3. U.S. Department of the Interior, Geological Survey. 7.5 Minute
Quadrangle Topographic Map; Podunk East, 1952, photorevised 1976; Podunk
West, 1958, photorevised 1976; Podunk, 1953, photorevised 1976.
4. Data-Quik Consultants, Inc., Site Investigation of A2Z Drycleaner's
Site, 1989, 72 pp.
5. Jones, David; former employee of A2Z Drycleaners. Telecon with Fred
Fieldquv, Data-Quik Consultants Inc., July 3, 1992.
6. Smith, Robert; former employee of A2Z Drycleaners. Telecon with Fred
Fieldquv, Data-Quik Consultants Inc., July 5, 1992.
7. Wermchopper, Sandy, Soil Survey of Podunk County. State Agricultural
Extension Service, 1984, 322 pp.
8. Facht, Art E., and Rex, T., The Geology and Paleontology of Podunk
County, the State Consortium of Learned Scholars and Animal Husbandry,
1894, 392 pp.
9. Clamper, Kelly, Podunk Well and Septic Service, Telecon with Fred
Fieldquv, Data-Quik Consultants, Inc., June 31, 1992.
10. Gneisskopf, Cliff, The Geology of Podunk County, the State University,
Department of Geology, 1982, 319 pp.
11. Rooter, Sue R. , Supervisor, Podunk County Sewer and Water Authority,
Interview with Fred Fieldquv, Data-Ouik Consultants, Inc.. June 17,
1992.
12. U.S. Dept. of Commerce, Bureau of the Census, 1990 Summary of Vital
Statistics; Podunk County, 150 pp., p.29.
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SD-Characterization and Containment
SOURCE DESCRIPTION
2.2 Source Characterization
Number of the source:
Name and description of the source:
Location of the source, with reference to a map of the site:
Containment
Gas release to air
Particulate release to air
Release to ground water
Release via overland migration and/or flood
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2.4.1 Hazardous Substances
Hazardous substance
Evidence
SD-Hazardous Substances
Source No.:
Reference
-------
SD-Hazardous Constituent Quantity
Source No.:
2.4.2. Hazardous Waste Quantity
2.4.2.1.1. Hazardous Constituent Quantity
Constituent
Quantity (pounds)
Hazardous Substance (Mass - S) Reference
sum: (pounds)
Hazardous Constituent Quantity Value (S)
-------
SD-Hazardous Wastestream Quantity
Source No.:
2.4.2.1.2. Hazardous Wastestream Quantity
Hazardous Quantity
Wastestream (pounds) Reference
sum: (pounds)
Hazardous Wastestream Quantity Value (W):
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SD-Volume
Source No.:
2.4.2.1.3. Volume
Dimension of source (yd3 or gallons):
References(s):
Volume Assigned Value:
2.4.2.1.4. Area
Area of source (ft2) :
Reference(s):
Area Assigned Value:
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SD-Source Hazardous Waste Quantity Value
Source No.:
2.4.2.1.5. Source Hazardous Waste Quantity Value
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SD-Characterization and Containment
SOURCE DESCRIPTION
2.2 Source Characterization
Number of the source:
Name and description of the source:
Location of the source, with reference to a map of the site:
Containment
Gas release to air
Particulate release to air
Release to ground water
Release via overland migration and/or flood
10
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2.4.1 Hazardous Substances
Hazardous substance
Evidence
SD-Hazardoua Substances
Source No.:
Reference
11
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SD-Hazardous Constituent Quantity
Source No.:
2.4.2. Hazardous Waste Quantity
2.4.2.1.1. Hazardous Constituent Quantity
Constituent
Quantity (pounds)
Hazardous Substance (Mass - Sl_ Reference
sum: (pounds)
Hazardous Constituent Quantity Value (S)
12
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SD-Hazardous Wastestream Quantity
Source No.:
2.4.2.1.2. Hazardous Wastestream Quantity
Hazardous Quantity
Wastestream (pounds) Reference
sum: (pounds)
Hazardous Wastestream Quantit_ Value (W)
13
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SD-Volume
Source No.:
2.4.2.1.3. Volume
Dimension of source (yd3 or gallons):
References(a):
Volume Assigned Value:
2.4.2.1.4. Area
Area of source (ft2):
Reference(s):
Area Assigned Value:
14
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SD-Source Hazardous Waste Quantity Value
Source No.:
2.4.2.1.5. Source Hazardous Waste Quantity Value
Source Hazardous Waste Quantity Value;
15
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SD-Characterization and Containment
SOURCE DESCRIPTION
2.2 Source Characterization
Number of the source:
Name and description of the source:
Location of the source, with reference to a map of the site:
Containment
Gas release to air
Particulate release to air
Release to ground water
Release via overland migration and/or flood
16
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2.4.1 Hazardous Substances
Hazardous substance
Evidence
SD-Hazardous Substances
Source No.:
Ref erenc-'
17
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SD-Hazardous Constituent Quantity
Source No.:
2.4.2. Hazardous Waste Quantity
2.4.2.1.1. Hazardous Constituent Quantity
Constituent
Quantity (pounds)
Hazardous Substance (Mass - S) Reference
sum: (pounds)
Hazardous Constituent Quantity Value (S)
18
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SD-Hazardous Wastestream Quantity
Source No.:
2.4.2.1.2. Hazardous Wastestream Quantity
Hazardous Quantity
Wastestream (pounds) Reference
sum: (pounds)
Hazardous Wastestream Quantity Value (W):
19
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SD-Volume
Source No.:
2.4.2.1.3. Volume
Dimension of source (yd3 or gallons):
References(B):
Volume Assigned Value;
2.4.2.1.4. Area
Area of source (ft2):
Reference(a):
Area Assigned Value:
20
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SD-Source Hazardous Waste Quantity Value
Source No. :
2.4.2.1.5. Source Hazardous Waste Quantity Value
Source Hazardous Waste Quantity Value:
21
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SD-Summary
SITE SUMMARY OF SOURCE DESCRIPTIONS
Containment
Source Hazardous
Source Waste Quantity Ground Surface Air
No. Value Water Water Gas Particulate
22
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GW-General
3.0 GROUND WATER MIGRATION PATHWAY
3.0.1 GENERAL CONSIDERATIONS
Soils underlying the site are of the Balderdash silt-loam series, a member
of the Spuria group. Spuria group soils are typic alfasols, developed in-
situ from unconsolidated alluvial parent materials. The Balderdash series
is characteristic of Spuric soils developed on level to gently sloping (less
than 3%) terrain. In the Balderdash, the A,, horizon extends to a depth of
8 to 12 inches, and is very dark gray to black in hue. The A,, horizon
overlies the A, horizon, which may extend to depths of 24 inches. The A,
horizon changes hue gradually with depth, fading from nearly black to green-
gray at its interface with the B horizon. The interface between the A,, and
A, horizon may be indistinct, and is usually absent if plowing or other
surface disturbance has occurred. The B through E horizons are relatively
undifferentiated, below the blanched spodic horizon; being a uniform gray-
green throughout. Typically, Balderdash soils extend to a depth of 4 to 5
feet, before grading into the parent material (Ref. 7, p. 14).
The shallowest aquifer underlying the site is an un-named, unconsolidated
alluvium. This alluvium is the parent material of the Balderdash soil, and
extends to a depth of approximately 30 feet, onsite (Ref. 4, p. 3-2; Ref. 7,
p.14; Ref 8, p.42; Ref 10, p.287, Fig. A). Groundwater occurs at a depth of
about 20 feet below the site, within the unconsolidated alluvium. (Ref. 4,
p. 3-2; Ref. 9; Ref 10, p.287, Fig. A).
Below the unconsolidated alluvium is the Sauber limestone. The Sauber
limestone formation is Cretaceous in origin, and contains numerous
fossilized dinosaur remains. This formation extends to a depth of
approximately 100 feet below land surface (Ref. 8, p. 42). Wells drilled in
the Sauber can yield water at rates of up to 10 gpm (Ref. 9). The Sauber is
an important regional source of water, especially for private wells (Ref 8,
p. 42; Ref. 9).
The Sauber limestone is underlain by the Leche de la Madre shale. This
formation is highly fractured (Ref. 8, p. 42). Wells drilled in a fracture
can yield water at rates of up to 25 gpm (Ref. 9). The Leche de la Madre
shale rests atop the Machtsnichts basalt. The interface of these two units
lies at a depth of approximately 200 feet below land surface throughout
Podunk County, except along Blackstone Ridge, where the Machtsnichts
formation extrudes above ground surface. The Machtsnichts basalt is
essentially impermeable, and extends to a depth of approximately 2,000 feet
below land surface throughout Podunk County (Ref. 8, p. 42; Ref. 10, p. 287,
Fig. A).
An onsite boring, conducted during the 1989 SI, confirms the depths of the
Sauber limestone, at 30 feet, and the Leche de la Madre shale, at 100 feet.
The total depth of this boring was 125 feet below ground surface.
Significantly, no clay layers or other confining units were encountered in
this boring (Ref. 4, p. 3-2, Fig. 1-1). Therefore, the three aquifers
underlying the site (the unconsolidated alluvium, the Sauber, and the Leche
de la Madre) may be considered a single hydrologic unit for HRS scoring
23
-------
purposes. These three aquifers can also be scored as a single hydrologic
unit based on the fact that they are interconnected through the Cross-
Border Quarry. The Cross-Border Quarry penetrates all the way down to the
Machtsnichts basalt and is 20 acres in area (Ref. 3; Ref. 8, p. 42; Ref 10,
Fig. A).
Aquifer/Stratum 1 (shallowest)
Aquifer/Stratum Name; Alluvium/Sauber/Leche de la Madre
Description; The alluvium extends from approximately 5 feet below ground
surface (below the soil) to a depth of 30 feet. The Sauber limestone
extends from 30 feet to 100 feet below ground surface. The Leche de la
Madre shale extends from 100 to 200 feet below ground surface, where it
meets the surface of the impermeable Machtsnichts basalt. Because the
alluvium, Sauber, and Leche de la Madre formations are interconnected
through the Cross-Border Quarry, and because no confining units separate
these three aquifers, they have been combined into a single hydrologic unit
for HRS scoring purposes.
References; 3, 4, 7, 8, 10.
24
-------
GW-Observed Release
3.1 LIKELIHOOD OF RELEASE
3.1.1 OBSERVED RELEASE
Aquifer Being Evaluated: Alluvium/Sauber/Leche de la Madre
Chemical Analysis;
Background Concentration
Sample ID
BGW1
Sample ID
BGW1
Top of Screened
20'
Hazardous
Substance
Vinyl Chloride
Interval
bgs
Concentration
ND
Date
3/17/89
Sample
Quantitation
Limit
l.OE -5 ppm
Reference
4, p. 4-1
Reference
4, p. 4-1
Contaminated Samples
Sample ID
MW1
Sample ID
MW1
Top of Screened
20'
Hazardous
Substance
Vinyl Chloride
Interval
bgs
Concentration
0.0002 mg/L
Date
3/17/89
Sample
Quantitation
Limit
l.OE -5 ppm
Reference
4, p. 4-1
Reference
4, p. 4-1
Attribution;
Vinyl Chloride was not detected in the ground water sample taken from BGW1,
which is located up-gradient (west) of all sources on site. Vinyl Chloride
was detected, above the SQL, in samples taken from MW1, which is located
down-gradient from all sources on site (Ref 4., p. 4-1, Fig 1-1).
Therefore, the Vinyl Chloride detected in MW1 is at least partially
attributable to the sources on this site.
Hazardous Substances Released
Vinyl Chloride
Ground Water Observed Release Factor Value: 550
25
-------
3.2 WASTE CHARACTERISTICS
3.2.1 Toxicitv/Mobility
Hazardous
Substance
Vinyl Chloride
PCE
Lead
Source
No.
None*
All
All
Toxicity
Factor Value
10,000
100
10,000
Mobility
Factor Value
1
0.01
0.01
Toxicity/
Mobility
10,000
1
100
2,
2,
2,
Ref .
p. B17
p. B15
p. Bll
* Vinyl Chloride was not demonstrated to be in any source, through analysis
of source samples. However, Vinyl Chloride is a degradation product of PCE,
which is present in all sources. The presence of Vinyl Chloride in a
release sample from MW1, above background, indicates that a hazardous
substance attributable to site sources has been released to ground water.
This constitutes an observed release to ground water, documented through
chemical analysis.
Toxicity/Mobility Factor Value: 10,000
26
-------
3.2.2 Hazardous Waste Quantity
Source Number
Source Hazardous
Waste Quantity
Value (Section 2.4.2.1.5)
GW-Hazardous Waste Quantity
Is source hazardous
constituent quantity
data complete? (yes/no)
1 (Sump)
2 (UST)
3 (Soil)
4 (AST)
102.5
20.0
0.44
60.0
NO
NO
NO
NO
Sum of Values: 182.94
3.2.3 Waste Characteristics Factor Category Value
Toxicity/Mobility Factor Value X Hazardous
Waste Quantity Factor Value: 1,000,000
(10,000 x 100 = 1,000,000)
Hazardous Waste Quantity Factor Value: 100
Waste Characteristics Factor Category Value: 32
27
-------
GW-Targets
3.3 TARGETS
Well
1
2
3
4
5
Level I Level II Potential
Distance Contain. Contain. Contain.
From Source Aouifer (Y/N) (Y/N) (Y/N) Ref.
3 -
2 -
3 -
1/4
0 -
4 mi. *
3 mi. *
4 mi. *
- 1/2 *
1/4 *
N
N
N
N
N
N
N
N
N
N
Y
Y
Y
Y
Y
11,
11,
11,
11,
11,
12
12
12
12
12
Well 1 = Podunk Municipal
Well 2 = West Mountain Village
Well 3 = East Mountain Village
Well 4 = Agua Peligroso Ranch
Well 5 = A2Z Cleaners
* All wells draw from the Alluvial/Sauber/Leche de la Madre aquifer.
28
-------
GW-Nearest Well
3.3.1 Nearest Well
Well: Agua Peligroso Ranch
Level of Contamination (I, II, or potential): Potential
If potential contamination, distance from source in miles: 1/4 (Ref. 11)
The closest well to the site is actually onsite, at A2Z Cleaners. But, this
well was closed in 1983, for reasons other than site-related contamination
(Ref. 11). Since no one uses this well any longer, the Agua Peligroso Ranch
well was scored as the nearest well.
Nearest Well Factor Value: 20
29
-------
GW-Level I Concentrations
3.3.2 Population
3.3.2.1 Level of Contamination
3.3.2.4 Potential Contamination
Distance
Cateaorv
3-4
2-3
0 - 1/4
# Connect 's.
13,025
35
3
Population
41, 680
112
9.6
Reference
11
11
11
; 12,
; 12,
; 12,
p-
P-
P-
29
29
29
Distance-We
Population
4,171
7
4
Value
Sum of Distance-Weighted Population Values: 4,182
The Podunk Municipal and East Mountain Village wells are in the 3-4 miles
distance category. The West Mountain Village well is in the 2-3 mile
category, and the Agua Peligroso Ranch well is in the 0 - 1/4 mile category
(Ref. 11). The number of hook-ups for each well was multiplied by 3.2
(persons/household) to estimate populations (Ref 12, p.29).
Potential Contamination Factor Value: 418
30
-------
GW-Resources
3.3.3 RESOURCES
Well Aquifer Resource Use Reference
None identified.
Resources Factor Value:0
31
-------
GW-Wellhead Protection Area
3.3.4 WELLHEAD PROTECTION AREA
Area Use Reference Value
None identified.
Wellhead Protection Area Factor Value: 0
32
-------
SUMMARY OF REFERENCES
REF
1.
2.
U.S. Environmental Protection Agency, Revised Hazard Ranking System,
Final Rule, 40 CFR 300, App. A, December 14, 1990.
U.S. Environmental Protection Agency, Superfund Chemical Data
Matrix, 9 March 1993, 833 pp., p. B-ll, B-15, and B-17.
See the following pages.
3.
U.S. Department of the Interior, Geological Survey. 7.5 Minute
Quadrangle Topographic Map; Podunk East, 1952, photorevised 1976;
Podunk West, 1958, photorevised 1976; Podunk, 1953, photorevised
1976.
Not provided with this exercise.
-------
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-------
4. Data-Quik Consultants, Inc., Site Investigation of A2Z Drvcleaner's
Site, 1989, 72 pp.
Pg. 1-2: The A2Z Drycleaners site occupies approximately 2 acres. The area
surrounding the site is primarily agricultural. The site consists
partially of a paved lot surrounded by a chain-link fence. There is
a wastewater treatment system on the west side of the facility. The
main building on-site is approximately 35,000 square feet and
contains the laundry wastewater clarifiers, the vehicle maintenance
area, two former dry cleaning areas, and other business operations.
See Fig. 1-1 for a schematic of the facility.
Pg. 1-3: The site is located in a topographic depression. The nearest
surface water body is the Podunk River, which is 5 miles south of
the site.
Pg. 1-4: The population within 2 miles of the site is sparse. There are 3
families living on a ranch approximately 1/4 mile from the site.
Pg. 1-6: Prior to construction of the facility in 1969, the site was
undeveloped. From 1969 to 1977 the current plant was operated as an
industrial laundry facility for Lincoln Industrial Services. On-
site laundry operations consisted of 60% water wash and 40%
drycleaning. In 1977, the facility was purchased by A2Z Drycleaners
and was operated as a central laundry facility for a number of
various industries. On-site laundry operations consisted of 50%
water wash and 50% dry cleaning during that this time. In 1983, A2Z
Drycleaners discontinued its dry cleaning operations and the
facility was closed.
Pg. 1-7: A2Z Drycleaners dry cleaned soiled work uniforms. Dry cleaning
operations consisted of 50% of the total laundry volume at the site.
The dry cleaning units were equipped with self-contained solvent
storage compartments for spent and reclaimed solvent. Spent solvent
recovery was accomplished through the use of vapor recovery,
multiple stage condenser stills, and diatomaceous earth filters.
Product PCE, contained in tanks, was piped directly into the dry
cleaning machine.
Pg. 1-8: Facility records indicate that the drycleaning operation utilized
approximately 2 gallons of water and detergent along with PCE
solvent per wash to remove water soluble stains. PCE was used at a
rate of approximately 60 gallons for 1,000 to 2,000 pounds of
laundry.
Pg. 1-10: Wastewater containing spent PCE and lead from the drycleaning
process was discharged into an on-site wastewater treatment system.
The on-site treatment system was designed to reclaim solvents and
remove particulates prior to the release of the wastewater into the
public sewer system.
Pg. 1-15: There is a sump next to the wastewater treatment system that is
designed to contain overflow from the system.
Pg. 1-16: The dimensions of the sump were measured as 20'x4'x4'.
Pg. 1-17: It is observed that the sump is made of concrete and is cracked and
uncovered. No liner was observed during the SI.
Pg. 1-19: During the SI, stained soil was observed next to the sump. This
area was also devoid of vegetation.
-------
(Ref. 4 Cent'd.)
Figure 1-1 Facility Map
Approximate Direction
NORTH
Wastewater
Treatment
System
Underground
Storage Tank
Paved or
Concrete
areas
Underground Gasoline Tank
Prepared By: Data-Quik
Consultants
June 1993
4,000 feet
MW1
Figure 1-1
Facility Map
A2Z Drycleaners
-------
(Ref. 4 Cont'd.)
Pg. 1-20: Five samples of the discolored soil next to the sump were taken.
Analysis of these samples indicate high concentrations of lead and
PCE. In addition, a background sample was taken for comparison.
Appropriate QA/QC methods were implemented and none of the data were
qualified. Complete analyses of these soil samples are included as
Appendix A of this report. The CLP laboratory QA/QC report for
these analyses are included as Appendix B. See Figure 1-2 for soil
sample locations and Table 1-2 for a summary of the analytical
results.
Table 1-2
PCE
lead
Soil Samples Analysis in mg/kg
S-l
500
3,900
S-2
40
2,000
S-3
<5
59
S-4
100
15,200
S-5
50
1,300
S-6
425
6,200
SQL
5
50
Pg. 1-25: There is an above ground storage tank in the southwest side of the
facility. According to facility records, it was purchased in 1979
and used to store product PCE.
Pg. 1-26: Because of its recent purchase, the tank was installed in compliance
with the new state regulations.
Pg. 1-27: The tank is located under a weather-sheltered structure and
surrounded by intact berms. The structure is situated on an
elevated cement pad. At the SI, there were no signs of leakage or
contaminated soil.
Pg. 1-28: According to the purchase order, the tank is constructed of double-
walled steel and the capacity of the above ground tank is 30,000
gallons.
Pg. 1-29: Prior to closure of the facility in 1983, the above ground storage
tank was clean-closed according to the state regulations. However,
at the time of the SI, the tank remains on-site.
Pg. 1-30: There is an underground storage tank in the northeast corner of the
facility that stored PCE until 1979 when it failed a pressure test
conducted by the state. The tank remains on-site. During the SI,
a sample of the residual sludge was collected from the bottom of the
tank and PCE was detected at 5,200 ppm.
Pg. 1-32 A 5,000-gallon fuel tank is located in the southeast corner of the
property. The tank was used to store unleaded gasoline for use in
the laundry delivery trucks. At the time of the SI, this tank was
etill present at the site and found to be leaking fuel.
Pg. 2-3: According to facility records, throughout the operating life of the
facility, sediment from the. sump was dredged and removed on a
monthly basis. Each month, 500 pounds of sediment were removed and
drummed for off-site disposal at a nearby, unpermitted, landfill.
Prior to off-Bite disposal, the drums were sampled and analyzed for
content. During the SI, records of statistically representative
analytical results were found in the facility records. These
results are presented in Table 2-1.
-------
Ref. 4 (Cont'd.)
Table 2-1
Constituent
PCE
lead
Percent of constituent in waste
(per 500 Ibs of sediment)
March 1981
2.5%
3.1%
April 1981
2.0%
3.1%
May 1981
2.5%
3.0%
June 1981
1.8%
2.5%
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(Ref. 4 Cont'd.)
Figure 1-2 Soil Sample Locations
S3
•
S1
S2
S4
S5
•
S6
Berm
(Cracked
in several
places)
Prepared By: Data-Quik
Consultants
June 1993
Wastewater
Treatme
Syst
Figure 1-2
Soil Sample Locations
A2Z Drycleaners
-------
(Ref. 4 Cont'd.)
Pg. 3-2: Chilly Drillers, Inc. were contracted to drill a 125-foot deep un-
cased borehole onsite in February 1989. The purpose of this boring
was to determine the stratigraphy underlying the site. The location
of this borehole is indicated on Figure 1-1. Significantly, no clay
layers or other confining units were encountered within the entire
depth of the boring. The materials encountered during drilling are
listed below, by increasing depth:
Surface to 2' depth: Dark organic soil materials.
2' to 5' depth: Gray-green soil materials, grading to sandy silt
with chert inclusions.
5' to 30' depth: Unconsolidated sandy silt with chert inclusions.
. Ground water was encountered at a depth of 20', and was continuous
throughout remainder of boring.
30'to 100' depth: Oolithic gray limestone was encountered at 30'
below ground surface, requiring use of 4X tungsten bit. This
limestone extended to a depth of 100'.
100' to 125' depth: Clastic black to dark gray shale was
encountered at a depth of 100', and continued to the termination of
the boring at a depth of 125'.
Pg. 4-1: Summary of Sample Results
All samples were collected using Standard Sampling Protocol #482
(see Appendix C), on March 17, 1989. Complete sample analyses are
included as Appendix A of this report. The laboratory QA/QC report
for these analyses are included as Appendix B. The locations of the
site sources and monitoring wells are depicted in Figure 1-1 of this
report. The top of the screened interval in each monitoring well is
20' below ground surface.
The significant results of these analyses are summarized, as
follows:
Background Samples:
BGW1 - All samples collected from the background monitoring
well (BGW1) were "non-detect" for all analytes. This well was
selected as representative of background conditions near the
site. Ground water flow is to the East, locally, and BGW1 is
westward of all site sources.
Release Samples:
MW1 - All samples taken from monitoring well #1 (MW1)
exhibited measurable concentrations of vinyl chloride. The
highest concentration of vinyl chloride was detected in sample
number XT1000, at 0.0002 mg/L (the SQL for Vinyl Chloride in
all samples analyzed was l.OE -5 ppm). No other analytes were
detected in any samples taken from MW1.
MW2 through MW5 - All samples collected from all of these wells were
"non-detect" for all analytes.
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5. Jones, David; former employee of A2Z Drycleaners. Telecon with Fred
Fieldquv, Data-Quik Consultants Inc., July 3, 1992.
Mr. Jones stated that the wastewater treatment system backed up once a
month and wastewater overflowed into the sump. He also stated that on
occasion, the sump itself would overflow into the nearby field.
6. Smith, Robert; former employee of A2Z Drycleaners. Telecon with Fred
Fieldquv, Data-Quik Consultants Inc.. July 5, 1992.
Mr. Smith stated that from 1970 to 1979 there was a 10,000-gallon
underground storage tank in the northeast corner of the facility that
stored product PCE. The facility discontinued use of the underground
storage tank in 1979 when it installed an above ground tank. The above
ground tank and its associated bei.ns were maintained and inspected
regularly during its use.
7. Wermchopper, Sandy, Soil Survey of Podunk County, State Agricultural
Extension Service, 1984, 322 pp.
Pg. 14: Soils underlying the site are classified as Balderdash silt-loam
series, a member of the Spuria group. Spuria group soils are typic
alfasols, developed in-situ from unconsolidated alluvial parent
materials. The Balderdash series is characteristic of Spuric soils
developed on level to gently sloping (less than 3%) terrain. In the
Balderdash, the AO horizon extends to a depth of 8 to 12 inches, and
is very dark gray to black in hue. The Aj, horizon overlies the A,
horizon, which may extend to depths of 24 inches. The A, horizon
changes hue gradually with depth, fading from nearly black to green-
gray at its interface with the B horizon. The interface between the
AO and AI horizon may be indistinct, and is usually absent if plowing
or other surface disturbance has occurred. The B through E horizons
are relatively undifferentiated, below the blanched spodic horizon,
being a uniform gray-green throughout. Typically, Balderdash soils
extend to a depth of 4 to 5 feet, before grading into the parent
material.
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8. Facht, Art E., and Rex, T., The Geology and Paleontology of Podunk County.
the State Consortium of Learned Scholars and Animal Husbandry, 1894, 392
PP-
Pg. 42: The recent completion of the Cross-Border stone quarry has afforded
an opportunity of great scientific importance in the study of Podunk
County's geologic and paleontologic history. The Cross-Border
quarry, located in Western Podunk County, is a marvel of modern
engineering. Through the use of steam driven shovels and dynamite,
the quarry has been completed at a depth of two hundred feet below
the surface of the earth. Because all of the stratigraphic units
transected by the excavation are water-bearing, it is not without
the considerable efforts of man and beasts that the waters have been
continuously pumped free of the excavation. As pumping operations
will soon be discontinued, the authors have hastily chronicled the
stratigraphy and paleontology of this excavation, in anticipation
that its secrets will soon be surrendered to the depths.
The stratigraphic units exposed by this excavation are as follows:
From the surface of the earth to a depth of four feet, fine
agricultural soils are in evidence. From five feet to a depth of
thirty are found an unconsolidated alluvium, which is very
transmissive of water below twenty feet.
Below the alluvium is found a limestone known as the Sauber
formation, which extends to a depth of 100 feet. The Sauber is
replete with oolites, which were at first thought to be the eggs of
the dinosaurs whose remains riddle this formation. Alas, the
oolites are nothing but calcareous agglomerations; but the
Cretaceous-aged dinosauran fossils are as fine a collection as has
been found in North America. Twelve species of dinosaurs have been
identified from the fossil record of the Cross-Border excavation, as
is further documented in Chapter Eighteen of the instant treatise.
As the Sauber Limestone is an important source of steam-drilled well
water in Podunk County, many a citizen may be surprised to learn
that his daily water is extracted from amongst the earthly remains
of these fallen giants.
The Sauber Limestone is underlain by the Leche de la Madre shale, so
named by the Spanish Conquistadors who drank its waters as they
emanated from springs that line the banks of the Podunk River, five
miles distant to the South. The Leche de la Madre is highly
fractured, and extends to a depth of some two hundred feet below the
surface of the earth. The Leche de la Madre is underlain by the
Machtsnichts basalt, an impermeable floor which retains all waters
collected in the Cross Border quarry. As this basalt is extremely
hard and has little economic value, quarrying operations have ceased
at the depth at which it is encountered.
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9. Clamper, Kelly, Podunk Well and Septic Service, Telecon with Fred
Fieldquy, Data-Quik Consultants, Inc., June 31, 1992.
I called Mr. Clamper (Kelly) to inquire about aquifers underlying the
site. Kelly was very familiar with the site area, and happy to answer
questions. Kelly said that, in colonial times, wells were hand dug to a
depth of about 25 feet. But, this proved unsatisfactory, since the
alluvial overburden completely dries out every summer, when the water
table drops to below 30 feet. Kelly knew of no wells currently in use
that are screened in the alluvial overburden.
As soon as steam-powered drills were invented, -people started drilling
their wells into the Sauber Limestone (according to Kelly). Many private
wells are still screened in the Sauber, today. These wells can yield up
to 10 gpm; adequate for home or farm use. Most community or municipal
wells, however, are screened deeper; into the highly-fractured Leche de la
Madre shale. These wells can yield up to 25 gpm, if drilled into a
fracture.
10. Gneisskopf, Cliff, The Geology of Podunk County, the State University,
Department of Geology, 1982, 319 pp.
Pg. 287: The first true "bedrock" encountered in the region lies at an
average depth of 30 feet. This is the surface of the Sauber
formation, an oolithic limestone with a hydraulic conductivity (K
value) of approximately 1 x 10E -5 cm/sec. The Sauber formation
extends to an average depth of 100 feet below ground surface.
The Sauber limestone is overlain by an un-named unconsolidated
alluvium, which was probably deposited as part of the outwash plain
of the Great Podunk Glacier, during the last ice age. This alluvium
has an average K value of 1 x 10E -2.
The Sauber limestone is underlain by the highly clastic Leche de la
Madre shale. This shale occurs between 100 and 200 feet below
ground surface throughout Podunk County, and is a primary drinking
water aquifer. The average K value for the Leche de la Madre shale
is 1 x 10E -2.
The Leche de la Madre shale rests atop the Machtsnichts basalt. The
interface of these two units lies at a depth of approximately 200
feet below land surface throughout Podunk County, except along
Blackstone Ridge, where the Machtsnichts formation extrudes above
ground surface as an igneous intrusion. The Machtsnichts basalt is
essentially impermeable, with a K value of approximately 1 x 10E -
200. The Machtsnichts formation extends to a depth of approximately
2,000 feet below land surface throughout Podunk County.
Figure A, below, illustrates a geologic cross-section of Podunk
County form 0 to 220 feet below ground surface.
-------
Cross- border Quarry
Site
A
Blackstone Ridge
^^^^^^^\^^\
'.x xx x x x x x x / ,
.N > > > > > \ > \ \
Alluvium, k = i x
• •• •• - ••" ''
' Water Tab 1 e|>>»>»s^^/v>/v^vwwx/N/w>N/s
*". .,-^j , , j - • * * ^^-** *^**
NN^NNNNNNNSNN\\SS\S\\V\ \ V s
'.'''.'-' XX XXX XX X X f f XX X X X X X X x XX
\NS\X\S\S\ v v
Sauber Limestone
k = 1 x 10E-5
Leche de la Madre
Shale
k = 1 x JOE-2
Machtsnichts Basalt
(Intrusion)
Machtsnichts Basalt
k = 1 x 10E-200
vertical exaggeration = X 1,000
Sauber Limestone -
Leche de la
Madre Shale
-------
11. Rooter, Sue R. , Supervisor, Podunk County Sewer and Water Authority,
Interview with Fred Fieldquy, Data-Quik Consultants, Inc., June 17, 1992.
I visited Ms. Rooter (Sue) to inquire about target wells within four miles
of the site. Sue said that it should be easy to document these wells,
since that area is very sparsely populated (almost all of it belonging to
the Agua Peligroso Ranch). After consulting her well permit files, Sue
told me that she was aware of five wells within the TDL; three public
wells, and two private wells. All of these wells are tested annually by
the Podunk County Health Department, and no contamination has ever been
detected in any of them. These 5 wells are listed below, and have been
hand-drawn on the attached map (sketch):
1) The Podunk Municipal well is located about three and one-half miles
southwest of the site, on Ranch Road. This well is screened between 150
and 200 feet below ground surface. This well is in almost continual
operation, feeding the Podunk water tower. Water from the tower is
gravity-fed to the town of Podunk, two miles west of the well. This well
is the sole source of water for the Podunk municipal water system, which
has about 13,000 connections.
2) West Mountain Village, a subdivision on Ridge Road, has a community
well that serves 35 single-family homes. This well is located about two
and three quarters miles northeast of the site, and is screened between 55
and 75 feet below ground surface.
3) East Mountain Village, another subdivision on Ridge Road, has a
community well that serves 25 single-family homes. This well is located
almost four miles east of the site, and is screened between 55 and 75 feet
below ground surface.
4) The Agua Peligroso Ranch is located about 1/4 mile west of the site.
The Ranch's water comes from a single windmill-driven well that feeds an
elevated storage tank. Water from the tank is then gravity-fed to the
ranch houses and outbuildings. Three families (the property owners and
two tenant families) use water from this well. This well is screened
between 50 and 75 feet below ground surface.
5) A2Z Drycleaners has a single well onsite. This well was capped and
locked by the County when A2Z went out of business, around 1983. This
well is screened between 125 and 150 feet below ground surface. This well
was used for drinking water, by A2Z's employees, and for some industrial
(laundering) processes. No contamination was ever detected in this well.
-------
4 miles
North
O
0
3
ri-
a
O
O
O
3
o
3-
Wells:
A = Podunk Municipal
B = West Mountain Village
C = East Mountain Village
D = Agua Peligroso Ranch
E = A2Z Drycleaners
',-ource Data-Quik Consultants, Inc. from information
provided by Podunk Sewer & Water Authority.
Scale: 1 mile = 3/4"
Locations not precise
-------
12. U.S. Dept. of Commerce, Bureau of the Census, 1990 Summary of Vital
Statistics; Podunk County, 150 pp., p.29.
The average population per household in Podunk County is 3.2 persons.
-------
-------
Cross-Referenced WordPerfect Format
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HRS DOCUMENTATION RECORD
GENERAL INSTRUCTIONS
The HRS documentation record provides a public record of the information the Agency relies upon to
reach its listing decision for the site. Before beginning the documentation record for a site, you must
first evaluate all site information to determine what HRS factors will be scored and how that
information documents those factors. For example, evaluate analytical results from the site to
decide what samples represent background levels and whether or not any samples meet the criteria
for an observed release before preparing the Chemical Analysis part of the Observed Release section
of the documentation record.
Include documentation for all HRS factors that are evaluated. If you evaluate more than one aquifer
for the ground water migration pathway, include a separate copy of the ground water portion of the
documentation record for each aquifer. Similarly, if you evaluate more than one watershed for the
surface water migration pathway, include a separate copy of the surface water portion of the
documentation record for each watershed.
Delete the pages documenting any HRS factors that are not evaluated. For example, the HRS
requires that you evaluate potential to release for a watershed only if an observed release cannot be
established for that watershed. If an observed release is established for the watershed, delete the
pages documenting the potential to release for that watershed. Similarly, delete the pages for any
migration pathway that is not evaluated.
Remember that all assertions of fact in the documentation record must be referenced. References to
analytical results should include the sample number or other identifier. If calculations were
performed to estimate a value, include the calculations as an attachment or a reference. The HRS
value that is assigned to each factor must be supported by the references provided.
The printed version of the documentation record has companion instructions to help you understand
the requirements of the documentation record. If you are unsure about how the instructions apply to
a particular situation, consult the HRS itself. The HRS is the definitive source on scoring a site. If
you cannot resolve the difficulty at the regional level, document the problem and refer it to EPA
Headquarters for resolution.
A companion WordPerfect® version of the documentation record has the instructions embedded as
comments. As you enter information into the documentation record, you will see the instructions,
but the printed copies for the public docket will not include the instructions. If you need extra space
to document an assigned value, WordPerfect will automatically provide extra pages; please do not
change or add any hard page breaks to the documentation record. A separate section entitled
"Instructions for Documentation Record Typists" provides more detailed instructions for using the
WordPerfect version.
In many places in the documentation record, you will be asked to copy data or assigned values at
the bottom of the page. This will assist EPA in entering the information into a database. If you are
using the WordPerfect version, please do not alter these data entry areas of the documentation
record except to enter the information requested.
You will also be asked to enter factor values into the HRS scoresheets, Tables 3-1, 4-1, 5-1, 6-1, 6-
2, and 6-8. Complete those tables as directed in the HRS, and place the completed scoresheet
table(s) at the end of the appropriate pathway in the documentation record. You may use EPA's
HRS Scoring Spreadsheet in Lotus 123* to produce these tables.
-------
MRS DOCUMENTATION RECORD-REVIEW COVER SHEET
Name of Site:
Contact Persons
Site Investigation:
(Name) (Telephone)
Documentation Record:
(Name) (Telephone)
Pathways. Components, or Threats Not Evaluated
List below any pathway, component, or threat that was not evaluated, along with a brief
rationale. Delete the corresponding pages from the documentation record below.
Avoid stating that there was "no risk" for a particular pathway. Instead, give a nonjudgmental
explanation of why that pathway would not have generated a significant HRS score.
Refer to the following sections of the HRS Guidance Manual, Interim Final, November 1992
(HRSGM):
• Sec. 2.2, Scoring All Pathways and Threats, p. 11.
• Sec. 3.1, General Approach to HRS Scoring, Step 3: Identify and Characterize Significant
Pathways, p. 23.
• Sec. 3.4, HRS Scoring Strategy, p. 31.
-------
MRS DOCUMENTATION RECORD
Name of Site:
EPA Region: Date Prepared:
Street Address of Site:
County and State:
Attach an 8"x 11" map showing the general location of the site within the state and
including large cities and nearby county boundaries.
Refer to the Regional Quality Control Guidance forNPL Candidate Sites, December 1991 (RQCG),
Appendix D, Map Specifications for the HRS Documentation Record.
Describe the general location of the site in the state, e.g, Central Illinois, Northeast New
Jersey, and give the name of the USGS topographic map(s) on which the site is located.
General Location in the State:
Topographic Map:
I Provide universal coordinates of the site in degrees, minutes, and seconds. I
Refer to the Guidance for Performing Preliminary Assessments Under CERCLA, September 1991,
Appendix E, Standard Operating Procedure to Determine Site Latitude and Longitude Coordinates.
Latitude: Longitude:
Copy the applicable pathway scores and the site score below.
Scores
Air Pathway
Ground Water Pathway
Soil Exposure Pathway
Surface Water Pathway
HRS SITE SCORE
-------
WORKSHEET FOR COMPUTING MRS SITE SCORE
Enter the pathway, component and threat scores from the HRS Tables as indicated. If you
do not evaluate a pathway or component, write "Not Evaluated" in the appropriate blank
in this worksheet.
O C2
O _3
1. Ground Water Migration Pathway Score (SBJ
(from Table 3-1, line 13)
2a. Surface Water Overland/Flood Migration Component
(from Table 4-1, line 30)
2b. Ground Water to Surface Water Migration Component
(from Table 4-25, line 28)
2c. Surface Water Migration Pathway Score (S,J
Enter the larger of lines 2a and 2b as the pathway score.
3. Soil Exposure Pathway Score (S,)
(from Table 5-1, line 22)
4. Air Migration Pathway Score IS.)
(from Table 6-1, line 12)
5. Total of S 2 + S.w2 + S,2 + S.2
6. HRS Site Score Divide the value on line 5
by 4 and take the square root
-------
REFERENCES
Assign each reference a number and refer in the documentation record to a reference
number and page.
Reference
Number Description of the Reference
Give a reference for each assertion in the documentation record when the assertion is
made. For any reference with 5 or more pages, identify not only the reference number but
the page number (e.g., ref. 23:18-20). For non-paginated references, e.g., data reports,
supply page numbers manually. Where analytical results are discussed, include the sample
number or identifier. If calculations were performed to estimate a value, include the
calculations as an attachment or a reference.
Refer to:
• RQCG Sec. 2.4.4, List of Reference Materials, p. 18, and remainder of Sec. 2.4, p. 15.
• HRSGM Sec. 3.2, The HRS Scoring Package, References, pp. 28-29.
-------
SD-Characterization and Containment
SOURCE DESCRIPTION
2.2 Source Characterization
Make a separate copy of sections 2.2 through 2.4.2.1.5 of the documentation record for
each source at the site (See section 1.0 for definitions). The information collected below
will be used in evaluating Waste Characteristics and Likelihood of Release under each
migration pathway; however, no factor values will be assigned in this section.
Information used in evaluating the Soil Exposure pathway will be documented separately.
Refer to:
• HRSGM Sec. 2.1, Source and Site Definitions, p. 9.
• HRSGM Chapter 4, Sources, p. 41.
Since response actions are considered by the HRS, with exceptions for sources where
there is evidence that contaminants have migrated from the site, or where there is
reasonable concern about the potential for migration from the site, distinguish between
current conditions and conditions prior to any response actions, as appropriate.
Refer to HRSGM Sec. 2.3, Evaluation of Sites With Waste Removals, p. 11.
If there are hazardous substances and hazardous wastestreams at the site that cannot be
allocated to any specific source, fill out the "unallocated source" description separately for
use in the hazardous waste quantity factor. Also assign the hazardous substances to
sources as appropriate.
Kefer to HRSGM Sec. 4.1, Characterization of Sources and Areas of Observed
Contamination, Tips and Reminders, p. 48.
Number of the source:
Use this number to identify this source throughout the documentation record. Enter this
number in the headers for sections 2.4.1 through 2.4.2.1.5 of the documentation record.
Name and description of the source:
Location of the source, with reference to a map of the site:
Refer to RQCG, Appendix D, Map Specifications for the HRS Documentation
Record, Source Characterization, p. D-4.
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Containment
Fully describe the methods currently in use to provide containment of the hazardous
substance source. In addition, if response actions have been carried out, give a complete
description of conditions for the source prior to any response actions. For sources where
there has been evidence of contaminant migration in the past, provide information on the
state of containment associated with that migration.
Refer to:
• HRSGM Sec. 4.1, Characterization of Sources and Areas of Observed
Contamination, Item (4), Evaluate the Containment for Each Source, pp.
45-46.
• The appropriate HRSGM Highlight, Data Needs for Evaluating Containment,
listed below for each pathway.
• The appropriate HRS containment factor value table, listed below for each
pathway. Describe source containment using the exact terminology found
in these tables.
Gas release to air
• HRSGM Highlight 10-4, p. 407.
• HRS Table 6-3, p. 51652 .
Particulate release to air
• HRSGM Highlight 10-4, p. 407.
• HRS Table 6-9, p. 51653.
Release to ground water
• HRSGM Highlight 7-22, p. 149.
• HRS Table 3-2, p. 51596.
Release via overland migration and/or flood
• HRSGM Highlight 8-26, p. 247.
• HRS Table 4-2, pp. 51609 - 51610.
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SD-Hazardous Substances
Source No.:
2.4.1 Hazardous Substances
List the hazardous substances attributable to this source, and cite the evidence, including
specific sample numbers or deposition records, that document the presence of the
substance in the source. In addition, if a source description has been prepared for an
unallocated source, include here each specific substance at the site that cannot be
allocated to a specific source, providing there is no definitive information that the
hazardous substance could not be present in this source.
Refer to HRSGM Sec. 2.4, CERCLA Pollutants or Contaminants, p. 18.
Hazardous substance Evidence Reference
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SD-Hazardous Constituent Quantity
Source No.:
2.4.2. Hazardous Waste Quantity
In the sequence presented below, evaluate quantities of hazardous substances and
hazardous wastestreams for the source. (Hazardous waste quantity for the Soil Exposure
pathway will be evaluated separately in Section 5.0)
Show all calculations and describe all methods used to calculate hazardous
waste quantity factor values. Attach long calculations or complex methods
as a reference to the documentation record. Include any maps or photos on
which measurements and calculations are based.
Refer to HRSGM Chapter 6, Hazardous Waste Quantity, p. 82.
2.4.2.1.1. Hazardous Constituent Quantity
Calculate and enter below the mass (S) in pounds of each CERCLA hazardous substance in
the source (with the exceptions noted for RCRA wastes in Section 2.4.2.1.1.). Include
references showing the basis for calculating the quantity for each substance. Sum the
quantities.
Refer to HRSGM Sec. 6.2, Tier A - Hazardous Constituent Quantity, p. 91.
Hazardous Substance
Constituent
Quantity (pounds)
(Mass - S)
Reference
sum:
(pounds)
Based on the above sum for constituent quantity, assign a value for hazardous constituent
quantity using Tier A of Table 2-5. Do not round to the nearest integer. Enter the value
below.
Hazardous Constituent Quantity Value (S)
Are the data complete for hazardous constituent quantity for this source? If so, assign
hazardous wastestream quantity, volume, and area values of 0 for this source and proceed
to Section 2.4.2.1.5. If not, proceed to hazardous wastestream quantity below.
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SD-Hazardous Wastestream Quantity
Source No.:
2.4.2.1.2. Hazardous Wastestream Quantity
Evaluate and enter below the mass in pounds of each hazardous wastestream in the
source plus the mass of any additional CERCLA pollutants and contaminants (as defined in
CERCLA Section 101(33) in the source. For a wastestream that consists solely of a
hazardous waste listed pursuant to Section 3001 or RCRA as amended, include the mass
of this entire hazardous waste. For a wastestream that consists solely of a RCRA
hazardous waste that exhibits the characteristics identified under Section 3001 of RCRA
as amended, include the mass of this entire hazardous waste. Cite all references which
describe and document the quantity of each wastestream.
Refer to HRSGM Sec. 6.3, Tier B - Hazardous Wastestream Quantity, p. 99.
Hazardous Quantity
Wastestream (pounds) Reference
sum; (pounds)
Based on this sum, assign a value for hazardous wastestream quantity from Tier B of
Table 2-5. Do not round to the nearest integer. Enter the value below.
Hazardous Wastestream Quantity Value (W)
Are the data complete for hazardous wastestream quantity for this source? If so, assign
volume and area a value of zero and proceed to Section 2.4.2.1.5. If not, proceed to
Volume, except: if this is the unallocated source, assign volume and area a value of zero
and then proceed to Section 2.4.2.1.5.
8
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SD-Volume
Source No.:
2.4.2.1.3. Volume
Estimate the volume of the source, and based on this volume, (V) assign the source a
value for volume using the Tier C equation in Table 2-5. Do not round to the nearest
integer.
Refer to HRSGM Sec. 6.4, Tier C - Volume, p. 105.
Dimension of source (yd3 or gallons):
References(s);
Volume Assigned Value:
If the source volume cannot be determined, proceed to Area. If it can be determined,
assign area a value of zero.
2.4.2.1.4. Area
Estimate the area of the source and based on this area, (A) assign the
source a value for area using the equation in Tier D of Table 2-5. Do not round to the
nearest integer.
Refer to:
• HRSGM Sec. 6.5, Tier D - Area, p. 109.
• HRSGM Highlight 9-2, Delineating Areas of Observed Contamination for
Sources Other Than Contaminated Soil, p. 346.
Area of source (ft2):
Reference(s) :
Area Assigned Value:
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SD-Source Hazardous Waste Quantity Value
Source No.:
2.4.2.1.5. Source Hazardous Waste Quantity Value
Select the highest of the values assigned to the source for hazardous constituent quantity,
hazardous wastestream quantity, volume, and area. Enter this value as the source
hazardous waste quantity value below. { Do not round to the nearest integer).
Refer to HRSGM Sec. 6.6, Hazardous Waste Quantity Calculation, p. 111.
Source Hazardous Waste Quantity Value:
10
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SD-Summary
SITE SUMMARY OF SOURCE DESCRIPTIONS
List each source described under each source characterization in Section 2.2 and give the
Source Hazardous Waste Quantity value. Indicate whether the source is available to each
pathway.
Containment
Source Hazardous
Source Waste Quantity Ground Surface Air
No. Value Water Water Gas Particulate
Refer to HRSGM:
• Ch. 4, Sources, p. 41.
• Ch. 6, Hazardous Waste Quantity, p. 83.
11
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GW-General
3.0 GROUND WATER MIGRATION PATHWAY
Evaluate each aquifer using a separate copy of the portion of the documentation record for
ground water, Section 3.0.1 through Section 3.3.4. Calculate a separate ground water
migration pathway score for each aquifer, using the factor category values for that aquifer
for likelihood of release, waste characteristics, and targets. Include both the targets using
water from that aquifer and the targets using water for all overlying aquifers through
which the hazardous substances would migrate to reach the aquifer being evaluated.
Assign the highest ground water migration pathway score that results for any aquifer as
the ground water migration pathway score for the site.
3.0.1 GENERAL CONSIDERATIONS
Characterize the aquifer being evaluated and all overlying aquifers and strata within the
target distance limit (usually 4 miles). Include the name, description, and references for
each aquifer or stratum, including information on composition, thickness, depth, and dip.
Note particularly any evidence of karst. If overlying aquifers are present, describe all
strata down through the aquifer being evaluated. Continue adding aquifers and strata until
all aquifers and their overlying strata have been described.
Refer to HRSGM Sections:
• 7.1, Determining Aquifer Boundaries and Number of Aquifers, p.
• 7.2, Treatment of Karst, p. 137.
• 7.9, Scoring Sites With Multiple Aquifers, p. 197.
115.
Pay close attention to the definitions of "Aquifer", "Aquifer Boundary", and
"Top of the Aquifer", pp. 116-117. The phrase; "significantly lower
hydraulic conductivity", as found in the "Aquifer Boundary" definition, is
further refined on pp. 120-124 of the HRSGM, and in the Background section
of the HRS, p. 51553. Check available references for information on
hydraulic conductivity.
For each aquifer, document all aquifer interconnections within 2 miles of the sources at
the site. If observed ground water contamination attributable to the site extends beyond 2
miles, any locations within this area of documented contamination also may be considered
in documenting aquifer interconnections.
Refer to HRSGM Sec. 7.1 Determining Aquifer Boundaries and Number of
Aquifers, Identifying Aquifer Interconnections, p. 127.
In the description, document discontinuities for each aquifer within 4 miles of the sources
at the site.
Refer to HRSGM Sec. 7.1 Determining Aquifer Boundaries and Number of
Aquifers, Identifying Aquifer Discontinuities, p. 125.
12
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Aquifer/Stratum 1 (shallowest)
Aquifer/Stratum Name:
Description;
References;
Aquifer/Stratum n (deepest)
Aquifer/Stratum Name;
Description;
References;
13
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GW-Observed Release
3.1 LIKELIHOOD OF RELEASE
3.1.1 OBSERVED RELEASE
Refer to HRSGM Chapter 5, Observed Release, p. 55. In evaluating an
observed release, be certain to document that hazardous substances have been
released to an "aquifer", as defined on page 116 of the HRSGM.
An observed release can be established by either direct observation or chemical analysis.
If an observed release is established by direct observation only, fill out the documentation
for direct observation and delete the chemical analysis documentation. Similarly, if an
observed release is established only by chemical analysis, delete the direct observation
documentation and fill out the chemical analysis documentation. If the observed release
can be established in both ways, include all documentation.
Refer to HRSGM Sec. 5.1 Establishing an Observed Release and Observed
Contamination, p. 55.
Document all samples and observations that meet the criteria for an observed release.
Note that this documentation also supports the determination of targets subject to Level I
and Level II concentrations in Section 3.3 below.
Refer to HRSGM Sec. 7.4, Actual Contamination, p. 153.
If no observed release can be established for the aquifer being evaluated, enter a value of
0 on line 1 in Table 3-1 and go on to Section 3.1.2, Potential to Release, for that aquifer.
Aquifer Being Evaluated:
Direct Observation;
Direct observation establishes that a material containing one or more hazardous
substances has been deposited into or has been observed entering the aquifer.
Basis for Direct Observation:
Describe the evidence for establishing the direct observation, including the aquifer that the
hazardous substance entered.
14
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Hazardous Substances in the Release
Provide analyses of the hazardous substances contained in the material or other
documentation of the content of the material. If analyses are provided, include the time
and location (provide a map as a reference) and the basis for selection for each sample.
Specify the hazardous substances, their concentrations, and the associated sample
quantitation limits. Identify (e.g., with asterisks) any data that was qualified by the
analyst and explain below the qualifications and the rationale for using the qualified data.
Refer to HRSGM Sec. 5.3, Transformation Products, p. 79.
Chemical Analysis;
When a chemical analysis established an observed release according to the criteria in
Table 2-3, documentation should include two parts: analytical significance versus
background and the rationale for the attribution of some portion of the release to the site.
Background Concentration
If the background concentrations are obtained from samples, identify the location (provide
a map as a reference) and the date of each background sample.
Sample ID Depth Date Reference
Note that the "Depth" heading, above, refers to the depth of the sample,
rather than the depth of the monitoring well. In a well, the depth of the
sample is equal to the top of that well's screened interval.
Explain the rationale for choosing the background samples, and establish that the
background samples are comparable to the contaminated samples described below.
For each background sample, list the hazardous substances found, their concentrations,
and the associated sample quantitation limits. Specify the unit of measure for all
concentrations. Identify (e.g., with asterisks) any data used that was qualified by the
analyst and explain below the qualifications and the rationale for using the qualified data.
Sample
Hazardous Quantitation
Sample ID Substance Concentration Limit Reference
15
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HRS Table 2-3, p. 51589, describes alternative detection limits that may
substitute for the sample guantitation limit. Edit the "Sample Quantitation
Limit" heading, above, to reflect the detection limit actually reported with
the data.
If the background concentrations are not obtained from samples, provide background
concentrations for each hazardous substance establishing an observed release. Explain
the rationale for choosing each background concentration listed.
Refer to: HRSGM Sec. 5.2, Selecting Appropriate Background Samples, p. 67.
Contaminated Samples
Identify the location (provide a map as a reference) and date of each sample that
established as observed release according to the criteria in Table 2-3.
Sample ID Depth Date Reference
Explain the rationale for choosing the contaminated samples.
Refer to HRSGM Highlight 5.3, Examples for Deciding Whether Significance
above Background is Established, p. 61.
For each contaminated sample, list the hazardous substances that establish an observed
release, their concentrations, and the associated sample quantitation limits. Specify the
unit of measure for all concentrations. Identify (e.g., with asterisks) any data used that
was qualified by the analyst and explain below the qualifications and the rationale for
using the qualified data.
Sample
Hazardous Quantitation
Sample IP Substance Concentration Limit Reference
16
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Level I Samples
Document below each contaminated sample that meets or exceeds a relevant health-based
benchmark (Table 3-10). Repeat the information for each sample that meets a Level I
criterion. If no sample meets or exceeds these criteria, delete the entire Level I sample
part of the documentation.
Enter below the concentration of each hazardous substance in the sample that meets the
criteria for an observed release. Document that the sample meets the requirements for
Level I by comparing the sample concentration to a health-based benchmark (Table 3-10).
If no hazardous substance individually meets or exceeds its benchmark concentration,
calculate the indices I and J as specified in Section 2.5.2 of the HRS. List the hazardous
substances considered in the table below and provide a reference showing the calculation.
Refer to HRSGH Sec. 7.4, Actual Contamination, p. 153.
Sample ID:
Reference for Benchmarks:
Hazardous Benchmark
Substance Hazardous Substance Concentration Benchmark
Attribution:
Enter here the rationale for attributing the release, at least in part, to a source at the site.
Discuss relevant alternative sources.
Refer to HRSGM Sec. 5.3, Transformation Products, p. 79,
Hazardous Substances Released
List the hazardous substances that meet the criteria for an observed release below.
If an observed release has been established for the aquifer being evaluated, enter a value
of 550 below and on line 1 in Table 3-1.
Ground Water Observed Release Factor Value:
17
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GW-Containment
3.1.2 POTENTIAL TO RELEASE
Evaluate the potential to release for each aquifer for which an observed release has not
been established. If an observed release to an aquifer has been established, do not assess
the potential to release for that aquifer. Rather, delete the documentation for
containment, net precipitation, depth to aquifer, and travel time for that aquifer and assign
the value of 0 to the potential to release on Table 3-1. Proceed to Section 3.2, Waste
Characteristics.
Refer to HRSGM Sections:
• 7.1, Determining Aquifer Boundaries and Number of Aquifers, p. 115.
• 7.2, Treatment of Karst, p. 137.
• 7.9, Scoring Sites With Multiple Aquifers, p. 197.
Pay close attention to the definitions of "Aquifer", "Aquifer Boundary", and
"Top of the Aquifer", pp. 116-117. The phrase; "significantly lower
hydraulic conductivity", as found in the "Aquifer Boundary" definition, is
further refined on pp. 120-124 of the HRSGM, and in the Background section
of the HRS, p. 51553. Check available references for information on
hydraulic conductivity.
3.1.2.1 Containment
For each source at the site, assign a source type and a containment value from Table 3-2
based on the containment of the source against release. Provide the descriptors for
containment from Table 3-2 that apply and the rationale for choosing those descriptors.
Refer to HRSGM:
• Chapter 4, Sources, p. 41.
• Highlight 4-1, Commonly Confused Source Types, p. 44.
• Highlight 7-22, Data Needs for Evaluating Containment, p. 149.
Source Descriptor Value
Select the highest source containment factor value assigned to those sources with a
source hazardous waste quantity value of 0.5 or more (Section 2.4.2.1.5). Note that this
minimum size requirement does not apply to any other factors in this pathway. If no
source at the site meets this minimum size requirement for containment, then ignore the
minimum size requirement in selecting the highest value. Enter this highest value below
and on line 2a of Table 3-1.
Containment Factor Value:
18
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GW-Net Precipitation
GW-Depth to Aquifer
3.1.2.2 Net Precipitation
Determine the net precipitation factor value from Figure 3-2. If the site is located such
that an appropriate factor value cannot be read from Figure 3-2, calculate net precipitation
from the procedure included in section 3.1.2.2 of the HRS. Show the calculations below.
Based on the annual net precipitation, assign a net precipitation factor value from Table 3-
4. Enter, on the line below and on line 2b of Table 3-1, the factor value assigned from
Figure 3-2 or Table 3-4.
Precipitation (in inches)
Reference;
Factor Value;
3.1.2.3 Depth to Aquifer
Evaluate the depth to the aquifer by determining the depth from the lowest known point
of hazardous substances at the site to the top of the aquifer being evaluated, considering
all layers in that interval. Begin the table with the lowest known point of hazardous
substances. Assign an intervening karst layer a thickness of 0 feet. Determine the depth
to the aquifer only at locations within 2 miles of the sources at the site, except when
observed ground water contamination attributable to these sources extends beyond 2
miles from them; then use any location within the limits of this observed contamination for
those aquifers that do not have an observed release. If the necessary depth information is
available at two or more locations, show the calculations for each location in the table
below.
Depth Cumulative
Location Stratum (in feet) Depth Reference
Make certain that all depth measurements are in units of feet, and are taken
from the same reference point, (e.g. "above mean sea level", or "below
ground surface", or "below top of well casing") before using these numbers
in calculations. The best approach is to convert all measurements to feet
above mean sea level.
Refer to HRSGM:
• Sec. 7.2, Determining Aquifer Boundaries and Numbers of Aquifers, p.
115.
• Sec. 7.2, Treatment of Karst, p. 137.
• Highlight 7-17, Scoring Considerations for Karst Aquifers: Depth to
Aquifer Factor, p. 142.
• Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 197.
Use the location having the smallest depth to assign the factor value. Enter this value
below and on line 2c of Table 3-1.
Net Precipitation Factor Value:
Depth to Aquifer Factor Value:
19
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GW-Travel Time
3.1.2.4 Travel Time
Assess travel time for those geologic materials that lie between the lowest known point of
hazardous substances at the site and the top of the aquifer being evaluated. Determine
travel time only at locations within 2 miles of the sources at the site, except when
observed ground water contamination attributable to these sources extends beyond 2
miles from them. Then use any location within the limits of this observed contamination
when evaluating travel time for those aquifers that do not have an observed release. If
the necessary subsurface geologic information is available at multiple locations, evaluate
the travel time factor at each location. Use the location that gives the highest factor value
to assign the factor value for the aquifer being evaluated.
If the depth to the aquifer is 10 feet or less, or if all the intervening materials are karst,
document the situation and assign a value of 35. No further documentation is required.
Enter this value below and on line 2d of Table 3-1.
Assign to any karst layer a thickness of 0 feet. Drop from further consideration the first
10 feet of intervening material and also any intervening layer less than 3 feet thick. If the
depth is greater than 10 feet, or if all the intervening materials are not karst, document the
following for each of the intervening layers: identification and composition of the layer,
the thickness of the layer, and the hydraulic conductivity. Select the intervening layer(s)
with the lowest hydraulic conductivity. Assign the HRS value for travel time from Table 3-
7.
Give preference to representative, measured hydraulic conductivities whenever available,
using the values in Table 3-6 as defaults.
Refer to HRSGM:
• Sec. 7.2, Determining Aquifer Boundaries and Numbers of Aquifers, p.
115.
• Sec. 7.2, Treatment of Karst, p. 137.
• Highlight 7-17, Scoring Considerations for Karst Aquifers: Depth to
Aquifer Factor, p. 142.
• Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 197.
Layer,
Compos it ion
Thickness
(feet)
Conductivity
(cm/sec)
Reference
Lowest Hydraulic Conductivity:
Enter the value determined below and on line 2d of Table 3-1.
Travel Time Factor Value:
20
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GW-Toxicity/Mobility
3.2 WASTE CHARACTERISTICS
Determine the waste characteristics factor category for each aquifer being evaluated.
3.2.1 Toxicitv/Mobilitv
For the aquifer being evaluated, list each hazardous substance for which an observed
release to ground water has been documented (Section 3.1.1) and hazardous substances
associated with all sources with a ground water containment value greater than 0 (as
determined in Section 2.4.1 and listed in the Site Summary of Source Descriptions of this
record).
Assign each substance a toxicity factor value (Section 2.4.1.1), a mobility factor value
(Section 3.2.1.2), and a combined toxicity/mobility factor value (Table 3-9) from the EPA
Chemical Database.
Give the reference which provides the rationale for assigning each of these values. If a
substance cannot be found in the data base, assign the value according to the instructions
in the HRS and provide a reference that shows how the value was assigned.
If all substances available to the ground water pathway receive toxicity values of 0
because of insufficient data, assign a default toxicity value of 100 to each hazardous
substance.
For any hazardous substance that meets the criteria for an observed release to one or
more aquifers underlying the sources at the site, regardless of the aquifer being evaluated,
assign a mobility factor value of 1.
For any hazardous substance that does not meet the criteria for an observed release to at
least one of the aquifers, assign that hazardous substance a mobility factor value from the
EPA Chemical Database. If a substance cannot be found in the database, assign a value
from Table 3-8 for the aquifer being evaluated, based on its solubility and distribution
coefficient (Kd). Provide references for the chemical properties and show how the value
was assigned.
If the hazardous substance cannot be assigned a mobility factor value because data on its
solubility or distribution coefficient are not available, use other hazardous substances for
which information is available in evaluating the pathway.
If none of the hazardous substances eligible to be evaluated can be assigned a mobility
factor value, use a default value of 0.002 as the mobility factor value for all these
hazardous substances.
Refer to HRSGM Sec. 7.2, Treatment of Karst, p. 137.
Hazardous Source Toxicity Mobility Toxicity/
Substance No. Factor Value Factor Value Mobility Ref.
21
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Select the hazardous substance with the highest toxicity/mobility factor value for the
aquifer being evaluated. Enter the value for that substance below and on line 4 of Table
3-1.
Toxicity/Mobility Factor Value:
22
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GW-Hazardous Waste Quantity
3.2.2 Hazardous Waste Quantity
List the sources that have a ground water containment factor value greater than 0 and the
source hazardous waste quantity value assigned to each source in the source description
(Section 2.4.2.1 of this documentation record and summarized in the Site Summary of
Source Descriptions). Note for each source whether the hazardous constituent quantity
data are complete or not.
Refer to HRSGM:
• Ch. 4, Sources, p. 41.
• Ch. 6, Hazardous Waste Quantity, p. 83.
Sum the source hazardous waste quantity values for each source and round this sum to
the nearest integer, except if the sum is greater than 0 and less than 1. In this case,
round it to 1.
Source Hazardous Is source hazardous
Waste Quantity constituent quantity
Source Number Value (Section 2.4.2.1.5) data complete? (yes/no)
Sum of Values:
Based on this sum, select a hazardous waste quantity value from Table 2-6. If all sources
are evaluated for the ground water pathway based on complete hazardous constituent
quantity data, assign the value from Table 2-6 as the hazardous waste quantity factor
value. If the hazardous constituent quantity data are not complete for one of more
sources evaluated, assign the greater of the value from Table 2-6 or a value of 10, except:
if the value from Table 2-6 is 0, then assign a value of 0 as the hazardous waste quantity
factor value. Enter this value below and on line 5 of Table 3-1.
3.2.3 Waste Characteristics Factor Category Value
Multiply the toxicity/mobility and hazardous waste quantity factor values, subject to a
maximum product of 1 x 10s. Based on this product, assign a value from Table 2-7 to the
waste characteristics factor category for this aquifer. Enter this value below and on line 6
of Table 3-1.
Toxicity/Mobility Factor Value X Hazardous
Waste Quantity Factor Value:
Hazardous Waste Quantity Factor Value:
Waste Characteristics Factor Category Value:
23
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GW-Targets
3.3 TARGETS
Determine the targets factor category value for each aquifer being evaluated. Evaluate the
nearest well, population, resources, and Wellhead Protection Area based on targets within
the target distance limits in Section 3.0.1.1 and the aquifer boundaries in Section 3.0.1.2
List all drinking water wells that lie within the target distance limit (and are not separated
from the site by a discontinuity) and draw water from the aquifer being evaluated or an
overlying aquifer. List also those drinking water wells that lie outside the 4-mile target
distance limit but are subject to an observed release. Include standby wells only if they
are used for drinking water supply at least once every year. If the list is extensive, private
wells drawing from the same aquifer may be reported as the number of wells within each
county and each distance category (categories are given in Table 3-11).
If one or more samples meet the criteria for an observed release for a drinking water well
within the target distance limit, determine if that well is subject to Level I or Level II
concentrations as specified in Sections 2.5.1 and 2.5.2. Targets in overlying aquifers can
be subject to Level I or Level II concentrations even if there is no observed release to the
aquifer being evaluated. For any well at which an observed release is documented,
reference should be made to documentation of the release at that well in Section 3.1.1,
Observed Release and a statement should be made as to whether the contamination is
Level I or Level II.
For any well subject to potential contamination, include the distance to the well from the
nearest source with a ground water containment value greater than 0. Note the special
instructions for karst aquifers and report the distance from a source to the karst aquifer.
Be sure to document that target veils actually draw from (are screened in)
an aquifer of concern.
Refer to:
• HRSGM Sec. 7.1, Determining Aquifer Boundaries and Number of Aquifers,
p. 115.
• HRSGM Sec. 7.2, Treatment of Karst, p. 137.
• HRSGM Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 197.
• RQCG Appendix D, Map Specification for the HRS Documentation Record,
Ground Water Pathway, p. D-5.
Level I Level II Potential
Distance Contam. Contam. Contain.
Well From Source Aquifer (Y/N) (Y/N1 (Y/tO Ref.
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GW-Nearest Well
3.3.1 Nearest Well
In evaluating the nearest well factor, include both the drinking water wells drawing from
the aquifer being evaluated and those drawing from overlying aquifers as specified in
Section 3.0. Include standby wells only if they are used for drinking water supply at least
once every year.
Assign a value for the nearest well factor as follows:
If one or more drinking water wells is subject to Level I concentrations, assign a value of
50.
If not, but if one or more drinking water wells is subject to Level II concentrations, assign
a value of 45.
Score a Level I or Level II well as the nearest well, even if other wells
(not subject to actual contamination) are closer to sources on site.
If not, determine the shortest distance to any of the drinking water wells, as measured
from any source at the site with a ground water containment factor value greater than 0.
Select a value from Table 3-11 based on this distance. Assign it as the value for the
nearest well factor, unless one of the target aquifers is a karst aquifer and a higher value
can be assigned. In this case, follow the instructions in Section 3.3.1 for karst aquifers.
Be sure to document that the nearest target well actually draws from (is
screened in) an aquifer of concern.
Refer to HRSGM:
• Sec. 7.1, Determining Aquifer Boundaries and Number of Aquifers, p. 115.
• Sec. 7.2, Treatment of Karst, p. 137.
• Sec. 7.5, Population and Nearest Well Factors, 163.
• Sec. 7.7, Standby Wells, p. 187.
• Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 197.
Well:
Level of Contamination (I, II, or potential):
If potential contamination, distance from source in miles:
Enter the value assigned to the nearest well factor below and on line 7 of Table 3-1.
Nearest Well Factor Value:
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GW-Level I Concentrations
3.3.2 Population
In evaluating the population factor, include those persons served by drinking water wells
within the target distance limit specified in Section 3.0.1.1. For the aquifer being
evaluated, count those persons served by wells in that aquifer and those persons served
by wells in overlying aquifers as specified in Section 3.0. Include residents, students, and
workers who regularly use the water. Exclude transient populations. When a standby
well is maintained oh a regular basis so that water can be withdrawn, treat it as an active
well and include the population it serves. Note that this criterion is different from that
stated for the nearest well.
In estimating residential population, when the estimate is based on the number of
residences, multiply each residence by the average number of persons per residence for
the county in which the residence is located. If house counts are used, include a map
showing the basis of the house count.
In determining the population served by a well, if the water from the well is blended with
other water, apportion the total population regularly served by the blended system to the
well based on the well's relative contribution to the total blended system, in accordance
with the instructions in Section 3.3.2.
Refer to HRSGM:
• Sec. 7.5, Population and Nearest Well Factors, 163.
• Sec. 7.6, Blended Water Supplies, p. 177.
• Sec. 7.7, Standby Wells, p. 187
• Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 197
3.3.2.1 Level of Contamination
Evaluate the population served by water from a point of withdrawal based on the level of
contamination for that point of withdrawal. Use the applicable factor: Level I
concentrations, Level II concentrations, or potential contamination.
Refer to HRSGM:
• Sec. 7.2, Treatment of Karst, p. 137.
• Sec. 7.4, Actual Contamination, p. 153.
3.3.2.2 Level I Concentrations
List the wells subject to Level I contamination, sum the number of people served by these
wells, and enter this sum below as the Population Served by Level I Wells. Multiply this
sum by 10 and assign this product as the value for this factor. Enter the assigned Level I
Concentrations factor value below and on line 8a of Table 3-1.
Level I Well
Population
Reference
Population Served by
Level I Wells:
Level I Concentrations Factor Value:
26
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GW-Level II Concentrations
3.3.2.3 Level II Concentrations
List the wells subject to Level II contamination and sum the number of people served by
these wells. Enter this value below and on line 8b of Table 3-1. Do not include wells
already counted under Level I.
Level II Well Population Reference
Level II Concentrations Factor Value:
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GW-Potential Contamination
3.3.2.4 Potential Contamination
For each distance category in Table 3-11, first determine the number of people served by
drinking water from points of withdrawal subject to potential contamination. Do not
include those people already counted under the Level I and Level II concentration factors.
Based on the number of people within a distance category, assign a distance-weighted
population value for that distance category, using Tables 3-12 and 3-13, in accordance
with the instructions in Section 3.3.2.4.
Distance Distance-Weighted
Category Population Reference Population Value
Sum the distance-weighted population values across the distance categories and divide
the sum by 10. If the result is greater than 1, round to the nearest integer. If the result is
less than 1, do not round. Enter this value below and on line 8c of Table 3-1.
Refer to HRSGM:
• Sec. 7.2, Treatment of Karst, p. 137.
• Sec. 7.9, Scoring Sites With Multiple Aquifers, p. 153.
Sum of Distance-Weighted Population Values:
Potential Contamination Factor Value:
28
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GW-Resources
3.3.3 RESOURCES
Assess all wells that lie within the 4-mile target distance limit (and are not separated from
the site by a discontinuity) and draw water from the aquifer being evaluated or from an
overlying aquifer. Include also wells outside the target distance limit that have an
observed release from a source at the site.
Document if water drawn from any of these wells is used for the purposes listed in
Section 3.3.3 of the MRS. Alternatively, document that, although there are no drinking
water wells in the aquifer being evaluated or the overlying aquifers, the water in any of
these aquifers is usable for drinking water purposes.
Refer to HRSGM Sec. 7.8, Resources and Wellhead Protection Area, p. 193.
I If any of the above uses are documented, enter a value of 5 below and on line 9 of Table |
3-1. Otherwise, enter a value of 0.
Well Aquifer Resource Use Reference
Resources Factor Value:
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GW-Wellhead Protection Area
3.3.4 WELLHEAD PROTECTION AREA
Evaluate the Wellhead Protection Areas factor based on areas designated according to
Section 1428 of the Safe Drinking Water Act, as amended. Consider only those areas
applicable to the aquifer being evaluated or overlying aquifers. Assign a value of 20 if
either of the following criteria applies for the aquifer being evaluated or overlying aquifers:
A source with a ground water containment value greater than 0 lies, either partially or
fully, within or above a designated Wellhead Protection Area.
Observed ground water contamination attributable to the sources at the site lies, either
partially or fully, within the designated Wellhead Protection Area.
Refer to HRSGM Sec. 7.8, Resources and Wellhead Protection Area, p. 193.
If neither criterion applies, assign a value of 5 if, within the target distance limit, there is a
designated Wellhead Protection Area applicable to the aquifer of concern or an overlying
aquifer. Assign a value of 0 if none of the above applies.
Area Use Reference Value
Enter on the line below and on line 10 of Table 3-1 the highest value that applies.
Wellhead Protection Area Factor Value:
30
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