United States Office of Solid Waste and EPA-540-B-00-010
Environmental Protection Emergency Response OSWER 9285.0-45
Agency (5201G) August 2000
www.epa.gov/superftjnd
Superfund
svEFA Introductory Preliminary
Assessment Training
Student Manual
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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 PRELIMINARY ASSESSMENT TRAINING
2 DAYS
This course provides participants with an introduction to the Superfund site assessment
process and the fundamentals of the preliminary assessment phase of this process. The
site assessment 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 back-
ground necessary to perform preliminary assessments and to develop preliminary
site scores. 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
Preliminary Assessments Under CERCLA. The focus is on implementing EPA
preliminary assessment 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
preliminary assessment scoring methodology.
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 preliminary assessments.
• Conduct a preliminary assessment data search and develop a site reconnaissance
plan.
• Perform preliminary assessment site scoring.
Note: Calculators are highly recommended.
Continuing Education Units: 1.3
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TABLE OF CONTENTS
SECTION
Section 1
Section 2
Section 3
Section 4
Section 5
Section 6
Section 7
Section 8
Sections
Section 10
TTTLE
Introductory Preliminary Assessment Training
Lecture Notes
Conducting the Preliminary Assessment Investigation
Lecture Notes
Case Study
Site. Source, and Waste Characterization
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
Completing the Preliminary Assessment Investigation
Lecture Notes
Federal Facilities
Lecture Notes
Appendices
Appendix A - EPA Fact Sheets
Appendix B - Acronym List and Glossary
Appendix C - PA Case Study Answer Sheets
1-1
2-1
2-20
3-1
3-13
4-1
4-14
5-1
5-17
6-1
6-11
7-1
7-11
8-1
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SECTION ONE
INTRODUCTORY
PRELIMINARY
ASSESSMENT
TRAINING
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INTRODUCTION
PRELIMINARY
ASSESSMENT TRAINING
This course:
• Introduces the site assessment process and
how preliminary assessments (PA's) fit into it
• Provides practical advice on conducting
PA's and completing PA Score Sheets
• Focuses on existing EPA guidance and
policies
• Introduces the concept of "integrated
assessments"
PRELIMINARY
ASSESSMENT TRAINING (cont.)
This course does not
• Assume you have much background in
Superfund site assessment or with the
Hazard Ranking System (HRS)
* Cover EPA region-specific policies,
procedures, or sites
WHAT DO WE
EXPECT FROM YOU?
Understanding/acceptance that the
PA Score is the screening model of
choice that U.S. EPA (Headquarters)
has implemented for the Superfund
Site Assessment Program
The PA Score follows the format of the
Hazard Ranking System (HRS) Model
Preliminary Af
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JiRODUCTfOf'
WHAT DO WE
EXPECT FROM YOU? (cont.)
Some of the terminology and
definitions are different from the HRS
and cannot be used interchangeably
Any region-specific information you
can provide will be helpful
WHAT DO WE
EXPECT FROM YOU? (cont.)
For an environmental glossary see:
www.nttc.edu/env/info/envglos.html
and
www.epa.gov/docs/OCEPAterms
OTHER ASSESSMENT MODELS
• Defense Priority Model (DPM) is used by
the Department of Defense (DOD)
• Multi-Media Environmental Pollutant
Assessment System (MEPAS) is used by
the Department of Energy (DOE)
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INTRODUCTIOr
OTHER SITE
ASSESSMENT PROCESSES
RCRA Facility Assessment
Standard Practice for Environmental Site
Assessments: Phase 1 Site Assessment
Process is issued by the American
Society for Testing and Materials (ASTM)
DISCIPLINES
In addition to understanding the PA Score.
you must incorporate a wide range of
technical skills to make professional
judgements on a number of pathway
factor questions.
DISCIPLINES (cont.)
Geology
Chemistry
Biology
Environmental Science
Air Chemistry/Meteorology
Engineering
Toxicology
Health Physics
PAGE 4
Preliminary Assessment Training
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INTRODUCTIOf
WHY IS A PRELIMINARY
ASSESSMENT NECESSARY?
National Oil and Hazardous Substances
Pollution Contingency Ran (NCP)
Purpose and Objectives:
'To provide the organizational structure and
procedures for preparing for and responding
to discharges of oil and releases of
hazardous substances, pollutants, and
contaminants."
40 CFR Part 300. Sub part A
WHY IS A PRELIMINARY
ASSESSMENT NECESSARY? (cont.)
• The NCP is required by Section 105 of
CERCLA and applicable to response
actions taken pursuant to CERCLA and
Section 311 of the Clean Water Act (CWA).
• PA's, under CERCLA, mean a review of
existing information and an off or on-site
reconnaissance, if appropriate, to
determine if a release may require
additional investigation or action.
•W CFR Part 300. Subpart A
ENVIRONMENTAL LAWS
ADMINISTERED BY THE EPA
• Comprehensive Response, Compensation,
and Liability Act (CERCLA) 1980/Superfund
Amendments and Reauthorization Act (SARA)
• Solid Waste Disposal Act (SWDA) 1965/
Resource Conservation and Recovery Act
(RCRA) 1976/Hazardous and Solid Waste
Amendments (HSWA) 1984
• Clean Water Act (CWA) 1977
• Safe Drinking Water Act (SDWA) 1974
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INTRODUCTION
ENVIRONMENTAL LAWS
ADMINISTERED BY THE EPA (cont.)
• Clean Air Act (CAA) 1970
• Toxic Substances Control Act (TSCA) 1976
• Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) 1972
* Ocean Dumping Act (ODA) 1977
• National Environmental Policy Act (NEPA) 1970
CERCLA
The Comprehensive Responsive, Compensation,
and Liability Act or Superfund, established a fee-
maintained (tax on chemical feedstocks and
petroleum) fund to dean up abandoned hazardous
substance sites. Sites undergo a rigorous
assessment and investigation process prior to listing
on the National Priorities List (NPL). The procedures
to be followed in responding to hazardous substance
releases (removal and remedial) are listed in the
National Contingency Plan (40 CFR 300). Hearth
assessments are also produced by the Agency for
Toxic Substances and Disease Registry (ATSDR).
CERCLA (cont.)
• P.L. 96-510 enacted in December 1980
• P.L. 99-499 Superfund Amendments and
Reauthorization Act (SARA) of 1986
reauthorized and enlarged the act
• P.L. 101-508 extended Superfund in 1990
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INTRODUCTION
LEGISLATIVE AND
REGULATORY BACKGROUND FOR
SITE ASSESSMENT PROCESS
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), Section 105 established a
$1.6 billion trust fund for five years
Hazard Ranking System (HRS), 47 FR
31180, July 16,1982
LEGISLATIVE AND
REGULATORY BACKGROUND FOR
SITE ASSESSMENT PROCESS (cont.)
• Superfund Amendments and Reauthorization
Act of 1986 (SARA) funded at $11.97 billion
through 1994
• Revised HRS, 55 FR 51532, December 14.1990
• Seewww.epa.gov/superfund
PA Guidance. Section 1.2
CERCLA DEFINITION
OF A RELEASE
"Any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing into
the environment, including abandonment or
discarding of barrels, containers, and other
closed receptacle containing any hazardous
substance, pollutant or contaminant."
40 CFR 302 3 and CERCLA 101 (22)
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INTRODUCTION
CERCLA DEFINITION
OF A RELEASE (cont.)
Releases to the environment do not include
releases that are wholly contained inside a
closed containment structure, such as a
building or an enclosed vehicle.
40 CFR 302.3 ant C&KXA 101 (22)
REPORTABLE QUANTITY
• For release of a hazardous substance to be
importable, a certain amount must be released
into the environment within a 24-hour period.
The release is measured in pounds. Consult
Appendices A & B in 40 CFR 302,4, Parts 355 or
detailed lists of hazardous substances. The
quantity is specific for each hazardous substance.
• This does not include federally permitted
releases such as those under RCRA, CWA,
CAA, etc,
40 CFR 355.«
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NTRODUCTIOr
CERCLA PETROLEUM
EXCLUSION
CERCLA Sections 101 (14) and (33)
exclude petroleum from the definitions of
"hazardous substance" and "pollutant or
contaminants."
It excludes "crude oil or any fraction thereof (if
that fraction is not specifically listed nor
designated a hazardous substance by other
listed acts), natural gas, natural gas liquids,
liquified natural gas, synthetic gas usable for
fuel." Also excluded are gasoline additives
coming out of a refinery.
CERCLA PETROLEUM
EXCLUSION (cont.)
• Sites are excluded if they contain
only excluded petroleum products.
CERCLA RADIOACTIVE
EXCLUSION
• Releases from any nuclear power plant
licensed by the NRC
• Releases from one of the uranium tailing sites
designated in the Uranium Mill Tailings
Radiation Control Act of 1978
• Any source uranium, thorium or other sources
that the NRC determines to be special
nuclear material under Section 170 of the
AEC Act
CB5CLA Secooo 101 (22)
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NTROOUCTION
OTHER CERCLA EXCLUSIONS
Any releases that result in exposure solely
within the workplace
Emissions from engine exhaust of a motor
vehicle, train, aircraft, vessel, or pipeline
pumping station
The normal application of fertilizer (FIFRA)
CERCIA Section 101 (22) and (104Xa)(3)
OTHER CERCLA
EXCLUSIONS (cont.)
• Naturally occurring substances from locations
where they are normally found, such as radon
• Products that are part of the structure of, and
result in exposure within residential business or
community structures, such as asbestos
• Substances in public or private drinking-water
supplies due to deteriorating pipes, such as
lead
CERCLA Section 101 (22) »na (104X»)(3)
ENVIRONMENTAL LAWS
Clean Water Act (CWA)
-The major law governing the chemical,
physical, and biological integrity of the
nation's waterways. Also known as the
Federal Water Pollution Control Act Major
sections include Title II and IV provisions
which authorize financial assistance for
municipal sewage treatment plant
construction and regulatory requirements for
industrial and municipal discharges.
PAGE 10
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NTRODUCTION
ENVIRONMENTAL LAWS (cont.)
Safe Drinking Water Act (SDWA)
-Protects the public drinking-water systems
from harmful contaminants. Developed
national primary drinking-water regulations,
underground injection controls, and
groundwater protection for sole source
aquifers and wellhead protection.
ENVIRONMENTAL LAWS (cont.)
Clean Air Act (CAA)
-Designed to protect human health and the
environment by controlling outdoor/ambient air
pollution through source controls
Toxic Substances Control Act (TSCA)
- Legislative directive to control specific toxic
substances. Involves testing, risk management,
and dissemination of information on certain
chemicals
ENVIRONMENTAL LAWS (cont.)
• Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA)
-Gave the EPA the authority to regulate
pesticides
• Ocean Dumping Act (ODA)
-Research and regulations regarding ocean
disposal of materials
• National Environmental Policy Act (NEPA)
-Review and comment on Environmental
Impact Statements
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INTRODUCTION
PA GUIDANCE GOALS
• Assist PA investigators in:
- Conducting high-quality assessments
- Making correct site screening or
recommendations for additional study
- Achieving national consistency in
performing PA's
PA GuidMic*. Section 1.1
PA GUIDANCE STRUCTURE
SECTION 1
SECTION 2
SECTION]
SECTION 4
SECTIONS
REFERENCES
GLOSSARY
APPENDICES A-E
INTRODUCTION
CONDUCTING THE PA INVESTIGATION
SITE EVALUATION AND SCORING
REPORTING REQUIREMENTS
REVIEWS
PA Guidance, SfOion 1.1
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SECTION TWO
CONDUCTING
THE PRELIMINARY
ASSESSMENT
INVESTIGATION
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
PA ACTIVITIES
DMA COLLECTION 60-80 Man
REPORTING 20-30 Haun
RECONNAISSANCE 10-20 Haun
SCCfflNG 5-15 Hours
AVERAGE PA - ISO HOURS
•coftwa
•ECOHNAISUNCE
DATA COLLECTION
Strategies
• Verify site name and location
• Collect and review readrly available
general site information
• Determine site eligibility/exclusions
• Conduct file searches
• Obtain and review "desktop" information
• Plan and conduct site reconnaissance
PAQuftmo. S>dk«2
DATA COLLECTION (cont)
PA information needs
• Specific information required to conduct
a PA is contained in the Checklist of PA
Information Needs
• Be familiar with this fist before starting
data collection activities
PA Guidance. Suction 2
Preliminary Assessment Training
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATE
CHECKLIST OF
Figure 2-1
PA INFORMATION
NEEDS
GENERAL SITE INFORMATION
O Site Name and Location
P CERCLIS ID Number
D Type of Facility
D Type of Ownership
D Site Status (active/inactive)
D Years of Operation
D Owner/Operator Information
D Operational History
D Environmental Setting
D Approximate Size of Site
D Latitude/Longitude
ID Site Sketch
SOURCE AND WASTE CHARACTERISTICS
D Source Types and Locations
D Size of Sources (dimensions)
D Waste Types and Quantities
D Hazardous Substances Present
GROUND WATER USE AND CHARACTERISTICS
D General Stratigraphy and Hydrogeology
D Presence of Karst Terrain
D Depth to Shallowest Aquifer
D Private Wens Within 4 Miles
(locations, population served)
O Municipal Wells Within 4 Miles
(locations, populations served, blended systems)
D Distance to Nearest Drinking-water Wed
D Wellhead Protection Areas
SURFACE WATER USE AND CHARACTERISTICS
d Flood Frequency at Site
D Distance to Nearest Surface Water
D Surface Water Body Types Within 15 Downstream Miles
D Surface Water Flow Characteristics Within 15 Downstream Miles
O Drinking Water Intakes Within 15 Downstream Miles (locations, populations served, blended systems)
D Fisheries Within 15 Downstream Miles
D Sensitive Environments and Wetlands Within 15 Downstream Miles
SOIL EXPOSURE CHARACTERISTICS
H Number of People Living Within 200 Feet D Number of Workers at Facfflty
O Schools or Day Care Within 200 Feet (enrottment)D Locations of Terrestrial Sensitive Environments
O Populations Within 1 Mile
AIR PATHWAY CHARACTERISTICS
D Populations Within 4 Miles
Q Distance to Nearest Individual
Preliminary Assessme
D Locations of Sensitive Environments
Within 4 Miles
D Acreage of Wetlands Within 4 Mies
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CONDUCTING THE PRELIMINARY ASSESSMEP
VESTIGATION
DATA COLLECTION (cont.)
PA information sources
• Site Assessment Information Directory (SAID)
* PA Guidelines, Appendix B, PA Information
Sources
Go to PA Guidance, Appendix B
PA Go«l»nc«. SMton 2
DATA COLLECTION (cont.)
File searches
• Existing file information
- EPAWasteLAN
- EPA RCRA files
- EPA CERCLA files, 103 forms, citizen
complaints
- State environmental department files
- State/county health department files
- In-house files
• Tax offices
- Historical property/ownership information
PA Guidance. Section 2.3
DATA COLLECTION (cont.)
"Desktop" information
• Maps
• Geological information
• Data bases/geographic information
systems
• Aerial photography
• Telephone inquiries
• HRS Guidance Manual Appendix A
'relimmary Assessment Training
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JDUCTING THE PRELIMINARY ASSESSMENT
!VESTIGATIO
DATA COLLECTION (cent.)
"Desktop" information (cent.)
• Internet Resources
-Tiger files: tiger.census.gov
-GIS info: www.hdm.com/8is3.htm
(links to over 725 CIS-related sites)
-Aerial photos: terrasen/ernnicrosoft.com
- Database vendors:
www.vistacheck.com
www.ecosearchnet.com
www.edmet.com
PA Guidanc*. S*c*on 2.4
Preliminary Assessment Training
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION;
SITE RECONNAISSANCE
AND DOCUMENTATION
SITE RECONNAISSANCE (cont.)
Objectives
• Verify
-Site file data-location, sources
-Population data-nearest residence
-Environmental data-wetlands, endangered
species, fisheries
PA Ouicknce. Secaon 2.5
SITE RECONNAISSANCE (cont.)
Objectives (cont.)
• Fill in data gaps identified after conducting
file search
• Develop documentation for reports, scores,
and PA conclusions-PA Appendix A
• Observe site conditions
* Evaluate need for removal action at all
times
Assessmer
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
SITE RECONNAISSANCE (cont.)
Preparation
• Review what is known about the site
• Plan to collect data to help determine:
- Source location, size and condition
- Likelihood of a release
/ Waste types and containment
S Site security
- Targets most likely to be exposed
/ Distance from outer edge of source to targets
S Targets at greatest risk
SITE RECONNAISSANCE (cont.)
Preparation (cont.)
• Decide whether to conduct on-site or off-site
reconnaissance
• Prepare health and safety plan
• Gather necessary equipment
• Obtain permission in writing for site access
SITE RECONNAISSANCE (cont.)
Activities
• Conduct perimeter survey
• Identify emergency response conditions
• Evaluate source types, sizes, and
containment
• Assess waste disposal practices
• Estimate quantity-volume, area
;nt Training
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
SITE RECONNAISSANCE (cont.)
Activities {cont.)
• Assess areas of stained soil and impacted
vegetation
• Determine drainage pathways
• Verify nearby targets
• Assess nearby land uses
• Interview local authorities
PA Guttw» Sadtoo 2.i2 mt 2A3
EMERGENCY RESPONSE
CONSIDERATIONS
(INTEGRATED ASSESSMENT & RESPONSE)
Site contttons that might teed to • removal assessment:
• Threat of fire and/or explosion
• Threat of direct contact with hazardous
substances
• Threat of continuing release of hazardous
substances
• Threat of drinking water contamination
Notify EPA when above conditions an observed.
Prelim inary
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
DOCUMENTATION
DOCUMENTATION
Logbook entry examples
• Personnel present
• Site location
• Date and time of visit
• Weather conditions
• Visual observations/source locations
See Example, PA Guidance. Page 30
DOCUMENTATION {cont)
Logbook entry examples (cont)
• Photographic record
• Site sketch
• Conversations
• House counts
• Gfoundwater well locations
| See Example. PA Guidance. Papa 30 |
PAOlttfM*. SMfen 2i.1
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
DOCUMENTATION (cont.)
Logbook requirements
• Bound notebook
• Waterproof paper
• Waterproof ink
• Pages numbered
• Each page signed and dated
• Unused space crossed out
| StJdant Koto: Turn to Logboofc Mini-Baiim*
ri nuMinra. Tmimi Ti 1
EXAMPLE LOGBOOK ENTRIES
(GOOD OR BAD?)
EXAMPLE #1
0800. Arrived at the site and began the
perimeter survey. The following potential
sources were identified drums, a debris pile,
and some contaminated soil. The site was
over 10 acres in size. The nearest house
was between 150 and 250 feet away.
EXAMPLE LOGBOOK ENTRIES
(GOOD OR BAD? cont.)
EXAMPLE #2
0800. The following were observed in the
southwest section of the property:
• A lagoon filled to within 6 inches from top of
freeboard. The area is estimated to be
approximately 100 ft x 200 ft. Depth is unknown.
• A vertical aboveground storage tank, 1000-gallon
size. Written on tank side: "PENTA." Tank appears
to be in good condition; no indication of leakage.
ary Assessment Tr
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
EXAMPLE LOGBOOK ENTRIES
(GOOD OR BAD? cont.)
EXAMPLE #3
1125, Followed site drainage from southeast
comer of site to stream. Drainage path was
dry and had some orange discoloration.
There appeared to be some stressed
vegetation along drainage (photo 13).
Stream was flowing.
EXAMPLE LOGBOOK ENTRIES
(GOOD OR BAD? cont.)
EXAMPLE #4
1420. Team members Hart and Jones met with
Ralph Singer, Chief Engineer, City of Springfield
Water Department He showed us a map
indicating the location of the water intake on
Lake Springfield and the distribution area
served. He also provided the following
information: 1,476 households are served by
this intake, no other sources of water exist
within 15 miles downstream of the site, and the
water from Lake Springfield is not blended with
other supplies.
EXAMPLE LOGBOOK ENTRIES
(GOOD OR BAD? cont.)
EXAMPLES
0745. Arrived on site and met with site
owner. Ms. Frieda Gluck. We toured the site
and observed several drums and a debris
pile. She said that her husband, who had
operated the site, was dead and that she did
not have any money if the EPA wanted to
prosecute her.
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CONDUCTING THE PRELIT
INVESTIGATION
PRE-REMEDIAL SITE
EVALUATION
Site Discovery & Study: Finding the Most Serious Sites
4OCFR30D.CP
REMEDIATION PROCESS
Long-Term Cleanup: Rxing the Most Serious Sites
REMOVAL ACTlVmES
4O CFR 3aO.42iV.43IV.436
THE NATIONAL
PRIORITY LIST (NPL)
• NPL was established under CERCLA to identify and
document the nation's most hazardous sites to
human health and the environment
• An HRS cutoff score of 28.5 points was used
based upon the original congressional mandate of
selecting 400 NPL sites.
• The listing of NPL sites is found in 40 CFR Part
300, Appendix B.
Please se»: www.«p*.gov/MJp«rfundAwnatisstfnpl..hrs.htm
or
www.cpa.gov/suparfund/sitos/n0wfin.hlm
PAGE 12
relim irtary
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CONDUCTING THE PRELIMINARY ASSESSP
INTEGRATED ASSESSMENTS
Integrating removal and remedial site
assessment investigation to achieve
increased efficiency and shorter response
times
Screen
-Determine the nation's priorities for remediation
OSWER DirectK* 9203 1-51
INTEGRATED ASSESSMENTS (cont.)
• Evaluate
- Identify and address sites posing
immediate threats
- Identify sites with lesser threats and refer to
appropriate authorities
- Identify site for NPL
• Document
- Establish defensible documentation for
potential NPL listing
SITE ASSESSMENT
SCREENING PROCESS
VtasfeLAN
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
THE SITE
ASSESSMENT CHALLENGE
• Evaluate many sites with limited resources
• Make sound decisions from limited information
• Protect public health without spending excess
resources on sites that pose little threat
PA Guidm. SMton 1.2
THE FOUR SITE
ASSESSMENT QUESTIONS
1. Have hazardous substances been
deposited at the site? If so, what and how
much?
2. Have hazardous substances migrated from
the source?
3. Who and what are likely to be impacted?
4. Must an emergency action be taken?
THE HAZARD RANKING SYSTEM
(HRS) MODEL
we
3-HRS FACTOR CATEGORIES
Preliminary Assessment Tr
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;OWDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
CERCLA DEFINITION OF A
HAZARDOUS SUBSTANCE
• Any pollutant or contaminant shall include:
-Any element, substance, compound, or mixture which
after release into the environment...
-may be reasonably anticipated to cause death,
disease, behavioral abnormalities, cancer, genetic
mutation, physical malfunctions ..
-that is harmful to human or ecological health..
CERCLA Section 101 (14) AND 101 (33)
MRS STRUCTURE
MRS PATHWAYS MINI EXERCISE
What are the
pathways of
concern?
ipfr
What are the
targets of
concern?
>ment Training
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
PURPOSE OF THE PA
• Differentiate sites that warrant further action
from those that pose little or no threat to
human health and the environment
• Support emergency response and remedial
activities
• Gather information for the site assessment
process
• Identify potential NPL sites
PA GiMwic*. Staort t.4
SCOPE OF THE PA*
Review existing information about the site
Conduct an on or off-site reconnaissance
Collect information about the site, especially
target information
Re-evaluate alt information
Develop a preliminary site score
Prepare PA summary report
• As defined In Section 420 oT the NCP (40 CFR Part 300).
PAOwtora. S«dioo1.4
PA STRATEGY
Focus on critical factors-ones that most
impact PA score
Maintain nationally consistent evaluation
process
MRS model provides all factors involved in
decision-making process
PAGuWvic*. SKttonl.4 md 1.5
PAGE 16
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CONDUCTING THE PRELIMINARY ASSESSME
PA CRITICAL FACTOR EXAMPLE:
GROUNDWATER PATHWAY
WHAT IS MOST IMPORTANT FOR PA?
TARGETS: WHO AND WHAT ARE
LIKELY TO BE IMPACTED?
• Targets are critical to pathway scoring
-"Uncapped" factors-weigh heavily
- No target = no site
• A comprehensive target survey is possible
at PA stage
PA Gut«ra. s«*on 1.9
PA TERMINOLOGY ONLY
•
•
•
Sources
Suspected release vs. no suspected release
Primary targets vs. secondary targets
'JOB
U '
JO. ,
'.~&gufttt -''jfixt&faf
TWWETO- "fiWBCIS
PA GuM*tt». Section 1.6
r
i "^
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
GROUNDWATER PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Groundwater Pathway Criteria List, page 7.)
Is the site located in karst terrain?
Depth to aquifer:
Distance to the nearest drinking-water well:
Yes
Yes
-No.
_No_
Jt
ft
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to groundwater (See
page 7), assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release to groundwater,
and the site is in karst terrain or the depth to aquifer is 70 feet or less, assign a
score of 500; otherwise, assign a score of 340. Use only Column 8 for this
pathway.
TARGETS
3.
4.
PRIMARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you suspect have been exposed to a hazardous
substance from the site. (See Groundwater Pathway Criteria List, page 7.)
people x 10 =
SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 2.
Are any wells part of a blended system? Yes_
No
If yes. attach a page to show apportionment calculations.
5. NEAREST WELL: If you have identified a primary target population for ground-
water, assign a score of 50; otherwise, assign the Nearest Well score from
PA Table 2, If no drinking-water well exist within 4 miles, assign a score of zero.
6. WELLHEAD PROTECTION AREA (WHPA): If any source lies within or above a
WHPA, or if you have identified any primary target well within a WHPA. assign a
score of 20; assign 5 if neither condition holds but a WHPA is present within 4
miles otherwise, assign zero.
7. RESOURCES
(sojo.ta.a.s.3.2
at 100)
GROUNDWATER PATHWAY SCORE:
LR x T x WC
82.500
PAGE 18
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CONDUCTING THE PREL
:MCNT INVESTIGATION
PA COMPONENTS
• Narrative report
• References
• PA data and site characteristics form
• PA score sheets
Turn to PA Guidance. Appendices A. C and D for examples
IA.CBMD
-------
CONDUCTING THE PRELI
RY ASSESSME
ESTIGATION
CASE STUDY:
ABC VACUUM SERVICE
OBJECTIVE
Using background information, inspection reports, and site reconnaissance notes for the ABC
Vacuum Site, complete the "General Information" portion of the PA score sheets.
METHOD
1. Review the background information, site map, reconnaissance logbook notes and
map, and the waste management inspection report.
2. Read the PA score sheet general information instructions provided in this case study.
3. Complete the "Site Description and Operation History" and "Probable Substances of
Concern" portions of the PA score sheet.
GENERAL OVERVIEW:
• This 13-acre site is located in Atlas Parish, Louisiana. It is currently inactive.
* The site was operated as a vacuum service and drilling fluids manufacturer from 1975
to 1985 (prior history is unknown).
• Wastewater was extracted from reserve pits created during petroleum exploration and
production activities.
• The facility is believed to have transported hazardous wastes that may have been
discharged into an on-site lagoon.
• The facility manufactured water and oil-based drilling fluids.
• The perimeter of the site is unfenced. Trespassing occurs infrequently.
• Five homes in a small subdivision are situated between 100 and 200 ft to the northwest
of the site.
• The mean annual precipitation is 57 inches.
Assessment Trj.
-------
CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
WASTE MANAGEMENT INSPECTION REPORT
DATE June 10.1999
FACILITY ABC Vacuum Service
LOCATION
Atlas torish
OWNER/OPERATOR A&C Vacuum Service
FACILITY TYPE
Vacuum service and drilling fluids manufacturer
(water £ oil-based)
YEARS OF OPERATION 1975 to present
FACILITY SIZE Property totals 13 acres
WASTE MANAGEMENT UNITS 750 sq' oxidation pond; drum storage pad;
2 mixing tanks above ground; idqoon; debris pile (rubbish).
WASTE TYPES Petroleum exploration wdstewaters.
Drlnq fluids waste from manufacturer.
RCRA WASTE CODES F~wastes (non-specifk hazardous wastes that are
toxic, igniteabie and reactive).
Preliminary Assessment Training
PAGE 21
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
WASTE MANAGEMENT INSPECTION REPORT
Page 2
WASTE MANAGEMENT UNITS Undetermined.
Observed during inspection:
125 drums on pad
"fao ianks are 1.000 gallon each
WASTEHANDLING Unknown wastes reported to have been deposited
in on-site lagoon.
NONCOMPLJANCE Palms not labeled. No records of wastes deposited
in on-site lagoon.
COMMENTS
of haz. wd^tes transported to site dnd
into on-site lagoon could not be confirmed or denied. Lagoon contained
an undetermined volume of aqueous material. _
INSPECTOR
1630 hrs.
W. Smith, Solid Waste Inspector 6/10/99
Preliminary Assessment Training
-------
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o&45 Perform on-site reconnaissance. Site is
currently inactive. Enter site from ware-
house complex, road.
0&5O Proceeding north/northwest from road.
Observe rubbish pile due west of railroad
tracks which traverses the site. The
' rubbish pile consists of assorted debris
and is estimated to be 5OO sq. ft in area
Continue walking east from rubbish pile.
OQ55 Observe area of standing rainwater east of
shed and metal structure. Shed covers two-
10OO gallon mixjng tanks. The tanks and
a metal structure are situated on one
concrete pad. The metal structure is
inaccessible. Adjacent to the north of this
pad is a smaller, second concrete pad on
which 200. 55-gatlon drums are stored.
Contents of the tanks and drums are not
indicated.
0915 Walked north/northwest of drum pad to a
lagoon. A concrete pad. shed and a series of
weirs are located on the southern edge of the
lagoon. A drainage ditch borders the west
and south of the lagoon: flow appears to be
north and east, respectively. North drainage
flows into a culvert pipe.
L\*ocA. LMi* 1-2-99
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1-2-99
-------
31
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The lagoon is estimated to be
5OOO sq. ft. volume unknown.
O940 Walk west over railroad tracks to site
warehouse building. Doors are located on the
south and north facades. The facilittf septic
tank is located to the west, outside of the
' warehouse. Two small concrete pads are
, located on the northeast and northwest
corners of the north facade. An oxidation
pond is observed north/northwest of the
warehouse. The fond is estimated to be
?5O 84, ft. Volume unknown. Borne debris
is observed in the pond.
O955 A drainage ditch is observed along the
perimeter of the property. The drainage ditch
is walked. The ditch appears to be inter-
mittent, although areas of the ditch were
observed to be overflowing during the recon-
naissance. The ditch appear to receive all
site runoff and borders the site to the
north and west and south. Eventual flow
is to the south into a perennial ditch
appron/matelif 6.OOO ft from the site
Three areas of overflow and stained soils
are observed along the northwest corner of
I the f roper tifc Each area is
\ Lite's A. iittfo- 1-2-99
-------
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1-2-99
approximately 1O ft wide and are estimated
at 5O ft. 2O ft and 5O ft in length.
respectively, for a total of WOO 8$ ft of
observed stained soils.
1050 The site perimeter is unfenced. hut no
evidence of trespass was observed. Total
site area is approximated to be 15 acres.
1040 Leave ABC property to complete survey of
nearbi^targets (environs).
1050 A small subdivision of 5 houses is located
between 1OO and ZOO ft to the north and
west of the site. No schools or daycare
facilities are observed within 1/4 mile of
site.
1150 Environs survey completed.
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NOT1D5CME
-------
CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
APPENDIX A
OMB Approval Number: 2050-0095
Approved for Use Through:
PA SCORE SHEETS
Site Name:
Street Address:
City/State/Zip:
Investigator.
Agency/Organization:
Street Adress:
City/State/Zip:
Date:
Preliminary Assessment Training
PAGE 27
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
INSTRUCTIONS FOR SCORE SHEETS
INTRODUCTION
This score sheet package functions as a self-contained workbook providing all of the basic
tools to apply collected data and calculate a PA score. Note that a computerized scoring
tool, "PA-Score," is also available from EPA (Office of Solid Waste and Emergency Response,
Directive 9345.1-11). The score sheets provide space to:
• Record information collected during the PA
• Indicate references to support information
• Select and assign values "scores" for factors
• Calculate pathway scores
• Calculate the site score
Do not enter values or scores in shaded areas of the score sheets. You are encouraged
to write notes on the score sheets; especially on the Criteria Lists. On score sheets with a
reference column, indicate a number corresponding to attached sources of information or
pages containing rationale for hypotheses. Attach a numbered list of these references to
the score sheets. Evaluate ail four pathways. Complete all Criteria Lists, score sheets
and tables. Show calculations, as appropriate. If score sheets are reproduced by photo-
copying, copy and submit the numbered pages (right-side pages) only.
GENERAL INFORMATION
SITE DESCRIPTION AND OPERATIONAL HISTORY
Briefly describe the site and its operating history. Provide the site name, owner/operator,
type of facility and operations, size of property, active or inactive status, and years of
waste generation. Summarize waste treatment, storage, or disposal activities that have or
may have occurred at the site. Also note if these activities are documented or alleged.
Identify probably source types and prior spills. Summarize highlights or previous investi-
gations.
PROBABLE SUBSTANCES OF CONCERN
Based on your knowledge of the site operations, list all hazardous substances that have
or may have been stored, handled, or disposed at the site. Identify the sources to
which the substances may be related. Summarize any existing analytical data con-
cerning hazardous substances detected on site, in releases from the site or at targets.
Preliminary
-------
CONDUCTING THE PRELIMINARY ASSESSMI
iTIGATION
GENERAL INFORMATION
Site Description and Operational History:
Probable Substances of Concern:
Preliminary
Training
PAGE 29
-------
CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
CASE STUDY SUPPLEMENT: ABC VACUUM SERVICE
GENERAL INFORMATION
OBJECTIVE
Using available general site information for the ABC Vacuum Service site, identify
data gaps, develop a set of PA site reconnaissance objectives, address site access
issues, complete an equipment list, and determine the adequacy of a prepared site
safety plan.
METHOD
1.
Review the site information found in the student manual. Working with
an assigned partner or group, complete the following activities and record
all answers on the work sheet provided with this exercise.
Identify any obvious data gaps in the available information
List at least eight (8) PA site reconnaissance objectives for
the ABC Vacuum site.
Outline the steps necessary to obtain access to this site
Read the site safety plan prepared for the ABC Vacuum site. Determine
if this plan is adequate for the PA objectives outlined above. Make any
necessary adjustments to the plan.
Complete the attached equipment list for the site reconnaissance of the
ABC Vacuum site. Include only the equipment you will need to meet the PA
objectives.
PAGE 30
Preliminary
-------
CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
CASE STUDY SUPPLEMENT: ABC VACUUM SERVICE
WORKSHEET
identify Data Gaps:
List at Least Eight (8) PA Site Reconnaissance Objectives:
1.
2.
3.
4.
*
5.
6.
7.
8.
Outline the Steps Necessary to Obtain Site Access:
Preliminary Assessment Training
PAGE 31
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CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
EQUIPMENT LIST: SITE RECONNAISSANCE VISIT
(Check off those items that apply.)
Expendable Protective Equipment
Butyl rubber boots {M L XL )
Boot covers (S__ M_ L_ XL_)
Hip boots (specify size)
Other
Chemical Resistant Clothing
Tyvek (S_ M_ L_ XL_ XXL__)
Saranex (S_ M L__ XL_ XXL_J
Fully encapsulating suit (specify size)
Other
Expendable Protective Equipment
SCBA tanks (45 cu. ft. composite)
SCBA harness
Cascade system
50-foot airlines
Full-face respirator (SCBA/APR)
Respirator cartridges (specify type)
Escape bottle
Other
Personal Protection/Safety Equipment
Hard hat
Safety goggles
Splash shield
Rain suit (S_ M_ L_XL__
Life vest (S_ M_ L_XL__
XXL_)
XXL_)
Ear plugs
First aid kit
Other
Gloves
Cotton (work gloves)
Viton
Butyl
Neoprene
Latex
Leather
Other
Air Monitoring Equipment
PID (HNU Photovac_ other_J
Organic vapor analyzer
Oxygen meter/explosimeter
Hydrogen sulfide meter
Radiation meter/mini-rad
Detector tubes
Other (specify.
Recording Supplies
Field notebook
Waterproof pens/indelible markers
Clipboard
Ruler
Meters
pH meter
Conductivity meter
Resistivity meter
Metal detector
Preliminary Assessment Training
-------
CONDUCTING THE PRELIMINARY ASSESSMENT INVESTIGATION
EQUIPMENT LIST: SITE RECONNAISSANCE VISIT
(Check off those items that apply.)
Cameras/Film
SX70 Polaroid
35mm Pentax
Kodamatic
12/24/36 print film (rolls )
12/24/36 slide film (rolls.
Other
Surveying Equipment
Optical rangefinder
Brunton compass
Compass
Binoculars
300-foot steel tape
Wooden stakes
Decontamination
Indian tank
Hand sprayer
Eyewash bottles
Scrub brushes
Alconox
Buckets
Paper towels
Other
Hand Tools
Hacksaw
Bolt cutter
Wire cutter
Pliers
Rake
Shovel
Trowel
Other
Tape
Clear plastic
Duct tape
Masking tape
Strapping tape/fiber tape
Flagging tape
Other
Additional supplies:
Miscellaneous
Mobile phone
Radios
Locks/keys
Trash bags
Plastic roll (10 feet by 25 feet)
Vermiculite
Preliminary Assessment Training
PAGE 33
-------
-------
SECTION THREE
SITE
SOURCE
AND
WASTE
CHARACTERIZATION
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
SITE ASSESSMENT QUESTION 1
• Have hazardous substances been
deposited at the site? If so, what and
how much? (See page 40 in PA
Guidance)
• Evaluate waste characteristics
once-use for all four pathways
PA Guidance. Section 3-2
HOW TO STRUCTURE
YOUR DATA SEARCH
• Types of sources on file
- Any impoundments? Are they full? Have
they overflowed? Can they? If empty,
were they used at one time? Where did
the contents go?
- Any drums? Are they corroding? How
are they stored and protected from
weather? Can contents get out?
PA Guidance. Section 3.2
HOW TO STRUCTURE
YOUR DATA SEARCH (cont.)
• Waste quantity
-How much?
-What kinds?
-Physical nature (solid or liquid)?
PA Guidance. Section 32
PAGE 2
Preliminary Assessment Training
-------
SITE. SOURCE AND WASTE CHARACTERIZATION
SOURCE/WASTE
INFORMATION SOURCES
• Files
- USGS maps
- Waste manifests
- Prior inspection reports
- Prior enforcement orders
• Site reconnaissance observations
- Source size/dimensions
- Containment
- Evidence for waste migration
PA Guidance, Section 32
SOURCE/WASTE
INFORMATION RESOURCES (cont.)
• Aerial photography
- Current and historical source types and
locations
- Source size/dimensions
See: //edcwww.cr.usgs.gov/eros-home.html:
PA Guidance. Section 3.2
SITE DEFINITION
Any area or areas where a hazardous
substance has been deposited, stored,
disposed, placed, or has otherwise come to
be located. Such areas may include multiple
sources and may include the area between
the sources.
NOTE: A site should be defined using all information,
both historical and current, regardless of existing
fences, boundaries, or ownership.
PA Guidance. Sector 321. Page 4 40 CFR Part 300. Append* A
'reliminary Assessmei
PAGE 3
-------
SITE, SOURCE AND WASTE CHARACTERIZATIOP
MINI EXERCISE; WHAT IS THE SITE?
SOURCE DEFINITION
• Source: area where hazardous substances have
been deposited, stored, disposed of, or placed.
Also, soil that may be contaminated from
hazardous substance migration.
• Sources do not include those volumes of air,
groundwater, surface water, or surface water
sediments that have become contaminated by
migration. Except in the case of either a ground-
water plume with no identified source or
contaminated surface water sediments with no
identified source; the plume or contaminated
sediments may be considered a source.
P!A Gt*tance. Section 32.1. Psge 4; 40 CFR PM 300. Appendx A
SOURCE DEFINITION (cont.)
i Evaluate present and former sources.
> Generally, source information is limited;
however, incomplete information is still
useful.
PA Guid*ie*. Section 3.2.1. P«9«4: 40 CFR Part 300. Appmdx A
Preliminary A;
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
TYPES OF SOURCES
• Landfills
• Surface impoundments
• Drums
• Containers or tanks
• Waste piles
• Landfarm/land treatment
• Contaminated soil
• Other
PA Guidance, Section 3.2.1. Table 3-1. Page 43
WASTE CHARACTERIZATION
Evaluate each source at a site based on four tiers
• Constituent quantity-Tier A
• Waste stream quantity-Tier B
• Source volume-Tier C
• Source area-Tier 0
For each source, evaluate as many tiers as you have
information to support.
Go to PA Guidance, Appendix A. PA Table 1. Page A-9
PA Guidance. Secbon 3.2.2. (Pefinbons en Pag* 45)
WASTE CHARACTERIZATION (cont.)
• For constituent and waste stream tiers, all
quantities are converted to pounds so they
can be added together
• Use conversions on Table 1 (Page A-9 in PA
Guidance Manual)
• Constituent and waste stream information is
often unavailable at PA stage
1 gallon =10 IDS
2000 Ibs = 1 ton
4 drums = 200 gallons
PA Guuance Section 32V Pig* « 40 CFR Pan 300. Appends A MRS Tame 2-5
Preliminary
PAGE 5
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
WASTE CHARACTERIZATION (cont.)
• Three waste characterization (WC) values
based on ranges of waste quantity:
- 18
- 32
- 100
• Use Single Source column of Table 1a; assign
each evaluated tier a WC score based on its
waste quantity
• Highest WC value is WC score for site
PAGukfcnca. Section 3.2.2. f*ge 47
WASTE CHARACTERISTICS
(WC) SCORING
• PA Table 1 is designed to categorize site sources
into different tiers based on the amount,
concentration, and types of waste present. Evaluate
as many tiers as you can at the PA stage, and use
tfie highest score obtained. The category cutoffs
were based on assumptions established by various
MRS workgroups and designers and are not
discussed within the content of this course.
Likewise, the divisors used in the multiple source
sites column make certain site assumptions based
on a large superfund site information database.
PA Guidance. Section 32.2. P»g« 47
WASTE CHARACTERISTICS
(WC) SCORING (cont.)
• The WC values (at trie PA stage) fall into one
of three scores. These include: 18, 32, or
100. These numbers were derived
mathematically to keep the WC score within
a certain range and thereby not make the
WC score be the driving factor in the overall
site score.
PA Guidance. Section 3.2.2. Page 47
Preliminary Assessment Training
-------
SITE. SOURCE AND WASTE CHARACTERIZATION
MINI EXERCISE
WASTE CHARACTERISTICS SCORE: SINGLE SOURCE (LANDFILL)
EXAMPLE: 500 gallons of a spent solvent mixture disposed of in a
landfill that is 600 feet wide, 1,000 feet long, and 30 feet
deep.
DIRECTIONS: Using PA Table 1 (Page A-9 of PA Guidance),
determine the waste characteristic (WC) score for all
tiers.
TIER A CONSTITUENT QUANTITY = Unknown
TIER B WASTE STREAM QUANTITY = 500 gal x 10 Ibs/gal
= 5,000 Ibs of waste stream
TIER C VOLUME = 600 ft x 1,000 ft x 30 ft = 18,000,000 cu ft
TIER D AREA = 600 ft x 1,000 ft = 600,000 sq ft
Preliminary Assessment Training
PAGE 7
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
MINI EXERCISE OVERVIEW
SINGLE SOURCE SITE
CONSTITUENT TIER
A
Constituent Quantity = not enough information
available.
WASTE STREAM TIER Waste Stream Quantity = 500 gallons
B
VOLUME TIER
C
AREA TIER
D
Waste we know to be in landfill.
Convert to Ibs since that is what is
listed on table.
500 gallons x 10 Ibs/gal = 5,000
From Table 1 - Single Source
Waste Stream Column 1: <500,000 Ibs;
the site WC value is 18.
Volume = 600 x 1,000 x 30 = 18,000,000 million cu ft
From Table 1, Source Type: Landfill;
Single Source Sites Column 2:
Range >6.76 million to 675 cu ft:
the site WC vaule is 32.
Area = 600 x 1,000 = 600,000 sq ft
From Table 1, Source Type: Landfill;
Single Source Sites Column 2:
Range >340,000 to 34 million sq ft:
the site WC vaule is 32 (look up WC at top
of column).
Use the highest value = WC of 32
Preliminary Assessment Training
-------
SITE. SOURCE AWD WASTE CHARACTERIZATION
MULTIPLE SOURCES
Mini Exercise
Two sources exist at the ERTP waste site. They include an
area with ten 55 gallon drums (Source 1) and a small lagoon
(Source 2). The drums are filled with contaminated
tetrachloroethyfene (90% solution) from metal parts cleaning
operation. The lagoon has unknown waste liquids. The
dimensions of the lagoon are 50 ft wide by 70 ft long by 6 ft
deep.
• Evaluate each waste source separately and use the
divisors in the multiple source (far right) column of PA
Table 1 to calculate a Waste Quantity (WQ) total. Sum the
totals for the various waste sources and derive a Waste
Characteristics (WC) Score from PA Table 1B.
MULTIPLE SOURCES
Source 1
Constituent Quantity Tier = Convert to Ibs. (10 drums x 50
gallons/drum x 10 Ibs/gallon x .90 = 4500.
From PA Table 1 - Source Type: Constituent Quantity,
Multiple Source Sites Column: divide the number of
Ibs by 1; the source WQ value is 4500.
Waste Stream Tier = Convert to Ibs (see conversions at
bottom of PA Table 1). 10 drums at 500 Ibs per
drum = 5000 IDS.
MULTIPLE SOURCES
Source 1 (cont.)
From PA Table 1 - source Type: Waste Stream. Multiple
Source Sites Column: divide the number of Ibs by
5000; the source WE value is 1.
Volume Tier = 10 drums
From PA Table 1 - Volume Tier/Source Type: Drums,
Multiple Source Sites Column: divide the number of
drums by 10; the source WE value is 1.
Area Tier = Not AppScable
iment Training
PAGE 9
-------
SiTE, SOURCE AND WASTE CHARACTERIZATION
MULTIPLE SOURCES
Mini Exercise
Two sources exist at the ERTP waste site. They include an
area with ten-55 gallon drums (Source 1) and a small lagoon
(Source 2). The drums are filled with contaminated
tetrachloroethyjene (90% solution) from metal parts cleaning
operation. The lagoon has unknown waste liquids. The
dimensions of the lagoon are 50 ft wide by 70 ft long by 6 ft
deep.
• Evaluate each waste source separately and use the
divisors in the multiple source (far right) column of PA
Table 1 to calculate a Waste Quantity (WQ) total. Sum the
totals for the various waste sources and derive a Waste
Characteristics (WC) Score from PA Table 1B.
MULTIPLE SOURCES
Source 1
Constituent Quantity Tier = Convert to Ibs. (10 drums x 50
gallons/drum x 10 Ibs/gallon x .90 = 4,500.
From PA Table 1 - Source Type: Constituent Quantity,
Multiple Source Sites Column: divide the number of
Ibs by 1; the source WQ value is 4,500.
Waste Stream Tier = Convert to Ibs (see conversions at
bottom of PA Table 1). 10 drums at 500 Ibs per
drum = 5,000 Ibs.
MULTIPLE SOURCES
Source 1 (cant.)
From PA Table 1 - Source Type: Waste Stream, Multiple
Source Sites Column: divide the number of Ibs by
5,000; the source WQ value is 1.
Volume Tier =10 drums
From PA Table 1 - Volume Tier/Source Type: Drums,
Multiple Source Sites Column: divide the number of
drums by 10; the source WQ value is 1.
Area Tier = Not Applicable
PAGE 10
Preliminary
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
MULTIPLE SOURCES
Source 2
Volume Tier = 50 ft x 70 ft x 6 ft = 21,000 cu ft
From PA Table 1 - Source Type: Surface Impoundment,
Multiple Source Sites Column: divide 21,000 by 67.5;
the site WQ value is 311.11.
Area Tier = 50 ft x 70 ft = 3,500 sq ft.
From PA Table 1 - Source Type: Surface Impoundment,
Multiple Source Sites Column: divide 3,500 by 13;
the site WQ value is 269.23.
MULTIPLE SOURCES
Scoring
To determine the WC Score sum the highest WQ values for
each source.
Source 1 (Drums) = WQ: 4,500 (highest value was from
constituent quantity)
Source 2 (Lagoon) = WQ: 311.11 (highest value was from
volume)
Total =WQ: 4,811.11
Look up (his WQ value on PA Table 1B to determine the
Waste Characteristics Score. This WQ value falls within the
range of >100 to 10,000. The WC has a score of 32.
WASTE CHARACTERIZATION (cont)
Multiple source site
• Determine waste quantity for each applicable
tier of each source using divisors in Multiple
Source Column of Table 1A
• Select highest waste quantity for each source
• Sum source highest waste quantity values to
yield waste quantity total
• Apply waste total to Table 18 to determine WC
score
PA Guidance. Section 3.2.2. Page 47
Preliminary Assessment iraimng
PAGE 11
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
SITE, SOURCE AND
WASTE CHARACTERISTICS
Waste Characteristics Score
• Evaluate as many tiers as you can based on the data
available
• Use PA Table 1 and 1B to derive the site Waste
Characteristics (WC) score
• Use the highest tier score at the PA stage. The tier
scoring may be different at the SI/HRS stage
• Depending on the number of site sources, use either
the Single Source Site section of Table 1 or the
Multiple Source Site Column.
PAGE 12
Preliminary Assessment Training
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
CASE STUDY: ABC VACUUM SERVICE
SOURCE CHARACTERIZATION
OBJECTIVE
Using the site information from the site reconnaissance visit, general information from
the previous exercise, and the site map, determine the waste characteristic score for
each source.
METHOD
1. Review the source information.
2. Describe each source on the Source Evaluation Work sheet.
3. Use PA Table 1, Waste Characteristics (WC) Scores and the source
descriptions to calculate the WC scores for each source. Record the
calculations and the scores on the source evaluation score sheets.
POTENTIAL SOURCES:
• Two hundred drums are situated on a small concrete pad north of the above
ground mixing tanks.
• A lagoon on the northwest corner of the site is bounded on the south and west by
drainage ditches. The estimated area of the lagoon is 3,000 sq ft.
• There is a 750-sq ft oxidation pond behind the warehouse. Unspecified debris
was observed in the pond during the site reconnaissance.
• A 500-sq ft rubbish pile is located on the southeastern corner of the site.
• Two 1,000-gallon mixing tanks are located on a concrete pad on the northeastern
corner of the site.
• Some parts of the drainage ditches were seen overflowing during
reconnaissance. Three distinct areas of stained soil were observed; total
estimated area: 1,000 sq ft.
Preliminr
-------
ABC VACUUM SERVICE
11 I I I I II I I I I I I I II 1 I I I I
• • 'Oxidation .
Pond •;
."...
fc^^m^^^
Shed on
tan nt
mixing tank*
O-
o
"""-Mixing
Tanks
| Metal Structure
Warehouse Complex Road
Drainage Ditch
Drainage Direction
|| ) [I" Railroad Track
Not to Scale
I
I
s
-------
SITE. SOURCE AND WASTE CHARACTERIZATION
SOURCE EVALUATION
Number and name each source (e.g., 1. East Drum Storage Area, 2. Sludge Lagoon, 3. Battery Pile).
Identify source type according to the list below.
Describe the physical character of each source (e.g., dimensions, contents, waste types, containment,
operating history).
Show waste quantity (WQ) calculations for each source for appropriate tiers. Refer to instructions opposite
page 5 and PA Tables 1A and 1B. identify waste quantity tier and waste characteristics (WC) factor
category score (for site with a single source, according to PA Table 1A). Determine WC from PA Table
1B for the sum of source WQs for a multiple-source site.
Attach additional sheets if necessary.
Determine the site WC factor category score and record at the bottom of the page.
Source Type Descriptions
Landfill: an engineering (by excavation or construction) or natural hole in the ground into which wastes
have been disposed by backfilling or by contemporaneous soil deposition with waste disposal, covering
wastes from view.
Surface Impoundment: a topographic depression, excavation, or diked area primarily formed from earthen
materials (lined or unlined) and designed to hold accumulated liquid wastes, wastes containing free
liquids, or sludges that were not backfilled or otherwise covered during periods of deposition; depression
may be dry if deposited liquid has evaporated, volatilized or leached, or wet with exposed liquid; structures
that may be more specifically described as lagoon pond, aeration pit, settling pond, tailing pond, sludge
pit, etc.; also a surface impoundment that has been covered with soil after the final deposition of waste
materials (i.e., buried or backfilled).
Drums: portable containers designed to hold a standard 55-gallon volume of wastes.
Tanks and Non-Drum Containers: any stationary device, designated to contain accumulated wastes,
constructed primarily of fabricated materials (such as wood, concrete, steel, or plastic) that provide
structural support; any portable or mobile device in which waste is stored or otherwise handled.
Contaminated Soil: soil onto which available evidence indicates that a hazardous substance was spilled,
spread, disposed, or deposited.
Pile: any non-containerized accumulation above the ground surface of solid, non-flowing wastes; includes
open dumps. Some types of piles are: Chemical Waste Pile—consists primarily of discarded chemical
products, by-products, radioactive wastes, or used or unused feedstock; Scrap Metal or Junk Pile-
consists primarily of scrap metal or discarded durable goods such as appliances, automobiles, auto parts,
or batteries, composed of materials suspected to contain or have contained a hazardous substance;
Tailings Pile—consists primarily of any combination of overburden from a mining operation and tailings
from a mineral mining, beneficiation, or processing operation; Trash Pile-consists primarily of paper,
garbage, or discarded nondurable goods which are suspected to contain or have contained a hazardous
substance.
Land Treatment: landfarming or other land treatment method of waste management in which liquid wastes
or sludges are spread over land and tilled, or liquids are injected at shallow depths into soils.
Other: a source that does not fit any of the descriptions above; examples include contaminated building,
ground water plume with no identifiable source, storm drain, dry well, and injection well.
PA Guidance, Page 43; 40 CFR Part 300, Table 2-5
Preliminary Assessment Training
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
SOURCE EVALUATION
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Site WC:
PAGE 16
Preliminary Assessment Training
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
SOURCE EVALUATION
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Source
Number:
Source Name:
Source Description:
Source Waste Quantity (WQ) Calculations:
Site WC:
Preliminary Assessment Training
PAGE 17
-------
SITE, SOURCE AND WASTE CHARACTERIZATION
PA TABLE 1: WASTE CHARACTERISTICS (WC) SCORES
PA Table 1A: WC Scores for Single Source Sites and Formulas
for Multiple Source Sites
w
A
s
T
E
S
T
R
E
A
M
V
O
L
U
M
E
SOURCE TYPE
N/A
N/A
Landfill
Surface
Impoundment
Drums
Tanks and Non-
drum containers
Contaminated Soil
Pile
Other
Landfill
Surface
Impoundment
Contaminated Soil
Pile-
Land Treatment
SINGLE SOURCE SITES (assigned WC scores)
WC = 18
£100fb
< 500,000 Ib
*6.7S million ft3
£250,01X3 yd1
S6.750K1
s2SOytf
£1,000 4runw
£50,000 gallons
s6. 75 million ft3
£250,000 yd'
S8.7SXP
4250yd1
£6,750 IP
S250r*
£340,000 ft'
£1.300 ft'
£0.029 acres
«3.4 million ft7
£78 acres
s1 .300' ft'
£0.029 acres
£27.000 ft>
sO 62 acre*
WC = 32
>100to 10.000 Ib
>500.000 to 50 million Ib
>6 75 million to 675 million ft3
>2SO.OOO to 25 million yd3
>6. 750 to 675.000 ft3
>250 to 25.000 yd>
>1. 000 to 100 .000 drums
>SO.OOO to 5 million gallons
>6.7S million to 075 million ft>
>250.000 to 25 million y6.750 to 675,000 tf
>2SO to 25.000 yrf>
>6.750 to 675.000ft1
>250 to 25.000 yrf1
>340.000 to 34 million ft'
>7.8to760acms
>1. 300 to 130.000 ft3
9O.029 to 2.9 acres
>3.4 million to 340 million ft'
>78 to 7.800 acres
>1.300 to 130.000 ft'
-O029 to 2.9 acns
•27.000 to 2.7 million ft'
•062 to 62 acres
WC = 100
> 10,000 Ib
>50 million Ib
>67S million ft9
>2S million y 675.000ft>
>25.000y«P
>1 00,000 drums
>5 million gallons
>675 million ft3
>25 million yd3
>675.000ft>
725,000yd1
>675,000ft'
>25,000yd>
>34 million ft'
>78O acres
>1 30.000 ft'
>i9 acres
>340 million ft'
>7.800 acres
>130.000fP
>2.9 acres
.2 7 million ft'
-62 acres
MULTIPLE
SOURCE SITES
Formula for
Assigning Source
WQ Values
«>-=• 1
Ib -r 5000
ft3 * 67.500
yd' * 2,500
ft3* 67.5
yd3* ZS
drums > 10
gallons * 500
fp+ 67.500
yd= + 2.500
ft>+ 67.5
yd1* Z5
ft3 * 67.5
yd> t 2.5
ft' + 3,400
* 0.078
ft'* 13
acres + 0.00029
ft' * 34.000
• 0.76
ft1 » 13
acres t 0.00029
ft' * 270
acres * 0.0062
1 ton = 2,000 Ib = 1 yd* = 4 drums = 200 gallons
Use area of land surface under pile, not surface area of pile.
PA Table 1B: WC Scores for Multiple Source Sites
WQ TOTAL
>0to100
•-tOO to 10.000
>10,000
WC SCORE
ta
32
too
PAGE 18
Preliminary Assessment Training
-------
SECTION FOUR
GROUNDWATER
PATHWAY
Resources
Wellhead
Protection
Area
Nearest
Well
Groundwater
Population
A
AQUIFER
-------
GROUNDWATER PATHWAY
DATA SEARCH QUESTIONS
Aquifers)
• What is local stratigraphy?
• What aquifer(s) serves nearby areas?
• How deep is the shallowest aquifer that is
used for drinking purposes?
. Go to PA Guidance, Appendix A,
Page A-11, Groundwater Use Description
PA GimJanw. See*oo 3.3
DATA SEARCH QUESTIONS (cont.)
Wells (targets)
• How many drinking-water wells? Locations?
• Any municipal systems? Private wells?
• How many people are served?
• Is water from different wells blended? Is
groundwater blended with surface water?
Go to PA Guidance, Appendix B.
Pag* B-13. Groundwater Us* and Characteristics
PA Guidance. Section 3.3
AQUIFER DEFINITION
Aquifer (as defined by PA Guidance)
• Saturated subsurface zone form which
drinking water is drawn
• For site assessment purposes, groundwater
used for certain resources, such as
agriculture and recreation, is also evaluated
Note: Not all aquifers are used for drinking purposes
PA Gudance, Section 3 3
PAGE 2
Preliminary
-------
GROUNDWATER PATHWAY
GROUNDWATER
INFORMATION SOURCES
• U.S. Geological Survey (USGS)
• Well logs
• Water utility
• Local offices-Health Department, water resources
• Site reconnaissance observations
• Files for other, nearby sites
http://www.usgs.gov
http://mapping.usgs.gov/
PA Guidance, Section 3,3
SITE ASSESSMENT QUESTIONS
FOR GROUNDWATER
#1
What rsihe like*hood
tha hazardous
substances have
been released to
groundwater?
#2
Who and what are
likely to be impacted
by contaminated
groundwater?
LR x T x WC =
82,500
#3
Have hazardous
subtrees been
deposted at the
site? If so. what?
How much?
Groundwater
Pathway
Score
GROUNDWATER
PATHWAY EVALUATION
• Waste characteristics (WC)
Determined during source characterization
(18,32,100)
• Likelihood of release (LR)
Suspected release (550)
No suspected release (500, 340)
• Targets (T)
Primary targets (uncapped)
Secon da ry targets
PA Guidance. Section 33
Preliminary Assessment Training
PAGE 3
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
Don
ODD
nan
non
ana
an
DDO
ODD
ODD
ODD
DD
DD
Are sources poorly contained?
Is the source a type likely to contribute to
groundwater contamination (e.g., wet
lagoon}?
Is waste quantity particularly large?*
Is precipitation heavy?**
Is the infiltration rate nigh?
Is the site located in an area of karst
terrain?
Is the subsurface highly permeable or
conductive?
Is drinking water drawn from a shallow
aquifer?
Are suspected contaminants highly mobile
in groundwater?
Does analytical or circumstantial evidence
sugestground water contamination?
Other criteria?
Y N U
eon
s k
DDD
ODD
DDE
ODD
ODD
ODD
ODD
an
DD
Is any drinking-water well nearby?
Has any nearby drinking-water well been
closed?
Has any nearby drinking-water user
reported foul-tasting or foul-smelling water?
Does any nearby well have a large draw-
down or high production rate?
is any drinking-water well located be-
tween the site and other wells that are
suspected to be exposed to a hazardous
substance?
Does analytical or circumstantial evidence
suggest contamination at a drinking-water
well?
Does any drinking-water well warrant
sampling?
Other criteria?
PRIMARY TARGET(S) IDENTIFIED?
SUSPECTED RELEASE?
If WQ > 32, it is considered large.
** If precipitation is > 40 inches of total annual
precipitation or > 15 inches of annual net precipitation.
then it is considered heavy
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
Preliminary
-------
GROUNDWATER PATHWAY
GROUNDWATER
PATHWAY CRITERIA LIST
• Us
• C(
wr
• Nc
• Cc
• Be
PA
;ed for determining a suspected release
attains issues to consider when determining
lether any drinking-water wells are primary targets
rt a tally sheet
msider other site-specific issues
st professional judgement
Go to PA GuKtance. Appendix A,
Guidance. Appendix A
SPECIAL CONSIDERATIONS FOR
LIKELIHOOD OF RELEASE:
DEPTH TO AQUIFER
[ Depth to Aquifer
I 22n>et-5
-------
GROUNDWATER PATHWAY
"SUSPECTED RELEASE" OR
"NO SUSPECTED RELEASE"
• Suspected release: High likelihood hazardous
substance has been released to groundwater
• No suspected release: Low likelihood of release
• Required professional judgment based on site
and hydrogeological conditions
PA Guidance, Pago 58 and 60
LIKELIHOOD OF RELEASE
EXAMPLE A:
How Ickeff are hazardous
substanoss to escape from
EXAMPLES:
One* substances have escaped
from source, how likely are they to
reach groundwater?
GROUNDWATER TARGETS*
• Drinking-water supply wells located within
4 miles of the site
• Groundwater target = well
• Groundwater population = people served by
well
• Primary targets are determined by likelihood
of exposure
• Secondary targets are distance-weighted
•Groundwater flow direction is NOT considered in a PA
PA Guidanca. Stctten 3.3.2
PAGE 6
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
GROUNDWATER TARGETS (cont.)
Multiple aquifers
• Evaluate all groundwater sources within
4 miles as targets, regardless of aquifer
from which they draw
• A definite connection between multiple
aquifers makes it one aquifer
PA Guidance, Section 3.3.2
GROUNDWATER TARGETS (cont.)
At PA, conduct comprehensive target survey
• Municipal wells
• Community wells
• Private wells
PA Guidance. Section 3.3.2
GROUNDWATER TARGETS (cont)
Need to know
• Well locations, depths
• Number of people served
• Number of connections
• Aquifer tapped
• Screen depth
• Volume pumped
• Annual production
• Karst terrain vs. n on-karst terrain
• Closed wells
PA Guidance. Sector 3.3.2
Preliminary A:
-------
GROUNDWATER PATHWAY
GROUNDWATER TARGETS (cont.)
All targets must be plotted on a map
• See http://mapping.usgs.gov/
PA Guidance, Section 3.3.2
GROUNDWATER TARGETS (cont.)
Target distance categories
• A series of concentric circles around the outer
boundaries of each source with radii of 1/4 mile,
1/2 mile, 1 mile, 2 miles, 3 miles, and 4 miles
drawn on a topographic map
• Distance circles are used to evaluate secondary
drinking-water target populations
• Distance is measured from nearest source to
well, not population
PA Giidance, Section 3.3.2
GROUNDWATER TARGETS
Target Distance Categories
(Not to seal*}
PAGES
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
GROUNDWATER TARGETS (cont.)
Blended municipal systems
Definition: Entire system is interconnected by
valves or connecting lines so that water drawn
from any supply well and/or intake can reach any
user of the system.
• For blended systems, assign a population to
each well or water intake
PA Guidance. S«c6on 3.3.2. Pago* 82-64
GROUNDWATER TARGETS (cont)
Blended municipal systems: apportionment of
population
• Apportionment is based on each well's contribution
* Base apportionment on average annual production
* Apportionment is not necessary if any well serving
the system is a primary target
» Apportionment is not necessary if all system wells
are in one target distance category
PA Guidance. SecUxi 3.32
GROUNDWATER TARGETS (cont.)
Blended municipal systems: apportionment of
population-The "40 Percent Rule"
• tf any supply well or intake in a blended system
contributes 40 percent or more of the system's
annual production, apportion population to
each well based on percent contribution
• tf all supply wells and/or intakes contribute less
than 40 percent, apportion population equally
among al
PA Gwdano*. S*etnn 3.3.2. Pag«63
Preliminary As:
PAGE 9
-------
GROUNDWATER PATHWAY
Mini Exercise: Blended Municipal Well
System The "40 Percent Rule"
^DW.1
f\ nUL, , (^MSfe) Water Irom OW-1 , OW-2. am) DW-3
^Dvk-2 V*ij|jPx isblOTdedtogelhef
and semes 10.000 people
^DVM
W
DV
DV
DV
SCENARIO ONE
- CMMtvgw S»m«
V-1 30
V-2 35
WJ 35
i
Wet
OW-I
OW-2
OW.J
SCENARIO TWO
AlRMH
comomion
SO
20
30
P*p«*IIM
Smtnt
GROUNDWATER TARGETS (cont)
Worker and student populations
• Should be evaluated if they are served by
groundwater drawn from within 1 mile of source
• Generally, do not spend time collecting
information about populations outside of 1 mile
because distance-weighting will greatly reduce
their significance
• However, you can count same person 3x if
person is a resident, student, and a worker
PA Guidance. Sactton 3.3.2. P»ge6S
GROUNDWATER TARGETS (cont)
Primary or secondary target wells
• Primary targets: high likelihood drinking-water
wells in question have been exposed to
hazardous substances from site
• Secondary targets: low likelihood of exposure
• Requires professional judgement based on
site, pathway and target characteristics
PA Gubsnca. Sector 312. Page 65
PAGE 10
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
DDD
ODD
ODD
nan
ana
an
nan
ODD
nan
DPD
DD
an
Are sources poorly contained?
Is the source a type likely to contribute to
groundwater contamination (e.g., wet
lagoon)?
Is waste quantity particularly large?*
Is precipitation heavy?**
Is the infiltration rate high?
Is the site located in an area of karst
terrain?
Is the subsurface highly permeable or
conductive?
Is drinking water drawn from a shallow
aquifer?
Are suspected contaminants highly mobile
in groundwater?
Does analytical or circumstantial evidence
sugestground water contamination?
Other criteria?
Y N U
eon
s k
DDD
ODD
nnn
ODD
ODD
DDD
DDD
DD
DD
Is any drinking-water well nearby?
Has any nearby drinking-water well been
closed?
Has any nearby drinking-water user
reported foul-tasting or foul-smelling
Does any nearby well have a large
drawdown or high production rate?
Is any drinking-water well located
between the site and other wells that are
suspected to be exposed to a hazardous
substance?
Does analytical or circumstantial evidence
suggest contamination at a drinking-water
well?
Does any drinking-water well warrant
sampling?
Other criteria?
PRIMARY TARGET(S) IDENTIFIED?
SUSPECTED RELEASE?
If WQ > 32, it is considered large.
' If precipitation is > 40 inches of total annual
precipitation or > 15 inches of annual net precipitation,
then it is considered heavy
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
GROUNDWATER
CRITERIA LIST
» Primary target well selection is based on:
- Characteristics of site and environs
- Sources, types and quantities of wastes
- Proximity of well to sou rce(s)
- Characteristics of the welJ (depth, screen,
construction)
• Primary target wells are identified using the
Groundwater Pathway Criteria List (PA
Guidance, Appendix A, Page A-13)
PA Guidance, Section 3.3.2, Peget 99-70
PRIMARY TARGET
POPULATION
Definition: The human population served by
drinking water from primary target wells thought
to be contaminated.
• Primary targets are possible only if a release
is suspected
PA Guidance. Section 3.3.2, Pagtc 66-70
SECONDARY TARGET POPULATION
Definition: The human population served by drinking
water drawn from secondary target wells.
• If a release is suspected, some taigets may be evaluated
as primary targets and others as secondary targets
• If no release is suspected, all targets are evaluated as
secondary targets
• Populations are distance-weighted based on the distance
category in which wells are located
• Populate ns served by wells located in inner rings carry
more "weghf because contaminants become diluted as
they migrate outward
PA Guicknce. Section 3 3.2. Pages 71 -72
PAGE 12
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
WELLHEAD PROTECTION AREA
(WHPA)
Definition: Under the federal SDWA, a state-designated area
restricting certain land uses and industrial practices around
drinking-water wells,
• Consider if any on-site sources or primary targets are
located within a designated WHPA
• Also consider if neither of the above apply but any part
of a designated WHPA is located within 4 miles of the
site
• WHPA must be established and not proposed
PA Guidance Section 3.3 2. Page 74
RESOURCES
Definition: Use of groundwater for purposes other than
drinking water.
• Irrigation of commercial craps
* Watering of commercial livestock
• Commercial food preparation
• Recreation
• Generally, do not expend significant effort
evaluating resources during PA
• Usually assigned a default value of 5 points
• If groundwater is know to be saline or of poor
quality, score: 0 points
PA Guidance. Section 3.3.2. Pige 75
GROUNDWATER PATHWAY
SCORE SHEET
PA Guidance, Appendix A, pages A-14
through A-17
Directions found in PA Guidance, Section 3.3.2
and in Appendix A
Secondary target population values
determined using PA Table 2, "Values for
Secondary Groundwater Target Populations"
Go to PA Guidance, Appendix A.
Page A-1 5. Grotndwater Pathway Score Sheet
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY SCORE SHEET
PA THWA Y CHARACTERS TICS
Do you suspect a release? (See Groundwater Pathway Criteria List, page 7.)
Is the site located in karst terrain?
Depth to aquifer:
Distance to the nearest drinking-water well:
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to groundwater (See
page 7), assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release to groundwater,
and the site is in karst terrain or the depth to aquifer is 70 feet or less, assign a
score of 500; otherwise, assign a score of 340. Use only Column B for this
pathway.
TARGETS
4.
6.
PRIMARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you suspect have been exposed to a hazardous
substance from the site. (See Groundwater Pathway Criteria List, page 7.)
people x 10 =
SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 2.
Are any wells part of a blended system? Yes No
If yes, attach a page to show apportionment calculations.
NEAREST WELL: If you have identified a primary target population for ground-
water, assign a score of SO; otherwise, assign the Nearest Well score from
PA Table 2. If no drinking-water well exist within 4 miles, assign a score of zero.
WELLHEAD PROTECTION AREA (WHPA): If any source lies within or above a
WHPA, or if you have identified any primary target well within a WHPA. assign a
score of 20; assign 5 if neither condition holds but a WHPA is present within 4
miles otherwise, assign zero.
7 RESOURCES
(20.5 or 0)
(5
UO.SorO>
(SvO)
T =
WASTE CHARACTERISTICS
8. a) If you have identified any primary target for groundwater. assign the waste
characteristics score calculated on page 4, or score or 32. whichever is
GREATER. Do not evaluate part B of this factor
b) If you have NOT identified any primary target for groundwater. assign the
waste characteristics score calculated on page 4.
(100. n o. HI (log. Surll)
wc =
(SUB|*C1 to • muamum Of 100)
GROUNDWATER PATHWAY SCORE:
LR x T x WC
82,500
PAGE 14
Preliminary Assessment Training
-------
PA TABLE 2: VALUES FOR SECONDARY GROUNDWATER TARGET POPULATIONS
PA Table 2a: Non-Karst Aquifers
Distance
from Site
Oto 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mite
> 1 to 2 miles
> 2 to 3 miles
> 3 to 4 miles
Population
Nearest Well =
Nearest Well
(choose
highest)
20
18
9
5
3
2
Population Served by Wells Within Distance Category
1
to
10
1
1
1
1
1
1
11
to
30
2
1
1
1
1
1
31
to
100
5
3
2
1
1
1
101
to
300
16
10
5
3
2
1
301
to
1.000
52
32
17
9
7
4
1,001
to
3.000
163
101
52
29
21
13
3,001
to
10.000
521
323
167
94
68
42
10.001
to
30.000
1,633
1.012
522
294
212
131
30,001
to
100.000
5.214
3,233
1,668
939
678
417
Greater
than
100.000
16,325
10,121
5,224
2,938
2,122
1,306
Score =
Population
Value
PA Table 2b: Karst Aquifers
Distance
from Stie
0 to 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mile
> 1 to 2 miles
> 2 to 3 miles
> 3 to 4 miles
Population
Nearest Well =
Nearest Well
(choose
highest)
20
20
20
20
20
20
Population Served by Wells Within Distance Category
1
to
10
1
1
1
1
1
1
11
to
30
2
1
1
1
1
1
31
to
100
S
3
3
3
3
3
101
to
300
16
10
8
8
8
8
301
to
1.000
52
32
26
26
26
26
1,001
to
3.000
163
101
02
82
82
82
3.001
to
10.000
521
323
261
261
261
261
10.001
to
30.000
1,633
1,012
816
816
816
816
30.001
to
100.000
5.214
3,233
2,607
2,607
2.607
2,607
Greater
than
100.000
16,325
10,121
8,162
8,162
8,162
8.162
Score =
Population
Value
-------
GROUNDWATER PATHWAY
MINI EXERCISE:
SECONDARY GROUNDWATER
TARGET POPULATION
DW-1
1.Smile* from source;
serve* 1, SCO people
DW-2
' 0.8 miles from i
serves 842 people
OW-5
n* 5.2 miles from:
serve* town of Baker
Town of Baker has 3
wells of Mini capacity
-!.700
solving j;
non-karsl bednck
DlnM
2.S miles from source
serves town of Baker
OW-3
0.4 miles from source;
Serves tow of Baker
(Not to scab)
MINI EXERCISE:
SECONDARY GROUNDWATER
TARGET POPULATION
Using PA Table 2A, Determine:
astmn
Category {m.)
0-1/4
1/4-1/2
1/2-1
1-2
2-3
3-4
Wei*
Number of
People
DinanoB-Weshted
Population Value*
Kant
MINI EXERCISE: SECONDARY
GROUNDWATER TARGET POPULATION
VIM
ow-t
DW-2
OW-3
'
«e~«s 2$ people
1 . 3 miles f nm aoum ;
.NV.t137p.ope
scssmcnt Training
-------
GROUMDWATER PATHWAY
GROUNDWATER SCORING
, r^ -r- ,«,~
LR X T X WC
no
'
Groundwater
_ Pathway
Score
(Maximum of 100)
GENERAL PATHWAY AND
SITE SCORING FACTS
• If one pathway scores 57 points and the remaining 3
pathways score 0 points, then the overall Site Score
= 28.50 points
• If one pathway scores a maximum of 100 points and
the remaining 3 pathways score 0 points, then the
overall Site Score - 50.0 points
• If one pathway initially scores 0 points for Targets,
use the default value of 5 points for Resources. This
will result in a Pathway score of 0.97 points (rather
than 0 points), assuming there is a Suspected
Release, and Waste Characteristics = 32 points.
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
CASE STUDY: ABC VACUUM SERVICE
GROUNDWATER PATHWAY
OBJECTIVE
Using the background information from file searches, site reconnaissance notes,
reference materials, maps, and phone conversation records, complete the "Ground-
water Pathway" portion of the PA score sheets.
METHOD
1. Review the general groundwater pathway information summary provided and
the file information included with this exercise.
2, Using the information provided, complete the "Groundwater Use Description"
of the PA score sheets, Page 27 of this section of the manual.
3. Read the instructions for the "Groundwater Pathway Criteria List" and complete
the "Suspected Release" and "Primary Targets" evaluations. Determine
whether you hypothesize a suspected release, and identify whether there are
any primary targets. Summarize the rationale for these decisions in the space
provided.
NOTE: The instructor will guide you through Steps #4 and #5.
4. Using the existing site information and the score sheet instructions, complete all
the portions of the "Groundwater Pathway Score Sheet." PA Table 2, 'Values
for Secondary Groundwater Target Populations," should be used to determine
population values for secondary targets if applicable. Remember to evaluate
the "Nearest Well" category.
5. Calculate and record the Groundwater Pathway score.
GROUNDWATER PATHWAY
• There are two aquifers of concern:
- A shallow, water table aquifer (depth to water = 30 ft) that consists mainly of
fine to coarse-grained sands
- A deeper aquifer (depth to water = 160 ft) that consists mainly of fine to
coarse-grained sands and gravel
• Five nearby residences use private wells that tap the shallow aquifer.
• No other private wells exist within 4 miles of the site.
Preliminary
-------
GROUNDVVATER PATHWAY
GROUNDWATER PATHWAY (cent)
• A blended municipal well system is present within 1 mile of the site:
- The total population served is 8,900
- The wells tap the deeper aquifer and are screened at approximately 195 ft.
• Ground-water is also used in commercial crayfish farms.
• No wellhead protection area is located within 4 miles of the site.
• The site is not located in an area of karst terrain.
MUNICIPAL WELL SYSTEM APPOINTMENT
WELL
IDENTIFICATION
Well A
WellB
WellC
DISTANCE
FROM SITE
2,800 ft
(0.45 miles)
4,000ft
(0.76 miles)
4,000 ft
(0.76 miles)
PERCENT ANNUAL
PRODUCTION
30
35
35
Preliminary Assessment
-------
Private Wfell
— — — Property Boundary
ABC VACUUM SERVICE
-------
GROUNDWATER PATHWAY
ABC Vacuum Service
1 Mile
Topographic
Contours, ,
\ 25'
i
Residential
Area
-------
Geologic Cross Section Beneath Site
I
3 .'t^- .'-o- .*erj •_.*cr>*' .'cr--,.
O- • - H • -O- • -O- • -O- • -O- . -O« • O . -O-
'"•' '' ~~ '-' ''" '•'^ '' '~ '•"' ''" "1 '* "" * '''
i
-------
GROUNDWATER PATHWAY
Geology Of Atlas Parish, Louisiana
By MARY CLARKE
U.S. GEOLOGICAL SURVEY
U.S. DEPARTMENT OF THE INTERIOR
UNITED STATES GOVERNMENT PRINTING OFFICE : 1989
Preliminary Assessment Trai
-------
GROUNDWATER PATHWAY
HYDROGEOLOGIC SETTING
Atlas Parish is situated in the subtropical zone along the borders of the Mississippi
River. Annual precipitation for this region averages 57 inches and is the major source of
recharge for the aquifers of the area.
GEOLOGIC FRAMEWORK
The Atlas Parish aquifer system consists of two aquifers of similar composition. The
shallow aquifer is composed of alluvial sediments, namely fine-to-coarse grained sands, and
has a depth to water of approximately 30 feet. The deeper aquifer consists mainly of fine-to-
coarse grained sand and gravel with silty clay layers, with depth to water being estimated at
160 feet. As a result of these compositions, permeabilities for both aquifers are high.
PAGE 24
Preliminary Assessment Training
-------
GROUNDWATER PATHWAY
Lisa A. Lifts
PHONE CONVERSATION RECORD
Originator
Conversations with:
Name: Karen Miller
Date: 12 / 20 / 99
Time: 2:33
AM
Company: U.S. CenSUS BureflU
Address: Federal Building
Pallas. Texas 73202
Phone:
<2W 655-0000
subject: Population multiplier for Atlas Parish LA
Originator Placed Call
Originator Received Call
w.o.t: 098763-^3
Notes: Ms. Miller provided ^he following information: Based on 1990 U.S. Census dak
there is an average of 3.5 persons per household in Atlas Parish. Louisiana.
12-20-99
File: ABC Vhcuum Service
FoBow-up Action:.
Tickle File:
Follow-up By:
Copy/Route T
Originator's Initials:.
LoUL
Preliminary Assessment Training
PAGE 25
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY
Groundwater Use Description: Provide information on groundwater use in the vicinity.
Present the general stratigraphy, aquifers used, and distribution of private and municipal
wells.
Calculations for Drinking-water Populations Served by Groundwater: Provide populations
from private wells and municipal supply systems in each distance category. Show apportion-
ment calculations for blended supply systems.
PAGE 26
Preliminary Assessment Training
-------
GROUNDWATER PA'
SOURCE EVALUATION
GROUNDWATER USE DESCRIPTION
Describe Groundwater Use Within 4 Miles of the Site:
(Describe stratigraphy, information on aquifers, municipal and/or private wells.)
Calculations for Drinking-water Populations Served by Groundwater:
Preliminary As:
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY CRITERIA LIST
This "Criteria List" helps guide the process of developing hypotheses concerning the occurrence of a
suspected release and the exposure of specific targets to a hazardous substance. The check-boxes
record your professional judgment in evaluating these factors. Answers to all of the listed questions may
not be available during the PA. Also, the list is not all-inclusive; if other criteria help shape your hypoth-
eses, list them at the bottom of the page, or attach an additional page.
The "Suspected Release" section identifies several site, source, and pathway conditions that could
provide insight as to whether a release from the site is likely to have occurred. If a release is suspected,
use the "Primary Targets" section to evaluate conditions that may help identify targets likely to be ex-
posed to a hazardous substance. Record responses for the well that you feel has the highest probability
of being exposed to hazardous substance. You may use this section of the chart more than once,
depending on the number of targets you feel may be considered "primary."
Check the boxes to indicate a "yes," "no" or "unknown" answer to each question. If you check the
"Suspected Release" box as "yes," make sure you assign a Likelihood of Release value of 550 for the
pathway.
PAGE 28
Preliminary
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
DDE
ODD
nan
ana
aaa
an
ana
aaa
ana
nan
aa
an
Are sources poorly contained?
Is the source a type likely to contribute to
groundwater contamination (e.g., wet
lagoon)?
Is waste quantity particularly large?
Is precipitation heavy?
Is the infiltration rate high?
Is the site located in an area of karst
terrain?
Is the subsurface highly permeable or
conductive?
Is drinking water drawn from a shallow
aquifer?
Are suspected contaminants highly mobile
in groundwater?
Does analytical or circumstantial evidence
sugest groundwater contamination?
Other criteria?
SUSPECTED RELEASE?
Y N U
eon
s k
COO
naa
aaa
aaa
aaa
naa
aaa
aa
na
Is any drinking-water well nearby?
Has any nearby drinking-water wefl been
closed?
Has any nearby drinking-water user
reported foul-tasting or foul-smelling water?
Does any nearby well have a large draw-
down or high production rate?
Is any drinking-water well located be-
tween the site and other wells that are
suspected to be exposed to a hazardous
substance?
Does analytical or circumstantial evidence
suggest contamination at a drinking-water
well?
Does any drinking-water well warrant
sampling?
Other criteria?
PRIMARY TARGET(S) IDENTIFIED?
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
Preliminary Assessment Training
PAGE 29
-------
GROUNDWATER PATHWAY
GROUNDWATER PATHWAY SCORE SHEET
Pathway Characteristics
Answer the questions at the top of the page. Refer to the Groundwater Pathway Criteria List (Page 7*) to
hypothesize whether you suspect that a hazardous substance associated with the site has been released to
groundwater. Record depth to aquifer (in feet): the difference between the deepest occurrence of a hazardous
substance, and the depth of the top of the shallowest aquifer at (or as near as possible) to the site. Note whether
the site is in karst terrain (characterized by abrupt ridges, sink holes, caverns, springs, disappearing streams).
Record the distance (in feet) from any source to the nearest well used for drinking water.
Likelihood of Release (LR)
1. Suspected Release: Hypothesize based on professional judgment guided by the Groundwater Pathway
Criteria List (Page 7). If you suspect a release to groundwater. use only Column A for this pathway, and do not
evaluate factor 2.
2. No Suspected Release: If you do not suspect a release, determine score based on depth to aquifer or whether
the site is in an area of karst terrain. If you do not suspect a release to groundwater. use only Column B to score this
pathway.
Targets m
This factor category evaluates the threat to populations obtaining drinking water from groundwater. To apportion
populations served by blended drinking-water supply systems, determine the percentage of population served by
each wed based on its production.
3. Primary Target Population: Evaluate populations served by all drinking-water wells that you suspect have been
exposed to a hazardous substance released from the site. Use professional judgment guided by the Groundwater
Pathway Criteria List (Page 7) to make this determination. In the space provided, enter the population served by any
wete you suspect have been exposed to a hazardous substance from the site. If only the number of residences is
known, use the average county residents per household (rounded up to the next integer) to determine population
served. Multiply the population by 10 to determine the Primary Target Population score. Note that if you do not
suspect a release, there can be no primary target population.
4. Secondary Target Population: Evaluate populations served by all drinking-water wells within 4 miles that you do
not suspect have been exposed to a hazardous substance. Use PA Table 2A or 2B for wells drawing from non-karst
and karst aquifers, respectively (Page 9). If only the number of residences is known, use the average county
residents per household (rounded to the nearest integer) to determine population served. Circle the assigned value
for the population in each distance category, and enter it in the column on the far-right side of the table. Sum the
far-right column and enter the total as the Secondary Target Population factor score.
5. Nearest Wei represents the threat posed to the drinking-water well mat is most likely to be exposed to a
hazardous substance. If you have identified a primary target population, enter 50. Otherwise, assign the score
from PA Table 2A or 2B for the closest distance category with a drinking-water well population.
6. Wellhead Protection Area (WHPA): WHPAs are special areas designated by States for protection under
Section 1428 of the Safe Drinking-water Act Loca, State, and EPA Regional water officials can provide information
regarding the location of WHPA's.
7. Resources: A score of 5 can generally be assigned as a default measure. Assign zero only if groundwater
within 4 mies has no resource use.
Sum the target scores in Column A (Suspected Release) or column B (No Suspected Release).
Waste Characteristics (WC1
8. Waste Characteristics: Score is assigned from Page 4. However, if you have identified any primary target for
groundwater, assign either the score calculated on Page 4 or a score of 32, whichever is greater.
Groundwater Pathway Score: Multiply the scores for LR, T and WC. Divide the product by 82.500. Round the
result to the nearest integer. If the result is greater than 100. assign 100.
*Pages noted here pertain to those in the PA Guidance Manual.
Preliminary Assessment Training
-------
5ROUNDWATER PATHWAY
GROUNDWATER PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Groundwater Pathway Criteria List, page 7.)
Is the site located in karst terrain?
Depth to aquifer:
Distance to the nearest drinking-water well:
Yes_
Yes
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to groundwater (See page 7),
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release to groundwater, and
the site is in karst terrain or the depth to aquifer is 70 feet or less, assign a score
of 500; otherwise, assign a score of 340. Use only Column B for this pathway
B
Suspected
Release
LR
TARGETS
3. PRIMARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you suspect have been exposed to a hazardous
substance from the site. (See Groundwater Pathway Criteria List, page 7.)
people x 10 =
4. SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 2.
Are any wells part of a blended system? Yes No
If yes, attach a page to show apportionment calculations.
5. NEAREST WELL: If you have identified a primary target population for ground-
water, assign a score of 50; otherwise, assign the Nearest Well score from
PA Table 2. If no drinking-water well exist within 4 miles, assign a score of zero.
6. WELLHEAD PROTECTION AREA (WHPA): If any source lies within or above a
WHPA, or if you have identified any primary target well within a WHPA. assign a
score of 20; assign 5 if neither condition holds but a WHPA is present within 4
miles; otherwise, assign zero.
7. RESOURCES
(50.20.1S,B .5.11 or
IJO.SorO)
15 or 01
(20.ltAS3.2arO)
(SorO)
T =
WASTE CHARACTERISTICS
8. A. If you have identified any primary target for groundwater. assign the waste
characteristics score calculated on page 4. or score or 32. whichever is
GREATER. Do not evaluate part B of this factor.
B. If you have NOT identified any primary target for groundwater, assign the
waste characteristics score calculated on page 4.
wc =
A|«ct to • mttdmum of 100)
GROUNDWATER PATHWAY SCORE.
Preliminary Assessment Training
LR x T x WC
82.500
-------
PA TABLE 2: VALUES FOR SECONDARY GROUNDWATER TARGET POPULATIONS
PA Table 2a: Non-Karst Aquifers
Distance
from Site
0 to 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mile
> 1 to 2 miles
> 2 to 3 miles
> 3 to 4 miles
Population
Nearest Well =
Nearest Well
(choose
highest)
20
18
9
5
3
2
Population Served by Wells Within Distance Category
1
to
10
1
1
1
i
1
1
11
to
30
2
1
1
1
1
1
31
to
100
5
3
2
1
1
1
101
to
300
16
10
5
3
2
1
301
to
1.000
52
32
17
9
7
4
1.001
to
3.000
163
101
52
29
21
13
3,001
to
10.000
521
323
167
94
68
42
10,001
to
30.000
1,633
1,012
522
294
212
131
30,001
to
100.000
5,214
3,233
1,668
939
678
417
Greater
than
100.000
16,325
10.121
5,224
2,938
2,122
1,306
Score =
Population
Value
PA Table 2b: Karst Aquifers
Distance
from Stie
0 to 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mile
> 1 to 2 mites
> 2 to 3 miles
> 3 to 4 miles
Population
Nearest Well =
Nearest Well
(choose
highest)
20
20
20
20
20
20
Population Served by Wells Within Distance Category
1
to
10
1
1
1
1
1
1
11
to
30
2
1
1
1
1
1
31
to
100
5
3
3
3
3
3
101
to
300
16
10
e
8
8
8
301
to
1.000
52
32
26
26
26
26
1,001
to
3.000
163
101
62
82
82
82
3,001
to
10,000
521
323
261
261
261
261
10,001
to
30.000
1,633
1,012
816
816
816
816
30.001
to
100.000
5,214
3,233
2.607
2.607
2,607
2.607
Greater
than
100.000
16.325
10,121
8,162
8,162
8,162
8,162
Score =
Population
Value
-------
SECTION FIVE
SURFACE WATER
PATHWAY
-------
SURFACE WATER PATHWAY
SURFACE WATER DEFINITION
<
«
•
<
PA<
» Surface water: Naturally occurring, and
some man-made, perennial water bodies
» All surface water is eligible
» Intermittently flowing water bodies qualify
as surface water in areas with less than
20 inches mean annual precipitation
• Overland flow must reach surface within
2 miles to score pathway
Go to PA Guidance. Glossary,
Pag« 166. for debited definitions of water body types
Guidance Section 34; MRS Guidance Manual, Page 207
CONTAMINANTS CAN REACH
SURFACE WATER BY:
Overland flow
Flood
Groundwater
discharge to
surface water
Runoff
SITE ASSESSMENT QUESTIONS
FOR SURFACE WATER
#1
What is me likelihood
that hazardous
substances have been
released to
sivface water?
#2
Who and what are likely
to be impacted by
contaminated
surface water?
LR x T x WC =
82,500
#3
Who and what are
likely to be impacted
by contaminated
surface water?
Surface
Water
Pathway
Score
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER
PATHWAY EVALUATION
Hurnan:Food
Chain threat
PA Quittance. Section 3.4
CHARACTERIZE THE SURFACE
WATER MIGRATION PATH
• Define overland segment
• Identify PPE
• Define "in-water" segment
• Determine flow(s) of the surface water
body/bodies to the 15-mile target
distance limit
• Locate targets for all threats
PA Gudance. Section 3.4
SURFACE WATER
INFORMATION SOURCES
• USGS topographic maps, water resources
reports
• State water reports
• Local water utility
• Soil Conservation Service field office
• U.S. and state fish and wildlife offices
• National Weather Service
• Site reconnaissance
PA Gud*n«. Section 3.4.1
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
DATA SEARCH QUESTIONS:
SURFACE WATER PATHWAY
Likelihood of Release
• What is the distance wastes must travel
to surface water? Where does the site
drainage enter surface water (PPE)?
• Is site subject to flooding? What is the
flood frequency?
• What is the floodplain?
PA Guidance, Section 341 and3 4 2
DATA SEARCH QUESTIONS:
SURFACE WATER PATHWAY (cont.)
Targets
• Uses of surface water downstream from
site? Drinking-water intakes? Fishing?
Recreation?
• Any wetlands or other sensitive
environments downstream that could be
impacted?
PA Gudance. Section 3.4.1 and 3 4.2
LIKELIHOOD OF RELEASE
Suspected Release
• Criteria list consideration
• Summarize rationale for suspected release
• Record decision on likelihood of release in
'Pathway Characteristics'* box on PA score
sheet
Go to PA Guidance. Criteria List for Suspected
Retrace to the Surface Wbtm Pathway, Pages 78-80
PA Gudanc*. Section 3.4.1 and Apponcic A. Pates A-20 and A-21
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
DDD
DDD
ODD
nan
ana
ana
DDD
nan
nan
ana
ana
ana
ana
an
an
Is surface water nearby?
Is waste quantity particularly large?
Is the drainage area large?
Is rainfall heavy?
Is the infiltration rate low?
Are sources poorly contained or prone to
runoff or flooding?
ts a runoff route well defined (e.g., ditch
or channel leading to surface water)?
Is vegetation stressed along the probable
runoff route?
Are sediments or water unnaturally
discolored?
Is wildlife unnaturally absent?
Has deposition of waste into surface water
been observed?
Is groundwater discharge to surface water
likely?
Does analytical or circumstantial evidence
suggest surface water contamination?
Other criteria?
SUSPECTED RELEASE?
Y N U
eon
s k
ODD Is any drinking-water well nearby? If yes:
D Drinking-water intake
D Fishery
D Sensitive environment
Don Has any intake, fishery, or recreational
area been closed?
DDD Does analytical or circumstantial evidence
suggest surface water contamination at or
downstream of a target?
DDD Does any target warrant sampfing? If yes:
D Drinking-water intake
D Fishery
D Sensitive environment
DD
DD
nn
DD
Other criteria?_
PRIMARY INTAKE(S) IDENTIFIED?
PRIMARY FISHERY(IES) IDENTIFIED?
PRIMARY SENSITIVE ENVIRONMENTS)
IDENTIFIED?
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
LIKELIHOOD OF RELEASE
No Suspected Release
• Special considerations
- Distance to surface
water
- Flood frequency
PA Guidance. SocJion 3.4 1
LIKELIHOOD OF RELEASE:
DISTANCE TO SURFACE WATER
Definition: shortest distance runoff would follow
from a source to surface water
* Measured along shortest drainage route
("as the water flows")
• Probable point of entry (PPE): point at
which runoff from site most likely enters
surface water
» Identify runoff route and PPE on site sketch
in PA score sheet
PA Guidance, Section 3.4.1, Pages 81 and 82
LIKELIHOOD OF RELEASE:
DISTANCE TO SURFACE WATER
Preliminary Assessment
-------
SURFACE WATER PATHWAY
LIKELIHOOD OF RELEASE:
FLOOD FREQUENCY
• Locate sources with respect to surface
water flood plains
• Use FEMA flood insurance rate maps
• Record flood frequency in "Pathway
Characteristics" box on PA score sheet
See www.fema.gov
PA Guidance. Section 3.4.1, P«g«s83
EVALUATE THREE SEPARATE
TARGETTHREATS
Drinking-water threat
People drinking surface water; drinking-
water intakes; resources
Human food chain threat
People eating aquatic organisms taken
from surface water; fisheries
Environmental threat
Impacts to sensitive environments (indudin
wetlands, critical habitats, and national
parks) along the surface water route
PA Guidance. Section 3 4.2
TARGET DISTANCE LIMIT
1. Begin measuring
in-water segment at
PPE. and continue
downstream for 15
miles
Go to PA Guidance .Section 3.4.2.
Pages 97 and 88, tor more examples
PA Guidance. Section 342. p»B° 8°
Preliminary Assessment Training
PAGE 7
-------
SURFACE WATER PATHWAY
TARGET DISTANCE LIMIT
2. If tn-water segment
ends in a lake, ocean.
or coastal waters,
measure within that
water body an arc
from mouth of stream
to shores of receiving
water body.
Go to PAGuttance.Secfen 3.4.2.
Pages 87 and 88. for more examples
TARGETS:
DRINKING-WATER THREAT
• Identify drinking-water intakes
• Identify nearest drinking-water intake
• Determine flow rates at intakes
• Evaluate drinking-water population
PA Guidance, Section 3.4.2
TARGETS:
DRINKING-WATER THREAT (cont.)
Multiple PPEs
• Evaluate each PPE
• Use highest scoring watershed
'relimmary
-------
SURFACE WATER PATHWAY
TARGETS:
DRINKING-WATER THREAT (cont.)
• Determine flow at target intakes
- Obtain average flow rate in cubic feet per
second (cfs)
- Estimate using water body type (PA Table 4,
Page A-25)
• Sources of information
- Local water authorities
- USGS water data reports
PA Guidance, Section 3.42. Pag* 89
TARGETS:
DRINKING-WATER THREAT (cont)
Evaluate drinking-water population
• Evaluate population served by each surface water
intake
• Estimate — Number of Y Average number
~ service of persons per
connections household
• Apply rule of apportionment for "blended" systems
PA Guidance. Section 3.4.2, Page 90
TARGETS:
DRINKING-WATER THREAT (cont.)
Primary drinking-water targets
• Target = intake
Population = people served by intake
• Primary target population identified using criteria
list (Appendix A, Page A-21)
• Primary target intake implies a high likelihood that
hazardous substance has reached intake
PA Guidance, Section 342. Page 97
Preliminary Assessment Training
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SURFACE WATER PATHWAY
TARGETS:
DRINKING-WATER THREAT (cont.)
Sec
* L(
re
• S
• c
in
PAG
ondary drinking-water targets
aw likelihood that hazardous substance has
ached intake
econdary targets are dilution-weighted
onsider workers and students only when
formation is readily available
Go to Appendix A. Tabta* 3 and 4.
Page A-25 in PA Guidance Manual
iiidance. Sector 3.< 2. Pag* 99
PRIMARY VS. SECONDARY TARGETS
Inttte *
TARGETS:
DRINKING-WATER THREAT (cont.)
• Resources: use of surface water for purposes other
than drinking
• Examples
- Irrigation of commercial food or forage crops (5-acre
minimum)
- Watering of commercial livestock
- Ingredient in commercial food preparation
- Major or designated water recreation area
• Generally, sufficient to assign value of 5 as default
PA Guidance. Section 341. Pag* 102
Preliminary Assessment Training
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY SCORE SHEET
LIKELIHOOD OF RELEASE AND DRINKING-WATER THREAT SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Surface Water Pathway Criteria List, page 11.) Yes No
Distance to surface water? ft
Flood frequency: yrs
What is the downstream distance to the nearest drinking-water intake? miles.
Nearest fishery? miles. Nearest sensitive environment? miles.
LIKELIHOOD OF RELEASE
References
1. SUSPECTED RELEASE: If you suspect a release to surface water (See
pagel 1}, assign a score of 550. Use only Column A for this pathway.
2.
NO SUSPECTED RELEASE: If you do not suspect a release to surface water,
use the table below to assign a score based on distance to surface water and
flood frequency. Use only Column B for this pathway.
Distance to surface water <, 2.500 fl
Distance to surface water > 2,500 ft, and
Site in annual or 10-yr floodplain
Site in 100-yr floodplain
Site in 500-yr floodplain
Site outside 500-yr floodplain
500
500
400
300
100
DRINKING-WATER THREAT TARGETS
3. Record the water body type, flow (if applicable) and number of people served by
each drinking-water intake within the target distance limit. If there is no drinking-
water intake within the target distance limit, factors 4, 5, and 6 each receive zero
scores.
Intake Name
Water Body Type Flow
cfs
cfs
People Served
cfc
PRIMARY TARGET POPULATION: If you suspect any drinking-water intake listed
above has been exposed to a hazardous substance from the site (see Surface
Water Pathway Criteria List, Page 11). list the intake name(s) and calculate the
factor score based on the total population served.
people x 10 =
SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water intakes that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 3.
Are arty intakes part of a blended system? Yes No
If yes, attach a page to show apportionment caculations.
NEAREST INTAKE: If you have identified a primary target population for the
drinking-water threat (factor 4), assign a score of 50; otherwise, assign the
Nearest Intake score from PA Table 3 If no drinking-water intake exists within the
target distance limit, assign a score of zero.
7. RESOURCES
6.
(50.20.10.2.1wO)
(20.10.2.1 orO)
(SorO)
"T ^
Preliminary Assessment Training
PAGE 11
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SURFACE WATER PATHWAY
TARGETS:HUMAN FOOD
CHAIN THREAT
• Fishery: area of a surface water body from
which food chain organisms are taken, or
could be taken, for human consumption
• Includes both commercial and sport fishing
• Identify all fisheries located between the PPE
and the 15-mile TDL
• Identify by water body type or flow
characteristics
PA Guidance. Section 3.4.1, Page 91
TARGETS:HUMAN FOOD
CHAIN THREAT (cont.)
Primary target fishery
• It is highly likely that hazardous substances
have reached the fishery
• Identified using the criteria list (Appendix A,
Page 22 in PA Guidance Manual)
PA Gudaneo. SsctbnSAZ Pages 103 and 104
TARGETS: HUMAN FOOD
CHAIN THREAT (cont.)
Secondary target fishery
• it is unlikely that hazardous substances
have reached the fishery
• Scored on the basis of flew rate
• Evaluated only if a primary target is not
identified
PA Guidance. S«ctor 3 4.2. PagM 103 and 104
PAGE 12
Preliminary Assessment Training
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY (cont.)
HUMAN FOOD CHAIN THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 12. LR =
Suspected
Release
(SSO)
No
Suspected
Release
(500.400 JOO or
100)
References
HUMAN FOOD CHAIN THREAT TARGETS
8.
Record the water body type, flow (if applicable) for each fishery within the target
distance limit. If there is no fishery within the target distance limit, assign a
Targets score of 0 at the bottom of the page.
Intake Name
Water Body Type Flow
cfs
cfc
People Served
efs
Cfs
Rfc
PRIMARY FISHERIES: If you suspect any fishery listed above has been exposed
to a hazardous substance from the site (see Surface Water Pathway Criteria List.
Page 11), assign a score of 300, and do not evaluate factor 10. List the primary
fisheries:
10 SECONDARY FISHERIES:
A. If you suspect a release to surface water and have identified a secondary
fishery, but no primary fishery, assign a score of 210.
B. If you do not suspect a release, assign a Secondary Fisheries score from the
table below using the lowest flow at any fishery within the target distance limit.
Lowest Flow
< 10 cfs
10 to 100 cfs
> 100 cfs. coastal
tidal waters, oceans
or Great Lakes
Secondary Fisheries Score
210
30
12
T =
Preliminary
PAGE 13
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SURFACE WATER PATHWAY
TARGETS:
ENVIRONMENTAL THREAT
Sensitive environment
• General definition, terrestrial or aquatic
resource, fragile natural setting, or other
area with unique or highly valued
environmental or cultural features
• Most common type of sensitive environment
is wetland
PA Guidance. Section 3.4.2, Pag** 92 and 93
TARGETS:
ENVIRONMENTAL THREAT (cont.)
Wetland
• General definition: an area that is
sufficiently inundated by surface water
or groundwater to support vegetation
adapted for life in saturated soil
conditions
PA Guidance. Section 3.4-2. Pages92 and 93
TARGETS:
ENVIRONMENTAL THREAT (cont)
• Identify all sensitive environments in or adjacent to
in-water segment
• PA Table 5 (Page A-31) lists sensitive
environment types and assigned values
• Measure wetland frontage along water body; see
PA Table 6 (Page A-31) for assigned score
• Identify primary targets using criteria list
Go to Appendix A, Table* 5 and 6.
Pago A-31 in PA Guidance Manual
PA Guidance. Section 342. Pages 92 and 93
PAGE 14
Preliminary Assessment Training
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY (cent)
ENVIRONMENTAL THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 12. LR =
Suspected
Release
<5W)
No
Suspected
Release
tsiu.4aa.3eo or
100)
References
ENVIRONMENTAL THREAT TARGETS
11. Record the water body type, flow (if applicable) for each surface water sensitive
environment within the target distance limit (see PA Tables 4 and 5). tf there are
no sensitive environments within the target distance limit, assign a Target score of
0 at the bottom of the page.
Environment Name
Water Body Type Flow
cfs
cfs
cfs
cfs
rfr
12. PRIMARY SENSITIVE ENVIRONMENTS: If you suspect any sensitive environ-
ment listed above has been exposed to a hazardous substance from the site
(see Surface Water Pathway Criteria List. Page 11). assign a score of 300. and do
not evaluate factor 13. List the primary sensitive environments:
13. SECONDARY SENSITIVE ENVIRONMENTS: If sensitive environments are
present but none is a primary sensitive environment, evaluate Secondary Sensitive
Environments based on flow.
A. For secondary sensitive environments on surface water bodies with flows of 100
cfs or less, assign scores as follows, and do not evaluate Part B of this factor.
Ftow
cfs
cfs
cfs
cfs
cfs
Dilution Weight
(PA Table 4)
X
X
X
X
X
Environment Type and Value
(PA Tattles 5 and 6)
S
S
—
S
S
Total
Sum ••
If all secondary sensitive environments are located on surface water bodies with
flows > 100 cfs assign a score of 10.
T =
(101
PAGE 15
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
WCx LR >:
WCx LR x
WC x LR x
82,500
SURFACE WATER
82.500 = PATHWAY THREAT
SCORES
82.500
• Evaluate drinking water, human food chain, and
environmental threats (subject to noted maximums)
• Sum scores for each threat to obtain overall pathway
score
PA Guidance, Section 3.4.2, P»ge 108
PAGE 16
Preliminary Assessment Training
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY CRITERIA LIST
This "Criteria List" helps guide the process of developing hypotheses concerning the occurrence of a
suspected release and the exposure of specific targets to a hazardous substance. The check-boxes
record your professional judgment in evaluating these factors. Answers to all of the listed questions
may not be available during the PA. Also, the list is not all-inclusive; if other criteria help shape your
hypotheses, list them at the bottom of the page or attach an additional page.
The "Suspected Release" section identifies several site, source, and pathway conditions that could
provide insight as to whether a release from the site is likely to have occurred. If a release is suspected,
use the "Primary Targets" section to evaluate conditions that may help identify targets likely to be
exposed to a hazardous substance. Record responses for the well that you feel has the highest
probability of being exposed to hazardous substance. You may use this section of the chart more than
once, depending on the number of targets you feel may be considered "primary."
Check the boxes to indicate a "yes," "no," or "unknown* answer to each question. If you check the
"Suspected Release" box as "yes," make sure you assign a Likelihood of Release value of 550 for the
pathway.
If the distance to surface water is greater than 2 miles, do not evaluate the surface water migration
pathway. Document the source of information in the text boxes below the surface water criteria list.
Preliminary Assessment Training
PAGE 17
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
nan
ODD
oan
nao
ana
DDD
DDD
nan
ana
nan
nan
ana
nan
aa
an
Is surface water nearby?
Is waste quantity particularly large?
Is the drainage area large?
Is rainfall heavy?
Is the infiltration rate low?
Are sources poorly contained or prone to
runoff or flooding
Is a runoff route well defined (e.g., ditch
or channel leading to surface water)?
Is vegetation stressed along the probable
runoff route?
Are sediments or water unnaturally
discolored?
Is wildlife unnaturally absent?
Has deposition of waste into surface water
been observed?
Is groundwater discharge to surface water
likely?
Does analytical or circumstantial evidence
suggest surface water contamination?
Other criteria?
SUSPECTED RELEASE?
Y N U
eon
s k
ana
ODD
ana
ana
an
an
an
DD
Is any drinking-water well nearby? If yes:
D Drinking-water intake
D Fishery
D Sensitive environment
Has any intake, fishery, or recreational
area been dosed?
Does analytical or circumstantial evidence
suggest surface water contamination at or
downstream of a target?
Does any target warrant sampling? If yes:
C] Drinking-water intake
D Fishery
D Sensitive environment
Other criteria?
PRIMARY INTAKE(S) IDENTIFIED?
PRIMARY FISHERYflES) IDENTIFIED?
PRIMARY SENSITIVE ENVIRONMENT(S)
IDENTIFIED?
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
PAGE 18
'reliminary Assessment Training
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY LIKELIHOOD OF RELEASE
AND DRINKING-WATER THREAT SCORE SHEET
Pathway Characteristics
The surface water pathway includes three threats: Drinking-water Threat, Human Food Chain Threat, and
Environmental Threat, Answer the questions at the top of the page. Refer to the Surface Water Pathway Criteria
List (Page 11*) to hypothesize whether you suspect that a hazardous substance associated with the site has been
released to surface water. Record the distance to surface water (the shortest overland drainage distance from a
source to a surface water body). Record the flood frequency at the site (e.g., 100-yr, 200-yr). If the sfte is located
in more than one floodplain, use the most frequent flooding event. Identify surface water use(s) along the surface
water migration path and their distances) from the site.
Likelihood of Release (LR)
1. Suspected Release: Hypothesize based on professional judgment guided by the Surface Water Pathway
Criteria List (Page 11). If you suspect a release to surface water, use only Column A for this pathway, and no not
evaluate factor 2.
2. No Suspected Release: If you do not suspect a release, determine score based on the shortest overland
drainag distance from a source to a surface water body. If distance to surface water is 2,500 ft or less, assign a
score of 500. If distance to surface water is greater than 2500 ft, determine score based on flood frequency. If you
do not suspect a release to surface water, use only Column B to score this pathway.
Drinking-water Threat Targets (T)
3. List all drinking-water intakes on downstream surface water bodies along the surface water migration path.
Record the intake name, the type of water body on which the intake is located, the flow of the water body, and the
number of people served by the intake (apportion the population if part of a blended system).
4. Primary Target Population: Evaluate populations served by all drinking-water intakes that you suspect have
been exposed to a hazardous substance released from the site. Use professional judgment guided by the Surface
Water Pathway Criteria List (Page 11) to make this determination. In the space provided, enter the population
served by all intakes you suspect have been exposed to a hazardous substance from the site, tf only the number of
residences is known use the average county residents per household (rounded up to the next integer) to determine
population served. Multiply the population by 10 to determine the Primary Target Population score Note that if you
do not suspect a release, there can be no primary target population.
5. Secondary Target Population: Evaluate populations served by all drinking-water intakes within target distance
limit that you do not suspect have been exposed to a hazardous substance. Use PA Table 3 (Page 13) and enter
the population served by intakes for each flow category. If only the number of residences is known, use the average
county residents per household (rounded to the nearest integer) to determine population served. Circle the assigned
value for the population in each flow category and enter it in the column on the far-right side of the table. Sum the
far-right column and enter the total as the Secondary Target Population factor score.
Gauging station data for many surface water bodies are available from USGS or other sources. In the absence of
gauging station data, estimate flow using the fist of surface water body types and associated flow categories in PA
Table 4 (Page 13). The flow for lakes is determined by the sum of flows of streams entering or leaving the take.
Note that the flow category "mixing zone of quiet flowing rivers" is limited to 3 mites from the probable point of entry.
6. Nearest Intake represents the threat posed to the drinking-water intake that is most likely to be exposed to a
hazardous substance. If you have identified a primary target population, enter 50. Otherwise, assign the score from
PA Table 3 (Page 13) for the lowest-flowing water body on which there is an intake.
7. Resources: A score of 5 can generally be assigned as a default measure. Assign zero only if surface water
within the target distance limit has no resource use.
Sum the target scores in Column A (Suspected Release) or Column B (No Suspected Release).
*Pages noted here pertain to those in the PA Guidance Manual.
Pfeltminar
PAGE 19
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SURFACE WATER PATHWAY
SURFACE WATER PATHWAY SCORE SHEET
LIKELIHOOD OF RELEASE AND DRINKING-WATER-THREAT SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Surface Water Pathway Criteria List, page 11.} Yes_
Distance to surface water?
Flood frequency:
What is the downstream distance to the nearest drinking-water intake? miles.
Nearest fishery? miles. Nearest sensitive environment? miles.
No
B
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to surface water (See
pagell). assign a score of 550. Use only Column A for this pathway.
2.
NO SUSPECTED RELEASE: If you do not suspect a release to surface water,
use the table below to assign a score based on distance to surface water and
flood frequency. Use only Column B for this pathway.
Distance to surface water £ 2,500 ft
Distance to surface water > 2,500 ft, and
Site in annual or 10-yr floodplain
Site in 100-yr floodplain
Site in 500-yr floodplain
Site outside 500-yr floodplain
500
500
400
300
100
DRINKING-WATER THREAT TARGETS
3.
Record the water body type, flow (if applicable) and number of people served by
each drinking-water intake within the target distance limit. If there is no drinking-
water intake within the target distance limit, factors 4, 5. and 6 each receive zero
scores.
Intake Name
Water Body Type Flow
People Served
cfc
cfs
efe
PRIMARY TARGET POPULATION: If you suspect any drinking-water intake listed
above has been exposed to a hazardous substance from the site (see Surface
Water Pathway Criteria List, page 11), list the intake name(s) and calculate the
factor score based on the total population served.
people x 10 =
5.
SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water Makes thai you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 3.
Are any intakes part of a blended system? Yes No
If yes, attach a page to show apportionment caculattons.
NEAREST INTAKE: If you have identified a primary target population for the
drinking-water threat (factor 4), assign a score of 50; otherwise, assign the
Nearest Intake score from PA Table 3. If no drinking-water intake exists within the
target distance limit, assign a score of zero.
7. RESOURCES
6
(SO.20.10.Z1 orO)
O0.10J.I orO)
(5 Of 0|
T =
PAGE 20
Preliminary Assessment Training
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PA TABLE 3: VALUES FOR SECONDARY SURFACE WATER TARGET POPULATIONS
Surface Water
Body Flow
(see PA Table 4)
<10 cfs
10to100cfs
> K» to 1,000 Cfs
• 1.000 to 1 0,000 cfa
> 10,000 cfs or
Great Lake
3-Mile Mixing Zone
Population
Nearest Intake =
Nearest
Intake
(choose
highest)
20
2
1
0
0
10
Population Served by Intakes Within Distance Category
1
to
30
2
1
0
0
0
1
31
to
100
5
1
0
0
0
3
101
to
300
16
2
1
0
0
8
301
to
1.000
52
5
1
0
0
26
1,001
to
3.000
163
16
2
1
0
82
3.001
to
10.000
521
52
5
1
0
261
10,001
to
30.000
1,633
163
16
2
1
816
30,001
to
1 00.000
5,214
521
52
5
1
2,607
100,001
to
300,000
16,325
1.633
163
16
2
8,162
300,001
to
1 .000.000
52,136
5.214
521
52
5
26.068
Greater
than
1 .000.000
163,246
16,325
1,633
163
16
61,663
Score =
Population
Value
PA TABLE 4: SURFACE WATER TYPE/FLOW CHARACTERISTICS
Type of Surface Water
Water Body Type OR
minimal stream
small to moderate stream
moderate to large stream
large stream to river
large river
3-mile mixing zone of quiet
flowing streams or rivers
coastal tidal water (harbors,
sounds, bays, etc.), ocean or
Great Lakes
Body
Flow
<10cfs
10 to 100 cfs
> 100 to 1,000 cfs
> 1.000 to 10,000 cfs
>1 0,000 cfs
10 Cfs or greater
N/A
Dilution
1
0.1
N/A
N/A
N/A
N/A
I
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
HUMAN FOOD CHAIN THREAT SCORE SHEET
Likelihood of Release (LR)
LR is the same for all surface water pathway threats. Enter LR score from Page 12*. LR is the same for all surface
water pathway threats. Enter LR score from Page 12.
Human Food Chain Threat Targets (T)
8. The only human food chain targets are fisheries. A fishery is an area of a surface water body from which food
chain organisms are taken or could be taken for human consumption on a subsistence, sporting, or commercial
basis. Food chain organisms include fish, shellfish, crustaceans, amphibians, and amphibious reptiles. Fisheries
are delineated by changes in surface water body type (i.e., streams and rivers, lakes, coastal tidal waters and
oceans/Great Lakes), and whenever the flow characteristics of a stream or river change.
In the space provided, identify at) fisheries within the target distance limit Indicate the surface water body type and
flow for each fishery. Gauging station flow data are available for many surface water bodies from USGS or other
sources. In the absence of gauging station data, estimate flow using the list of surface water body types and
associated flow categories in PA Table 4 (Page 13). The flow for lakes is determined by the sum of flows of streams
entenng or leaving the lake. Note that, if there are no fisheries within the target distance limit, the Human Food
Chain Threat Targets score is zero.
9. Primary fisheries are any fisheries within the target distance limit that you suspect have been exposed to a
hazardous substance released from the site. Use professional judgment guided by the Surface Water Pathway
Criteria List (Page 11) to make this determination. If you identify any primary fisheries, list them in the space
provided, enter 300 as the Primary Fisheries factor score, and do not evaluate Secondary Fisheries. Note that if
you do not suspect a release, there can be no primary fisheries.
10. Secondary fisheries are fisheries that you do not suspect have been exposed to a hazardous substance.
Evaluate this factor only if fisheries are present within the target distance limit, but none is considered a primary
fishery.
A. If you suspect a release to surface water and have identified a secondary fishery but no primary fishery,
assign a score of 210.
B. If you do not suspect a release, evaluate this (actor based on flow. In the absence of gauging station flow
data, estimate flow using the list of surface water body types and associated flow categories in PA Table 4
(Page 13). Assign a Secondary Fisheries score from the table on the score sheet using the lowest flow at
any fishery within the target distance limit (Dilution weight multiplier does not apply to PA evaluation of this
factor.)
Sum the target scores in Column A (Suspected Release) or Column B (No Suspected Release).
"'Pages noted here pertain to those in the PA Guidance Manual.
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY (cont)
HUMAN FOOD CHAIN THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 12. LR =
Suspected
Release
(00)
No
Suspected
Release
(SOMOOJOOv
too)
References
HUMAN FOOD CHAIN THREAT TARGETS
6.
Record the water body type, flow (if applicable) for each fishery within the target
distance limit. If there is no fishery within the target distance limit, assign a
Targets score of 0 at the bottom of the page.
Fishery Name
Water Body Type Flow
pf«
cfe
cfs
cfs
PRIMARY FISHERIES: If you suspect any fishery listed above has been exposed
to a hazardous substance from the site (see Surface Water Pathway Criteria List,
Page 11), assign a score of 300, and do not evaluate Factor 10. List the primary
fisheries:
10. SECONDARY FISHERIES:
A. tf you suspect a release to surface water and have identified a secondary
fishery, but no primary fishery, assign a score of 210.
B. If you do not suspect a release, assign a Secondary Fisheries score from the
table below using the lowest flow at any fishery within the target distance limit
Lowest Flow
< 10 cfs
10 to 100 cfs
> 100 cfs, coastal
tidal waters, oceans
or Great Lakes
Secondary Fisheries Score
210
30
12
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
ENVIRONMENTAL THREAT SCORE SHEET
Likelihood of Release (LR1
LR is the same for all surface water pathway threats. Enter LR score from Page 12*.
Environmental Threat Targets fT)
11. PA Table 5 (Page 16) lists sensitive environments for the Surface Water Pathway Environmental Threat In the
space provided, identify all sensitive environments located within the target distance limit Indicate the surface water
body type and flow at each sensitive environment Gauging station flow data for many surface water bodies are
available from USGS or other sources. In the absence of gauging station data, estimate flow using the list of surface
water body types and associated flow categories in PA Table 4 (Page 13). The flow for lakes is determined by the
sum of flows of streams entering or leaving the take. Note that if there are no sensitive environments within the
target distance limit, the Environmental Threat Targets score is zero.
12. Primary sensitive environments are surface water sensitive environments within the target distance limit that you
suspect have been exposed to a hazardous substance released from the site. Use professional judgment guided by
the Surface Water Pathway Criteria List (Page 11) to make this determination. If you identify any primary sensitive
environments, list them in the space provided, enter 300 as the Primary Sensitive Environments factor score, and do
not evaluate Secondary Sensitive Environments. Note that if you do not suspect a release, there can be no primary
sensitive environments.
13. Secondary sensitive environments are surface water sensitive environments that you do not suspect have been
exposed to a hazardous substance. Evaluate this factor only if surface water sensitive environments are present
within the target distance limit, but none is considered a primary sensitive environment. Evaluate secondary
sensitive environments based on flow.
• In the table provided, list ail secondary sensitive environments on surface water bodies with flow of 100 cfs or
less.
1) Use PA Table 4 (Page 13) to determine the appropriate dilution weight to each.
2) Use PA Tables 5 and 6 (Page 16) to determine the appropriate value for each sensitive environment type
and for wetlands frontage.
3) For a sensitive environment that falls into more than one of the categories in PA Table 5, sum the values for
each type to determine the environment value; e.g., a wetland with 1.5 miles frontage (value of 50) that is
also a critical habitat for a Federally designated endangered species (value of 100) would receive a total
value of 150).
4) For each sensitive environment, multiply the dilution weight by the environment type (or length of wetlands)
value, and record the product in the far-right column.
5) Sum the values in the far-right column, and enter the total as the Secondary Sensitive Environments score.
Do not evaluate Part B of this factor.
• If all secondary sensitive environments are on surface water bodies with flows greater than 100 cfs, assign 10
as the Secondary Sensitive Environments score.
Sum the target scores in Column A (Suspected Release) or Column B (No Suspected Release).
*Pages noted here pertain to those in the PA Guidance Manual.
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY (cont.)
ENVIRONMENTAL THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 12. LR =
Suspected
Release
toot
No
Suspected
Release
(S00.400.300v
100)
References
ENVIRONMENTAL THREAT TARGETS
11. Record the water body type, flow (if applicable) for each surface water sensitive
environment within the target distance limit (see PA Tables 4 and 5). If there are
no sensitive environments within the target distance limit, assign a Target score of
0 at the bottom of the page.
Environment Name
Water Body Type
Flow
12. PRIMARY SENSITIVE ENVIRONMENTS: If you suspect any sensitive environ-
ment listed above has been exposed to a hazardous substance from the site
(see Surface Water Pathway Criteria List, Page 11), assign a score of 300, and do
not evaluate factor 13. List the primary sensitive environments:
13. SECONDARY SENSITIVE ENVIRONMENTS: If sensitive environments are
present but none is a primary sensitive environment, evaluate Secondary Sensitive
Environments based on flow.
a. For secondary sensitive environments on surface water bodies with flows of 100cfs
or less, assign scores as follows, and do not evaluate Part B of this factor.
Flow
cfs
cfs
cfs
cfs
cfs
Dilution Weight
(PA Table 4)
X
X
X
X
X
EnvironmentType and Value
(PA Tables 5 and 6)
*
2
Z
m
=
Total
Sum =
b If all secondary sensitive environments are located on surface water bodies with
flows > 100 cfs assign a score of 10
(tO)
(10)
T =
Prelimman
PAGE 25
-------
SURFACE WATER PATHWAY
PA TABLE 5: SURFACE WATER AND AIR PATHWAY
SENSITIVE ENVIRONMENTS VALUES
Sensitive 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 Wifdemess Act
Sensitive Areas identified under the National Estuary Program or 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 takes)
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 Wikttfe 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
75
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 miles
Greater than 2 to 3 miles
Greater than 3 to 4 miles
Greater than 4 to 6 miles
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 26
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY
WASTE CHARACTERISTICS, THREAT, AND PATHWAY SCORES
Waste Characteristics (WC)
14. Waste Characteristics: Score is assigned from Page 4. However, if a primary target has been identified for any
surface water threat, assign either the score calculated on Page 4 or a score of 32, whichever is greater.
Surface Water Pathway Threat Scores
Fill in the matrix with the appropriate scores from the previous pages. To calculate the score for each threat
multiply the scores for LR, T, and WC; divide the product by 82,500 and round the result to the nearest integer. The
Drinking-water Threat and Human Food Chain Threat are each subject to a maximum of 100. The Environmental
Threat is subject to a maximum of 60. Enter the rounded threat scores in the far-right column.
Surface Water Pathway Score
Sum the individual threat scores to determine the Surface Water Pathway Score. If the sum is greater than 100,
assign 100.
sment Training
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY (concluded)
WASTE CHARACTERISTICS, THREAT, AND PATHWAY SCORE SUMMARY
WASTE CHARACTERISTICS
14. A. If you have identified any primary target for surface water (Pages 12, 14, or
15), assign the waste characteristics score calculated on Page 4 or score of
32, whichever is GREATER. Do not evaluate Part B of this factor.
B. tf you have NOT identified any primary target for surface water, assign the
waste characteristics score calculated on Page 4.
WC<
SURFACE WATER PATHWAY THREAT SCORES
Threat
Drinking water
Human Food
Chain
Environmental
Likelihood of
Release (LR) Score
(from Page 12)
Target (T) Score
(Pages 12. 14. 15)
Pathway Waste
Characteristics (WC) Score
(determined above)
SURFACE WATER PATHWAY SCORE
(Drinking Water Threat + Human Food Chain Threat
+ Environmental Threat)
Threat Score
LRxTxWC
/ 82,500
(Si*fMt to • Mmuh at tOO)
(&*^d lo » IMJBPUB « 100)
(Strict to * ntvfcnuR e( 80}
(S<*t«ct to > radnun of 100)
PAGE 28
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
CASE STUDY: ABC VACUUM SERVICE
SURFACE WATER PATHWAY
OBJECTIVE
Using the background information form file searches, site reconnaissance notes, and
maps complete the "Surface Water Pathway" portion of the PA score sheets.
METHOD
1. Review the general surface water pathway information summary provided and
the map included with this exercise.
2. Read the instructions for the "Surface Water Pathway Criteria List" and
complete the "Suspected Release" and "Primary Targets" evaluations.
Determine whether you hypothesize a suspected release, and identify whether
there are any primary targets. Summarize the rationale for these decisions in
the space provided.
3. Using the existing site information and the score sheet instructions, complete all
the portions of the "Surface Water Pathway Score Sheet." Use PA Table 3,
'Values for Secondary Surface Water Target Populations" and PA Table 4,
"Surface Water Type/Flow Characteristics With Dilution Weights for Secondary
Surface Water Sensitive Environments" to determine population values for
secondary targets, if possible. Remember to evaluate the nearest intake factor.
4. Calculate and record the Surface Water Pathway score.
SURFACE WATER PATHWAY DATA
• Runoff is channeled into intermittent ditches along the perimeter of the facility.
• These drainage ditches flow 6,000 ft (1.1 miles) into the perennial ditch.
• The perennial ditch reaches the bayou 3 miles FROM THE PPE.
• The distance between the bayou and the river is 10 miles.
• Estimated flow rates:
- Bayou = 15 cu ft per second (cfs)
- River = 75 cfs
• Both the bayou and the river are used for fishing and swimming. The bayou
contains wetlands.
• There are no surface water intakes within the 15-mile target distance limit.
Preliminary Assessment
PAGE 29
-------
SURFACE WATER PATHWAY
SURFACE WATER PATHWAY DATA (cont.)
• The following sensitive environments are present:
- A critical habitat for federally designated endangered species is located 14 miles
downriver from the PPE
- A 5-acre wetland is located downriver from the site
- The wetland frontage equals 0.4 miles
• The site lies within the 500-year flood plain.
• The drainage basin covers about 165 acres around the site.
PAGE 30
Preliminary Assessment Training
-------
SURFACE WATER PATHWAY
ABC Vacuum
Service
Surface Water Map
(not to scale)
Endangered
Species
Habitat
y*_w_«
River
Wetland
15-Mile Target
Distance Limit
-------
-------
SECTION SIX
SOIL EXPOSURE
PATHWAY
Fence
Contaminated
Soil
Breach
in Fence
8
200 Feet
i
XYZ Corporation
Contaminated
Soil
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY
• People or other targets coming into direct
contact with hazardous substances
• Contaminated soil and accessible site
wastes are evaluated
• Not limited to soils; can include gravel,
waste piles, contaminated flooring,
asphalt, and concrete
PA Guidance. Section 351
SITE ASSESSMENT QUESTIONS 2
AND 3 FOR SOIL EXPOSURE
2. Is there suspected contamination?
3. Do people live, go to school, or work
on or within 200 ft of suspected
contamination? Are there terrestrial
sensitive environments on suspected
contaminated soil?
PA Guidanc*. Section 3.5.2, Pagtt I12andt1«
SOIL EXPOSURE
PATHWAY EVALUATION
PAGE 2
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
LIKELIHOOD OF EXPOSURE
AND TARGETS
I
Fence
Contaminated
Soil
Breach
in Fence
200 Feet
XYZ Corporation
Contaminated
Soil
LIKELIHOOD OF EXPOSURE
• For most PA's, assume suspected surface
contamination
• Need appropriate reliable analytical data to
assume no suspected contamination
• Score 550 for suspected contamination and
score 0 for no suspected contamination
• Determine area(s) of suspected contamination
• Consider mechanisms to transport
contaminants to nearby properties (vehicles,
flooding, wind blown)
PA Guidance. Section 35.1. Pages 110 and 111
LIKELIHOOD OF EXPOSURE:
SUSPECTED CONTAMINATION
Definition:
Areas known or suspected to contain
hazardous substances not covered by an
essentially impenetrable cover or more than 2 ft
of dean cover material.
(Not limited to soils-any accessible surface
source is considered. Evaluate broken
asphalt/concrete and sources inside a building
if not secure.)
PA Guidance, Section 351.
Prelimmar
-------
SOIL EXPOSURE PATHWAY
LIKELIHOOD OF EXPOSURE:
WHAT IS AREA OF SUSPECTED
CONTAMINATION?
Asphalt Paving
PA Guidance. Section 35.1
LIKELIHOOD OF EXPOSURE
Evaluate all sources except:
• Sources covered by at least 2 ft of dean
material or impenetrable cover
• Sources not accessible by direct contact
• Example:
- Wastes secured inside a building
- Ground water plume with no identifiable
source
PA Gudance. Section 35.1
SOIL EXPOSURE TARGETS
Resident population threat
• Residents and students
• Workers
• Terrestrial sensitive environments
• Resources
(Corresponds to "primary targets"
assessment for other pathways.)
PA Guidance. Section 3.52
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE TARGETS (cont.)
Nearby population threat
• Residents within 1-mile radius of
contamination
PA Guidance. Section 3.52
SOIL EXPOSURE TARGETS:
RESIDENT POPULATION THREAT TARGET
EVALUATION
Resident population factor is defined as:
• Person who resides on or within 200 ft of area of
suspected contamination (not the property
boundary)
• Person who attends school or daycare on or within
200 ft of area of suspected contamination
Resident population factor is identified using the Soil
Exposure Pathway Criteris List
Go to Appendix A Soil Exposure Pathway Criteria List.
Page A-35 in the PA Guidance Manual
PA Guidance. Section 352
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY CRITERIA LIST
SUSPECTED CONTAMINATION
RESIDENT POPULATION
Surficial contamination can generally be assumed.
Y N U
eon
s k
nnn
DDD
nna
ODD
DDD
an
an
Is any residence, school, or daycare facility
on or within 200 feet of an area of sus-
pected contamination?
Is any residence, school, or daycare facility
located on adjacent land previously owned
or leased by the site owner/operator?
Is there a migration route that might spread
hazardous substances near residences,
schools, or daycare facilities?
Have on-site or adjacent residents or
students reported adverse health effects,
exclusive of apparent drinking water or air
contamination problems?
Does any neighboring property warrant
sampling?
Other criteria?.
RESIDENT POPULATION IDENTIFIED?
Summarize the rationale for Resident Population (attach an additional page if necessary):
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE TARGETS:
RESIDENT POULATION THREAT
150R <
I <^ Contaminated Soil >
SOIL EXPOSURE TARGETS
Res
• V
P
• T
a
• R
PAG
tident population threat also includes:
Yorkers on facility property or nearby
roperty
errestrial sensitive environments on. the
rea of suspected contamination
esources
Go to Appendix A. Table 7. Sol Exposure Pathway
Terrestrial Sensitive Environment Values.
Page A-39 in the PA Giidance Manual
uktance. Section 3.5.2
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
PA TABLE 7: SOIL EXPOSURE PATHWAY
TERRESTRIAL SENSITIVE ENVIRONMENTS VALUES
Terrestrial Sensitive Environment
Assigned Value
Terrestrial critical habitat for Federally designated threatened or endangered species
National Park
Designated Federal Wilderness Area
National Monument
100
Terrestrial habitat known to be used by Federally designated or proposed threatened or endangered species
National Preserve (terrestrial)
National or State Terrestrial Wildlife Refuge
Federal land designated to the protection of natural ecosystems
Administratively Proposed Federal Wilderness Area
Terrestrial areas utilized by large or dense aggregations of animals (vertebrate species) for breeding
75
Terrestrial habitat known to be used by State designated endangered or threatened species
Terrestrial habitat known to be used by a species under review as to its Federal endangered or threatened status
SO
State land designated for wildlife or game management
State designated Natural Areas
Particular areas, relatively small in size, important to maintenance of unique biotic communities
25
PAGE 8
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE TARGETS
Nearby population threat
• Population that does not qualify as resident
population but may come in contact with areas of
contamination
• Located within a 1-mile radius of site
Population Within
1 Mile
<10,000
10,000 - 50.000
> 50.000
Nearby Population
Threat Score
1
2
4
PA Gudance, Section 3.S.4
RESIDENT POPULATION
THREAT SCORE
LE x T x WC
82,500
Threat
Note: T does not indude nearby population
threat score, it is added to the above
calculated value.
PA Guidance. Section 35.4
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY SCORE SHEET
Ut
PATHWAY CHARACTERISTICS
Do any people live on or within 200 ft of areas of suspected contamination?
Do any people attend school or daycare on or within 200 ft of areas of
suspected contamination?
Is the facility active? Yes N1.0OO 15
> umber of people occupying n
00 ft of areas of suspected c
( PifQe 1P) pft
ied a resident population (Fac
ore of 0.
in a score based on the total
nth suspected contamination:
ssidences
ontamina-
ople x 10 =
;tor 2),
number of
TERRESTRIAL SENSITIVE ENVIRONMENTS: Use PA Table 7 to assign a value foi
each terrestrial sensitive environment on an area of suspected contamination:
TarmsH*/ SansttmEnviennMnf T/pe
RESOURCES
VW»
Sum *
T =
(50<*0)
(15.10.5 or 0»
(So.0)
WASTE CHARACTERISTICS
7. Assign the waste characteristics score calculated on Page 4. VVC =
LE x T x WC
o^.&oo
(100. 32 or 1»)
(•MM* <« « •»*•«. ol 1001
NEARBY POPULATION THREAT SCORE:
SOIL EXPOSURE PATHWAY SCORE:
Resident Population Threat + Nearby Population Threat
(«i«r'l
CO*
*d to • m*m*im of 100)
PAGE 10
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
CASE STUDY: ABC VACUUM SERVICE
SOIL EXPOSURE PATHWAY
OBJECTIVE
Using the background information form file searches, site reconnaissance notes, and
maps, complete the "Soil Exposure" portion of the PA score sheets.
METHOD
1. Review the general soil exposure pathway information summary provided,
existing source information, and the map included with this exercise.
2. Read the instructions for the "Soil Exposure Population" evaluation.
Determine whether you can identify a resident population. Summarize the
rationale for these decisions in the space provided.
3. Using the existing site information and the score sheet instructions, complete all
the portions of the "Soil Exposure Pathway" score sheet. Use PA Table 7,
'Values for Secondary Surface Water Target Populations" and PA Table 4,
"Soil Exposure Pathway Terrestrial Sensitive Environment Values," to determine
values for terrestrial sensitive environments, if applicable. Remember to
evaluate the resident individual factor.
4. Calculate and record the Soil Exposure Pathway score.
SOIL EXPOSURE PATHWAY DATA
• Nineteen residents live within 200 ft of the site.
• No schools or day care facilities are within 200 ft of the site.
• The site is inactive; therefore, no workers are present on-site.
• Ten people are employed at the crayfish ponds.
• One report indicated that the warehouse complex employed 65 people.
Preliminary Assessment Training
PAGE 11
-------
ABC VACUUM SERVICE
Stained Soil '
titrt-rnitttm-ttti-rtrm-htii-
Culvert
.££» Drainage Ditch
Drainage Direction
Standing
ainwater
| [ | } [' Railroad Track
Not to Scale
Shed on
top of
mixing tanks
Metal Structure
Warehouse Complex Road
-------
SOIL EXPOSURE PATHWAY
ABC Vacuum Service
Topographic
Contours
Residential
Area
Preliminary
PAGE 13
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY CRITERIA LIST
Areas of surficial contamination can generally be assumed. This "Criteria List" helps guide the process of
developing a hypothesis concerning the exposure of specific targets to a hazardous substance at the
site. Use the "Resident Population" section to evaluate site and source conditions that may help identify
targets likely to be exposed to a hazardous substance. The check boxes record your professional
judgment. Answers to all of the listed questions may not be available during the PA. Also, the list is not
all-inclusive. If other criteria help shape your hypothesis, list them at the bottom of the page or attach an
additional page.
Check the boxes to indicate a "yes," "no," or "unknown" answer to each question.
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY CRITERIA LIST
SUSPECTED CONTAMINATION
RESIDENT POPULATION
Surflcial contamination can generally be assumed.
Y N U
eon
s k
DDD
ODD
ana
ODD
nan
an
an
Is any residence, school, or daycare facility
on or within 200 feet of an area of sus-
pected contamination?
Is any residence, school, or daycare facility
located on adjacent land previously owned
or leased by the site owner/operator?
Is there a migration route that might spread
hazardous substances near residences,
schools, or daycare facilities?
Have on-site or adjacent residents or
students reported adverse health effects,
exclusive of apparent drinking water or air
contamination problems?
Does any neighboring property warrant
sampling?
Other criteria?
RESIDENT POPULATION IDENTIFIED?
Summarize the rationale for Resident Population (attach an additional page if necessary):
Preliminary Assessment Training
PAGE 15
-------
SOIL EXPOSURE PATHWAY
SOIL EXF'OSURE PATHWAY SCORE SHEET
Pathway Characteristics
Answer the questions at the top of the page. Identify people who may be exposed to a hazardous substance
because they work at the facility, or reside or attend school or daycare on or within 200 feet of an area of suspected
contamination, if the site is active, estimate the number of full and part-time workers. Note that evaluation of target
is based on current site conditions.
Likelihood of Exposure O.E)
1. Suspected Contamination: Areas of surficial contamination are present at most sites, and a score of 550 can
generally be assigned as a default measure. Assign zero, which effectively eliminates the pathway from further
consideration, only if there is no surficial contamination; reliable analytical data are generally necessary to make this
determination.
Resident Population Threat Targets (T)
2. Resident Population corresponds to "primary targets" for trie migration pathways. Use professional judgment,
guided by the Soil Exposure Pathway Criteria List (Page 18), to determine if there are people living or attending
school or daycare on or wrthin 200 feet of areas of suspected contamination. Record the number of people identified
as resident population, and multiply by 10 to determine the Resident Population factor score.
3. Resident Individuals: Assign 50 if you have identified a resident population; otherwise, assign zero.
4. Workers: Estimate the number of full and part-time workers at this facility and adjacent facilities where contami-
nation is ateo suspected. Assign a score for the Workers factor from the table.
5. Terrestrial Sensitive environments: In the table provided, list each terrestrial sensitive environment located on
an area of suspected contamination. Use PA Table 7 (Page 20) to assign a value for each. Sum the values and
assign the total as the factor score.
6. Resources: A score of 5 can generaly be assigned as a default measure. Assign zero only rf there is no land
resource use on an area of suspected contamination.
Sum the target score.
Waste Characteristics fWC)
7. Enter the WC score determined on Page 4.
Resident Population Threat Score: Multiply the scores for LE. T, and WC, Divide the product by 82,500. Round the
result to the nearest integer. If the result is greater than 100, assign 100.
Nearby Population Threat Scorer: Do not evaluate this threat if you gave a zero score to Likelihood of Exposure.
Otherwise, assign a score based on the population within a 1-mile radius (use the same 1-mile radius population you
evaluate for air pathway population targets):
Population Within One Mite Nearby Population Threat Score
<10,000 1
10,000 to 50.000 2
>SO.OOO 4
SoD Exposure Pathway Score:
subject to a maximum of 100.
Sum the Resident Population Threat score and the Nearby Population Threat score.
PAGE 16
Preliminary Assessment Training
-------
SOIL EXPOSURE PATHWAY
SOIL EXPOSURE PATHWAY SCORE SHEET
Lit
PATHWAY CHARACTERISTICS
Do any people live on or within 200 ft of areas of suspected contamination?
Do any people attend school or daycare on or within 200 ft of areas of
suspected contamination?
Is the facility active? Yes No. If yes, estimate the number of workers;
KEUHOOD OF EXPOSURE
1. SUSPECTED CONTAMINATION: Surficial contamination can generally be
assumed and a score of 550 assigned. Assign zero only in the absence of
surticial contamination (see Soil Exposure Pathway Criteria List, Page 18). i p _
Yes No
Yes No
Suspected
Contamination
(550 or 0}
References
RESIDENT POPULATION THREAT TARGETS
2.
3.
4.
5.
6.
RESIDENT POPULATION: Determine the r
or attending school or daycare on or within 2
tion (see Soil Exposure Pathway Criteria Lis
RESIDENT INDIVIDUAL: If you have idenfi
assign a score of 50; otherwise, assign a sc
WORKERS: Use the following table to assic
workers at the facility and nearby facilities w
NumttrofWaim Scan
0 0
1 to 100 5
101 to 1.000 10
>1,000 15
lumber of people occupying residences
00 ft of areas of suspected contamma-
t Pag* 1S) p»opl* y 10 =
Red a resident population (Factor 2).
ore of 0.
jn a score based on the total number of
nth suspected contamination:
TERRESTRIAL SENSITIVE ENVIRONMENTS: Use PA Table 7 to assign a value foi
each terrestrial sensitive environment on an area of suspected contamination:
Tamfrw/ Swufrv* Emirennwrt Type
RESOURCES
WASTE CHARACTERISTICS
7.
Vttue
Sum =
T =
Assign the waste characteristics score calculated on Page 4. VVC =
RESIDENT POPULATION THREAT SCORE
NEARBY POPULATION THREAT SCORE.
LE x T x WC
82,500
SOIL EXPOSURE PATHWAY SCORE:
Resident Population Threat * Nearby Population Threat
(SOorO)
{15.10.5 or 0»
(SwO)
(too. 12 at l»>
(iillHel to t mattart of 100)
(4.2 or 1)
(>i«Ncl to • nuamuni «f 100)
Preliminary Assessment Training PAGE 17
-------
SOIL EXPOSURE PATHWAY
PA TABLE 7: SOIL EXPOSURE PATHWAY
TERRESTRIAL SENSITIVE ENVIRONMENTS VALUES
Terrestrial Sensitive Environment
Terrestrial critical habitat for Federally designated threatened or endangered
National Park
Designated Federal Wilderness Area
National Monument
Assigned Value
species
Terrestrial habitat known to be used by Federally designated or proposed threatened or endangered species
National Preserve (terrestrial)
National or State Terrestrial Wildlife Refuge
Federal land designated to the protection of natural ecosystems
Administratively Proposed Federal Wilderness Area
Terrestrial areas utilized by large or dense aggregations of animals (vertebrate species) for breeding
Terrestrial habitat known to be used by State designated endangered or threatened species
Terrestrial habitat known to be used by a species under review as to its Federal endangered or threatened status
State land designated for wildlife or game management
State designated Natural Areas
Particular areas, relatively small in size, important to maintenance of unique
biotic communities
100
75
50
25
PAGE 18
Preliminary Assessment Training
-------
SECTION SEVEN
AIR PATHWAY
Potential sources
of a release to air
FIRE
Bum operation
(odore, gases,
participates)
Contaminants may
sctfle on buildings or
sette 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 PILE
LAGOON May release
vapors/gases that are
detected by nearby
residents/workers
CONTAMINATED
SOILS
-------
AIR PATHWAY
AIR PATHWAY EVALUATION
Human
PA Guidance. Sectbn 3.6
SITE ASSESSMENT QUESTIONS
2 AND 3 FOR AIR
2. What is the likelihood that hazardous
substances are being released to air
and can be detected through monitoring
and/or sampling?
3. Who and what are likely to be affected?
PA Guidance. Section 361 and 36.2
LIKELIHOOD OF RELEASE
• Evaluated differently than other migration
pathways
• Based on likelihood of detecting airborne
hazardous substances during SI monitoring
and/or sampling
• Scored on "suspected release" or "no
suspected release"
• Determined using the Criteria List for
Suspected Release to Air pathway
(Appendix A. Page A-41 in PA Guidance
Manual)
PA Guidance. Sector) 3.6 1
PAGE 2
Preliminary
-------
AIR PATHWAY
AIR PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
nnn
nnn
nnn
nnn
nn
nn
Are odors currently reported?
Has release of a hazardous substance to
the air been directly observed?
Are there reports of adverse health effects
(e.g , headaches, nausea, dizziness)
potentially resulting from migration of
hazardous substances through the air?
Does analytical or circumstantial evidence
suggest a release to the air?
Other criteria?
If you suspect a release to air, evaluate all populations
and sensitive environments within 1/4 mile (including
those onsite) as primary targets.
SUSPECTED RELEASE?
Summarize the rationale for Suspected Release (attach an additional page if necessary):
Preliminary Assessment Training
PAGE 3
-------
AIR PATHWAY
AIR TARGETS
• People living, going to school, or
working within 4 miles of sources
• Sensitive environments (terrestrial and
aquatic) within % mile
• Resources
PA Guidance. Section 362
AIR TARGETS
4
PA Guinea. Stcton 3.6.2
Target
Distance Categories
(No! to scab)
HUMAN POPULATION TARGETS
Resident populations
• Identify population on-site and in each of
the six distance categories
• Can use databases or house counts
depending on distance from site
Worker and student populations
• Identify those within V4 mile of site
• Use readily available information
PA Guidance. Section 3.62. Pages 131 and 132
PAGE 4
Preliminary
-------
AIR PATHWAY
HUMAN POPULATION TARGETS
DATABASES
• Automated databases based on U.S.
Census population are very useful
• Graphical Exposure Modeling system
(GEMS)
• U.S. EPA Office of Toxic Substances
• Internet sources: www.census.gov
PA Guidance. Section 3.82
HUMAN POPULATION TARGETS
DATABASES (cont.)
• Other population database resources:
- Local city/county planning offices
- Topographically Integrated Geographic
Encoding and Referencing (TIGER)
- U.S. Census
- Population data from private vendors
PA Guidance. Section 3.62
DATABASES
Limitations of automated
population databases:
• 'Census tracts' based on
population density (smaller in
urban areas; larger in rural
areas)
• Population is assigned to
centroid of tract
• Result underestimation or
overestimation of population for
small, dose-in, distance
categories (% mile, Km He)
PA Guidance. Section 3 6.2. Page 131
Preliminary
;ment Training
PAGE 5
-------
AIR PATHWAY
DATABASES (cont.)
Solution:
• Verify close-in population with house
counts from topographic maps, aerial
photos, reconnaissance windshield
survey, or combination of all three
• Generally, automated population data-
bases are sufficiently accurate beyond
!4 mile
PA Guidance, Section 3.6.2. Page 132
HUMAN POPULATION TARGETS
Nearest individual
• Defined as the closest person to any
source at the site
• Indicates the magnitude of threat to the
person who is most likely to be exposed
• Represented by nearest regularly occupied
building
• Distance to nearest individual is noted on
the pathway characteristics box of the air
pathway score sheet
PA Guidance. Section 3 62. Pages 137
SENSITIVE ENVIRONMENT TARGETS
• Identity all sensitive environments
either on site within % mile of the sie
or within % mite of the site
• Include terrestrial and aquatic
environments
• PA Table 5 (Appendix A. Page A-31) '
lists quaifying sensitive environments
• Wettalnds are scored on acreage
totals within each distance ring \
(minimum size: 1 acre) \
• Internet sources
www.nwi.Kvs.gov
www.nvs.gov
PA Guidance. Sectcn 36 2. Page 132-134
• Wetlands
Preliminary Assessment Training
-------
AIR PATHWAY
PRIMARY AND SECONDARY
TARGETS
• All populations and sensitive environments
out to and including the % mile distance
category are considered primary targets
• Must have suspected release to identity
primary targets
• All targets beyond % mile are considered
secondary targets
• Secondary target population values are
assigned using PA Table 8 (Appendix A.
PageA-45)
W Gui
-------
PA TABLE 8: VALUES FOR SECONDARY AIR TARGET POPULATIONS
Distance
from
Site
Onsite
>0(oV. mile
>V. to Vi mile
>!4 to 1 mile
>1 to 2 miles
>2 to 3 miles
>3 to 4 Miles
Population
Nearest Intake =
Nearest
Intake
(choose
highest)
20
20
2
1
0
0
0
Population Within Distance Category
1
to
10
1
1
0
0
0
0
0
11
to
30
2
1
0
0
0
0
0
31
to
100
5
1
1
0
0
0
0
101
to
300
16
4
1
1
0
0
0
301
to
1.000
52
13
3
1
1
1
0
1.001
to
3,000
163
41
9
3
1
1
1
3.001
to
10,000
521
130
26
8
3
1
1
10.001
to
30,000
1.633
406
88
26
8
4
2
30,001
to
100,000
5,214
1.303
282
83
27
12
7
100,001
to
300,000
16,325
4,081
882
261
83
38
23
300.001
to
1^00.000
52,136
13.034
2,815
634
266
120
73
Greater
than
1 ,000,000
163.246
40,811
8,815
2,612
833
376
229
Score =
Population
Value
PA TABLE 9: AIR PATHWAY VALUES
FOR WETLAND AREA
Wetland Ana
Less than 1 acre
1 to 50 acres
Greater than SO to 100 acres
Greater than 100 to 150 acres
Greater than 150 to 200 acres
Greater than 200 to 300 acres
Greater than 300 to 400 acres
Greater than 400 to 500 acres
Greater than 500 acres
Assigned Value
0
25
75
125
175
250
350
450
500
PA TABLE 10: DISTANCE WEIGHTS AND CALCUALTIONS
FOR AIR PATHWAY SECONDARY SENSITIVE ENVIRONMENTS
Distance
Onsite
0-1/4 mite
1/4 - 1/2 mile
Distance
Weight
0.10
0.025
0.0054
Sensitive Environment Type and Value
(from PA Table 5 or 9)
X
X
X
X
X
X
X
X
X
Total Environmental Score =
Product
-------
AIR PATHWAY
VALUES FOR SECONDARY
TARGET POPULATIONS
F
DISTANCE
FROM SITE
Orate
O-'/. Mile
>'/•-» Mie
AIR
(PA Table 8)
183
41
Q
|
>1-2 Mb*
> 2-3 Mies
>3-4Mtos
1
1
1
GROUND WATER (norteret)
(PA Table 2A)
-
183
101
52
29
21
13
>opufatkxi Range: 1001 to 3000
LIKELIHOOD OF RELEASE
No suspected release vs. suspected releas
\ rvip; / i T^P;
\ _^k / i \ _A •'
(Not to scale)
^ = Primary Targets
O = Secondary Targets
Preliminary
raining
PAGE 9
-------
AIR PATHWAY
AIR PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Air Pathway Criteria List, page 21.) Yes
Distance to nearest individual?
No
ft
LIKELIHOOD OF RELEASE
1 SUSPECTED RELEASE: If you suspect a release to air (See page 21),
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: ff you do not suspect a release of air. assign
a score of SOX). Use only Column B for this pathway.
TARGETS
3. PRIMARY TARGET POPULATION: Determine the number of people subject to
exposure from a suspected release of hazardous substances to the air.
people x 10
4. SECONDARY TARGET POPULATION: Determine the number of people not
suspected to have been exposed to a release of air, and assign the total
population score using PA Table 8.
5 NEAREST INDIVIDUAL: If you have identified any Primary Target Population for
the air pathway, assign a score of 50; otherwise, assign the Nearest Individual
score from PA Table 8.
6. PRIMARY SENSITIVE ENVIRONMENTS: Sum the sensitive environment values
(PA Table 5) and wetland acreage values (PA Table 9) for environments subject
to exposure from a suspected release to the air.
Sum *
7. SECONDARY SENSITIVE ENVIRONMENTS: Use PA Table 10 to determine the
score for secondary sensitive environments.
8. RESOURCES
SeiuilmEmirotmenl Type
Vitas
(50.20.77.1 or 0)
(M.7.J.1WO)
(5
-------
AIR PATHWAY
CASE STUDY: ABC VACUUM SERVICE
AIR PATHWAY
OBJECTIVE
Using the background information form file searches, site reconnaissance notes, and maps, complete
the "Air Pathway" portion of the PA score sheets.
METHOD
1 .Reviewthe existing site information, site reconnaissance notes, population database
information, and the map included with this exercise.
2. Read the instructions for the "Air Pathway" criteria list, and complete the
"Suspected Release" evaluation. Determine whether you can identify a resident
population. Summarize the rationale for this decision in the space provided.
3.Using the existing site information and the score sheet instructions, complete all
the portions of the "Air Pathway" score sheet. Use PA Table 9, "Values for
Wetland Area" and PA Table 10, "Distance Weights and Calculations for Air
Pathway Secondary Sensitive Environments to Evaluate." Remember to
evaluate the resident individual factor.
4. Calculate and record the Air Pathway score.
SOIL EXPOSURE PATHWAY DATA
• Nineteen residents live within 200 ft of the site.
• No schools or day care facilities are within 200 ft of the site.
• The site is inactive; therefore, no workers are present on-site.
• Ten people are employed at the crayfish ponds.
* One report indicated that the warehouse complex employed 65 people.
Air Pathway: GEMS Population Data
for ABC Vacuum Service
North Latitude: 30° 30' 18" West Longitude: 91° 19' 16"
Total Population: 6489
Numbvr
1
2
3
4
5
•
Population
0
o
1,086
1.254
1.733
2.406
House
0
0
320
330
456
710
DM)
Kiomaen
0.40
0.81
1.60
r 3.20
4.80
6.40 !
me*
Mies
0.25
050
1
2
3
4
Sector
1
1
1
1
1
1
Preliminary Assessment Training
PAGE 11
-------
ABC VACUUM SERVICE
KEY
Private Well
Properly Boundary
Not to Scale
-------
AIR PATHWAY
AIR PATHWAY CRITERIA LIST
This "Criteria List" helps guide the process of developing hypotheses as to whether a release to the air is
likely to be detected. The check-boxes record your professional judgment. Answers to all of the listed
questions may not be available during the PA. Also, the list is not all-inclusive; if other criteria help shape
your hypotheses, list them at the bottom of the page or attach an additional page.
The "Suspected Release" section identifies several conditions that could provide insight as to whether a
release from the site is likely to be detected. If a release is suspected, primary targets are any residents,
workers, student, and sensitive environments on or within % mile of the site.
Check the boxes to indicate a "yes," "no," or "unknown" answer to each question. If you check the
"Suspected Release" box as "yes," make sure you assign a Likelihood of Release value of 550 for the
pathway.
Preliminary Assessment Training
PAGE 13
-------
AIR PATHWAY
AIR PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
s k
D D D Are odors currently reported?
D D D Has release of a hazardous substance to
the air been directly observed?
D D D Are there reports of adverse health effects
(e.g., headaches, nausea, dizziness)
potentially resulting from migration of
hazardous substances through the air?
D D D Does analytical or circumstantial evidence
suggest a release to the air?
If you suspect a release to air, evaluate all populations
and sensitive environments within 1/4 mile (including
those onsrte) as primary targets.
an
nn
Other criteria?
SUSPECTED RELEASE?
Summarize the rationale for Suspected Release (attach an additional page if necessary):
Preliminary As?
-------
AIR PATHWAY
AIR PATHWAY SCORE SHEET
Pathway Characteristics
Answer the questions at the top of the page. Refer to the Air Pathway Criteria List (Page 21} to hypothesize whether
you suspect that a hazardous substance release to the air could be detected. Due to dispersion, releases to air are
not as persistent as releases to water migration pathways and are much more difficult to detect Develop your
hypothesis concerning the release of hazardous substances to air based on Veal time' considerations. Record the
distance (in feet) from any source to the nearest regularly occupied building.
Likelihood of Release (LR)
1. Suspected Release: Hypothesize, based on professional judgment guided by the Air Pathway Criteria List
(Page 21). If you suspect a release to air, use only Column A for this pathway, and no not evaluate factor 2.
2. No Suspected Release: If you do not suspect a release, enter 500, and use only Column B to score this path
way.
Targets (Tl
3. Primary Target Population: Evaluate populations subject to exposure from release of a hazardous substance
from the site. If you suspect a release, the resident, student, and worker populations on and within 1/4 mile of the
site are considered primary target population If only the number of residences is known, use the average county
residents per household (rounded up to the next integer) to determine the population. In the space provided, enter
this population. Multiply the population by 10 to determine the Primary Target Population score. Note that if you do
not suspect a release, there can be no primary target population.
4. Secondary Target Population: Evaluate populations in distance categories not suspected to be subject to
exposure from release of a hazardous substance from the site, if you suspect a release, residents, students, and
workers in the 1/4 to 4-mile distance categories are secondary target population. If you do not suspect a release, all
residents, students, and workers on site and within 4 miles are considered a secondary target population.
Use PA Table 8 (Page 23). Enter the population in each secondary target population distance category, circle the
assigned value and record it on the far-right side of the table. Sum the far-right column, and enter the total as the
Secondary Target Population factor score.
5. Nearest Individual Intake represents the threat posed to the most likety to be exposed to a hazardous substance
release from the site. If you have identified a primary target population, enter 50. Otherwise, assign the score from
PA Table 8 (Page 23) for the closest distance category in which you have identified a secondary target population.
6. Primary Sensitive Environments: If release is suspected, all sensitive environments on or within 1/4 mile of the
site are considered primary targets. List them and assign values for sensitive environment type (from PA Table 5,
Page 16) and/or wetland acreage (from PA Table 9, Page 23). Sum the values, and enter the total as the factor
score.
7. Secondary Sensitive Environments: If a release Is suspected, sensitive environments in the 1/4 to 1/2 mile
distance category are secondary targets; greater distances need not be evaluated because distance weighting
greatly diminishes the impact on site score. If you do not suspect a release, all sensitive environments on and within
1/2 mile of the site are considered secondary targets, List each secondary sensitive environment on PA Table 10
(Page 23), and assign a value to each using PA Table 5 and 9 Multiply each value by the indicated distance weight,
and record the product in the far-right column. Sum the products, and enter the total as the factor score.
8. Resources: A score of 5 can generally be assigned as a default measure. Assign zero only if there is no land
resource use with 1/2 mile.
Sum the target scores in Column A (Suspected Release) or column B (No Suspected Release).
Waste Characteristics (WC1
9. Waste Characteristics: Score is assigned from Page 4. However, if you have identified any primary target for
the air pathway, assign either the score calculated on Page 4 or a score of 32, whichever is greater.
Air Pathway Score: Multiply the scores for LR, T and WC. Divide the product by 82,500. Round the result to the
nearest integer. If the result is greater than 100, assign 100.
Preliminary
PAGE 15
-------
AIR PATHWAY
AIR PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Air Pathway Criteria List, page 21.)
Distance to nearest individual?
Yes
No
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to air (See page 21).
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release of air, assign
a score of 500. Use only Column B for this pathway.
TARGETS
3. PRIMARY TARGET POPULATION: Determine the number of people subject to
exposure from a suspected release of hazardous substances to the air.
people x 10 =
SECONDARY TARGET POPULATION: Determine the number of people not
suspected to have been exposed to a release of air, and assign the total
population score using PA Table 8.
NEAREST INDIVIDUAL: If you have identified any Primary Target Population for
the air pathway, assign a score of 50; otherwise, assign the Nearest Individual
score from PA Table 8.
PRIMARY SENSITIVE ENVIRONMENTS: Sum the sensitive environment values
(PA Table 5) and wetland acreage values (PA Table 9) for environments subject
to exposure from a suspected release to the air.
SarutinEmimnmtnt lype
Sum--
7. SECONDARY SENSITIVE ENVIRONMENTS: Use PA Table 10 to determine the
score for secondary sensitive environments.
8 RESOURCES
150.20.7.2.1 «0>
C20.7.2.1VOI
(SorO)
T =
WASTE CHARACTERISTICS
A. If you have identified any Primary Target for the air pathway, assign the waste
characteristics score calculated on Page 4, or a score of 32, whichever is
GREATER. Do not evaluate Part B of this factor.
B.lf you have NOT identified any Primary Target for the air pathway, assign the
waste characteristics score calculated on Page 4.
WC =
AIR PATHWAY SCORE:
PAGE 16
LR x T x WC
82.500
|«*t«f lo a mmmm of 100)
Preliminary Assessment Training
-------
PA TABLE 8: VALUES FOR SECONDARY AIR TARGET POPULATIONS
Distance
ffom
Site
Onsite
>0to% mile
>'/4 to % mile
>y, to 1 mile
>1 to 2 miles
>2 to 3 miles
>3 to 4 Miles
Population
— _
Nearest Intake -
Nearest
Intake
(choose
highest)
20
20
2
1
0
0
0
Population Within Distance Category
1
to
10
1
1
0
0
0
0
0
11
to
30
2
1
0
0
0
0
0
31
to
100
5
1
1
0
0
0
0
101
to
300
16
4
1
1
0
0
0
301
to
1,000
52
13
3
1
1
1
0
1,001
to
3,000
163
41
9
3
1
1
1
3,001
to
10,000
521
130
2B
8
3
1
1
10,001
to
30.000
1,633
408
B8
26
8
4
2
30,001
to
100.000
5.214
1,303
2B2
83
27
12
7
1 00,001
to
300,000
16,325
4.081
8B2
261
83
38
23
300,001
to
1 ,000,000
52,136
13.034
2,815
834
266
120
73
Greater
than
1 ,000,000
163,246
40,811
8,815
2.612
833
376
229
Score ~
Population
Value
PA TABLE 9: AIR PATHWAY VALUES
FOR WETLAND AREA
Wetland Ana
Less than 1 acre
1 to 50 acres
Greater than 50 to 100 acres
Greater than 100 to 150 acres
Greater than 150 to 200 acres
Greater than 200 to 300 acres
Greater than 300 to 400 acres
Greater than 400 to 500 acres
Greater than 500 acres
Assigned Value
0
25
75
125
175
250
350
450
500
PA TABLE 10: DISTANCE WEIGHTS AND CALCUALTIONS
FOR AIR PATHWAY SECONDARY SENSITIVE ENVIRONMENTS
Distance
Onsite
0-1/4 mite
1/4- 1/2 mile
Distance
Weight
0.10
0.025
0.0054
Sensitive Environment Type and Value
(from PA Table 5 or 9)
X
X
X
X
X
X
X
X
X
Total Environmental Score =
Product
-------
-------
SECTION EIGHT
COMPLETING THE
PA INVESTIGATION
COMPLETE
PA PACKAGE
-------
COMPLETING THE PA INVESTIGATION
COMPLETING THE
PA INVESTIGATION
SITE SCORE
• Combines scores for all four pathways
• Uses a root-mean-square formula:
Site Score =
s,2*s,!
• Calculate score using matrix provided in the
PA score sheet (Appendix A, Site Score
Calculation, Page A-47)
• Round score to nearest integer
PA Gudance. Section 3.7
SUMMARY
• Provides a qualitative evaluation or relative risk
of targets exposed to hazardous substances
from the site
• Cross-checks individual pathway scores
• Identifies affected targets
• used as basis for site hypotheses
• Summary table and instructions are found in
Appendix A, Pages A-46 and A-47 of PA
Guidance Manual
PA Gudance. Section 3.7
PAGE 2
Preliminary Assessment Training
-------
COMPLETING THE PA INVESTIGATION
SITE SCORE CALCULATION
In the column labeled S. record the Groundwater Pathway score, the Surface Water Pathway score, the
Soil Exposure Pathway score, and the Air Pathway score. Square each pathway score and record
the result in the S2 column. Sum the squared pathway scores. Divide the sum by 4, and take the square
root of the result to obtain the Site Score.
SUMMARY
Answer the summary questions, which ask fora qualitative evaluation of the relative risk of targets being
exposed to a hazardous substance from the site. You may find your responses to these questions a
good cross-check against the way you scored the individual pathways. For example, if you scored the
groundwater pathway on the basis of no suspected release and secondary targets only, yet your
response to question #1 is "yes," this presents apparently conflicting conclusions that you need to
reconsider and resolve. Your answers to the questions on page 24 should be consistent with your
evaluations elsewhere in the PA score sheets package.
Preliminary
icnt Training
-------
COMPLETING THE PA INVESTIGATION
SITE SCORE CALCULATION
GROUNDWATER PATHWAY
SCORE (SgJ:
SURFACE WATER PATHWAY
SCORE (SJ:
SOIL EXPOSURE PATHWAY
SCORE (S,):
AIR PATHWAY
SCORE (S,):
S
SITE SCORE-
\
5^2 + 5^2 + 5,2+3,2
4
S2
SUMMARY
1.
2.
3.
4.
Is there a high possibility of a threat to any nearby drinking-water well(s) by migration of a
hazardous substance in ground water?
A. If yes, identify the well(s).
B. If yes. how many people are served by the threatened wetl(s)?
Is there a high possibility of a threat to any of the following by hazardous substance
migration in surface water?
A. Drinking-water intake
B. Fishery
C. Sensitive environment (wetland, critical habitat, others)
O.lf yes, identify the targets).
Is there a high possibility of an area of surficial contamination within 200 feet of any
residence, school or daycare facility?
If yes, identify the property(ies) and estimate the associated population(s).
Are there public health concerns at this site that are not addressed by PA scoring
considerations? If yes, explain:
YES
D
n
D
D
D
D
NO
D
D
D
n
D
D
Preliminary Asse:
-------
COMPLETING THE PA INVESTIGATION
REPORTING REQUIREMENT
Wfft
SUMMWW
FOB*
COMPLETE
PA PACKAGE
Go to Appendix D. Pago D-3
in the PA Gudarew Manual, for PA check list
PA Guidance. Section 4
REPORTING REQUIRMENTS (cont.)
• Potential hazardous waste site preliminary
assessment form (PA Guidance, Appendix D)
• Narrative report
- May be a letter report or a stand-alone document
- Factual statements must be keyed to a supporting
reference
- References not available to general public are
attached to report
- Must include latitude and longitude worksheet
- Table 4-1 (Pages 145-147) contains PA report
outline
PA Gudance, Sect»n4.1 and 4,2
Preliminary A:
-------
"\ INVESTIGATION
TABLE 4-1
PA NARRATIVE REPORT, OUTLINE OF CONTENTS
INTRODUCTION
State that a PA was performed, name the agency or organization performing it, and state the authority
under which it was conducted (i.e., CERCLA as amended by SARA and EPA contract or cooperative
agreement). Include the site name, CERCLIS identification number, and location (street address, city,
county, state).
Briefly state the purpose of the PA (i.e., to assess the immediate or potential threat that wastes at
the site pose to human health and the environment and to collect information to support a decision
regardiing the need for further action under CERCLA/SARA) and the scope of the investigation
(e.g., research and review file information, comprehensive target survey and an off-site or on-srte
reconnaissance).
SITE DESCRIPTION. OPERATIONAL HISTORY AND WASTE CHARACTERISTICS
• State brief directions to the site. Provide latitude/longitude coordinates. Identify the type of site (e.g.,
plating facility, chemical plant), whether it is active or inactive, and years of operation. Describe its
physical characteristics (e.g., dimensions, size, structures, buildings, borders, drainage patterns) and
setting (e. g., topography, local land uses). Include a USGS 7.5-minute base map locating the site
and showing a 1-mile radius. On the map, identify the surface water drainage route; nearest well,
intake and residence; wetlands and other sensitive environments. Include a drafted site sketch
showing features on and around the site.
* Provide an operational history of the site. Identify current and former owners and operators, and
describe site activities. Identify and describe wastes generated, quantities, disposal practices, and
source areas. Indicate source areas on the sketch. Describe any removals, whether conducted by
facility operators or regulatory authorities.
• Describe past regulatory activities including permits, violations, and inspections by local, state, or
Federal authorities. Present available analytical data in a table and discuss.
PATHWAY AND ENVIRONMENTAL HAZARD ASSESSMENT
Groundwater
• Describe the local geologic and hydrogeologic setting (e.g., stratigraphy, formations, aquifers, karst
features, depth, and permeability to the shallowest aquifer.)
• On the basis of the site description, operational history, local geology and hydrogeology, and any
available analytical data, state whether release of a hazardous substance from the site to ground-
water is suspected. If analytical data are available, summarize them in a table.
• Discuss groundwater use within a 4-mile radius. Identify the nearest drinking-water well and state
the distance to it. Quantify drinking-water populations served by wells within 4 miles. Differentiate
between populations served by private wells and those served by municipal wells; identify
blended systems. Identify drinking-water wells suspected to be primary targets, and quantify the
populations associated with each.
Preliminary
-------
COMPLETING THE PA INVESTIGATION
TABLE 4-1 (continued)
PA NARRATIVE REPORT, OUTLINE OF CONTENTS
PATHWAY AND ENVIRONMENTAL HAZARD ASSESSMENT (continued)
Surface Water
* Describe the local hydroiogic setting, including site location with respect to floodplains and the over
land and downstream portions of the surface water migration path. State the distance from the site to
the probable point of entry (PPE) to surface water. Identify the water bodies within a 15-mile down
stream distance, and state the length or reach and flow characteristics of each. Include a drafted
sketch of the surface water migration path.
• On the basis of the site description and operational history, local hydrology, and any available
analytical data, state whether release of a hazardous substance from the site to surface water is
suspected. If analytical data are available, summarize them in a table.
• Indicate whether surface water within a 15-mile downstream distance supplies drinking water. Identify
each drinking-water intake, and state the distance from the PPE to the nearest intake. Quantify the
drinking-water population served by surface water, and identify blended systems. Identify surface
water intakes suspected to be primary targets, and quantify the populations served by each.
• Indicate whether surface water along a 15-mile downstream distance supports fisheries. Identify each
fishery, and state the distance from the PPE to the nearest fishery, identify the fishery with the lowest
flow characteristics. Identify fisheries suspected to be primary targets.
• Indicate whether sensitive environments are present in or adjacent to the surface water migration path
(overland and along a 15-mile downsteam distance). Identify each sensitive environment, and
state the distance from the PPE to the nearest; identify the sensitive environment with the lowest
flow characteristics. Identify sensitive environments suspected to be primary targets.
Soil Exposure and Air
• Indicate the number of on-site workers and the number of people who live on-site or within 200 ft
of areas of known or suspected contamination. Identify schools and daycare facilities on-site or
within 200 ft of areas of known or suspected contamination, and state the number of attendees.
Quantify the populations (residents, students and workers) within 4 mile of the site; state the
distance to the nearest regularly occupied on-site or off-site building. Identify sensitive environ-
ments on site and within 4 mile of the site. Discuss the likelihood of a hazardous substance
being released to the air. If analytical data are available, summarize them in a table.
SUMMARY AND CONCLUSION
• Briefly summarize the major aspects of the site and its history that relate to the potential for
releases of hazardous substances and the exposure of targets. Identify principal pathways and
targets of concern. Discuss additional qualitative considerations or unusual circumstances that
should be brought to the attention of Regional EPA site assessment personnel.
Preliminary Assessment Training
PAGE?
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COMPLETING THE PA INVESTIGATION
TABLE 4-1 (concluded)
PA NARRATIVE REPORT, OUTLINE OF CONTENTS
SUMMARY AND CONCLUSION
* Briefly summarize the major aspects of the site and its history that relate to the potential for
releases of hazardous substances and the exposure of targets. Identify principal pathways and
targets of concern. Discuss additional qualitative considerations or unusual circumstances that
should be brought to the attention of Regional EPA site assessment personnel.
PHOTODOCUMENTATION LOG
• As an attachment, provide original photographs of the site and pertinent site features (e.g.,
waste source areas, stained soil, stressed vegetation, drainage paths) taken during the site
reconnaissance. Provide a written description on the back of each photo, in captions or in
an accompanying text. Key each photo to its location on the site sketch.
REFERENCES
• Provide a numbered list, in bibliographic citation format, of all references cited in the
PA report.
• Attach copies of references cited in the PA report. Include complete copies of site-specific
references (e.g., USGS topographic quads, records of communication, drinking-water population
apportionment and calculation work sheets, GEMS and other database printouts, waste handling
records or shipping manifests). Include only the title page and pertinent excerpts of general
references (e.g., geologic reports, census reports, other publicly available documents).
Preliminary Assessment Training
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COMPLETIN
REPORTING REQUIRMENTS (cont.)
PA Scoring
• PA score sheets
- Must be included
- Provide national consistency in reporting
- Found in PA Guidance, Appendix A
- Also available from EPA
- Regional variations may exist
PA Guidano*. Section 4 3
REPORTING REQUIRMENTS (cont.)
PA Scoring (cont.)
• PA-Score*
- Computer program developed by EPA
- Performs all factor value table look-ups
and mathmatical calculations
- PA-print used to print score sheets,
references and PA data summary form
*See: www.epa.gov/superfund/resources/pascore
PAGuUMnce. S«aton4.3
INTERNAL QA REVIEWS
Checking for internal consistency
• Look at:
- Criteria lists
- Pathway characteristics boxes
- Scoring Columns "A" and "B"
- PA Tables 1-10
- Summary questions \,
Use Table 5-1, Checklist for Internal
Consistency. PA Guidance, Pages 151-152,
for each pathway
PA Guctonce. Section 5.1
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COMPLETING THE PA INVESTIGATION
REVIEWS
Review of PA hypotheses
• Ensure hypotheses are reasonable and
well-founded
• Evaluate responses on catena lists for
appropriate conclusions
• Resolve any differences of opinion between
author/reviewer
• Avoid inappropriate NFRAP
recommendations
• Use most up-to-date data/documentation
PA Gudsnce, Sect»n52
THE NEXT STEP . . .
PAGE 10
Preliminary A
;nt Training
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TABLE 1-1: PA FACTORS BY PATHWAY
FACTORS WITHIN FACTOR CATEGORIES
PATHWAY
LIKELIHOOD OF RELEASE
WASTE CHARACTERISTICS
TARGETS
GROUNDWATER
SURFACE WATER
SOIL EXPOSURE
AIR
Suspected Release
No Suspected Release
Depth to Aquifer
Suspected Release
No Suspected Release
Distance to Surface Water
Flood Frequency
Hazardous Waste Quantity
Hazardous Waste Quantity
Suspected Contamination
Hazardous Waste Quantity
Suspected Release
No suspected Release
Hazardous Waste Quantity
Primary Target Population
Secondary Target Population
Nearest Drinking-water Well
Wellhead Protection Area
Resources
Primary Target Population
Secondary Target Population
Nearest Drinking-water Intake
Resources
Primary Taret Fisheries
Secondary Target Fisheries
Primary Target Sensitive Environments
Secondary Target Sensitive Environments
Resident Population
Resident Individual
Workers
Terrestrial Sensitive Environments
Resources
Nearby Population
Primary Target Population
Secondary Target Population
Nearest Individual
Primary Target Sensitive Environments
Resources
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SECTION NINE
FEDERAL AGENCY
HAZARDOUS WASTE
COMPLIANCE DOCKET
-------
FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
WHAT IS A FEDERAL FACILITY?
• Any building, installation, structure, land,
or public work owned or leased by the
federal government. This excludes
ships at sea, aircraft in the air, land
forces or U.S. installations located on
foreign soil.
DEFINITION OF A FACILITY
Based on the RCRA definition:
• Encompasses all contiguous land owned by
the federal agency
• Includes all individual sites or units on the
property, including government-owned and
contractor-operated (GOCO) sites
• The PA/SI should address all contamination
emanating from the facility, not just portions
that have been reported
Federal Register. Vol. 58. No. 23. February 5, 1993. Pg. 7298
DISCOVERY AT
FEDERAL FACILITIES
Sites may be referred to EPA by:
• States
• Citizen petitions
• Coast Guard
• Agency for Toxic Substances and Disease
Registry (ATSDR)
• Indian tribes or other agencies
NOTE: The agency governing the site has the responsibility
for cleanup using its own budget. No funds come from
Superfund.
Preliminary Assessment Training
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FEDERAL
RDOUS WASTE COMPLIANCE DOCKET
PURPOSE OF DOCKET
identify the universe of federal facilities that
must be evaluated to determine whether they
pose a risk to public health and the environment
Compile and maintain the information submitted
to EPA on these facilities as required under the
provisions of CERCLA Section 120 (c)
Provide a mechanism to make this information
available to the public
See: www.epa.gov/swerflrr/laws.htm
(Federal Facility Compliance Act)
Federal Register. Vol. 58. No. 23. February 5, 1993. Pg. 7296
DOCKET REQUIREMENTS
• Required by Section 120(c) of CERCLA as
amended by SARA on October 17, 1986
• Contains information submitted by federal
agencies to EPA under CERCLA Section 103
(Notification of a Release or Potential
Release)
DOCKET REQUIREMENTS (cont)
CERCLA Sectfon 103 requires:
• The owner or operator of a facility to notify the
National Response Center (NRC) of the
release of a reportabte quantity of a hazardous
substance
• Any person in charge of a vessel or
onshore/offshore facility must immediately
notify the NRC of any release of a hazardous
substance in quantities equal to or greater
than those reportsble quantities listed in
Section 102 of the title
Federal Register. Vol 56. No 23. February 5. 1933. Pg 7298
Preliminary Asse:
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FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
DOCKET REQUIREMENTS (cont.)
CERCLA Section 103 requires:
• Initial reporting of any known or suspected
hazardous waste sites
• Preliminary Assessments (PAs), Site
Inspections (Sis), Installation Restoration
Program (IRP) reports or other
environmental restoration reports are
considered equivalent forms of notification
Federal Register. VoL 56. No. 23. February 5, 1993, Pg. 7298
DOCKET REQUIREMENTS (cont.)
* Section 3005 (Interim Status/Permitting Authority)
• Section 3010 (Notification of Hazardous Waste
Activity for Generators, Transporters and TSD
Facilities)
* Section 3016 (Biennial Inventory) of Federal
Agency Hazardous Waste Activities)
Federal Register, Vol. 56. No. 23. February 5.1983. Pg. 7296
DOCKET REQUIREMENTS (cont.)
In general:
• Must be updated even/ 6 months; updates must
be published in the Federal Register
• Federal agencies must conduct a PA and, if
necessary, an SI for each facility on the docket
• For facilities appearing on updates, PA/SIs are
due 18 months after publication in the Federal
Register
• Docket must be available for public inspection
Federal Register. Voi 58. No 23. February S. 1993. Pg 7296-7299
Preliminary Assessment Training
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FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
DOCKET REQUIREMENTS (cont.)
In general:
• Commence a Remedial Investigation and
Feasibility Study (RI/FS) within 6 months of listing
onNPL
• Commence a Remedial Action (RA) Interagency
Agreement within 180 days of review by EPA
• Federal Register shall also indicate a regional site
information contact in the Federal Register
• Listing of a facility on the docket is usually
permanent
RELATIONSHIP OF DOCKET
TO THE NPL
• Docket is NOT intended to be an NPL for
federal facilities
• Identifies those facilities that must be
assessed with a PA
• If an additional evaluation is necessary, the
responsible agency must provide to EPA the
information to conduct an MRS scoring
• If the MRS score meets the criteria for listing,
the facility will be proposed for the NPL
COMPILATION PROCEDURES
Extracted from four databases:
• Comprehensive Environmental Response,
Compensation and Liability Information
System (CERCLIS)
• Emergency Response Notification System
(ERNS)
Please see: www.epa.gov/superfund
www.epa.gov/ERNS
Federal Register. Vol. 58. No. 23. February 5,1993. Pg 7298
Preliminary Assessment Training
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FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
COMPILATION PROCEDURES
Extracted from four databases:
• RCRA 3016-Biennial inventory of federal
agency hazardous waste activities
• Resource Conservation and Recovery
Information System (RCRIS)
Please see:
www.epa.gov/reg5rcra/wptdiv/rcrisint. htm
DOCKET COMPILATION
• EPA compares revised docket database to
new facility information
• EPA prepares draft revision, corrections, and
removal lists
• All EPA regions and federal agencies are
given opportunity to comment on draft lists
• Additions, corrections, and removal lists are
published in the Federal Register
Federal Register. Vol 58. No 23. February 5, 1983. Pg. 7298-7301
IMPACT OF DOCKET LISTING
ON FEDERAL AGENCIES
• Responsible federal agency has 18 months
from docket publication to complete a PA
• CERCLA Section 120 (d) requires a PA to
be conducted for each facility on docket
• If ownership changes from another federal
agency, new owner has 18 months from
subsequent publication to complete a PA
Preliminary Assessment Training
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FEDERAL FACILITY DOCKET
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
C»rrKtfon* vM
N«m«val« Utt
x
EPAIUvtawi
Oilw
•"•u'-i'.-r
?»>..«
F«*r»l
CoRKtlOm
-------
FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
DOCKET UPDATE PROCESS
• Updated every 6 months in Federal Register
• Updates include new facilities, corrections to
facility listings, and removals
• Repository files updated every 6 months at
EPA regional offices
Fedwal Ragittw. Vol. SB, No. 23. February 5. 1083, Pg. 7269-7300
REMOVING FACILITIES
FROM DOCKET
• Improperly listed facilities can be removed by
written request to EPA headquarters
• Written confirmation from EPA follow request
for correction
* If facility is properly listed and poses no
significant threat, it will remain on docket even
if no further action is needed
• Facilities deleted from docket will no longer be
subjected to CERCLA requirements 120(d)
F*d«ral Register. Vol. 58, No. 23. Fibnwry 5. 1993, Pg. 7299-7300
FACILITIES EXEMPT
FROM DOCKET
Those formerly owned by a federal agency that
are now privately owned
SQGs that have reported solely under RCRA
Section 3016 that have never produced more
than 1000 kg/month of hazardous waste
Those that are solely transporters as reported
under RCRA 3010
Federal Register. Vol. 58. No. 23. February 5. 1993. Pg. 7298-7299
Preliminary
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FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKE1
DOCKET ACCESS
• Located in repositories at EPA
regional office responsible for facility
• Located in Office of Federal Facilities
Enforcement at EPA Headquarters in
Washington DC
• Public review by appointment with
Headquarters Docket coordinator
Ptease see: //es.epa.gov/oeca/fedfac/oversight/ovefsrte.html
Federal Register. Vol. 5&. No. 23. February 5,1993, Pg 7300
DOCKET IS ORGANIZED BY:
• Responsible agency and grouped
alphabetically by state
• Region and grouped alphabetically by city
DOCKET IN FORMATION INCLUDES:
• Region/state
• Site name and complete address
• Reporting mechanism (CERCLA, RCRA)
• Responsible agency
• Update listing/status code
• Date of PA
Preliminary Assf
PAGE 9
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FEDERAL AGENCY HAZARDOUS WASTE COMPLIANCE DOCKET
STATUS CODES OF FACILITIES*
• U = Undetermined
• N = NFRAP
• P = Currently proposed for the NPL
• F = Cun'ently final on NPL
• R = Removed from proposed NPL and no
longer considered for final NPL
• D = Deleted from the final NPL
'Status may change due to new site information or
changing EPA policy
FEDERAL FACILITIES ON NPL
• 165 sites currently on list
• Subject to Interagency Agreement (IGA) under
CERCLA 120(e)
• May be added based on health advisory
criteria by ATSDR
May be proposed on a priority
basis by states
Federal Register. VoL 58. No. 23. February 5.1993. Pfl 7298
PAGE 10
ssessment Trail
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APPENDIX A
EPA
FACT
SHEETS
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Version 01
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COMPENDIUM OF HRS/NPL LISTING POLICIES AND GUIDANCE
'olities, Guidance Documents, and Other Related Material
Schmedes, Susan, Applicability of the CERCLA Petroleum Exemption to Waste Oil (undated).
U.S. Environmental Protection Agency, Introductory Site Inspection Training. OSWER 9285.9-28
(undated).
U.S. Environmental Protection Agency, PREscore Training Course (undated).
U.S. Environmental Protection Agency, Supplemental Instructions for "Uncontrolled Hazardous Waste
Site Ranking System - A Users Manual," June 28,1982.
Hedeman, William N. Jr., Guidance for Establishing the National Priorities List, June 28,1982.
Caldwell, Steve, Supplemental Instructions for the Hazard Ranking System. July 29, 1982.
Perry, Robert M, Applicability of CERCLA to Contamination of Ground Water by Diesel Oil,
December 2,1982.
Caldwell, Steve, Toxicity Rating for Asbestos and Trichloroethylene, May 9,1983.
Hedeman, William N. Jr., Guidance for Updating the National Priorities List, May 12,1983.
i. Hedeman, William N. Jr., Promulgation of the National Priorities List, May 17,1983.
Barnes, A. James, Applicability of the CERCLA Petroleum Exemption to Gasoline Spills, August 12,
1983.
Thomas, Lee M., Instructions far Promulgating the National Priorities List Update, January 18,1984.
Thomas, Lee M.. Placing Federal Facilities on the Next NPL Update, February 13,1984.
Thomas, Lee M., Interim Procedures for Deleting Sites from the National Priorities List, March 27,
1984.
Thomas, Lee M., Procedures for Updating the National Priorities List, May 23,1984.
Hedeman. William N. Jr., National Priorities List Categorization. July 17,1984.
Wyner. Russel H.. Clarifying the Names of NPL Update #2 Sites. July 18,1984.
U.S. Environmental Protection Agency, "Uncontrolled Hazardous Waste Site Ranking System - A Users
Manual." 1984.
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19. Hedeman, William N. Jr., California WetlfieUt Sites (without source information), March 28, 1985.
20. Hedeman. William N. Jr, Interim Information Release Policy, April 18, 1985.
21. Kovalick, Walter W., Request Information with Respect to Mining Sites, July 31,1985.
22. Longest, Henry L. D, Comment on Draft Sampling Strategy to Support HRS Scoring, January 7,1986,
OSWER 9345.1-1.
23. Longest, Henry L. U, Assistance on Super/and Remedial Program Issues, May 29, 1986.
24. Longest, Henry L. 0, Listing Municipal Landfills on the NPL, October 24,1986.
25. Friedman, David, Notes on RCRA Methods and QA Activities, October 1986.
26. Longest. Henry L. n. NPL FIFRA Policy, January 12,1987.
27. Porter, J. Winston, Red Border Review of the National Priorities List - RCRA Federal Facilities Listing
Policy, January 13,1987.
28. Longest, Henry L. n, RCRA "Special Study" Waste Definitions: Sites That Require Additional
Consideration Prior to NPL Proposal Under the Superfund Amendments and Reauthorization Act,
March 10,1987.
29. Longest. Henry L. IL Interim Guidance for Consideration of Sections 105 (g) and 125 of the
Superfund Amendments and Reauthorization Act of 1986 Prior to NPL Proposal of Special Study Waste
Sites, May 29.1987, OSWER 9320.1-07.
30. McGraw, Jack W., Status of RCRA Sites Proposed for thetfPL, July 21,1987.
31. Blake, Francis. Scope of the CERCLA Petroleum Exclusion Under Sections 101(14) and 104 (a) (2), My
31,1987.
32. Longest, Henry L. IL Listing Municipal Landfills on the NPL, August 21.1987.
33. Parish, Scott, Municipal LandfUl/NPL Policy, August 25,1987.
34. Haynes, Benjamin W., Coal Tar Wastes Generated from Coal Gasification Plants (special study wastes),
September 14.1987.
35. Parrish, Scott. Apache Power Reproposal (nitrate contamination), February 12,1988.
36. Longest, Henry L. IL Additional Proposed NPL Update, April 15.1988.
37. Crystal, Sandra J., NPL Docket Procedures for Upcoming Federal Register Notices, May 23.1988.
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38. U.S. Environmental Protection Agency, Technical Support Document: Revised Hazard Ranking System,
December 23. 1988.
39. U.S. Environmental Protection Agency, Hazard Ranking System (HRS) For Uncontrolled Hazardous
Substance Releases; Appendix A of the National Oil and Hazardous Substance Contingency Plan;
Proposed Rule. December 23, 1988.
40. U.S. Environmental Protection Agency, National Oil and Hazardous Substances Pollution Contingency
Plan; Final Rule, 40 CFR Part 300, March 8, 1990.
41. Clay, Don R., Requirements for Cleanup of Final NPLSites Under RCRA, July 11, 1990.
42. U.S. Environmental Protection Agency, The Revised Hazard Ranking System: An Improved Tool for
Screening Superjund Sites, November 1990, OSWER 9320.7-0 IPS.
43. U.S. Environmental Protection Agency, The Revised Hazard Ranking System: Background
Information, November 1990, OSWER 9320.7-03FS.
44. U.S. Environmental Protection Agency, The Revised Hazard Ranking System: Qs and As,
November 1990, OSWER 9320.7-02FS.
45. U.S. Environmental Protection Agency, Closing the NPL Book Under the Original HRS, November
1990, OSWER 9320.7-04FS.
46. U.S. Environmental Protection Agency. Hazard Ranking System; Final Rule, December 14,1990,40
CFR Part 300.
47. U.S. Environmental Protection Agency, Response to Comments on the Revisions to the Hazard Ranking
System, December 14,1990.
48. U.S. Environmental Protection Agency, Management of Investigation-Derived Wastes During Site
Inspections, May 1991, OSWER 9345.3-02.
49. Wyeth. George B., Federal Facility Site Definition, August 13.1991.
SO. U.S. Environmental Protection Agency, Guidance for Performing Preliminary Assessments Under
CERCLA, September 1991, OSWER 9345.0-01 A.
51. U.S. Environmental Protection Agency, The Revised Hazard Ranking System: Evaluating Sites After
Waste Removals, October 1991. OSWER 9345.1-03FS.
52. U.S. Environmental Protection Agency, Regional Quality Control Guidance for NPL Candidate Sites,
December 1991.
53. U.S. Environmental Protection Agency, National Oil and Hazardous Substances Pollution Contingency
Plan (The NCP), January 1992. OSWER 9200.2-14.40 CFR Part 300.
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54. U.S. Environmencal Protection Agency, Guidance for Performing Site Inspections Under CERCLA,
September 1992, OSWER 9345.1-05.
55. Longest. Henry L. n. Guidance on Setting Priorities for NPL Candidate Sites, October 28,1992,
OSWER 9203.1-06.
56. U.S. Environmental Protection Agency, The Hazard Ranking System Guidance Manual, Interim Final,
November 1992, OSWER 9345.1-07.
57. Longest, Henry L. n. Discussions with the Public Concerning NPL Listings, April 30, 1993, OSWER
9320.1-11.
58. Longest, Henry L. Q, Guidance on "Worst Sites" and "NPL Caliber Sites" to assist in SACM
Implementation, August 26,1993, OSWER 9320.2-07.
59. U.S. Environmental Protection Agency, Site Inspection Prioritization Guidance, August 1993, OSWER
9345.1-15FS.
60. U.S. Environmental Protection Agency, Integrating Removal and Remedial Site Assessment
Investigations, September 1993, OSWER 9345.I-16FS.
61. U.S. Environmental Protection Agency, The Hazard Ranking System Guidance Manual: Fact Sheet,
September 1993, OSWER 9345.1-07FS.
62. U.S. Environmental Protection Agency, Guide To Community Involvement for Site Assessment
Managers, September 1993, OSWER 9345.4-2FS.
63. U.S. Environmental Protection Agency, Site Assessment: Evaluating Risks at Superfund Sites,
September 1993, OSWER 9345.4-03FS.
64. Longest, Henry L.U, Guidance on Use of Integrated Risk Information System (IRIS) Values, laaaaey 4,
1994.
65. U.S. Environmental Protection Agency, Using Qualified Data to Document an Observed Release, Draft,
July 1994. OSWER 9285.7-14FS.
66. U.S. En viroranenial Protection Agency, Hazard Ranking System Training, Winter 1994 (Updaffid),
OSWER 9285.9-25.
67. Luftig, Stephen D-. Removal ofNFRAP Sites from CERCUS, February 7,1995.
68. Luftig, Stephen D., Guidance on Deferral of NPL Listing Determinations While States Oversee Response
Actions, May 3,1995. OSWER 9375.6-11.
69. Luftig, Stephen D-, Response to Comments on the 1988 Proposed NCP Deferral Policy Concept, May 3.
1995, OSWER 9375.6-11A.
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70. Diamond, Bruce M., Final Policy Toward Owners of Property Containing Contaminated Aquifers, May
24. 1995.
71. Luftig, Stephen D., Coordinating with States in NPL Listing Determinations, June 12, 1995.
72. Luftig, Stephen D., Clarification of NPL Listing Policy, August 3, 1995.
73. Laws, Elliot P., Model Comfort Letter Clarifying NPL Listing, Uncontaminated Parcel Identifications,
and CERCLA Liability Involving Transfers of Federally Owned Property, August 9,1995.
74. U.S. Environmental Protection Agency, Establishing Areas of Observed Contamination, September
1995, OSWER 9285.7-18FS.
75. U.S. Environmental Protection Agency, Establishing Background Levels, September 1995, OSWER
9285.7-19FS.
76. U.S. Environmental Protection Agency, Establishing an Observed Release, September 1995, OSWER
9285.7-20FS.
77. Luftig, Stephen D., Procedures for Partial Deletions at NPL Sites, April 30,1996, OSWER 9320.2-11.
78. U.S. Environmental Protection Agency, Soil Screening Guidance: Fact Sheet, June 19%, OSWER
9355.4-14FSA.
79. U.S. Environmental Protection Agency, Superfund Chemical Data Matrix, August 15,1996.
80. Luftig, Stephen D., Pre-CERCUS Screening Guidance, September 30,19%, OSWER 9200.4-05.
81. Laws, Elliot P., Coordinating with the States on National Priorities List Decisions, November 7,19%.
82, Laws, Elliot P., Coordinating with the States on National Priorities List Decisions, November 14,19%.
(supersedes Laws November 7.19%]
83. U.S. Environmental Protection Agency. Using Qualified Data to Document an Observed Release and
Observed Contamination, November 19%. OSWER 9285.7-14FS. [supersedes EPA July 1994]
84. Luftig, Stephen D., Revision to OSWER NPL Policy "The Revised Hazard Ranking System: Evaluating
Sites After Waste Removals." April 4.1997, OSWER 9345.1-25. [addendum to EPA October 1991]
85. Fields, Timothy, Coordinating with States on National Priorities List Decisions-Issue Resolution
Process, Jufy 25, 1997.
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Federal Register Notices
I. December 30, 1982 Proposal 1 47 FR 58476. Proposes first 418 sites to the NPL
2. Septembers, 1983 Final 48 FR 40658. Finalizes first 406 sites on the NPL Also includes discussion
of Voluntary or Negotiated Response; Scoring on the Basis of Current Conditions; and eligibility
requirements for Radioactive Releases, Federal Facility Releases, RCRA Sites, Mining Wastes, Non-
contiguous Facilities, and Sites on Indian Lands.
3. September 21, 1984 Final 49 FR 37070. Discusses sites that may be cleaned up by responsible partie
• and scoring of air releases.
4. October IS. 1984 Proposal 2 49 FR 40320. Discusses eligibility of FIFRA-regulatedpesticide
releases.
5. June 10, 19" Final 51 FR 21054. RCRA site listing policy.
6. June 24,1988 Proposal 7 53 FR 23988. Discusses Special Study Wastes as required by SARA. Also
expands RCRA policy to allow NPL consideration for additional types of RCRA-regulated facilities.
7. March 13,1989 Final 54 FR 10512. Discusses site expansions and site ^classification. Also includes
revised discussion of releases from Federal facilities.
8. March 13,1989 Notice of Poticy Statement 54 FR 10520. Presents policy for listing Federal
Facilities that are also under RCRA Subtitle C corrective action authority.
9. Match 31.1989 Final 54 FR 13296. Discusses Rl/FS work at proposed NPL sites. Facility (site)
boundaries are defined.
10. October 4,1989 Final 54 FR 41015. Discusses Federal facility sites with Special Study Wastes and
mining sites.
11. February 21,1990 Final 55 FR 6154. Response to comments on Special Study Wastes.
\ 2. May 26.1995 Final 60 FR 278%. Discusses effects of Unfunded Mandates Act.
13. September 29,1995 Final 60 FR 50435. New wording for "Facility (Site) Boundaries" section.
14. June 17,19% Final 61 FR30510. Governor's concurrence to NPL listing discussed.
15. December 23,19% Final 61 FR 676567. Effects on small businesses.
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United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive 9285.7-14FS
PB94-963311
6PA/540/F-94/028
July 1994
Using Qualified Data to
Document an Observed Release
Office of Emergency and Remedial Response
Hazardous Site Evaluation Division (5204G)
Quick Reference Fact Sheet
ibstract
>ata validation checks the accuracy of analytical data, and qualifies results that fall outside performance criteria of
lie Contract Laboratory Program (CLP). Results qualified with a "I* are estimated concentrations that may be
iased, but may be used to determine an observed release in Hazard Ranking System (HRS) evaluation. This fact
beet explains the conditions for use of T-qualified data, and introduces factors which compensate for variability
nd enable their use in HRS evaluation.
fhy Qualify Data?
'bemtcal concentration data for environmental
ecision-makrag are generated using analytical
lethods. EPA analytical iemistry methods are
esigned to provide the definitive analyte
lentification and quantitation needed to establish an
bserved release under the Hazard Ranking System
HRS). Routine operational variations in sampling
ad analysis inevitably introduce a degree of error
ito the analytical data. Data validation checks the
sability of the analytical data for HRS evaluation and
lentifies the error (bias) present The validation
rocess qualifies the biased data. Certain types of
ualified data for release and background samples
tay be used to determine an observed release.
PA Data Qualifiers
PA analytical methods (e^, SW-846 and Contract
aboratory Program [CLP]) introduce * number of
Duality Assurance/Quality Control (QA/QC)
ierhaiusms during the course of sample analysis to
leisure qualitative and quantitative accuracy.WlU
tich mechanisms include matrix spikes, matrix spike
uplicates, laboratory control samples, surrogates,
inks, laboratory duplicates, and quarterly blind
srfonnance evaluation (PE) samples. Surrogates
id spikes are chemically similar to the analytes of
terest and thus behave similarly during the
lalyttcal process. They are introduced or "spiked*
at a known concentration into the field samples
before analysis. Comparison of the known
concentrations of the surrogates and spikes with their
analytical results measures accuracy, and may i«die«te
bias caused by interferences from the sample medium
(matrix effect).1'25 Laboratory control samples
contain known concentrations of target analytes and
are analyzed in the same batch as field samples.
Their results are used to measure laboratory
accuracy. Blanks are analyzed to detect any
contamination introduced either IB
field or in the laboratory. Laboratory duplicates
consist of one sample that undergoes two separate
analyses; the results are compared to determine
laboratory precision. Quarterly blind PE samples also
evaluate lab precision.
CLP and other EPA analytical methods include
specifications for acceptable identification, and
minimum and maximum percent recovery of the
target analytes and QA/QC compounds. Data are
validated according to guidelines which set
performance criteria for instrument calibration,
analyte id^rifiTt^^", and identification and recovery
of the QA/QC compounds. *** The National
Functional Guidelines for Data Review used in EPA
validation were designed for data generated under the
CLP organic and inorganic analytical protocols.1****
The guidelines do not preclude the validation of field
and non-CLP data; many EPA Regions have adapted
the National Functional Guidelines for Data Review to
validate non-CLP data. Data which do not meet the
-------
guidelines' performance criteria are qualified to
indicate bias or QC deficiencies. The data validation
report usually explains why the data were qualified
and indicates the direction of bias when it can be
determined. Most EPA validation guidelines use the
data qualifiers presented below. .u (Other data
qualifiers besides these are b use; always check the
validation report for the exact list of qualifiers and
their meanings.)
• 'IT qualifier -- the analyte was analyzed for,
but was not detected above the reported
sample quantitation limit. For practical
purposes, *U' means "not detected*; the result
is usable for characterizing background
concentrations for HRS evali**tion. *
• T qualifier - the analyte was positively
identified; the associated numerical value is
the approxunate.concentration of the analyte in
the sample. "J" data are biased, but provide
definitive analyte identification, and are usually
reliable. They may be used to determine an
observed release under conditions specified
later in this fact sheet5
• "N" qualifier - the analysis indicates the
presence of an analyte for which there is
presumptive evidence to make a tentative
identification.1 *N* data are not sufficiently
definitive for HRS evaluation.
• "NJ* qualifier — the analysis indicates the
presence of an analyte that has been
'tentatively identified" and the associated
numerical value represents its approximate
concentration. "NT data are not sufficiently
definitive for HRS evaluation. .
• "UJ* qualifier - the analyte was not detected
above the reported sample quantitation limit
However, the reported quantitation limit is
approximate and may or may not represent the
actual limit of quantitation" necessary to
accurately and precisely measure the analyte in
the sample. 'UP Don-detects are not definite;
the analyte may be present The result can be
used to document non-detects in background
samples under certain conditiuis.
• "R* qualifier ~ the sample results are rejected
due to serious deficiencies in the ability to
analyze the sample and meet quality control
criteria. The presence or absence of the
analyte cannot be verified. EPA does not use
"R" data because they are considered
unreliable. *
Validrted data that are not qualified are unbiased,
and can be used at their reported values for HRS
evaluation.
Criteria for Determining an Observed Release with
Chemical Data
Chemical data demonstrate an observed release when
all of the following are true:
1. The release of a hazardous substance is at least
partially attributable to the site under
investigation. •
2. The release sample concentration is greater than
or equal to the appropriate detection limit (e.g,
sample quantitation limit [SQL]).
3. If background levels are below detection limits,
the release sample concentration must be greater
than its detection unit, or, if background levels
are greater than or equal to detection limits, the
release sample concentration must be at least
three times the background concentration.*
Direction of Bias in T-Qaalified Data
It is important to understand the bias associated with
T-qualified data when using them for HRS
evaluation. T data may have high, low, or
indeterminate bias. A low bias means that the
reported concentration is most fikely an
underestimate of the true concentration. For
example, data may be biased low when sample
holding times for volatile organic compounds (VOCs)
are exceeded or when the recovery of QA/QC
compounds is significantly less than the true amount
originally introduced into the sample. A high bias
means that the reported concentration is most likely
an overestimate of the true concentration. A bias is
indeterminate when it is impossible to ascertain
whether the concentration is an overestimate or an
underestimate. For example, an indeterminate bias
could result when matrix effects obscure QA/QC
compounds.
-------
Qualified Data and Direction of Bias
Qualified data may be used when it can be
demonstrated that the data meet the HRS rule for
determining an observed release despite the bias in
the reported concentrations. This condition depends
on the direction of bias: low bias data may be used
for release samples, and high bias data may be used
for background samples. Low bias release samples
are underestimates of true concentration. Under-
estimated release concentrations that still meet the
HRS criteria (e.g., they are still three times
background level) dearly establish an observed
release. High bias background samples are
overestimates of background level. If the
concentration of unbiased release samples still
significantly exceeds aa overestimated background
level according to HRS criteria, an observed release
is clearly established Similarly, an observed release
is established when low bias release concentrations
significantly exceed high bias background
concentrations according to the HRS criteria.
These scenarios show that low bias "/-'qualified data
may be used for release samples at their reported
concentrations, and that high bias "/-"qualified data
may be used for background samples at their
reported concentrations.
High bias release samples may not be used at their
reported concentrations because they are an
overestimate of true concentration; the true
concentration might be less than the HRS criteria for
an observed release. The reported concentration for
low bias background concentrations may not be
compared to release samples because it is most likely
an underestimate of background level; the release
sample concentration might not significantly exceed
the background concentration. However, high bias
release data and low bias background data may be
used with factors which compensate for the variability
in the data. The factors will enable these types of
biased data to meet HRS criteria for determining an
observed release.
Factors for Biased Data: Tables 1 through 4 (pages
6-13) present anaJvte-specific factors to address the
uncertainty when determining an observed release
using high bias release data and low bias background
data. The factors are derived from percent recoveries
of matrix spikes, surrogates, and laboratory control
samples in the CLP Analytical Results Database
(CARD) from January 1993 to March 1994.
The range of CARD data for each anaiyte includes 95
percent of all percent recoveries. Discarding outliers
left 95 percent of the CARD data available for
calculating factors. The factors arc ratios of percent
recovery values at [be 97.5 and 25 percentOes. The
ratios generally show a consistent pattern.
An attempt to 'convert* a biased value to its true
concentration is cot recommended because the
CARD data do not differentiate and quantify
individual sources of variation. The factors are
applied as "safety factors" to ensure that biased data
can be used to meet HRS criteria for determining an
observed release. Dividing a high bias value by a
factor effectively deflates it from the high end of the
range to the low end (low bias • alue). Multiplying a
low bias value by the factor effectively inflates it to a
high bias value. Use of the ratio of percentiies is a
"worst-case" assumption that the data are biased by
the extent of the range of CARD data considered.
The factors either inflate the values to the high end of
the range, or deflate the data to the low end, and thus
compensate for the apparent variability when
comparing a high bias value to a low bias value (see
Exhibit 1).
Factors have been selected for all analytes in the CLP
Target Compound List (organic analytes) and Target
Anaiyte List (inorganic analytes). Some organic
factors were derived from matrix spike percent
recoveries, and some from surrogate percent
recoveries, depending on availability of data. When
both matrix spike and surrogate data were available
for the same compound, the larger value
(representing more extreme high and low percent
recoveries) was used. Laborato.^ control samples
were used to calculate some of the inorganic factors.
A default factor of 10 was used for analytes when
percent recovery data were unavailable.
Application of the Factors: Exhibit 1 shows how to
apply the factors to "J" qualified data. High bias
background data, low bias release data, and unbiased
data may be used at their reported concentrations.
Multiply low bias background sample data by the
analyte-specinc factor to bring them to their new
value. The new background value •ffectively becomes
a high bias value that may be used to determine an
observed release. Divide high bias release sample
data by the analytc-specific factor to bring them to
their new value. The new release sample value
effectively becomes a low bias result that may be used
13 fl I? IT
-------
Exhibit 1: Use of Factors for 'J'-Qualified Data
Type of Sample
Background
Sample
Release
Sample
Type of Bias
No Bias
Low Bias
High Bias
Unknown Bias
No Bias
Low Bias
High Bias
Unknown Bias
Action Required
Norm: Use concentration without factor
Multiply concentration by factor
None: Use concentration without factor
Multiply concentration by factor
None: Use concentration without factor
None: Use concentration without factor
OMde concentration by factor
Divide concentration by factor
to determine an observed release. Note: Adjusted
release and background values must still meet HRS
criteria (e.g., release concentration must be at least
three times background level) to determine an observed
release.
Examl
Trichloroethene in Soil:
L Release sample data biased low, background
sample data biased high.
Release sample value:
Background sample value:
30 jig/kg (J) low bias
10 jtg/kg (J) high bias
In rt»»*
direction of the bias indicates
that the release sample concentration exceeds
background by more than three times, so an observed
release is established (provided all other HRS criteria
are met). Use of the factors is not needed.
2. Release sample data unbiased, background sample
data biased low.
Release sample value:
Background sample value:
30 Mg/kg no bias
10 Mg/kg (J) low bias
To use the data to establish an observed release,
multiply the background sample value by factor given
for trichloroethene (1.8). No factor is needed for the
release sample.
New background sample value:
(10 MgAg) x (1.8) - 18 MgAg P) nigh bias
The release sample concentration does not exceed the
new background level by a factor of three, so an
observed release is not established.
3. Release sample data biased high, background
sample data unbiased.
Release sample value: 75 /ig/kg (J) high bias
Background sample value: 15 pg/kg no bias
To use the data to establish an observed release,
divide the release sample value by the factor for
trichloroethene (L8). No factor is needed for the
background sample.
New release sample value:
(75 jig/kg) * (1.8) * 42 pg/kg (J) low bias
The new release sample concentration does not
exceed background concentration by a factor of three,
so an observed release is not established.
4. Release sample data biased high background
sample data biased low.
Release sample value: 100 /tg/kg (J) high bias
Background sample value: 10 MgAg (J) low bias
To use the data to establish an observed release,
divide the release sample value and multiply the
background sample value by the factor given for
trichloroethene in soil (1.8).
I
-------
New release sample value:
(100 Mg/kg) * (1.8) = 56 Mg/kg (J) low bias
New background sample value:
(10 MgAg) * (1-8) - 18 Mg/kg (J) tog* bias
The new release sample concentration is three times
the new background concentration, so an observed
release is established, provided all other HRS criteria
are met
Documentation Requirements for Use of Qualified
Data: When using V-qualified data to determine an
observed release, include the "J'-qualifier commentary
horn the data validation report in the HRS package.
rhis step wiU ensure that toe direction of bias is
iocumented.
Use of Other Factors; EPA Regions may substitute
higher factor values other than the ones in this fact
sheet on a case-by-case basis when technically
ustified. For example, other factors may be applied
:o conform with site-specific Data Quality Objectives
[DQOs) or with Regional Standard Operating
Procedures (SOPs).*
Detection Limit Restriction*' Factors may only be
ippfied to "J" data with concentrations above the CLP
Contract Required Quantitadon Limit (CRQL) or
:ontract Required Detection Limit (CRDL). T-
jualified data with concentrations below CLP
letection limits cannot be used to document an
>bserved release.
Jse of >UJ*-QnaIified Data
^ combination of the *U" **"* *J" qualifiers indicates
hat the reported value may not accurately represent
the concentration necessary to detect the anaiyte b
the sample. Under limited conditions, *UJ" data can
be used to represent background when determining
an observed release. These conditions include
instances when there is confidence that the
background concentration has not been detected and
the sample measurement that establishes the observed
release equals or exceeds the SQL or other
appropriate detection limit. This reasoning is based
on the presence of a high bias in the background
sample. Thus, UI data can be used only when ail of
the following conditions apply:
• The *UJ* value applies to the background
sample and represents the detection limit,
• The'UP value is biased high, and
• The release sample concentration exceeds the
SQL (or applicable detection Emit) and is
unbiased or biased low.
Summary
Data validation checks the usability of analytical data
and identifies certain errors (bias). T-qualified data
identify that analytes are present, but the reported
values represent estimated concentrations associated
with bias. Low bias release data and high bias
background data may be used at the reported values.
High bias release data and low bias background data
may not be used at their reported concentrations
because they do not establish an observed release
with certainty. Application of factors introduced in
this fact sheet compensate for this u icertainty, and
enable "J" data to be used to determine an observed
release.
IT
-------
Table 1: Factors for Volatile Organic Analytea
VOLATILE
ORGANIC
ANALYTES
1,1,1 -TRICHLOROETHANE
1 .1 ,2,2-TETRACHLOROETHANE
1 ,1,2-TRICHLOROETHANE
1.1-OICHLOROETHANE
1,1-DICHLOROETHENE
1,2-DICHLOROETHANE
1,2-DICHLOROETHENE (TOTAL)
1 ,2-DICHLOROPROPANE
2-BUTANONE
2-HEXANONE
44dETWL-2-PENTANONE
ACETONE
BENZENE
BROMODICHLOROMETHANE
BROMOFORM
BROMOMETHANE
CARBON DISULF1DE
SOIL MATRIX
Number of
CARD
Samples
Reviewed
_
11144
—
11144
2064
11144
11144
—
11144
11144
11144
11144
2060
—
—
11144
11144
Factor
10.0
1.5
10.0
1.4
2.4
1.4
1.4
10.0
1.4
1.5
1.5
1.4
1.7
10.0
10.0
1.4
1.4
WATER MATRIX
Number of
CARD
Samples
Reviewed
—
9180
—
9179
1484
9179
9179
—
9179
9180
9180
9179
1482
—
—
9179
9179
Factor
10.0
1.2
10.0
1.3
2.0
1.3
1.3
10.0
1.3
1.2
1.2
1.3
1.5
10,0
10.0
1.3
1.3
-------
Table 1: Factors for Volatile Organic Analytes (continued)
VOLATILE
ORGANIC
ANALYTES
CARBON TETRACHLORIDE
'CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
CIS-1 .3-DICHLOROPROPENE
DIBROMOCHLOROMETHANE
ETHYLBENZENE
METHYLENE CHLORIDE
STYRENE
TETRACHLOROETHENE
TOLUENE
TRANS-1 ,3-DICHLOROPROPENE
TRICHLOROETHENE
VINYL CHLORIDE
XYLENE (TOTAg
SOIL MATRIX
Number of
CARD
Samples
Reviewed
—
2058
11144
11144
11144
—
-
11144
11144
11144
11144
2029
—
2046
11144
11144
Factor
10.0
1.6
1.4
1.4
1.4
10.0
10.0
1.5
1.4
1.5
1.5
2.0
10.0
1.8
1.4
1.5
WATER MATRIX
Number of
CARD
Samples
Reviewed
—
1480
9179
9179
9179
—
—
9180
9179
9180
9180
1468
—
1452
9179
9180
Factor
10.0
1.4
1.3
1.3
1.3
10.0
10.0
1.2
1.3
1.3
1.2
1.4
10.0
1.5
1.3
1.2
-------
Table 2: Factors for Semivolatile Organic Analytes
SEMIVOLATILE
ORGANIC
ANALYTES
1 .2,4-TRICHLOROBENZENE
1 ,2-DICHLOROBENZENE
1 .3-DICHLOROBENZENE
1 ,4-DICHLOROBENZENE
2.2'-OXYBIS(1 -CHLOROPROPANE)
2,4.5-TRICHLOROPHENOL
2,4.6-TRICHLOROPHENOL
2.4-DICHLOROPHENOL
2.4-DIMETHYLPHENOL
2.4-DINfTROPHENOL
2.4-DINITROTOLUENE
2,6-DJNITROTOLUENE
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2-METHYLNAPHTHALENE
2-METHYLPHENOL
2-NITROANIUNE
2-NrmOPHENOL
3.3'-OICHLOROBENZfDINE
3-NITROANIUNE
4.6-DINITRO-2-METHYLPHENOL
4-BROMOPHENYL-PHENYL ETHER
4-CHLORO-3-METHYLPHENOL
4-CHLOROANIUNE
4-CHLOROPHENYL-PHENYL ETHER
4-METHYLPHENOL
SOIL MATRIX
Number of
CARD
Samples
Reviewed
1978
11899
11899
1980
11899
11889
11889
11896
11896
11889
1979
11889
11889
1930
11896
HS'W
11«89
11?96
11898
—
—
—
1927
11896
11899
11899
Factor
3.5
3.8
3.8
3.8
3.8
8.9
8.9
4.0
4.0
8.9
3.4
8.9
8.9
32
4.0
3.8
8.9
4.0
4.3
10.0
10.0
10.0
3.6
4.0
8.9
3.8
WATER MATRIX
Number of
CARD
Samples
Reviewed
1375
7951
7951
1--=73
7951
7952
7952
7949
7949
7952
1375
7952
7952
1376
7949
795.
7952
7949
7951
—
—
—
1375
7949
7952
7951
Factor
2.9
4.0
4.0
3.0
4.0
3.6
3.6
Z5
2.5
3.6
2.6
3.6
3.6
2.9
2.5
4.0
3.6
2.5
6.0
10.0
10.0
10.0
3.5
2.5
3.6
4.0
-------
Table 2: Factors for Semfvoiatlle Organic Analytes (continued)
SEMIVOLATILE
ORGANIC
ANALYTES
4-NrTROANIUNE
4-NITROPHENOL
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZO(A)ANTHRACENE
BENZO{A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(G.H.I)PERYLENE
BENZO(K)FLUORANTHENE
BIS(2-CHLOROETHOXY)METHANE
BIS(2-CHLOROETHYL) ETHER
BIS(2-ETHYLHEXYL)PHTHALATE
BUTYLflENZYLPHTHALATE
CARBAZOLE
CHRYSENE
DI-N-BUTYLPHTHALATE
Di-N-OCTYLPKTHALATE
D!BENZ(A.H)ANTHRACENE
DIBENZOFURAN
DJETHYLPHTHALATE
DIMETHYU>HTHALATE
FLUORANTHENE
FLUORENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROCYCLOPENTADIENE
SOIL MATRIX
Number of
CARD
Samples
Reviewed
11889
1905
1965
11889
-
11898
-
-
—
—
11896
11899
11898
11898
-
11898
-
—
11889
11889
11889
11869
—
11889
—
11896
11 869
Factor
8.9
4.8
3.1
8.9
10.0
4.3
10.0
10.0
10.0
10.0
4.0
3.8
4.3
4.3
10.0
4.3
10.0
10.0
8.9
8.9
8.9
8.9
10.0
8.9
10.0
4.0
8.9
WATER MATRIX
Number of
CARD
Samples
Reviewed
7952
1368
1361
7952
—
7951
-
-
-
—
7949
7951
7951
7951
-
7951
-
—
7952
7952
7952
7952
—
7952
—
7949
7952
Factor
3.6
4.5
3.0
3.6
10.0
6.0
10.0
10.0
10.0
10.0
2.5
4.0
6.0
6.0
10.0
6.0
10.0
10.0
' 3.6
3.6
3.6
3.6
10.0
3.6
10.0
2.S
3.6
-------
Table 2: Factors (or Semivolatile Organic Analytes (continued)
SEMIVOLATILE
ORGANIC
ANALYTES
HEXACHLOROETHANE
4-N!TROPHENOUNDENO(1 ,2.3-CD)PYRENE
ISOPHORONE
N-NITROSO-DI-N-PROPYLAMINE
N-NFTROSODIPHENYIAMINE (1)
NAPHTHALENE
NITROBENZENE
PENTACHLOROPHENOL
PHENANTHRENE
PHENOL
PYRENE
SOIL MATRIX
Number of
CARD
Samples
Reviewed
11899
—
11896
1966
—
11896
11896
1895
—
1924
1901
Factor
3.8
10.0
4.0
3.7
10.0
4.0
4.0
18.8
10.0
3.2
8.3
WATER MATRIX
Number of
CARD
Samples
Reviewed
7951
_
7949
1345
-
7949
7949
1359
—
1368
1369
Factor
4.0
10.0
2.5
3.7
10.0
2J5
2.5
3.7
10.0
3.5
4.9
10
-------
Table 3: Factors for Pestidde/PCB Analytes
PESTICIDE/PCB
ANALYTES
I,4'-DDD
i,4'-DDE
i,4'-DDT
ILDR1N
1PHA-BHC
iPHA-CHLORDANE
ROCLOR-1016
flOCLOR-1221
flOCLOR-1232
ROCLOR-1242
ROCLOR-1248
ROCLOR-12S4
ROCLOR-1260
ETA-BHC
ELTA-BHC
IELDRIN
SOIL MATRIX
Number of CARD
Samples Reviewed
-
—
1801
1870
—
—
—
—
—
—
-
—
—
—
—
1886
Factor
10.0
10.0
7.4
7.9
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
6.2
WATER MATRIX
Number of CARD
Samples Reviewed
_
_
1353
1350
—
—
23305
23305
23305
23305
23305
23305
23305
—
_
1350
Factor
10.0
10.0
4.6
4.8
10.0
10.0
8.7
8.7
8.7
8,7
8.7
a7
E7
10.0
10.0
2.8
11
-------
Table 3: Factors for Pestlcfde/PCB Analytes (continued)
'ESTICIOE/PCB
ANALY7ES
OOSULFAN 1
.NDOSULFAN li
ENDOSULFAN SULFATE
ENDRIN
ENDRIN ALDEHYDE
ENDRIN KETONE
GAMMA-BHC (UNDANE)
GAMMA-CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
METHOXYCHLOR
TOXAPHENE
SOIL MATRIX
Number of CARD
Samples Reviewed
—
-
—
1866
—
—
1872
—
1877
_
_
-
Factor
10,0
10.0
10.0
8.5
10.0
10.0
4.5
10.0
4.5
10.0
10.0
10.0
WATER MATRIX
Number of CARD
Samples Reviewed
-
-
—
1348
-
-
1350
-
1351
-
—
—
Factor
10.0
10.0
.10.0
3.4
10.0
10.0
3.1
10.0
3.6
10.0
10.0 .
10.0
12
-------
Table 4: Factor* for Inorganic Analytcs
INORGANIC
ANALYTES
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
CYANIDE
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
SOIL MATRIX
Number of CARD
Samples Reviewed
1147
1153
1208
1149
1150
1148
1163
1148
1153
1154
884
1149
1331
1143
1151
1563
1150
—
1190
1152
—
1197
1152
1154
Factor
1.5
1.8
1.6
3.3
1.2
1.3
1.2
1.2
1.2
1.1
1.4
1.2
1.3
1.2
1.2
1.7
1.2
10.0
2.3
1.6
10.0
1.7
1.2
1.3
WATER MATRIX
Number of CARD
Samples Reviewed
1686
1688
1701
1686
1686
1685
1685
1686
1685
1683
—
1687
1727
1686
1685
—
1685
—
1695
1684
-
1691
1685
1689
Factor
1.2
1.2
1.2
1.1
1.2
1.2
1.1
1.2
1-2
1.2
10.0
1.2
1.2
1.1
1.2
10.0
1.2
10.0
1.3
T.3
10.0
1.2
1.1
1.2
13
-------
References
1. U.S. Environmental Protection Agency, 1994.
CLP National Functional Guidelines for Inorganic
Data Review. Office of Solid Waste and
Emergency Response. Publication 9240.1-05-01.
2. U.S. Environmental Protection Agency, 1993.
CLP National Functional Guidelines for Organic
Data Review. Office of Solid Waste and
Emergency Response. Publication 9240.1-05.
3. U.S. Environmental Protection Agency, 1991.
Contract Laboratory Program Statement of Work for
Inorganics Analysis. Document No. ILM02.0
4. U.S. Environmental Protection Agency, 1991.
Contract Laboratory Program Statement of Work for
Organics Analysis. Office of Solid Waste and
Emergency Response. Document No. OLM1.8
5. U.S. Environmental Protection Agency, 1992.
Hazard Ranking System Guidance Manual. Office
of Solid Waste and Emergency Response.
Directive 9345.1-07.
6. U.S. Environmental Protection Agency, 1991.
Guidance for Performing Preliminary Assessments
Under CERCLA, Office of Solid Waste and
Emergency Response. Publication 9345.0-01A.
7. U.S. Environmental Protection Agency, 1992.
Guidance for Performing Site Inspections under
CERCLA. Office of Solid Waste and Emergency
Response. Directive 9345.1-05.
8. U.S. Environmental Protection Agency, 1992.
Quality Assurance/Quality Control Samples.
Environmental Response Team Quality Assurance
Technical Information Bulletin.
9. U^. Environmental Protection Agency, 198o. Test
Methods for Evaluating Solid Waste (SW-846):
Physical and Chemical Methods. Office of Solid
Waste and Emergency Response. Document No.
SW-346.
10. U.S. Environmental Protection Agency, 1993.
Data Quality Objectives Process for Super/and.
Office of Emergency and Remedial Response.
Directive 9355.9-01.
14
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive 9285.7 20F3
P894-963314
EPA/54Q/F-94/031
September 1995
EPA Establishing an Observed Release
Office of Emergency and Remedial Response
Quick Reference Fact Sheet
tetnct
•PA uses the Hazard Ranking System (HRS) (40 CFR Part 300, App. A) to evaluate Supcrfund sites to be proposed OB
ic National Priorities List (NPL). Based oo the HRS criteria, an observed release is rsfibfahfd when conuminann have
ijgrated away from a site 'trough environmental media. This fact sheet describes an observed release, the data required,
ad the process used to document it. Efficient sampling also a emphasized to optimize the use of limited resources, which
i especially important m light of rMtfr"-*»g integrated assessments under the Superfund Accelerated Oeanup Model
SACM).
ntrodnctioB
Vben planning a Site Inspection, an integrated
issessment should be considered as appropriate under
he Superfund Accelerated Cleanup Model (SACM).
fhis planning would incorporate a «a««pi"if strategy that
should maximize remedial and removal resources.
rhrec categories of sampling generally are performed
during a Ske Inspection (SI):
• Source sampting to establish the presence of
hazardous sobstances at a sites
* STr*r^*?> in tbp media of fflitff re. to *^*«m«^ an
observed release, with backgrouad sampling
corresponding to the source to establish attribution;
• Quality Assttraacc/Quafity Control (OA/QQ;
sampling (e^. field blaaks) to ensure data integrity.
Although ail three of these categories are important, this
fact sheet pertains to the second category of sampling,
and dSscimct resource conservation by using available
data and an integrated sampling approach.
Determining an Observed Release
An observed release is based on evidence that
contaminants have migrated from a site through a
pathway or medium. The Hazard Ranking System
(HRS) establishes two genera! criteria to document an
observed release: there must be evidence of a hazardous
substance in the medium of concern at a concentration
iig^ifi/^nriy above the background level, and the release
of the hazardous tubstinfe must be at least partially
attributable to the site under investigation
Ranting System. Knot toil*. 40 CFR Part 300, App. A).
An observed release can be determined either by
chemical analysis of samples, or by directly observing the
release of the hazardous substance (to be documented)
into the medium of concern (see Figure 1). Observed
releases can occur through the ground-water, surface
water, and air migration pathways. In contrast, the soil
exposure pathway is evaluated lor otuer*dco*tamiiutio*
where targets (human poptihrinm. resources, and
sensitive environments) may come into direct contact
with contaminants. (For more information on the soil
exposure pathway, refer to the fact sheet Establishing
Ana of OfcMrwrf CoHtamuutiCK, September 1995,
OSWER Directive 9285.7-I8FS.)
The lavam^*1™- of an observed release by chemical
analysts should be accompanied with information on
background level and attribution. Attribution requires
evidence that the hazardous substance detected in a
medium resulted from some portion of the release from
the site. Background levels are *f*iKKfl>*4 by sampling
or by using other acceptable information, such as
published or existing sample 4%tt. i*™****** Han or data
from background samples should be generated by
sampling and analytical methods similar to those used for
the release data (Hawd RanJdnf Syttem
-------
Figure i: Flowchart for Establishing an Observed Release Under the HRS
•Not
Rgunl
to Qfound wttBf plum* »tta«
from OSMEff OfcecttW 9345L J-07
November 1992. OSWER Directive 9345.1-07).
e iafonnatioo oc cttf iblKhingVactyoqod levek.
(For mo
refer to the bet sheet £taa*ibfti»f Bodbjrxmud £««*,
September 1995. OSWER Directive 928S.7-19FS.)
Docnmeatiag aa observed release is a prerequisite for
evaluating actual coatamiaatioa at targets. Actual
exposure to hazardous tubatanm Note that the
detecboa of romamSnatitr^ at targets k act ta itself
to establish aa observed release or actual
i (OSWER Directive 9345.1-07). The level
of actual contiaiinafioa is determiaed by oaapariag the
release eoaceatntioa to heakh^based or ecological
beachaiark values, where available. Level I
cootamiaatioo is at or above substaace-spectfic
beochmarks; Level II is detectioa bebw benchmark
values.
Resource Coosldentfoaa
GeaeraUy, the SI is a liauted-scope biased samp
eveat However, uader SACM, tndkioeal remedial
should be iatefrated with tradkkMal removal
aummntft The Data Quality Objective (DQO) pro
provides a logical fraawwork for plaaaiag mobile
tavestigatkNis, thereby futfilfiac the iategrated
assessmeatfDalo(cro&»-prcvraarespoaseplaoaiag
aOowiaf optimal cross-program data usabOiry.
Data Quality Obj*ai*a Proc*uJorSnp«ifiuid. Septet
1993, OSWER Directive 9355541 for fimher detai
the DQO process.)
Whea possible, avaoabie data should be uwi to m
objectives so that resources are coaserved (see E
1). Samples caa be strategically coQected to estabt
observed release aad to iaciude oae or more target
-------
Exhibit I: Considerations when Assessing the Need for Sampling
• Is there an imminent or current threat to human health or the environment? h a removal action warranted?
Sample at targets if human or environmental exposure (o contaminants is suspected Always sample for
public health concerns.
• Can sampling meet both removal and remedial lite assessment objectives? If yes, and site conditions warrant,
aa integrated sampling approach may be used. (For more information, refer to IntegratingKemoval and
Remedial Site Assessment Investigations, September 1993. OSWER Directive 9345.1-16FS.)
• What are ihe objectives of the SI? Table 4-7 in Guidance for Performing Site Inspections Under CERCLA.
1992, OSWER Directive 9345.1-05, provides guidelines oa the number of samples recommended for a
focused, expanded, or single SI as part of an observed release sampling strategy.
• Could the pathway criticaifyaffea the site Hazard Ranking System (HRS) score fe 2&.5O)?Ifyes. must an
observed release be documented for that pathway to achieve that site score? If no, evaluating the pathway for
potential contamination may be sufficient (particularly for less critical pathways).
* What are the pathway criteria? Are targets nearby? Each HRS pathway has certain criteria for determining
and limiting target distance with respect to ronraminanK For example, for the soil exposure pathway,
must be documented within a zero to two feet depth from the surface,
must be on the property and within 200 feet of targets. For the surface water pathway, the surface water
body must be within two overland miles of the site or source. Sample collection should be avoided if
sampling cannot meet the pathway criteria,
dual purpose sampling). Analytical data with appropriate
and adequate quality assurance/quality control (QA/QC)
are needed, TIIKT K^nrhm a Ac ^re expressed in
concentration "«"*«
The Agency for Toxic Substances and Disease Registry
(ATSDR) should be consulted when there is the
potential for human exposure to toxic substances. The
sampling approach for these sites should include data
collection for the human exposure information that
ATSDR uses to determine if a health advisory is needed.
ATSDR also uses this data in the preparation of a public
health M«*w*»*t. which is required within 12 months of
proposal to the National Priorities List.
Observed Release by Direct Ohiemtttt
To retabfofr an observed release by direct observation, a
hazardous y«*nT""-« must be observed or known to have
been released into the medium of concern. Existing
dfltft of flfhffr TtfefttKrCSj such is TT* * t1 *^p^tv
should be used to document that the hazardous substance
is present or known to have been released (OSWER
Directive 9345.1-07). See Exhibit 2 for examples of an
observed release by direct observation.
For the ground-water pathway, an observed release by
direct observation may be documented with information
that hazardous materials have come to be located or
deposited in the aquifer of concern (OSWER Directive
9345.1-07).
For the surface water pathway, direct observation to
establish an observed release can be documented by:
• ^*«*»"g ha7ardf>m TOfatym*^ fftfrina rtu» vrftrr faftjy
through migration or knowing they have entered
through direct deposition;
• Natural fl"o*pflg of a source area so that hazardous
substances come in direct contact with the water in
this case, the presence of a hazardous substance
significantly above background prior to flrn^int
must be demonstrated (OSWER Directive 9345.1-
07). Historical data may be sufficient to document
flood levels, the presence of a hazardous substance,
and its direct contact with flooded waters;
• Advene effects (c£, fish kiD) associated with ihe
release of a hazardous substance to surface water.
Note that inference requires extensive
documentation and verified attribution (OSWER
Directive 9345.1-07).
For ihe air pathway, direct observation may be
established by demonstrating adverse effects from a
release (OSWER Directive 9345.1-07).
Observed Release by ChenienJ Analysis
An observed release can be documented when samples
from the media of concern exhibit contamination
significantly above background levels, and the
contaminants are attributable to the source. Since
concentrations of contaminants usually decrease with
-------
Exhibit 2: Examples of an Observed Release
by Direct Observation For
Different Media
• Ground* water pathway-Hazardous
substances placed into an old quarry where
the water table has rises above the level of
the deposited materials.
• Surface water pathway-An impoundment
leachate seep seen catering a stream.
(Collect a sample from the leachate to
documeat hazardous substances) Also.
effluent known to contain hazardous
jqKfjaii^f (through tinpifttTf) seen entering
a surface water body.
• Ait pathway~A field logbook entry and
photodocumeaiatioa of » dust doud
originating from a tailings pile. A sample of
the fine particulate matter from the pile
showing the presence of hazardous
substances will verify the release (OSWER
Directives 9345.1-05 and 9345.1-07). ____
distance from a source, sampling near sources wflj belter
establish an observed release and attribution (Guidance
for Performing Site Inspections Under CEKCLA,
September 1992, OSWER Directive 9345.1-05). At a
^pimtiin one validated sample and a background level
are required to document a release, even if earlier or
later sampling fails to show a release. Varying results
could be due in part to intermittent releases (OSWER
'Directive 9345.MJ7).
To document an observed release by chemical analysis,
the foBowing criteria must be met (except for
radkmudJdcs, which are 't*"?n source tlKMiH be tawptcd It is p
to select background well(s) outside the influc
source and in the same zone of the same aquii
evaluated. Cross-gradient or upgndient bat
sample locations are used when flow gradient infi
is available. (Ground-water 0ow gradient infon
not required for HRS scoring purposes.) Estabii
observed release in the ground-water pathway
further complicated by uncertainties about grout
flow direction, and any resultant uncertain!
background I*MJ attribution. Caution should be i
regarding the use of wells that are dose to th
determine background levels. For example, i?»"
impoundments could interfere with natural groui
flow. Pumping also may affect ground-water <
and plume movement. If available, pumping
nearby wells (mctoding those sampled) may se
useful source of mformatioa for addressing botl
comparability and contaminant effect. Note: 1
well may not necessarily be used to documei
contamination of targets. For a target populatio
TOpn should be documented ******> a
water well
The characteristics of suspected y^a'n'ff^qti u
water should be considered when selecting
locations **if 4ffM^** f*««n ^«»ii««»»»5 in Bound w
not be evenly dispersed. For example, oils and
substances lighter than water (fight non-aquea
liquids [LNAPLiJ) tend to float on top of the wti
Contaminants heavier than water (dense non-
phase liquids (DNAPLsJ) sink to the bottom of i
column (OSWER Directive 9345.1-07).
-------
Surface Water Pathway
Aqueous, effluent, sediment, and tissue samples from
sessile, benthic organisms are used to document an
observed release to the surface water pathway.
Generally, at least two samples (aqueous or sediment)
are required for documenting an observed release in the
surface water pathway. They are: a background sample
slightly upstream of the Probable Point of Entry (PPE)
for contaminants from the site or source; and a sample
at or slightly downstream of the PPE. Exceptions to this
two sample minimum requirement are when: 1) the
surface water body originates at the site (no upstream
background exists), 2) multiple PPEs east, or 3) tidal
flow easts. In the first case, one sample may be
sufficient to document a release. In the second case, it
nay be advisable to sample upstream of each PPE. In
this case, sampling is necessary at the PPE or
downstream of each PPE to establish an observed
release. In the third case, background data may need to
be collected inside and outside the tidal area.
Aqueous samples may be used to document current
releases to a surface water body. A preferred way is to
collect the downstream sample first, and to collect
aqueous samples before sediment* to avoid the
introdwtMHi of any ^^y^migt1*** not associated with, the
site or i*tfrm Aeration of a sample should be
minimized to prevent reducing the concentration of
contaminants such as volatile organic ^h*1**^**
Seasonal and other potential variations such as irrigation
and flooding should be considered when sampling inf****
pathway. Deep, slow-moving surface water bodies often
exhibit some chemical or thermal stratification.
Stratification can occur where two streams converge.
Additionally, the absorption or *t^"t"M> of substances is
affected by stream movement, and depositkmal
conditions vary wkhin the rifBes or close to stream edges
(OSWER Directive 9945.1-07).
Sediment samples may be iwf to document historical
releases to a surface water body. Ideally, the
characteristics of the ttnprctrd footaminani(s) should be
known in order to select the best sample medium,
location, and •"•>pK«| method. Often, sediments are
scoured and deposited in beads of streams and other
flowing surface water bodies. Sample from like areas
(e,g, inside bend deposition areas) for comparability.
Grain size, organic content, and structure can affect
adsorbanee of substances to sediments, possibly
introducing bias to the samples. For example,
trichloroethvtcae (TCE) could adsorb to certain particles
(OSWER Directive 9345.1-07).
When possible, differentiate sediments from soils,
especially when sampling along the edge of a water body.
Note that in arid or semiarid locations (less than 20
inches mean annual precipitation), 'sediments' include
areas with intermittently flowing waters as well as
contiguous intermittently flowing ditches. Contamination
in these areas should be evaluated in the surface water
pathway (40 CFR Part 300, App. A).
Tissue sampling can pose challenges for comparability
because of differences between members of the same
species, differences between species, variations within a
study population, species mobility, and tissue
differentiation. The target sample species should be
examined for type of organism, approximate age, gender,
size of population, migratory nature, and seasonal,
feeding, spawning, or other periodic activities that
influence concentration of substances within the organism
(OSWER Directive 9345.1-07). Due to the potential
ifffr|y samples, »i
are more readily used to 4fffw"*itf
instead of an observed release. & is prudent to coded
tissue samples in concert with other sampling activities
when documenting an observed release.
For tissue sampling, both the rationale for the tissue
selection and the accuracy of measurement should be
Edible tissues from
organisms are preferred for HRS evaluation. (Generally,
non-sessile bffBt^ic organisms, ^"fvtK amphibians, ""*
reptiles should not be used.)
Note that the surface water pathway requires sampling at
or beyond the target to establish actual contamination; in
contrast, the ground-water pathway requires sampling at
the target.
At Pathwa
It is important to consider temporal variability in air
sampling because large variations in substance
concentration can occur over a very short time.
characteristics depend upon topography and
changeable atmospheric conditions, including
temperature, pressure, wind speed and direction,
precipitation, and atmospheric stability.
Monitoring wind direction is important in documenting
migration of hazardous substances from the source.
Wind roses, which detail the percentage of predominant
wind direction, should be developed for the sampling
period to document shifts in wind direction (OSWER
Directive 9345.1-07).
-------
For die air pathway, an air sample may be used to
document both an observed release and actual
contamination of targets within a certain radius from the
source. An observed release by chemical analysis can be
difficult to establish for the air pathway because of the
challenge of obtaining comparable and verifiable samples.
Under the MRS, EPA evaluates outdoor ambient air
conditions only; indoor air samples are not evaluated for
this pathway (OSWER Directive 9345.1-07).
Partial Attribution tad Multiple Source Sites
from t}»g site
may originate
from ooo-poiat sources such as pesticide application, and
from products y*ita'ii't>ff lead.
»*-"** '**if "T*1 other
often pnrynf For frt^it
background levels is especially important
when attributing hazardous r «aces to varied sources.
Background and site sample data should be from the
same medium "T'"g fimii«> sampling and analytical
methods* P^<^rgnr*irt^ ^""p^r* 5r"^iH be collected from
outside tfr* infltffwf of contamination from fh^* site
under investigation, but do not have to be free of
f^-f |-tmi-i^f «*f-} fof purport of tftT*r>titff> The data need
only support that the sample conceatration is beyond an
established background level The location of other
ppt-»-iri-4 sources should be thoroughly reviewed and
documented so that the appropriate background umpBng
locations cam be sckcted Background levels for
ubiquitous substances should account for local variability,
several samples may be required to establish the
background levels (OSWER Directive 9345.1-07).
Where attribution is questionable, sampling should be
done to gather analytical data demonstrating that the
~ V u««* r***1'«lly
t« fhe cite
Cootaminatioo from site* sometimes can be isolated by
identifying bazardoos substances unique to the site under
investigation. Special analytical services and dose
evaluation of data may be required to identify these
hazardous t**frirwrfT li*^T*t*H°f about thf *jf existence of a *y***<^iof*'"'yt*nB ptftdwt.
if Off transformation product is *^tfV a hazardous
substance. In these cases, the observed release must be
documented by chemical analysis (OSWER Directive
91*5.1-07).
Tf-(iKfcjf-natif|-t products are *"*M>^*^^t found "HiT" a
hazardous substance is changed in the environment by
physical, chemical, or biological processes. Most
transformation products at hazardous waste sites are the
result of degradation (OSWER Directive 9345.1-07).
la order to attribute the parent substances and
transformation product to the site, the presence
transformation product in a sampk at a level
above the background level(s) should be documented.
-------
I The following references may be useful for documenting
parent substances and transformation products:
• Site-specific studies on the transformation process by
qualified research organizations (e.g., US.
Government agencies, universities)
• Technical reports on transformation from EPA's
Office of Research aad Development
• Databases containing EPA-reviewed information
• Articles from peer-reviewed journals
• Textbooks on soil, environmental microbiology,
biotechnology, and biotreatmeat processes and their
effectiveness (OSWER Directive 9345.1-07}
For determining an observed release, conditions at the
site must be conducive to, or must not impede,
transformation, and at least one source must be able to
release the substance to a pathway (OSWER Directive
9345.1-07).
RadloBudide Sites
The criteria for documenting an observed release by
direct observation apply to radionudides. Table 7-1 in
tic Hazard Ranting System. Fowl Rule provides the HRS
factor categories that are evaluated differently when
radionudidcs are present (40 CFR Part 300, App. A).
Radionudide sites are divided into three groups for
documenting an observed release by chemical analysis:
Radionudidcs that exist "^rurally »*d ubiquitous
Man-made radkmuclides which are not ubiquitous
• External gamma radiation (for the soil exposure
pathway onry). For gamma radiation, measure the
exposure rate at one meter above ground, (for
more information, refer to the fact sheet
Establishing Background Levels, September 1995,
OSWER Directive 9285.7- 19FS.)
Observed releases from a combination of radionudides
and hazardous wastes (mixed waste) should be
documented separately. Establishing an observed release
requires;
• Identification of the radionudide of concern and the
physical and chr-mical properties of the radionudide;
• On-site and background levels for that radionudide;
and
• Detection i*"*** for !kf radionudide.
Specific requirements for establishing an observed release
for each of the three groups of radionndides can be
found in Section 7.1.1 of the Hazard Ranking System,
ruul ffiife (40 CFR Part 300, App. A).
Summary
Documenting an observed release requires evidence that
the concentration of t^tf **yardf>wt ^vtmarr of concern
significantly exceeds the background level The
hazardous surntanrr must be attributable at least in part
to the site under investigation (except for sites with
ground-water <*fi
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive 9285.7-18PS
P694-963312
EPA/54Q/F-94/029
September 1995
Establishing Areas of Observed
Contamination
Office of Emergency and Remedial Response
Quick Reference Fact Sheet
Abstract
This fact sheet addresses the use of analytical data to ctfiblifl* areas of observed contamination at hazardous waste sites
when evaluating the soil exposure pathway under the Hazard Ranking System (HRS) (40 CFR Part 300). The data may
also be used to evaluate hazardous waste quantity for some HRS source types. The soil exposure pathway is evaluated only
if observed comamuiatio* is cstabfahfd based oa analytical data. Factors that are critical to determine observed
i-irwpit*rafM?** levels of <**"»** »»ymit« and the area of **?r>*M1iiflat*ini- An integrated
approach under the Superfund Accelerated Cleanup Model (SACM) should be considered when planning the sampling
strategy to fiTiHisH observed i
Introductioo
The Hazard Ranking System (HRS) Fmal Rule (40 CFR
Part 300* App. A) cttihlhhft general criteria to
document an observed rebate ol hazardous substances to
media (e^g, ground water, surface water, air) and to
*fftC'int*iwT fffaifrvttf fOHtmniMtfifit m the Mil exposure
pathway. An observed release is based on evidence that
""»»«•""•»• have migrated away from a site through a
•^^jijflpi in ','
-------
Figure i: Flowchart for Establishing Observed Contamination
STAflT
* Direct observation dees not apply to tt*e to!
expoeure pathway
OSWEA Mueft* 0M5LI-07
include ooOettiou of the aecessary site information far
development aad use of SoflScreeuiaf Leveb (SSLs) lor
use during the Remedial Inveatiajarion/FeaiibiBty Study
(RI/FS). It is appropriate to use data gathered during
the SI for the RI. especially to develop the Conceptual
SiteModeL
SSLa are not appropriate for use at the SI stage because
the objectives of the SI and SSL* are different The
caac* or *hot spotT contaattnation, Ik is ant intended to
a risk
OB the feadts of the SI. EPA
oo the NatKMal Prioritie* Lot or dbwoaboi from
further Suoerfood coaaideration. SSU an osed ta the
RI to screem out poteaoaJ
areas for
the Compreheacive
«ad Liability
Act (CERCLA) (Draft Soil Jcrwwaj
Deomber 1994. OSWER Dtrediie 93514-14FS).
EatahUahfa* Obserxd
The soil exposure pathway can be evaluated only if there
are documented areas of observed cootamiaaiiotL The
source samples are- compared to a background level
Moat fHfiF**t *"*"iiT of tflffl, but leachate. waste.
CEROA, September 199% OSWER Directive
05).
The fottowtag criteria must be oset at order to document
observed conrimmtrinai by ttoaical aaaiynt;
The release of the hazardous
least paroaOy attributable to a
sBustbeat
at the site.
The tfturtf *****ptf coakceaCtatioat I'IT* be
than or equal to the appropriate and properly
-------
• If the hazardous substance of concern is nojader both the types and locations of targets
cations. Establish as area of
dose to targets as
Evaluate targets under the HRS 'resident popu
png
threat* when aa area of observed contamination ies
within 200 feet of a residence, school, day are center, or
workplace, and also lies on the property. Evaluate
sensitive environments and resources under the HRS
population threat* only at the area of observed
i ies wkhia the boundaries of a terrestrial
or resource. Evaluate targets
beyood 200 feet but wkhi» one nule travel distance of the
the HRS •nearby
threat" (40 CFR Part 300, App, A). Collect
> deeper thaa two fed below the surface.
impenetrable cover osateriat (eg, asphalt, concrete) over
aoy poctkx oc an area of observed
(OSWER Directive 9J4SJ-07).
appropriate
sources. Obtain source
surfiaal
is not Smiled to soil, sampfiag of other
aa teachate or waste, should be
nay be attributed to a ske by collecting
fraround samples outside the influence of
aapks from locations where the
v? uupcucd to have been deposited (e.g..
;onf am.'tufi*i. «oii al>.rty the flood plain of a contaminated
surfcct ?atr. H>*K'J (OSWER Directive 9j45.i^jf7),
Exaibti i. ii.'g^*sl5 Appropriate locauons for background
samples by ii^y/^r "vpe.
vVa>te Quantity by Defining Areaj of
Observed CaBtaaamattoa
The following criteria are important to consider when
evaluating the soil exposure pathway under the HRS:
• The soil exposure pathway can be evaluated only if
there are areas of observed contamination.
• Target values are «««igf«*H based on the 4»y*ar"y of
targets from the area of observed contamination.
• Waste quantity ^v* be calculated ba
-------
Exhibit 1: Possible Location* of Background Samples for Areas of Observed Contamination
Source
Contaminated sol
Tanks/Drums filled with contaminated sol
Tanks/Drums containing liquid or solid wastes
UndfiM*
Pies'
Surface impoundment (liquid)'
Surface impoundment (sludges or backfBed)'
Background Sample ^
Soi in vicinity of the site*
Same as for the soi at the site
Background Is zero
Soi in vicinity of the site
Sol in vicinity of the site
Aqueous samples from vicinity of the site;
background may be zero
Soi In the vicinity of the sfte
Review on a site-specfflc basis
^. ^.. _M-M^_ -fcl t tmmm A j»^ IW« AjdWMfSMAl su-kn«ilrlA#*tt>u%si
990 seuKjio 9. • ••» w-& w> w».«-<. «»~»»~w^ —. -— _- —
•For these source types, the indicated sample is IBceiy to be the most appropriate background.
Note: Do not era/cats inoicr containers.
Figun adapted from Highlight 9-1 of OSWEft Directive 9345.1-07 (p.
in Highlights 9-3 through 9-6 in OSWER Directive
9345.1-07).
Points and linear strips of observed ?"«*•««'"^rkr may
be evaluated as areas of observed contamination for the
soil exposure pathway, even though it may not be
possible to delinratr an actual "area,* For sous, one
f*fnf jp»s«yrj«f mnple Jrnctft a point of observed
f«Mi^ai»iii*yri*f«i Two rr"1T?miff'f**><* soil samples denote a
linear strip of obse
Either a point or
a linear strip can be used to identify otler targets and to
demonstrate a harardout waste quantity vane greater
than zero. When possible, however, esuboshtng i
of observed
as waste piles, observed
is sufficient to
of observed
For non-soil sources,
at a
establish the
contamination.
Bated so3, an area of observed
For,,
may be inferred within sampling locations that meet the
observed contamination criteria and have been properly
'f^^iHHgntffd Select ssmp&ng locations *^*,f will allow
efficient use of inferred areas of observed contamination.
It is likely that with this strategy, more targets may be
identified with fewer samples. Consider the following
when inferring an area of observed soil contamination:
Density of sampling points
Physiography
Topography and drainage patterns
Transport and deposition of hazardous substa
re***""**"*""* in *he dowagradient portion of a
wea-defined migration route
Data derived from other investigations (e*.
geophysical surveys)
Sofl staining
Stressed vegetation patterns
Aerial and ground photography
Infrared ntfty*** imagery indicating Mil anomalies
Use of composite staple I nmpki within one grid
cefl may be combined; vertical sampira from a single
point within a zero to two-foot depth may be
combined. In general, avoid using non-grid
horizontal fotnpositt *""pVs to infer areas of
observed ^-*««"HttM> (OSWER Directives 93*5.1-
05 and 9345.1-07).
-------
Additionally, consider UK nodes of contaminant
transportation and deposition when inferring an area of
observed contamination. Contaminants dispersed by air
would be distributed differently than those transported by
water. Avoid inferring an area of observed
contamination between soils in the floodplain of a
contaminated surface water body and those soils
contaminated from other modes of transportation and
deposition.
Determining Levels of Actual Contamination
Finding positive evidence of observed tTHttlniiMfkni is a
prerequisite for evaluating actual n7Mtari'inir""i si
targets. Actual fffHtyy^iuftOB at Ti'rrft v"f?ftrpf a
likfIirMK"f of exposure to hazardous substances. Note
that the presence of contamination it targets is not m
sufficient to rtftHu*1 observed **Mt*rm"'yT*Mi or
The level of actual contam
is determined by comparing the release sample
ftfQffmtf$tfaQ to tirtftttrfr-tffffif'f benchmark values,
where applicable (OSWER Directive 9345.1-07).
Samples taken to find observed
an
ontamination can be
and lo include one or more targets (dual purpose
pGng). Analytical data with appropriate tod
deqnate quality assurance/quality control (QA/QQ are
needed since benchmarks are expressed in coaceotratioa
•***•*« Analytical data "TUTU" provide definitive
Hfr»ntifr-«riq«i of the M""*"^ tuhstsncrt (OERR
Directive 9355.9-01).
Grid samples may consist of grab samples (from a single
following coaditioas apply:
• Samples are obtaiaed frost a depth of two bet or
less from the soarce or sol:
is not covered by HDpcrvmis i
• T1»eavmilabkanar>tkal
-------
Determining aj| faff* of Observed ContlJauiatiQil for
Other hafl Sol
Section 5.0.1 of the HRS states *..Jor all sources except
contaminated soil, if observed cotuamiaatioa from die
sate is present at any sampling location within toe source,
consider that entire source to be an area of observed
contamination.* For example, a dry, buried, or backfilled
fwfacf ipfrv"'n/^"*^iif should be evaluated aj v area of
observed contamination. An area of observed
contamination is lififTVHiifnfd as follows?
• For dry surface it
treatment units—the surface area of the source is
used;
For piles—die land surface area under the pile is
used;
For **"fc«_ drums, **"* other nttfai Try—tin? volume
of the container is iped.
Assign a source hazardous waste quantity vahie for each
area of observed coarauuuatioa. Sam the source
hazardous waste quaa^valoesassigBc4 to each area of
observed contamination to detemi&e the hazardous
waste quaatity factor vane. Table 5-2 » the J&IS
Jtulr provides equations for asogaiag hazardous waste
quantity values lor aO types of sources hi the soil
re pathway (40 CFR Part 300, App. A).
Site
at Of 4i ttm&DC? OK
batteries occurred at a scrap
surrouaded by a
mitigated severe soil
OK
yard, which was
property bouadaries of the soap yard. However, EPA
had BOC sampled the residential area. Eleven, residences
were situated oa a tract adjacent to the site; six
he scrap yard boundary. The
:ifv of the rs*iJcntiaI area raised the possibility
inhabitants rauld be exposed to lead from sources at
•scrap yard A zva/ of the area revealed that lead cool
be deposited on the residential tract from surface runoff,
dispersion of particulates from wind, and vehicular
movement EPA hypothesized that these modes of soil
transport created an area of observed contamination in
the residential tract.
EPA sampled the soil at each residence and at border
areas to demonstrate attribution of lead contamination
aiyi contiguity of the T""Tn"iin^frd area. Background
samples were collected at nearby areas that were outside
the influence of sources at the scrap yard. In an
industrial area, it is always possible that background
conceatratioa is elevated from various sources. To
account for this possibility, seven spatially divergent
sample locations were selected within the background
area to ensure provision of at least one representative
background level Soils in all sample tonrtmtf were
classified so that release samples could be compared to
backgrouad samples of similar soil composition All
samples were collected within six inches of the ground
surface. Analytical results from the area of suspected
lead mntamhiartmi revealed lead coocentratiom ranging
from 740 to 12*00 mg/kf (see F%ure 2). Lead
coecentratioas from the background area ranged from.
448 to 1,410 ag/kf. Observed and actual * "'
concentrations greater than or equal to three times the
highest background level, aad the lead was attributable to
the scrap yard.
Data from local and regional health agencies indicated
that the highest backgrouad level, which k away the
oae selected far HRS evaluation, was elevated. Because
this was the case, the ****ftkff of **ifrffifTt with V^MI*
decided to examiae the background data more dotery.
Accordiag to data from the health agencies, backgrouad
levels of lead ia area soils ranged from 500 to WOO
ntg/kg. Statistic*! analysis of the background levels
showed that the highest vane, 1,410 Bff/kg, was not aa
outlier, but did fie well above the upper quarale of the
data distribution. EPA suspected that the highest
backgrouad value was aot a repceaeatative level, aad
considered using a tfathriralry derived coacentratioB.
The use of the mean coaceatntioa was immediately
rejected because it was subject to inflation from the
-------
Figure 2: Lead Concentrations In Residential Soil* Related to Various Background Levels
A - Levei i 8encrmaric
8 - 3X Lowest
C - 3* SecofXJ Highest
0 - 3X Hignesc
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Res < dene
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive 9285 7-tgFS
PB94-963313
EPA/540/F-94/030
September 1995
Establishing Background Levels
Offic* of Emergency and Remedial Response
Quick Reference Fact Sheet
Abstract
EPA uses the Hazard Ranking System (HRS) (40 CFR Part 300, App. A) to evaluate Superfund sites to be proposed oa
the National Priorities List (NPL). Based OB the HRS, an observed release or observed contamination is established when
contaminants that are yptffiryitly above background levels have migrated away from a site through environmental media.
This fact sheet dfstrite* how to determine background levels for each migration pathway, and emphasizes the necessity
of strategic, efficient sampling, which is particularly important in light of conducting integrated assessments under the
Superfuad Accelerated Cleanup Model (SACM).
Introduction
The determination of background levels under the
Hazard Ranking System (HRS), usually by chemical
analysts, is necessary to evaluate an observed release
(Hazard Rooting System, rand tote, 40 CFR Part 300,
App. A). Background levels are key in •maMUK^g
attribution of •^M>*v"'t*»« where multiple sources or
contaminant coatributon exist Additionally, an
integrated «««»r>^n strategy should be considered when
determining background levels, as appropriate.
A background level k "the
of a
substance that provides a defeasible reference point that
can be used to evaluate whether or not a release from
the site has occurred. The background fcvel should
the medium of concern for the environmental setting oa
or near a site. Background level does not necessarily
represent pre-release conditions, nor conditions in the
absence of influence from source(s) at the site* (Hazard
Ranting System Guidance Manual. November 1992,
OSWER Directive 9345.1-07). Background levels do not
have to reflect pristine conditions.
Obtaining suitable background fampfcj ftn be
"fryn*"jp*'g because of varying media compositions and
potentially false assumptions Tfs*r^*i>s ambient
fffM'tfofT Consult the Guidance far Performing Site
Inspections Under CERCLA, September 1992. OSWER
Directive 9345.1-05, for information on
background levels.
A umpHag strategy for an integrated assnuneat under
the Superfuad Accelerated Cleanup Model (SACM)
should be considered, and planned if appropriate. The
elements deemed accessary for aa integrated assessment
depend on the particular aceds of a specific site and
could involve similar, additional, or sughtly different
activities compared to traditional removal or remedial
ijfi<£ ^«*^«*y>»Y*t? (For more information, ttt Integrated
Removal and Remedial Site Assessment Investigations,
September 1993, OSWER Directive 9345.M6FS.)
The data gathered from the Site Inspection (SI) may be
useful later in the overall site strategy, especially where
it appears that a response action may be required. In
such cases,, site managers may consider a broader
-------
sampling strategy. For instance, such efforts might
include collection of the necessary site in/bnsatioa for
development and use of Soil Screening Levels (SSLs) for
use during the Remedial Investigation/Feasibility Study
(RI/FS). It is appropriate to use data gathered during
the SI for the RI, especially to develop the Conceptual
Site Model.
SSLs are not appropriate for use at the SI stage because
the objectives of the SI and SSLs are different The
objective of the SI is to obtain information oa 'worst
case* or 'hot spot* wM»»ammar"pi It is not intended to
be a detailed analysis of the extent of fmit*tnm*tvu, nor
a risk assessment Based on the results of the SI, EPA
decides whether the site qualifies for possible inclusion
on the National Priorities List or elimination from
further Superfund consideration. SSLs are used in the
RJ to screen om potential f4?***am'f?ft*s and exposure
areas for remedial action under the Comprehensive
Environmental Response, Coxnpensatica, and Liability
Act (CERCLA) (Draft Soil Screening Guidance.
December 1994, OSWER Directive 9355.4-14FS).
The Agency for Toxic Substances and Disease Registry
(ATSDR) should be consulted when there is the
potential for fcy»«« exposure to toxic substances. The
approach for these sites should include data
for the human exposure information that
ATSDR uses to determine if a health advisory is needed.
ATSDR also uses this data in the preparation of a public
h^frftpi ^yctm»nf which is required within 12 months of
proposal to the National Priorities List.
Usually a few background samples are necessary to
evaluate an observed release and attribution for HRS
purposes. The selection of strategic sampling locations
is critical to the soceets of the SI which a a fimited-
scope biased sampung event. When feasible, evaluate the
benefits of tampfing at specific locations and assets the
validity of availabk data to meet SI or other integrated
assessment objectives. The data quality objective (DQO)
process provides a logical framework for planning
multiple field investigations, thereby fulfilling the
integrated site nw*iif^f* goal of cross-program response
planning and allowing optimal cross-program data
usability. (See Data Quality Objtctivts Procet for
Supafitad. September 1993, OERR Directive 93S5.9-01
for further details on the DQO process.)
Background Level Determination Without Sampling
Establishing a background level requires determining the
concentration level of a hazardous substance. Sampling
is not always necessary to make this dctenainauon.
Some man-made hazardous substances (e.g., pesticides,
chlorinated organic solvents, except drinking water
chlorinatioo) can be attributed only to a contaminant
source. The presence of these substances in the release
is yfR<*»*pf to show fMrtyuBiffMyi' a background sample
is not needed (OSWER Directive 9345.1-05).
Sampling may not be necessary for certain sample
locations, such as wells, which may serve as their own
background (OSWER Directive 9345.1-05). A release
can be demonstrated when historical data from a
contaminated well or intake show that it was previously
Detailed historical
data are useful to define encroachment of a contaminant
plume. Often, historical data are available for wells and
surface water intakes at industrial sites or municipal
water facilities which have a regular monitoring program
(OSWER Directive 9345.1-07). For example, a ground-
water well or surface water intake may have associated
In some cases, published background levels may exist
that can be applied to a specific site. The following
published data sources may be consulted:
• Background sample results from other nearby
CERCLA site investigations
• Local surveys by other Federal or State agencies
(e*. US. Geological Survey (USGS), Soil
Conservation Service (SCS))
• University studies
• Tables or databases with natural concentration
ranges and averages in local or regional sous
(OSWER Directive 9345.1-05)
Published data may be useful when selecting background
Mmpifag hyrpt^f if pubushed data are used, multiple
sources of information help to support a comparison
determination. The use of background level data without
sampling (e^, published data) may be acceptable for SI
or HRS scoring activities. The analytical package for the
published data should be obtained whenever possible
(OSWER Directive 9345.1-05).
-------
Published information may not be appropriate to use ia
many cases. Published data may not account for regionaJ
variations or unique site-specific characteristics (OSWER
Directive 9345.1-05). Background levels may vary with
regional and locaJ geology (c.g^ ore veins, soils with
naturally high metals contest). It may be difficult to
demonstrate comparability using published data because
of the difficulty of duplicating sample method and
analysis. For comparison, published or existing data
should be generated under quality assurance/quality
control (QA/QC) measures equivalent to EPA
requirements.
Considerations for Selecting Background Samples
Under the HRS, the collection of background samples
usually Is necessary for the following reasons:
• A release cannot be determined by direct
observation;
• The source CTM*V*^T of fruit!!** initfrt soil;
• Historical rti** are unavailable or insufficient;
• The substance of interest is ubiquitous.
Under the HRS, the highest background sample
concentration generally can be used as a background
level In a non-industrial area, avenge background
concentrations may be used when efficient background
f^mpifj are collected ia a relatively homogeneous
environment, and there are no alternative sources of
contamination nearby. Qualified analytical data may also
be used for background level determination (refer to the
interim fact sheet Using Qualified Data to Document an
Observed Release, July 1994, OSWER Directive 9285,7-
14FS, for more information). At least oae background
sample per pathway or medium of concern should be
collected. Preferably the samples should be taken
outside the area believed to be influenced by the site.
However, it is often necessary to collect more than oae
background sample.
Determining the locatioa and number of background
samples depends upon, the following factors:
expect
present at the site and
the following factors:
Availability yd quality of •**«**»> information
analytical data;
Objectives of the investigation;
Site hypotheses to be tested;
• Media variability;
• Size of the lite, oumber, and type of sources;
* Pathway-specific considerations (e.g., geologic
formations, {ypes of surface water bodies); and
• Other potential sources of contamination in the
vicinity of the site (OSWER Directive 9345.1-05)
The number of background samples collected may also
depend upon the type of investigation performed. At
timf^ a p*m*a™>fUfA background sample M*t he
compared with a release to demonstrate that the site
under investigation contributes at least part of the
contamination in the release {OSWER Directive 9345.1.
05).
In aD evaluations, release and background samples must
be similar for comparison. Factors which determine
sample similarity include location, type, depth, "»«*frfB.
sampling method, preservation, ^"^ling, *«mtiM» gnd
weather fMKHtk*** during sampling.
In some situations, collection of a comparable
background sample is not possible (e.g, when there is no
surface water sample similar to an isolated pond, or
when a surface water body originates from a spring)
(OSWER Directive 93*5.1-05). If background sampnag
is not possible, substitute published data, as available.
When collecting samples at a site, the activities of the
investigation team should not introduce any
non-attributable contaminants to samples. !
methodology can minimiae these potential errors.
Variability introduced by sampling methods can be much
greater than that introduced by the analytical laboratory.
When feasible, consider variability factors for each HRS
pathway under javnatjgarion The following are specific
considerations when selecting background samples for
each HRS pathway.
Ground-water Pathway
A direct observation of a release to ground water can be
documented if it is observed or known that a hayiHoBi
substance has been deposited, or the source lies below
the water table of the aquifer of concern (tg, injection
well, buried waste). Therefore, a direct observation of a
release to ground water does not require f^uWthf *
background level, but the presence of a M**HT"*
substance in the release should be documented by
manifest data or chemical analysis (OSWER Directives
9345.1-05 and 9345.1-0r7).
-------
When establishing an observed release to ground water
by chemical analysis, background samples generally are
needet Background samples should be collected from
nearby wells that are act expected to be influenced by
the source of contamination or by other sites. If there
are other sites or potential local sources of ground-water
i additional background samples should be
fontant'i
collected where possible to differentiate their
contribution from that of the site under investigation
(OSWER Directive 9345.1-05).
Similarity of Aquifers
Aqueous release and background samples must be
collected from comparable zones (ej* saturated zone) in
the same aquifer and. where possible, should be collected
during the same sampling event Interconnected aquifers
should not be considered as one aquifer when comparing
57^i|»u« (or an observed release. When collecting
background samples, it is preferable not to use «a««pig«
from a well screened in two or more aquifers (OSWER
Directive 9345.1-05).
When feasible, evaluate aquifer characteristics before
selecting weOs for fai^pi'ia^ especially in areas of
complex or variable geology. Be aware of the existence
of mines, faults, or other aquifer intrusions which may
affect sample representativeness. (Note: Section 7.1 of
OSWER Directive 9345.147 provides detailed guidance
on determining aquifers and aquifer boundaries.)
Note information on ground-water flow direction if it is
known or can be easily determined. This information
may also be useful in selecting monitoring weU
installation locations far Expanded Site Inspection (ESI)
and Remedial Investigation (RI) work. Information on
flow direction should be obtained by wmf piezometers,
by «>««i»t"««fl static water levels in existing weOs in the
same aquifer, and by using data from pubGshed reports.
The well used for background sampEag should be beyond
the influence of the site (OSWER Directive 9345.1-05).
Comparability of Well Sample*
Samples from any two wells can be considered
comparable if both are collected from the same aquifer.
Filtered ground-water samples should be compared to
filtered background samples; uafiltered ground-water
samples should be compared to uafiltered background
samples. Ideally, well completion techniques and usage
of background wells should be similar to those of the
well under investigation. Sampled wells generally should
be screened at similar zones within the same aquifer,
depending on the site hydrogeologic setting, because
different depths may nave different contaminant levels
and water chemistry. Depth should be measured as
elevation relative to a reference (e.g, mean sea level)
instead of below ground surface for data consistency.
Where possible, duplicate purge parameters and method,
sampling method, and sampling equipment for ail well
samples. If possible, sample release and background
samples on the same day, but preferably not more than
three days apart (OSWER Directive 9345.1-05).
In cases where a background well is not available,
consider the possibility of sampling a spring before it
reaches the surface by inserting a pipe or well point near
the location where ground water discharges at the spring
(OSWER Directive 9345.1-05). Sampling data may be
supplemented with applicable published data. Springs
may be used for background «""pK«ig of surficial
aquifers only.
Surface Water Pathway
Direct observation of a release to surface water may
documented if material «w»*»i««i«g « ^Turdous $
is seen entering surface water; is known to have entered
surface water through direct deposition; or is present in
a source which is in contact with surface water through
flooding. Direct observation of a release to surface water
eliminates the need for background sampling, but the
presence of a hfl^vdom "f^ttfoe in the release should
be documented analytically. A background sample is not
required when, sampling an effluent discharge from the
site into surface water, because the effluent is considered
a direct observation.
In non-tidal surface water bodies, k is preferable to
downstream to upstream. Backcround sediment
. from a h)fntwi comparable to rhit of
the release (e*, fine vidimrmi from quiescent zones)
(OSWER Directive 9345.1-05). Generally, sediment
samples are preferred over aqueous samples for
evaluating the surface water pathway because sediments
are more likely to retain contaminants. In general,
aqueous samples might represent current release
conditions, whereas sediment samples might exhibit
historical release conditions.
When it is necessary to collect biological samples,
background samples from essentially sessile, bent
organisms (e.g., sponges,'oysters) can be compared
-------
similar (same specie)) tissue samples. Organisms
selected for background tissue sampling should be the
same gender and approximate age, wherever possible, of
those selected for release tissue sampling (OSWER
Directive 9345.1-05).
Special Considerations for Tidal Water Bodies
Where appropriate, determine the need to collect
aqueous and sediment samples when the surface water
body is tidalry influenced. One approach for background
sampling is to collect outside of the zone of tidal
influence (this can be gauged by the level of the highest
tide). It is possible that tidal flow could pick up
additional sources upstream. The effect of the tidtt on
concentration T^*viM be
(Upstream concentrations would be highest during the
rising tvte ai>4 lowest at failing tide.) CofTttdrr fHhrripg
release and background samples at the same tidal level
(OSWER Directive 9345.1-07).
Comparability of Water Bodies
Consider collecting release and background samples from
the same type of water body. Flow characteristics can be
used to determine similar water bodies. For example, a
background cjjp*plp from a **"*n tributary ritffliM no* be
compared to a sample from a river. Physical and
chemical properties of the surface water (e^ tack of
inning in large, slow-flow segments of riven, physical
transport •»**'i«y«*'«f f^ y>
-------
direction during the selected time period, as well as ihc
average high wind speed for lie period. If wind roses
ar- utiT sd, try to determine the elevation for which the
wind rose was calculated; this elevation should be
representative of target exposure. Weather stations aad
airports may provide information on local wind direction
at ground level aad at various elevations.
Sftil KTPPSlirp
Because it is not possible to directly observe
contamination in the soil exposure pathway, soil must be
sampled to determine background levels. As previously
mentioned, there will be sites that appear to require
response actions (e-g., early actions). In such cases, site
managers may consider a broader sampling strategy.
Such efforts might include collection of the necessary
information for development of soil screening levels
(SSLs).
Establishing background levels in the soil pathway can be
particularly if thf hazardous
attributed to the site are naturally occurring; Where
possible, collect oa-site backgrouad soil samples from
surficia! soils not likely to be affected by the source. Off-
site backgrouad soil samples should be collected from
shallow soils which ideally should not be affected by
other sources and sites in the area. However, if there
are alternative sources of contamination in the area,
backgrouad levels should be measured to determine
contributions from them. When possible, sample release
aad background Tf'plfi oa the «v<* day or withia three
days. (See Highlight 9-1 of OSWER 934S.1-07 for
information oa backgrouad samples for aoa-soti sources
ia the soil exposure pathway.)
Carefully documeat location, depth, and appearaace of
aQ sod samples. If depths aad thicknesses of soil strata
vary with location, easure (hat release and backgrouad
samples are from a similar stratum aad soil type.
Samples should have nuLv texture, color, and grata size
(OSWER Directive 9345J-05). Grab samples (as
opposed to composite) are preferred Cor determining soil
contamiaatioa ia the SL Preferably obtain the
background sample from aa undisturbed, unfilled area,
because fill may have contaminants which are not
representative of background conditions. If a site is
located on fill, it may be necessary to obtain the
backgrouad samples from a similarly filled area (where
the fill U not considered one of the areas of observed
contamination at the site) (OSWER Directive 9345.1-07).
It is a recommended strategy to select more than one
background sample and location for the soil exposure
pathway. Avoid collecting background soil samples from
a drainage channel which receives water from off site
(OSWER Directive 9345.1-07). Where possible, collect
background samples from a higher elevation than the
sources to avoid the effect of potential surface drainage.
Avoid background sample locations that are subject to
airborne contamiaatioa from the site or other sources
(OSWER Directives 9345.1-05 and 9345.1-07).
Determining Ri< i^i imail Levels hi Industrial, Mining,
and Radioactive Areas
Industrial areas can pose a special challenge to
determining backgrouad levels. Ambient conditions may
include elevated yKTBt"*"**** of common contaminants
from sources not
with the y** Some common
r*Mitafm«i«tiff in backgrouad samples in
urban areas include:
• Metals in soils (e^, lead)
• Trichloroetheae (TCE) and perchloroetheae (PCE)
in urban aquifers
• Organic substances in harbor sediments (
Directive 9345.1-05)
In industrial areas, the investigator often needs to
document that a sampk is above background sample
variability. One approach is to determine where
potential alternative sources exist aad where they could
possibly interfere with release or backgrouad samples.
Because industrial areas are affected by increased levels
of frwitamtnanti and greater local vsnabuity, ^Q^PV™
backgrouad samples may be required to establish off-site
conditions. Be sure to collect a suffickat number of
samples between the ske aad all other poteatial sources
of ffi*t> intitiatifrti IB iy4ff to attribute ifcr incrfay to th*
site (OSWER Directive 9345.1-05). Ia general U is
inappropriate to average backgrouad samples ia aa
industrial area where more than oae type of industry
existed hcra1***
-------
sampling. Surface water may pass through the mined
watershed. Consequently, the nearest upstream location
away from the influence of the site may be in a different
geologic formation, with different water chemistry,
producing uncertainty about comparability.
When surface water in mining areas originates in the
source or when no similar upstream location exists, a
water body with similar physical characteristics (e.g^ a
similar stream on the other side of a mined hill) should
be selected for background sampling. The similar water
body should not be directly affected by the site.
OoHfyBt^ifiom in the vicinity of "»'"'"£ vitfi may be so
iiiiy elevated that published data may provide a
more reasonable background level
Mines are often located in areas with aquifers that are
highly fractured or influenced by «•'«* drainage yupn^^
In giMiinff areas, it may be ^i^kiih to find undisturbed
areas in which to locate ground-water wells and
therefore, difficult to determine ground-water
background levels. In such cases, it is preferable to
determine aa observed release by direct observation.
Mine tailings generally contain minerals and are
considered waste. Collecting background samples is not
necessary if tailings are analyzed and the mineral
concentrations are shown to be elevated well beyond
what "*u?h* be expected v"f**f natural conditions.
To sample sites with radioactive wastes, follow sampling
strategies similar to those for other hazardous substances.
Criteria to establish an observed release through
rhfnrtrV analysis for radioactive wfHff"1** exist for f^f
following three groups:
RadionucBdrt that occur naturally, or ubiquitous
man-made radionudides;
Non-ubiquitous man-made radioaucGdes; and
External gamma radiation (soil exposure pathway
only).
Some portion of the release must be attributable to the
sice. For each group, compare release concentrations
against known background radionuctide concentrations or
against detection limits for a sample medium. Section
4.9.4 of OSWER Directive 9345.1-05 provides details on
establishing an observed release for each group.
Summary
Thorough documentation of the locations of the
background samples and potential alternative sources is
necessary to assess the adequacy of the background levels
and to evaluate release and attribution. The benefits of
sampling at specific locations should be evaluated and the
validity of *"«>«"g analytical data should be assrsMd.
Meet SI objectives while conserving Superfuad resources.
Direct observation of a release does not require
background sampling if detectable concentrations of
^jfTi^fantt fn^^f»^ny« 3fg documented to be present in
the source. Background samples may not be necessary
for certain man-made compounds. If demonstrating a
release or establishing actual contain in itiftn is oii*ca^ 10
evaluating a site, background or QA/QC samples should
not be limited unduly because of budgetary
considerations—collecting these samples may prevent
having to return to the site.
To fttablfch background levels by chemical analysis, on-
site and off-site sources and their locations should be
thoroughly reviewed. Release and background samples
should be collected from similar lorafiom and media.
Ground-water samples are similar when they come from
the same zone within aa aquifer and undergo similar
sample preparation. Background samples for surface
water should be collected upstream of the PPE.
Additional site reconnaissance \r4 review are often
needed to select M"trE"C locations in industrial and
tuiniM areas and at complex
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9320.8-01 FS
PB95-963321
EPA 540/F-95/034
September 1998
Evaluating Ground Water Plumes
Under the Hazard Ranking System
Office of Emergency and Remedial Response
State, Tribal, and Site Identification Center (5204G)
Quick Reference Fact Sheet
This fee* Aftrt prundes infntmafiQrt an when a prtmrial National Priorities List (NPL) site can he evaluated as a contaminate*
ground water phone with no identified source and how such a site is evaluated under the Hazard RanJdng System (HRS). It
defines the steps that should generally be taken before a ground water phm» can be evaluated as a souicc;nimmari7gs scoring
considerations fir sites that consist solely of a ground water phone; and discusses other cooskteatkms for evahian^ sites
where ground water phones are present as the sole source. Responses to commonly asked questions about evaluating
contaminated ground water plumes at potential NPL sites arc also presented. This fact sheet is intended to provide general
guidance on ground water plumes for people who are pe
by EPA on a site-specific
BACKGROUND
The HRS is die primary too! that EPA uses to place
hazardous waste sites on the NFL under the
andUabiliryAct(CERCLA). NPL sites are releases and
potential releases of hazardous substances and mdndeaH
areas where substances have been deposited, stared,
dLsposfd, ox placed, or hav
In
anrf the «.im fftttf nrmtaminalifm has nrt
dearly been iflri^uTed. These sites arc reieiied to as
ground water phone sites. When evaluating these releases
for possible proposal to the NPL, the HRS scorer should
take into anoount jjumipnate considerations ;
with contaminated ground water plumes.
A
-------
observed release criteria may be used to delineate plume
boundaries. However, extent of site and associated
liability issues are frequently misunderstood at ground
water plume sites.
The Extent of a Ground Water Phime Site
Many people incorrectly assume that at the listing stage of
the CERCLA "nrwdifrtion process the pw-*9f boundaries
of the site and the extent of contamination are known.
However, the purpose of listing sites on the NFL is to
identify releases that are priorities for further evaluation,
not to identify the extent of the site. Defining the
boundaries of 3 nt^fninat the geographical area in
which the phnne is located (L&, XYZ Ground Water
PtameX instead of iirtuding potentially respoosHe parties
m the site name (Le^ Smith Co. Plant). Regardless, the
ritftaeiWinxlty thaHPS ig nritJtfrrtfialtnnrrmnfinfit
by the boundaries of any specific properly from which the
site name is derived
EVALUATING A GROUND WATER PLUME AS A
SOURCE
Under the HRS, a contaminated around water plume can
be evaluated as a source when the origin of hazardous
substances which have contributed to the phnne cannot be
reasonably identified (35 FR 51587, December 14. 1990).
The first step in evaluating a phone site is to show that
contamination of an aquifer has occurred. Ground water
sampling should generally be conducted to verify that a
contaminated ground water plume is present While the
exact extent of the plume does not necessarily have to be
defined, all samples used to characterize the ground water
plume should generally meet the criteria for establishing
an observed release. For HRS purposes, the dimensions of
the ground water plume should generally be based on the
available samples that meet the criteria for an observed
release. Areas tying between such samples should be
considered a part of the plume, unless available
information indicates contamination should not be
inferred between these points.
an
Once ground water contamination is Hftqim
attempt should generally be made to identify a source in
the area which has contributed to the phnne. unhazardous
atieixnfr% contained in the phime can be attributed to a
specific source in the vicinity, the actual plume is not
considered the source. In this case, the identified source
of the plume is evaluated as the source and the phime is
considered an observed release attributable to that source.
The source of ground water contamination can be
designated as »mvfamifi«j jf the Expanded Site
Investigation (ESI), or an equivalent effort which involves
concludes thaf the original souice of the ground
- nmrtaihinarinn hag nnt Kpan Anmmfn^ ThcESI
should at least include a she reconnaissance, record
searches, employee interviews, and gainpi"'g to gain.
information on the possible origins of the ground water
contamination. The attempt to identify a source should be
(lisuMBd in the HRS documeotaliuti record and potential
sources and potentially responsible parties should be
After the souice of contamination is designated as
SOQKOC JOT Xlt^O SOOHQ2 OQ^DOfiBS IS
clified
as "ground water phone with no
sounx." The ground water pbjme should be evaluated as
the source with an HRS source type of "other.11 An
unidentified source should not be confused with an
unallocated source (refer to Exhibit 1).
lasa
Once the ground water phime has been estabU
source, the extent of the plume is generally considered to
be the extent of the sue. This means that in most cases the
contaminated ground water plume will be the only source
scored for the ground water pathway.
In summary, make note of the following points before
evaluating a ground water phime as a source:
-------
The area of ground water contamination has been
rstaHishfl by sampling or inference using the
observed release criteria outlined in the HRS.
A reasonable search for potential sources of the
ground water oofiaminaaon has been conducted and
sampling tfljfcjflg that DO SOUTCe Of the gTOOOd
water contamination has been identified (the level of
effort to identify the original source should be
equivalent to an ESI).
In most cas^s the ground water plume is evaluated
as the source and the site.
EXHIBIT 1
UNIDENTIFIED
VS.UNALLOCATED
SOURCES
Under the HRS, the terms unidentified
and unallocated are not equivalent
* An unidentified source is an
example of the HRS source type
"other." A source may be classified
as unidentified when a contamimtml
ground water plume or surface water
sediment contaminatioo exists, but
the original source of contamination
is unknown and cannot be identified
through the appropriate means.
• An unallocated source- is cot an
HRS source type. Unallocated
sources are used to account for the
haTardnus waste quantity at a site
where the location of the hazardous
substances canoot be associated with
a specific source. A ground water
plume should not be considered an
unallocated source.
Source: The Hazard Ranking System
Guidance Manual, Interim Final,
OSWER Publication 9345.1-07,1992.
HRS SCORING CONSIDERATIONS OF GROUND
WATER PLUMES AS SOURCES
As for any site, an HRS score is calculated for the ground
water pathway for each aquifer existing at or below the
source at the site, or in this case, the contaminated ground
water plume. Assign the highest ground water migration
score for an aquifer as the ground water migration
pathway score for the site. In general, the aquifer in
which the ground water plume has been identified will
score higher than an underlying aquifer that is evaluated
for potential to release. An exception occurs when the
underlying aquifer is associated with a significantly larger
target population factor value. In this case, the target
factor category value must be sufficient to compensate for
the lower likelihood of release factor category value.
Evaluating Likelihood of Release
The likelihood of release factor category reflects either an
observed release to an aquifer or the potential to release to
an aquifer. The presence of a ground water phone with
contaminant levels significantly above background in an
aquifer constitutes an observed release to that aquifer.
Documenting the pfyffl*ncy of a ground water plume
usually involves establishing an observed release by
chemical analysis. Establishing an observed release by
chemical analysis at a plume site with no identified source
requires documenting that the concentration of at least one
hazardous substance in the ground water plume is
opnHjgynfiy increased above its background level.
Background samples should be selected to demonstrate
that the release cannot reasonably be attributed to any
known source. As slated in the HRS, to establish an
observed release by chemical analysis at a ground water
phone site, no separate attribution is required when the
source itself consists of aground water plume with no
i^ytiiifiad source. It is generally not appropriate to
attribute the hazardous substances to a site since the
contaminated pbnne with no identified source is the site.
The data presented in the HRS documentation record to
: the presence of a contaminated ground water
phone should be of known ?nd documented quality. Well
siting, installation, completion, and development should
be performed in accordance with protocols specified in
EPA ground water monitoring guidance, in particular,
The Hoard Ranking System Guidance Manual, Interim
Final OSWER Publication 9345.147 (1992). In
addition, all guidelines specified in the HRS, or relevant
gnidar** regarding similarity of background and
observed release samples should be met For example, the
HRS Guidance Manual stales that background and release
samples should be representative of the same portion of
-------
tiie aquifer that is bang evaluated Once an observed
release has been rflaMish*** by chemical analysis, the
analytical data used to associate the hazardous substances
with the plume may also be used to define the extent of the
source and the site for MRS purposes.
As discussed in the Evaluating Aquifers section, when
multiple aquifers exist, it may be necessary to determine
the potential far the release to migrate to an underlying
aquifer. In this case., the contaminated ground water
plume is evaluated for each of the four potential to release
factors (containment, net precipitation, depth to aquifer,
and travel time), as for any other source.
Evaluating Waste Characteristics
At a contaminated ground water phnne site with no
source, the hazardous substance
for
consideration in ^ft oift HRS, flfp^ measuring toe 4*mue target
jfiflatm* limit and assnciaffd distance nogs at the
geometric center of the area of observed ground water
contamination. The area of contamination should be
based on available samples that meet observed release
criteria.
g Act*1**! Con*arr|'Itation
At a contaminated ground water plume site with no
Hfrpriifcirt omime, actual contamination kectaMfchtd far
drinking water wells that meet observed release criteria.
Evaluate other drinking water wells within the -V-mile
-------
target distance limit under potential contamination. If a
drinking water well has been dosed due to contamination
from the plume being evaluated, classify the pre-dosurt
population associated with the well as subject to actual
contamination. Actual contamination cannot be inferred
for drinking water wells that are screened within the
dimensions of the plume. If none of the drinking water
wells are subject to «•*»"> contamination, yiyj atv^"^
well factor value based on the shortest distance to any
drinking water well, as measured from the geometric
center of the ground water plume (55 FR 51587,
December 14,1990).
QUESTIONS AND ANSWERS
Q: Can a contaminated ground water phone which is
JOtniBfl D|f IDC uQDDittBC OK jC9Cu8EC fiQOA 2 ]9Qufiu DC
evaluated as the source at a site?
A: If the contaminants in the phone can be attributed to
the landfill the phone should not be scored as the
source. In this case, the source at the site should be
classified as a landfill
Q:
Q:
If several suuius on Adinf* facilities (Le., different
property bomdflnf.s) are separated by large distances
and are shown to contribute to a single large
umiiiiiiglnl uatemiiHted ground water plume, can
the pfanneitsetfbe evaluated as the source?
In general, if the original source of ground water
contamination can be identified, the phone should
not be evaluated as a source. Indus case, since a
site under the HKS is not restricted to property
boundaries, the scorer should investigate the
possibility of evaluating all of the sources that
contribute to the phone as the sources at the site.
to be mining from one large facility flat has a single
owner, but the exact source of the conliuninannn is
not known, should the plume be considered the
source?
If the proper effort to identify a source is
unsuccessful at the site, then the scorer should
consider evaluating the facility as the source under
HRS source type 'other.1' This may be done when
contamination is attributed to operations or
processes at the facility but not to a specific source.
Q: If two distinct ground water phones with no
AT Detroieiiin rinxniw^i't ^^" the other
contains CERCLA eligible hazardous substances,
can the release be listed on the NPL?
The release of any CERCLA eligible hazardous
substance may be listed on the NPL. Petroleum
products may not be used in scoring under the HRS.
Q: ffagro
source is doaimented. bat sofl-gas samples show
contamination at a nearby area with the «"««
UnrnH the mmlaminiaeH soil or the
phime be evabatcd as the source?
Since soil-gas data do not establish actual soil
contamination or ground water contamination at a
site, Out contaminated ground water phone can be
considered a source ^observed release samples are
available. Soil-gas samples may generally only be
used to identify the presence of hazardous
substances in an existing source for purposes of
scoring waste characteristics. Soil-gas data may.
however, be used to establish the area of soil
contamination if verified through correlation with
soil samples.
-------
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9320.8-02FS
PB95-963322
EPA 54Q/F-95/036
September 1998
Evaluating Karst Geology Using
the Hazard Ranking System
Office of Emergency and Remedial Response
State, Tribal, and Site identification Center (5204G)
Quick Reference Fact Sheet
Under least conditions, contaannatian from a hazardous waste source can be expected to travd in ground water
Because of tins, sites overiyingkarst may pose
a greater threat to buman health and the environment. The Hazard Ranking System1 (HRS) contains special
consktaaora to aooourt forte uncased threat po This &ct sheet
win discuss die definition and identification of karst, the w^ in whklilcaistconditic^ at the taation of a source affect
the HRS sending pn>',yys_ and rrnrmytnty-adrnH qpadinn; and ai'fr"" <•
INTRODUCTION
What is karst? Consistent with die definition of karst in
the HRS, The Hoard Ranking System Guidance ManuaP
defines karst as;
A land of terrain with characteristics of relief and
drainage arising from a high Jegite of rock
solubility. The majority of karst conditions occur
> 22C8SL uQt jQUSt ^DSY 3US& OOCDT ID
areas of dolomite, gypsum, or salt
1 with karst terrain m
irregular topography, «
-------
information. The Hoard Ranking System Guidance
Manual suggests that the site evaluator
I, Use geologic maps and other readily available
information to determine if karst features are expected
within 4 miles of the site. If a karst formation is identified
within the target distance limit (TDL), continue with the
following steps.
2. Compile die available site-specific evidence that
indicates the presence of karst Such information can be
obtained from topographic maps, aerial photographs,
maps of caves, and visual observations.
3, Estimate the lateral extent of karst Based on the
distribution of the karst features within the formation, use
professional judgement to dHltyjtf laterally the areas
containing karst feauucs. Documentation of karst
A drilling or boring log from on-site weUs that
indicates voids beneath the source, illustrated by a
Kthctogic log, loss of dad mad, or intermittent plunges
of the drill bit into yhrtinn cavities.
SiTrfifial featiiBBt of karcf tt-t
are evident on the site.
such as a sink hole,
limit and indicate the
* Estimate the thickness of karst As an initial
i^iJAJiung Ac kact featuies should be evaluated,
Indications of depth and thickness may be available from
wen log data, iJniific liln aline, or other information
complied during the evaluation of aquifer boundaries.
5. frftnetntaqtferbowiamesjbrkfrt aquifers. To
u^iil iiy Irat^ aqmfr
and tnlbnnadflo compiled during the ^
definition of aquifers. Based on o^ information,
a list of geologic materials and/or formations that are
known to contain karst features.
6. Identifr^Us that draw drinking voter from a kant
aquifer that vndeHies sources at the site. These drinking
The steps provided in The Hoard Ranting System
Guidance Manual aDow the use of professional judge
in identifying and evahating karst aquifers. The rationale
for evaluating a karst aquifer should be supported by site-
spocinc and regional geologic references.
SPECIFIC CONSIDERATIONS OF KARST IN THE
HRS
The &ctors that are potentially impacted when karst is
present are listed in Exhibit 1. The following discussion
summarizes how the affected factor values are adjusted
when karst is present.
EXHIBIT 1
HRS GROUND WATER PATHWAY
FACTORS EVALUATED DIFFERENTLY
FOR KARST
Ground Water Pathway
Likelihood of Release
Observed Release
Potential to Release
Evaluated
Differently
No
YES
Containment No
Net Precipitation No
Depth to Aquifer YES
Travel Time YES
Waste Characteristics
Toxicity
Mobility
Hazardous Waste Quantity
No
YES
No
Targets
Nearest Well
Population
Resources
Wellhead Protection Area
YES
YES
No
No
Likelihood of Release
The adjustment? in the likefahnorl of release to die
potential ID release ftctor value show mat contaminants
move rapidly through a karst aquifer.
value for a site
of 0 feet to a
In evaluating the depth to aquife
located in karst terrain, assign a
karst aquifer that underlies any portion of the sources at
the site.
-------
TcaydTime values from HRS Table 3-12, applied to the remainder of
The HRS gives special consideration in the travel time the target drinking water population.
factor value by stating that "[if], for the interval being
evaluated, all layers (hat underlie a portion of the sources
at the site are karst assign a value of 35."' If the entire
interval is not karst, continue the evaluation for the "Other
Than Karst" layers. Assign a thickness of 0 feet to a karst
layer that underlies any portion of the sources at the site.
Waste Characteristics
The adjustment to the waste characteristics mobility factor
value shows that contaminants may move more rapidly in
solution channels, or other karst features, man through a
non-karst aquifer.
Mobility
The Suponmd Chemical Data Matrix4 (SCDM) gives
mobility values for chemicals in karst and non-karst
settings. Use the value given in the "karst" column if the
entire interval from a source at the site to the aquifer being
evaluated is karst If Itarst is present in the interval, but
the entire interval is not karst, use "non-karst" values
given in SCDM
When using HRS Table 3-8 to assign a mobility factor,
use the distribution coefficient category "karst" if the
entire interval from a source at the site to the aquifer being
evaluated is karst If karst is present in the interval, but
the entire interval is not karst, use "non-karst" values
given in die table.
Targets
Adjustments in the evaluation of targets show that the
individuals drinking water from a karst aquifer can be
exposed to higher coacentradoos rf nrmtamiimiiK than
they would be if they were drinking from other aquifer
Nearest Well
If none of the target drinking water wdls is subject to level
lorlev^nujncentraionsfbrtheaqniferandifoneoftbe
target aquifer is a karst aquifer that underlies any portion
of the sources at the she *nd if any weB draws drinking
water from mis karst aquifer within the TDL, assign a
value of 20 for the nearest well factor for the aquifer.
For potentially contaminated drinking water populations,
use the "Karst* portion of HRS Table 3-12 to assign values
only for that portion of the target population served by
points of withdrawal of drinking water from a karst
aquifer that underlies any portion of the sources at the site.
Continue the evaluation with use of "Other Than Karst"
-------
QUESTIONS AND ANSWERS
Q: Are surficial features of karst, such as sinkholes,
springs, and disappearing streams, necessary to
establish the presence of an underlying kaist aquifer?
A; No. A karst aquifer may exist at such a depth that
surface features do not east. Consideration of an
aquifer as karst does not require surface features.
Q: Are surficial features of karst sufficient to document
die existence of a karst aquifer if found at or very near
a source?
A: UsuaBy. Although these features may be absent in the
case of karst existing at depth, the presence of
sinkholes and other surfidal features is indicative of
karst However, in the western United States, lava
tubes, fissures, open sinkholes, and caves have been
formed by extrusion of the still-liquid portion of
cooling lava. These surface features may bear a
resemblance to karst. "Sinkholes" in lava generally
lack the symmetry of those developed in solution
terrain.
Q: Cfff1 a
a»ea riddled with mining shafts OT
lava tubes be evaluated as kaist?
A; No. These features may, however, be adequate to
Jucwient aquifer interconnection, -which may lead to
a higher site score.
Q-. Does the presence of a Iraesttne aquifer necessarily
mean that the aquifer is karst?
A: No. The area must either show surfidal karst
expression or the aqmjer must have karst features.
Q: Can the ex isteocecf^kaDifbniiatiop lying between
^Vt^O QOOrvGBESK fiQflQB8DQOS PC QSDQ wfr OOCDDBCflC
inttoonnectkn between die aquifers above and below
die kaist layer?
A: Not necessarily. It still should be shown that the
hydraulic conductivities are less man two orders of
magnitude between each formation. For example.
karst feaafts can actually channel -water horaontoUy
and stop vertical migration.
Q: When some of die individuals within the TOL are
obtaining water fioon a wrfif'il kaist pt|ft*o*1 of an
aquifer, but otbers are <^*a«m"e water from a noo-
karst portion, how are the targets evaluated?
A: The two sets of targets are evaluated separately and
then added together. Use the karst portion of HKS
Table 3-12 to assign values for the population that
obtains voter from an eligible karst aquifer. The
remaining non-karst water-drawing population is
assigned a value jrom the "other than karst* portion of
HRS Table 3-12. These values are then assigned to
the potential contamination formula in HRS section
3.3.12.
Q: A kant aquifer found 2.1 mites away fiom a source is
proven to be intHnnnnfrtttlwith an aquifer noderiying
the source. Ca" the atpafer beneath the ?tT be
evaluated as karsr? What tftte mterconnected karst
aquifer is found 1^ milesfrooiasoQroc?
A: At greater man 2 miles, interconnection is not used in
scoring a site, so distant karst formations an not
relevant to site evahutton. At less Hum 2 miles, an
interconnected karst aquifer that is used'for linking
water is evahiated as karst only if that karst aquifer
underlies a source on me site.
-------
REFERENCES
1/40 C.F.R., Appendix A (1997). Hazard Ranking
System; FmalRule. 55 FR 51582.
2. U.S. Environmental Protection Agency, November,
1992. The HazcrtRankfySys^ Guidance Manual
Interim Final Office of Solid Waste and Emogeocy
Response. Directive 9345.1-07, pp. 137 to 146.
3. U.S. Department of the Interior, U.S. Geological
Survey, 1986. National Atlas of the United States of
America, "Engineering Aspects of Karst," Map with
4. U.S. EnvininiiaMalPtDtectkMi Agency, Jane, 1994.
TheSup^mdO>emk^DataMatrtX(SCDM). Office
of Solid Waste and Emergency Response. Oucctivc
9360.4-18.
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
EPA-540-F-9S-037
OSWER 9375.2-09FS
PB98-963308
October 1999
Improving Site Assessment:
Abbreviated Preliminary
Assessments
Office of Emergency and Remedial Response
Site Assessment Team
Quick Reference Guidance Series
ABSTRACT
(APA)insteadofafullPrdiiniDafyA
DUDBDUQ XBQUIT'Q&CDES Krt CXTOtauCuflP 3Q ^\Dua!CVI8t6u l^FC1101ID8a-y «\
(PA). TbePApnxxssoVtffrmiDCSanddcicunientawhetherSupert^
is needed ataCon^a^facaarvcEnvuuunnaal Response. Cor^^
UK region may produce an APA report at any phase of die PA (prior to corrfk*irigaMPA)wbaierKKighinfbanaiioni»
avaD&bfe to make a deciskn CD further CERCLAactkn. ThagiiidaaoedoaBDeatsq>e{9edeS9ectk]o4.4ofttK(rfadbiioe
lteiminary Assessments voder CEROA, Publication 9345.O01A, September 1991.
BACKGROUND
XDQO1BCQ * A BDOfOBCu COOQ01DCS ICSURS 01 puOC
projects andpastexpanepcetisiBg die odstrngPAprocera.
EPA region* haw found that they an often determine a
site's tocsdon m Ac Sifnfind she joecnm roceas and
wfaafaa it afaciiM be removed fiomlfaepiooenategediet,
witfa less infimiump dun a requiied fcr a coovtolioQal
PA. la these eadydeciaioaiDstaDce^ you may produce an
APA report in place of • full PA npoit
*PPB*C*1
"B-"^i"" aa me
jiKiyiirm and pact site assessment experience to make
decisions about a site at eariier **f of DC PA pcnmi
ResrxnsiUityandrlmdJngfbrAPAsarethesameaifbr
OUUVdftilMI PAS»
WHAT IS THE PURPOSE OF AN APA?
The PA is die fust step you take to determine whether a
site wanam St^perfund response after a site has him
entered inoCERCLJS. The National Oil aod Hazardous
^^Nftncft PoOudoo Commgency Plan (NCP) (40 CFR
300.420) requires the lead agency (EPA in most instances)
to perform PAs on all sites in CERCL1S toe
tfaflt OO DOC PQSC
or ibc ^HviHj M •• npitf from fyrtocr
oomidentkxu
• DetEnniDcifdiaeisaiieedfivxaDovaiactioB;
. Set pfioei ties for Sis; »d
• Gather data ID fefj;>^» later evaiuatkxt of the
If you OD meet these PA objective* witbDrt perfa
Qg
a M PA, you may perfbon an APA. m the case of a
citianpeaticn(aeeCERCLA 105(d)X*eNCP requires
dw feed agency to ehfaer f**vyb*» a PA or provide an
aqpianaoon to me petitioaer of v4y Aft assessuent is not
appropnaK. A brief APA leport won a conpieted
Abbreviated Pftbmtfy Assessment Otedaat (see
Attacfament A), or eojuivilent documezotkn. meets aD
die CERCLA and NCP requirements for a PA.
There are dare typical ^*>wvjm in which you could
perfbon an APA instead of a full PA to increase
efficiency and shorten the PA process:
-------
(t) A ate has been unnecessarily listed in CERCLJS
either because it is not eligible or because it could be
deferred to another response pfogrant
(2) Available infonnarion allows EPA to make an early
decision to undertake a combined PA/SI, an SI, or
another Superfund investigation.
P) A No Funher Remedial Action Planned (NFRAP)
decision can be made without completing a full PA.
In each situation, an APA can save resources and reduce
costs bydimmatingunnecessary efforts. Federal Agencies
and Sates cmdiirring CERCLA site aucnimaift should
consukwithdKEPARegionalOfl5cepQor»initianiigan
APA to ensue that ^tfu-ifnt data wiD be collected to
make an appropnate decisHn about Ac she.
WHAT ARE THE THREE PHASES OF THE
PRELIMINARY ASSESSMENT PROCESS?
You may produce an APA report during any phase of the
PA process prior to cttnpkting a full PA. Note dot an
APAmustineetthebasicPAaiteriaspeci6edinmeNCP.
The fust phase, the CERCLA eligibility evaluation,
involves collecting and reviewing readOy available file
mfi«niii«5im aod remvestigating the site's CERCLA
eligibility. Electing ifabinfbmaticc may begm before
the site is entered iito CERCUS, as part of pre^ERCUS
? - - ~ *- - -• - *•,• • e^_^__ j__ Oi»—
rm***fntt£nivmfKu*ff*m\9&&*m,r*+mi*s*fLVMWuvY'w-if9£i
Assessment: Pre~CERCUS Screening Assessments*).
The second phase is the initial site evaluation which
CESoib gathning inSinnalioo llduugfa Ste searches. Thb
may involve visftmgme site to deteonine the appropriate
action. IfyoudecidetDtakenofuttheractit^youshould
complete an APA report An APA report may also be
completed if you decide to move straight a> an SI without
tafifflPA.
You complete the third phase of this PA process if you
u8VC iBSUI&QCOt 1D20O3Q8&OD tP fllaUQB flfi CBnV ClOCtSIQD
about ruCaeSupernmd response, m this case, you should
a decision about future Supcr&nd acooo at the site.
Peifijuu full PAs in accordance with the Gutdaxxfar
ryAaasments Under CERCLf.
WHAT ARE THE POSSIBLE DECISIONS?
You could make one of the folk
results of an APA:
ton
NFRAP under Superfund;
Defer the site to another Federal program with
investigation, enforcement or remediation
aumority (e.g., RCRA, NRC);
Delay the decision until State/Tribal program ends
active involvement in response activities;
Assign high priority for further assessment;
Assign low priority for further jtaeviiirm,
Refer to the removal program; or
this **** ""*" a" griaring fT« Hf*t IS fjtf
See the Superfund Program Implementation Manual
(SP1M) for more intbonanoo on ""^"irg decisions.
HOW IS A CERCLA ELIGIBILITY EVALUATION
PERFORMED?
m the first phase of the PA process, you wfll determine
whether the site is eligilsk fir evahiaticoiioler CERCLA.
Catena for deteonining *b ace identified below (from
guidance dnrammr tided Improving Ste Assessment:
Pre-CERCUS Screening Assessments1). If a pre-
-IS SCIQQDlDff JlBS ffffCn OOKDOlC&Ou USDttE tuB96
i^itnm^ das phase of the PA utucess is naafffffy
Gather n»nigli data to adoRss the "*"*""»g cntena
below, to hdp make a CERCUS eligibility dedsko.
These criteria are primarily based on OSWER Directive
#9200.4-05.
A site should not be entered into CERCUS i£
• Tj£siteisanejfty_jD_C£R£LJS>_Q£ju3_been
CERCUS enttv. Detemune whether the site has
previously been evaluated under the Fedeal
Superfund Program to avoid entering a diiptifatr
site record into CERCUS. Check CERCUS and
WCDIV6 dob for previous cotncs Of s site n*"^fl stc
tiiatfhliiM f"6 subject to
- Too includes cases where me release is:
(1) Of a natunDy occurring substance in its
unaltered fbnn. or altered solely through
naturally occuning processes or phenomena.
fiom a location where it is naturally found;
-------
(2) From products that ait part of the structure of,
and result in exposure within, a residential
building or business or community structure; or
(3) Into a public or private drinking water supply
due to deterioration of the system through
ordinary use.
A Stele or
response at a ate that is in the process of a final
clean-up (e.&, a State Superfund program, State
voluntary dean-up program, and State or local
Brownfiekfa programs).
During the screening process, a file search of other
Agency programs cuminBtes sites wuui> oner
piu^juB are actively involved. Baaed on the seattfa
of the geographKal Iffr***"*1 of flic site and the site
idephonecalb to staff of other potentially mvotved
programs. You, in consultation with State and
Tribal pwgtaiu representatives, are responsible tor
determining whether another program is actively
involved with the site.
When another program with sufficient
investigation, enforcement, and remediation
resources is actively involved with a site, postpone
a decision onCERCLJS entry until all actions have
been completed. EPA is responsible for
oftnuiiumg if the actions are sufficKif and win
tben uCteQDme ^vfaetDcr any tuclBcr Supertuno
involvement is warranted.
l^BtlJtQiy fliCHlSlOn Hf-if, t
atural gas, natural gas ttquids, synthetic
petn
gas usable fix ****
release located m a w
ial application of fertilizer,
kplace, naturalry occurring,
or covered by the Nbckar Regulattiy Qxnntsaon
(NRQ, and Uaniun Mill Tailings Radiation
Control Act (UMTTRCA)). See CERCLA Secnoo
101(22).
Corrective Action). Refer to the Regional QC
Guidance far NPL CtmtKdatf Sites1 fbr more
Ine site investigator should, at a minimum, search
other current EPA data, sets using site identification
data (name and location) to determine whether the
site is already being addressed by other authorities.
The NPL/RCRA deferral policy states that sites
should not be placed on the NPL if they can be
addressed under RCRA Subtitle C Corrective
Action Authorities. However, according to the
NPL/RCRA policies published June 10, 1986 (51
FR 21057), June 24, 1988 (53 FR 23978X and
October 4, 1989 (54 FR 41000), facilities tfaat are
subject to RCRA Subtitle C may be listed on the
NPL when corrective action is unlikely to succeed
or occur promptly, as in the following situations:
(1) inability to finance, (2) unwillingness/loss of
authorization to operate, (3) unwillingness/case-
by-case determination, (4) converters,non-orlatc
filers, (5) pre-HSWA (Hazardous and Solid Waste
Amendments) permittees, and (6) when not au of
the release from the facility is covered by RCRA
corrective action.
i
am (Le, based on potentially unreliable sources
or with no information to support the presence of
hazardous substances or CERCLA-eligjble
pollutants and contaminants).
or a checklist with what appears to be unreliable
data, you should identify tfae data deficiencies and
forward these data needs tome site investigator fbr
further data coflection. For rnore information, see
the Pre-CERCLJS Screening Assessment
Checklist/Dectsk»Foanm the guidance document
tided improving Ste Assessment: Pre-CERCLJS
Screening Assessments. When it u not feasible to
use professional judgement when deciding to place
asheinCEROJS.
sddjaatjdv
heahh
ebensrvc
investigation equivalent data showing no release
above applicable or relevant and appropriate
requuemenB (ARARsX completed remove! acocn
of all sources and releases, documentation showing
triat no bazardoiissubstarMxreleasesrdrve occurred,
or a completed EPA approved risk assessment
showing no risk).
If tfae answer is "yes" to any of these herns and there is
no other Federal Supertbndinterest,yournay assign die
site a NFRAP designation or deter it to another
program. Thiso^isico should beooninTentedinabrief
-------
APA report (repotting requirements are described
below). This action terminated the PA process. If the
answer is "no" to any of the bulleted items, you may
pnxeed to tfae next phase of the PA process, the initial
site evaluation.
HOW IS THE INITIAL SITE EVALUATION
PERFORMED?
The initial site evaluation is the phase in which site
investigators collect and review information on the ate
and its surroundings. EPA investigators may use their
make nccfmneadBdom about further CERCLA action.
Exhibit 1 iderifiesdiffecnttypetofsileiaibnnati
id
provides some poaab4eiri«iiiieuhtion» fee fiamersiie
assessment activities based on tfatf iiifiiiiiatinii You
should use Exhibit 1, or equivalent mfcnaation, in
detennming the need fix fixther action at the site, based
on the answers to the questions in Attachment A.
Exhibit 1 and Part2of Attachment Apresentas
site enntBtifing itff indJCJIf* ™lnllin'
actionmaybenecessaiy. Thesesrfccondflionsarcbased
on HRS facaxa and include charactens
cammanry cause sites to receive high or low HRSi
WHAT ARE THE REPORTING
REQUIREMENTS FOR THE PA PROCESS?
When a fuQ PA is unnecessary, you should develop an
APA report to document me latmnale for me dectswn.
The NCP (40 CFR 300.420) speciSesPAiequirenjeDts,
and an APA repcxt nominee these rcquireniats. The
NCP states mat the lead agency may complete me
•jmlim'-- - » __ ^- - •- « - t
ftfaaSamj Bill, IMjem luuu, OT OS eQUMKu, ••(
prepare a PA repot to:
Describe the release;
• Desoalw the probabkrotfiK of the release; and
• Rfi'^'fiiBf*1**1'' *"*tllifi nBlfapr artioo ** ^x^^^^^^^
which lead agecy should conduct firmer action,
and whether an SI and/or a removal action should
be undertaken.
If the PA is the result of a citizen petition, the NCP
further requires die lead Federal agency ft) notify die
petitioner of die PA outcome and fxplam its
detennination.
The APA report should present and fully support all
infbnrntion that led to abbreviating the PA process.
IrKhKfcAttachtnertAorequivakntinfonnationaspart
of the APA report. The APA report must also meet all
the NCP requirements for a PA report discussed
previously, including those requirements for response to
a citizen petition. The criteria discussed above should
be used to explain the decision.
Adding more information to the APA Chffk''** is
acceptable (preferably on separate pages), but do not
rommiuiii
If an APA is not appropriate tor the site, complete the
mD PA discussed in the Guidance for Paformuig
Pretminay Assessments Under CERCLf.
How Wffll me Information be Managed?
CERCUS/WasteLAN is the official national
ganM* systan for the Superfund
Site assessment data must be entered into
CERCLlS/WasteLAN and regularly updated to
cficctivdy sod cfiicicDuy imuufiic SUDCZWDDS site
assessocnt process. PiCBseicfa to tbc latest vn.uuu of
EPA's SP1M and CERCLJS/WasteLAN Coding
Guidance Manual &r instructions on entering APA
infimiatJcaintoCERCLlSWasteLAN.
REFERENCES
I. U.S. Environmental Protection Agency, October
1999. Quick Reference Guidance Series -
Site Assessment: Pre-CEBCUS
of Solid Watte and Emergency Response.
Publication 9345.CMHA.
2. U.S. Envirootnpjital Protection Agency,
eptember 1991. Gtadancf for Perform
3.
FOR MORE INFORMATION
For more mrbrrnation on APAs, please contact Michael
Hunt at EPA Headquarters, phone (703) 603-8836 ore-
mail at fofd.mKhaei@epa.gov.
_
1991. Regional Quality Coord Guidance for
NPL Candidate Stes. Office of Sotid Waste ad
Publication 9345. 1-Ofc.
-------
ATTACHMENT A
ABBREVIATED PRELIMINARY ASSESSMENT
CHECKLIST
-------
ABBREVIATED PRELIMINARY ASSESSMENT CHECKLIST
This checklist can be used to help the site investigator detennine if « Abbreviated Ptdinoinaty Assessment (APA) is wananted
This checklist should document the rationale far the deciskn on whrthtr furih^ steps U1 the site inv^
under CERCLA. Use additional steels, if necessary.
Checklist Preparer
(Dae)
(Adtko)
(Pfceoe)
Site None:
Protons Names Of any):
Site Location:
(ST) (Z?)
Latitude:
LoogHnde:
Describe the rekaae (or potential release) and Us probable nature;.
Fart 1 - SapcrfeBd EH&bUty Evabntioo
If aManvwen are "no* go on to fart 2^ uUmwiat pimctd to Part 3.
1. Is tbe site oaiaaly in CERCUS oral "alias" of another site?
? i««h»««^hi^ii»j>Mn.L.«»^liif«Mii»rtrfii^-F».in««al r«r»ttiam fFmWil .StafcflrTrihun?
^ A«^ Jw- 1ajiMjiii« «^wtmw w*P**ialtv r^l^a^^ ^l}v **•• iraiirtHf IHVVT' fl HHIliiiV g»rhi«Miffi ^ a
fertilizer, rdeaae located in a wixkpiact, naturally ooeunnb or regulated by the Nltt^UMTRCA, or
OSHA)?
A jj A_ !_• V-i i_a •ivVintniinaiai nrataawatiaftirn-lflMHiit aaT tlu *inm jTJ^hllU^ l»f rt^lfTf rrwiaSAliiXnlMlil /• f
uuuiod to RCRA OODCC&VC ichoo)?
^•Ei.iidnm mhtfincc idcMcs baive occuged,, or IP EPA a^jpcwed riak lattcagpcct coii|>lrtffd)?
YES
D
p
NO
0
A-l
-------
Part 2 - Initial Site Evaluation
determine whether an APA is appropriate. Exhibit 1 parallels the questions in Part 2. Use Exhibit 1 ID make
1. Does the she have a release or a potential to release?
•> rv— A.^.V™. .tt^^^i «™*j • rni»rt A r TJ. h**,**.?
decisions in Part 3.
YES
D
a
a
NO
a
D
a
If Ibe aoiivvii to qnctfom lt % Md 3 atew
proceeding tt> Ptrt 3.
CtC« J "^* VftHl *^p^^**^ tej f ItMWBWlBilB flnfMHMa^V VMlMMBMra Q^ff) QIC SBC (
' *
Stlf tlVII in •l^ritf IlllJ^M ill tta •IlL Ul''^' i"i iii ifciiiiH»
-------
EXHIBIT I
SITE ASSESSMENT DECISION GUIDELINES FOR A SITE
Exhibit 1 identifies different types of site information and provides some possible recommendations for further site assessment activities
based on that information. You will use Exhibit 1 in detemiining the need for nmheractkxi at the site, based on tte
questions in Part 2. Please use your professional judgement when evaluating a site. Your judgement may be different from the general
recommendations for a site given below.
Saspected/Documeoted Site Coodttkwf
I. There are no releases or potential to release.
2. No uncontaincd sources with CERCLA-digibk substances ate
present on site.
4. ThiJfiP M AMiniMiiatMiii ttwfiraring
tDSt ft target (€.£, mmlntig WHET
substaooe fc)cA9cd nocn the Site.
iicxc m oil uppueiii mease at UK
exposed targets, but there are targets
on trtr nr imniBii Lutr lu arftacmf fn ih^
site.
Option 1:APACSI
Optical- PA/SI
Option 1: APA O SI
Option Z- PA/SI
located within 1 mik of the site and hv
iliCCJlilOOQ OTfX^OfflV^ fk^ H f^TTlin^T'lW T
tfaesfle.
t adjacent to the site, but
i are those tatgets that are
*e a relatively high
7. Thne is no intKfatin, of a h»>»rir-i« «nl«t«nr> tgli-aa* nnH
on she or in proximity to the site.
ease wish targets present
APA
Yes
Yes
Yes
Yes
No
Yes
No
No
No
Fafl PA
No
No
No
No
No
No
No
Yes
Yes
FA/SI
No
No
No
No
Yes
No
Yes
No
No
SI
No
No
No
Yes
NA
Yes
NA
No
No
fat 3 - EPA
F»eXMDple,iftfaeMtiwertoqaestian 1 toFS«2
then an APA n»v be perfcrnrdaidte'TtfRAP" box below abou^ Addte»afly,iftheanswertoqoeation4in
Pw2is*^Mtiienyouhcvetwociptiott(asniiatedinEzh^ Option 1 - conduct an APA and cbedc the Tower PnadQrST or
"Higher Priority SI" box bdow; or Option 2 -proceed wilfa aoombinedPA/Sli
Cbecktfae box tttat applies bated oa the
O NFRAP D
O Higher PrioriqrSJ O
Q Lower Priority SI a
O Defer »RCRA Subtitle C a
O Defer to NRC
of tte APA:
Refer to Removal Prognm - further site assessmez
Refer to Removal Ptogtam - NFRAP
Sifcb being addnasedai part of another CERC1JS site
Other
:ded
Regkwal EPA Reviewer:
Pri
Owe
A-3
-------
PLEASE EXPLAIN THE RATIONAL)!; FOR YOUR DECISION:
NOTES:
A-4
-------
APPENDIX B
ACRONYM LIST
AND
GLOSSARY
-------
APPENDIX B
ACRONYM LIST*
AALAC ambient aquatic life advisory concentration
AOC area of observed contamination
AWQC ambient water quality criteria
BCF bioconcentration factor
BIA Bureau of Indian Affairs
BLM Bureau of Land Management
BPF bioaccumulation potential factor
BPFV bioaccumulation potential factor value
BTAG Biological Technical Assistance Group
CA cooperative agreement
CERCLA Comprehensive Environmental Response. Compensation and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation and Liability Information
System
CERI Center for Environmental Research Information
CFR Code of Federal Regulations
CLP Contract Laboratory Program
CRDL contract-required detection limit
CRQL contract-required quantitation limit
ODD dichloro-diphenyl-dichloro-ethane
DDE dichloro-diphenyl-ethane
DDT dichlorodiphenyl-trichioroethane
DL detection limit
DNAPL dense nonaqueous phase liquid
DOE U.S. Department of Energy
DOT U.S. Department of Transportation
EECA engineering evaluation/cost ana lysis
EIS environmental impact statement
EP extraction procedure
EPA U.S. Environmental Protection Agency
ERD Emergency Response Division
ERT Environmental Response Team
FDAAL Food and Drug Administration Advisory Level
FRDS Federal Data Reporting System
FWRS Fish and Wildlife Reference Service
GIS Geographic Information System
GW groundwater
HFC human food chain
HRS Hazard Ranking System
HRSGM Hazard Ranking System Guidance Manual
HWQ hazardous waste quantity
IAG interagency agreement
IDL instrument detection limit
LNAPL fight nonaqueous phase liquid
LR likelihood of release
MCL maximum contaminant level
MCLG maximum contaminant level goal
MDL method detection limit
MMS Minerals Management Service
NAAQS National Ambient Air Quality Standards
NAWDEX National Water Data Exchange
NCP National Contingency Plan
PAGE 2
Preliminary Assessment Training
-------
APPENDIX B
NESHPA National Emission Standard for Hazardous Air Pollutants
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric Ad ministration
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
NPS National Park Service
NRC Nuclear Regulatory Commission
NRT National Response Team
NSFF National Sport Fishing Federation
NWI National Wetlands Inventory
OSC On Scene Coordinator
OSM Office of Surface Mining
OSWER Office of Solid Waste and Emergency Response
OVA organic vapor analyzer
OWRS Office of Water Regulations and Standards
PA preliminary assessment
PCB polychlorinated biphenyl
PPE probable point of entry
PRP potentially responsible party
QA quality assurance
QC quality control
RA removal action
REAC Regional Engineering Analytical Contract
RCRA Resource Conservation and Recovery Act
RDT Regional Decision Team
RI/FS remedial investigation/feasibility study
RREL Risk Reduction Engineering Laboratory
RRT Regional Response Team
SARA Superfund Amendments and Reauthorization Act
SAV submerged aquatic vegetation
SC screening concentration
SCDM Superfund Chemical Data Matrix
SCS Soil Conservation Service
SDWA Safe Drinking Water Act
SF slope factor
SI site inspection
SQL sample quantitation limit
SW surface water
SWDA Solid Waste Disposal Act
TAT Technical Assistance Team
TCLP Toxic Characteristic Leaching Procedure
TDL target distance limit
TSCA Toxic Substances Contra* Act
TSDF treatment, storage, or disposal facility
USC U.S. Code
USDA U.S. Department of Agriculture
USFS U.S. Forest Service
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UV ultraviolet
WC waste characteristics
WPA wellhead protection area
*fora more complete listing refer to: www.epa.gov/superfund/gloss1 .htm
or www.epa.gov/students/dictiona.htm
Preliminary Assessment Training
PAGE 3
-------
APPENDIX B
GLOSSARY*
Apportioned population: In the evaluation of drinking water target populations associated with a blended
system, that portion of the population evaluated as being served by an individual well or intake within the
system.
Aquifer: A saturated subsurface zone from which drinking water is drawn.
Blended system: A drinking-water supply system which can or does combine (e.g., via connection
valves) water from more than one well or surface water intake or from a combination of wells and intakes
CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act of 1980.
CERCLA Information System: CERCLIS, EPA's computerized inventory and tracking system for
potential hazardous waste sites.
CERCLIS: CERCLA Information System.
Coastal tidal waters: Surface water body type that includes embayments, harbors, sounds, estuaries,
back bays, etc. Such water bodies are in the interval seaward from the mouths of rivers and landward
from the 12-mile baseline marking the transition to the ocean water body type.
Comprehensive Environmental Response. Compensation and Liability Act of 1980: Legislation that
established the Federal Sup^erfund for response to uncontrolled releases of hazardous substances to the
environment.
Contaminated soil: Soil onto which available evidence indicates that a hazardous substance was spilled,
spread, disposed, or deposited.
Depth to aquifer The vertical distance between the deepest point at which hazardous substances are
suspected and the top of the shallowest aquifer that supplies drinking water.
Distance to surface water: The shortest distance that runoff would follow from a source to surface water.
Drinking water population: The number of residents, workers, and students who drink water drawn from
wells or surface water intakes located within target distance limits.
Drums: Portable containers designed to hold a standard 55-gallon volume of wastes.
Emergency response: See "removal."
Factor: The basic element of site assessment requiring data collection and evaluation for scoring
purposes.
Factor category: A set of related factors. Each pathway consists of three factor categories-likelihood of
release or exposure, targets, and waste characteristics.
Federal Register Daily publication of the Government Printing Office; contains public notices, rules, and
regulations issued by the Federal Government. Cited as " FR ."
FEMA: Federal Emergency Management Agency.
Fishery: An area of a surface water body from which food chain organisms are taken or could be taken
for human consumption on a subsistence, sporting or commercial basis. Food chain organisms include
fish, shellfish, crustaceans, amphibians, and amphibious reptiles.
FR: Federal Register.
GEMS: Geographical Exposure Modeling System.
Preliminary Asses
-------
APPENDIX B
Geographical Exposure Modeling System: Population database maintained by EPA's Office of Toxic
Substances; provides residential populations in specified distance rings around a point location.
Hazard Ranking System: EPA's principal mechanism for placing sites on the NPL
Hazardous constituent: Hazardous substance.
Hazardous substance: Material defined as a hazardous substance, pollutant, or contaminate in CERCLA
Sections 101 (14) and 101 (33).
Hazardous waste: Any material suspected to contain a hazardous substance, pollutant, or contaminant
that is or was in a source.
HRS: Hazard Ranking System.
Karst: A kind of terrain with characteristics of relief and drainage arising from a high degree of rock
solubility. The majority of karst conditions occur in limestone areas, but karst may also occur in areas of
dolomite, gypsum, or salt deposits. Features associated with karst terrain may include irregular topogra-
phy, abrupt ridges, sinkholes, caverns abundant springs, disappearing streams, and a general lack of
well-developed surface drainage system of tributaries and streams.
Lake: A type of surface water body which includes:
• Natural and artificially-made lakes or ponds that lie along rivers or streams (but excluding the great
Lakes).
• Isolated but perennial lakes, ponds, or wetlands.
• Static water channels or oxbow fakes contiguous to streams or rivers.
• Streams or small rivers, without diking, that merge into surrounding perennially-inundated wetlands.
• Wetlands contiguous to water bodies defined as lakes are considered to be part of the lake.
Landfill: An engineered (by excavation or construction) or natural hole in the ground into which wastes
have been disposed by back filling or by contemporaneous soil deposition with waste disposal, covering
wastes from view.
Land treatment: Land farming or other land treatment method of waste management in which liquid
wastes or sludges are spread over land and tilled, or liquids are injected at shallow depths into soils.
National Contingency Plan: Regulation that establishes roles, responsibilities, and authorities for re-
sponding to hazardous substance releases. The NCP established the HRS as the principle mechanism
for placing sites on the NPL
National Priorities List: Under the Superfund program, the list of releases and potential releases of
hazardous substances, pollutants, and contaminants that appear to pose the greatest threat to public
health, welfare and the environment.
NCP: National Oil and Hazardous Substances Pollution Contingency Plan, commonly known as the
National Contingency Plan.
NFRAP: No further remedial action planned; site disposition decision that further response under the
Federal Superfund is not necessary.
No suspected release: A professional judgement conclusion based on site and pathway conditions
indicating that a hazardous substance is not likely to have been released to the environment. (No
suspected release is the PA term analogous to the HRS "potential to release.")
NPL: National Priorities List.
Preliminary Assessment Training
-------
APPENDIX B
Ocean: A type of surface water body which includes:
• Ocean areas seaward from a baseline distance of 12 miles from shore.
• The Great Lakes, along with wetlands contiguous to them.
PA: Preliminary assessment.
PA-Score: EPA's computer program that automates PA site scoring.
Pathway: The environmental medium through which a hazardous substance may threaten targets. The
PA evaluates the migration and threat potential through the groundwater, surface water, air, and soil
exposure pathways.
Pile: Any non-accumulation above the ground surface of solid, non-flowing wastes; includes open
dumps. Some types of piles are: Chemical Waste Pile - consists primarily of discarded chemical
products, by-products, radioactive wastes, or used or unused feedstocks: Scrap Metal or Junk Pile -
consists primarily of scrap metal or discarded durable goods such as appliances, automobiles, auto
parts, or batteries, composed of materials suspected to contain or have contained a hazardous sub-
stance; Tailings Pile — consists primarily of any combination of overburden from a mining operation and
tailings from a mineral mining, beneficiation, or processing operation: Trash Pile - consists primarily of
paper, garbage, or discarded nondurable goods which are suspected to contain or have contained a
hazardous substance.
PPE: Probably point of entry.
Preliminary assessment: Initial stage assessment under Superfund; designed to distinguish between
sites that pose little or no threat to human health and the environment and sites that require further
investigation.
PREscore: EPA's computer program that automates site scoring with the Hazard Ranking System.
Primary target: A target which, based on professional judgement of site and pathway conditions and
target characteristics, has a relatively high likelihood of exposure to a hazardous substance. (Primary
target is the PA term analogous to the MRS target exposed to Level I or Level II actual contamination.)
Probable point of entrv: The point at which runoff from the site most likely enters surface water.
RCRA: Resource Conservation and Recovery Act of 1976.
Removal: An action taken to eliminate, control, or otherwise mitigate a threat posed to the public health
or environment due to release or threatened release of a hazardous substance. Removals are relatively
short-term actions to respond to situations requiring immediate action.
Resident: A person whose place of residence (full-time or part-time) is within the target distance limit.
Resident individual: Under the soil exposure pathway, a resident or student within 200 feet of any area of
suspected contamination associated with the site.
Resident population: Under the soil exposure pathway, the number of residents and students within 200
feet of any area of suspected contamination associated with the site.
Resource Conservation and Recovery Act of 1976: Legislation that established cradle-to-grave account-
ability for hazardous wastes, from point of generation to point of ultimate disposal.
SARA: Superfund Amendments and Reauthorization Act of 1986.
Secondary target: A target which, based on professional judgement of site and pathway conditions and
target characteristics, has a relatively low likelihood of exposure to a hazardous substance. (Secondary
target is the PA term analogous to the MRS target exposed to potential contamination.)
PAGE 6
Preliminary Assessment Tramrng
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APPENDIX B
Sensitive environment: A terrestrial or aquatic resource, fragile natural setting, or other area with unique
or highly-valued environmental or cultural features.
S[: Site inspection.
Site: The area consisting of the aggregation of sources, the areas between sources and areas that may
have been contaminated due to migration from sources; site boundaries are independent of property
boundaries.
Site inspection: Second stage of site assessment under Superfund, conducted on sites that receive a
further action recommendation after the PA; builds on PA information and typically includes sampling to
identify hazardous substances, releases, and contaminated targets; identifies sites that pose the greatest
threats to human health and the environment.
Source: An area where a hazardous substance may have been deposited, stored, disposed, or placed.
Also, soil that may have become contaminated as a result of hazardous substance migration. In general,
however, the volumes of air, ground water, surface water, and surface water sediments that may have
become contaminated through migration are not considered sources.
Stream flow: The average rate of flow of a water body, expressed in cubic feet per second (cfs).
Stream or riven A type of surface water body which includes:
• Perennially-flowing waters from point of origin to the ocean or to coastal tidal waters, whichever
comes first, and wetlands contiguous to these flowing waters.
• Above ground portions of disappearing rivers.
• Artificially-made ditches only insofar as they perennially flow into other surface water.
• Intermittently-flowing waters and continuous intermittently-flowing ditches in areas where mean
annual precipitation is less than 20 inches.
Student: A full-time or part-time attendee of a day care facility or educational institution located within the
target distance limit.
Superfund Amendments and Reauthorization Act of 1986: Legislation which extended the Federal
Superfund program and mandated revisions to the MRS.
Surface impoundment: A topographic depression, excavation, or diked area, primarily formed from
earthen materials (lined or unlined) and designed to hold accumulated liquid wastes, wastes containing
free liquids or sludges that were not backfilled or otherwise covered during periods of deposition;
depression may be dry if deposited liquid has evaporated, volatilized, or leached, or wet with exposed
liquid; structures that may be more specifically described as lagoon pond, aeration pit, settling pond,
tailings pond, sludge pit, etc.; also a surface impoundment that has been covered with soil after the final
deposition of waste materials (i.e., buried or backfilled).
Surface water: A naturally-occurring, perennial water body; also, some artificially-made and/or intermit-
tently-flowing water bodies. See "water body type' and subsequent definitions for more detail.
Suspected release: A professional judgement conclusion based on site and pathway conditions
indicating that a hazardous substance is likely to have been released to the environment. (Suspected
release is the PA term analogous to the MRS "observed release.")
Tanks and non-drum containers: Any stationary device, designed to contain accumulated wastes,
constructed primarily of fabricated materials (such as wood, concrete, steel, or plastic) that provide
structural support; any portable or mobile device in which waste is stored or otherwise handled.
Preliminary Assessment Training
PAGE 7
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APPENDIX 8
Target: A physical or environmental receptorthat is within the target distance limit for a particular
pathway. Targets may include wells and surface water intakes supplying drinking water, fisheries,
sensitive environments, and resources.
Target distance limit: The maximum distance over which targets are evaluated. The target distance limit
varies by pathway: oroundwater and air pathways - a 4-mile radius around the site; surface water
pathway - -15 miles downstream from the probable point of entry to surface water; soil exposure
pathway - - 200 feet (for resident population threat) and 1 mile (for nearby population threat) from areas
of known or suspected contamination.
Target population: The human population associated with the site and/or its targets. Target populations
consist of those people who use target wells or surface water intakes supplying drinking water, consume
food chain species taken from target, fisheries, or are regularly present on the site or within target
distance limits.
Terrestrial sensitive environment: A terrestrial resource, fragile natural setting, or other area with unique
or highly-valued environmental or cultural features.
USF&WS: U.S. Fish and Wildlife Service.
Water body type: Classification of a surface water body. Water body types include: streams and rivers,
lakes, oceans (includes the Great Lakes), and coastal tidal waters. See the specific definition of each
water body type for more detail.
Wetland: A type of sensitive environment characterized as an area that is sufficiently inundated or
saturated by surface or groundwater to support vegetation adapted for life in saturated soil conditions.
Wetlands generally include swamps, marshes, bogs, and similar areas.
Worker: Under the soil exposure pathway, a person who is employed on a full-time or part-time basis on
the property on which the site is located. Under all other pathways, a person whose place of full-time or
part-time employment is within the target distance limit.
*For a more complete listing, refer to: www.nttc.edu/env/info/envglos.html
or
www.epa.gov/students/dictiona.htm
PAGE 8
Preliminary Assessment Training
-------
APPENDIX C
ABC VACUUM
CASE STUDY
ANSWER SHEETS
-------
APPENDIX C
SECTION TWO
"PLAN FOR CONDUCTING ON-SITE RECON AT ABC VACUUM"
IDENTIFY DATA GAPS
1. Site ownership
2. Exact site address
3. Quantities and types of v/astes generated/stored/disposed
4. On-site drainage patterns
5. Number of nearby homes/population
6. Prior site history
PA SITE RECON OBJECTIVES FOR THE ABC VACUUM SITE
1. Conduct a local/state file search
2. Observe/verify current on-site conditions
3. Evaluate the need for emergency response/removal actions
4. Locate and identify all sources
5. Identify pathways of waste migration
6. Identify land use
7. Determine nearby population within target distance limits
8. Identify sensitive environments within target distance limits
9. Obtain prior site history/records/documentation
10. Determine ground water use
11. Locate nearby bodies of surface water
12. Estimate waste quantity
OBTAINING SITE ACCESS
1. Visit tax office and determine ownership
2. Review background information
3. Contact owner/lawyer
4. Inform owner/lawyer of site tasks to be performed
5. Get access permission in writing
6. Carry copy of site authorization to recon
PAGE 2
Preliminary Assessment Training
-------
APPENDIX C
PA TABLE 1: WASTE CHARACTERISTICS (WC) SCORES
PA Table 1A: WC Scores for Single Source Sites and Formulas
for Multiple Source Sites
T
1
E
R
c
o
N
S
T
t
T
U
E
N
T
W
A
S
T
E
S
T
R
E
A
M
V
0
L
U
M
E
A
R
E
A
SOURCE TYPE
N/A
N/A
Landfill
Surface
Impoundment
£\ Jf"ffls^# 1
•"Tanks and Not£"\ „
Contaminated Soil
Pile
Other
Landfill g p
^ Surface "^v
^***"*-^^M^^^y*1^
^Contaminated Sgjf)f
CS>#4
Land Treatment
5
3
6
SINGLE SOURCE SITES (assigned WC scores)
WC = 18
£ 100 Ib
< 500.000 Ib
46.75 million ft1
£250,000 yd3
s8.7SOfP
sZSOyd3
si ,000 drums
SSO.OOO gaHom
£6. 75 million ft1
£250.000 yd*
48.750 ft'
2250yd1
s6,7soff
S2SO yd'
£340.000 ft'
s7.8 ceres
it. 300 ft'
£0.029 acres
i3 * mill ion ft1
i78 acres
St. 300«'
40 029 seres
i27.000 It'
^0.62 acres
WC = 32
>100 to 10,000 Ib
>500.000 to 50 million Ib
>£.7S million to S7S million ff
>2SO.OOO to 2S nttHion yd*
>6,7SOto 675.000 ft3
>2SO to 25.000 y#
>1.000 to 100,000 drums
>50.000 to 5 million gaJlons
>6.7S million to 675 million It1
>250,000 to 25 million yd1
>€, 750 to 675,000ft3
>2SO to 25,000 yd1
>6.7SO to 675.000 ft'
>250 to 25,000 yd'
>340.00O to 34 million ft'
>7eto760acns
>1, 300 to 130.000 ft'
>0.029toZ9acmc
^3.4 million to 340 million ft'
,78 to 7.800 aow
-1.300 to 130.000 It1
•O 029 to 2.9 acres
,27,000 to 2.7 million ft'
^O 62 to 62 acres
WC = 100
> 10,000 Ib
>50 million Ib
>675 million ft>
>25 minion yd*
>«75.000ft>
>2S.OOOyd>
>1 00,000 drums
>5 million gallons
-675 million ft'
•25 million yd3
.675.000 «'
•25.000yd'
.675,000 ff
-2S.OOO yd'
-34 million ft'
.780 acres
vt30,000 ft'
»2.9 acres
•340 million ft'
•7.800 acres
-130.000ft'
•2 9 acres
•2 7 million ft'
-62 acres
\
MULTIPLE
SOURCE SITES
Formula for
Assigning Source
WQ Values
^- 1
Ib* 5000
If » 67,500
yfl1 + 2.500
ft"* 67.5
yd' » 25
ft' » 67.500
yd' t 2.500
n1»67 s
yd'» 2.5
«> » 67 5
yd' « 2.5
1 ton = 2,000 Ib = 1 yd' =4 drums = 200 gallons
Use area of land surface under pile, not surface area of pile.
PA Table 1 b: WC Scores for Multiple Source Sites
WQ TOTAL
.-010100
C^00to10.000^>
••10.000
WC SCORE
18
100
Preliminary Assessment Training
PAGE 3
-------
APPENDIX C
ANSWERS TO SECTION THREE
CASE STUDY: ABC VACUUM SERVICE
SOURCE CHARACTERIZATION
SOURCES
SOURCE WASTE
QUANTITY CALCULATIONS
SOURCE#1
200 55-gallon drums.
(Evaluate under Volume tier.
Use Drums source type.)
200/10 = 2
WQ1 = 20
SOURCE #2
3000 sq ft lagoon.
(Evaluate under area tier.
Use surface impoundment source type.)
3000/13 = 230.77
WQ2 » 230.77
SOURCE#3
750 sq ft oxidation pond.
(Evaluate under area tier. Use surface
impoundment source type.)
750/13 = 57.69
WQ3 = 57.69
SOURCE#4
500 sq ft rubbish pile.
(Evaluate under area tier. Use pile
source type.)
500/13 = 38.46
WQ4 = 38.46
SOURCE #5
Two 1000-gallon tanks.
(Evaluate under volume tier. Use
tank source type.)
2000/500 = 4
WQ5 = 4
SOURCE #6
1000 sq ft of ditches.
(Evaluate under area tier. Use
contaminated soil source type.)
1000/34,000 = 0.03
WQ6 = 0.03
MULTIPLE SOURCE SITE WASTE CHARACTERIZATION SCORING
Calculate the Waste Quantity (WQ) Score for each source.
Sum the highest WQ scores for each source.
Obtain the Waste characterization Score Form Table 1B
WQ (total) = WQ1 + WQ2 * WQ3 + WQ4 + WQ5 + WQ6
WQ (total) = 20 + 230.77 + 57.69 + 38.46 + 4 + 0.03
WQ + 350.95
Using Table 1B, a WQ (total) of 350.95 falls between > 100 to 10,000.
This is a Waste Characterization (WC) score of 32.
PAGE 4
Preliminary Assessment Training
-------
APPENDIX C
SECTION FOUR
ABC VACUUM SERVICE
GROUND WATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
Y
e
N U
o n
D
DB
BDD
EDP
DDB
BDD
BD
DD
Are sources poorly contained?
Is the source a type likely to contribute to
groundwater contamination (e.g., wet
lagoon)?
Is waste quantity particularly large? 732
Is precipitation heavy? 757
Is the infiltration rate high?
Is the site located in an area of karst
terrain?
Is the subsurface hilghly permeable or
conductive?
Is drinking water drawn from a shallow
aquifer?
Are suspected contaminants highly mobile
in groundwater? ^Q ])Q{Q
Does analytical or circumstantial evidence
suggest groundwater contamination?
Other criteria? Stained Soil
SUSPECTED RELEASE?
DD7
DDR
DD0
DDE
DBD
HDD
EDO
Is any drinking-water well nearby?*
Has any nearby drinking-water weH been
closed?
Has any nearby drinking-water user
reported foul-tasting or foul-smelling water?
Does any nearby well have a large draw-
down or high production rate?
Is any drinking-water well located be-
tween the site and other wells that are
suspected to be exposed to a hazardous
substance?
Does analytical or circumstantial evidence
suggest contamination at a drinking-water
well?
Does any drinking-water well warrant
sampling?
Other criteria? JtoD^^eJaKD
PRIMARY TARGET(S) IDENTIFIED?
Nearby is defined as within 1/8 of a mile; see Page 66
in PA Guidance Manual.
Summarize the rationale for Suspected Release
(attach an additional page if necessary):
Unlined lagoon and oxidation pond:
siained soil.
Summarize the rationale for Primary Targets (attach
an additional page if necessary):
5 private wells;
shallow aquifer.
Preliminary Assessment Training
PAGE 5
-------
SECTION FOUR
ABC VACUUM SERVICE
PA TABLE 2: VALUES FOR SECONDARY GROUNDWATER TARGET POPULATIONS
PA Table 2a: Non-Karst Aquifers
Distance
from Site
0 to 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mile
> 1 to 2 miles
> 2 to 3 miles
> 3 to 4 miles
Population
0
1%1
w*>
0
0
0
Nearest Well =
Nearest Well
(choose
highest)
20
(7e)
9
5
3
2
\s
Population Served by Wells Within Distance Category
1
to
10
1
1
1
1
1
i
11
to
30
2
1
1
1
1
1
31
to
100
5
3
2
1
1
1
101
!o
300
16
10
5
3
2
1
301
to
1,000
52
32
17
9
7
4
1,001
to
3.000
163
0°V
52
29
21
13
3,001
to
10.000
521
323
CjeT)
94
68
42
10.001
to
30.000
1.633
1,012
522
294
212
131
30,001
to
100,000
5,214
3.233
1,668
939
678
417
Greater
than
100.000
16,325
10,121
5.224
2.938
2,122
1,306
Score =
Population
Value
0
101
167
0
JL
0
266
PA Table 2b: Karst Aquifers
Distance
from Stie
0 to 1/4 mile
> 1/4 to 1/2 mile
> 1/2 to 1 mile
> 1 to 2 miles
> 2 to 3 miles
> 3 to 4 miles
Population
Nearest Well -
Nearest Well
(choose
highest)
20
20
20
20
20
20
Population Served by Wells Within Distance Category
,'o
10
1
1
1
1
1
1
11
to
30
2
1
1
1
1
1
31
to
100
5
3
3
3
3
3
101
to
300
16
10
B
8
8
8
301
to
1,000
52
32
26
26
26
26
1,001
to
3.000
163
101
82
82
82
82
3,001
to
10,000
521
323
261
261
261
261
10,001
to
30,000
1,633
1,012
816
816
816
816
30.001
to
1 00,000
5.214
3,233
2,607
2,607
2,607
2,607
Greater
than
100.000
16.325
10,121
8,162
8,162
8,162
8.162
Score =
Population
Value
-------
APPENDIX C
SECTION FOUR
ABC VACUUM SERVICE
GROUNDWATER PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Groundwater Pathway Criteria List, page 7J
Is the site located in Karst terrain? [TOfT)
Depth to aquifer:
Distance to the nearest drinking-water well:
Yes
Yes.
Previous Info^
V_No_.y~
NaZI
30 «
100 to 200 ft
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to groundwater (See page 7),
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release to groundwater, and
the site is in karst terrain or the depth to aquifer is 70 feet or less, assign a score
of 500; otherwise, assign a score of 340. Use only Column B for this pathway
LR =
TARGETS
5.
6.
PRIMARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you suspect have been exposed to a hazardous
Undwater Pathway Criteria List, page 7.)
• - " - c -. 2fl people x 10 =
substance from the site. ISee Groundwater
Round Up Wue —•> 3, B or 4 x
SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water wells that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 2.
Are any wells part of a blended system? Yes V No
If yes, attach a page to show apportionment calculations.
NEAREST WELL: If you have identified a primary target population for ground-
water, assign a score of 50; otherwise, assign the Nearest Well score from
PA Table 2. if no drinking-water well exist within 4 miles, assign a score of zero.
WELLHEAD PROTECTION AREA (WHPA): If any source lies within or above a
WHPA, or if you have identified any primary target well within a WHPA, assign a
score of 20; assign 5 if neither condition holds but a WHPA is present within 4
miles; otherwise, assign zero.
7. RESOURCES
Crayfish Farm
268
0)
50
(20.50.11)
0
(5«OI
flC.I».».S.3.2(rO>
(20.5 or 0)
(SorO)
T =
WASTE CHARACTERISTICS
8.
Gl
A. If you have identified any primary target for groundwater, assign the waste
characteristics score calculated on page 4, or score or 32. whichever is
GREATER. Do not evaluate part B of this factor.
B. If you have NOT identified any primary target for groundwater, assign the
waste characteristics score calculated on page 4.
WC =
3OUND WATER PATH WAY SCORE' LR x T x WC
82,500
(100. 31 or It) (100,32or1t}
0
32
(SOjKt to m m«nmum or tOO)
100 (11137)
Preliminary Assessment Training
PAGE?
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE
SURFACE WATER PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Is surface water nearby? < 2
Is waste quantity particularly large? > 32
Is the drainage area large? \$fo Acres
Is rainfall heavy? 57
Is the infiltration rate low? 72 /T
Are sources poorly contained or prone to
runoff or flooding? 2^~Hf Rdin
Is a runoff route well defined (e.g
or channel leading to surface water
Is vegetation stressed along the probable
runoff route? No Data
Are sediments or water unnaturally
discolored?
Is wildlife unnaturally absent?
Has deposition of waste into surface water
been observed?
Is groundwater discharge to surface water
likely?
Does analytical or circumstantial evidence
suggest surface water contamination?
Other criteria? No DflTfl
SUSPECTED RELEASE?
Y N U
eon
DO
DDE
DDE
i/na
any drinking-water well nearby? If yes:
'Drinking-water intake
'Fishery
Sensitive environment
Has any intake, fishery or recreational
area been dosed? fJQ Data
Does analytical or circumstantial evidence
suggest surface water contamination at or
downstream of a target?
Does any target warrent sampling? If yes:
fDrinking-water intake
MShery R
Sensitive environment Pu>
Other criteria? (12 IDJleS
PRIMARY INTAKE'S) IDENTIFIED?
PRIMARY FISHERY(IES) IDENTIFIED?
PRIMARY SENSITIVE ENVIRONMENT^}
IDENTIFIED? (D BJ)
Summarize the rationale for Suspected Release
Heavy rainfall runoff route well defined.
surface wafer nearby.
Summarize the rationale for Primary Targets (attach
Fishery, bayou: critical habitat may not
be a primary target. (SB)
PAGE 8
Preliminary
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE
SURFACE WATER PATHWAY SCORE SHEET
LIKELIHOOD OF RELEASE AND DRINKING-WATER THREAT SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Surface Water Pathway Criteria List, page 11.)
Distance to surface water?
Flood frequency:
What is the downstceam distance to the nearest drinking-water intake?
Nearest fishery? 3>IC mites. Nearest sensitive environment?
Yes
715
.miles.
.miles.
19 miles from PPE or 3 miles from site
LIKELIHOOD OF RELEASE
References
1,
2.
SUSPECTED RELEASE: If you suspect a release to surface water (See
page11). assign a score of 550. Use only Column A for this pathway.
NO SUSPECTED RELEASE. If you do not suspect a release to surface water
use the table below to assign a score based on distance to surface water and
flood frequency. Use only Column 8 for this pathway.
Distance to surface water <, 2,500 ft
Distance to surface water > 2,500 ft, and
Site in annual or 10-yr floodplain
Site in 100-yr floodplain
Site in 500-yr floodplain
Site outside 500-yr floodplain
500
500
400
300
100
DRINKING WATER THREAT TARGETS
3. Record the water body type, flow (if applicable) and number of people served by
each drinking-water intake within thte target distance limit. If there is no drinking-
water intake within the target distance limit, factors 4, 5, and 6 each receive zero
scores.
Intake Name
Water Body Type Flow
cfs
cfs
efs
People Served
4.
PRIMARY TARGET POPULATION: If you suspect any drinking-water intake listed
above has been exposed to a hazardous substance from the site (see Surface
Water Pathway Criteria List, Page 11). list the intake name(s) and calculate the
factor score based on the total population served
. people x 10 =
5. SECONDARY TARGET POPULATION: Determine the number of people served by
drinking-water intakes that you do NOT suspect have been exposed to a hazardous
substance from the site, and assign the total population score from PA Table 3.
Are any intakes part of a blended system? Yes No
If yes, attach a page to show apportionment escalations.
6. NEAREST INTAKE. If you have identified a primary target population for the
drinking-water threat (factor 4), assign a score of SO, otherwise, assign the
Nearest Intake score from PA Table 3. If no drinking-water intake exists within the
target distance limit, assign a score of zero.
7. RESOURCES
0
(50.30.10.2.1 pr»)
0
(SorO)
5
(2O.10.2.1orOt
T =
Preliminary Assessment Training
PAGE 9
-------
SECTION FIVE
ABC VACUUM SERVICE
PA TABLE 3: VALUES FOR SECONDARY SURFACE WATER TARGET POPULATIONS
Surface Water
Body Flow
(see PA Table 4)
<10 cfs
10 to 100 cfs
>100to1,000cfs
-1,000 to 10,000 eft
>10,000 cfs or
Great Lake
3-Mile Mixinp Zone
Population
___ — —
— —
Nearest Intake =
Nearest
Intake
(choose
highest)
20
2
1
0
0
10
NA:
Population Served by Intakes Within Distance Category
1
to
30
2
1
0
0
0
1
31
to
100
5
1
0
0
0
3
101
to
300
16
2
1
0
0
6
301
to
1.000
52
5
1
0
0
26
1,001
to
3.000
163
16
2
1
0
82
3,001
to
10.000
521
52
5
1
0
261
10.001
to
30.000
1.633
163
16
2
1
816
30,001
to
100.000
5,214
521
52
5
1
2.607
100,001
to
300.000
16,325
1,633
163
16
2
8.162
300,001
to
1 .000.000
52.136
5.214
521
52
5
26,066
Greater
than
1 .OpQ.OOQ
163,246
1 6,325
1,633
163
16
81,663
No know Wakes within 15 miles downstream of site. Scofe =
Population
Value
PA TABLE 4: SURFACE WATER TYPE/FLOW CHARACTERISTICS
Type of Surface Water
Water Body Type OR
minimal stream
small to moderate stream
moderate to large stream
large stream to river
large river
3-mlle mixing zone of quiet
flowing streams or rivers
coastal tidal water (harbors,
sounds, bays, etc.), ocean or
Great Lakes
Body
Flow
100 to 1,000 cfs
>1. 000 to 10,000 cfs
>10,000 cfs
1 0 cfs or greater
N/A
Dilution
1
0.1
N/A
N/A
N/A
N/A
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE
SURFACE WATER PATHWAY (cont)
HUMAN FOOD CHAIN THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 1 2. LR -
Suspected
Release
(550)
550
No
Suspected
Release
(500. 400.300 or
100)
Reference
HUMAN FOOD CHAIN THREAT TARGETS
8.
Record the water body type, flow (if applicable) for each fishery within the target
distance limit. If there is no fishery within the target distance limit, assign a
Targets score of 0 at the bottom of the page.
Fishery Name
&dyou
'
River
Water Body Type
sm. stream
mnd. strMm
Row
P cfs
cfs
cfs
!jf J?
9. PRIMARY FISHERIES: If you suspect any fishery listed above has been exposed
to a hazardous substance from the site (see Surface Water Pathway Criteria List.
Page 11), assign a score of 300, and do not evaluate Factor 10. List the primary
fisheries:
Bayou
River
10. SECONDARY FISHERIES:
a. If you suspect a release to surface water and have identified a secondary
fishery, but no primary fishery, assign a score of 210.
b. If you do not suspect a release, assign a Secondary Fisheries score from the
table below using the lowest flow at any fishery within the target distance limit.
Lowest Flow
< 10 cfs
10to lOOcfs
> 100 cfs, coastal
tidal waters, oceans
or Great Lakes
Secondary Fisheries Score
210
30
12
T =
Preliminary Assessment Training
PAGE 11
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE
SURFACE WATER PATHWAY (cont.)
ENVIRONMENTAL THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 1 2. LR =
Suspected
Release
»»}
550
Mo
Suspected
Release
(SOO.400.3Ol!!
100)
Reference
ENVIRONMENTAL THREAT TARGETS
1 1
. Record the water body type, flow (if applicable) for each surface water sensitive
environment within the target distance Omit {see PA Tables 4 and 5). If there are
no sensitive environments within the target distance limit, assign a Target score of
0 at the bottom of the page.
Environment Name
FederalF
yli$i
iere<
:ed
Water Body Type
River
Flow
75
_ cfs
cfs
' ' cfs
Cffi
W^tMrv
75
_ cfs
12. PRIMARY SENSITIVE ENVIRONMENTS: If you suspect any sensitive environment
listed above has been exposed to a hazardous substance from the site (see Surface
Water Pathway Criteria List. Page 11). assign a score of 300. and do not evaluate
Factor 13. List the primary environments:
13. SECONDARY SENSITIVE ENVIRONMENTS: If sensitive environments are
present but none is a primary sensitive environment, evaluate Secondary Sensitive
Environments based on flow.
a. For secondary sensitive environments on surface water bodies with flows of
100 cfs or less, assign scores as follows, and do not evaluate Part B of this factor.
Flow
cfs
cfs
cfs
cfs
cfs
Dilution Weight
(PA Table 4)
X
X
X
X
X
EnvironmontType and Value
(PA Tables 5 and 6)
S
s
£
•
2
Test
b.
Sum
If all secondary sensitive environments are located on surface water bodies with
flows > 100 cfs assign a score of 10.
0
(10)
0
110)
300
PAGE 12
Preliminary Assessment Training
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE X
SURFACE WATER PATHWAY (cortt.)
ENVIRONMENTAL THREAT SCORE SHEET
B
LIKELIHOOD OF RELEASE
Enter Surface Water Likelihood of Release score from Page 12. LR =
Suspected
Release
(sso)
550
Mo
Suspected
Release
(sgo.40o.aoo «
100)
Reference
ENVIRONMENTAL THREAT TARGETS
11. Record the water body type, flow (if applicable) for each surface water sensitive
environment within the target distance limit (see PA Tables 4 and S). If there are
no sensitive environments within the target distance limit, assign a Target score of
0 at the bottom of the page.
Environment Name Water Body Type
FederdlK
1 fisted River
ered speries
r
Flow
75
cfs
cfs
cfs
cfs
Wctktnd
75
cfs
12. PRIMARY SENSITIVE ENVIRONMENTS: If you suspect any sensitive environ-
ment listed above has been exposed to a hazardous substance from the site
(see Surface Water Pathway Criteria List, Page 11}. assign a score of 300. and do
not evaluate Factor 13. List the primary environments:
13. SECONDARY SENSITIVE ENVIRONMENTS: It sensitive environments are
present but none is a primary sensitive environment, evaluate Secondary Sensitive
Environments based on flow.
a. For secondary sensitive environments on surface water bodies with flows of 100
cfs or less, assign scores as follows, and do not evaluate Part B of this factor.
Flow
75 cfs
cfs
cfs
75 cfs
cfs
Dilution Weight
(PA Table 4)
0.1 X
X
X
0.1 X
X
EnvironmentType and Value
(PA Tables 5 and 6)
ion
=
=
75
s
Test
10
Z 5
Sum =
b. If all secondary sensitive environments are located on surface water bodies with
flows >100 cfs assign a score of 10.
12.5
110)
0
110)
12.5
Some environments may be listed under several designations;
use all that apply.
Preliminary Assessment Training
-------
APPENDIX C
SECTION FIVE
ABC VACUUM SERVICE
SURFACE WATER PATHWAY (concluded)
WASTE CHARACTERISTICS, THREAT AND PATHWAY SCORE SUMMARY SHEET
WASTE CHARACTERISTICS
10. a. If you have identified any primary target for surface water (Pages 12. 14. or
15), assign the waste characteristics score calculated on Page 4, or score of
32, whichever is GREATER. Do not evaluate Part B of this factor.
b. If you have NOT identified any primary target for surface water, assign the
waste characteristics score calculated on Page 4.
wc =
ENVIRONMENTAL THREAT TARGETS
Threat
Drinking Water
Human Food
Chain
Environmental
Likelihood of
Release (LR) Score
(from Page 12)
550
550
550
Target (T) Score
(Pages 12, 14, 15)
5
300
12.5j^
^^300
Pathway Waste
Characteristics (WC) Score
(determined above)
32
32
32
SURFACE WATER PATHWAY SCORE
(Drinking Water Threat + Human Food Chain Threat
+ Environmental Threat)
Threat Score
LRxTxWC
/ 82.500
(SJ>)»et to i mmanvm of 100|
1.07
(SuojMf lo x minmuBi of 100)
61
t$uM*cl w a maanm of SJL— — '
5^6^)
(SuBfrrt to a ntsbnun of 100). — "
6jJ^m
*W'iT.hout primary sensitive environments
(125.07)
PAGE 14
Preliminary Assessment Training
-------
APPENDIX C
SECTION SIX
ABC VACUUM SERVICE
SOIL EXPOSURE PATHWAY CRITERIA LIST
SUSPECTED CONTAMINATION
RESIDENT POPULATION
Surficial contamination can generally be assumed.
Y N U
eon
CDD
DDE
vfnn
DDE
Is any residence, school, or daycare facility
on or within 200 feet of an area of sus-
pected contamination?
Is any residence, school, or daycare facility
located on adjacent land previously owned
or leased by the site owner/operator?
Is there a migration route that might spread
hazardous substances near residences,
schools, or daycare facilities?
Have on-site or adjacent residents or
students reported adverse health effects,
exclusive of apparent drinking water or air
contamination problems?
Does any neighboring property warrant
sampling? .
other criteria? stained
RESIDENT POPULATION IDENTIFIED?
Summarize the rationale for Resident Population (attach an additional page if necessary):
Drainage ditch, siained soil.
Preliminary Assessment Training
PAGE 15
-------
APPENDIX C
SECTION SIX
ABC VACUUM SERVICE
SOIL EXPOSURE PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do any people live on or within 200 ft of areas of suspected contamination?
Do any people attend school or daycare on or within 200 ft of areas of
suspected contamination? /
Is the facility active? Yes Noy If yes. estimate the number of workers; f\l
LIKELIHOOD OF EXPOSURE
1. SUSPECTED CONTAMINATION: Surficial contamination can generally be
assumed, and a score of 550 assigned. Assign zero only is the absence of
surficial contamination (see Soil Exposure Pathway Criteria list, Page 18). (_£ =
Yes ¥ No
. Yes No^
L_
Suspected
Contamination
dm oo>
550
RESIDENT POPULATION THREAT TARGETS
2. RESIDENT POPULATION: Determine the number of people occupying residences
or attending school or daycare on or within 200 ft of areas of suspected contamina-
tion (see Soil Exposure Pathway Criteria List, Page 18). 19 people x 10 -
From actual data
3. RESIDENT INDIVIDUAL: If you have identified a resident population (Factor 2).
assign a score of 50; otherwise, assign a score of 0.
4. WORKERS: Use the following table to assign a score based on the total number of
workers at the facility and nearby facilities with suspected contamination:
Numtxr of Workers Sean
0 0
110100 5
101 to 1.000 10
>t,000 15
5. TERRESTRIAL SENSITIVE ENVIRONMENTS: Use PA Table 7 to assign a value foi
each terrestrial sensitive environment on an area of suspected contamination:
Temslnal Sensible £rn/ronmenf Type Vttue
Sam-
e. RESOURCES None on contaminated soil
T =
WASTE CHARACTERISTICS
7. Assign the waste characteristics score calculated on Page 4. \A/C =
LE x T x WC
KtSIUbNt POPULATION THREAT SCURc. -- CAQ
NEARBY POPULATION THREAT SCORE: < 10,000 V/|t,Kin 1 milt
SOIL EXPOSURE PATHWAY SCORE:
Resident Population Threat + Nearby Population Threat
190
(SOerO)
50
(1 S.I 0.5 or 0»
0
0
(SorQ)
0
m
(IPO. 13 Of )•)
32
Itutjld 10 • ina»mun if 100)
51.20
(«.2« 1)
1
1*«*}«cl to a mwamum of 100)
52.20
Reference
PAGE 16 Preliminary Assessment Training I
-------
APPENDIX C
SECTION SEVEN
ABC VACUUM SERVICE
AIR PATHWAY CRITERIA LIST
SUSPECTED RELEASE
PRIMARY TARGETS
Y N U
eon
5 >
DDE,
ODD
DDE
Are odors currently reported?
Has release of a hazardous substance to
the air been directly observed? ^0 Ptftd
Are there reports of adverse health effects
(e.g., headaches, nausea, dizziness)
potentially resulting from migration of
hazardous substances through the air?
Does analytical or circumstantial evidence
suggest a release to the air?
Other criteria? UnCOVered SOUKCS
If you suspect a release to air, evaluate all populations
and sensitive environments within 1/4 mile (including
those on site) as primary targets.
SUSPECTED RELEASE?
BE)
Summarize the rationale for Suspected Release (attach an additional page if necessary):
Uncovered sources near residences, stdined soil.
-------
APPENDIX C
mile
SECTION SEVEN
ABC VACUUM SERVICE
AIR PATHWAY SCORE SHEET
PA THWA Y CHARA CTERISTICS
Do you suspect a release? (See Air Pathway Criteria List, page 21 .) Yes
Distance to nearest individual?
J No
_nLft
LIKEUHOOD OF RELEASE
1. SUSPECTED RELEASE: If you suspect a release to air (See page 21).
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release of air, assign
a score of 500. Use only Column B for this pathway.
TARGETS
3. PRIMARY TARGET POPULATION: Determine the number of people subject to
exposure from a suspected release of hazardous substances to the air.
19 residents * 10 workers at crayfish pond 29 people x 10 =
4. SECONDARY TARGET POPULATION: Determine the number of people not
suspected to have been exposed to a release of air, and assign the total
population score using PA Table 8.
5 NEAREST INDIVIDUAL: If you have identified any Primary Target Population for
the air pathway, assign a score of 50; otherwise, assign the Nearest Individual
score from PA Table 8.
6. PRIMARY SENSITIVE ENVIRONMENTS: Sum the sensitive environment values
(PA Table 5) and wetland acreage values (PA Table 9) for environments subject
to exposure from a suspected release to the air.
Sum'
7.
SECONDARY SENSITIVE ENVIRONMENTS: Use PA Table 10 to determine the
score for secondary sensitive environments.
RESOURCES
Crayfish Farm
WASTE CHARACTERISTICS
T =
290
(SO.20.77.locO)
50
(20,7.2.1 or 0)
0
(SorO)
5
351
(5 or 0|
9. A. If you have identified any Primary Target for the air pathway, assign the waste
characteristics score calculated on Page 4. or a score of 32, whichever is
GREATER. Do not evaluate Pan B of this factor.
B If you have NOT identified any Primary Target for the
waste characteristics score calculated on Page 4.
AIR PATHWAY SCORE:
air pathway, assign the
WC =
LR x T x WC
82,500
7; _
< 100.32 « 1 1> ( 100.32 or It)
0
32
IwAlM la • m»nwi of 100)
71.88
PAGE 18
Preliminary Assessment Traimng
-------
APPENDIX C
SECTION SEVEN
ABC VACUUM SERVICE
AIR PATHWAY SCORE SHEET
PATHWAY CHARACTERISTICS
Do you suspect a release? (See Air
Distance to nearest individual?
Pathway Criteria List, page 21 .)
Yes _^NoJ/_
B
LIKELIHOOD OF RELEASE
1. SUSPECTED RELEASE. If you suspect a release to air (See page 21),
assign a score of 550. Use only Column A for this pathway.
2. NO SUSPECTED RELEASE: If you do not suspect a release of air. assign
a score of 500. Use only Column B for this pathway.
TARGETS
3. PRIMARY TARGET POPULATION: Determine the number of people subject to
exposure from a suspected release of hazardous substances to the air.
people x 10 =
4. SECONDARY TARGET POPULATION: Determine the number of people not
suspected to have been exposed to a release of air, and assign the total
population score using PA Table 8.
5. NEAREST INDIVIDUAL: If you have identified any Primary Target Population for
the air pathway, assign a score of 50; otherwise, assign the Nearest Individual
score from PA Table 8.
6. PRIMARY SENSITIVE ENVIRONMENTS: Sum the sensitive environment values
(PA Table 5) and wetland acreage values (PA Tabie 9) for environments subject
to exposure from a suspected release to the air.
Sensitive Environment Type
Vtlue
Sum'
SECONDARY SENSITIVE ENVIRONMENTS: Use PA Table 10 to determine the
score for secondary sensitive environments.
8. RESOURCES
Crayfish Form
(SO.20.7.2.1orO)
(20.7.2.1 Of 0)
(SorO)
0
(SorO)
T =
WASTE CHARACTERISTICS
32
9. A. If you have identified any Primary Target for the air pathway, assign the waste
characteristics score calculated on Page 4, or a score of 32, whichever is
GREATER. Do not evaluate Part B of this factor.
B. If you have NOT identified any Primary Target for the
waste characteristics score calculated on Page 4.
AIR PATHWAY SCORE:
air pathway, assign the
WC =
LR x T x WC
82,500
...... ^
(tOO.Mcr II) (100.32 or 11)
32
32
(!!*)• Bt to I IWMMK of 100)
6.21
Preliminary As
PAGE 19
-------
PA TABLE 8: VALUES FOR<|ECONDARj>AIR TARGET POPULATIONS $USpeded Release
Distance
from
Site
Onsite
>Oto'/4 mile
>V. to % mile
>'/, to 1 mite
>1 to 2 miles
>2 to 3 miles
>3 to 4 Miles
Population
1Q96
1254
JZ22_
2106
Nearest Intake =
Nearest
Intake
(choose
highest)
20
20
2
0
0
0
1
Population Within Distance Category
1
to
10
1
1
0
0
n
0
0
11
to
30
2
1
0
0
0
0
0
31
to
100
5
1
1
0
0
0
0
101
to
300
16
4
1
1
0
0
0
301
to
1,000
52
13
3
1
1
1
0
1,001
to
3,000
163
41
9
3,001
to
10,000
521
130
26
8
3
1
1
10.001
to
30,000
1,633
406
88
26
8
4
2
30,001
to
1 00,000
5,214
1,303
282
83
27
12
7
100,001
to
300,000
16,325
4.081
882
261
83
38
23
300.001
to
LOOO.OOO
52,136
13,034
2.815
834
266
120
73
Greater
than
1 ,000,000
163,246
40,81 1
8,816
2,612
833
376
229
Score =
Population
Value
0
0
0
3
1
1
1
6
PA TABLE 9: AIR PATHWAY VALUES
FOR WETLAND AREA
Wetland Ana
less than 1 acre
1 to 50 acres
Greater than 50 to 100 acres
Greater than 100 to 150 acres
Greater than 150 to 200 acres
Greater than 200 to 300 acres
Greater than 300 to 400 acres
Greater than 400 to 500 acres
Greater than 500 acres
Assigned Value
0
25
75
125
175
250
350
450
500
PA TABLE 10: DISTANCE WEIGHTS AND CALCUALTIONS
FOR AIR PATHWAY SECONDARY SENSITIVE ENVIRONMENTS
Distance
Onsite
0- 1/4 mile
1/4- 1/2 mile
Distance
Weight
0.10
0.025
0.0054
Sensitive Environment Type and Value
(from PA Table 5 or 9)
X
X
X
X
X
X
X
X
X
Total Environmental Score =
Product
-------
PA TABLE 8: VALUES FOR SECONDARY AIR TARGET POPULATIONS No $U5peded Rektfse
Distance
from
Site
Onsite
>OtoY« mile
>% to % mile
>'/. to 1 mile
>1 to 2 miles
>2 to 3 mites
>3 to 4 Mites
Population
-22_
-JL-
1096
1254
1733
2H06
Nearest Intake =
Nearest
Intake
(choose
highest)
20
2
t
0
0
0
20
Population Within Distance Category
1
to
10
1
1
0
0
0
0
0
11
to
30
2
0
0
0
0
0
31
to
100
5
1
1
0
0
0
0
101
to
300
16
4
1
1
0
0
0
301
to
1,000
52
13
3
1
1
1
0
1,001
to
3,000
163
41
9
3,001
to
1 0,000
521
130
28
8
3
1
1
10,001
to
30,000
1,633
406
88
26
8
4
2
30,001
to
100,000
5,214
1,303
282
83
27
12
7
100,001
to
300,000
16.325
4,081
882
261
83
38
23
300,001
to
1 ,000,000
52,136
13,034
2.815
834
266
120
73
Greater
than
1 ,000,000
163,246
40,811
8,815
2,612
833
376
229
Score =
Population
Value
0
0
3
1
1
-J-
7
PA TABLE 9: AIR PATHWAY VALUES
FOR WETLAND AREA
PA TABLE 10: DISTANCE WEIGHTS AND CALCUALTIONS
FOR AIR PATHWAY SECONDARY SENSITIVE ENVIRONMENTS
Wetland Area
Less than 1 acre
1 to 50 acres
Greater than 50 to 100 acres
Greater than 100 to 150 acres
Greater than 150 to 200 acres
Greater than 200 to 300 acres
Greater than 300 to 400 acres
Greater than 400 to 500 acres
Greater than 500 acres
Assigned Value
0
25
75
125
175
250
350
450
500
Distance
Onsite
0- 1/4 mile
1/4-1/2 mile
Distance
Weight
0.10
0.025
0.0054
Sensitive Environment Type and Value
{from PA Table 5 or 9)
X
X
X
X
X
X
X
X
X
Total Environmental Score =
Product
-------
APPENDIX C
SECTION EIGHT
ABC VACUUM SERVICE
SITE SCORE CALCULATION
GROUNDWATER PATHWAY
SCORE
100.00
10,000
SURFACE WATER PATHWAY
SCORE (SJ:
too.oo'
67.74
10,000
SOIL EXPOSURE PATHWAY
SCORE (S,):
52.20
2724.64
AIR PATHWAY
SCORE (St):
74.86
6.21
5607.
38.56
SITE SCORE:
With primary sensitive environments
c Suspected release to air pathway
84.16
65.86
SUMMARY
1 . Is there a high possibility of a threat to any nearby drinking-water well(s) by migration of a
hazardous substance in groundwater?
a.lf yes. identify the well(s). -. n .11 j. 11
-------
APPENDIX C
CASE STUDY SUPPLEMENT:
SMITH AIR FORCE BASE (Federal Facility)
OBJECTIVE
Using background information provided, complete the "General Information" portion of the PA
score sheets.
METHOD
1. Review the background information, site map, telecon notes, and underground
storage tank report.
2. Using an outline format complete the "Site Description and Operational History"
and "Probable Substances of Concern" portions on pages 2-19 to 2-21 of the PA score
sheets included in the student manual.
3. Complete Sections 1, 2, 3, and 5 of the "EPA Potential Hazardous Waste Site
Preliminary Assessment Form" found on pages D-3 to D-4 in Appendix D of the
PA Guidance Manual.
4. Identify data gaps, develop a set of eight (8) PA site reconnaissance objectives,
and outline the steps necessary to obtain site access.
5. Complete the site safety plan for an on-site reconnaissance, and complete the
equipment list to meet your PA objectives.
General Overview:
Smith Air Force Base (AFB), first commissioned in 1942, is the current home of the 999th
Military Airlift wing which provides immediate airlift and sustenance capabilities for air and
ground combat units worldwide. Several types of activities at Smith AFB have potentially
contributed to environmental contamination of the base. These activities include, but are not
limited to, aircraft maintenance, fire fighting training, industrial waste treatment, solid waste
land filling, and grounds maintenance.
Smith AFB, is located in the town of Mt. Airy, California, a moderate-sized suburban
community with a population of 40,000. The base encompasses 1600 acres on the north-
eastern end of Happy Valley, an alluvial valley flanked by moderately steep mountain ranges.
The land is characterized by a downward gradient from north to south. An intermittent stream
runs through the center of the site; the stream empties into the South River, a small river
which flows from southwest to northeast on the southern edge of the base. The South River
flows into the East River approximately 1/2 mile from the southeastern comer of the facility.
The East River flows north toward Mt. Airy. The Mt. Airy region is moderately dry, with an
annual net precipitation of 15.5 inches. A wetland area is located at the confluence of the
intermittent stream and the South River and extends in both directions along the bank of the
South River. The base is entirely fenced along its perimeter and entry to Smith is by pass only
through guarded gates.
\ssessment Training
PAGE 23
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
WORKSHEET
Identify Data Gaps:
List at Least Eight (8) PA Site Reconnaissance Objectives;
1.
2.
3.
4.
5.
6.
7. „
8.
Outline the Steps Necessary to Obtain Site Access:
PAGE 24
Preliminary Assessment Training
-------
t
N
RESIDENTIAL
F
OPEN
FIELD
SMITH AIR FORCE BASE
Meeting Airy, California
1 1
0 '/2
1 1
1 2
Miles
IRRIGATION
WELL
OFF-BASE
HOUSING
! T
• I BASE .
| I HOUSING I
RESIDENTIAL
A
RESIDENTIAL
r* SCHOOL
u an
~ DAYCARE
A 09 CENTER
3>dT|j
FIRE FIGHTING ||
TRAINING AREA
Hi
UJ
GOLE/I 0Pond
I COURSE Vl
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
TELEPHONE CONVERSATION RECORD
CONVERSATION WITH: MAJOR TOM
COMPANY: SMITH AIR FORCE BASE
.DATE: 4/20/99
.TIME: 1300 HOURS
ADDRESS: 25 FIRST STREET
MT. AIRY, CALIFORNIA
(916)123-7890
PHONE:
SUBJECT: HAZARDOUS MATERIALS USED ON BASE
NOTES:
I contacted Major Tom of Smith Air Force Base and asked him what
types of hazardous materials were handled at the base. He stated
that he did not have a detailed list of hazardous materials, but he
knew that flammable materials were used in the fire training area
since the early 1940s. These materials include jet fuel, methyl
ethyl ketone (MEK), and gasoline. They were set on fire and used to
simulate aircraft fires on mock aircraft and other debris to train
fire fighting personnel. Major Tom stated that this area was
excavated last year under a "removal order" and that clean soil was
backfilled into the pit. He also knew of an underground steel
storage tank in the maintenance hangar that he thinks contains
diesel fuel used by base motor vehicles. In addition, he stated
there was an old but covered landfill at the base where sludge from
the base's waste treatment plant, old paint, paint cans, residual
pesticides, construction debris, automotive and aircraft batteries,
and hundred of gallons of sulfuric acid from these batteries was
disposed along with other unknown materials and solvent-type
liquids. Untreated sulfuric acid was also disposed of at the waste
treatment plant and possibly into the South River. Lastly, the base
formerly maintained a pesticide shed near the golf course. Here,
pesticides such as DDT and Roundup were stored, mixed, and used for
grounds maintenance. He admitted that in the past, pesticides may
have been spilled or waste pesticides disposed of on the ground
adjacent to this shed. Major Tom said he would forward me a more
detailed list of hazardous materials, once he compiles it.
PAGE 26
Preliminary Assessment Training
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
SITE, SOURCE AND WASTE CHARACTERIZATION
OBJECTIVE
Using background information provided from the previous exercise and the site map,
determine the waste characteristic score for each source.
METHOD
1. Review the source information provided below.
2. Describe each source on the Source Evaluation work sheet and determine whether
they are CERCLA—type eligible hazardous substances. Each source and corre-
sponding number can be found on the accompanying site map.
3. Evaluate each source under as many tiers as possible based upon the information
provided. Select the best (highest scoring) tier. In the PA Guidance manual, use PA
Table 1, "Waste Characteristics (WC) Scores" and the source descriptions to calculate
the WC scores for each source. MRS conversion factors are listed on the bottom of
the last page of this exercise.
4. Record the calculations and the scores on the Source Evaluation score sheets on
pages 3-16 and 3-17 of the student manual.
5. Complete Section 6 of the "EPA Potential Hazardous Waste Site Preliminary
Assessment Form" found on page D-4 in appendix D of the PA Guidance manual.
Sources:
During the PA file search, five potential hazardous waste generation storage or disposal
sources were identified at Smith AFB:
Source 1: Fire Fiohting Training Area
A shallow, unlined dirt pit exists in the northeast comer of the base and has been used as a
fire-fighting training area since 1943. Airplane wreckage and mock airplanes are placed in the
pit, soaked with waste fuels and set afire to provide practice and training for fire fighters.
Substances known to have been bumed at the pit include diesel fuel, jet fuel and gasoline.
The pit is approximately 30 feet wide by 50 feet long and 5 feet deep. Soil in the pit area is
blackened and unvegetated. Contaminated soil was excavated and completely removed from
the base last year and disposed of at a permitted RCRA facility in Utah, as part of a "qualifying
removal action."
Source 2: Pesticide Mixing and Rinsate Area
From the mid-1950s to 1982 pesticides applied at the base were stored and mixed at a shed
located near the maintenance garage by the golf course. An intermittent stream that empties
into the South River is located approximately 100 feet from this area. During mixing and
rinsing in a 200-gaHon sprayer tank, pesticide-laden water was disposed of onto bare ground
toward the nearby intermittent stream. An area of heavily stained soil and dead vegetation,
measuring 80 feet by 50 feet, occurs in a small valley leading toward the intermittent stream.
Preliminary Asses;
-------
APPENDIX C
The sprayer tank is no longer present, and no pesticide mixing is currently done on base.
Pesticides known to have been used at the base include DDT, 2,4-D, Telvar, Aminotrizol and
Roundup.
SourceS: Underground Storage Tank
A 6000-gallon underground steel storage tank has stored diesel fuel for use by base vehicles
for more than 40 years. The tank has never been inspected and remains in place today. Its
present volume of diesel fuel is unknown.
Source 4: South Landfill
From 1958 to 1975, wastes generated at the facility were disposed of at the South Landfill,
located between the maintenance garage and the intermittent stream/wetland area. The
landfill occupies approximately 18 acres. Although the landfill received primarily trash and
garbage, any wastes generated at the facility during this time may have been disposed of at
the landfill. When it was closed in 1975, the area was covered with an unknown thickness of
clay. The area currently is vegetated with grass and bushes. No gas or leachate collection
systems have been installed. Wastes disposed of in the landfill include sludge from the
industrial waste treatment plant, paint cans, residual paint, pesticide containers, and residual
pesticides, solvents, asbestos, demolition debris, batteries from airplane and motor vehicles,
and other general debris. According to maintenance records, an unknown volume of suifuric
battery acid was discharged into the landfill each year for 17 years.
SourceS: Industrial Waste Treatment Plant Discharge
The Industrial Waste Treatment Plant (IWTP) was constructed in 1968 to treat wastewater
from various base operations. Treated effluent is disposed of into an unlined ditch that carries
the effluent to the South river. Sludge from the treatment plant was spread at the South
Landfill until it closed in 1975. The liquid treated at the IWTP was waste suifuric battery acid;
but, it is unknown whether is became neutralized after treatment. Records are incomplete.
However, from 1968 to 1972, discharge from the plant was approximately 250 gallons per day.
Effluent from the IWTP has been discharged under a state permit since 1972.
MRS CONVERSTION FACTORS:
1 ton = 2000 pounds = 1 cubic yard = 4 drums = 200 gallons
1 gallon = 10 pounds
PAGE 28
Preliminary Assessment Training
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
GROUNDWATER PATHWAY
OBJECTIVE
Using previous background information provided from file searches, reference materials,
maps, and phone conversation record complete the "Groundwater Pathway" portion of the PA
score sheets in the student manual.
METHOD
1. Review the general Groundwater Pathway information summary provided below and
the file information included with this exercise.
2. Using the information provided, complete the "Groundwater Use Description" section
of the PA score sheets on page 4-27 of the student manual.
3. Read the instructions for the "Groundwater Pathway Criteria List" on page 4-28, and
complete the "Suspected Release" and "Primary Targets" evaluations on page 4-29 in
the student manual. Determine whether you hypothesize a suspected release and
identify whether there are any primary targets. Summarize the rationale for these
decisions in the space provided on the bottom of page 4-29 of the student manual.
4, Complete the Table provided for the Secondary Groundwater Population Values. On
page 4-32 of the student manual, use PA Table 2, "Value for Secondary Groundwater
Target Populations" to determine population values for secondary targets, if applicable.
Remember to evaluate the "Nearest Well" category.
5. Complete Section 7 of the Groundwater Pathway on page D-5 in Appendix D of the
PA Guidance manual.
6. Calculate and record the Groundwater Pathway score on page 4-31 of the student
manual.
Groundwater Pathway:
• There is only one aquifer of concern beneath this site which consists of alluvial material.
• The site is not located in an area of karst terrain.
• The depth to the water table ranges from 140 to 160 feet.
• Groundwater from several wells on and around Smith Air force Base supply base and
vicinity residents with potable water. None of these wells are blended.
* A municipal water system exists in Happy Valley; therefore, no other private wells exist
within 4 miles of the base.
• Three municipal wells supply potable water for the 40,000 people of the town of Mt. Airy,
but these wells are located outside of the 4-mile target distance limit (TDL) for the site.
• There is no wellhead protection area (WHPA) located within 4 miles of the site.
* The population served by groundwater is provided below and in the included table.
Preliminary Assessment Training
PAGE 29
-------
APPENDIX C
The population for the site is divided as follows:
• A 147-house development is located north of the base in BLOCK A.
* A 98-house development is located northeast of the base in BLOCK B.
• A 133-house development is located north of the base in BLOCK C. A school with a
total of 450 students and staff and a daycare center with a total of 220 student and staff
are also located in BLOCK C.
* A 102-house development is located south of the base in BLOCK D.
• A housing development is located north of the base that is occupied by 250 people in
BLOCK E.
* A 202-house development is located west of the base in BLOCK F.
Civilian and military personnel living in BLOCK G and working at the base
include:
-115 workers in the main office complex
- 42 workers at the maintenance hanger
- 23 workers at the maintenance garage
- 3 workers at the IWTP
According to the 1990 U.S. Census, the county-wide average population is 3.2 persons per
household.
SECONDARY GROUND WATER TARGET POPULATION BY RESIDENTIAL BLOCKS*
0 - 1/4 mile
1/4 - 1/2 mile
1/2 - 1 mile
1-2 miles
2-3 miles
3-4 miles
A
-
-
-
-
163
307
B
-
-
-
-
-
314
C
-
-
-
192
904
-
D
-
-
-
256
70
-
F
-
-
-
250
598
48
TOTAL
0
0
0
*For purposes of this exercise, Groundwater Populations of secondary targets have been
already determined as measured from the pesticide mixing area (Source 2), since this source
would allow the highest number of targets when compared to all of the other sources in the
Groundwater Pathway. Keep in mind that all sources should be evaluated along with the
targets they may impact within their target distance limits. As per the HRS Guidance Manual,
Section 7.5, page 172, this method".. .is most effective for sites with a large number of
sources and for sites with large populations using weils within the TDL. Note, however,
that this method may underestimate target scores."
Preliminary Assessment Training
-------
APPENDIX C
Resources:
An alfalfa field that covers approximately 150 acres is located at the northwest corner of the
base. This field is irrigated by groundwater from a well located at the northeast comer of the
field.
Hydrogeologic Setting:
Happy Valley is an alluvial valley, approximately 5 miles wide and 30 miles long. The valley is
encircled by moderately steep mountain ranges of Miocene age. The valley is filled with more
than 500 feet of alluvium eroded from the surrounding mountains. The alluvium is a poorly
sorted mixture of weathered rock, gravel, sand, silt and clay. The grain size decreases with
distance from the mountains. A thick layer of lake sediments of silt and clay occurs at the
northeast end of the valley, referred to as the Lower Basin, where drainage from the East
River collects before exiting the valley and heading west toward the Pacific Ocean. This layer
is approximately 25-30 feet thick and is continuous at a depth of 75 feet throughout the valley.
Groundwater Resources:
Groundwater is the only source of drinking-water for all residents of Happy Valley. It occurs
principally in a single aquifer located in the thick, gravelly sands and silts of the valley floor.
The groundwater flow gradient generally follows the land surface contours, flowing downslope
to the river, with a down-river component to flow direction. The depth to water in the aquifer
typically ranges from 140 to 160 feet.
Preliminary Assessment Training
-------
APPENDIX
CASiE STUDY: SMITH AIR FORCE BASE
SURFACE WATER PATHWAY
OBJECTIVE
Using previous background information provided from file searches and maps, complete the
"Surface Water Pathway" portion of the PA score sheets in the student manual.
METHOD
1. Review the general Surface Water Pathway information summary provided below and
the map included with this exercise.
2. Read the instructions for the "Surface Water Pathway Criteria List," and complete the
"Suspected Release" and "Primary Targets" evaluations found on page 5-18 of the
student manual. Determine whether you hypothesize a suspected release, and identify
whether there are any primary targets. Summarize the rationale for these decisions in
the space provided at the bottom of the sheet.
3. Using the existing site information and the score sheet instructions, complete all
portions of the "Surface Water Pathway" score sheet found on pages 5-20 to 5-28 of
the student manual. Use PA Table 3, 'Values for Secondary Surface Water Target
Populations" and PA Table 4, "Surface Water Type/Flow Characteristics with Dilution
Weights for Secondary Surface Water Sensitive Environments," on page 5-21 of the
student manual to determine population values for secondary targets, if applicable.
Remember to evaluate the "nearest Intake" factor.
4. Complete Section 8 of the Surface Water Pathway on pages D-5 and D-6 in Appendix
D of the PA Guidance manual.
6. Calculate and record the Surface Water Pathway score on page 5-28 of the PA
Guidance manual.
Surface Water Pathway:
* There are no surface water intakes located on either the East or South Rivers within 15
miles downstream of the site.
• The intermittent stream empties into a wetland before entering the South River.
• The 100-year flood plain extends up to, but does not include the main runway at Smith
AFB.
• Flow rates are variable for both the East and South Rivers.
• The mean annual discharge for the East River is 385 cfs.
- The mean annual discharge for the South River at its confluence with the East River is
48.1 cfs.
• The South and East Rivers are not used for swimming in the vicinity of the base, since
they are too shallow.
• The East River and South Rivers are both known spawning area.
Preliminary
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
SOIL EXPOSURE PATHWAY
OBJECTIVE
Using previous background information provided from file searches and the site map, complete
the "Soil Exposure Pathway" portion of the PA score sheets in the student manual.
METHOD
1. Review the general Soil Exposure Pathway information summary provided below,
existing source information and the map included with this exercise.
2. Read the instructions for the "Soil Exposure Pathway Criteria List," and complete the
"Resident Population" evaluations found on page 6-15 of the student manual.
Determine whether you can identify a resident population. Summarize the rationale for
these decisions in the space provided at the bottom of the sheet.
3. Using the existing site information and the score sheet instructions, complete all
portions of the "Soil Exposure Pathway" score sheet found on page 6-17 of
the student manual. Use PA Table 7, "Soil Exposure Pathway Terrestrial Sensitive
Environment Values" to determine values for terrestrial sensitive environments, if
applicable. Remember to evaluate the "resident individual" factor.
4. Complete Section 9 of the Soil Exposure Pathway on page D-6 in Appendix D of the
PA Guidance manual.
6. Calculate and record the Soil Exposure Pathway score on page 6-17 of the student
manual.
Soii Exposure Pathway:
* No schools or daycare centers or residences are located within 200 feet of any source.
* The base is still active today.
• The cover on the landfill is intact but there is a report of a leachate outbreak in the
vicinity of the wetland.
* Stained soil occurs between the intermittent stream and the pesticide mixing shed.
• The fire-fighting training area was subjected to a "qualifying removal action" last year.
Prior to being listed for 18 months on the Federal Facility Hazardous Waste Compliance
Docket, the top 6 feet of soil within the pit and the surrounding area was excavated and
disposed of at a RCRA permitted disposal facility in Utah. Clean soil was backfilled and
seeded with grass. CLP-type analytical data verifying the cleanup are on file at the
base.
• The total population within 1 mile of sources 1, 2 and 4 is 1,318.
• The 34-acre wetland is a State Designated Natural Area.
Preliminary Assessment Training
-------
APPENDIX C
CASE STUDY: SMITH AIR FORCE BASE
AIR PATHWAY
OBJECTIVE
Using previous background information from Tile searches, GEMS data and the site map,
complete the "Air Pathway" portion of the PA score sheets in the student manual.
METHOD
1. Review the existing site information, population data base information and
the map included with this exercise.
2. Read the instructions for the "Air Pathway Criteria List" and complete the "Suspected
Release" evaluations found on pages 7-14 of the student manual. Determine whether
you can hypothesize a suspected release. Summarize the rationale for these decisions
in the space provided.
3. Using the existing site information and the score sheet instructions, complete all
portions of the "Air Pathway" score sheet found on pages 7-16 of the student manual.
Use PA Table 8, "Values for Secondary Air Target Population;" PA Table 9, "Air
Pathway Values for Wetland Area" and PA Table 10, "Distance Weights and
Calculations for Air Pathway Secondary Sensitive Environments" to evaluate sensitive
environments and secondary targets. Remember to evaluate the nearest individual
factor.
4. Complete Section 10 of the Air Pathway on page D-6 of Appendix D in the PA
Guidance manual.
5. Calculate and record the Air Pathway score on page 7-16 of the student manual.
Air Pathway:
Population values for Smith AF6 based upon GEMS data and site information.*
0-1/4 mile
23
1/4 -1/2 mile
0
1/2-1 mile
250
1 - 2 miles
1214
2-3 miles
1429
3 - 4 miles
549
*For purposes of this exercise, the GEMS Data was determined from Source 2, since this
allows for the highest number of targets.
PAGE 34
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OMB Approval Number: 2050-0095
Approved for Use Through: 1/92
4>ERA Potential Hazardous
Waste Site
Preliminary Assessment
1. General Site Information
Ntme: Street Addrew
Chy: State:
Ta*inHtf T~^tmn1fr Approximate A
* *
2. Owner/Operator Information
Owner: Operator
Street Address: Street Add.
City: Cigr:
Stale: ZsjCodK Telephone: State ]
Type of Ownennip: How bub*.
D Private D Coonty DC
D Federal Agency D Municipal D fc
Name D Not Specified D S"
O Stale D Other Q X
Dbdiaa
3. Site Evaluator Information
Name of Evttalor AgCBcy/Orgioizitioc:
Street Addreu:
Name of EPA or Stale Agency Contact
City:
4. S/te Disposition (for EPA use only)
Emergency Resftonte/Renoval CERCUS Reeonmeiidatiott: •
Aueameot Receaaneodatraa: ~ Higher Priority SI
D Yea ~ Lower Priority SI
D No Z NFRAP 1
Date: ~ RCRA
~ Other
Date:
Identification
State: CERCLIS Number.
rnrm
JL V/A. M\H CERCLJS JDiBCOvwy Pttc*
Zip Code: County: Co. Code: Cong.
Disc
na of Site: Status of Site:
D Active D Not Specified
Acres Ofasctrve O NA (OW plume, etc.)
Square Ft
rets:
Zip Code: Teiephone:
By Identified:
jtitcn Compbiat O Federal Pimiaui
\ Petition D heidental
ate/Local Program Q Not Specified
OU/CERCLA Notification D OOwr
Date Prepared:
City: | State:
Street Address:
Stale: Telephone:
Signature:
Manw (typed):
Petition:
-------
Potential Hazardous Waste Site
Preliminary Assessment Fonn - Page 2 of 4
CERCUS Number
5. General Site Characteristics
Predominant Land U«cj Within 1 Mite of Site {check all that apply):
O Industrial D Agriculture D DOI
O Commercial O Mining O Other Federal Facility
O Residential Q DOD
D Forest/Field* Q DOE O Other
Site Sating:
D Urban
CSuburban
C Rural
Yean of Operation:
Beginning Year_
B0e«gYear _
D Unknown
Type of Site Operation* (check all that apply):
O Manufacturing (a
check
O Umber and Wood Products
O Inorganic Cbnmicih
O Plastic and/or Rubber Products
O PamU, Varaiabea
a Industrial Orgaaie Cbaoicali
O Agricukura] CVm'rah
(e.g., pesticides, fertilizers)
G Miscellaneous Chemical Products
(e.g., adbejtvei, explosive*, ink)
O Primary Meuli
O Metal Coating. Plaling. Engraving
D Metal Forging, Stamping
G Fabricated Structural Metal Products
D Electro** Equipment
O Other Manufacturing
Mining
Q Metals
DCojJ
OoaaadOai
Q Non-odalBe Maenla
O Retail
D Recycling
O Junk/Salvage Yard
O Municipal Landfill
O Other Landfill
D DOD
a DOB
DD01
D Other Federal FmoSief
a RCRA
O Treatment, Storage, or Dupoaal
O Large Quantity Generator
O StnaU Quantity Generator
G SaMtfeD
DMunicipal
Dlndujtrial
O •Convejte'
O "Protective Filer-
D-Moo-or Laic Fikr-
D Not Specified
Q Other
Wane Generated:
O Oniile
O OiTiKe
O Omile and OfTahe
Wane OeponbcB Auttorized By:
D Pre*eot Owner
O Former Owner
O Fmeat A Former Owner
0 Unautborbed
O Unknown
Waste Accearibk to the Public:
O Ye.
DNo
Distance to Nearc* Dwelling,
School, or Workplace:
Feet
6. Waste Characteristics Information
Source Wane Quantity:
(include utthj)
Source Type:
(check all that apply)
D Landfill
Q Surface Im ia •mill
ODrunw
O Tank! and Noo-Drum Conuinen
O Chemical W«te Pfle
D Scrap Metal or luak Pile
D Tailing! Pile
O Train Pile (open dump)
O Land Treatment
D ConlaouDated Ground Water Hume
(unidentified Nurce)
O Cooaminated Surface Water/Sediment
(unidentified wurce)
D Contanunated Soil
D Other
O No Sourcei
C " Coaatiuent, W =» Waatatrcja. V * Volume, A » Area
Tier'
General Typet of Wa«e (check aB that apply)
D Metals
D Organic!
D borganks
D Solvent!
D Painti/PigiDeoU
O Pejticide^Herbicide*
DAcioVBaM*
DOtlyWaiae
Q Muaicipal Waits
G Mining Waste
Q Laboratory/Hospital Waite D Expletives
Q Radioactive Watte O Other
D Conttroctioa/DemoliiiOB
Wane
Physical Stale of Waate a* Deposited (cheek an bat
O Solid O Sludge Q Powder
a Liquid d Gat
-------
Potential Hazardous Waste Site
Preliminary Assessment Form - Page 3 of 4
CERCUS Number
7. Ground Water Pathway
b Ground Water Uaed for Drinki*
Water Wrthm 4 Milea:
DYea
O No
Type of Drinkinf Water Well*
Within 4 Milea (check tU Hut
a Municipal
O Private
DNeac
Depth to ShaDoweal Aquifer
Feet
Kant Terrain/Aquifer PrtamE
O Yea
DNo
b There a Suapected Rekaae to Ground
Water
D Yea
O No
Have Primary Target Drinking Water
Welb Been Identified:
O Yea
DNo
If Yea, Enter Primary Tar(et Popubtjoo:
Ptooplc
Area.
Q Underlie* She
D >0-4Milea
O None WkhiD 4 MOea
Lin SeeoDdaiy Tarjet Population Served by Ground Water
Whhdnwa Prow
0-11 Mite
>«- ViMife
>Mt-lMUe
>l-ZMika
>2-3MD«
>3-4NQei
TottlWMiin4Mfle»
S. Surface Water Pathway
Type of Surface Water Drama* Site and 15 kffika Oownatream (check alt
diatappr/):
D Stream D River G Food D Lake
DBay D Ocean a Other
Shortest Overland DtMaace From Any Source to Smftcc Water
Feet
MBca
b Therea Suapected Releaae to Surface Water
O Yea
DNo
D AanMl-lOyrFloodplaa
O >IOyr- lOOjTFtoodphni
D >iOOyr.SOOyrHoadpl*Bl
O >*»vrFkwJpbun
Drinkiat Water latakea Located Atone *e Surface Water M«nuxa Padt:
O Yea
DNo
Have Primary Tarfet Dnokiat Water Intakea Been Identified;
O Yea
DNo
If Yet, Eater PopuUtkiB Served by Primary Target latakea:
People
Li* AH Secondary Tufet Drinkk« Water bttkea:
Name Water Body Flow (eft) Pooulatioa Served
Total w»Ui 13 Mika
Fuherie* Located Alooj the Surface Water Mention Path,
O Yea
O No
Have Primary Target Fiaheriea Been IdentiTied;
a Yea
DNo
Plow tefal
-------
P«»*«t»al Hazardous Waste Site
Prtfiminary Asscssnent Fonn - Page 4 of 4
CERCUS Number
Surface Water Pathway (continued)
Weitapdt Loctted Ate* fte 3wfcee W«er Mfcntioa Pitt:
Q Yet
DNo
Mm Primary Tu|«c Wetbadi Been Identified:
QYci
CNo
Lift Seccoduy T«|«t Weted*:
Water Body F»q» 1.000
« WiAn 200 Feet of Ann of Kaam or Setpeeted
DNo
Pathway
to Air
DYe.
DNo
EoterTaUlPopatMicoaaarWidw
0- * Mfle
>2-3Uaet
>}-4M3et
Tcul WMik 4 Mfc*
Lowed Widm 4 MQet of (he Site
DYet
ONo
(Witta 4 Mikt of flw Ste
OY«
a NO
Wife* M MO* of fee SIM:
0-UMBt
------- |