United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
(5201G)
EPA-540-B-00-009
QSWER 92S5.&-44
August 2000
www.epa.gov/superfund
Introductory Site Inspection
Training
Student Manual
U S EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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U.S. EPA TRAINING POLICY AND PROCEDURES
It is the policy of the U.S. Environmental Protection Agency's Environmental
Response Training Program to provide and maintain a learning environment that
is mutually respectful.
Please refrain from any actions or comments, including jokes, which might make
another class participant feel uncomfortable.
The Course Director is prepared to take appropriate action to ensure your full
participation and benefit from our training. Please present your concerns to the
Course Director or the U.S. EPA Project Officer, Bruce Potoka, at (513) 567-7537.
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9285.9-27
EPA540-R-94-099
PB95-963212
RECORD OF REVIEW
This manual is for reference use of students enrolled in scheduled training courses of the
U.S. Environmental Protection Agency (EPA). While it will be useful to anyone who
needs information on the subjects covered, it will have its greatest value as an adjunct to
classroom presentations involving discussions among the students and the instructional
staff.
This manual has been developed with a goal of providing the best available current
information; however, individual instructors may provide additional material to cover
special aspects of their presentation.
Because of the limited availability of the manual, it should not be cited in bibliographies or
other publications.
References to products and manufacturers are for illustration only; they do not imply
endorsement by EPA.
Constructive suggestions for improvement of the content and format of the manual are
welcome.
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INTRODUCTORY SITE INSPECTION TRAINING
2 DAYS
This course provides participants with an introduction to the Superfund site assessment
process and the fundamentals of the site inspection phase of this process. The site as-
sessment process is used to screen hazardous waste sites for inclusion on the U.S.
Environmental Protection Agency's (EPA) National Priorities List and to prioritize sites
for further investigation and remediation. Participants will receive the background
necessary to evaluate preliminary assessments and to develop and implement site
inspection strategies. The course is designed for individuals with little experience in the
initial evaluation of hazardous waste sites.
The course format is based on the EPA document entitled Guidance for Performing Site
Inspections Under CERCLA. The focus is on implementing EPA site inspection
guidance rather than on emphasizing the mechanics of scoring sites using the Hazard
Ranking System.
Topics to be discussed include an overview of the site assessment process; the
fundamentals of the Hazard Ranking System; data collection strategies; site
reconnaissance and documentation procedures; site, source, and waste characterization
techniques; groundwater, surface water, air, and soil exposure pathway analyses; and
reporting requirements.
After completing this course, participants will be able to:
Describe how the outcome of the site assessment process affects the placement
of a hazardous waste site on the National Priorities List.
Define key phrases related to site inspections.
Review a Preliminary Assessment document and develop a site reconnaissance
plan.
Develop site sampling strategies that will test preliminary assessment hypotheses
and will provide adequate data for performing Hazard Ranking System calculations.
Note: Calculators are highly recommended.
Continuing Education Units: 1.35
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TABLE OF CONTENTS
SECTION
Section 1
Section 2
Section 3
Section 4
Section 5
Section 6
Section 7
Section 8
Section 9
Section 10
TITLE
Introduction
Lecture Notes
SI Approaches
Lecture Notes
SI Planning and Sample Strategies Part 1
Lecture Notes
SI Planning and Sample Strategies Part 2
Lecture Notes
Case Study
Groundwater Pathway
Lecture Notes
Case Study
Surface Water Pathway
Lecture Notes
Case Study
Soil Exposure Pathway
Lecture Notes
Case Study
Air Pathway
Lecture Notes
Case Study
Radiation
Lecture Notes
SI Evaluation
Lecture Notes
SI Case Study
PAGE
1-1
2-1
3-1
3-12
3-36
4-1
4-14
5-1
5-29
6-1
6-12
7-1
7-9
8-1
9-1
10-1
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540B00009
SECTION ONE
INTRODUCTORY
SITE INSPECTION
TRAINING
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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INTRODUCTION
SITE INSPECTION TRAINING
This course...
Focuses on the role of the Site Inspection (SI)
in the site assessment process
Examines the relationship of the Si to the
Preliminary Assessment
Demonstrates that the SI process is flexible
and dynamic
SITE INSPECTION TRAINING (cont.)
Describes the activities necessary to develop
pathway-specific sampling
Emphasizes the importance of sampling smart
Introduces the concept of "integrated
assessments"
SITE INSPECTION TRAINING (cont.)
This course does not provide...
Detailed SI standard operating guidelines
or procedures
Hazard Ranking system (MRS) training
Region-specific policy, procedures, and
sites
PAGE 2
Introductory Site Inspection Training
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INTRODUCTION
GUIDANCE GOALS
Assist SI investigators in:
Conducting efficient, high-quality
assessments
Making correct site recommendations
Achieving national consistency in
performing Si's
SI Guidance. Chapter 1
SI GUIDANCE STRUCTURE
SECTION 1
SECTION 2
SECTION 3
SECTION 4
SECTION 5
SECTION 6
GLOSSARY
REFERENCES
APPENDICES A-E
INTRODUCTION
SI APPROACHES
PLANNING
SAMPLING STRATEGIES
SI EVALUATION
REPORTING REQUIREMENT
SI Guidance, Chapter 1
SUPERFUND TACKLES
HAZARDOUS WASTE EMERGENCIES AND
THE NATION'S MOST SERIOUS SITES
PRE-REMEDIAl SITE ASSESSMENT PORTION
Site Discovery & Study: Finding the Most Serious Sites
REMOVAL ACTIVIIT1ES
lulroduclory Site Inspection Training
PAGE 3
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INTRODUCTION
SUPERFUND TACKLES
HAZARDOUS WASTE EMERGENCIES AND
THE NATION'S MOST SERIOUS SITES (cent.)
REMEDIAL PORTION
Long-Term Cleanup: Fixing the Most Serious Sites
40 CFR 300.420
COMPARISON OF SUPERFUND PROCESS
AND RCRA CORRECTIVE ACTION
CERCLA Process
Noll feat ion
RCRA Process
Notification
Listing m CERCLJS
Listing on Docket (FF)
Preiurunarv Assessment
Site Inspection
MRS Package
RCRA Facility
Assessment
Inleragency Agreement (FF)
Inteiagency Agreement (FF)
COMPARISON OF SUPERFUND PROCESS
AND RCRA CORRECTIVE ACTION (cont.)
CERCLA Process
1
Interagency Agreement (FF)
Rentedttl Investigation/
FenfcMy Study
Record of Decision
JL
Remedial Design/
RCRA Process
1
Intengency Agreement (FF)
RCRA FaeWy Invesllgallon
Corrective Meesures Study
RCRA Peimtt
Correctt^e Meaiures
imptementellon
PAGE 4
Introductory Site Inspection Training
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INTRODUCTION
CERCLA INFORMATION
SYSTEM (CERCLIS)
Database to record the track activities at
discovered sites
All site assessment activities stem from
CERCLIS entry
Data included in CERCLIS
- Site name
- EPA identification number
- Discovery date
- Superfund program status and event dates
Please see: www.epa.gov/superfund
PRELIMINARY ASSESSMENT (PA)
First step to determine if site warrants
further CERCLA action
- Emergency response
- Site inspection
Low cost review of available information
(120 hours)
PRELIMINARY
ASSESSMENT (PA) (cont.)
Data collection and documentation performed
by federal agency responsible for site
Data evaluation and decision-making by EPA
- PA/HRS evaluation
Further Superfund action or NFRAP
Introductory Site Inspection Training
PAGE 5
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INTRODUCTION
THE SITE ASSESSMENT PROCESS:
PRELIMINARY ASSESSMENT (PA)
The PA identifies:
* Historical waste generation and disposal practices
Hazardous substances associated with sources
* Potential sources of hazardous substances
Important migration pathways and affected media
A comprehensive survey of targets
Critical sample locations for SI
SI Guidance. Section 1 1 1
SITE ASSESSMENT SUPERFUND
MRS
NO FURTHER REMEDIAL ACTION
PLANNED (NFRAP)*
Federal agencies not required to take further
action under CERCLA
Other authorities may require agencies to
initiate further assessment and/or cleanup
activities
- States
- Native American tribes
- Other federal regulations (e.g., RCRA
corrective action)
Formerly Known aซ Site Evaluation Accomplished (SEA)
PAGE 6
Introductory Site Inspection Training
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INTRODUCTION
NO FURTHER REMEDIAL ACTION
PLANNED (NFRAP)* (cont.)
Activities at facilities must be consistent with
policy of responsible federal agency and all
applicable federal and state environmental
statutes (e.g., NEPA, CWA, SDWA and FFCA)
Formerly known as Site Evaluation Accomplished (SEA)
WHY IS AN SI NECESSARY?
Required by CERCLA/SARA for all federal
facility sites not receiving NFRAP designation
after PA
MRS scoring requires analytical data
- Analytical data usually not available or
complete during PA
Data collected during other site investigations
may not address specific HRS requirements
THE SITE ASSESSMENT ACTIVITIES
PA ACTIVITIES
DATA
COLLECTION
57%
SI ACTIVITIES
PREPARATION
AND PLANNING
SITE
RECONNAISSANCE
SAMPLING AND
DATA
COLLECTION
REP Oft TING AND
DOCUMENTATION
EVALUATION
AND SCORING
mUoULictoiy o
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INTRODUCTION
THE SITE ASSESSMENT PROCESS:
Site Inspection (SI):
Intended to test PA hypotheses
Includes collection of environmental samples
Involves more detailed data collection than a
PA
Results in a decision to recommend for MRS
scoring or no further remedial action planned
(NFRAP)
S) Guidance. Section 1.1.2
THE SITE ASSESSMENT
PROCESS (cent):
Primary SI objectives:
Determine whether hazardous substances are
likely to be released to the environment (LR)
Identify substances present and their waste
characteristics (WC)
Determine whether hazardous substances
have impacted or could impact specific targets
CO
SI Guidance, Section 1.1.2
THE SITE ASSESSMENT
PROCESS (cont.):
Additional objectives:
Support potential removal activities
Support enforcement actions and identify
potential responsible party (PRP Search)
Collect data to support the remedial
investigation/feasibility study (RI/FS)
SI Guidance. Section 1 1,2
PAGE 8
Introductory Site
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INTRODUCTION
COMPARISON OF SI AND PA
SI
Limited scope
Biased sampling investigation
Flexible and dynamic
evaluation
Sampling strategy and data
collection to satisfy MRS
criteria
Additional information to test
critical assumptions and
hypotheses
PA
Limited scope
Nonsampling investigation
Step-by-step evaluation
Comprehensive target survey
Conservative assumptions
and professional judgment
introductory Site Inspection
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SECTION TWO
SI APPROACHES
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SI APPROACHES
THE TRADITIONAL SUPERFUND PROCESS vs. THE SACM PROCESS
CURRENT SUPERFUND
PROCESS
SUPERFUND ACCELERATED
CLEANUP MODEL (SACM)
Site
Discovery
Preliminary Assessment (PA)
Site Inspection (SI)
Expanded Site Inspection (ESI)
Site Screening and
Asssessment
(PA, SI, ESI. Rl)
'Assessments
combined
Hazard Ranking System (HRS)
National Priorities List (NPL)
Removal
Action as
Necessary
Enforcement
Activities/
State
Participation
Community
Relations
Remedial Investigation (Rl)
Feasibility Study (FS)
Selection of Remedy/
Record of Decision (ROD)
Remedial Design (RD)
Remedial Action (RA)
Operation and
Maintenance
V
NPL
Deletion
,
^
Enforcement
Activities/
State
Participation
Community
Relations
Long-Term
Action
complete
'Indicates assessment phase of pipeline
PAGE 2
introductory Site Inspection Training
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SI APPROACHES
TRADITIONAL SI APPROACHES
SI Guidance. Chapter 2
EXPANDED SI: GOAL
"... collect all data necessary to prepare an
HRS scoring package to propose the site to
the NPL"
SI Guidance. Section 2.2
EXPANDED SI: EMPHASIS
Hypotheses or conclusions not adequately
documented during the PA
Collect samples necessary to attribute
hazardous substance contamination to site
operations
Collect several samples to establish
background/quality control
SI Guidance. Section 22
Introductory Site Inspt
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SI APPROACHES
EXPANDED SI: EMPHASIS (cont.)
Collect missing data for significant pathways
not previously sampled
Collect all remaining nonsampling data
Establish thorough and defensible
documentation
Si Guidance. Section 2.2
EXPANDED SI: SAMPLING
Design to support MRS requirements:
"Observed release" of hazardous
substances relative to background
"Observed contamination"
"Levels of contamination"
SI Guidance. Section 22
EXPANDED SI: SAMPLING (cont.)
May require special field activities:
Monitoring well installation
Air sampling
Geophysical studies
Drum/tank sampling
Soil borings
Background sampling studies
Sl Guidance. Section 2 2
PAGE 4
Introductory Site Inspection Training
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S! APPROACHES
EXPANDED SI: SCOPE
Average 600 hours; typically 550 to 650 hours
Average 30 samples; typically 25 to 35
samples
Adequate QA/QC and background samples
Satisfy HRS requirements
Note: Hours are region specific
SI Guidance. Section 2.2
EXPANDED SITE ACTIVITIES
MOBILIZATION,
TRAVEL AND
OEMOBLIZATION
SAMPLING
AND DATA
COLLECTION
REPORT
PREPARATION.
HRS EVALUATION
AND REVIEWS
PREVIOUS
INVESTIGATION
REVIEW AND
PLANNMC
Total Expanded S! Hours: 620
SI Guidance. Section 2.2
SI APPROACH: TYPICAL DATA
COLLECTION ACTIVITIES
ACTIVITY
Nonsampfing data collection
Target sampling
Source sampling
Release sampling
Background sampling
Attribution sampling
QA/QC sampling
Special data collection or
sampling tasks
EXPANDED AND SINGLE SI
/
//
//
vV
,/V
//
//
If necessary
SI Guidance, Section 2.2, Tibls 2-3
introductory Site Inspection Training
PAGE 5
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SI APPROACHES
SINGLE SI
Eligibility for single SI:
Sites with available analytical data
- If previous analytical data are of sufficient
quality and indicate site is a likely NPL
candidate
"Simple" sites
- Well defined source, few targets, one
pathway of concern
SI Guidance. Section 23
SINGLE SI (cont.)
Eligibility for single SI: (cont.)
"Remote"
- Only one mobilization feasible
"Potential contamination" sites
- Targets subject to significant contamination
upon impact
SI Guidance, Sector 2.3
SINGLE SI: ACTIVITIES
Scope varies:
Collect data to satisfy MRS requirements
Obtain adequate QA/QC and background
samples
Collect missing nonsampling information for
significant pathways
Document thoroughly
SI Guidance. Section 2.3
PAGE 6
Introductory Site Inspection Training
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SI APPROACHES
INTEGRATED ASSESSMENTS
Integrating removal and remedial site
assessment investigations to achieve
increased efficiency and shorter response
times
TRADITIONAL APPROACHES
Removal assessments are traditionally
based on whether site conditions meet
National Contingency Plan (NCR) criteria
for a removal action
Remedial site assessments are focused
on collecting data for HRS
The need to integrate these programs is
based on the assumption that there is
duplication of effort between the programs
EPA Directive 9345 1-16FS (Fact Sheet). Integrating Removal and Remedial
Site Assessment Investigations. September 1993
WHAT IS THE
REMOVAL PROGRAM?
Federal response capability for releases or
threatened releases of:
Hazardous substances that present a threat
to public health, welfare or the environment
Oil spills into or on navigable waters and
shorelines
Petroleum releases from underground
storage tanks
Introductory Site Inspection Training
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SI APPROACHES
WHAT ARE THE REMOVAL
PROGRAM AUTHORITIES?
Statutory
Clean Water Act (CWA) as amended by the Oil
Pollution Act of 1990
Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA)
Superfund Amendments and Reauthorization Act
(SARA)
Oil Pollution Act
Regulatory
NCP
INITIATING REMOVAL ACTIONS
Authority to approve a removal is generally
based on estimated cost
Less than $200K - Onscene Coordinator (OSC)
$200K to $2M - Regional Administrator
Over $2M - Assistant Administrator, OSWER
PRP search
NCP requirement
Note Cost criteria are subject to change.
INITIATING REMOVAL
ACTIONS (cont.)
Action memorandum
Criteria for qualifying site
Proposed removal action
Estimated cost
PAGE 8
Introductory Site Inspection irainmg
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SI APPROACHES
WHAT ARE REMOVAL ACTIONS?
Near-term response actions taken to prevent, minimize,
or mitigate threats to public health, welfare, or the
environment including, but not limited to:
Collection and analysis of samples
Provision of alternate water supplies
On-site treatment
Source control/stabilization
Off-site storage, treatment, destruction, or disposal
Temporary relocation of threatened individuals
Installation of security fencing/guards
CLASSIFICATION OF
REMOVAL ACTIONS
Classic emergency
ป 33 percent of removal actions since 1985
ปImmediate action required
Time critical
Planning period of less than 6 months
CLASSIFICATION OF
REMOVAL ACTIONS (cont.)
Non-time critical
Planning period of greater than 6 months
is available
Agency conducts an engineering
evaluation/cost analysis (EE/CA)
Intfoduclory Site Inspection
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SI APPROACHES
HOW IS THE APPROPRIATE
RESPONSE SELECTED?
Discovery or.
Notification
. Removal Site.
Evaluation
. No release or
threatened release
Nonfederal party
undertaking proper
response
Removal action
. (removal action
memo to document
a threat)
Remedial action
THE REMOVAL EVALUATION
Removal preliminary assessments and site
inspections are conducted to determine and
evaluate:
Presence and magnitude of threat to health
or environment
Source and nature of the release
Activities required to mitigate threat
ป Ability of nonfederal party(ies) to undertake
response
Need for CERCLA-funded removal
REMOVAL CRITERIA
1 Actual or potential human or animal food
chain exposure
1 Actual or potential drinking-water
contamination
' Fire or explosion threat
> Hazardous substance in containers that
pose a threat of release
PAGE 10
Introductory Site Inspection Training
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SI APPROACHES
REMOVAL CRITERIA (cont.)
Highly contaminated soils at the surface
that pose direct-contact threat
Weather conditions that may cause
substances to migrate
Unavailability of other response or
enforcement mechanisms
HOW ARE REMOVALS
IMPLEMENTED?
Technical response support
Superfund Response - contractor
Superfund Assessment/Technical
Assistance (SATA) - contractor
U.S. Coast Guard (USCG)
Environmental Response Team (ERT)
HOW ARE REMOVALS
IMPLEMENTED? (cont.)
Mitigation/cleanup response
Emergency Rapid Response Services
(ERRS) - contractor
Site - specific contracts
Cooperative agreements (CAs) with states
Introductory Site Inspection Training
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St APPROACHES
ERRS
Analytical services
Containment and countermeasures
Cleanup, mitigation and disposal
Site restoration
REMOVAL AND
REMEDIAL ASSESSMENTS
Similarities in programs'goals
Evaluate potential for human exposure
to drinking water, soil, and airborne
contaminants
Evaluate threats to sensitive
environments (e.g.. wetlands)
Fact Sheet, Page 3
REMOVALAND
REMEDIAL ASSESSMENTS (cont.)
Similarities in activities
Telephone and file investigations
Site visits or PA recons
Sampling visits
Fact Sheet. Page 3
Introductory Site Inspection Training
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SI APPROACHES
INTEGRATED ASSESSMENT GOALS
Eliminate duplication of effort
Expedite the process
Minimize the number of site visits and
other steps in the process
Collect only the data needed to
assess the site appropriately
Fart Sheet. Page 3
INTEGRATED
ASSESSMENT APPROACH
Important features:
Combined notification/site discovery/screening function
Single site visit for both programs
Phased file searches
Integrated sample planning and inspection
See Figure 2. Integrated Assessment, Integrating Removal
and Remedial Site Assessment Investigations, Fact Sheet,
EPA 540-F-93-038, September 1993
Fad Sheet. Page 4
INTEGRATED ASSESSMENT
APPROACH (cont)
Notification/site discovery/screening
"One door" notification process
All sites screened for emergency response
Determine whether there is enough time for
a file search before initial site visit
Classic emergency
Respond immediately
Little or no time for file search or telephone
investigation
Fact Sheet. Page 3
Introductory Site Inspection Training
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SI APPROACHES
INTEGRATED ASSESSMENT
APPROACH (cont.)
File search:
Includes all elements of a removal
assessment file search
Table 1: File Search and Telephone
Investigaton, lists these elements
Document all elements for both programs
Fact Sheet. Page 3
INTEGRATED ASSESSMENT
APPROACH (cont.)
Initial field investigation/PA reconnaissance:
Combines elements from removal field visit and
remedial PA reconnaissance
Documentation procedures for removal
assessment may require revision to meet
remedial assessment needs
Would require on-site reconnaissance at all sites
Table 2: Data Elements of the Site Visit, lists data
needs for both programs
Fact Sheet, Page 5
INTEGRATED ASSESSMENT
APPROACH (cont.)
Sample (optional)
Should follow current removal assessment
approach
Should consider HRS data needs
Fact Sheet. Page 5
Introductory Site Inspection Training
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SI APPROACHES
INTEGRATED ASSESSMENT
APPROACH (cont.)
Review data and decide further action
Both programs meet to decide next step(s)
May continue removal assessment. PA, or both
concurrently
May expedite PA to determine whether remedial
site assessment requirements should be included
in sampling plans
Fact Sheet. Page 5
INTEGRATED ASSESSMENT
APPROACH (cont.)
Complete the PA:
Collect additional information needed to complete
PA
Calculate preliminary MRS score
Prepare PA report
Table 3: Data Elements Needed to Complete the
PA, should be consulted
Refer site to regional decision team if score is
greater than or equal to 28.5
Fact Sheet, Pages 5 and 6
INTEGRATED ASSESSMENT
APPROACH (cont.)
Integrated sampling plan:
Combines screening level SI plans and remaining
removal sampling activities
For site going to NPL, remedial project manager
(RPM) should be consulted
Could include sampling for long-term objectives
See Table 4. Integrating Removal and Remedial
Site Assessment Investigations, Fact Sheet. EPA
54O-F-93-038, September 1993
Fact Sheet. Page 6
Introductory Site Inspection
PAGE 15
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SI APPROACHES
INTEGRATED ASSESSMENT
APPROACH (cont)
Sl/removal assessment samp/ing:
One event
Meet needs of both programs
See Table 4, Integrating Removal and Remedial
Site Assessment Investigations. Fact Sheet. EPA
540-F-93-038. September 1993
Fad Sheet, Page 6
INTEGRATED ASSESSMENT
APPROACH (cont.)
Expanded Site Inspection/remedial investigation:
Option allowing Rl to start as soon as site
appears to qualify for NPL
NPL listing needs and Rl needs can be
incorporated into single sampling plan
Fact Sheet. Pages fi
FEDERAL FACILITIES
Integrated assessment at Federal Facilities:
EPA Federal Facilities Enforcement Office
(FFEO)
U.S. Department of Defense (DOD)
U.S. Department of Energy (DOE)
Memorandum: Guidance on Accelerating CERCLA Restoration
of Federal Facilities, August 22.1994
PAGE 16
Introductory Site Inspection Training
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SECTION THREE
SITE PLANNING AND
SAMPLING STRATEGIES
(PART 1)
Health and Safety
Plan (HASP)
Site-specific
Work Ran
Site Sample Plan
Investigation-derived
(IDW) Waste Plan
Sampling
Strategies
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SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
PLANNING - OVERVIEW
Four plans are needed to:
Refine investigation objectives: Sampling
Action Plan
Ensure activities proceed efficiently: Work
Plan
Ensure safety: HASP
Address investigation-derived waste (IDW)
Negotiate site access
SI Guidance. Chapter 3. Pages 15 and 30
REVIEW INFORMATION
FOR SI PLANNING
Compile all relevant and available site data
* - Hazardous waste sources completely
described? (boundaries, location,
containment substances)
- Migration pathways all evaluated?
- Human and environmental targets identified?
- Existing analytical data of CLP quality?
*See www.epa.gov/superfund/resources/chemicals.htm
SI Guidance. Seeton 35
REVIEW INFORMATION
FOR SI PLANNING (cont.)
Review PA reports
- Examine hypotheses; are they feasible/logical?
- Look for changes in site conditions over time
since PA was conducted.
SI Guidance. Section 35
Introductory Site
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SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
REVIEW INFORMATION
FOR SI PLANNING (cont.)
Other sources of information:
Previous investigations by other parlies
Investigations at nearby site - similar
information
Removal actions and reports
EPA or other federal agencies
State agencies
SI Guidance, Section 3.5
REVIEW IN FORMATION
FOR SI PLANNING (cont.)
Other sources of information (cont):
Health departments
Academic studies
Owner/operator records
Database vendors (facility audit reports)
- www.edmet.com
- www.ecesearchnet.com
- www.vjstacheck.com
SI Guidance. Section 3.S
EXISTING ANALYTICAL
DATA REVIEW
Use data to support design of sampling and
analysis program
Refer to SI Guidance, Table 3-7, Types of
Analytical Data, for application of existing data
Sl Guidance. Section 352
(ntroductory Site Inspection Training
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SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
EXISTING ANALYTICAL
DATA REVIEW (cont.)
SI Guidance, Table 3-8, Review of Previous
Analytical Data, provides a procedure for data
review
ป SI Guidance, Exhibit 3-1, Checklist for
Usability of Previous Analytical Data, should
be applied to existing data
SI Guidance, Section 352
WORK PLAN
Work plans should:
Summarize site background and hazards
present
Identify SI objectives
Set work schedule
Identify personnel and training needs
* Determine equipment/laboratory requirements
Include provisions to secure contract services
* See www. epa.gov/superf und/programs/d p/aboutsrv htm
SI Guidance. Section 36.1
A SAMPLE PLAN INCLUDES:
Fie
ad
Sa
sai
loc
Id operations - sequence for conducting field
jvities
mple locations, rationale, and methodology -
npletype, sample number, and sample
ation map
Refer to SI Guidance, Exhibit 3-2
SI Sample Ran Outline on the following pages
Introductory Site Inspection Training
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SITE PLANNING AMD SAMPLING STRATEGIES (PART 1)
A SAMPLE PLAN INCLUDES (cent):
A
san
pre
Sai
sto
alytical requirements and sample handling -
npting equipment, container types,
servation techniques, and filtering
nple delivery- laboratory locations, special
rage, and transport requirements
Refer to SI Guidance, Exhibit 3-2
SI Sample Plan Outline on the following pages
Introductory Site Inspection
PAGE 5
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SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
EXHIBIT 3-2: S! SAMPLE PLAN OUTLINE
INTRODUCTION
Briefly state the authority and purpose for conducting the SI and scope of the investigation. Discuss
the objectives and goals of the SI.
SITE DESCRIPTION AND REGULATORY AND OPERATIONAL HISTORY
Describe the site location. Identify the type of facility, whether it is active or inactive, and years of
operation. Describe its physical characteristics and setting (e.g., local land use, climate, topography,
geology, hydrology, hydrogeology). Include a map showing the location, include a site plan or sketch
showing features on and around the site.
Describe historical site operation, including all past and current operations and conditions. Identify
current and former owners/operators, types of site activities, wastes generated, and waste disposal
practices. Identify all sources and source types. Provide the hazardous waste quantity disposed in
each source, if possible, and provide volume or area of the sources. Identify hazardous substances
associated with or detected in the sources. Describe source containment. Describe any spills that
have occurred at the site.
Specify whether any sources are regulated by RCRA. Describe past regulatory activities, including
permits, permit violations, and inspections by local, state or federal agencies. If applicable, provide
emergency response and waste removal information. Summarize analytical results of earlier
investigations. Specify type of data (e.g., CLP, non-CLP, owner/operator).
COLLECTION OF NON-SAMPLING DATA
Describe additional non-sampling information to be collected (e.g., aquifer boundaries,
interconnections, and discontinuities; resources; drainage area; soil group; participate migration
factors); and the rationale for collecting this information. Discuss any field activities needed to obtain
this information.
SAMPLING ACTIVITIES
Discuss objectives of planned field activities.
Discuss the rationale for these tasks.
Describe procedures and necessary resources.
Provide explicit instructions for all field activities, including field observations, sampling, environmental
monitoring for health and safety purposes, and field QA/QC protocols. Reference appropriate
Standard Operating Procedures (SOPs). Discuss purpose of both onsite and offsite reconnaissances
and observations (e.g., to verify the selection of sample locations, to evaluate the degree of
containment at site sources, to measure source dimensions, to verify distances to nearby targets, and
to characterize additional sources of contamination not identified during previous investigations).
Justify proposed sample locations. Discuss methods to more fully characterize wastes and sources.
Identify specific targets to be sampled (e.g., drinking-water wells or intakes, fisheries, sensitive
environments), or substantiate target contamination hypotheses. Describe sampling strategy to
test or substantiate observed release hypotheses and presence of media contamination (e.g., soil,
groundwater, sediment, air. surface water).
Include a map or site sketch showing previous and proposed sample locations.
Summarize sample plan in a table, identifying sample types, sample numbers, sample locations,
and sample-selection criteria. Describe methods of sample collections and preservation, field
measurements, and analytical methods, Refer to Standard Operating Guidelines (SOGs) or
provide a table or checklist describing the SOGs.
Introductory Site Inspection Training
-------
SITE PLANT
AND SAMPLING STRATEGIES (PART 1)
Describe investigation-derived wastes (IDW) that may result from field activities. Reference the IDW
plan that describes the management approach for non-hazardous and hazardous IDW.
PROJECT MANAGEMENT
Identify all people who will be involved in the field activities, and discuss their specific responsibilities.
Identify all safety and sampling equipment and supplies. Describe any contractual services needed
to accomplish field activities. Summarize all transportation and shipping information.
* Describe community relations plans and meetings.
Provide information on SI costs (e.g., number of technical hours; number of CLP, field screening, or
other samples; subcontracting costs). Provide schedule for SI activities and deliverables. Summarize
any special requirements that impact the SI (e.g., special safety considerations, special analytical
service, or special equipment).
Reference the work plan.
ATTACHMENTS
Sample summary table.
Sample location sketch.
List of references cited in this plan.
Health and safety plan.
Appropriate SOPs and SOGs.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992
Introductory Situ inspection Tr.iuiiiKj
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
HEALTH AND SAFETY PLAN (HASP)
Goal: To establish requirements and procedures
to protect the health and safety of investigative
personnel and nearby public.
* Routine operations - describe hazards, list key
safety personnel, levels of protection by task,
designate work areas, security, environmental
monitoring, training requirements, and weather-
related problems.
SI Guidance, Section 3.6.3
HEALTH AND
SAFETY PLAN (HASP) (cont.)
> Emergencies - communication alternatives,
contact procedures for emergency response
units, emergency equipment, map of route to
hospital, transport vehicles, worker evacuation,
and decontamination.
SI Guidance. Section 3.6.3
INVESTIGATION-DERIVED WASTES
(IDW) MANAGEMENT PLAN
stc
Minimize quantity of wastes generated
Remove wastes that pose an immediate
threat to human health or the environment
Must comply with applicable federal and
state requirements
Refer to Directive 9345.3-02, Management of
Investigation-Derived Wastes During Site
Inspections
Guidance, Section 36 4
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 1)
SITE ASSESSMENT TEAM
Site Assessment Manager (SAM)
Health and safety officer
Field team
Chemist/data evatuator
Hydrogeoiogist
Subcontracts officer/procurement officer
ON/OFF SITE
RECONNAISSANCE
Verify site conditions
Verify sample locations (accessible?,
obstructions?)
ป Locate and identify all sources
Determine physical state of wastes
* Evaluate source containment and migration
SI Guidance. Section 3.7
ON/OFF SITE
RECONNAISSANCE (cont.)
Identify overland flow paths (or subsurface
storm water drainage system)
Determine distance from sources to targets
Refine site sketch
Evaluate need for emergency response
SI Guidance, Section 3.7
Introductory Site Ir
PAGE 9
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART
SITE ACCESS
Legal access must be obtained from site owner
before conducting an SI
Voluntary entry - by notifying owner in writing
of activities to be conducted (sample
collection, photography)
Conditional entry - consent to entry with
restrictions (limit area of reconnaissance,
employee interviews, records)
Sl Guidance. Section 3.7.3
SITE ACCESS (cont.)
Entry with a warrant - SI must be conducted
in strict accordance with warrant
Consult with EPA Office of Regional Counsel
SI Guidance. Section 373
COMMUNITY, NEIGHBORHOOD
AND GOVERNMENT CONTACTS
Contact local representatives in advance
Explain purpose of SI
Explain tasks to be performed
Identify contact for further information:
regional Site Assessment Manager (SAM)
SI Guidance, Sections 37 4 and 3.7.5
PAGE 10
Introductory Site Inspection Training
-------
, E PLAIMMIMG AND SAMPLING STRATEGIES (PART 1)
COMMUNITY, NEIGHBORHOOD AND
GOVERNMENT CONTACTS (cont.)
Determine routing of SI results and other
information
Consult Community Relations in Superfund:
A Handbook. Section 4.1, OSWER Directive
9230.0-03C, January 1992
Contact appropriate municipal, county, state,
and federal officials before SI
St Guidance, Sectors 374 and 37.5
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SITE PLANNING AND
SAMPLING STRATEGIES
(PART 2)
Health and Safety
Plan (HASP)
Site-specific
Work Plan
Site Sampie Plan
Investigation-derived
(IDW) Waste Plan
Sampling
Strategies
PAGE 12
Introductory Site Inspection Training
-------
SiTE PLANNING AND SAMPLING STRATEGIES (PART 2)
SAMPLE COLLECTION ISSUES
Demonstrate that hazardous substances are
present
Determine whether they have migrated from
their original locations to specific targets
SI Guidance, Section 3.12
Waste Source
Samples
Landfills
Surface impoundments
Drums/con taners
Piles
Contaminated soil
\
Media (Environmental
Samples)
Groundwater
Surface water
Soil (sediment)
Air
Further discussion of sample types is found in Table 3*1.
Types of Samples, Page 16 of the SI Guidance
SAMPLE VARIABILITY: FACTORS
Sample collection and handling techniques
Spatial variability
Temporal variability
Media variability
SI Guidance. Section 3.1.2. Pages 17-212
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SAMPLE VARIABILITY:
MEDIA-SPECIFIC SAMPLING
Surface and groundwater
Soil/sediment
Air vapors or particulates
Tissue
Containerized materials
Turn to SI Guidance, Table 3-4, Sampling Issues
Affecting Confidence in Analytical Results, Page 19,
for media-specific sampling issues
SI Guidance, Section 3.1.2, Piges 17-212
SAMPLE ANALYSIS OPTIONS
Contract Laboratory Program (CLP):*
Standardized analytical services provided
by laboratories under contract to U.S.
Environmental Protection Agency (EPA)
- Organics/inorganics
- Water or solid samples
*See www.epa.gov/superfund/programs/dp/process.htm
SI Guidance, Section 3.4. Page 24
SAMPLE ANALYSIS OPTIONS (cont.)
Contract Laboratory Program (CLP) (cont.):
Reliable, legally defensible data
- Broad spectrum analysis
/ Target compound list (TCL)
/ Target analyte list (TAL)
Validated data from other sources (state or
PRP)
S! Guidance. Section 34. Page 24
PAGE 14
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SAMPLE ANALYSIS OPTIONS (cont.)
Non-CLP services:
May provide data of similar quality to CLP
Analytical protocols must be selected -
method, detection levels, instrumentation, etc.
SI Guidance. Section 3.4. Page 25
SAMPLE ANALYSIS OPTIONS (cont.)
Field Analytical Screening Program (FASP):
Use "portable" analytical instruments
Allows for "intelligent" decision-making in
the Held
SI Guidance. Sedan 3.4. Page 25
SAMPLE ANALYSIS OPTIONS (cont.)
Field Analytical Screening Program (FASP) (cont.):
Applications:
~ Screen many samples - Select sample locations
- Design soil sampling - Reduce CLP costs
- Fast turnaround time
- Determine extent of waste migraton
- Determine monitoring well locations
- Estimate hazardous waste quantity (HWQ)
SI Guidance. Section 34. Pige 25
Introductory Site Inspection Training
PAGE 15
-------
SITE PLANNING AND SAMPLING STRATEGIES {PART 2)
FIELD QUALITY ASSURANCE AND
QUALITY CONTROL (QA/QC)
CONSIDERATIONS
Help evaluate quality of analytical results and
field methods
QA/QC samples treated in same manner as
site samples
Consult EPA regional guidelines for number
and type of QA/QC samples to be collected
SI Guidance. Section 3.2. Page 212
QA/QC SAMPLE TYPES
Co-bated or
Duplicates
Replicates or Splits
Field Blanks
Trip Blanks
Field Rinsates
(Equipment Blanks)
Field Matrix Spices
Two samples ootected at the same time and location.
One sample tret is divided and sent to the same or
Sampfes of contaminant-free medium that are either
transferred from one container to another or are
exposed to field conditions.
Samples prepared from contain rant-free medium
and placed in sample containers prior to the SI. They
are kept unopened with sie samples throughout the
investigation.
Dctoneed water flushed throug h sampling equpment
after decontamination and before resampling to
montor decontamination procedures.
Field samples prepared by adding a known amount or
contaminants to selected site samples
QA/QC SAMPLES
St(
Collected to confirm precision and accuracy
of data
QA/QC samples for Si's are limited
- One aqueous trip blank per day
- One equipment rinsate blank for each
medium collected
Turn to SI Guidance, Table 4-6. Guidance for Minimum
QA/QC Samples: Expanded SI or Single St. Page 56,
SI Guidance
3uidance. Chapter 43
PAGE 16
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
QA/QC SAMPLES (cont.)
Suggested QA/QC sample guidance for
expanded and single Si's is found in Table 4-6
(Note: EPA regional guidance may differ)
Refer to Qualified Data Fact Sheet, Appendix A
Turn to SI Guidance. Table 4-6, Guidance for Minimum
QA/QC Samples: Expanded SI or Single SI, Page 56,
SI Guidance
SI Guidance. Chapter 4.3
Introductory Site Inspection Trail
PAGE 17
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
TABLE 4-6: GUIDELINES FOR MINIMUM QA/QC SAMPLES
EXPANDED SI OR SINGLE SI
MEDIUM
Aqueous
Soil and sediment
Air
Source material
REPLICATES/
DUPLICATES
1 in 20
1 in 20
1 in 20
1 in 20
FIELD BLANKS
1 in 20
1 in 20
Not applicable
Usually not required
TRIP BLANKS
1 /day of sampling
Usually not required
1 /day of sampling
Usually not required
Sample requirements should be developed on a site-specific basis. Laboratory
blanks and spikes are method-specific and are not included in the table.
PAGE 18
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
QA/QC SAMPLES: MINI EXERCISE
(NO DISPOSABLE EQUIPMENT)
ฉGWB flflft
ฎ SSB Residence
@ Private
Weil
GW1
f ฉV01
ฃ^3 ^ n:
\ Lagoon ) *"^^fct
\ / SSiX
\ /
SW2 @ff
Small
-^ -Stream
(10cfs)
4'SWB
'f' \ S = Source :i
"> \ SW = Surface Water i:
t'/ \ SO = Sediment ?
k^ ,'s ? SS = Surface Soil }
^3- ซju s GW = Groundwater ?
-?j sec ^ ฐ 25n 50ft -
5 1 .1 1 :
QA/QC SAMPLES: MINI EXERCISE (cont.
(NO DISPOSABLE EQUIPMENT)
] SAMPLING PLAN
Sampled
SD1
SD2
SS1
SSB
SW1
SW2
SWB
S1
6W1
GWB
Rational
Sediment from lagoon
Sediment from probable
point of entry (PPE)
Surface soil from ditch
Surface soil background
Surface water at PPE
Surface water downstream
of PPE
Surface water background
Source (aqueous)
Groundwater from private well
Groundwater background
QA/QC SAMPLES '.
Expanded SI
i
SELECTING ANALYTICAL
PARAMETERS
Does
high quality
or screening
analytical data
xist?
SI Gutdam. Chapter 4
May perform
partial analyses based
on prior results
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
HRS SAMPLING CONSIDERATIONS
Several HRS elements require sample data for:
* Site and source characterization list
- Identify hazardous
wastes/substances/source types
- Determine hazardous waste quantity
- Delineate source boundaries/containment
SI Giidance. Section 3.3. Paces 22-23
HRS SAMPLING
CONSIDERATIONS(cont)
Several HRS elements require sample data for:
Observed release and areas of observed
contamination
- Provide direct evidence of an "observed release"
to affected media
- Demonstrate "significant" contamination
- Estimate area of contamination
- Demonstrate "attribution" to site activity/operations
SI Guidance. Section 3.3. Pages 22-23
HRS SAMPLING
CONSIDERATIONS(cont)
Additional HRS elements requiring sample data to
determine:
Levels of contamination at specific targets
- Document "actual contamination"
- Targets include drinking-water wells, surface
water intakes, fisheries, workers,
residential/school properties, and sensitive
environments (wetlands)
- Support "potential contamination"
- Define levels of contamination
SI Guidance. Section 3.3
PAGE 20
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
MRS SAMPLING
CONSIDERATIONS(cont.)
Additional MRS elements requiring sample data
to determine (cont.):
Target distances
- Establish target distance limits for each
pathway
SI Guidance. Section 33
HRS SAMPLING CONSIDERATIONS:
LEVELS OF CONTAMINATION
Tatget Samptod
Yes
Actual Contamiutjon
toncentratwirs
Above
enchmark'
No
Sr QuKHnci. SidUn 3.3
Lavซl 1 ConUmmation
IntrocHicloiy Site luspoction Tr.nmng
PAGE 21
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2) ^oo
*
EGEND
f^
FENCE
WETLAND
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X
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(
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u.
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UJ
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~^\ ~^l _ij \ \" Q
~^l \ \ CO
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25
i
[ * ^ *W%|
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* ^^4
uj / -^L
uj / ;^
o-L g / / T\cv,
4 a ฃ /p/ g
Q Q / * / n1 uj
co a. a.
PAGE 22
Introductory Site
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
DEMONSTRATING A RELEASE:
MRS REQUIREMENTS
An observed release can be documented by:
Direct observation
Chemical analysis (preferred method)
SI Giidance. Chapter 4.41
DEMONSTRATING A RELEASE:
LEVELS AND
QUANTITATION LIMITS
Background Sample: A sample used in establishing
a background level.
Contract Laboratory Program (CLP): Analytical
program designed to provide legally defensible
analytical results, supported by a high level of
quality assurance and documentation.
MRS Manual. Page 57
DEMONSTRATING A RELEASE:
LEVELS AND
QUANTITATION LIMITS (cont.)
Contract-required Detection Limit (CRQL): The
substance-specific level that a CLP laboratory
must be able to routinely and reliably detect in
specific sample matrices (the level that a CLP
laboratory must reliably quantify).
Method Detection Limit (MDL): The lowest
concentration of a hazardous substance that a
method can detect reliably in either a sample or a
blank.
MRS Manual. Page 57
Introductory bite Inspection
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
DEMONSTRATING A RELEASE:
LEVELS AND
QUANTITATION LIMITS (cont.)
Sample Quantitation Limit (SQL): The quantity of
a substance that can be reasonably quantified
given the limits of detection for the methods of
analysis and sample characteristics that may
affect quantitation (e.g.. dilution, concentration).
MRS Manual. Page 57
DEMONSTRATING A RELEASE
BY SAMPLING
Key Factor:
To demonstrate a release by chemical analysis
for a pathway, at least one sample must show
contamination significantly above the background
level for a hazardous substance at or above the
SQL
See SI Guidance, Page 59, tor a discussion
of the term "significance"
SI Guidance, Chapter 4.41
DEMONSTRATING A RELEASE
BY SAMPLING (cont.)
DOCUMENT OBSERVED
RELEASE
(actual contamination)
SI Guidance, Chapter 4 41
PAGE 24
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
DEMONSTRATING A RELEASE
BY SAMPLING: BACKGROUND
Considerations:
Naturally occurring vs. man-made
concentrations
Site-specific chemical analytical data
vs. published data
Comparability of background and
release samples
Background sampling locations
SI Guidance. Chapter 4.41
DEMONSTRATING A RELEASE
BY SAMPLING: ATTRIBUTION
Considerations:
Some portion of the release must be
attributable to one or more sources
Can use a unique hazardous substance from
a site to differentiate it from other sites
May be addressed by source characterization
Age of site
Transformation products
SI Guidance. Chapter 4 41
ATTRIBUTION?
Source
Sample
1,2 DCS
Benzene
Toluene
Xylene
Introductory Site
Tr.iming
PAGE 25
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
DEMONSTRATING A RELEASE
BY SAMPLING: TARGETS
Evaluate target factors:
Nearest individual
Population
Sensitive environments, including wetlands
Evaluate on the basis of:
Actual contamination (Primary Targets)
Potential contamination (Secondary Targets)
SI Guidance. Chapter 4.41
DEMONSTRATING ACTUAL
CONTAMINATION
> Must first demonstrate observed release
' Targets exposed to concentrations meeting
observed release criteria are evaluated as
actual contamination
(download from vnww.epa.gov/superfund/resources/scdm)
Si Guidance. Chapter 4.4.1
DEMONSTRATING ACTUAL
CONTAMINATION (cont.)
Two degrees of actual contamination
- Level I = concentration :ป applicable benchmark(s)*
- Level II = concentration < applicable benchmarks}*
Use benchmark that provides highest score
* See Superfund Chemical Data Matrix (3COM)
(download from www.epa.gov/cupenVind/reBources/scdm)
SI Guidance. Chapter 4.4.1
PAGE 26
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
ACTUAL CONTAMINATION?
CONCENTRATIONS (in
ANALYTE
COMPOUND X
SITE
25
BACKGROUND
5U
INTAKE
20
BENCHMARK
15
U = nondetect
Numerical value is die method detection limit (MDL)in
micrograms per liter (^g/L). Therefore, Compound X was not
detected in the background sample at a concentration 2
HRS SAMPLING CONSIDERATIONS.
WHAT ARE BENCHMARKS?
i
s
ป Health or ecological-based reference
concentrations that reflect relative risk
(for example, cancer)
ป Media and threat-specific
Any threat may involve more than one
benchmark
Benchmarks are presented in Table 3-6,
Media-specific Benchmarks, St Guidance, Page 23
1 Guidance. Section 3.3
HRS SAMPLING CONSIDERATIONS:
WHAT ARE BENCHMARKS? (cont.)
SIC
Found in look-up table (for example,
Super-fund Chemical Data Matrix {SCDM})
Default to Level II if a sample meets observed
release criteria, no benchmark applies
Benchmarks are presented in Table 3-6,
Media-specific Benchmarks, SI Guidance, Page 23
Suidance. Section 33
Introductory Silt' Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
TABLE 3-6: MEDIA-SPECIFIC BENCHMARKS
HRS PATHWAY/THREAT
Groundwater
Surface Water
Drinking-water Threat
Drinking-water Threat
Environmental Threat
Groundwater
Air
BENCHMARKS1
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Screening Concentrations23
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Screening Concentrations2-3
Food and Drug Administration Action Levels
Screening Concentrations2-3
Ambient Water Quality Criteria
Ambient Aquatic Life Advisory Concentrations
Screening Concentrations"
National Ambient Air Quality Standards
National Emmissions Standards for Hazardous Air Pollutants
Screening Concentrations2 3
1See Superfund Chemical Data Matrix (SCDM)
2 Screening concentrations for cancer corresponding to concentrations for the 10-* individual cancer
risk for oral exposure (inhalation exposure for the air pathway)
3 Screening concentration for noncancertoxicological responses corresponding to RFDs for oral
exposure (inhalation exposure for the air pathway)
* If more than one benchmark exists, use lower value.
SCDM-Download from: www.epa.gov/superfund/resources/scdm
Guidance for Performing Site Inspections Under CERCLA, USBPA, September 1992
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SUPERFUND CHEMICAL
DATA MATRIX (SCDM):
A source for factor values and benchmark values applied
when evaJuathg potential National Priority List (NPL) sites
using the Hazard Ranking System (HRS). Factor values
are part of the HRS mathematical equation for determining
the relative threat posed by a hazardous waste site and
reflect hazardous substance characteristics such as:
Toxicity
Persistence
Mobility
Potential for Bioaccumuiation
EPA web silerwww.epa.gov/superfund/resoufces/scdm
SI SAMPLING PRINCIPLES
Collect analytical data to test PA hypotheses
Identify hazardous substances present
* Determine waste quantity
Determine whether a release has occurred
Determine impact on targets
Determine need for further investigations
SI Guidance. Chapter 41.2
SI SAMPLING CONSIDERATIONS
Concentrate on samples in major pathways
that affect the score
Use previous analytical data or published
data*
Limit collection of background and QA/QC
samples
"Subject to data review and evaluation
SI Guidance, Chapter 4 1 2
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
EXPANDED AND SINGLE SI
SAMPLING PRINCIPLES
Coll
D<
DC
Dซ
DC
Co/A
Con
SISuk
act fully documented data to prepare HRS package
scument observed releases (GW, SW, Air)
>cument observed contamination (Soil exposure only)
Jtermine waste quantity
>cument levels of target exposure
9ct field data for the Rl when appropriate
duct field activities beyond the scope of focused SI
Turn to SI Guidance, Section 4.1 .3, Page 49,
for a list of expanded SI activities
tanct. Chapnr 4.1.3
EXPANDED AND SINGLE SI
CONSIDERATIONS
Collect samples to improve documentation for
factors that significantly affect scoring
Collect adequate background and QA/QC
samples
SI Guidance, Chapter 4.1.3
PAGE 30
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2}
TABLE 4-3: PRIORITIES FOR EXPANDED SI SAMPLES
SAMPLE CRITERIA
PRIORITIES
Number of pathways sampled
Sample pathways critical to site source.
If multiple pathways are critical to site score, sample to fully
document all remaining site hypotheses.
Number of targets sampled
Sample targets (e.g., drinking-water wells and intakes, residential
and school properties, surface water sensitive environments, and
wetlands) most likely to be exposed to site-related contamination.
Resample targets where previous analytical results are question-
able or where background concentrations are needed to docu-
ment contamination of targets.
Number of sources sampled
Sample sources to attribute hazardous substances to site.
Sample to more fully describe areas of observed surficial contami-
nation.
If multiple source types exist at site, at a minimum, sample each
different source type.
Number of release samples
Sample to document a release for critical pathways. When
possible, collect samples to document an observed release in
conjunction with a target exposed to actual contamination.
Limit number of release samples to critical pathways.
Number of background and
QA/QC samples
Collect background and QA/QC samples necessary to confidently
document site score.
Other criteria
Use previous analytical data to optimize sample locations.
Do not resample at locations where reliable previous analytical
data documented a hazardous substance or a release, unless
samples are needed to pair those with background samples taken
at the same time.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992
Inspection Tr,iin:n<
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SAMPLING STRATEGIES:
CONCLUSIONS
The key to any successful SI: SAMPLE SMART
Conserve resources
Set sampling priorities
Emphasize dual-purpose sampling
Use previous analytical data to augment scope
SAMPLING STRATEGIES:
CONCLUSIONS (cont.)
The key to any successful SI: SAMPLE SMART (cont.)
Tailor sampling to meet SI objectives/use
screening sample methods
Consider MRS math when planning samples
Focus on major pathway(s)
Focus on critical HRS factors
SOURCE DEFINITION
An area where hazardous substances may have
been deposited, stored, disposed of, or placed.
Also, soil that may have become contaminated
as a result of hazardous substance migration.
But not volumes of air, groundwater, surface
water, or sediment that have become
contaminated through migration.
SI Guidance. Glossary. Pag* 121
PAGE 32
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
BASIC PRINCIPLES
Sample to confirm or refute contamination at site
Sample to characterize sources
Identify hazardous substances present
Support determination of waste characteristics
- waste quantity, toxicity, mobility
Support attribution to site activities/operations
SI Guidance. Section 42
SOURCE CHARACTERIZATION
GUIDELINES
Biased sampling:
Sample where wastes are likely to collect or
be concentrated
Collect background sample for selected
sources (for example, contaminated soil)
Use composite samples carefully
SI CUUmmm. CHปปW 4.1.}
MINI EXERCISE:
WHAT ARE THE SOURCES? WHAT KIND OF SAMPLES'
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Inlrotluclory Situ Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
TABLE 4-4: SOURCE SAMPLING STRATEGIES
CRITERION
EXPANDED SI AND SINGLE SI
Primary objective
To verify inconclusive data collected during focused SI.
In limited situations, to help quantify hazardous waste quantity.
Samples to help demonstrate
observed contamination
Samples to further describe the area of observed contamination
in the direction of targets for the soil exposure pathway.
Samples to help evaluate source
containment or source type
Generally only collected when the containment factor value fora
migration pathway is not 10; sometimes collected to demonstrate
a biogas release if air pathway is significant pathway.
Samples to help describe source
boundaries and estimate hazard-
ous waste quantity
In certain situations, samples to estimate the depth of a source or
to further describe the area of sources other than contaminated
soil (e.g., landfill, land treatment, buried surface impoundment).
In certain situations, samples to estimate hazardous constituent
quantity or hazardous waste volume quantity.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992 (modified)
itroductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
CASE STUDY:
EXAMPLES OF SOURCE SAMPLING STRATEGY
Located near a town of 10,000 people, the Lakefield Farm Site is an abandoned strawberry
farm that was used for various types of waste activities for an unknown period (see Lakefield
Farm Site Sketch #1). During the preliminary assessment, three potential sources were
identified: a wet surface impoundment with a volume of approximately 45,000 cubic feet of
electroplating sludge; a drum storage area containing about 30 leaking drums (contents
unknown) at the southeast comer of the site; and an area of stained soil near the site's
western boundary.
LAKEFIELD FARM SITE
Sketch #1
Surface Impoundment
(Sludge)
SS-2
firm
Nearest Well and
Nearest Individual
Drum LAKEFIELD
Sฃef FARM SITE
t
N
Stained
Soil
GREEN ACRES
SUBDIVISION
KEY
Source Samples
Drinking Water Well
Irrigation Well
(Not to Scale)
Municipal Well
Introductory Site Inspection Training
PAGE 35
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SOURCE SAMPLING STRATEGY FOR EXAMPLE SITE
POTENTIAL WASTE
SOURCE AREA
Wet Surface
Impoundment
Drum Storage Area
Stained Soil
SI SAMPLING
STRATEGY
Collect one composite
source sample of
impoundment sediments
(SD-1) plus one sludge
sample (SL-1) to
evaluate hazardous
substances present.
Collect one composite
surficial soil sample
(SS-1) adjacent to
drums to determine
hazardous substances
present.
Collect one composite
surficial soil sample
(SS-2) to determine
whether area is contami-
nated and to identify
hazardous substances.
HRS
CONSIDERATIONS
More than 675,000
cubic feet is needed to
increase HWQ factor
to next category value.
More than 1,000 drums
are needed to increase
HWQ factor value to
next category value.
More than 78 acres of
contaminated soil are
needed to increase
HWQ factor value to
next category.
NONSAMPLING
DATA COLLECTION
Obtain physical
dimensions of source:
evaluate containment,
consider using aerial
photographs.
Verify number of
drums, evaluate
containment, look for
container markings
and examine area
around drums.
Obtain physical
dimensions or area,
evaluate containment.
PAGE 36
Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2)
SOURCE SAMPLING EXERCISE:
ACME MANUFACTURING COMPANY
OBJECTIVE
Using available site information, develop a source sampling strategy, implementing
procedures established in the SI guidance manual.
METHOD
1. Review the general site information provided below.
2. Identify site sources on the map.
3. Develop a source sampling strategy that includes source characterization,
background determination, and collection of quality control samples. You are
limited to 20 samples. You do not need to use all available samples.
4. Record your sampling strategy on the table provided.
GENERAL SITE INFORMATION:
The ACME Manufacturing Company site is an inactive electroplating facility. The
total acreage is about 10 acres (see site map).
Rinse water from the electroplating process was discharged to treatment ponds
from 1907 until 1995.
Drums, which were located in the former drum storage area found on the
northwestern corner of the facility property, are believed to have contained waste
solvents. They were held there prior to offsite removal.
Stained soil was observed adjacent to the bulk chemical unloading area and
manufacturing building.
The waste pile appears to be dried sludge from the treatment ponds.
The landfill reportedly received "off-spec" products, spent solvents, and treatment
pond sludge.
Leachate seeps and stained soil were observed along the southeast comer of the
landfill with stressed vegetation extending beyond the facility boundary.
Introductory Site Inspection Training
PAGE 37
-------
SITE PLANNING AND SAMPLING STRATEGIES {PART 2)
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Introductory Site Inspection Training
-------
SITE PLANNING AND SAMPLING STRATEGIES (PART 2}
SOURCE SAMPLING EXERCISE:
SITE NAME: ACME MANUFACTURING COMPANY
SAMPLE ID#
SAMPLE TYPE
AQUEOUS//NON AQUEOUS
RATIONALE
Total Samples:
Special Sampling Considerations:
Introductory
-------
SECTION FOUR
GROUNDWATER
PATHWAY
Resources
Wellhead
Protection
Area
Nearest
Well
\
Groundwater
Population
A
AQUIFER
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY
Basis for pathway score
Number of people served by drinking-water
wells within aquifer(s) of concern
* Likelihood of release to each aquifer
Likelihood that drinking-water wells are
contaminated by site
SI Guidance, Sector 4.5
GROUND WATER PATHWAY:
REVIEW PA INFORMATION
Determine whether major pathway of concern is
based on:
* Suspected release
Primary targets
Number of secondary targets
* Characteristics of waste
GROUNDWATER PATHWAY:
REVIEW PA INFORMATION (cont.)
Has contamination already been demonstrated?
Visual observation of the source
Previous sampling
Reports of suspected release
Number of secondary targets
Introductory Site Inspector
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
REVIEW PA INFORMATION (cont.)
Identify specific information concerning
primary targets
-Type of well/population served
-Distance from outer boundaries of sources
-Depth of screened interval
GROUNDWATER PATHWAY:
REVIEW PA INFORMATION (cont.)
* Identify wellhead protection areas
Identify relevant hydrogeological information
Identify potentially affected resources
Where do you expect hazardous substances
to be found? Sinkers (DNAPLs) vs. floaters
(LNAPLs).
DNAPL = Dense non-aqueous phase liquid
(i.e., tetrachioroethene)
LNAPL = Light non-aqueous phase liquid
(i.e., gasoline, #2 fuel oil)
GRQUNDWATER PATHWAY
Compile existing analytical and nonsampling
information
SI data summary document can be used to:
Summarize existing information
Identify factors not fully evaluated
Focus additional data collection efforts
, Go to SI Guidance Appendix B, I
j SI Data Summary, Page B-11 to B-11 {
SI Guidance. Appendix B
(iuctoty Stlf Inspection Training
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
HRS CONSIDERATIONS
Likelihood
Release
of I i Waste I
iij I Characteristics I
Targets
T
T
Demonstrate/Document
Release
Conducted
Under
Source
Characterization
PA Guidance, Section 3.4
Actual
Contamination
(Primary Target)
LEVEL I
Potential
Contamination
(Secondary Target)
LEVEL II
GROUNDWATER PATHWAY:
LIKELIHOOD OF RELEASE
Document an observed release by:
Direct observation (injection well)
Chemical analysis
Chemical analysis is preferred
SI Guidance. Section 4.5
GROUNDWATER PATHWAY:
LIKELIHOOD OF RELEASE (cont.)
At least two groundwater samples are needed
to document an observed release
- Background sample (upgradientwith
respect to direction of groundwater flow and
site sources)
- Release sample (downgradient with respect
to site sources, background sample, and
groundwater flow direction)
Introductory Site Inspection
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
LIKELIHOOD OF RELEASE (cont)
Well samples should be from same aquifer
and comparable screened intervals
Wells should be of similar construction
GROUNDWATER PATHWAY: LIKELIHOOD
OF RELEASE/OBSERVED RELEASE ?
CONTAMINATED
WELL SAMPLE
(downgradient)
BACKGROUND
WELL SAMPLE
(upgradiecit)
200'
GROUNDWATER PATHWAY:
LIKELIHOOD OF RELEASE (cont.)
Sample nearest well expected to be
contaminated
Background well should be out of influence of
site and upgradient
Sample both wells within the same sampling
period (1-3 days)
Samples should be similar
- Sample analyses
- Filtered or unfiltered
SI Guidance, Section 4.5
Site Inspection Training
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
TARGETS
PA primary targets are sampled at SI
to establish "actual contamination"
PA secondary targets at SI become
"potential contamination"
GROUNDWATER PATHWAY:
TARGET DISTANCE LIMIT
The Target Distance Limit (TDL) is 4 miles
Can be extended if we have an Observed
Release
If a ground water plume is the site source,
begin measuring the 4-mile TDL from the
center of the plume
MRS Rule. Section 3.0.1.1. Page 51595
GROUNDWATER PATHWAY:
AQUIFER EVALUATION
Evaluate aquifers separately
If aquifer interconnections occur within 4 miles
of the source, you may combine aquifers
If aquifer discontinuities exist within 4 miles,
only score based on populations before the
discontinuity
The discontinuity must entirely transect the
aquifer to be considered
MRS Rule. Section 3.0.1.2. Page 51595
Training
-------
GROUNDWATER PATHWAY
Introductory Site Inspection
PAGE 7
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
TARGETS
Groundwater pathway targets
- Municipal drinking-water wells
- Private drinking-water wells
- Public drinking-water wells
Always sample nearest target well
Attempt to sample all primary targets
Cannot infer contamination between wells
for actual contamination
SI Guidance, -Section 4.5
GROUNDWATER PATHWAY:
GROUNDWATER SAMPLING CONSIDERATIONS-
WHAT ARE TARGETS?
BACKGROUND
WELL
GROUNDWATER SAMPLING
TYPฃOF
WEU.
MONITORING
PRIVATE
MUNICIPAL
INDUSTRIAL
IRRIGATION
STANDYBY *
USE TOR
BACKGROUND
GET AN
OBSERVED
RELEASE
ACTUAL
CONTAMINATION
j
i
* Must be maintained, used once-a-year Far a 24-hour period.
PAGE 8
Introductory Site Inspection Training
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
SI STRATEG^RELEASE
If PA hypothesized release to groundwater
Sample to test hypotheses
Sample nearest drinking-water well
SI Guidance. Section 4.5.1
GROUNDWATER PATHWAY:
SI STRATEGY-RELEASE (cont.)
Background wells may not be available
Wells near source(s) may not exist
Installing monitoring wells are an expanded
SI activity
Can use other sources to establish background,
if necessary
SI Guidance. Section 4 51
GROUNDWATER PATHWAY:
SI STRATEGY-TARGETS
Not every primary target well must be sampled
Sample wells where detection of hazardous
substances is likely
Sample critical welt locations with substantial
populations
Target well = drinking-water well
Background well = any type of well
Some wells can serve as their own background
wells if continuous monitoring data are available
St Guidance. Seeton 451
Site Inspection
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY:
SI STRATEGY- ACTUAL
CONTAMINATION
If "actual contamination" is hypothesized
Drinking-water wells should be sampled
If all wells cannot be sampled, sample
nearby and municipal wells
Sample remaining wells during expanded SI
Can use samples from target wells to demonstrate
observed release and actual contamination
SI Guidance. Section 4.5. 1
WHICH WELLS SHOULD BE
SAMPLED TO TEST FOR ACTUAL
CONTAMINATION?
f x
i SOURCE N
/'
^ /
GROUND WATER FLOW
PRIVATE
WELL
INDUSTRIAL
WELL
seals in mtos
GROUNDWATER PATHWAY:
SI STRATEGY- BLENDED SYSTEM
2 mile
1 mite
1M.mile\ \
WELLC
/
SI Guidance. Section 4.5.1
Wells A, B and C
are part of a
blended system.
Which well*
should be
sampled?
Introductory Site inspection Training
-------
GROUNDWATER PATHWAY
EXPANDED SI AND
SINGLE SI STRATEGY
Review existing analytical data
from wells in the vicinity of the site
Check for abnormalities
Determine need for resampling
Is data of CLP or comparable
quality?
SI Guidance. Sector 4.5.2
ABC Sซซ: Analytical 0>u
Samples Results
EXPANDED SI AND
SINGLE SI ACTIVITY:
DOCUMENT OBSERVED RELEASE
Resample wells as needed
Sample wells not tested during single SI
Collect background samples
Install monitoring wells
Collect QA7QC samples
EXPANDED SI AND
SINGLE SI ACTIVITY:
GROUND WATER TARGET
SAMPLING CONSIDERATIONS
"Actual contamination" requires an observed
release, attribution, and presence of hazardous
substance at target
Collect QA/QC samples
Base well selection on ground water flow direction
Background well should be upgradient or at least
outside of the influence of sources
Focus on targets
SI Guidance. Sectbn 4.S.2
-------
GROUNDWATER PATHWAY
EXPANDED SI AND
SINGLE SI ACTIVITY:
MONITORING WELL INSTALLATION
Done only on sites expected to score because
of observed release
May not be necessary if groundwater pathway
is not critical to overall site score
SI Guidance, Section 4.5.2
GROUNDWATER PATHWAY
After sampling and analysis have been
completed, compile new information
Complete SI data summary sheets
pertaining to groundwater
Go to SI Guidance, Appendix B,
SI Data Summary
Introductory Site Ins
-------
GROUNDWATER PATHWAY
TABLE 4-8. GROUNDWATER SAMPLING STRATEGIES
CRITERION
Primary objective
Average number of
samples
Types of activities
Background samples
Attribution samples
QA/QC samples
EXPANDED SI AND SINGLE SI
To demonstrate a release based on HRS documentation requirements.
To demonstrate targets exposed to actual contamination and determine
levels of exposure.
Oto 14 based on HRS documentation requirements.
Resample existing wells if previous data did not conclusively demon-
strate a release or targets exposed to actual contamination.
Sample wells not yet sampled.
Collect multiple samples from drinking-water wells where hazardous
substance concentrations are likely to be near benchmarks.
Install monitoring wells as needed.
2 background per 3 release samples.
Install background monitoring wells, if necessary.
Generally should not rely on published data.
Those necessary to attribute a share of a release to the site.
Those necessary to obtain precise and accurate data.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992 (modified)
Introductory SiU
-------
GROUNDWATER PATHWAY
CASE STUDY:
EXAMPLES OF SOURCE SAMPLING STRATEGY
During the PA it was determined that residents near the Lakefleld Farm Site rely on shallow
domestic wells for drinking water (see Lakefield Farm Site Sketch #2). A municipal well that
provides drinking water to about 10,000 people is located 0.5 miles southeast of the site. The
municipal well and several nearby irrigation wells are screened in the deep aquifer, which
appears to be interconnected with the shallow aquifer. The PA identified the primary targets
as all domestic wells within 0.25 miles of the site and the municipal well. The PA indicated
groundwater flows to the south. Several domestic wells appear to be downgradient from the
site.
LAKEFIELD FARM SITE
Sketch #2
GW-2
m rH
I
SL-1
SD-1
SS-2
Nearest
Well Direction of
groundwater flow
LAKEFIELD
FARM SITE
_A_
KEY
Drinking-water Well
Source Samples
Irrigation Well L
(Not to Scale) GW-10
4-
GW-9
GW-6
GW-7
+
GW-8
I all ซI
mrn
GREEN ACRES
SUBDIVISION
Municipal Well A
-f -N-
GW-1 2 I
| PAGE 14 Introductory Site inspection Jrai
rung
-------
GROUNDWATER PATHWAY
GROUND WATER SAMPLING STRATEGY FOR EXAMPLE SITE
SAMPLES
Municipal well (GW-1 2)
Domestic wells (GW-3,
GW-4.GW-5.GW-6,
GW-7, GW-8, GW-9,
GW-1 0, GW-1 1
Background (GW-1 ,
GW-2)
Sources (SD-1 , SL-1 ,
SS-1.SS-2)
Sources (SD-1 . SL-1 ,
SS-1,SS-2)
SAMPLING STRATEGY
Collect sample prior to
treatment, sample to
document contamination,
identify hazardous sub-
stances, and determine
level of contamination.
Sample nearest domestic
drinking-water wells
suspected of exposure to
contamination.
Sample drinking-water
aquifer; limit number of
background samples.
Collect grab or composite
soil samples to identify
hazardous substances
present at site.
Monitor sample collection
and decontamination
procedures; one rinsate
and one field blank.
HRS
CONSIDERATIONS
Determine municipal
well contamination,
which is critical to
protecting public
health and the
screening decision.
Determine domestic
well contamination,
which is critical to
protecting public
health and the
screening decision.
Sample to determine
concentrations of
hazardous sub-
stances.
Do not sample to
increase hazardous
waste quantity
(amounts are not
close to HWQ factor
value breakpoints).
NONSAMPLING
DATA COLLECTION
Verify aquifer from
which well draws;
verify population
served.
Verify aquifer from
which wells draw;
verify population
served.
Verify aquifer from
which well draws.
Obtain physical
dimensions of surface
impoundment and
estimate area of
contaminated soil;
verify number of
drums and look for
drum labels.
Introductory Site Inspection Training
PAGE 15
-------
-------
SECTION FIVE
SURFACE WATER
PATHWAY
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
Likelihood of release to surface water body
Likelihood that surface water body is
contaminated by the site
Number of people exposed to contaminated
drinking water or contaminated food items
Sensitive environments exposed to
contaminated water
Resources
St Guidance. Stefan 4.6
SURFACE WATER PATHWAY (cont.)
Key Factor: If there are no surface waters
within 2 miles of the site, the
surface water pathway need
not be evaluated.
S) Guidance. Section <.6
SURFACE WATER PATHWAY
CLASSIFICATIONS
Rivers
- Perennially flowing waters and man-made
ditches, intermittent flowing water and
man-made ditches in arid/semi arid areas
(<20" mean annual precipitation)
Lakes
- Natural and man-made, static water
channels or oxbow lakes and wetlands
See: //usgsgov
See: MRS 4.0.2 Surface Water Categories
Introductory Site Inspection
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
CLASSIFICATIONS (cont.)
Oceans
- Territorial Sea; Great Lakes and contiguous
wetlands
Coastal Tidal Waters
- Harbors, sounds, estuaries, lagoons,
wetlands, etc.
See: ltusgs.gov
See: MRS 4.02 Surface Water Categories
Source
HOW CONTAMINANTS REACH
SURFACE WATER
Runoff
Overland flow
Flood
Groundwater
discharge to
surface water
SI Guidance, Section 4.6
SURFACE WATER ASSESSMENT
Drinking-water Threat
Human Food Chain Threat
Introductory Site
-------
SURFACE WATER PATHWAY
SURFACE WATER
PATHWAY INVESTIGATION
SIGuid
Complete the SI Data Summary
Surface Water section using
available data
See SI Guidance, Appendix B, Surface Water
Information Section. Pages B-12 through B-15
*ne*, Appwttor 8
REVIEW PA INFORMATION
Determine whether major pathway of concern is
based on:
Suspected release
Primary targets exposed to hazardous
substances
Number of secondary targets not suspected to
be exposed
SI Guidance. Section 4.6
REVIEW PA INFORMATION (cont.)
Identify physical characteristics of surface water
migration route
Is overland segment greater than 2 miles?
Are there multiple watersheds?
Location of Probable Points of Entry (PPE)
Tidal influence
Flow rate for each segment of migration path
measured in cubic feet per second (cfs)
SI Guidance SKtton 4.6
PAGE 4
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
REVIEW PA INFORMATION (cont.)
Identify locations of primary targets on
topographic map
Drinking-water intakes
Fisheries
Wetlands and other sensitive environments
Resources
See: www.fws.gov (U.S. Fish and Wildlife Service)
www.nwi.fws.gov {Wetland Inventory)
SI Guktanca. Section 4.6
SURFACE WATER SAMPLING
CONSIDERATIONS
Are sources actively discharging contamination
to surface water?
How old is the site?
ป What are surface water flow characteristics?
* What are the chemical properties of hazardous
substances of concern (for example,
persistence and bioaccumulation potential)?
See: //h2o erusgs.gov (Surface Water information)
31 Guidance, Section 46
SAMPLE TYPE CONSIDERATONS
Sediment, Aqueous, or Tissue
Sediment samples typically detect contamination
more often than other sample types
Consider adding aqueous samples for intakes or
sensitive environments (no benchmarks for
sediments)
Tissue samples are generally not recommended
(use sessile benthic organisms)
SI Gukhnca. Section 46
Introductory
-------
SURFACE WATER PATHWAY
LIKELIHOOD OF RELEASE:
OBSERVED RELEASE BY
DIRECT OBSERVATION
Hazardous substance seen entering or
known to have been deposited into surface
water bodies
Sample effluent discharge, source runoff, or
leachate (no background required)
or
SI Guidance. Section 4.6
LIKELIHOOD OF RELEASE:
OBSERVED RELEASE BY
DIRECT OBSERVATION (cont.)
ป Rely on existing analytical data indicating
effluent contains hazardous substances prior
to entering surface water
ป Must sample discharge, runoff, or leachate to
snow they contain hazardous substance
SI Guidance Section 4.6
LIKELIHOOD OF RELEASE:
OBSERVED RELEASE BY
DIRECT OBSERVATION (cont.)
Sources are Hooded and sources are in
direct contact with flood waters
Must rely on historical "source" data and flood
information
No SI sampling necessary
Use historical watermarks
Sae: www.fema.gov (Flood maps)
Si Gukrtnc., Sectton 4.6
PAGE 6
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
LIKELIHOOD OF RELEASE:
OBSERVED RELEASE BY
CHEMICAL ANALYSIS
Minimum of two samples
- One background sample upstream from PPE
- Second sample at or reasonably close to
PPE (downstream sample)
If multiple PPEs present, sample each
Background and release samples must be
same type and from same or similar water body
(same depth, sediment type)
SI Guidance. Section 4.6
SAMPLE TO ESTABLISH
BACKGROUND
Where is the PPE;
locate background
samples
KEY
LIKELIHOOD OF RELEASE:
OBSERVED RELEASE BY
CHEMICAL ANALYSIS (cont.)
Comparable sampling and analytical
procedures
Collect most downstream samples first
Collect aqueous samples before sediment
samples at same location
SI Guidance, Section 4.6
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
SAMPLE TO TEST
SUSPECTED RELEASE
PPE
SOURCE
SOURCE
TARGETS
Sampling considerations for actual contamination
Must establish observed release first
Can infer contamination between "hits"
- No need to sample each target
- Can sample adjacent to or beyond (downstream
of) target locations
* Sample for human health considerations,
regardless of score
- Always sample nearest drinking-water intake if
contamination is suspected
SI Guidance, Section 4.6
TARGETS:
INFERRING CONTAMINATION
SOURCE
PPE
Introductory Site fn?
-------
SURFACE WATER PATHWAY
INFERRING CONTAMINATION
.
-------
SURFACE WATER PATHWAY
ACTUAL CONTAMINATION?
LEVEL OF CONTAMINATION?
SAMPLE
SW1
SW2
SW3
RESULT
Noncltl.ct
100 ppb
SO ppb
lENCHBARK
10 ppb
TARGETS: HUMAN FOOD
CHAIN THREAT
Demonstrate actual contamination
Only attempt if this threat is essential to site
score
Use sediment samples (not organisms)
Tissue sampling is expanded SI activity
If fishery is closed for fishing, surface water
sample can be used to establish threat
Collect multiple samples to verify threat
TARGETS: HUMAN
FOOD CHAIN THREAT (cont.)
Sampling considerations for actual contamination
Observed release at target + bioaccumulation
potential factor value (BPFV) considerations
Sediment, aqueous, and effluent
samples-require substance within BPFVs 500
Tissue samples-no BPFV requirement
Substance must be taken up by organism
tissue
-------
SURFACE WATER PATHWAY
TARGETS:
ENVIRONMENTAL THREAT
Determine actual contamination
Only aqueous samples can be used to score
Level I contamination
Collect at or downstream of sensitive
environment
St Guidance. SfCOon 4.6
TARGETS:
ENVIRONMENTAL THREAT (cont.)
For wetlands
- Sample near PPE
- Two samples from wetland (at least 0.1 miles
apart, use wetland frontage)
Collect unfiltered surface water for total metals
Sensitive environments for this pathway are found in
: PA Table 5 in the PA score sheets. Also see HRS
! Table 4-24 in 40 CFR Part 300. Appendix A.
SI Guidance. Section 4.6
Introductory
-------
SURFACE WATER PATHWAY
PA TABLE 5: SURFACE WATER AND AIR PATHWAY
SENSITIVE ENVIRONMENTS VALUES
Sens/five Environment
Assigned Value
Critical habitat for Federally designated endangered or threatened species 100
Marine Sanctuary
National Park
Designated Federal Wilderness Area
Ecologically important areas identified under the Coastal Zone Wilderness Act
Sensitive Areas identified under the National Estuary Program of Near Coastal Water Program of the Clean Water Act
Critical Areas identified under the Clean Lakes Program of the Clean Water Act (subareas in lakes or entire small lakes)
National Monument (air pathway only)
National Seashore Recreation Area
National Lakeshore Recreation Area
Habitat known to be used by Federally designated or proposed endangered or threatened species
National Preserve
National or State WVdUfe Refuge
Unit of Coastal Barrier Resources System
Federal land designated to the protection of natural ecosystems
Administratively Proposed Federal Wilderness Area
Spawning areas critical for the maintenance of fish/shellfish species within a river system, bay or estuary
Migratory pathways and feeding areas critical for the maintenance of anadromous fish species in a river system
Terrestrial areas utilized for breeding by large or dense aggregations of vertebrate animals (air pathway) or
semiaquatic foragers (surface water pathway)
National river reach designated as Recreational
76
Habitat known to be used by State designated endangered or threatened species
Habitat known to be used by a species under review as to its Federal endangered or threatened status
Coastal Barrier (partially developed)
Federally designated Scenic or Wild River
50
State land designated for wildlife or game management
State designated Scenic or Wild River
State designated Natural Areas
Particular areas, relatively small in size, important to maintenance of unique biotic communities
25
State designated areas for protection/maintenance of aquatic life under the Clean Water Act
Wetlands
See PA Table 6 (Surface Water Pathway)
or
PA Table 9 (Air Pathway)
PA TABLE 6: SURFACE WATER AND PATHWAY
WETLAND FRONTAGE VALUES
Total Length of Wetlands
Less than 0. 1 mile
0.1 to 1 mile
Greater than 1 to 2 mles
Greater than 2 to 3 mles
Greater than 3 to 4 mles
Greater than 4 to 8 mies
Greater than 8 to 12 miles
Greater than 12 to 16 miles
Greater than 16 to 20 miles
Greater than 20 miles
Assigned Value
0
25
50
75
100
150
250
350
450
500
PAGE 12
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
EXPANDED AND SINGLE
SI STRATEGY
Determine whether aqueous samples are
needed to demonstrate a release at intake or
sensitive environment
Collect surface water samples at targets that
were not sampled earlier
Sample to expand fishery and wetland
boundaries if these are important
a Guidance. Section 4.6
introductory Site
-------
SURFACE WATER PATHWAY
TABLE 4-10: SURFACE WATER SAMPLES TO SUPPORT A RELEASE AND
TARGET CONTAMINATION
MRS Factors
Observed release
Level I drinking water
Level II drinking water
Level I sensitive
evironments
Level II sensitive
evironments
Level I fisheries
Level II fisheries
Sediment1
Yes
No
Yes
No
Yes
No
Yes*
Aqueous
Yes
Yes
Yes
Yes
Yes
No
Yes5
Effluent2
Yes
No
Yes
No
Yes
No
Yes5
Sessile
Benthic
Organisms
Yes
No
Yes
No
Yes
Yes3
Yes3
Non-sessile
Benthic
Organisms
No
No
No
No
No
Yes34
No
Finfish
Amphibians,
and Reptiles
No
No
No
No
No
Yes3'4
No
1 No benchmarks available; evaluate as Level II contamination.
2 Does not require comparison to background to document a release.
3 Sample only tissues of edible species to evaluate human food chain level of contamination.
4 Can be used to score Level 1 targets, but not an observed release; must be collected within
boundaries of surface water contamination.
5 Targets can be evaluated if hazardous substance has a bioaccumulation factor value of 500 or
greater.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992
PAGE 14
raining
-------
SURFACE WATER PATHWAY
SURFACE WATER
SAMPLING STRATEGIES
Refer to:
SI Guidance, Table 4-11, Surface Water Sampling
Strategies, presents expanded and single SI
sampling criteria and strategies
Prior to sampling, carefully plot sample locations
using information gathered during the site
reconnaissance and the nonsampling investigation
Photo document sample locations to aid in data
evaluation and to resample locations if necessary
SI Gurianca. Section 4.6.3; MRS Guidance Manual. Chapter 8
Introductory Site Inspection Training
PAGE 15
-------
SURFACE WATER PATHWAY
TABLE 4-11: SURFACE WATER SAMPLING STRATEGIES
CRITERION
Primary objective
Average number
of samples
Types of activities
Background samples
Attribution samples
QA/QC samples
EXPANDED SI AND SINGLE SI
To document a release based on HRS requirements.
To document targets exposed to actual contamination and determine
levels of exposure.
0 to 14 based on HRS documentation requirements.
Resample surface water locations if previous data did not document a
release or targets exposed to actual contamination.
Sampled surface water targets not yet sampled, particularly sensitive
environments and wetlands.
Collect multiple aqueous samples from drinking-water intakes where
hazardous substance concentrations are likely to be near surface water
benchmarks.
2 background per 3 release samples.
Should not rely on published data.
Those necessary to attribute a portion of a release to the site.
Those necessary to obtain precise and accurate data within the SI scope.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992 (modified)
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
CASE STUDY:
EXAMPLES OF SURFACE WATER SAMPLING STRATEGY
Returning to the Lakefield Farm Site example, the site description now includes the Apsley
River, a moderate-to-large water body (streamflow 900 cfs) approximately 200 feet north of
the surface impoundment (see Lakefield Farm Site Sketch 3). A recreational fishery is located
within the river, and a 10-acre wetland lies 1 mile downstream from the PPE. An unnamed
creek flows into the Apsley River about 750 feet upstream of the PPE, and an outfall to this
creek is 1 mile upstream of this confluence. During the PA, the investigator suspected a
release to the Apsley River from the Lakefield Farm and a release to groundwater.
Because of significant threats to both groundwater and surface water and because attribution
is a problem, an SI is planned with an expanded SI to be performed if necessary. SI sampling
will test whether groundwater and surface water targets are exposed to contamination.
Introductor
-------
SURFACE WATER PATHWAY
LAKEFIELD FARM SITE
Sketch #3
Outfall
LAKEFIELD
FARM SITE
+
GW-6
GREEN ACRES
SUBDIVISION
+ m +
I nซn I
oo
HID.
I_J Surface Water Sedment Sample
O Surface Water Aqueous Sampl e
9 Source Samples
Drinking-water Wall
-A- Irrigation Wall
fii
fi
Municipal Wall
+
GW-7
N
I
(Not to Scale)
PAGE 18
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
SURFACE AND GROUND WATER SAMPLING STRATEGY FOR EXAMPLE SITE
SAMPLES
Municipal well (GW-7)
Domestic wells (GW-3
through GW-6)
Background for ground-
water
Surface water target
locations
Background for surface
water (SW-1.SED-1)
Sources
(SD-1.Sl-1.SS-1.
SS-2)
Quality control
(Q-1 through Q-4)
(Not shown)
APPROACH
Sample drinking water
prior to treatment; sample
to document contamina-
tion, identify hazardous
substances, and deter-
mine level of contamina-
tion.
Sample nearest domestic
wells suspected of being
exposed to actual con-
tamination.
Sample drinking-water
aquifer; limit number of
background samples.
Sample sediments to
determine if contamina-
tion is present in the
fishery (SED-4) or
wetland (SED-5, SED-6).
Limit number of back-
ground samples.
Identify hazardous sub-
stances present at the site
through composite
samples.
Monitor collection and
decontamination proce-
dures; one rinsate for
groundwater equipment,
one rinsate for surface
water equipment, one trip,
and one field blank.
RATIONALE
Determining municipal
well contamination, is
critical to protecting
public health and to
the site screening
decision.
Determining municipal
well contamination
is critical to protecting
public health and to
the site screening
decision.
Sample to determine
concentrations of
hazardous substances
in ambient conditions.
Human food chain or
sensitive environment
contamination is vital
to screening decision.
Sample to determine
levels of hazardous
substances.
Do not sample to
increase hazardous
waste quantity if
amounts are not
close to HWQ factor
value breakpoints.
NONSAMPLING
DATA COLLECTION
Verify aquifer from
which well draws;
verify population
served.
Verify aquifer from
which wells draw;
verify population
served.
Verify aquifer from
which well draws.
Verify linear footage
of wetland exposed to
actual contamination.
Collect information
about background
sample location,
including setting,
flow, and physical
characteristics (e.g.,
sediment grain size).
Obtain physical
dimensions of surface
impoundment and
estimate area of
contaminated soil;
verify number of
drums, and look for
drum labels.
Introductory Site Inspection Triiming
-------
SURFACE WATER PATHWAY
SOURCE SAMPLING EXERCISE:
R.R. ACME LANDFILL
OBJECTIVE
Using available site information, develop a single SI sampling strategy to test a PA
hypothesis of suspected contamination of surface water.
METHOD
1. Review the general site information and map.
2. Identify site sources on the map.
3. Identify probable points of entry (PPE).
4. Identify all targets.
5. Develop a sampling strategy to test the PA hypothesis of suspected release to
surface water. You should use the procedures outlined in the SI guidance to
demonstrate observed contamination. Because this is a single SI, all data must
be sufficient to complete MRS scoring and documentation.
6. You are limited to 20 samples. You do not need to use al! available samples.
7. Record your sampling strategy on the table provided.
GENERAL SITE INFORMATION:
The R.R. Acme Landfill is a municipal landfill that was active between 1950 and
1980.
The PA has determined that the surface water pathway is the major pathway of
concern for this site.
* The PA has determined that the hazardous substances of concern are DDT, lead,
and mercury.
Critical distances:
- PPE to wetland = 200 feet
- PPE to wilderness area and habitat = 0.5 miles
- PPE to intake = 5 miles
PAGE 20
Introductory Site Inspection Training
-------
SURFACE WATER PATHWAY
7/7///
'
//////I
7 / -x /
Introductor1.
;tion Tr.nnrng
-------
SURFACE WATER PATHWAY
SAMPLING STRATEGY
SITE NAME: R.R. ACME LANDFILL
SAMPLE ID#
SAMPLE TYPE
RATIONALE
Total Samples:
Special Sampling Considerations:
Requested Analyses:
PAGE 22
Introductory Site Inspection Training
-------
SECTION SIX
SOIL EXPOSURE
PATHWAY
Fence
Breach
in Fence
n
CD
XYZ Corporation
Contaminated
Soil
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY
Pathway score based on:
Likelihood that residential, school, or
workplace properties are contaminated
Likelihood that residents, students, or
workers are exposed to site
contaminants
SI Guidrae. Section 4.7
SOIL EXPOSURE PATHWAY (cont.)
Pathway score based on (cont.):
Likelihood that federal or state designated
terrestrial sensitive environments (National
Parks, Wilderness Access, Critical Habitats,
etc.), or unique biotic communities are
contaminated
Likelihood that commercial agriculture,
silviculture and livestock production or grazing
lands are contaminated
'. S*cfen 4.7
SOIL EXPOSURE:
MRS CONSIDERATIONS
Neaifcy
Population
Residing Within
introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
REVIEW PA INFORMATION
Determine whether a major pathway of
concern is based on:
Resident individuals (on-site residents, students
Workers
Terrestrial sensitive environments/resources
Number and location of primary targets
Areas of suspected surficial contamination
Property boundaries
If contamination has been demonstrated
S Gtfldane*. SKBon 4.7
SOIL EXPOSURE
PATHWAY INVESTIGATION
Complete the SI Data Summary
Soil section using available data
i See SI Guidance. Appendix B. SI Data Summary.
; Pages 8-1 6 through B-18
SI Guidance
Sector 4.7
MOST IMPORTANT
ANALYTICAL DATA
Establishing observed contamination
Establishing level of contamination
- Level I (observed concentration > benchmark
concentration
- Level II (observed concentration <. benchmark
concentration or no applicable benchmark)
SI Gudanoc. Sacton 4 7
Introductory Site
Training
-------
SOIL EXPOSURE PATHWAY
ESTABLISHING OBSERVED
CONTAMINATION
Must use analytical evidence (no direct observation)
Should demonstrate
- Attribution
- Contamination present at significant levels
Need to collect two soil samples
Background
Area of contamination
* If observed contamination cannot be established, do
not evaluate soil pathway
S Guidance. Scctot 4.7
SAMPLING CRITERIA FOR
OBSERVED CONTAMINATION
Must meet criteria for observed contamination
(similar to observed release for migration
pathways), and samples must be collected within
two feet of surface
Cannot collect sample beneath impenetrable
cover
Can infer contamination within a source not
between sources
Multiple samples documenting observed
contamination are required to establish an area of
surficial contamination for the entire source
SI Guidanc*. Section 4.7
SAMPLE FOR OBSERVED
CONTAMINATION (SOURCES)
LANOFIU
SSt
FORMER DRUM
STORAGE AREA
ฃ5
SI Guidance. Section 4.7
PAGE 4
Introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
SAMPLING CONSIDERATIONS
Sample to identify targets exposed to
surfidal contamination
(most heavily weighted)
I
Resident individuals
Workers
Terrestrial sensitive environment
Resources (least heavily weighted)
Nearby population
Site accessibility
SI Guidance. Section 47
SAMPLING
CONSIDERATIONS (cont.)
Sample in direction of targets only
Do not sample to delineate total extent of
surficial contamination
SiGuKtonoo. SoOKnA.7
TARGET CONSIDERATIONS
Resident individuals and workers
Demonstrate contamination on the property
and within 200 feet of residence, school, or
workplace
Sensitive environments and resources
Demonstrate contamination within boundary
of resources and sensitive environments
Introductory Sit
-------
SOIL EXPOSURE PATHWAY
SAMPLE TO DEFINE RESIDENT INDIVIDUALS
. AACAS of vtaerxnoM/ . .
I wwccnotoi. M **racr
ESTIMATING AREAS OF
OBSERVED CONTAMINATION
Sample to identify resident population threat
targets
Three soil samples (minimum) needed
* Two soil samples for critical targets that lie along
a line
* One nonsoif source sample can designate an
entire source as area of observed contamination
SI Guidance. Section 4.7
AREA OF INFERRED
CONTAMINATION
i Established between two points of observed contamination
SOURCE
X
X
[X
X
X
II 1
o- 100- 200- AERIAL
SI Guidance, Section 4.7 VIEW
: HOUSE
, PROPERTY SOUNOAR
SOIL SAMPLE
Introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
INFERRING CONTAMINATION
CONSIDERATIONS
Density of the soil
Physiography
Topography
Operational history
Transport and deposition patterns
Means by which the substance migrates, such
as wind dispersion
Contamination in the downgradient portion of the
migration route
INFERRING CONTAMINATION
CONSIDERATIONS (cont.)
Data from other investigations
Soil staining
Stressed vegetation
Aerial and ground photography
Infrared satellite imagery
Use of composite samples/sample program
design
INFERRING CONTAMINATION
Introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
EVALUATING LEVEL
OF CONTAMINATION
Analytical results are compared with soil
benchmarks (milligrams/kilogram)
Populations associated with areas of inferred
contamination can only be evaluated as Level II
resident threat targets
SI GukSnc*. Sector 4.7
ADDITIONAL SAMPLING
CONSIDERATONS
So/7 samples collected for comparison should
be similar
Soil type
Same soil horizon
Mineralogy
Composition
S Guidance. Sป*x> 4.7
ADDITIONAL SAMPLING
CONSIDERATONS (cent.)
For background, observed contamination,
and metals analysis, the samples need to
have similar.
Texture
Color
Grain size
For MRS purposes, grab samples are preferred
(not composite sample)
SI GuMana. S*cDon 4.7
Introductory Site
-------
SOIL EXPOSURE PATHWAY
ESTABLISHING BACKGROUND
Background samples should:
Represent uncontaminated conditions
Be collected from undisturbed areas
Not be collected from drainage channels
Be collected within 1-3 days
SI GuWanw. Svcton 4.7
SI STRATEGY
Review PA hypotheses concerning suspected
observed surficial contamination and exposed
targets
Establish areas of observed contamination
Target resident individual exposures
Can use inferred contamination areas
a Guidance. Sacbon 471
EXPANDED AND
SINGLE SI STRATEGY
Focus on documentation of target exposure
Sample locations not sampled during earfier
investigations
Establish and document background
Rigorous quality control
SI Gudvxa. Sacbon 4.7 1
-------
SOIL EXPOSURE PATHWAY
SOIL SAMPLING STRATEGY
SI Guidance. Table 4-14, Soil
Sampling Strategies, compares
criteria and activities associated with
expanded and single Si's.
SI GuHjane*. Section 4.7.1.
Introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
TABLE 4-14: SOIL SAMPLING STRATEGIES
CRITERION
Primary objective
Average number of
samples
Types of activities
Background samples
Attribution samples
QA/QC samples
EXPANDED SI AND SINGLE SI
To document target exposure to hazardous substances related to site
sources.
0 to 20 based on HRS documentation requirements and
number of sources and targets.
Resample locations if previous data did not demonstrate areas of
observed contamination or targets exposed to actual contamination.
Sample other resident target properties not yet sampled.
Collect multiple samples on properties where hazardous substance
concentrations are likely to be near benchmarks.
As many as necessary; research natural soil concentrations as well as
development history in the area to select critical background sample
locations; use aerial photographs.
Those necessary to attribute substances to the site being
evaluated.
Minimum 1 split and 1 blank or per Regional guidelines.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992 (modified)
Introductory Site Inspection
-------
SOIL EXPOSURE PATHWAY
CASE STUDY:
EXAMPLES OF SOIL SAMPLING STRATEGY
The Carveth Landing site is a dump near a residential neighborhood and elementary school
(see Carveth Landing site sketch). The PA reported that dumping occurred for an unknown
period of time and allegedly included paints, organic and inorganic substances, and
construction debris. The area is devoid of vegetation. Sources at the site include several
piles of 5-gallon containers and two poorly defined areas of stained soil. Pigeon River, which
flows at 1,600 cubic feet per second and is located 400 feet east of the site, has flooded twice
in the past 7 years. Commercial and recreational oyster beds are downstream of two PPEs to
surface water. The PA concluded the flooding may have carried hazardous substances into
the surface water and onto adjacent school and residential properties. Hazardous substances
associated with the site are not known, but could involve metals typically found in paints.
CARBETH LANDING SITE SKETCH
XS-3
XS-4
XS-5
XS-6
KIY
Source Samples
Soil Samples
Sediment Sample
Fishery
XS=Expanded SI Soil Sample
jL-XS-7
XS-10
XS-15
PAGE 12
Introductory Site Inspection Training
-------
SOIL EXPOSURE PATHWAY
SOIL AND SURFACE AND WATER SAMPLING STRATEGY FOR EXAMPLE SITE
SAMPLES
Surface water locations
(SED-3, SED-4)
Residential soil
samples
Background soil
(SS-7, SS-8)
Background surface
water (SED-1 , SED-2)
Sources
(SS-1 through SS-6)
Quality control
(Q-1 through Q-3)
APPROACH
Sample sediments to
demonstrate a release;
determine if contamination
is present and level of
contamination.
Sample to determine if
nearby residential prop-
erties (SS-1 1, SS-12.
SS-1 3) and the school
yard (SS-9, SS-1 0) are
exposed to surficial
contamination.
Limited.
Collect sediment
samples upstream of
PPEs; ensure samples
are beyond tidal influ-
ence of hazardous
substance migration.
Identify hazardous sub-
stances present at the
site; sample to test
hypothesis of surficial
contamination.
Monitor sample collection
and decontamination
procedures; two rinsates
and one trip blank.
RATIONALE
Investigate release to
surface water and
determine if fishery is
exposed to actual
contamination.
Investigate population
exposure to hazardous
substances.
Sample to determine
relative levels of
hazardous substances
under ambient condi-
tions and to better
define effects of
flooding at site.
Sample to determine
levels of hazardous
substances under
ambient conditions.
Do not sample to
increase hazardous
waste quantity
because amounts
are not close to HWQ
factor value
breakpoints.
NONSAMPLING
DATA COLLECTION
Document use of river
for fishing; estimate
annual commercial
food chain production
for oysters.
Determine number of
people per residence
and number of students
attending school.
If available, obtain
historical aerial photo-
graphs and FEMA
maps; research
natural background
levels of metals.
Research other
potential sources of
hazardous sub-
stances.
Estimate physical
dimensions of stained
soil; count paint pails
and look for drum
labels.
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
Introductory Site Inspection Training
PAGE 13
-------
-------
SECTION SEVEN
AIR PATHWAY
Potential sources
of a release to air
FIRE
Bum operation
(odors.gases,
participates)
Contarninants may
settle on buildings or
settle on to soils
Sensitive Environment
(e.g., habitat, park or
recreation area)
Dry and dusty
conditions may
cause
particulates to be
blown off site
MINE TAILINGS
WASTE WATER RLE
LAGOON Mayrdease
vapors/gases that are
detected by nearby
residents/workers
CONTAMINATED
SOILS
-------
AIR PATHWAY
AIR PATHWAY EVALUATION
Pathway score based on:
Likelihood that airborne contaminants are
migrating from site
Likelihood of detecting contaminants at
human and sensitive environment targets
Characteristics of waste
SI Guidance. Section 4.8
REVIEW PA INFORMATION
Was air pathway significant to
preliminary score?
Identify sources (source areas)
Identify primary targets and primary
target populations
Identify most dispersible substances
SI Guidance, Section 4.8
AIR PATHWAY INVESTIGATION
a GUI
Complete the SI Data Summary Air section
using available data.
This information may help determine
whether to evaluate the pathway.
Soo SI Guidance, Append* B. SI Data Sinvnary.
Pages B-1 9 through B-21
nine*. Section B
PAGE 2
Introductory Site Inspection
-------
AIR PATHWAY
WHEN IS AIR MONITORING AND/OR
SAMPLING APPROPRIATE?
Is air a significant pathway?
Typically expanded or single SI activity
Usually a unique event that must be
understood prior to conducting fieldwork
Are any health based levels potentially
exceeded?
S) Guidance, Section 4 8
AIR PATHWAY: MRS
CONSIDERATIONS
Likelihood of
Detection
a Guidance, Section 4.8
AIR PATHWAY:
LIKELIHOOD OF RELEASE
Depends on nature of source
Chemical properties
Source type-gas/particulate
Containment
Affected by atmosphere
Wind direction and speed
Temperature
Precipitation
PA Gudarta, Scefen 3.9.1
Introductory Site Inspection Training
PAGE 3
-------
AIR PATHWAY
WASTE CHARACTERISTICS
Critical factors to consider:
Contaminants' inhalation toxicity
Contaminants' gaseous and/or paniculate
mobility
Likelihood of detection
SI Guidance. Section 4.8
OBSERVED RELEASE BY
DIRECT OBSERVATION
Particulate or visible gaseous emission seen
entering atmosphere directly
Use photographs to document emissions
Need information supporting that emission
material contains hazardous substance
- Existing analytical data
- Manifests
- Soil or source samples
Sample source to document direct observation
Si Guidance. Section 4.8
OBSERVED RELEASE
BY DIRECT OBSERVATION
MINE TAILINGS PILE
RESIOENTWIAREA
Introductory Site Inspection Training
-------
AIR PATHWAY
OBSERVED RELEASE BY
CHEMICAL ANALYSIS
Background and release samples should be similar
Collection and analysis
Same time frame
Multiple contaminants may require method
specific collection per contaminant
Requires rigorous QA/QC
AIR PATHWAY: TARGETS
Do not need to sample air targets directly
Observed release can demonstrate actual
contamination of targets within the distance
category
Emission models can be utilized to support
exposure determinations
Introductory SiU
-------
AIR PATHWAY
Chemical Properties
S
1
CL
i
il
= I
UJ fc
in
0>
I
CL
o
CO
Biorate constant
Octanoi-water coefficient
Water solubility
Diffusivity in water
Diffusivity in air
Henry's Law constant
Vapor pressure
Molecular weight
Density
Precipitation
Wind speed
Temperature
Surface roughness
Particle size distribution
Organic content
Moisture content
Porosity
Density
Level of concentration
Source extent
to
%
o
O
o
| SEAMS Closed Landfill
o
CJ
u?
o>
c
X
1 RTI Land Treatment
'a.
to
(0
ฃ
LL
CO
LU
CO
| SIMS Aqueous Lagoons
| SEAMS MSW Landfill
| Scholl Canyon Model
jParticulate Models |
o
tO
o
en
TJ
0)
ra
EL
| Unpaved Road
1 MRl "Limited" Erosion
J>
'
o>
2
2
CO
E
j SCS Wind Erosion Model
CO
S
*
i
-------
AIR PATHWAY
AIR TARGETS
4S1_I|E_OM.E
ISO PEOPLE ''''\
M PEOPLE
AIR SAMPLING
CONSIDERATIONS
Sample targets within a 0.25 mile target
distance limit
Conduct air sampling before or after other
sampling activities (not during)
May require more than one sampling event
Should not be conducted near facilities
discharging into air
Monitoring stations should be located near
sources
Si Guidance, Section 4.8.3
EXPANDED AND
SINGLE SI STRATEGY
Single SI option is selected if air is the only
pathway of concern
Conduct sampling:
- If air pathway is of concern
- If public health is threatened
Utilize method-specific sampling time to
reduce variability
Determine predominant wind direction
Maintain rigorous quality control
SI Guxlanc*. Section 4,8.3
Introduclory Site Inspection
-------
AIR PATHWAY
EXPANDED AND SINGLE
SINGLE SI STRATEGY:
ESTABLISHING BACKGROUND
Background sample locations should be
outside influence of site to ensure attribution
Necessary at this stage
Upwind or cross-wind samples acceptable
Multiple samples preferred
Rigorous QA/QC required
SI Guidano*. Section 4.8.2
PAGE 8
Introductory Site Inspection Training
-------
AIR PATHWAY
CASE STUDY:
EXAMPLES OF AIR SAMPLING STRATEGY
Vega Ore is a remote site near Smalltown where ore is processed for the extraction of lead,
zinc, and silver (see Vega Ore site sketch). The site has been operating since 1930, and
current activities are very limited. Waste sources include three tailings piles, a drum storage
area for acids, and an above ground tank.
The nearest residence is 1,000 feet from a tailings pile. Smalltown relies on drinking water
from an intake 3 miles away. A national park is located 900 feet from the site. A total of six
ranches within 0.25 miles of the site rely on bottled water and cisterns for drinking water.
Based on PA research, the significant threats posed by Vega Ore involve suspected migration
of hazardous substances through air that may impact people and sensitive environments. No
groundwater targets exist, and the nearest surface water body is more than 2 miles from the
site.
VEGA ORE SITE SKETCH
I
N
Prevailing wind direction
during air sampling
National Park
t-
0.25 Mite
Target Distance
Limit
KEY
Source Samples
Soil Samples
Smalltown
Introductory Site
-------
AIR PATHWAY
AIR SAMPLING STRATEGY FOR EXAMPLE SITE
1
SAMPLES
Release and air targets
(A-4 through A-6>
Support for release
and air targets
(A-7, A-8)
Background
{A-1 through A-3)
Sources
(SS-1 through SS-5)
Quality control
(Q-1 through Q-4)
(not shown)
APPROACH
Sample to test if contamination
is present and determine level
of actual contamination.
Monitor wind speed, direction,
and other atmospheric
conditions.
Sample to test if other sources
of air contamination exist in the
site vicinity; or if wind direction
changes during the sampling
event, establish crosswind
sample stations.
Sample to collect background
levels of ambient air concen-
trations.
Sample to determine back-
ground soil levels.
Identify hazardous substances
present at the site through
surficial soil samples and
tailing samples.
Monitor sample collection and
decontamination procedures:
2 trip blanks and 2 duplicates.
RATIONALE
Determine whether the
0.25-mile target distance
category is exposed to
actual air contamination,
This is vital to investigat-
ing the public health and
the screening and listing
decisions.
Support determining
whether the 0.25-mile
target distance category
is exposed to actual
contamination.
Sample to determine
relative levels of particu-
late hazardous sub-
stances in ambient
conditions.
Ensure sufficient
background samples for
listing purposes.
Do not sample to
increase hazardous
waste quantity (amounts
are not close to HWQ
factor value
breakpoints).
Ensure sufficient QA/QC
samples for listing
purposes.
NONSAMPLING
DATA COLLECTION
Determine population of
Smalltown lying within
the 0.25-mile target
distance category from
site sources.
Determine number of
workers at Vega Ore.
Determine boundaries of
national park.
Identify other sources of
partculate emissions in
area.
Collect descriptive
information for all
background sample
locations.
Obtain physical dimen-
sions of tanks, drums,
and tailings piles, and
estimate area of contami-
nated soil; verify number
of drums and look for
drum labels.
Introductory Site Inspection Training
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SECTION EIGHT
RADIATION
-------
RADIATION
t
RADIATION: DEFINITIONS
1 . RADIOACTIVE SUBSTANCE: Solid.
liquid, or gas containing atoms of a single
radionuclide or multiple radionuclides.
2. RADIONUCLIDE/RADIOISOTOPE:
Isotope of an element exhibiting
radioactivity. For MRS purposes,
"radionuclide" and "radioisotope" are
used synonymously.
HRS Final Rule. Section 1.1. Page 51 586
RADIATION: DEFINITIONS (cont
3. RADIOACTIVITY: Property of those
isotopes of elements that exhibit
radioactive decay and emit radiation.
4 RADIATION: Particles (alpha, beta.
neutrons) or photons (X- and gamma-rays)
emitted by radionuclides.
HRS Final Rde. Section 1.1. Page 51586
)
RADIOACTIVE
SUBSTANCES ARE:
Hazardous substances under CERCLA and
should be considered in HRS scoring
Treated as additional wastes with special
properties under the HRS
Special analytical data requirements apply
HRS Final Rule. Section 7 0. Page 51663
introductory Site Inspection Training
-------
RADIATION
RADIATION: TYPES
1 . IONIZING RADIATION: includes X-rav and
gamma radiation. They are both forms of
electromagnetic radiation which have
sufficient energy to break chemical bonds
and cause chemical reactions. Ionizing
radiation also includes high speed
subatomic particles such as alpha and
beta particles, and neutrons.
RADIATION TYPES (cont.)
2. NON-IONIZING RADIATION: is
electromagnetic radiation that does not
have sufficient energy to break chemical
bonds or cause chemical reactions. This
includes radio waves, TV, microwaves,
radar, visible light, and ultraviolet light.
RADIATION UNITS
1 . RAD (Radiation Absorbed Dose):
When ionizing radiation penetrates and
interacts with a material, it imparts energy
to the material. For a given mass of
material this energy is called the
absorbed dose. The unit that measures
absorbed dose is the RAD.
:n Training
-------
RADIATION
RADIATION UNITS (cont.)
2. REM (Roentqen Equivalent Man): For an
individual, the dose equivalent is obtained
by multiplying the absorbed dose by a
factor that varies with the type of radiation
and takes into account these different
affects.
RADIATION UNITS (cont.)
1 Mill irem= 1/1 000 REM
New International Units:
1 Gray (gy) = 100 RAD
1 Sievert=100REM
1 Roentgen (R) = 2.58 x 1 0'4 Coulomb
1 R = 1 RAD = .01 gy
THE PENETRATING POWER OF ALPHA
AND BETA PARTICLES, AND GAMMA RAYS
fl ALPHA PARTICLES
Stopped byป
shut of paper
ETA PARTICLE!
Stopptdbyalayvrof
doting cr by a (ปป
alumnum
GAMMA RAYS
Stopped 0ป mini
PAGE 4
Introductory Site Inspection Trainrng
-------
RADIATION
RADIATION: CHARACTERISTICS
OF THE THREE MAJOR TYPES
SOURCE
ALPHA
BETA
GAMMA
SYMBOL
d
P
y
FORM
Pamela
Particle
Etectro-
magnetic
energy
RELATIVE
MASS
(Chirgt)
4
C*3
0.00055
(+A1)
0
(0)
tor
IONIZATONS
AJMINAJR
lOO.OWs
10CTs
1
PATH
LENGTH
IN AIR
<2.54cm
1 meter
Several
meters
to
kilometers
HAZARD
LOCATION
OFSOURCE
Internal
Internal/
external
Internal/
external
TWO HRS GROUPS OF
RADIONUCLIDES
1. Naturally occurring or ubiquitous in the
environment
2. Man-made radionuclides not ubiquitous in
the environment (elements beyond
atomic number 92. uranium).
HRS Final Rule, Section 7.1.1. Page 51663.
SI Guidance. Section 4.9.4. Page 89
RADIATION MEASUREMENT
Raa
Cun
One
per
HRSI
iation is measured in activity units (Curies).
e (Ci). Measure used to quantify radioactivity.
Curie equals 37 billion nuclear transformations
second and one picocurie (pCi) equals 10"12 Ci.
MEDIA
Sort
Ground/surface
water
Air
UNIT
MEASUREMENT
pCi/kg
pCi/l
pCi/m3
riral Rule. Section 7.11. Page 51663
Introductory Site Inspection Training
-------
RADIATION
CERCLA EXCLUSIONS
Section 101(22) of CERCLA excludes a limited
category of radioactive materials, making them
ineligible for CERCLA response or the NPL
1. Excludes releases of source uranium or
thorium ..., by-product or material made
radioactive by exposure to radiation from
the use or production or special nuclear
material (plutonium, ^U, enriched "HJ,
^U) or any material that the NRC
determines to be special nuclear material
subject to Section 170 of the AEC Act.
HRS Guidance. Page 19
CERCLA EXCLUSIONS (cont.)
2. Any release of source, by-products, or
special nuclear material from any
processing site specifically designated
under the Uranium Mill Tailings Radiation
Control Act of 1978.
3. If facility has a current NRC license.
MRS Guidance, Page 19
POTENTIAL RADIOACTIVE
WASTE SITES
pose special hazards for field investigators
(gamma radiation)
Less than 2 percent of CERCLA sites involve
radioactive materials
Detailed investigations and information are
handled by EPA's Office of Air and Radiation
Programs (OAR) or by an EPA Regional
Health Physicist
PA Guidance. Section 2.7, Page 34
introductory Site Inspection Training
-------
RADIATION
FACILITIES THAT CONTAIN
RADIOACTIVE MATERIALS
DOD/DOE research labs, university labs,
contractors, and suppliers
Public/private energy production and
research labs
Ore mining, milling, and processing
industries
Deep well injection sites
PA Guidance. Section 27. Page 34
FACILITIES THAT CONTAIN
RADIOACTIVE MATERIALS (cent.)
Aircraft, submarine, and shipbuilding
companies
Businesses that manufacture, use, store, or
dispose of radio Pharmaceuticals (hospitals)
Industrial radiography (X-rays)
PA Guidance. Section 2.7, Page 34
EVIDENCE OF
RADIOACTIVE MATERIALS
Presence of drums and containers with
radiation symbols (trefoil)
Permits, manifests, and
records of radioactive
materials
Above-background reading
on a radiation meter
EPA action guideline: readings 21mR/hr for gamma
radiation - EVACUATE AREA!!
PA Guoance. Section 2.7. Page 34
Introductory Site Inspection Training
-------
RADIATION
RADIATION SAMPLING* GOALS
Identify radionuclides and activity concentrations
in situ, both onsite and offsite with radiation meter
(background)
Locate elevated radioactivity sources and
external radiation exposure rates, consult Part B
or SCDM
Estimate areat extent of contamination and major
migration pathways
'After consultation with a health physicist
SI Guidance, Section 4.9.1. Pages 86-88:
40 CFR Part 300, URS Final Rule 7.3.1
RADIATION SAMPLING*
GOALS (cont)
Confirm radiation releases through sampling
Document Level I and Level II contamination
Support QA/QC requirements (samples
require specialized CLP)
"After consultation with a health physicist
SI Guidance. Section 4 9.1. Pages 36-88.
40 CFR Part 300, HRS Final Rule 7 3 t
FACTORS THAT ARE EVALUATED
DIFFERENTLY UNDER HRS IN
ALL FOUR PATHWAYS
Observed release
. Toxicity _^ *ซ*
Persistence ' isotope
HWQ in tiers A and B only
Refer to 40 CFR Part 300.
HRS Final Ruto. Section 7 for specific information
HRS Final Rule. Table 7-1. Page 51 663
PAGE 8
itroductory Site Inspection Training
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RADIATION
OBSERVED RELEASE FOR
CC AND
Direct observation for each migration pathway
except soil*
Known radioactive source seen entering
groundwater, surface water, or air; or known
to have direct contact with media through
deposition or flooding
Measured concentration in activity units in all
four pathways
"Soil exposure pathway must have a soil sample
for analysis
SI Oiftlwia. SfMan ซ.S.1 . Pagซl M-U: 40 CFS Pol 300. MRS Hnw Ruta 7 J.I
OBSERVED RELEASE
1. Observed release for naturally occurring
radionudides
Concentrations that exceed upper limit of
regional background for a specific nuclide
and media type
Must be attributable to site
SI Guidance. Section 4.9 4, Pages 89-90
OBSERVED RELEASE (cont.)
2. Observed release for man-made
radionudide without ubiquitous background
concentrations in the environment
Measure concentrations that equal or exceed
the SQL* for that nudide in a specific media
Must be attributable to site
*tf CLP-generated date, use CRQL (Contract Required
Quantitetion Unit): if non-CLP-generated data, use IDL
(Instrument Detection Level)
SI Guidance, Section 49 4. Pages 89-90
Introductory Sile Inspection Training
PAGE 9
-------
RADIATION
OBSERVED RELEASE OF ซ ANDJ3
FOR SOIL EXPOSURE PATHWAY
Radiation source
Must be present at surface or covered by
2 feet or less of cover material
Exceeds the upper-limit value of the range
of regional background concentration
values for that specific radionuciide in that
type of sample
Must be attributable to the site
Excludes gamma radiation
SI Guidance Section 4.8.4. Pag* 69; MRS Final Rule 7.3.1
OBSERVED RELEASE IN SOIL
EXPOSURE PATHWAY WITH
GAMMA RADIATION
Whose concentration equals or exceeds 2 times
the site-specific background gamma radiation
exposure rate
Must be attributable to the site
Does not have to be within 2 feet of the surface
* Must have external gamma radiation readings
taken at no more than 1 meter above ground
MRS Final Rule, Section 7.1.1. Page 51664
TO CALCULATE HAZARDOUS
WASTE QUANTITY (HWQ)
Use activity units (curies) to evaluate sources
Need source area and depth (volume in cubic
yards or gallons)
Need net activity concentration of each nuclide
(after subtracting background concentration)
SI Guidance. Section 4.9 2. Pages 66-89
Introductory Site Inspection Training
-------
RADIATION
TO CALCULATE HAZARDOUS
WASTE QUANTITY (HWQ)(cont.)
Evaluate radionudide constituent quantity
(Tier A) or waste stream quantity (Tier B)
Activity in curies is converted to equivalent
pounds
SI Guidance, Section 4 9.2. Pages 88-89
HWQ
Tier A: Based on activity content. Convert from
curies to equivalent pound of non-
radioactive hazardous substances by
multiplying the net activity estimate or
area of observed contamination by 1,000.
Assign the product as a constituent
quantity value.
Select the higher value for HWQ
1 curie = same threat as 1,000 pounds of a hazardous
chemical substance
HRS Final Rule. Sector 7257. Pages 5166-51666
HWQ (cont.)
TterB: Based on activity content. Estimate
total volume (cubic yards or gallons);
divide cubic yards by 0.55 and gallons
by 110 to obtain equivalent pounds of
non-radioactive hazardous substances.
Assign resulting value as radio nuclide
quantity value.
Select the higher value for HWQ
1 curie * same threat as 1,000 pounds of a hazardous
chemical substance
MRS Final Ruin. Secnon 7257, Pagis 5166-51666
Introductory Site Inspection Training
PAGE 11
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-------
SECTION NINE
SITE INSPECTION
EVALUATION
AND
REPORTING
Site Score = / 5 2
2 , 2 , 2
qw
-------
SITE INSPECTION EVALUATION AND REPORTING
SIE\
SI Guidance.
/ALUATION OVERVIEW
REVIEW AND VALIDATE
ANALYTICAL DATA
1
IDENTIFY ANALYTICAL DATA
FOR SCORING
1
REVIEW NONSAMPUNG
INFORMATION
1
SITE SCORING
Chatter 5
SI EVALUATION: DATA REVIEW
Compile all data
- Existing
- New SI data
Include sampling and nonsampling
information
Evaluate existing analytical data using
procedures outlined in Chapter 3 of the
SI Guidance
* Evaluate new analytical data against
performance criteria in SI work plan
SI Guidance. Section 5.1
SI EVALUATION:
DATA REVIEW (cont.)
All new analytical data should be
independently validated before review
Review should be conducted by the site
investigator and project chemist
SI Guidance, Table 5-1, provides data
review considerations
SI Gujdwn. Soaun &1
PAGE 2
Introductory Site Inspection Training
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SITE INSPECTION EVALUATION AND REPORTINC
TABLE 4-1: DATA REVIEW CONSIDERATIONS
| | Review data reports for transcription and typographical errors (e.g., 0.5 v. .05; ppb v. ppm).
Determine if sampling protocols were appropriate.
Compare data against field and trip blanks to detect cross-contamination.
Compare field replicate samples.
Review laboratory QA/QC (e.g., laboratory blanks, method standards, spike recovery, dupli-
cates).
D
D
D
Summarize detection limits for non-detectable results.
Review detection limits for positive but non-quantifiable data.
Review sampling program design for assessing media variability.
Review background concentrations to help identify site-specific contamination.
Delete unusable data, attach qualifiers to usable data, and explain limitations of qualified data.
Guidance for Performing Site Inspections Under CERCLA, USEPA, September 1992
Introductory Site
-------
SITE INSPECTION EVALUATION AND REPORTING
SI EVALUATION:
DATAREVIEW(cont.)
Scope of data review reflects use
requirements
Problems with data packages should be
resolved with laboratory
SI Guidance. Section 5 1
SI EVALUATION:
IDENTIFY DATA FOR SCORING
MRS aspects that depend on analytical data
Observed releases
Observed contamination (soil pathway)
Targets exposed to actual contamination
* Levels of target contamination
Hazardous waste quantity
Can use CLP and non-CLP data deemed suitable
for SI objectives
SI Guidance. Secoon S.2
SI EVALUATION: IDENTIFY
DATA FOR SCORING (cont.)
Criteria for establishing acceptable minimum
data quality:
Intended use of data
Specific site hypothesis being tested
Particular MRS factor being examined
Levels of target contamination
Hazardous waste quantity
SI Guidance, Section 5.2
PAGE 4
Introductory Site inspection Training
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SITE INSPECTION EVALUATION AND REPORTING
SI EVALUATION: IDENTIFY
DATA FOR SCORING (cont.)
Determine usability of qualified data
Qualifiers are added to data during
laboratory analysis or data validation
S) Guidance, Secocn 5 2
ANALYTICAL DATA
REVIEW PROCESS
Planning
Dat
1 r
Field Sample i
Wo* * Analyss |
C
0:
> '
f Individual A
Review
1 by Lab
a [ Data Rwcw
| Vary
^ SMO L
^ Date Review |*
da
| Contract )
, Compliance
Screening 1
^ J
\
Regional D*ป UabiWy
Data Review Review
(Data * (CLP. 1
Vabdatkxi) Non-CLP)
\
.'Quality Assured] Site ^.
Legally i i Scoring
DefensiWe J !
SI EVALUATION: IDENTIFY
DATA FOR SCORING (cont.)
Qualified analytical data
Data with attached letter code of "flag"
indicates QA/QC problems or questions
concerning chemical identity or
concentration
Flag assigned by analyzing laboratory or
person validating data
Introductory Site Inspection Training
PAGE 5
-------
SITE INSPECTION EVALUATION AND REPORTING
SI EVALUATION: IDENTIFY DATA
FOR SCORING (cont.)
Examples of Qualified Data
SAMPLES j 1
Trichloroethylene ' 40J
Tetrachloroethylene
Phenol
25U
330U
2
160
150J
390
3
120
100R
1 9.000J
4
30J
45
490
Concentrations (ppb)
SI EVALUATION: IDENTIFY
DATA FOR SCORING (cont.)
Common qualifiers in CLP data
J-flag: Concentrations are estimated;
identification of hazardous substances
certain
U-flag: Compound analyzed for but not
detected
R-flag. QA/QC indicates data are unusable
* Specific meaning of a qualifier may vary
SI EVALUATION:
NONSAMPLING INFORMATION
Review S! data sheets
Update with new information if needed
- Changes in site conditions (e.g.. a
removal)
- Changes in targets
Assess quality of nonsampling information
SI GuKMnea, Secoot- 5.3
PAGE 6
ion Training
-------
SITE INSPECTION EVALUATION AND REPORTING
SI EVALUATION: SITE SCORE
General strategy
Characterize sources
Focus on significant pathways
Document releases
St Gudance. Section 5.4
SI EVALUATION: SITE SCORE (cont.)
SI worksheet
PREscore software program
HRS score sheets
Other evaluation tools developed by EPA
regional or state offices
See SI Guidance, Appendix C,
Site Inspection Worksheets
SI Guidance, Section 5.4
SI REPORTING REQUIREMENT
NARRATIVE
REPORT
Introductory Site Inspi
-------
SITE INSPECTION EVALUATION AND REPORTING
SI REPORTING:
NARRATIVE REPORT
Report should:
Describe history and nature of waste
handling at site
Describe known hazardous substances
Describe pathways of concern
Identify and describe targets
Present SI analytical results
Sl Gurtance. Section 6.1
SI REPORTING:
NARRATIVE REPORT (cont.)
> Can be letter report or stand-alone document
> Factual statements should be supported by
references
> References not generally available should be
attached
ป Structure and format should follow format in
Exhibit 6-1, SI Narrative Report Form
SI Gudance. Section 6 1
-------
SITE INSPECTION EVALUATION AND REPORTING
EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT
INTRODUCTION
State that an SI was performed, the name of the agency performing it, and the authority under
which it was conducted (e.g., CERCLA as amended by SARA, and EPA contract or cooperative
agreement).
State the site name. CERCLIS identification number, and location (street address, city, county,
State, latitude/longitude coordinates). If necessary, provide brief directions to the site.
State the purpose, scope, and objectives of the SI.
SITE DESCRIPTION AND REGULATORY HISTORY
Identify the type of site (e.g., plating facility, chemical plant, municipal landfill), whether it is active
or inactive, and years of operation. Describe its physical setting (e.g., topography, local land
uses). Include the appropriate portion of a USGS 7.5-minute topographic map locating the site
and showing a 1-mile radius. On the map, identify the surface water drainage route; nearest well,
drinking-water intake, and residence; and wetlands and other sensitive environments. Include a
drafted sketch showing site layout, source areas, and features on and around the site.
* Briefly summarize dates and scope of previous investigations.
Describe prior land use and past regulatory activities including the site's RCRA status, permits,
permit violations, and inspections by local, state, or federal authorities. Discuss any citizen
complaints.
OPERATIONAL HISTORY AND WASTE CHARACTERISTICS
* Provide an operational history of the site. Identify current and former owners and operators, and
describe site activities. Identify and describe wastes generated, waste disposal practices, waste
source areas, waste source containment, and waste quantities. Indicate source areas on the site
sketch.
Discuss any previous sampling at the site; provide dates of sampling events and sample types.
Summarize analytical results in a table. Include a site map of all previous sample locations.
Discuss SI source sampling results. List in a table each waste source sample and summarize
analytical results. Include a site map of all waste source and pathway sample locations.
Identify hazardous substances associated with sources.
Describe accessibility to source areas.
GROUNDWATER
Describe the local geologic and hydrogeologic setting (e.g., stratigraphy, formations, aquifers,
karst features, confining layers, depth and permeability to each aquifer).
Guidance for Performing Site Inspections Under CERCLA. USEPA. September 1992
Introductory Site Inspection Training
PAGE 9
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SITE INSPECTION EVALUATION AND REPORTING
EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT (cont.)
GROUNDWATER (cont.)
Discuss groundwater use within a 4-mile radius of the sources. Identify the nearest private and
municipal drinking-water wells and state the distance from sources. Quantify drinking-water
populations served by wells within 4 miles, differentiating between private and municipal wells and
specifying aquifers. Identify any municipal wells that are part of a blended system; state number
of wells, locations, pumping rafes, and aquifer from which water is drawn. Identify wells in karst
aquifers.
Identify designated wellhead protection areas (WHPA) and specify location.
Discuss any previous groundwater sampling results; provide dates of sampling events and the
depths and names of sampled aquifers.
List in a table each well or spring sampled during the SI, provide the depth from which it draws
drinking water and the screened interval, quantify the population associated with it, and identify its
distance from site sources. Discuss SI groundwater sampling results. List in a table each
sample, and summarize analytical results. Include a site map of sample locations. Identify
drinking-water wells exposed to hazardous substances and quantify the drinking-water
populations served by each.
SURFACE WATER
* Describe the local hydrologic setting, including site location with respect to floodplains, and the
overland and in-water segments of the surface water migration path. State the distance from the
site to the probable point of entry (PPE) into surface water. Identify the water bodies within the in-
water segment, and state the length of reach and flow or depth characteristics of each; describe
tidal influence. Include a drafted sketch of the surface water migration path. Describe upgradient
drainage areas, onsite drainage (including storm drains, ditches, culverts, etc.), facility discharges
into surface water, permits, and historical information, including floods, fish kills, fishery closures.
and other events.
* Indicate whether surface water within the target distance limit supplies drinking water. Identify the
location, and state the distance from the PPE to each drinking-water intake. Quantify the drinking-
water population served by surface water and identify blended systems.
Indicate whether surface water within the target distance limit contains fisheries. Identify and state
the distance from the PPE to each fishery; briefly characterize each fishery.
Indicate whether sensitive environments are present within or adjacent to the in-water segment.
Identify and state the distance from the PPE to each sensitive environment. Describe each
sensitive environment and state the frontage length of wetlands on surface water.
Discuss any previous surface water sampling results, dates, locations, and types of samples.
Discuss SI surface water sampling results. List in a table each sample and summarize analytical
results. Identify surface water intakes exposed to hazardous substances and quantify the
drinking-water populations served by each. Identify fisheries exposed to hazardous substances
and quantify the food chain population associated with each. Identify sensitive environments and
wetlands exposed to hazardous substances; quantify the frontage of exposed wetlands.
Guidance for Performing Site Inspections Under CERCLA. USEPA. September 1992
PAGE 10
Introductory Site Inspection Training
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SITE INSPECTION EVALUATION AND REPORTING
EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT (cent.)
SOIL EXPOSURE
State the number of workers on properties with site-related contamination.
State then number of people who live on properties with site-related contamination and within 200
feet of an area of observed contamination. State the hazardous substance concentration and
compare to health-based benchmarks.
Identify schools and day care facilities within 200 feet from an area of observed contamination on
the school property and state the number of attendees.
Identify terrestrial sensitive environments and resources in an area of observed contamination.
State the number of people who live within 1 mile travel distance of the site.
Discuss any previous sampling results of sources of surficial materials, including dates and
locations.
Discuss SI surficial source samples. List each sample in a table and summarize analytical results.
AIR
Identify the location of, and state the distance to, the nearest individual. State the population
within 4 miles of the site, including students and workers. Identify sensitive environments on
sources and within 4 miles.
Discuss any previous air sampling results, including dated, locations, sampling procedures, and
meteorological conditions.
Discuss SI air sampling procedures and results. Identify sample locations on a map. List in a
table each sample and summarize analytical results.
SUMMARY AND CONCLUSION
Briefly summarize the major aspects of the site and its history and relate to the release or
threatened release of hazardous substances and the exposure of targets. Briefly summarize
principal pathways and targets of concern.
Summarize sampling results, including substances detected in site sources and in environmental
media.
PHOTODOCUMENTATION LOG
As an attachment, provide photographs of the site taken during the SI depicting pertinent site
features such as waste source areas, containment conditions, stained soil, stressed vegetation,
drainage routes, and sample locations. Describe each photograph in captions or accompanying
text. Key each photo to its location on the site sketch.
Guidance for Performing Site Inspections Under CERCLA. USEPA. September 1992
Introductory Site Inspection Training
-------
SITE INSPECTION EVALUATION AIMD REPORTING
EXHIBIT 6-1: SI NARRATIVE REPORT FORMAT (cent.)
APPENDICES
- Analytical results reports
QA Report
Other attachments
REFERENCES
List, in bibliographic citation format, all references cited in the SI report.
Attach copies of references cited in the SI report. Include complete copies of site-specific
references (e.g., USGS topographic maps, records of communication, drinking-water population
apportionment and calculation worksheets, GEMS and other data base printouts, waste handling
records or shipping manifests). Include only the title page and pertinent excerpts of publicly
available references (e.g., geologic reports).
Guidance tor Performing Site Inspections Under CERCLA. USEPA. September 1992
PAGE 12
Introductory Site Inspection Training
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SITE INSPECTION EVALUATION AND REPORTING
Si REPORTING:
SCORE AND DOCUMENTATION
During SI scoring, investigator should:
Start at beginning of package and work
through systematically
Document all assumptions
Develop references
Evaluate SI Results:
Use Table 6-1, Additional Evaluation of SI
Results, to aid in decisions
St Guidance, Section 6 1
SI REPORTING: REVIEWS
SI reports and score sheets undergo three
separate reviews
SI investigator conducts detailed review of SI
report and score sheets for completeness and
internal consistency
Independent reviewer reviews analytical data
and internal consistency
EPA regional officials and state personnel
review reasonableness and whether SI
objectives were met
SI Guidance. Section 6 1
SI REPORTING: REFERENCES
Log books
Source containment descriptions
Sample descriptions (matrix, location, color,
depth, etc.)
Migration path descriptions
Photograph descriptions
Surrounding land use
Site Inspection Training
-------
SITE INSPECTION EVALUATION AND REPORTING
SI REPORTING:
REFERENCES (cont.)
Data sheets
Field screening
Borings and monitoring wells
Chain of custody
SITE DISPOSITION DECISION
Recommendation based on site score
No further remedial action planned (NFRAP)
Expanded SI
HRS package preparation
EPA makes final decision
PAGE 14
Introductory Site Inspection Training
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SECTION TEN
CASE
STUDY
-------
CASE STUDY
CASE STUDY:
SI SAMPLING STRATEGY
OBJECTIVE
Using available site information for the Wolfram Industries site, develop a SI sampling
strategy implementing procedures established in the SI guidance manual.
METHOD
1. Review the site information provided with this case study. The information is
derived from the preliminary assessment (PA).
2. Identify the following elements and label them on the appropriate maps:
- Sources
- Targets
- Areas of suspected contamination
-PPE
- In-water portion of the surface water pathway
3. Develop a list of objectives for an SI sampling plan.
4. Develop a sampling strategy to test the following PA hypotheses:
- Suspected release to groundwater, surface water, and air
- Suspected soil contamination
- Exposure of targets to contaminated groundwater, surface water, soil, and air
5. Include the following elements in the sampling strategy:
- Characterization of background
- Demonstration of attribution
- Quality control (minimal)
6. There is a limit of 20 samples for this exercise. You are not required to use all
allocated samples.
7. Plot all sampling locations on the site map(s).
8. Complete the sampling strategy table.
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Introductory Site Inspection Training
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CASE STUDY
SITE INSPECTION CASE STUDY:
WOLFRAM INDUSTRIES
GENERAL SITE DESCRIPTION
Wolfram Industries is a 12-acre site located within an industrial area in Harbor Hill
County, Fairlawn, New York. It consists of a laboratory, a warehouse, and a refinery.
The site was active from 1941 to 1989 and has since been abandoned. The Mosquito
River is located east of the site and flows south into Harbor Hill Bay. There are several
small wetlands along the banks of the Mosquito River. A potato farm occupies a piece
of land to the east of the river. Rainfall for this area is approximately 28 inches per
year, according to the local weather station records.
The TIGER database provides the following population information for the region lying
within 4 miles of the site.
DISTANCE FROM SITE
Onsite
0 -1/4 mile
1/4 - 1/2 mile
1/2 - 1 mile
1-2 miles
2 - 3 miles
3-4 miles
POPULATION
0
250
1,080
4,520
9,900
35,400
67,900
U.S. Census Bureau data for this region indicate an average 2.5 people per household.
OPERATIONAL HISTORY
A review of site records indicates that this facility processed tungsten ore into
tungsten metal via crushing and hydrochloric acid extraction and precipitation reactions.
Processed tungsten was used for making lighting filaments and other tungsten
compounds. Waste products include acidic metallic slag that contains high concen-
trations of hexavalent chromium, lead, zinc, manganese, iron, copper, and cyanide.
Inirocluclory Site inspection Tiaininy
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CASE STUDY
Information obtained during the PA revealed several possible source areas on-site (see
Figure 1, Wolfram Industries Site Map). The slag is stored in stacked 55-galfon drums
throughout the site. The outdoor portions of the site are not paved. Two large piles of
coarse-grained black ore tailings are adjacent to the refining facility. They are estimated
to contain 375 cubic yards of waste within an estimated combined area of 416 square
feet. A plastic-lined lagoon of unknown depth is found to the north of the refinery. It
occupies an area of 2,000 square feet. The lagoon was reported to contain process
waters and acidic solutions containing heavy metals and cyanide. Plants were
observed growing out of a portion of the lagoon. Three monitoring wells that are 75 feet
in depth are located around the lagoon. One down gradient monitoring well was
reported to be vandalized and filled in with beer cans and gravel. The facility is fenced
on three sides, but there is a large hole in the southern fence due to a recent automo-
bile accident.
PROBABLE SUBSTANCES OF CONCERN
Based on observations made during the off-site reconnaissance for the PA, the
55-gallon drums of slag are badly deteriorated and the contents of several drums
are spilling black, powdery slag onto the ground. Partially corroded drums were found
on the north side of the warehouse; their contents are unknown. A topographic map of
the area shows that the site slopes toward the northeast, and it is documented that
runoff from the site is directed into the Mosquito River through an outfall pipe. The
soil between the outfall pipe and the river was stained green and is devoid of vegeta-
tion. Aerial photographs of the site and information gathered during the PA indicate that
there are 4,321 drums located outdoors. There is no containment, and these drums are
in contact with the unpaved ground. The area of stained soil adjacent to the drums is
estimated to be 400 feet by 600 feet. The area of contaminated soil near the outfall is
estimated to be 100 feet long by 10 feet wide. The estimated depth of the contaminated
soil for both areas is 0.5 feet.
GEOLOGY AND GROUNDWATER
Based on information gathered from a United States Geological Survey (USGS) publi-
cation, the native soil for the site and surrounding area is a thin (0 to 2 feet thick} cover
of loamy soil. Beneath this soil lies a thick formation of sand and gravel that is part of
the Atlantic Coastal Plain from the Cretaceous Period. A water table aquifer occurs at a
depth of 60 feet below the surface, although perched water tables exist over small and
discontinuous clay lenses at shallow depths (about 10 feet) throughout the area.
Groundwater flow in the vicinity of the site is known to flow east-southeast or toward the
Mosquito River.
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Introductory Site Inspection Training
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CASE STUDY
FIGURE 1: WOLFRAM INDUSTRIES SITE MAP
Heavy
Equipment
Storage
Large Drum Dump
Stained Soil
(not to scale)
\AWetiand
W\
Introductory Site In
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CASE STUDY
GROUNDWATER PATHWAY
According to the municipal water authority, potable water for residents within 4 miles of
the site comes from water reservoirs located 5 miles from the site. A wellhead
protection area does not exist for this region. However, according to a USGS ground-
water database, some residents have their own potable wells screened within a
confined sand aquifer at a depth of 300 feet, but are located upgradient of the site.
Groundwater from a shallow perched water table aquifer is used for the irrigation of
Mr. Spuds 4.5-acre potato farm. There are eight homes located 0.3 miles from the site
and 44 homes at 3.75 miles. This information was obtained from a USGS computer
listing of wells within the county. No information is available on any well closures due to
site contamination.
SURFACE WATER PATHWAY
The Mosquito River was identified on the topographic map as the closest surface water
body to the site. It lies within 100 feet of the site. Based on information gathered during
the off-site reconnaissance, an outfall pipe from the facility and its associated stained
soil area lie adjacent to the river bank. The bank of this river is located several feet
below the grade of the site. The Federal Emergency Management Agency (FEMA)
indicates that the site is located on the 10-year flood plain. On average, the Mosquito
River flows at 1,500 cubic feet per second, according to the USGS Water Resource
Atlas for this region. The state fish and wildlife bureau has confirmed that portions of
this river serve as a fishery for catfish and smallmouth bass and as a habitat for the
state-designated endangered species known as the "long-eared sunfish." In addition,
many sport saltwater fish are caught in Harbor Hill Bay located 13 miles to the south.
One unmapped wetland (0.1 miles in length) was observed along the river closest to the
site and another (0.4 miles in length) was identified from published wetlands maps. No
known drinking-water intakes are located on the Mosquito River.
SOIL EXPOSURE PATHWAY
The PA states that there are no residents, schools, or day care centers located on or
within 200 feet of an area of observed soil contamination. A hole in the fence of the
facility allows unauthorized access by children or others. There are no terrestrial
sensitive environments located on any areas of observed contamination. The total
population within 1 mile of the site is 5,850 (based on TIGER data).
AIR MIGRATION PATHWAY
The nearest residence is located 0.24 miles west of the site and prevailing winds come
from the west. No windbreak or covering is associated with the tailings piles.
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CASE STUDY
FIGURE 2: SURFACE WATER PATHWAY MAP
Extent of salt water
t
N
= Fishery
(not to scale)
15-mile target
distance limit
HARBOR HILL BAY
Introductory SlU
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CASE STUDY
SI SAMPLING STRATEGY
SAMPLE ID#
SAMPLE TYPE
RATIONALE
Total Samples:
Special Sampling Considerations:
Requested Analyses:
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Introductory Site Inspection Training
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