PRC Engineering
                                       Planning Research Corporation
                              DRAFT PROTOCOL

                        FOR GROUNDWATER INSPECTIONS

                      AT  HAZARDOUS WASTE TREATMENT,


                                Prepared for
                    Office of Waste Programs  Enforcement
                          Washington,  D.C.  20460
                                  Work Assignment  No.
                                  EPA Region
                                  Site No.
                                  Date Prepared
                                  Contract  No.
                                  PRC No.

                                  Prepared  By

                                  Telephone No.
May 2, 1985
15-1922-36 through
PRC Environmental
Management, Inc.
(312) 938-0300
     Thomas D. Brisbin
   Deputy Program Manager
    Robert (jr. Van Osten  /
  Chief of Administration

                             TABLE OF CONTENTS



     1.1  Statement of Objectives                               1-1

     1.2  Scope of Work                                         1-2

     1.3  Task Force                                            1-3

     1.4  Facility Inspection Protocol                          1-4


     2.1  Training and Prerequisites                            2-1
          2.1.1  NEIC Evidentiary Workshop                      2-1
          2.1.2  Confidential Business Information
                 (CBI) Clearance                                2-2

     2.2  Document Control System                               2-2

     2.3  Identification of Information Sources                 2-4

     2.4  Procurement of Information                            2-6
          2.4.1  Identify Information Needs                     2-6
          2.4.2  Determine Availability of Information          2-6
          2.4.3  Identify Additional Information Sources        2-7
          2.4.4  Request Categorization of Information Prior
                 to Visiting the Information Locations or
                 Transmittal to Contractor                      2-10
          2.4.5  Schedule Visit                                 2-10
          2.4.6  Conduct Visit                                  2-11

     2.5  Inventory of Facility-Specific Information            2-11

     2.6  Determination of Missing Information                  2-14
          2.6.1  List of Information Missing from Initial
                 Data Gathering Efffort                         2-14
          2.6.2  Facility Environmental Coordinator             2-14

     2.7  Development of Document Package                       2-14
          2.7.1  Assign Document Control Number                 2-14
          2.7.2  Document Package Format                        2-15

     2.8  Communication Plan                                    2-15


     3.1  Scope  of Meeting                                      3-1

     3.2  Definition  of Technical Objectives                    3-2
          3.2.1  Areas of Concern For Each Facility             3-2

Table of Concents Continued
          3.2.2  Outline Sampling Objectives                    3.3
     3.3  Preliminary Organization and Coordination             3-4
          3.3.1  Tentative Schedule of Facility Visits          3-4
          3.3.2  Tentative Inspection Team Selection            3-5
          3.3.3  Outline of Field Investigation Plan            3-5

     4.1  Organization and Coordination                         4-1
          4.1.1  Introduction                                   4-1
          4.1.2  EPA Core Team                                  4-1
          4.1.3  Regional EPA Team                              4-1
          4.1.4  State Team                                     4-2
          4.1.5  NEIC Team                              ,        4-2
          4.1.6  Contractor Team                                4-3

     4.2  Development of Facility Inspection Plan               4-3

     4.3  Communications Plan                                   4-5

     4.4  Coordination With CLP Laboratories                    4-5

     4.5  Site Visit Schedule                                   4-6

     4.6  Field Investigation Report Format                     4-6

     4.7  CBI Status                                            4-8
          4.7.1  Introduction                                   4-8
          4.7.2  Handling TSCA CBI                              4-9

     4.8  Problem Resolution                                    4-10

     4.9  Safety                                                4-11

     4.10 Quality Assurance/Quality Control (QA/QC)             4-12


     5.1  Notification Letter                                   5-2

     5.2  Facility Entry                                        5-3

     5.3  Facility Entry Procedures                             5-4

     5.4  Initial Briefing With Owner/Operator
          of the Facility                                       5-9
          5.4.1  Scope of Inspection                            5-9
          5.4.2  Document and Data Requests                     5-10

     5.5  Interviews                                            5-10
          5.5.1  Owner/Operator/Facility Engineers              5-10
          5.5.2  Sampling Personnel                             5-11

Table of Concents Continued

          5.5.3  Laboratory Manager                             5-11
      5.6  Records Review                                        5-11
          5.6.1  Detection Monitoring System                    5-12
          5.6.2  Alternate Ground-water Monitoring System       5-13

      5.7  Visual Inspection                                     5-13
          5.7.1  Geomorphic Features                            5-14
          5.7.2  Surface Water and Seeps                        5-14
          5.7.3  On-Site Wells                                  5-14

      5.8  Sampling  Procedures Evaluation                        5-15

   -$•5.9  Laboratory  Inspection                                 5-16

      5.10 Facility  Owner/Operator Debriefing Meeting            5-16

      5.11 Analysis  of Results                                   5-17

      5.12 Checklists                                            5-18


      6.1  Review Document Package and Field Investigation Plan  6-1
          6.1.1  Monitoring System Evaluation                   6-1
          6.1.2  Analytical Evaluation                          6-5

      6.2  Development of Preliminary Sampling Approach          6-6
          6.2.1  Selection of Sampling Locations                6-6
          6.2.2  Manpower Allocations                           6-7
          6.2.3  Equipment Designation                          6-7
          6.2.4  Safety Considerations                          6-8
          6.2.5  Logistical Considerations                      6-8
          6.2.6  Notification of Sample Management Office
                 and  CLP Laboratory                             6-8

      6.3  Equipment Staging                                     6-9

      6.4  Monitoring  Well Inspection                            6-11
          6.4.1  Perform Safety  Survey                          6-11
          6.4.2  Opening The Well                              6-12
          6.4.3  Measure Physical Parameters of the Well        6-12
          6.4.4  Equipment Options and Preferences              6-13
          6.4.5  Determine Well  Purging Volume                  6-13
:          6.4.6  Determine Liquid Phases  in  the Well            6-15

      6.5  Well Evacuation                                       6-16
          6.5.1  Select Pumping  Equipment                      6-16
          6.5.2  Purging Procedures                             6-18
          6.5.3  Disposal of  Purged Water                      6-20
          6.5.4  Procedures  for  Slow-Recharging Wells          6-20

Table of Concents Continued

     6.6  Parameter-Specific Procedures                         6-20
          6.6.1  Priority Pollutant Sampling Requirements       6-21
          6.6.2  EP Toxicity Sampling Requirements              6-22
          6.6.3  BTU Sample Requirements                        6-22

     6.7  Well Sampling                                         6-23
          6.7.1  Select Sampling Equipment                      6-24
          6.7.2  Sample Collection Procedures                   6-28
          6.7.3  In-Situ Measurements                           6-29

     6.8  Sampling Ground-Water Seeps (Surface Water)           6-30
          6.8.1  Location Selection                             6-30
          6.8.2  Sampling Techniques and Equipment              6-30

     6.9  Soil Sampling                                         6-33
          6.9.1  Location Selection                             6-33
          6.9.2  Sampling Techniques and Equipment              6-33

     6.10 Lagoon Sampling                                       6-35

     7.1  Potential Hazards                                     7-1
          7.1.1  Toxic Substances                               7-1
          7.1.2  Explosive Materials                            7-2
          7.1.3  Corrosive Materials                            7-2
          7.1.4  Flammable Materials                            7-2
          7.1.5  Heat or Cold Stress  '                          7-3
          7.1.6  Oxygen-Deficient Atmosphere                    7-3
          7.1.7  Cancer-Causing Agents                          7-3
          7.1.8  Irritants                                      7-3
          7.1.9  Excessive Noise                                7-4
          7.1.10 Biologically Active Materials                  7-4
          7.1.11 Radioactive Materials                          7-4
          7.1.12 Accidents Resulting  in Physical Harm           7-4

     7.2  Routes of Exposure                                    7-5
          7.2.1  Inhalation                                     7-5
          7.2.2  Dermal Exposure                                7-5
          7.2.3  Dermal Absorption                              7-6
          7.2.4  Ingestion                                      7-6

     7.3  Exposure Prevention Protocol                          7-6
          7.3.1  Medical Surveillance Program                   7-8
          7.3.2  Respiratory Protection Program                 7-9
          7.3.3  Field Safety Practices Enforcement             7-12

     7.4  Determination of Approach Level of Protection         7-15
          7.4.1  Historical Data As An Indicator                7-16
          7.4.2  Pre-Entry Surveillance Criteria                7-16
          7.4.3  Monitoring During Work Performance             7-17

Table of Contents Continued


     7.5  Levels of Safety Protection                           7-17

     7.6  Emergency Procedures                                  7-18

     7.7  Personnel Decontamination and Equipment Disposal      7-20


     8.1  Preparation For Field Activities                      8-1
          8.1.1  Personnel Training and Qualifications          8-1
          8.1.2  Pre-Inspection Strategy Meeting                8-2
          8.1.3  Staging                                        8-3

     8.2  Field Operations                                      8-4
          8.2.1  Chain of Command                               8-4
          8.2.2  Inspectors Responsibilities                    8-4
          8.2.3  Sampling Personnel Responsibilities            8-4
          8.2.4  Quality Assurance/Quality Control Samples      8-5

     8.3  Equipment                                             8-6
          8.3.1  Routine Maintenance/Calibration                8-6
          8.3.2  Decontamination                                8-7

     8.4  Documentation                                         8-8
          8.4.1  Field Forms and Personal Logs                  8-8
          8.4.2  Photographs                                    8-9

     8.5  Sampling Handling                                     8-10
          8.5.1  Containers                                     8-10
          8.5.2  Chain-of-Custody                               8-13
          8.5.3  Labeling and Packaging                         8-14
          8.5.4  Transportation                                 8-16


     9.1  Introduction                                          9-1

     9.2  Scope of Meeting                                      9-1

     9.3  Technical Objectives                                  9-2
          9.3.1  Status of Facility RCRA Compliance             9-2
          9.3.2  Identification of Appropriate Actipn           9-2
          9.3.3  Schedule For Action                            9-3

     9.4  Recommendations                                       9-3

     9.5  Technical Report                                      9-3

Table of Contents Continued



      10.1  Development of a Facility Management Plan           10-1

      10.2  Implementation of Facility Management Plans         10-2

      10.3  Monitoring the Progress of Initiated Actions        10-3

      10-4  Identification of Implementation Problems           10-3

      10-5  Final Report                                        10-4

                             LIST OF APPENDICES
Appendix A     Field Investigation Report Format

Appendix B     NEIC Procedures For Conducting An
               Inspection Under A Warrant

Appendix C     Facility Inspection Checklist

Appendix D     Health & Safety Plan For Site Visits

Appendix E     Administrative Enforcement Orders



Figure 2-1     Document Identification Number System            2-3

Figure 2-2     Document/Subject Cross-Reference Chart           2-7

Figure 2-3     Document Organization Categories                 2-13

Figure 4-1     Overview of Sampling                             4-17

Figure 6-1     Determination of Volume of Standing
               Water In Well                                    6-14

Figure 7-1     User Training, Medical Clearance                 7-10

Figure 7-2     Unit Issue Maintenance Log                       7-13

Figure 7-3     Exposure Report Form                             7-19



Table 6-1      Purging Equipment Selection                      6-17

Table 6-2      General Types of Monitoring Well Sampling
               Equipment With Discussion of Advantages
               and Disadvantages                                6-25

Table 8-1      Containers Available From The Sample
               Bottle Repository Program                        8-12


1.1       Statement of Objectives

This document presents a protocol for the activities of the Hazardous Waste
Ground Water Task Force.  The Task Force will assess 58 commercial  sites  for
compliance with RCRA ground-water monitoring regulations.

The Task Force is made up of a U.S.  EPA Headquarters Core  Team,  U.S. EPA
Regional Office Task Force Coordinators,  personnel  from the State
environmental agencies in whose states the sites are located,  and personnel
from the U.S. EPA National Enforcement Investigations  Center (NEIC).

The sites were selected primarily because they have land-based RCRA
treatment,  storage, or disposal (TSD) facilities and are  now receiving or
are expected to receive large  quantities  of hazardous  waste from Superfund
(CERCLA) sites clean-up activities.   These sites are located in U.S.  EPA
Regions II through X, with no sites in Region I.  The evaluation of sites is
expected to continue through 1987.

The basic ground-water monitoring requirements  for RCRA land-based TSD
facilities set forth in 40 CFR,  Parts 264 and 265,  Subpart F,  were origi-
nally promulgated  in 1980.  EPA has recognized the need to verify and assure
compliance with these rules by the  regulated community. Compliance through
adequate self monitoring,  is necessary to determine whether or not these
facilities are posing an immediate threat to human health  and the environ-
ment.  Wastes  from CERCLA  clean-up  activities are being disposed of at some
of these facilities.  Ground-water monitoring will assist U.S.  EPA in deter-
mining  whether these  facilities are  adequately protected  to prevent ground-
water contamination which may necessitate later removal of wastes at a
significant  added  cost.

The objectives of  the Task Force are:

     o    To evaluate commercial land disposal  facilities  for:

               Compliance with the regulations in 40 CFR,  Part 265,
               Subpart F,  "Interim  Status Standards for Owners...,"
               and potential compliance with the rules set forth in
               Part 264,  "Standards for Owners  and Operators  of
               Hazardous Waste Treatment, Storage, and Disposal Facilities"

               Levels of contamination in the ground-water

               Compliance with ground-water aspects of the Superfund
               off-site policy.  (The final draft of this policy  is
               presently being completed by EPA and will be incorporated
               into this protocol).

     o    To establish a rigorous  nationally consistent method of ground-
          water evaluation.

     o    To implement a nationally consistent program of action in the form
          of permit conditions, orders, and penalties related to
          compliance with the RCRA ground-water monitoring regulations.

The effort will include review of existing documents, field inspections and
sampling.  Decisions will be reached by consensus  between  teams of experts
from  the EPA Headquarters,  EPA Regions, and  State  agencies.

1.2       Scope of Work

Initially,  the Task  Force  will evaluate one  facility in each  of  U.S.  EPA
Regions  II  through X.  (There are no commercial land disposal facilities in
Region I).   The 58 sites  commercially handle hazardous wastes or their
residues in land-based facilities subject to RCRA Regulations, 40 CFR Parts
264 and  265, Subpart F.  The initial evaluations will be performed at sites
chosen by balancing a number of considerations:

     o    Ongoing or near-term planned  State,  Regional, or NEIC  evaluations.

     o    Volume  and variety of waste.

     o    Receipt of large quantities of wastes from Superfund
          sites clean-up.

     o    Location and number of sites among the nine Regions.

     o    Variety of seasonal weather conditions.

The evaluation of the first 28 facilities will be completed during 1985 and
1986.   As of April 1985,  the initial nine sites have been identified with
the balance to be subsequently designated.   The evaluation of all 58 facili-
ties may take several years.

In order to coordinate the activities of the Task Force,  EPA has developed a
phased work plan which will be used to evaluate each site.

          o    Phase I.        Planning and Protocol Development
          o    Phase II.       Data Procurement
          o    Phase III.     Data Analysis
          o    Phase IV.       Site Visit
          o    Phase V.        Technical Report
          o    Phase VI.       Follow Up

1.3       Task Force

The joint Hazardous Waste Ground Water  Task Force  is made up of personnel
from EPA Headquarters, EPA  Regional  offices, state environmental  agencies,
and NEIC.   The Headquarters Core Team will initially be composed  of  three
investigators, each with hydrogeologic background  and  field  experience.
Current assignments are:

          o    Group 1 Regions  II, III, V  - Randy Breeden
          o    Group 2 Regions  IV, VII, IX - Don Shosky
          o    Group 3 Regions  VI, VIII, X - Roy Murphy

After  initial site evaluations  in Region II, IX, and VI,  the team will be

expanded to six hydrogeologists.  The  three additional Core Team  members
will be assigned one each to activities  in Groups 1  to  3.

The technical coordinator for the Core Team will also review the findings on
most facilities, providing consistent hydrogeologic review and an indepen-
dent opinion on technical matters.

1.4       Facility Inspection Protocol

This protocol will be used to aid in achieving consistent and thorough
facility evaluations.  The areas covered by this protocol are:

          o    Data Procurement
          o    Facility Inspection Planning
          o    Development of Field Investigation Plan
          o    Facility Inspection
          o    Development of a Sampling Plan
          o    Health and Safety
          o    Field Quality Assurance
          o    Compliance Evaluation
          o    Follow Up Activities  •

The protocol is presented in the following sections, corresponding to the
topics listed above.  Within each section, step-by-step items or procedures
are listed.  Since many of these steps involve choosing between alterna-
tives,  a discussion of the approaches, considerations, or options available
follows the  list of steps.


For each site, available hydrogeologic and operating information will be
reviewed as the first step in performing compliance assessments.   This
process involves identifying all information sources,  other than the site
operator or owner,  obtaining pertinent documentation from those sources, and
determining what information is missing but necessary for performing the
compliance assessment.  Efforts should then be focused on obtaining the
missing information from the site's existing files or through
sampling/inspection activities at the site.

2.1       Training and Prerequisites

Team members must use a prescribed set of procedures for obtaining and
handling site-specific information and documents (I/D).  Such procedures
should aid in providing efficient retrieval of site-specific I/D, and will
providing defensible I/D evidence for potential litigation.

2.1.1     NEIC Evidentiary Workshop

The U.S. EPA's National Enforcement Investigations Center  (NEIC) has estab-
lished a document control system for handling evidence obtained  in  the
course of enforcement/compliance site inspections.  Prior  to initiating any
data procurement activities, the Task Force Core Team members and their
contractors should attend NEIC's evidentiary workshop, or  its equivalent,  co
become familiar with document control procedures.  The workshop  should cover
at least the  following topics:  overview of procedures used by inspectors
when collecting field data and establishing a document file for  a site,  and
document handling procedures for I/D cataloging, storage,  accessibility,
retrieval, routing, and disposal.  The procedures should be modified, as
appropriate,  and be used by. the Task Force Core Team members and their.
contractors in all data procurement efforts.

2.1.2     Confidential Business Information (CBI) Clearance

Certain site-specific documents may be classified as general confidential
business information (CBI) or as CBI specifically related to provisions  in
the Toxic Substances Control Act (TSCA).   CBI and TSCA CBI each require
special clearance and safeguards to preclude their inappropriate release to
the general public.  Accordingly,  prior to reviewing or obtaining CBI,  the
Core Team members and their contractors will obtain clearance through NEIC
to handle CBI and TSCA CBI documents.

2.2       Document Control System

The purpose of a document control system is to provide organization and
accountability for the I/D compiled under this program.  This system will
describe the handling, routing and storage procedures which will be used for
I/D gathered for each targeted site and includes an I/D-unique numbering
system, a document inventory procedure, and a central filing system.

A document control officer (DCO) would control the handling and routing of
I/D, and would insure proper storage in files.  CBI would be maintained in
locked files.

In addition to providing  organization and limited access to the I/D, the
document control system will facilitate I/D retrievability.  This will be
achieved by assigning a unique, 13-digit, document number for each document
obtained under this program.  This document identification number will
reflect the following:  Task Force project identifier, unique commercial
site identification number (assigned by the Task Force), data procurement
contractor, I/D category  and subcategory, and a serial number.  Figure  2-1
provides a graphical description of this numbering assignment scheme.

Example Document Identification Number:


     T - Task Force Project Identifier

     001 - Site Identification Number (1-999)
     P - Data Procurement
         Contractor Identifier
         (P - PRC Engineering)
                                  01 -  Source  Identifier
State EPA
EPA RCRA Program Enforcement
EPA Compliance/Permit
                                       02 - Document Subcategory

                                       00 - No subcategory
                                       01 - Application/revisions
                                       02 - Comments/Review/Request
2 - Document Category        :

1 - Part B Application
2 - Part A Application
3 - Compliance/Enforcement
4 - Hydrogeological Reports
5 - Correspondence
6 - Technical Reports and Plans
7 - Maps, Drawings and Photos
9 - Task Force Reports and Plans

005 - Document Serial Number, 1-999, to make each overall document
      number unique
          Figure 2-1.

     Identification of Information Sources
The data procurement contractor, as instructed by the Core Team member(s),
will initially obtain all available pertinent I/D for each site from sources
other than the site.  The following agencies have been identified as sources
of I/D that are relevant to the objectives of the Task Force,  as discussed
in Section 1.  Listed opposite each source agency are the typical I/D types
likely to be available from that source.
U.S. EPA Headquarters
U.S. EPA Regional RCRA
Permit Personnel
U.S. EPA CERCLA Personnel
State Programs Personnel
RCRA Part A and Part B
Application Revisions
Engineering Reports
Hydrogeologic Reports
Groundwater Monitoring/
Assessment Plan
Site Standard
Operating Procedures
Waste Analysis Plan
Waste Inventory/Manifest/
Closure/Post Closure  Plan
Permits  (air, water,  etc.)
Manifests/Receiving Orders
Inspection Reports
Documented Complaints and
o    U.S. EPA Regional RCRA
     Compliance Personnel
o    Regional Counsel
                                         Inspection Reports
                                         Notices of Deficiencies  (NODs)
                                         Records of Decisions  (RODs)
                                         Litigation Actions
                                         Documented Complaints  and

o    U.S. and State Geological
Geologic and Hydrologic Reports
Water Monitoring Data
Topographic Maps and Aerial
Well Inventory/Water Use
     U.S. Department of Agriculture
Soil Maps
Soil Types, Physical Character-
istics, and Depths
Aerial Photographs
Climatic Data
     U.S. Corps of Engineers (COE)
Floodplain Maps
Aerial Photographs
Land Plats
     U.S. National Enforcement
     Investigation's Center  (NEIC)
Site Financial Assessment
Analytical Data
     Technical Analysis Branch
     (TAB), NEIC
Aerial Photographs
     National Cartographic Information
     Center  (NCIC)
     Environmental Photographic
     Interpretation Center (EPIC)
     Environmental Monitoring Systems
     Laboratory  (EMSL)
 Sophisticated  Imagery Inter-
 pretation and  Special Maps
     U.S. Environmental  Services
     Division  (ESD)
 Analytical  Data

2.4       Procurement of Information

The federal and state agencies previously listed,  as well as others,  will be
visited to obtain available information which is pertinent to the Task
Force's objectives.  In order to insure consistency in the types of I/D
collected for the target sites a checklist of pertinent I/D has been pre-
pared and will be used on all data procurement efforts under this program.
It is projected that the data procurement effort for each site will take
approximately six weeks to accomplish.  The following sections discuss these
data procurement activities in more detail.

2.4.1     Identify Information Needs

The Task Force Core Team members, working with the data procurement contrac-
tor, have developed a comprehensive checklist of I/D necessary for perform-
ing the nationwide assessment of sites.  This checklist was used to develop
the Document/Subject Cross-Reference Chart, shown in Figure 2-2, which will
facilitate indexing and retrieving specific I/D.

A unique 13-digit number will be assigned  for each site-specific I/D
collected.  Each I/D1s number will be recorded on a diagonal  line at  the top
of a column and the subjects in  that  I/D will be checked off  in  the appro-
priate column below.  By reviewing the subject index, one would  be able  to
locate the I/D dealing with a particular subject.  Alternately,  by focusing
on a specific document, one could determine if a particular subject is
discussed therein.

2.4.2     Determine Availability of Information

The data procurement contractor  will  make  preliminary telephone  calls  to the
previously listed agency sources, excepting the federal EPA  (e.g., state
regulatory agencies, USGS, USDA-, USCOE, etc.) to determine what  I/D are
available from non-EPA sources,  their quantities, and,  if reasonable,
whether or not these can be transmitted directly to the contractor.   If  the
non-EPA source contact states that its policies prohibit  transmittal  of

Figure 2-2.  Docunienc/iuojecc

desired I/D or that it is not feasible to do so, the contractor will ask the
contact whether the I/D can be reproduced at the source agency or taken to a
commercial reproduction service.  If neither is possible, the contractor
will either purchase the I/D (e.g., reports, maps, etc.) or record pertinent
information regarding the nature of the I/D and their location.

Prior to initiating data procurement activities at federal and state EPA
offices, the contractor will telephone the EPA Regional Team Leader (RTL)
and request the names and telephone numbers of Regional and State EPA com-
pliance and permit personnel that have files on the target site.  The con-
tractor will then contact these Regional and State personnel, and determine
what I/D on the cross-reference chart (Figure 2-2) are available, in which
files they are located, and their approximate quantities.

2.4.3     Identify Additional Information Sources

During the telephone conversation with each source agency contact, the
contractor will identify on the cross-reference chart the I/D which are
apparently available from that source and will note which I/D are still
missing.  After determining the location and quantity of the available I/D,
the contractor will ask the source contact for other possible sources for
the missing I/D.

This method of tele-networking would be continued until either  all the I/Ds
are located and identified as obtainable or until no further sources are
identified.  In the latter case, if all I/Ds have not yet been  located or
are unavailable, the contractor may decide  to:  contact  the  following public
agencies and private companies  to  obtain the missing I/D; attempt to obtain
the missing I/D through EPA's issuance of a 3007  letter  to the  site  (see
Appendix C); or collect the I/D at the site during the Task  Force's  site

County or Regional Planning

Other County Offices
*    Health Department

*    Planning and Zoning
*    Assessor
*    Clerk

City Offices
*    Chamber of Commerce
*    Engineer

*    Fire Department

*    Law Enforcement

Building Contractors
Soil Exploration and Foundation
Contractors/Water Well Drillers
U.S. Department of Labor,
Occupational Safety and Health
Administration (OSHA)

National Oceanic and Atmospheric
Administration (NOAA)
Plans, concerns, and past
problems at site
Problems, complaints,
analytical data
Land use restrictions
Plat maps,  landowners
Deeds of Transfer,  Liens
Information on local industries
including number of employees,
principal products, and
site addresses
Foundation and inspection reports
Survey benchmark locations
History of fires and/or
explosions at site
Complaints and violations of
local ordinances

Local soils
Shallow water levels

Local soils
Water levels

Industrial processes
Protective equipment needs

Climatic data

2.4.4     Request Categorization of Information Prior to Visiting
          the Information Locations or Transmittal to Contractor

In order to facilitate the procurement of relevant data for a specific site
from the various federal and state EPA sources, the contractor will request
the agency contact to separate the available I/D,  as necessary,  into
unclassified and CBI categories.  Separation of the I/D into these two cate-
gories facilitates its subsequent handling, routing and storage by the

As discussed in Section 2.4.2, all I/D sources also will be requested by the
contractor to identify and/or separate their site I/D into I/D that can be
sent directly to the contractor (e.g., reports, maps, aerial photographs)
and I/D that require on-site procurement, due to their nature and/or quanti-
ties.  Unless purchased by the contractor, all I/D sent by the source will
be reproduced either at the contractor's office or at a commercial site, and
the originals returned usually within one week of their receipt.

For I/D requiring on-site procurement, the contractor will request the
source to further identify and/or separate them into I/D that may be re-
leased into the contractor's custody for duplication and I/D that may not be
released by the source.

By having the I/D categorized into the above-mentioned categories prior  to
the on-site visit, the contractor can schedule and perform data procurement
activities more efficiently.

2.4.5     Schedule Visit

The contractor will schedule  data procurement  activities at U.S.  EPA Re-
gional sources with a Core Team member and RTL so  that the on-site  data
procurement visit coincides with EPA1s site  assessment kick-off meeting.
The scheduled data for this meeting  should correspond  to the Task Force's
Work Schedule Plan for this program.

At  the site assessment kick-off meeting,  attended  by usually one  Core  Team

member, Regional EPA permit and compliance/enforcement personnel and the
contractor, the following subjects will be identified and discussed.  I/D
locations, data gathering logistics, location and handling procedures for
CBI, DCO for TSCA CBI, existence of aerial photo workups,  and the necessity
for issuing a 3007 letter to get I/D from the site owner or operator.

2.4.6     Conduct Visit

After  the site kick-off meeting, Regional EPA personnel (usually the RTL)
will assist the contractor in collecting the desired site I/D by either
accompanying the contractor or making preliminary telephone calls to
facilitate access to appropriate state and federal sources.

The contractor will normally review the following files at state and federal
EPA sources:  Regional Office (RO) permit, enforcement/compliance, and
CERCLA files (if any); Headquarters enforcement/compliance files (as neces-
sary); RO state implementation files; ESD files, and State files.  During
the review of EPA's files, the contractor will tag individual I/D corre-
sponding to the items listed on the cross-reference chart.  Depending on the
nature and quantity of I/D that are tagged by the contractor, as well as the
source agency's internal I/D handling policies, either the contractor or EPA
source personnel will extract the tagged items, have them reproduced/
duplicated, and return them to their original locations in the respective
files.  All CBI and TSCA CBI will be sent directly either to the Task Force
DCO at EPA Headquarters or to the contractor's DCO.

The contractor will normally schedule visits to non-EPA agency sources after
completing data procurement activities at EPA sources, and will utilize
similar procedures for obtaining copies of I/D.

2.5        Inventory of Site-Specific Information                     .

The relevant I/D obtained  for each  site to be evaluated will be  arranged
into  nine  major categories, as  shown in Figure  2-3.

The contractor will complete a  separate cross-reference chart  for  each  major

category co identify the subjects contained in each category's I/D.

Arrangement of the I/D in this manner will not require separation of indivi-
dual documents, and will permit a reviewer to focus on a major area of
interest, a specific subject or an individual I/D.

1.    Part B Application

     1.1  Application/Revisions
     1.2  Comments/Review/Request

2.    Part A Application/Interim Status

     2.1  Application/Revisions
     2.2  Comments/Review/Request

3.    Compliance/Enforcement

     3.1  Inspection Report
     3.2  Requests, Notices, Orders,  Permits from
          Responsible Agency Official to Site
     3.3  Response, Reports, Applications from
          Site to Responsible Agency Official

4.    Hydrogeological Reports

5.    Correspondence

     5.1  Regulatory Agency to Site
     5.2  Site to Regulatory Agency
     5.3  Third Party Regulatory
     5.4  Internal

6.    Technical Reports and Plans

     6.1  Engineering Reports
     6.2  Soil/Water Resource
     6.3  General Technical

7.    Maps,  Drawings and Photos

8.    Confidential Information

     8.1  CBI
     8.2  TSCA CBI

9.    Task Force Reports and Plans

     9.1  Technical Reports
     9.2  Data Analysis Report
     9.3  Site Management Plan

2.6       Determination of Missing Information

2.6.1     List of Information Missing from Initial Data Gathering Effort

After performing the inventory of site-specific I/D, the completed cross-
reference charts will be reviewed to determine which subjects are not
contained in the I/D collected during the initial procurement activities.
The contractor will then summarize these I/D deficiencies,  which must be
subsequently obtained at the site.

2.6.2     Site Environmental Coordinator

After compiling a list of missing I/D, the data procurement contractor will
telephone the EPA RTL to indicate the need for obtaining the missing I/D at
the site and to discuss a tentative schedule for visiting the site.  The
contractor should be certified as having undergone appropriate health and
safety training prior to the site visit.

The RTL will coordinate the site visit with the Core Team members, Regional
Office inspection team members, the sampling and data procurement contrac-
tors,  and the site's environmental coordinator.  The RTL will determine
whether the site has a document copier and,  if so, whether the owner or
operator will permit its use by EPA's contractor.  In addition,the RTL will
attempt to ascertain from the site environmental coordinator the quantity of
I/D to be collected.

2.7       Development of Document Package

After all available site-specific I/D have been gathered, the individual I/D
will be numbered and placed into the previously described categories.
Separate I/D packages will be prepared for CBI and TSCA CBI.

2.7.1     Assign Document Control Number

The data procurement contractor will utilize the numbering system described
in Figure 2-2 for coding the various  types of  site-specific  I/D obtained

under this program.  CBI and TSCA CBI will grouped under Category 8,
Confidential Information.

2.7.2     Document Package Format

In order to provide consistency and facilitate document review/retrieval by
the Task Force members and program participants,  the contractor will
describe the contents of each I/D package in the following manner:

     o    Table of Contents,
     o    Document Inventory,
     o    Major Document Categories.

The above three items will be included in each volume of a document package
and will contain, for each I/D, the document number, the volume it is
located in, and (except  for CBI and TSCA CBI) the title or a brief descrip-
tion of the document.  Confidential information will only be described by
its document number and  general category:  CBI or TSCA CBI.  One copy of
each site-specific document package will be forwarded to the following
participants:  State EPA (or its counterpart), NEIC, EPA Regional Office,
and Core Team DCO.  CBI  and TSCA CBI packages will be forwarded only to the
Core Team DCO.

2.8       Communication  Plan

In order to avoid inconsistent and contradictory statements to the general
public or site community, the data procurement contractor should direct all
questions to the appropriate Regional EPA communications staff (press or
community relations) through the RTL.  This staff willestions to the
appropriate Regional EPA communications  staff (press or community relations)
through the RTL.  This staff will coordinate their  activities and responses
with the Task Force Communications Coordinator at EPA Headquarters and  the


3.1       Scope of Meeting

Upon completion of the data procurement task,  a Document Package will be
issued to a combined evaluation team.  The Facility Assessment Program
reaches Phase III on the work plan, Data Analysis.   The combined evaluation
team is composed of representatives from the Core Team, Regional EPA Team,
State Team and NEIC Team.  NEIC will only participate in the evaluation of
the first facility in each of the nine Regions.  After an indepth evaluation
of the document by the team members, a meeting will be held to discuss and
reach consensus on the major findings.  The NEIC or Region is responsible to
schedule the meeting and prepare agenda for the meeting.  The agenda should

     o    Discussions on the findings from each member's evaluation
          of the information provided in the document package.

     o    Resolution of any disagreements on technical findings.

     o    Establish technical objectives for the Field Investigation

     o    Establish specific objectives regarding sampling.

     o    Assemble a list of technical questions needed to be resolved.

     o    Outline the Field Investigation Plan.

     o    Identify members of the  combined Field Investigation Team
          and team leader.

     o    Establish preliminary  site  visit schedule.

3.2       Definition of Technical Ob1actives

The purpose of Che meeting is to discuss and evaluate the findings from the
review of each Document Package with emphasis on the following areas:

     o    Compliance with 40 CFR 264, "Standards for Owners and Operators
          of Hazardous Waste Treatment,  Storage, and Disposal Facilities",
          and 40 CFR 265, Subpart F, "Interim Status Standards",

     o    The nature of any contaminants in the ground-water,

     o    Inadequate ground-water monitoring system design and/or

     o    Validity and completeness of the existing data, and

     o    Characterization of existing or potential geological problems
          in proximity to the site which could contribute to the endan-
          germent of the ground-water.

The evaluations will be used to develop the field data requirements to be
addressed by the Facility Inspection Plan.

3.2.1     Areas of Concern For Each Facility

After considering the areas mentioned in the previous section on a facility
specific basis, each site will be characterized and the technical
objectives for field investigation outlined.

Due to the extensive experience of NEIC in site investigations, they will
prepare a facility  inspection plan for  the first facility, in each Region.
The Region will then prepare a subsequent plan.  This approach will provide
a method of standardizing all facility  inspection plans and promoting  a
nationally consistent investigation.

A facility specific inspection plan will focus on (but not be limited to)
the following major areas:

     o    Organization and coordination of the combined field
          inspection team.

     o    Procedures for evaluation of owner/operator sampling techniques.

     o    Development of sampling plan.

     o    Evaluation of self-monitoring data.

     o    Examination of on-site records.

     o    Review and evaluation of the ground-water monitoring system.

     o    Schedule and logistics.

3.2.2     Outline Sampling Objectives

Based upon the findings from the review of the documents, the degree of
compliance with the previously established technical objectives can be
established and the sampling objectives for each facility can be outlined.
A detailed discussion of the sampling plan is provided in Section 5.0.  To
ensure that the sampling activity yields complete and admissible results,
contractors assigned responsibility for the sampling will receive direct
supervision by EPA.

Sampling activity should focus on  :

     o    Completing any areas with missing or incomplete data.

     o    Confirming or eliminating any possibility of ground-water

     o    Discovering the reliability of the facility self-monitoring

Samples collected during the field activities will be split with the
regional ESD laboratory (when involved) and the CLP laboratory for analyses.
An offer will also be made to split samples with the owner or operator's
laboratory and the State laboratory.  Point of evaluation samples will be
prepared by U.S. EPA, ORD, Cincinatti.  The contractor will manage the
sample packaging and distribution.  VIAR has been contracted to coordinate
the sampling activities with the sample bottle depository (IChem), sampling
contractor and CLP laboratory.  VIAR will also arrange with ORD and NEIC for
laboratory audits where analysis of quality control samples do not provide
acceptable results..  The coordination of analytical services is discussed in
further detail in Section 4.0.

3.3       Preliminary Organization and Coordination

After a consensus is reached on the sampling objectives, a preliminary
schedule of activities will be developed at the conclusion of the meeting.

3.3.1     Tentative Schedule of Facility Visits

The schedule of visits will be established initially by coordinating the
workloads of the Core Team, the Region, NEIC, the State, the sampling con-
tractor, and the laboratories.  Of prime importance to scheduling is the
level of responsibility of each group for the planning and execution of each
inspection.  The Core Team and the Regional Team will expend significantly
more time than will other participants and, therefore, may need to have
greater input to the scheduling process.

3.3.2     Tentative Inspection Team Selection

Based upon the objectives outlined for each facility, and the tentative
schedule of site visits, an inspection team should be selected to include
individuals whose areas of expertise correspond to the sampling needs,
thereby providing a high level of accuracy and reliability in the results.

3.3.3     Outline of Field Investigation Plan

Prior to the conclusion of the initial consensus meeting, an outline of the
Field Investigation Plan will be developed to identify specific items to be
included in the plan.  This will provide guidance in preparing the Facility
Management Plan and will insure that all the findings and objectives are
addressed in the plan.  The outline will also include the following informa-

     o    Tentative combined field investigation team

     o    Tentative field investigation schedule


4.1       Organization and Coordination

4.1.1     Introduction

To ensure that the field investigation is both comprehensive and efficient,
each of the teams involved will have clearly defined roles.   The coordina-
tion of team functions must be planned carefully in order to provide an
optimum degree of overlapping effort and to avoid redundancy.

4.1.2     EPA Core Team

The Core Team functions to:

     1)   Ensure consistency and uniformity during the facility
     2)   Identify and evaluate problems encountered in the field
          and provide guidance,
     3)   Assist in the development of the project, and
     4)   Provide assistance in coordinating the various teams to assure
          smooth functioning of the effort.

4.1.3     Regional EPA Team

The Regional EPA Team will organize individual facility assessments in
accordance with the standard operating procedures  included  in this protocol.
Makeup of the Regional team is at the discretion of the team leader and
Regional management but should include in most cases, field  inspectors,
permit writers, enforcement staff, Regional counsel, sampling and analytical
personnel (usually ESD), and a communication expert.  Designated Team Lea-
ders for the nine regions  are:

          Region II    - Rich Ualka
          Region III   - Bruce  Smith
          Region IV    - George Harlow

          Region V    - Joe Boyle
          Region VI   - William Rhea
          Region VII  - Mike Sanderson
          Region VIII - Mike Gansecki
          Region IX   - Phil Bobel
          Region X    - Ken Feigner

The Regional Team will establish contacts with the states.   Facility inves-
tigations will be scheduled by the Regional Team Leader.   Due to their
extensive experience, the first on-site coordinator in the Region will be
provided by NEIC; however, for all subsequent inspections,  the Region will
provide the on-site coordinator.  Similarly, NEIC will draft the first
facility evaluation in each Region and the Region will draft all subsequent
evaluations.  The Regional team will be responsible for overseeing the State
implementation of most of the decisions reached.

4.1.4     State Team

The Region will discuss with the State Team their level of involvement in
the inspection process.  Generally, it is anticipated that the State Team
will participate as an equal partner in the Task Force.

4.1.5     NEIC Team

The NEIC's role is to:

     1)   Establish  the procedures which will be followed during subsequent
          site investigations and evaluations by providing a single team
          for the first evaluation in each Region,

     2)   Assist the Core Team  in developing  the inspection protocol  and
          standard operating procedures,

     3)   Provide a  structure for the program based upon their  extensive
          investigative experience, and

     4)   Provide an independent source of expertise to the program.

4.1.6     Contractor Team

The role of the  Contractor Team is discussed in Section 2.0.

4.2       Development of Facility Inspection Plan

The facility inspection has two primary objectives; 1) to expand and/or
verify background information,  and 2) to assess the potential for ground-
water contamination, through visual  inspection, and where necessary,  sam-
pling and analysis.

A facility-specific inspection plan should be developed to address the
scope,  schedule,  and level of effort involved in conducting an inspection to
achieve the aforementioned objectives.   The elements that should be included
in the facility  inspection are  listed below.

     1)   Prepare .Facility Inspection Plan - The Core Team should deter-
          mine inspection and sampling objectives upon completing the
          evaluation of the Document Package, and develop a detailed inspec-
          tion plan (the elements of such a plan are discussed in Sections
          5,  6,  7, and  8 of this protocol).  The Core Team should also
          assign various team members to be responsible for certain aspects
          of the onsite interview and activities, and should identify and
          assemble all  required documentation for  the  facility  inspection.
          The plan should also  identify the responsible personnel at the
          facility who will be  interviewed.  A draft inspection plan should
          be transmitted to members of the inspection  team  for review and
          comments.  The Core Team  is responsible for  incorporating approp-
          riate  changes into  the  final inspection  plan.

     2)   Notification  Letter  - The  Core Team should issue  an official
          "Notice of Inspection" letter to responsible  personnel at
          the  facility.  If a scheduling conflict arises, the facility

     should be requested to adjust their sampling schedule,  if
     possible, to accommodate the inspection.
3)   Distribute Inspection Plan - The final inspection plan should
     be distributed to all team members (including communications
     specialist), the sampling contractor,  and an appropriate contact
     at VIAR or the CLP lab.   This should be done at least three
     weeks in advance of the anticipated sampling date.

4)   Verify Contractor Readiness - The sampling contractor
     and the CLP laboratory (through VIAR)  should notify the Core
     Team as soon as they are ready to begin field activities.
     If logistical or other problems arise within the three-
     week lead period, the sampling contractor should notify the
     Core Team as soon as practicable to resolve such problems.

5)   Conduct -the Inspection - The onsite inspection should be
     conducted by beginning with an initial briefing (see Section
     5.0), followed by the designated inspection/sampling activi-
     ties, and concluding with an exit briefing.  A daily meeting
     should be held for the entire inspection team at the close of
     each day's activities to review progress and resolve any field
     problems.  The inspection/sampling activities may include
     interviews with facility environmental, sampling, or process
     personnel, observation of facility operations and sampling
     techniques, review and copying of facility documents, and
     sampling at onsite monitoring wells or other appropriate
     locations  (see Sections 5.8).  All documents (e.g. field
     logbooks) generated during  this inspection should be entered
     into the Task Force document control system.

6)   Data Review - Site inspection and analytical data should be
     reviewed by all  team members for validity, quality,  and  relevance
     to the regulatory requirements  for ground-water monitoring.

     7)   Compliance Evaluation -  Team members should meet Co complete
          the data review and determine the facility's compliance  status
          with the appropriate regulations.  If needed,  appropriate
          action(s) should be identified;  these,  together with recommen-
          dations for their implementation, should be summarized in  a
          technical Field Investigation Report.   This effort should
          conclude with the development of a Facility Management Plan to
          ensure that recommended actions  are implemented effectively.
4.3       Communications Plan

The Task Force Communications Coordinator will meet with the Regional Team
Leader and with the community relations staff to develop a facility specific
communications  plan.  Although it is the policy of EPA to make information
about EPA and its work freely available,  this policy does not extend to
confidential information and evidence relating to the possible violation of
Federal environmental laws.   Since much of the information obtained during
the site investigations will be "sensitive",  the  team  members should refer
all inquiries to the designated Communications Coordinator.

4.4       Coordination With CLP Laboratories

VIAR has been selected to coordinate the activities related to sampling and
analysis including hardware selection,  sample distribution, QA/QC and
laboratory selection (from the Contract Laboratory Program).   VIAR will
coordinate the  efforts of these groups:

     o    Versar - Provide sampling equipment and sampling
     o    IChem - Provide sample bottles.
     o    Life  Systems - Provide laboratory  quality assurance
     o    EPA ORD, Cincinnati, Ohio - Provide point of evaluation
          samples  (blanks and spikes)  to monitor performance of analytical
          laboratories samples.

     o    EPA EMSL/LV (Environmental Monitoring Systems Laboratory/
          Las Vegas) - QA/QC,  protocol evaluation,  and standards
     o    Contract Laboratories (from CLP) -  Laboratory to perform
          sample analysis.

Figure 4-1, depicts the information flow among the  participating groups;

     1)   IChem will supply the sample containers to Versar.

     2)   At the direction of VIAR, Versar will transport the necessary
          equipment and sample containers to the facility.  Versar will ship
          the samples to the CLP laboratory for analysis.

     3)   CLP will analyze the samples and distribute sample results
          to the Core Team, Life Systems, VIAR, and EMSL/LV.

     4)   ORD will supply blanks and control samples.

4.5       Site Visit Schedule

A site visit schedule will be established by considering the work load
distribution of the Task Force members.  Both the preparatory work and the
site visit require a significant time expenditure by the Core Team and by
the Regional Team.  Therefore, to ensure that there is adequate time in
which to do the necessary planning, the number of simultaneous visits within
a Region should be minimized.

4.6       Field Investigation Report Format

The inspectors will use an established Field Investigation Report  format to
promote consistency and accuracy,  during  the site investigation.   The report
prepared by NEIC  for  the  first facility  in each Region will  serve  as a
general format to be  followed by subsequent field investigation teams.



4.7       CBI Status

4.7.1     Introduction

Pursuant to Title 40 CFR, Part 2, Subpart B, Sections 2.201-2.309 [40 FR
36902, September 1, 1976, as amended in 43 FR 39997,  September 8, 1978], a
facility can designate information "confidential."  A facility may also
designate a "business confidentiality" claim for all or part of their infor-
mation pursuant to 40 CFR 2.203(b).  Any information received with a request
of confidentiality should be handled as "confidential."

Provisions of the Toxic Substances Control Act (TSCA) allow a company to
make a claim of confidentiality for any or all information collected by EPA
during an inspection if the material meets all of the following criteria:

     1)   The company has taken measures to protect the confidentiality
          of the information, and it intends to continue to take such

     2)   The information is not, and-has not been, reasonably obtainable
          without  the company's consent, by non-company personnel (other
          than government bodies) by use of legitimate means  (other  than
          discovery based on a showing of special need in a judicial
          or quasi-judicial proceeding).

     3)   The information is not publicly available elsewhere.

     4)   Disclosure of  the information would cause substantial  harm to
          the company's  competitive position.

Once confidentiality is  claimed, there  are  stringent procedures  that must be
followed.  Only persons  who have been granted special  clearance  may  have
access to the material  in the  files.

4.7.2     Handling TSCA CBI

     1)   Documents muse be supervised directly by a Document Control
          Officer (DCO) who has been TSCA CBI authorized.   Documents must
          be returned to the DCO each day unless the user  has approved TSCA
          document storage facilities.

     2)   TSCA CBI can be discussed only with authorized persons.

     3)   Information must be safeguarded when in use by keeping it under
          constant surveillance by covering it or placing material face
          down when unauthorized persons enter the area.  It must be
          returned to approved storage containers when not in use.

     4)   TSCA CBI may not be reproduced.  Copies must be obtained from
          the DCO.

     5)   TSCA CBI cannot be destroyed except upon approval by and under
          the supervision of the DCO.

     6)   TSCA CBI cannot be discussed over the telephone without prior
          written approval.

     7)   If TSCA CBI must be sent to another authorized  individual,  the
          transmittal  is accomplished through the respective Document
          Control Officers.

The  penalties for violating  the  required procedures  are severe.   A  viola-
tion is  the failure  to  comply with any provision  in  the TSCA Confidential
Business Information Security Manual, whether or  not such failure leads  to
actual unauthorized  disclosure -of TSCA Confidential  Business Information.
Violators of  these procedures may be removed from the authorized  access  list
and  be subject  to  disciplinary  action with penalties up to and including
dismissal.  Willful  unauthorized disclosure of  TSCA Confidential  Business
Information may subject the  discloser to a fine of not more than  $5,000  or

imprisonment for not more than 1 year,  or both.

It is essential that personnel be familiar with and abide by these require-
ments.  TSCA confidential files are subject to inspections by personnel from
the EPA Security and Inspection Division, as well as personnel from the
Office of the Inspector General.

EPA publications provide in-depth discussions on TSCA CBI handling
4.8       Problem Resolution

It is anticipated that discussions among members of the investigation team
will sometimes fail to reach a consensus.  In such situations, the following
guidelines will apply:

     1)   Technical Questions - Failure to reach consensus on a technical
          question will usually be due to insufficient reliable informa-
          tion, a legitimate scientific knowledge gap or interpretation
          of available data.  In the case of insufficient information,
          the Task Force should develop plans for gathering the necessary
          additional  information from the owner or operator, or through
          additional  inspections or contractor action, etc.

          If the problem stems from a lack of scientific knowledge, there
          are several alternatives:

          a)   The Core Team should identify the need to the Headquarters
               Program Evaluation Team for incorporation into the
               research program, and

          b)   The lead agency  (Region or State) must make  interim
               decisions based on a preponderance of evidence pending
               a technical  resolution.

          If the problem stems from different interpretation of the  avail-
          able data,  the  Core Team  should submit  the problem to the  Tech-
          nical Advisory Panel  for  review  and recommendations.

     2)   Regulation or Policy  Interpretations -  The  regulations and
          policies are often non-specific  in terms of  performance;  there-
          fore, disagreements may arise in interpreting their specific
          application.   Where consensus cannot be reached,  the  Task  Force
          Chairman is responsible for obtaining official interpretation in
          writing from the lead Headquarters office (i.e., OSW,  OWPE,  or

     3)   Procedural Disagreements  - Disagreements may also arise on how
          to proceed based on the conclusions reached (e.g., action on a
          permit application vs.  the use of an enforcement order to  deal
          with non-compliance).   Questions such as this may not be
          addressed in regulations  and policies issued to date.  They
          may simply represent alternative acceptable approaches with
          differing advantages.   In this circumstance, the responsible
          agency (State or Region)  should make an interim decision.
          Other team members, if they feel strongly,  may raise the issue
          to higher management for possible discussion at that level.
4.9       Safety

Protecting the health and safety of the investigative team is a major con-
cern in hazardous waste site investigations.   Section 111 (c) of CERCLA and
the National Contingency Plan  (40 CFR  300.71) require all hazardous waste
site work to be conducted by personnel who are adequately trained in safety
procedures.   Therefore all field staff will have completed field safety
training.  This is discussed further in Section  7.0.

4.10      Quality Assurance /Quality Control  (QA/QC)

Decisions concerning the control and management of hazardous substances
documented in the field investigation or the need for  legal actions are
based on analytical data.   Because such decisions can  be no better than the
data on which they are based, the quality of the data  must be ensured.   A
comprehensive and well-documented QA program is essential to obtaining
precise and accurate data that are scientifically and  legally defensible.
The concepts outlined in the QA program must be considered when determining
the sites for sampling, the frequency of sampling, the number of samples to
be collected, the procedures involved in the collection, preservation,  and
transport of samples, the calibration and maintenance  of instruments, and
the processing, verification, and reporting of the data.

The objectives of sampling quality assurance are:  1)  to ensure that the
procedures used will not detract from the quality of results, and 2) to
ensure that all activities, findings, and results follow an approved plan
and are documented.  These objectives dictate that much of the sampling
quality assurance effort be made before the field work begins.  Preparations
should include:

     o    written protocols for all activities;
     o    training all field team members regarding equipment operation,
          sampling procedures, and proper documentation procedures;
     o    ensuring that all containers and equipment have been
          properly cleaned and are appropriate for analytes of
          interest; and
     o    ensuring coordination with the laboratory

A distinction should be made between field quality control and laboratory
quality control.  Any  laboratory analyzing samples from hazardous waste
sites will have an associated quality control program  (in  the case  of  the
Contractor Laboratory  Program, this program is standard).  However,  the
laboratory's program only provides adequate quality control  for the analyti-
cal function and cannot be used  to ensure the quality  of  the  entire sampling

and analysis process.  Consequently, the sampling plan should provide for
adequate field quality control.

In addition to provisions for quality control,  sampling quality assurance
should specify a system of quality assurance procedures.checks, audits,  and
corrective actions specific to the site activities.   Field quality control
will be discussed in greater detail in Section 8.0,  "Field Quality Assur-
ance ."


The facility inspection activities should be carried out in a methodical,
well-thought-out fashion.   While many inspections may be routine,  the
possibility of adversarial postures by facility personnel and subsequent
litigation requires that the following items be a part of the facility
inspection protocol:

     o    Facility entry should be scheduled for normal working hours,
          unless overriding circumstances dictate.  Entry should
          commence by proper presentation of authorizing credentials,
          and will be announced in advance by a notification letter.

     o    Inspectors should complete a visitor register if requested
          but should not sign a waiver of liability.

     o    Inspectors should follow established Agency rules of conduct,
          including procedures when entry is denied.

     o    Begin the inspection with an initial briefing that states the
          purpose, objectives, and authority of the inspection.

     o    Interview knowledgeable personnel about specific facility
          details before making site observations (e.g., site opera-
          tions, monitoring system and sampling details, etc.).

     o    Review appropriate  records concerning compliance with ground-
          water monitoring  regulations.

     o    Conduct a visual  inspection of  the  facility  to verify conditions
          reported  in background  information  and  facility records, and
          to evaluate facility  sampling practices.

     o    At the close  of  the inspection, conduct a debriefing meeting
          with  facility personnel.

          Complete the appropriate inspection checklists  during the
          site visit.

          Each member of the inspection team should maintain a field log
          book to record observations throughout the inspection.   The  log
          book should contain factual information only.
5.1      Notification Letter

The Core Team will alert the facility prior to the inspection with a
Notification Letter that describes the intent and scope of the inspection.

The time when the facility is to be inspected should coincide with the
facility's  routine  quarterly  ground-water  sampling program.   Before the
Notification Letter is issued,  Regional Team personnel will telephone the
facility to establish the time  when the next round of ground-water samples
will be taken.   Care Team personnel will then contact Headquarters, State,
and contractor team members  to determine if the date for the inspection is
satisfactory.  If so, the notification letter can be issued.  If the initial
date presents a conflict for  some of the team members,  the Regional Team
leader should determine  an acceptable alternate date.  The Notification
Letter should then include a request for the facility to adjust the date of
their quarterly sampling (preferably not more than one week earlier or
later) to accommodate the inspection team's schedule.  It is the Regional
Team's responsibility to work out scheduling conflicts and  notify all parti-
cipants of  the  final  inspection  schedule.

Approximately one week  prior to  the inspection date, the Regional Team leader
should telephone the facility to reaffirm the date and time of the  inspec-
tion.  During this conversation,  the Team leader should supply the names of
EPA Regional and State  personnel  as well as  those of the  contractor's that
will be included in  the site visit.  The Regional Team leader can also
reiterate  the general mechanisms of the inspection  procedure  including:

     1)   the areas he would like to view during the  site  visit,
     2)   the facility personnel he would like to interview,  and
     3)   the documents he will need to review.

Specific questions about the  inspection procedure or matters  of compliance
should not be discussed at this time.
5.2      Facility Entry

The appropriate time of entry should be determined by the inspection  team
leader.   All inspections should be conducted at  reasonable  times  or during
normal working hours.  Inspections which cannot  be  completed before the
normal close of business for the facility will be continued on the  next
business day unless the time required for completion is so short that the
management does not object to working past normal closing time.   If the
facility runs continuously or the management normally departs before  opera-
tions stop,  the inspection may continue at the owners discretion.  However,
the inspection should be completed in a timely manner.

The plant premises should be entered through the entrance designated  by  the
facility in its response  to  an  inspection notification letter.

If there is only a guard present at the entrance, the inspection  team leader
should present his/her credentials and suggest the guard call his superior
or the responsible official.   The team leader should then document the entry
in his/her logbook and note  the date, time and name of the facility person-
nel encountered.

The inspection team  should be aware  that  consent to the inspection may be
withdrawn at any time.  However, any segment of  the inspection completed
before withdrawal of consent remains  valid.  Withdrawal of consent is
equivalent to a refused entry.  Therefore, a warrant may be secured to
complete  the  inspection (see Section 5.3 Procedures).

Consent to enter the site is not required for an inspection to observe and
report things in plain view (i.e., that a member  of  the  public could be in a
position to observe).   This includes observations made while on private
property in areas not closed to  the public (e.g.,  matters observed while the
inspector presents credentials).   However,  if the inspector does not have
a warrant, it may limit  the  inspector's access to any portion of the  facility.
All inspections must be  conducted in  light of  the Barlow's decision.  An
understanding of the implications of this decision on inspection activities
is crucial for  their  proper evaluation (See  Section 5.3,  Procedures).
5.3      Facility Entry Procedures

         o    Present Credentials

Upon arrival at a company or  facility, an inspector should introduce
himself/herself as an EPA inspector and present the proper EPA credentials
to the owner, operator or agent in charge whether or not identification  is
requested.   He/she should allow the person to whom the credentials are
presented the opportunity to  closely scrutinize, but not photocopy the
credentials since they indicate that the holder is a lawful representative
of the Administrator of the Environmental Protection Agency and authorize
performance under RCRA and under  all other  applicable  statutes.

         o    Liability Form

Under the authority of federal law, inspectors  shall not sign any liability
form or  release of  liability  (waiver) when  entering a  facility.

         o    Visitor Register

If the facility provides a blank  sign-in sheet, log or visitors register,  it
is acceptable  to  sign  it.

         o    Demeanor

EPA inspectors are required to perform their duties in a professional and
responsible manner and to refrain from any use of official  position for
private gain.   They are also required to collect and report the  facts of an
investigation completely, accurately, and objectively.  The  inspectors must
conduct themselves at all times  in accordance with the regulations  pre-
scribed in the EPA handbook,  "Responsibilities And Conduct  For EPA
Employees." The following paragraphs review some topics  in the  handbook
especially applicable to work conducted by the HWGW Task Force.

Employees  shall avoid conflicts of interest through outside employment or
other private interests.   A conflict  of interest may exist  whenever an EPA
employee or contractor has a personal or private interest in a matter which
is related to his official duties and responsibilities.   It is important Co
avoid even the appearance of a conflict of interest because the  appearance
of a conflict  damages the integrity of the Agency and its employees in the
eyes of the public.  All employees must, therefore, avoid situations which
are,  or give the appearance of, conflicts of interest when dealing  with
others in  or outside the government.

Good public relations and common sense dictate that employees dress appro-
priately and with proper safety equipment  for the activity  in which  engaged.
When in the laboratory,  field, or facility, employees should consult their
supervisor and the NEIC Safety Manual relative to proper attire  and safety
requirements.   Chapter 7 describes the appropriate health and safety
measures to be followed while conducting an inspection for  the HWGW Task

It is important that cooperation be  obtained  and good working relations
established when working with  the public.  This can best be accomplished by
using diplomacy,  tact, and persuasion.  Employees should not speak of any
person, other regulatory agency, or facility in a derogatory manner and
should use discretion when asked to  give a professional opinion on specific
products or projects.  All information acquired during an  employee's duties
is for official use  only.

An employee is forbidden to solicit or accept any gift, gratuity, entertain-
ment, favor, or any other thing of monetary value from any person, corpora-
tion, or group which has a contractual or financial relationship with EPA,
which has interests that may be substantially affected by such employee's
official actions, or which conducts operations regulated by EPA.   Respon-
sibility for individual actions rests  with the employee where circumstances
make  it inappropriate  to decline a nominally valued gratuity, such as lunch
in a company cafeteria where no payment mechanism is provided.

         o    Facility Entry Denial

If an inspector  is refused entry into a facility for the purposes of an
inspection under Section 3007 of RCRA, certain procedural steps must be
carefully followed.  These steps are  as follows:

     1)   Present proper identification to the facility, representative
          authorized to consent to an inspection.  Consent must be given  at
          the time of  the  inspection.

     2)   Thoroughly document  the  event,  noting  time,  date,  and facility
          personnel encountered.

     3)   If entry is  denied,  ask the reason  for denial.

     4)   If the problem  is beyond the  inspector's authority, suggest
          that the official contact an attorney  to obtain legal advice on
          his/her responsiblity under Section 3007 of  RCRA.

     5)   Under  no circumstances discuss  potential penalties  or do any-
          thing  which  may be construed as threatening.

     6)   If entry is  denied a second time, exit from  the premises and
          document any observations made  pertaining to the  denial, particu-
          larly  any  suspicions of violations  being covered up.

     7)    Report all aspects of denial of entry to the  Enforcement
          Division for appropriate action to be taken including help in
          obtaining a search warrant  (see Appendix B).

     8)    An Enforcement Division attorney will assist  the inspector in
          the preparation of the documents necessary to obtain a search
          warrant and will arrange for a meeting with the inspector and a
          U.S. Attorney.  The inspector will bring a  copy of the appropriate
          draft warrant and affidavits to the meeting.

     9)    The Enforcement Division attorney will inform the appropriate
          Headquarters Enforcement attorney of any refusals to enter and
          send a copy of  all papers filed to Headquarters.

    10)    The attorney will then secure the warrant and forward it to
          the inspector,  and/or  the U.S. Marshall.

It is the policy of EPA to obtain a warrant when all other efforts to gain
lawful entry have been exhausted.  This policy, of course, does not apply to
pre-inspection warrants,  which may be  obtained under circumstances described
later in  this chapter.

In  Marshall  v. Barlow's,  Inc..  436 U.S.  307  (1978),  the  Supreme Court
addressed the need for an administrative warrant when an Occupational Health
and Safety Administration inspector sought entry  into a work place where
consent for the inspection was not voluntarily given by the owner.  The
Court concluded that an administrative warrant was required to  conduct such
regulatory inspections unless  the industry is one with a history  of exten-
sive regulation, such as  liquor  or firearms.

As a matter of policy, the  Agency will  apply the  requirements  of Barlow's
to all RCRA  inspections.  According to Barlow's,  a warrant may  be obtained
where there is a specific reason to think that a violation has been commit-
ted (i.e., where  there  is  probable cause,  such as an employee's complaint or
a competitor's tip).   A warrant may also be issued if the Agency  can show
that the  establishment  to be  inspected has  been  selected pursuant to a

neutral inspection scheme.

Conducting an inspection under a search warrant will differ from conducting
a normal inspection.   The following procedures  should be  complied with in
these situations:

     1)   Use of a Warrant to Gain Entry

          a.    If there is a high probability that entry will be refused
               even with a warrant or where there are threats of violence,
               the inspector should be  accompanied by a  U.S. Marshall.

          b.    The inspector  should never attempt to make any forceful entry
               of the establishment.

          c.    If entry is refused to an inspector holding a warrant but
               not accompanied by  a U.S. Marshall, the inspector should
               leave the establishment  and inform the Enforcement Division

     2)   Conducting the Inspection

          a.    The inspection must be conducted strictly in accordance
               with the warrant.  If the warrant restricts the inspection  to
               certain areas of the premises or  to  certain  records, those
               restrictions must be  adhered  to.

          b.    If sampling is authorized, all procedures must be care-
               fully followed including presentation  of  receipts for  all
               samples  taken.  The facility should also be informed of  its
               right to retain a portion of the samples  obtained by the

          c.   If records or property are authorized  to be  taken, the
               inspector must provide receipts and  maintain an  inventory of
               all items removed from the premises.

 Inspectors  should consult NEIC's procedures  for  further  guidance  (see
 Appendix B).
 5.4      Initial  Briefing with Owner/Operator of the Facility

 During the  initial  briefing with  the owner/operator of the facility the
 inspector should  state  the purpose  of  the  inspection and the authority under
 which the inspection is being conducted.   If requested, the inspector should
 furnish a copy of the Act and appropriate  regulations to the facility repre-
 sentative .

 5.4.1    Scope  of Inspection

 The inspector should outline the  objectives of  the  inspection  and  the order
 in which various  aspects of  the  facilities operations will be  examined.   If
 duties regarding  sampling  and  laboratory analysis have  been  delegated to  key
 personnel,  the inspector can suggest a schedule for meeting with those
 responsible persons if  a meeting has not been established already.  A well-
 planned schedule  can eliminate wasted  time in waiting  for  records  to  be
 gathered, key facility  personnel  to become available, and  intermittent
 facility operations to  be  started.  During a compliance  inspection,  it would
 be beneficial to  have a facility representative accompany the  inspection
 team to describe  to them  the plant  and its principal operating charac-
 teristics and to answer their questions.

 The plant manager and facility officials should also be informed of their
 right to request  and receive immediately duplicates of any samples collected
 for laboratory analysis during the  inspection,  and  copies  of analysis
: results later (if an enforcement case  is not pending or being pursued).   By
 establishing an atmosphere of cooperation between the  inspection team and
 facility officials, inspectors will be able to  accomplish inspection activi-
 ties more  easily.

5.4.2    Document and Data Requests

Most information on ground-water monitoring system details, ground-water
assessment programs and monitoring waiver demonstrations will be submitted
and available for review at the regional EPA offices and/or at the state
offices and will probably be included as part of the document package for
the facility.  The documents  available should be reviewed prior to the site
visit.   There will be instances when such information will not be available
for review until the site inspection.   In this case,  the inspector will have
to request to review the applicable ground-water documents at the  facility.
After a review of the documents at the  facility, the inspector should re-
quest copies of pertinent documents.  The copies can then be brought back
with the inspector for a more  detailed  review.
5.5      Interviews

Much time  can be  saved by  interviewing the appropriate knowledgeable facil-
ity personnel.  Before beginning a visual inspection of the facility,
Owners/Operators,  Facility Engineers, and sampling and laboratory personnel
should be  interviewed.

5.5.1    Owner/Operators/Facility Engineers

The owner/operator and facility engineer can provide information that will
give the inspector  a general understanding of the  operation of the  facility.
This knowledge is necessary to aid in the determination of substances pre-
sent at the  facility.   It  is not necessary that an inspector has an  in-depth
understanding of  all  the intricacies of the onsite processes;  however, a
sufficient understanding will provide  the inspector with confidence  to
conduct the  inspection.                                    •.."•'•

The questions on  the checklist (Appendix  C) should also be directed  toward
the facility engineer,  or  toward the owner or operator, if the  facility is

5.5.2     Sampling Personnel

The sampling personnel will be able to answer specific questions on the
checklist regarding sample collection.   For example,  questions pertaining to
how ground-water wells are purged prior to  sampling,  sampling equipment and
procedures,  and sample preservation and shipment,  chain-of-custody proce-
dures can be asked of sampling personnel.

5.5.3     Laboratory  Manager

The laboratory manager will, of course, be the focal  point for questions
concerning analytical procedures and the types of parameters measured.  The
laboratory manager should also be aware of proper chain-of-custody proce-
dures and laboratory QA/QC requirements.  If the analyses are carried out by
an outside laboratory, the inspection team will determine, on a case-by-case
basis, if an additional inspection of the outside lab is  necessary.
5.6      Records Review

A facility may have implemented one of three types of ground-water monitoring

1) A groundwater detection monitoring system as described in 40 CFR

2) An alternate ground-water monitoring system as described in 40 CFR

3) A ground-water  quality  assessment  plan as described in 40 CFR 265.93(d).

The following sections define the procedures to be followed in conducting
the comprehensive  ground-water  investigations for each  type of system.  See
the checklist (Section 5.10 and Appendix C) for details of protocol

5.6.1    Detection Monitoring System

If a detection monitoring system was implemented, inspect the files for,
and evaluate the adequacy of:

     o    Analytical Records - All facilities  should have  appropriate
          analyses on file.   The record should include  the  following

               o    Parameters
               o    Frequency
               o    Replicates as appropriate
               o    Timeliness

          If any of the National Interim Primary Drinking Water Standards
          results obtained during the first year exceed the respective
          MCL's,  the results should be highlighted in the quarterly report
          submitted to the Regional Administrator.

     o    Ground Water Elevations - These should be determined before
          samples are removed each time a well is sampled.

     o    Sampling and Analysis Plan

     o    Well  Construction Data (not  required by regulations).  If it is
          not available, interview appropriate facility personnel who may
          have knowledge  of installation.

     o    Ground Water Quality  Assessment  Outline.

     o    Evidence of semi-annual statistical comparison of ground water
          data.  Where comparisons indicate no significant change, perform
          independent comparison using facility  data (note if alternative
          statistical procedure was  used).                            «•

     o    Evidence of implementation of a ground water quality assessment
          plan if the semi-annual statistical comparison  indicates a signi-
          ficant change in ground water has occurred.

5.6.2    Alternate Ground-water  Monitoring System

If an alternate ground-water monitoring system was implemented, inspect
files for:

     o    An alternate ground-water  monitoring  system plan (see checklist
          for specifics regarding certification, dates of submission and
          implementation, plan basics and objectives).

     o    The report (which  should have been submitted as  soon as
          technically feasible after implementation of the plan)  to the
          appropriate regulatory agency with  the results  of the  assessment.

     o    Evidence of continued quarterly monitoring,  including  analyses
          and evaluations.

     o    Correspondence documenting submission of annual assessment
          report to  appropriate regulatory agency.
5.7      Visual Inspection

Following the initial briefing or opening conference with facility manage-
ment or operating personnel,  and interviews with sampling and laboratory
personnel, a visual inspection must be conducted.   When touring the facil-
ity, appropriate facility safety requirements must be strictly adhered  to.
It may be useful to have the plant engineer conduct the tour along with the
facility's sampling personnel.   The laboratory manager will only be required
for the inspection of his laboratory.  The plant engineer will be able to
describe the facility's  processes as  the  tour  continues.   The sampling
personnel will direct the inspector to the sampling points and demonstrate

the sampling  techniques  practiced by the  facility.

5.7.1     Geomorphic Features

An important  aspect of the  site  investigation  is to ensure that all
potential sources of discharge of hazardous waste to the ground-water are
addressed in  the program.   It is necessary for the inspector to locate the
sources described in the  monitoring or assessment program and determine if
any source has been omitted.  In the event that any waste management areas
have been left out, the  inspector must note the location, size and type of
area in his/her  inspection  log  book.

The occurrence of significant topographic or surficial features,  if any,
should be noted in the inspector's log book.  These  features  may  indicate
areas of ground-water recharge  or discharge.

5.7.2     Surface  Water and  Seeps

During the  inspection, attention should be paid to any surface water bodies
or streams  on or  adjacent to  the  site.  Since ground-water may be discharged
to these surface water bodies, there is a possibility that contaminants in
the ground-water may  also be  present in  the surface water.   Signs of conta-
mination may  be:

         o    an  oily sheen on  the surface of  the water;
         o    discoloration on the banks  from  precipitation  of contaminants;
         o    dead or distressed vegetation along the banks;  and,
         o    unusual foaming or odors.

The distances of  surface water bodies, streams and wetlands  should be  noted
: in  the  inspector's  log  book.                                :

5.7.3     On-Site Wells

While  it may not be possible to observe all well construction details,  there
are several items that  can  be checked.   These  include  the construction

materials, the location and number of the monitoring wells,  the total  depths
and the ground-water elevations.   During the  inspection,  the  locations  and
numbers of monitoring wells should be checked to ensure that all wells  are
located and in agreement with  the  monitoring  program locations.  See  Section
6.3  for a detailed discussion of monitoring well inspection.
5.8      Sampling Procedures Evaluation

During the sampling inspection,  the following sampling procedures practiced
by the facility should be evaluated (see Checklist,  Appendix C):

     1)   How are wells purged prior to sampling and how are  samples

     2)   Are all wells sampled with the same equipment?  If so, what
          provisions are used to clean  the equipment after  sampling to
          prevent cross-contamination between wells?

     3)   Are all organic constituents  to be  sampled?

     4)   Are samples collected with equipment to minimize absorption
          and volatilization?

     5)   Have standard preservation procedures been followed?

     6)   Are samples refrigerated?

     7)   Are sample holding period requirements adhered to?

     8) .  Are suitable containers used?

     9)   Are provisions made to keep samples chilled during shipment?

5.9      Laboratory Inspection

During the laboratory inspection the following analytical procedures  should
be evaluated (see Checklist, Appendix C):

     1)   How are samples preserved and what are the holding times?

     2)   Are approved analyses used as standard operating procedure?

     3)   Are analytical instruments routinely calibrated and in good
          state of repair?

     4)   Is there an adequate QA/QC program for all analyses?

     5)   Are calibration records and other recordkeeping logs kept at
          the laboratory?

     6)   Is the glassware cleaned and baked according to proper
          laboratory procedure?

5.10     Facility Owner/Operator Debriefing Meeting

A debriefing meeting or closing conference should be held with facility
management  or  operating personnel  at the  end of the inspection.  The inspec-
tion team's main function is to observe and evaluate compliance, but it is
noted  that overall compliance  will be  determined by the Task Force Core Team
upon final review of the report and other pertinent findings.  Statements on
compliance  status, legal effects, or enforcement consequences should not be
discussed with  facility  management or its operating personnel.

At  this  meeting, inspectors  may request additional  data,  questions may be
asked  or answered,  requested permit  changes and process modifications are
noted  and necessary  receipts are given.  The  inspectors should make  a final
review of checklists and field notes before  the  conclusion of the  visit.
Field  notes  taken during the visit should not be turned  over  to  the company

officials.   However,  the inspectors  are  free  to  let  the company know  that
they may request a copy of  the  inspection report, and that it may be  made
available in accordance with the restriction  of  the  Freedom  of  Information
Act and 40 CFR Part 2.

Written receipts are given for samples and documents taken from the facil-
ity.   A declaration of Confidential Business  Information  (see Section 4.7)
shall include a list of items declared confidential  by an authorized  facil-
ity official, and procedures should  be explained if  the company desires  to
make any subsequent declaration.
5.11     Analysis of Results

Results of the inspection should be discussed during the debriefing meeting.
Discussion may include observed deviations  from prescribed or recommended
procedure.   Facility officials should be informed of any leaks,  spills,  or
other problems that require immediate attention.  However,  the inspector's
discussion should be limited to specific findings of the visit.   Certain
precautions are  essential.

The inspector must:

     1)   Remember  that his/her function is to observe and  evaluate
          compliance while on compliance inspections.   The  overall compli-
          ance or non-compliance status of the facility will be  determined
          by the Core Team upon review of the inspection report.   State-
          ments  regarding compliance  status and any legal effects or
          enforcement consequence should not be discussed with  the permittee
          or facility operating personnel.

     2)   Realize that it is an. unacceptable practice  to recommend a
          particular consultant or  consulting  firm  even if  asked to  do  so.
          However,  it is not unethical to suggest that the  permittee, opera-
          tor, or agent contact a professional society for advice concerning
          this matter.

     3)   Make no attempt to substitute his/her own judgement for that
          of plant operating personnel regarding details of operation.
5.12     Checklists

At all inspected facilities,  a checklist  must be completed and submitted as
part of the inspection report.   A checklist  for  comprehensive  ground water
inspections at RCRA facilities was developed by  NEIC and will  be  used  as
part of this protocol.   The checklist  is  designed to evaluate  compliance
with subpart F of the interim status standards at 40 CFR Part 265,  Subpart
F: Groundwater Monitoring.  An example checkist  is shown as Appendix C.


The protocol for developing the sampling plan is addressed below in four
areas: pre-survey activities,  equipment staging, monitoring well inspec-
tion, and sampling.  In each area, the salient requirements of the protocol
are presented as specific items or steps.  These are followed by a discus-
sion of some of the considerations or options associated with each item in
the protocol.
6.1      Review Document Package and Field Investigation Plan

Compilation of the sampling plan should begin with a review of the facility
data collected by the HWGW Task Force (the 'document package') and the
Field Inspection Plan developed after the first consensus meeting.  The
document package and the Facility Inspection Plan should be reviewed to:

     (1) determine the physical characteristics and layout of the
         wells comprising the monitoring system.
     (2) determine the nature of the hydrogeologic regime into
         which the monitoring system has been installed.
     (3) determine the types of samples that need to be taken during the
         inspection (e.g., ground-water, leachate, soil, surface water)
     (4) determine the analytes of interest for each type of sample.
     (5) determine the equipment and sample containers needed for
     (6) determine schedule requirements (e.g., to obtain quality
         control samples from the CLP lab; obtain bottles from the Sample
         Bottle Repository), level of effort estimates, and safety

6.1.1    Monitoring System Evaluation

The parties responsible for preparing the sampling plan should review  the
facility description information, analytical data, and background geologic
data in the document package.  The objective of this review is to evaluate

the characteristics of the monitoring system in place at the facility and
the implications this would have on the sampling approach.   It is assumed
that sampling activities initially will focus on those monitoring wells
routinely used by the facility as part of their ground-water monitoring
system, consistent with the sampling objectives developed in Section 3.2.

For the purposes of the Task Force's evaluations,  the wells to be sampled
and inspected must be part of a monitoring system that is designed and
installed in accordance with the applicable RCRA regulations:
          "Owners or operators of surface impoundments,  landfills,  or land
          treatment facilities which are used to manage  hazardous waste
          must have implemented a ground-water monitoring program capable of
          determining the facility's impact on the quality of ground-water
          in the uppermost aquifer underlying the facility." (40 CFR

          "A ground-water monitoring system must have been installed
          capable of yielding samples for analysis and consisting of:

          (a)  Monitoring wells (at least one) installed hydraulically
          upgradient from the limit of the waste management area.
          Upgradient wells must yield ground-water samples which are
          representative of background ground-water quality and not
          affected by the facility; and

          (b)  Monitoring wells (at least three) installed hydraulically
          downgradient at the limit of the waste management area.
          They must be located and constructed such that .they will
          immediately detect any significant amounts of hazardous
          waste or hazardous waste constituents that migrate from
          the waste management area to the uppermost aquifer.
          All monitoring wells must be cased in a manner  that
          maintains the integrity of the borehole.  The casing must
          be screened or perforated and gravel packed where necessary

          to enable sample collection at depths where appropriate
          flow zones exist.   The annular space above the gravel pack
          must be sealed with a suitable material (e.g.,  cement
          grout or bentonite slurry)  to prevent contamination of
          samples and ground water."  (40 CFR 265.91)

An evaluation of the adequacy of the  wells in each monitoring system re-
quires definition of the hydrogeological characteristics of the site.
Important characteristics include:

     o    Depths to, and thicknesses  of aquitards and
          aquifers of interest.

     o    Ground-water elevations.

     o    Textural properties of aquifers and aquitards.

     o    Hydraulic conductivities, pressure gradients, and
          flow rates within the system.

Site-specific hydrogeological information which may supply much of the data
needed to determine these characteristics may be obtained from RCRA Part B
Permit applications and from ground-water monitoring and assessment plans.
Useful information to be obtained should include:

     o    Monitoring well boring logs

     o    Monitoring well construction details

     o    Facility site map showing well locations

     o    Survey data on well elevations

Regional geologic details should also be reviewed,  if  available, to enable
verification or refinement of site-specific data.   Regional geologic condi-
tions may also relate to  the potential pollution problem at hand and may

affecc some of the considerations of the sampling approach as well.

The natural erosional or depositional history of a site can often be deduced
from land forms.  When present, common geomorphic features, such as  flood
plains, stream terraces, glacial moraines, dunes, sinkholes,  drainage
divides, and valley profiles, should be identified.   Topography and  drainage
observations from site maps may aid in evaluating surface runoff, infiltra-
tion, and ground-water flow possibilities.  Topography around the site go-
verns surface water flow and suggests the probable direction of ground-water
flow.  Drainage patterns may indicate bedrock control, through joints or
structures, which could influence ground-water flow.

Springs and seeps represent ground-water discharge and are generally a
result of the water table intersecting the land surface or of leakage from
an artesian aquifer.  Such features should be located on a site map.

Surface water bodies, such as streams and impoundments, may be contributing
to or receiving ground-water flow.  Their importance in this regard must be
evaluated.  Streams, rivers, and/or impoundments near the site should be
located and described in terms of physical dimensions, source waters, and
topographic relation to the facility.  Water-level records for the identi-
fied surface water bodies should be obtained and used together with ground-
water elevation data to predict the direction of ground water flow and
pollutant movement.

These data should be reduced and interpreted by a qualified hydrogeologist
and compared with monitoring system characteristics to determine if the
requirements of 40 CFR 265 are fulfilled.  To the extent possible, construc-
tion information about any well identified as part of the monitoring  system
should be used.  These data  should include:

     o    Location of the well -

     o    Well  depth  ("as built" and  present)

     o    Casing dimensions  and material

     o    Screen dimensions and material

     o    Sealing material and methods in borehole above gravel  pack

     o    Gravel pack interval and materials,  if applicable

     o    Static water level and data measured

Extensive evaluation procedures are presented in the "Ground Water Technical   j
Enforcement Guidance Document - Draft: March 21, 1985"  (U.S.  EPA,  Office  of   |
Solid Waste and Emergency Response).  Evaluation of a well as not  ful-
filling the regulatory requirements should exclude it from consideration  as
a monitoring point and may indicate the need to use alternate (existing)
wells or install new wells at appropriate location(s).

6.1.2    Analytical Evaluation

Determination of the nature and types of samples that need to be taken
during the inspection should be made primarily on the basis of previous
sampling activities conducted at the facility.  The protocol followed by the
HWGW Task Force should attempt to utilize, rather than duplicate,  existing
site information; therefore, the analyses that are specified in the sampling
plan should include those routinely made by the facility for compliance
purposes.  These analytical parameters may be determined from previous
reports of analytical data and from permit applications.  Previous ground-
water analyses and applications generally provide information concerning
potential and actual ground water contaminants.  In addition, knowledge of
the behavior of particular contaminants in ground water will be necessary  to
evaluate the adequacy of  the monitoring system and to determine personal
protective equipment requirements during sampling operations.  Previous
inspection reports should reviewed to determine a facility's com-
pliance history, problems which may be associated with certain contaminants,
and any details which may require special attention.  In reviewing  this
information an effort should be made  to determine the integrity (from both
security and physical standpoints)  of wells in  the monitoring system.

6.2      Development of Preliminary Sampling Approach

A preliminary sampling approach should be developed to:

     (1) select sampling locations (this may or may not  correspond to
         existing wells at the site,  depending on their  evaluation).
     (2) specify the manpower requirements of sampling activities.
     (3) identify equipment needs.
     (4) identify safety and logistical considerations.
     (5) determine the scheduling requirements needed to perform the samp-
         ling activities.

Information conveyed in the document package for the facility and the field
investigation plan (Section 4.2) will be the primary resources for develop-
ment of the preliminary sampling approach.

6.2.1    Selection of Sampling Locations

The determination of sampling site locations should be done first, because
this will have bearing on the equipment needs and logistical considerations
of the sampling activities.  The prime candidates for sampling are the
monitoring wells specified as part of the compliance monitoring system;
however, these wells must be evaluated as to their adequacy in terms of the
regulatory requirements  (discussed in Section 6.1.1).  Monitoring wells that
do not fulfill these requirements should not be used as sampling  locations;
alternate (existing) wells may have to be used, or new wells may have to be

Surface water (e.g., streams, lagoons) and soil sampling locations may be
selected if samples from these locations would verify or augment well sam-
ples.  Surface water samples should, in general, be selected from areas of
known or suspected ground-water discharge downgradient of the facility.  Soil
samples may be useful in determining contamination from leachate  or  disposal
activity, and in delineating possible areas of contamination.

The sampling approach should designate all proposed sampling locations on a
map of the site and should designate the type of sample (e.g.  soil,  ground-
water) and analytical parameters associated with each location.
6.2.2    Manpower Allocations

The sampling approach should identify the name or classification (e.g.,
environmental engineer, hydrogeologist) of the personnel required for the
inspection, and the responsibilities of each member of the team.  In
general, this will follow the organization set up by the Field Investigation
Plan (Section 4.1) but should also include designation of the team leader
and person(s) responsible for carrying out specific sampling activities.
6.2.3    Equipment Designation

The sampling approach should describe the equipment needed to carry out the
sampling inspection.  This equipment can be categorized in three general
areas:  sampling equipment, containers and preservatives, and expendable
items.  Selection of the actual samp I-Ing equipment to be used is discussed
in the sections to follow.

Specification of the number and type of containers needed at each sampling
location depends on the type of sample to be taken and the analytical
parameters of interest.  This information is most easily prepared in a table
format, using a reference  such as  "Methods for Chemical Analysis of Water
and Waste" (U.S. EPA, 1983) to determine the specific container types
(glass, plastic) and volumes (pint, liter, etc.) needed for each parameter.
The table should have a list of the preservatives required by each of the
analytical parameters, and should  present totals for the various types of
containers needed.   The totals' must also include the quality assurance
samples required by the laboratory, such as field blanks and trip blanks.
Quality assurance samples  are discussed in Section 8.0.

The equipment List should also include a list of expendable items that will
be needed to conduct the sampling.   These items include,  but are not limited
to: solvents and distilled water for washing sampling equipment in the field
(unless one-time disposable equipment is being used);  plastic sheeting and
paper products for maintaining a clean work area and cleaning/drying equip-
ment; sample packing boxes and material; ice (wet;  solid carbon dioxide or
'dry ice1 is restricted for transportation) for refrigerating samples; and
filters for filtering dissolved metals samples in the field.

6.2.4    Safety Considerations

The sampling approach should detail the specific safety concerns identified
from available site information,and describe the appropriate precautions or
response to be taken.  This issue is discussed further in Section 7.0.

6.2.5    Logistical Considerations

The sampling approach should lay out a  schedule for all activities asso-
ciated with the sampling investigation, with particular attention to  items
or events that may be of a significant  duration and thereby delay the
sampling schedule.  This includes specifying and scheduling equipment prepa-
ration (ordering expendable items, obtaining sample containers, etc.),
equipment staging and calibration (if necessary), and transportation  of
equipment to the site and samples to the analytical laboratory.  The
sampling plan should also detail the logistics of obtaining quality
assurance samples; specifically, these  samples include trip blanks, which
should be obtained from the CLP laboratory  selected by EPA, and performance
evaluation samples, which will be obtained  from EPA-ORD in  Cincinnati.

6.2.6    Notification of Sample Management  Office and CLP Laboratory

The  sampling approach should  include the name(s) and telephone number of
contacts at the EPA Sample Management Office  (SMO) or the responsible
contractor such as VIAR and at  the CLP  laboratory to be used  for  sample
analysis.  These contacts should be made in advance of field  activities and
should report the dates of sampling, the anticipated number and  types of

samples,  the kinds of analyses required,  and the anticipated method and time
of shipment.  The appropriate analysis request forms  and other  documenta-
tion, if applicable,  should be requested at the time  of contact.
6.3      Equipment Staging

Preparation and assembly of the required equipment  and materials  for  site
sampling should proceed as follows:

     (1) Equipment should be assembled using a checklist based on the
         requirements of the preliminary sampling approach.
     (2) All equipment should be checked for proper calibration,  assembly,
         and operation.
     (3) All sampling equipment that will potentially contact sample
         material should be cleaned with a detergent wash,  solvent rinse,
         and distilled water rinse.
     (4) Openings in sampling equipment and small sampling implements
         should be wrapped in clean aluminum foil for transport.

Sampling equipment and associated material should be assembled in a clean
laboratory area for preparation and check-out.  This is facilitated by using
an equipment checklist that can be developed during preparation of the
sampling approach.  This list should be prepared in cooperation with all
personnel involved in  the study.  Items should be checked and rechecked
against the list prior to departure so nothing will be forgotten.  The list
should include:

     o    Portable analytical equipment (e.g., pH meter,
          conductivity meter)

     o    Sample preservatives -

     o    Analytical reagents and cleaning solvents

     o    Glassware

     o    Appropriate sampling gear (e.g.,  Kenanerer  samplers,
          Teflon bailers,  corers,  submersible  pumps,  etc.)

     o    Sample containers

     o    Shipping and sample storage containers  (ice chests)

     o    Photographic equipment

     o    Water-level sounding apparatus (mechanical, electrical,
          or acoustic)

     o    Notebooks, sample tags,  field data sheets,  custody sheets

     o    Protective clothing, breathing apparatus,  first aid
          equipment, etc.

The above list is only an example and should be amended to include equipment
or supplies that address the specific sampling requirements associated with
the facility to be inspected.

Mechanical and electrical equipment that will be used for sampling should be
checked to make sure  it is in working order before entering the field.
Sampling equipment,  including all pumps, bailers, and other implements that
will enter a well or  contact sample material,  should be cleaned with non-
phosphate soap and hot water, rinsed  (hexane or acetone for priority pollu-
tant or organic samples; dilute nitric acid for metals), and finally rinsed
several times with distilled, deionized water.   The open ends of sampling
equipment (e.g., pump inlets/outlets) should be covered with clean aluminum
foil until used.  Smaller  implements  (e.g., coring tubes) should be entirely
wrapped in foil.

The preparation and  cleaning  of sample containers is discussed in Section

6.4      Monitoring Well Inspection

Onsite sampling activities should commence with an inspection of the
monitoring wells selected for sampling.   This inspection should proceed as

     (1) Perform a safety survey prior to opening each well.
     (2) Open the well carefully, while  observing for possible pressure in
         the casing or the presence of toxic or noxious gas.
     (3) Measure and record the well parameters (casing diameter,  total
         depth, static water elevation).
     (4) Determine the volume of water to be purged from the  well prior to
     (5) Determine whether there are different liquid phases  or stratified
         contaminants in the well so that sampling strategies may be

6.4.1    Perform Safety Survey

Ordinarily, monitoring wells are constructed in such a way that the ambient
pressure is equalized with the pressure inside the casing; ground water in a
well also does not usually evolve toxic or noxious gases that would present
a safety hazard.  However, the potential to encounter both of these situa-
tions exists for wells which may be encountered by the HWGW Task Force, and
the initial approach to a well should incorporate a safety survey.

Typically, the survey should include an inspection of the closed well  to
determine if overpressure in the casing may be present.  This would likely
be found in a deep well constructed of solid, unvented casing with a
threaded cap or plug.   If such a condition  is encountered, the sampling
personnel should  open the well slowly, after donning eye protection.    The
escaping gas at the well head should be sampled with an organic vapor
analyzer  (OVA or  HNU) to determine  the need  for respiratory protection.
Sampling personnel should also be equipped with portable equipment (e.g.,
Drager  sampler) to analyze for other gases  such as hydrogen cyanide, hydro-
gen chloride, etc.

6.4.2     Opening The Well

Each monitoring well should be unlocked and opened at the time of sampling;
premature opening of the well (except for evacuation of standing water in
wells drilled into an aquifer of low transmissivity) may invite questions
concerning the security of the well and the resultant validity of sample
data.  Depending on the installation methods,  materials at hand,  and other
factors, the monitoring wells that will be encountered by the HWGW Task
Force may have several different kinds of closure configuration.   Where
facility personnel will accompany Task Force members to each well,  access
should not be a problem; however, the sampling equipment should include
various implements such as pipe wrenches (for steel casing), strap wrenches
(for plastic), and rubber mallets to assist in opening corroded or tight
well closures.

6.4.3     Measure Physical Parameters of the Well

Several measurements of the physical parameters of each well must be made
before sampling can commence.  The reasons for this are twofold.  The mea-
surements are needed to calculate the volume of standing water in the well
casing, which in turn will determine the volume of water that must be purged
from the well prior to sampling.  An additional reason for measuring well
parameters (e.g., total depth) is as a check for casing integrity and for
siltation of  the well screen.  Corrosion can cause collapse and/or leaking
of the well casing.  This could  lead to erroneous or misleading water level
measurements.   Corrosion and silting can clog well screens causing a slug-
gish response or no response to  water level change.  In wells used for water
sampling, this can be tested by  removing a known volume of water from the
well and monitoring the water level response as the well recharges.

The  inner diameter  (I.D.) of the well casing should be determined and re-
corded.  Then, the  static water  level and depth of  the well should be
determined with a chalked (blue  carpenter's chalk)  steel  tape; an electric
or acoustic sounder may also be  used for  the water-level measurement.    The
steel  tape should be  lowered into  the water slowly  to  prevent  splashing.

Whatever cool is selected should at least be wiped with a clean paper towel
and rinsed/washed with distilled water prior to and after use.   The time of
the depth to water reading, point of reference, and depth to water level
should be recorded.  Determination of the number of linear feet of standing
water should be made by subtracting the distance from the top of the casing
to the static water level from the total depth of the well.   It is important
to determine the static water level before purging the well so that a point
of reference is obtained for observing the recharge of the well (especially
in low-permeability aquifers).
6.4.4     Equipment Options and Preferences

Several tools are available to perform the above measurements; the choice of
tools generally depends on availability and the familiarity of the sampling
personnel with each device.  The advantage of a steel tape over the electric
sounder or acoustic measuring devices is the ability to measure the depth to
water more accurately -- to within 0.01 foot.  The disadvantage of the steel
tape compared to the electric tape or acoustic sounder is that if the depth
to water is unknown, it may be necessary to lower che tape into the well
several times before obtaining a reliable reading; water on the casing wall
may also wet the tape above the true water level, resulting in measurement
errors.  Where a series of measurements are needed in quick succession, such
as in pumping tests, electric tapes have the advantage of not having to be
removed from the well for each reading.

6.4.5     Determine Well Purging Volume

The volume of standing water that should be removed from the casing prior
to sampling should be determined from the chart presented in Figure 6-1.

50 -,
45 -
                '50          "100         "150         200         250

                  Volume of Water to be Purged from Well  (gallons)
         Figure 6-1:  Determination of Volume of Standing Water in Well

This chart is based on the formula:

          V -  r2h(0.163), where:
               V - standing water volume in gallons
               r - inside radius of well casing in inches
               h - linear feet of standing water in the casing
               0.163 - conversion factor (includes conversion of
                       inches to feet, cubic feet to gallons, and pi)

The effects of pumping a well for a period of time to insure collection of
a "representative" sample have been documented effectively.   In most cases,
the water stored in the well casing is of a different chemical quality than
that contained in the aquifer to be sampled.  Solutes may be adsorbed or
desorbed from the casing material, oxidation may occur, and biological
activity is possible.  Therefore, the stagnant water within the well bore
must be purged (see Section 6.4).  This will enable ground-water which is
representative of the aquifer to enter the well.

6.4.6     Determine Liquid Phases in the Well

During development of the preliminary sampling approach, it will become
apparent whether or not the ground water to be sampled might include consti-
tuents of different densities and solubilities.  It is to be expected that
any of the following conditions could be encountered:

1)   Immiscible fluids -  insoluble compounds may either rest on the
     ground-water surface or descend to a confining layer beneath the
     aquifer depending on density differentials.

2)   Dense solutions and  contaminant stratification  -  some soluble
     contaminants tend to form  discrete stratification sequences
     with narrow adjacent zones of dispersion.  Ground water flow
     velocities are  typically very low and  do  not  create sufficient
     turbulence to uniformly blend the solutions.

To sample the constituents of interest properly ,  sampling personnel should
attempt to determine if an immiscible layer is present at the top or bottom
of the well.  This may be done by sending down a steel tape coated on one
side with a paste that is color-sensitive to organic liquids and on the
other with a water-sensitive paste.  The approximate thickness of different
liquid phases in the well can be read directly from the tape.

6.5      Well Evacuation

Each monitoring well to be sampled should be purged of stagnant water in
the well casing, as mentioned above.  This should be done by the following

     (1) Determine how the well should be evacuated, depending on its
         recharge characteristics.
     (2) Select the appropriate equipment to purge the well.
     (3) Record the appropriate measurements and field observations prior
         to and during the well evacuation.
     (4) Purge the well and dispose of the extracted water properly.

6.5.1     Select Pumping Equipment

The method used to purge a well is partly dependent upon the size (I.D.) of
the well to be sampled, depth to water, volume of water in the well, and
well accessibility.  The other important factor is the recharge
characteristics of the well as discussed below.  The types of equip-
ment available for well evacuation  include hand-operated or motor-driven
suction pumps, peristaltic pumps, compressed-gas (air lift) pumps, submer-
sible pumps, and bailers made of various materials such as stainless steel,
copper, Teflon, and PVC.  In general, well purging should be done with
equipment that will allow large volumes of Water to be removed but that
will not contaminate the remaining  water in  the well.  These considerations
are discussed thoroughly in references such  as  "Manual For Ground Water
Quality Sampling Procedures"  (U.S.  EPA, 1981).  Table 6-1 presents a
compilation of applicable well-purging equipment.

0 iameter
 Casi ng
Peristaltic   Vacuum                Diaphragn     Submersible      Submersible
   Pu«p        Pump     Airlite   "Irash" Puap   Diaphragm Pump   Electric Pump
Water level
 <25 ft

Water level
 >25 ft
Water level
 <25 ft

Water level
 >25 ft
Water level
 <25 ft

Water level
 >25 ft
Water level
 <25 ft

Water level
 >25 ft
                                                        Source:   Region II  S.O.P.  for  Well  Sampling,  1984

Special care must be taken to prevent cross-contamination between sampling
points.  The well purging and sampling devices must be cleaned thoroughly
to ensure that contaminants from one well are not carried to another.

The purging equipment should be decontaminated with a water wash,  acetone
rinse, and a distilled water rinse.   Heavily contaminated purging equipment
should be cleaned with a hot water detergent wash followed by the rinsing
procedure.  Clean gloves should be worn by the sampling personnel.   In
addition, a clean plastic sheet should be placed adjacent to or around the
well in order to prevent surface soils from coming in contact with the
purging equipment and support ropes which in turn could introduce contamin-
ants to the well.  The effects of cross-contamination also can be minimized
by sampling the least contaminated well first and progressing to the more
contaminated ones, if such information is known.

6.5.2 Purging Procedures

If the recovery rate of the well is sufficient, the well should be com-
pletely evacuated at least five times (which is the volume determined from
Figure 6-1) and allowed to recover prior to sample withdrawal.  The amount
of water removed can be determined by collecting ic in a container of
known volume during the purging operation.  Complete evacuation may be not
possible from wells installed in high yield aquifers.  In these cases,
several factors must be considered in determining adequacy of evacuation
procedures.  These include the type of equipment used, (bailers or pumps);
the discharge rate; and the intake position in the well (above screen or
within screen).  Intake position will affect flow patterns in the well and
influence the determination of volumes to be evacuated to insure sampling
of fresh formation water.

Sampling personnel should record the following information:

1)   Type of evacuation equipment and types of materials of which it  is
     constructed, including delivery lines or lines used to lower equip-
     ment into the well.

2)   Whether wells are completely evacuated,  and,  if so,  the  number  of  times
     they were evacuated.

3)   Intake depth in wells not completely evacuated.

4)   Volumes evacuated from all wells.

5)   Methods used to determine volumes  evacuated.

6)   Procedures for collection, management and disposal of evacuated

7)   Whether or not individual wells have dedicated evacuation

8)   Decontamination and cleaning procedures for equipment used in
     more than one well.

9)   Physical properties of evacuated water
     o    Color
     o    Odor
     o    Turbidity
     o    Presence of oil or grease

A second approach to well purging is based upon the stabilization of temper-
ature, pH, Eh, and conductance.  Once successive measurements of these
indicator parameters agree within + 10 percent over three consecutive
purged volumes, uniform sampling conditions can be presumed to exist.  The
stabilization of pH is the most important indicator.  This method is appro-
priate for both ground-water monitoring wells and water supply wells.  It is
recommended that this method be applied to large water supply wells where
the well casing water volume can not be determined.  The water from
residential wells should be monitored and pumped to waste for ten to twenty
minutes before the sample  is collected.

6.5.3    Disposal of Purged Water

The water removed from a hazardous waste site monitoring well may contain
hazardous chemicals.  Therefore, the purged water may need to be contain-
erized (drummed) and should not be discharged directly on the ground at the
well site.  Determination of the nature of the purged water should be based
upon the site background review, the location of the well in relation to the
site, and screening of the purged water with a  HNU, OVA, or conductance
meter.  If these parameters suggest that the water may not need special
handling, the purged water should be disposed on site in the facility's
wastewater treatment system or leachate management system.  The disposal of
purged water also should be considered as part of the site safety plan.
(Section 4.7).

6.5.4    Procedures for Slow-Recharging Wells

There are currently several different approaches to purging and sampling
wells that recharge slowly.  These approaches include (1) evacuating the
well to dryness and allowing it to fully recharge before sampling; (2)
allowing the well to recharge after complete evacuation while taking several
small incremental samples during recharge, and  (3) evacuating the well until
the water level reaches the top of the well screen, then withdrawing samples
such that no additional drawdown occurs. At present, there  is very little
reliable data on which to choose one sampling method over another in "tight"
formations.  The preponderant approach seems to be complete evacuation
followed by collection of samples as soon as sufficient recharge has
6.6      Parameter-Specific Procedures

Depending on  the  type of analysis planned for each of the samples obtained
at a  facility,  there will be  different  requirements for sampling container!-
zation, and sample handling.  These requirements are covered briefly below.

6.6.1     Priority Pollutant Sampling Requirements

Special sampling and sample handling procedures must be instituted when
priority pollutant and/or trace contaminant samples  are being collected.
These procedures are:
     (1) All sampling equipment which comes into contact with the  water in
         the well must be cleaned in accordance with the procedures descri-
         bed in Section 8.0.
     (2) Sampling personnel must wear a clean pair of disposable gloves
         each time a new station is sampled.
     (3) If possible, background samples and possibly contaminated samples
         should be collected by different sampling teams.  If this is noc
         possible, background samples should be collected first and
         containerized separately.
     (4) If possible, one member of the sampling team should take  all field
         notes, etc. while the other member does all of the sampling.
     (5) Surface water samples should be collected before sediment samples
         at the same location.
     (6) Sufficient sample material should be obtained so that all of the
         priority pollutant parameters can be analyzed.  For water samples,
         this requires the collection of the following sample aliquots at
         each sampling location:

Sample Volume
Volatile Organics

Acid Extractables
Base/Neutral Extractables
Oil & Grease
IOC and Ammonia
40 ml in duplicate
1 gallon in duplicate

1 liter
1 liter
1 liter
1 liter
1 liter
1 liter
1 liter
40 ml vials,
Teflon septa


Glass or plastic
Glass only
Glass only
Glass or plastic
Glass or plastic
Glass or plastic
Soil and sediment samples to be tested for priority pollutants should be
collected as duplicate 1-kg samples (approximately one pint) in glass jars
with Teflon-lined lids.  All samples should be field-preserved and refri-
gerated for shipment, according to the requirements described in Section

6.6.2    EP Toxicity Sampling Requirements

According to the method requirements given in EPA SW-846 (U.S. EPA, 1984),
the analyses performed for the EP extraction procedure require the collec-
tion of at least 500 ml of sample.  Therefore, a 1-liter sample of ground-
water or surface water, or a 1-kg sample of soil should be collected to
ensure that there is adequate sample material.  These samples are not to be
preserved or refrigerated (unless it is known that refrigeration will not
affect the integrity of the sample).
6.6.3    BTU Sample Requirements

The  sampling requirements  for material  to be analyzed for BTU value are not
specified  in the usual water-quality or solid waste method references;

however, standard methods have been developed for this type of analysis as
it relates to fuels and other materials.  Perhaps the most applicable
methods for BTU analysis are those formulated by the American Society of
Testing and Materials (ASTM).   The applicable test methods are D2015 (Stan-
dard Test Method for Gross Calorific Value of Solid Fuel by the Adiabatic
Bomb Calorimeter) and D3286 (Standard Test Method for Gross Calorific Value
of Solid Fuel by the Isothermal-Jacket Bomb Calorimeter).  Both methods
require preparation of several small (1 gram) samples, but these samples
must be representative of the waste or contaminated material.  Representa-
tive sampling methods are discussed in ASTM D2234 (Standard Methods for
Collection of a Gross Sample of Coal) and in EPA SW-846 (as they apply to
waste materials.  For the purposes of the HWGW Task Force, collection of a
1-kg sample according to either method should be sufficient.
6.7      Well Sampling

Well sampling activities should concentrate on obtaining representative
samples of ground water that are properly preserved and handled according to
the requirements of the analytical methods that will be used.  Attention
should also be given to appropriate documentation of all activities.  The
procedures to be used are as follows:

     (1) Select the right equipment, depending on the construction and
         depth of the well, field conditions, and the analytes of interest.
     (2) Obtain samples from the well, avoiding undue aeration or
     (3) Transfer sample material to the appropriate containers and
         preserve samples according to standard methods.
     (4) Measure in-situ parameters (pH, dissolved oxygen, specific
         conductivity, and  temperature) at the time of sampling.
     (5) Clean all  sampling equipment before using at the next site.
     (6) Document all sampling activities, including sample  numbers.

6.7.1    Select Sampling Equipment

There are currently several different kinds of sampling equipment available
to obtain ground-water samples.  The more common types are described in
Table 6-2; since the selection of a certain kind of sampling device depends
on many factors (e.g. depth and diameter of the well,  parameters to be
analyzed, accessibility of power sources),  the choice  of equipment should be
made on a site-specific basis by consensus  of the Task Force.

Table 6-2:  General Types of Monitoring Well Sampling Equipment
            With Discussion of Advantages and Disadvantages
 Type Of
Equipment           Advantages
Bailer     Can be constructed in a wide
           variety of diameters

           Can be constructed from a
           wide variety of materials

           No external power source

           Extremely portable
           Low surface area to volume ratio,
           resulting in a very small amount
           of outgassing of volatile organics
           while sample is contained in bailer

           Easy to clean

           Readily available

                                  Time consuming sampling,  sometimes
                                  impractical to evacuate  casing
                                  properly before taking actual  samples

                                  Transfer of water to sample  bottle
                                  may result in aeration
Relatively portable

Readily available

Sampling is limited to situations
where water levels are within
about 20 ft. from ground surface
                                            Vacuum effect can cause the water
                                            to lose some dissolved gas and
                                            volatile organics

                                            In some cases, not constructed with
                                            materials compatible with sampling
                                            certain constiuents

Table 6-2 Continued
 Type Of
Relatively portable

Readily available

           Very suitable for well
Generally not considered appropriate
method for acquisition of water
samples for detailed chemical studies
owing to degassing

Regardless of the gas utilized
changes in CCK concentrations make
this method unsuitable for sampling
for pH sensitive parameters.

Aeration of water remaining in well
frequently make method unsuitable
for well evacuation

If air is used, oxygenation is
impossible to avoid unless elaborate
precautions are taken (only a very
small amount of oxygen is required
to cause a water sample to attain
saturation with respect to oxygen)
Wide range in diameters

Various materials are

Fairly portable

Depending upon size of pump
and pumping depths, relatively
large pumping rates are possible

Positive displacement minimizes
loss of volatiles during pumping

Readily available
Conventional units are unable to
pump sediment-laden water without
incurring damage to the pump
                                            Relatively expensive

Table 6-2 Continued
 Type Of
Can be constructed in dia-
meters as small as one inch

Can be constructed from a
wide variety of materials

Relatively portable

Fair range in pumping
rates are possible

Driving gas does not contact
water sample, eliminating
possible contamination or
gas stripping

Positive displacement minimizes
loss of volatiles
Gas source required

Large gas volumes and long cycles
are necessary for deep operation

Pumping rates are not as great as
with suction or jet pumps

Commercial units are relatively
expensive - pumps cost around
$300.00, while central gas unit
costs about $15.00
Isolates the sample from the
operating gas

Requires no electrical
power source

Operates continuously and
reliably over extended
periods of time

Uses compressed gas economically

Can be operated at pumping heads
in excess of 500m

Positive displacement minimizes
loss of volatiles
Relatively expensive; in excess of
$3000 for the continuously
operating unit

Particulate material may damage or
inactivate pump unless the suction
line is filtered

Low pumping rates

6.7.2    Sample Collection Procedures

The major consideration for sample withdrawal procedures is insuring that
samples are not altered or contaminated during the process.  Sampling equip-
ment must be constructed of materials compatible with actual or potential
contaminants.  These materials must neither leach nor absorb constituents of
interest.  Sampling equipment must be dedicated to individual wells  or be
capable of being fully disassembled and cleaned between wells.   Lines used
to lower equipment into the well and discharge piping must also be construc-
ted of materials compatible with possible contaminants.  Samples should be
collected a soon as possible after purging the well.

It is expected that, in general, submersible pumps will be used for purging
and well development purposes only, and that samples  will be collected
using bailers, peristaltic pumps, or in-place plumbing.  This will minimize
the possibility of contaminating the sample with material leaching from the
discharge tube/hose of the pump and/or from inadequate cleaning of the
internal pump parts-or the inside of the pump discharge tubing.  Therefore,
the procedure included here applies to Teflon or stainless-steel bailers.
Sampling should proceed as follows:

1)   Select new or cleaned Teflon bailer.

2)   Attach bailer to a line for lowering.  (Use either non-synthetic rope
     or stainless steel wire.)  The line should be of more than sufficient
     length to allow for water level drawdown while sampling.

3)   Lower bailer slowly until it contacts water surface.

4)   Allow bailer to sink and fill with a minimum of surface disturbance.

5)   Slowly raise bailer to surface.  Do not allow bailer  line to contact
     ground.  Place bailer line on protective  liner.

6)   Tip the bailer to allow slow discharge from top to  flow gently  down
     the side of the sample bottle with minimum entry  turbulence.

7)   Repeat as needed to acquire sufficient sample volume.

Reasonable care should be taken in transferring water from the bailer to
sample containers so that the sample is not aerated.   This is especially
important for volatiles, but also is a concern for metal samples to avoid

After each sample has been collected, it should be preserved in accordance
with the requirements given in "Methods for Chemical  Analysis of Water and
Wastes" (U.S. EPA, 1983).  Samples for organics analysis should not have
preservative added.  All sample bottles should be labeled properly (see
Section 8.0) and placed in an appropriate carrying container maintained at
4°C throughout the sampling and transportation period.  Upon completion of
sampling,  bailers should be placed in plastic bags for transportation to the
laboratory.  Each well must be securely capped.  Sampling equipment should
be decontaminated by cleaning with detergent, rinsing with distilled water,
and rinsing with methylene chloride, acetone, or hexane.  It is recommended
to use a separate bailer for each well to avoid cross-contamination.  If
this is not possible, field decontamination should be performed prior to
each use.   A new support line should be'used for each well sample and
decontaminated or disposed in an acceptable manner after each use.

6.7.3    In-Situ Measurements

At the time each well is sampled, four in-situ parameters should be mea-
sured: temperature, pH, dissolved oxygen, and specific conductance.  A
separate sample can be withdrawn from the well into a beaker for these
measurements; alternatively, direct-reading  instruments may be used if  the
probe and cable assembly is long enough to reach to the depth of the well
screen.  If direct-reading instruments are used in the well casing, the
probes and cable should be cleane'd before use  in the same manner as the
other sampling equipment.  All  instruments should be calibrated  (with refe-
rence solutions or internal standards) prior  to making  the reading; calibra-
tion  information should be recorded  along with the other sampling data  in
the field notebook.

6.8      Sampling Ground-water Seeps (Surface Water)

6.8.1    Location Selection

Sampling locations for ground-water seepage should be  selected on the  basis
of their probability for showing contaminants migrating from a site.   Prior
to any sampling, surface water drainage at and around  the site should  be
characterized using all available background information,  including topogra-
phic maps and aerial photography.

In general, sampling locations may include rivers, brooks,  or streams  run-
ning through or adjacent to a site.  These would include bodies of water
receiving ground-water discharge and/or leachate from  a site.  In areas where
the ground surface slopes steeply away from buried wastes,  ground-water
seepage or leachate may emerge from the ground, forming a damp or wet  area
or a small stream.  Samples taken from such streams may have to be treated
as medium or high concentration samples, depending upon a field evaluation.
Exposed soil should be examined for areas of discoloration.  Areas of
excessive dead vegetation are also good indicators of  leachate emergence.

The number of sampling locations selected is dependent on a variety of
factors including the size of a site, the accessibility and magnitude  of the
discharge, and the availability of analytical support.  Sampling should be
performed at a minimum of two locations.

6.8.2    Sampling Techniques and Equipment

Ground-water seepage sampling at hazardous waste sites involves a number of
different problems and concerns.  The major criteria used in determining how
and where to sample surface leachate streams  include obtaining a representa-
tive sample, safety of the personnel involved  in  sampling, and using a simple
method which is applicable at various sites.   Due  to  the nature of hazardous
waste sites, no one sampling method  can be assured to be reliable  for
obtaining a representative sample  at each  site.   Therefore,  the judgment and
discretion of the project leader  is  required  to determine  the most suitable

sampling locations and techniques.

Due to the unknown chemical and toxic nature of surface  leachate streams,  it
should be required that all sampling at these locations  be performed by a
minimum of two persons using at least Level B protection (SCBA,  chemical
protection suit, boots and gloves).

Two types of sampling techniques are generally recognized for leachate
streams, grab sampling and composite sampling.Grab samples are taken over  a
short period of time (e.g., less than 15 minutes)  and are used to
characterize the seep at a given time.  Weather conditions and flow volume
of the leachate seep should be recorded at the time of sampling.  Composite
samples are a combination of individual samples taken over a prolonged
period of time at the same sampling point.  This technique is generally not
used in sampling surface leachate streams; however, a modification of this
method may be used at sites with numerous leachate outbreaks.  This modifi-
cation involves combining samples taken at different leachate locations.
This provides a location composite as opposed to a time composite and may
provide useful data on the average concentration of contaminants or the
presence or absence of hazardous substances in the area.

The best method for manual sample collection is to use the actual sample
container which will be used to transport the sample to the laboratory.
This eliminates the possibility of contaminating the sample with an inter-
mediate collection container.  The actual sample container must always be
used for collecting oil and grease and bacterial samples.

A separate collection container can be used to collect the sample, from
which the sample can be redistributed to other containers.  If this is done,
the container used to collect the sample must be cleaned properly
and must be made of a material that meets the requirements of the para- .
meter(s) being  investigated.  Separate containers should be used at each
sample site to  avoid cross contamination between sampling sites.

Sample boCCles should be labeled prior Co actual sampling with at  least  the
following information:  sample ID number, date,  site name or case  number,
sample location and analysis to be performed by  the  laboratory (see  Section
8.5.3).  All labeling should be done with a waterproof marker to prevent
label information from being washed off during and after sampling.

If the ground-water seep cannot be physically reached by the sampling person-
nel, an intermediate collection container may be used.   The  sample is then
collected by lowering a properly cleaned Teflon, plastic, glass or stainless
steel collection vessel (type of collection vessel used depends on the
parameter being investigated) into the material  to be sampled. Samples
should be collected manually by tipping the collection container  into the
seep or stream so the mouth of the container faces upstream.  The  container
should be rinsed out via this procedure at least twice before the  sample is
collected (except if preservatives are present in the sampling container or
for certain analyses such as oil and grease and  bacteria).

Care should be taken to avoid collecting leaves, stones, and other debris
into the sample container.  The sample bottle should be filled with about
10% ullage (empty space) remaining for shipping  purposes.  In some
instances, a wide-mouth quart jar will have to be used to collect the
sample.  This sample should then be transferred  to the appropriate sample
bottles for analysis.  The quart jar used for sampling should be  disposed

If the leachate stream flow is low, a shovel may be  used to dig a small hole
at the sampling point.  The hole is allowed to fill  with leachate and
sufficient volume is then obtained from  the hole.  The shovel should be
decontaminated before use at another sample location.  Decontamination of
all sampling equipment and sample containers should follow the procedures
outlined in Section 8.3.3.

After the samples have been collected, the samples should be  preserved as
necessary and placed on ice  (4°C) for transport to the laboratory.

6.9      Soil Sampling

6.9.1    Location Selection

Areas selected for soil sampling should be located strategically in order  to
collect a representative fraction of the soils with the minimum number  of
samples and effort.  A surface inspection of the subject area should be made
to locate pertinent features (e.g.,  rock outcrops,  drainage patterns, sur-
face runoff, ponds, lakes, vet areas, seeps, springs,  permanent structures,
fill areas, erosional areas, depositional areas, etc.) and to evaluate  the
relationship between these features and potential sources of pollution. The
locations of sediment depositional areas are good indicators of surface
runoff direction.  If direction of surface runoff or drainage is difficult
to detect, observation of new deposition or sediment movement following a
rain may prove helpful in establishing this direction.  The spreading or
fanning out of the sediment body will indicate direction of flow.

In most instances, the HWGW Task Force's investigation of a site will be
similar to a reconnaissance or screening type study.  Sampling of soil  in
these instances will generally be confined to surface soils or shallow
coring using hand equipment such as shovels, post hole diggers, or hand
augers.  For screening purposes, surface soil/sediment sampling should be
conducted in depositional areas on the periphery of the study area, primar-
ily in the downstream or downgradient portion of the area of interest;
however, an upgradient sample is often valuable as a control.  Sampling at
depositional areas tends to bias the sampling toward high concentrations;
this is a valuable screening tool but should not be construed as represent-
ative of the area conditions.

6.9.2    Sampling Techniques and Equipment

Sampling of undisturbed soils may be done by both hand or power equipment.
Hand equipment such as spoons, scoops, shovels, hand  augers, and small
diameter push tubes are available and may be used for sampling at shallow
depths.  However, hand equipment is  limited even at shallow depths when the
soils are difficult to penetrate.  Power equipment  such as augers may  be

used for sampling at shallow depths when hand coring equipment cannot be

Shelby tubes or thin wall push tubes can be used with both power and hand
equipment to sample undisturbed soils.   Stainless steel construction is
recommended for most types of sampling.   Soils can be extruded from the
tubes for logging and selective sampling or sealed and sent directly to  the
laboratory in the tubes.

Surface soil samples should be collected with a spoon or scoop.   Grass,
leaves, or other debris should be scraped away prior to sampling.  Shallow
depth samples may be collected by digging a hole with a shovel or post hole
digger, then removing all the loose soil and collecting a sample at the
desired depth using a sampling spoon.  For deeper sampling using hand equip-
ment, a larger diameter auger is used until the desired depth is reached.  A
small diameter auger or Shelby tube is then used to collect the sample.   The
sample is extruded, the portions that are disturbed and/or contaminated are
discarded, and the remainder is placed in an aluminum or stainless steel pan
for mixing.  These procedures shall be repeated until the desired
amount/number of samples are collected.   If an undisturbed sample is re-
quired, the Shelby tube and sample may be shipped intact to the laboratory
for analyses.

The split spoon sampler may be used for sampling at greater depths.  Because
of its weight, the split spoon sampler is generally used with power equip-
ment.  A hollow stem auger is used to advance the hole to the desired depth.
The split spoon is added to the correct length of drill rod and forced  into
the undisturbed soil by means of a 140-pound weight or hammer.  The split
spoon is retrieved from the hole and opened to reveal the sample.  The  top
two or three inches of the sample normally will be disturbed and should be
discarded.  The undisturbed portion should be placed in an aluminum or
stainless steel pan by means of a clean stainless steel spoon or spatula.
The procedure is repeated until the desired amount for the sample is collec-
ted.  The sample should then be mixed thoroughly and split into  the
appropriate  sample containers.

6.10     Lagoon Sampling

Surface impoundments used for the storage or evaporation of hazardous wastes
vary greatly in size.  It is difficult to collect representative samples
from large impoundments without incurring considerable expense and assuming
excessive risk.  Any samples desired beyond about 10 feet from the bank will
require the use of a boat or crane, and therefore generally will not be
feasible to collect.

Lakes, ponds, and impoundments have a much greater tendency to stratify than
rivers and streams; the relative lack of mixing requires that more samples
be obtained.  The number of water sampling sites on a lake, pond, or
impoundment will vary with the size and shape of the basin.  In ponds and
small impoundments, a single vertical composite at the deepest point may be
sufficient.  In naturally-formed ponds, the deepest point is usually near
the center; in impoundments, the deepest point is usually near the dam.

In larger impoundments, several vertical subsamples should be composited to
form a single sample.  These samples are often taken along a transect or
grid.  Again, the number of vertical subsamples and the depths at which
subsamples are taken are usually at the discretion of the sampling crew.  In
some cases, it may be of interest to form separate composites of deep and
shallow zones, but normally a composite would be taken, consisting of seve-
ral vertical subsamples collected at various depths.

To sample, the surface area of the impoundment is divided into an imaginary
grid.  The number  of grid sections is determined by the desired number of
samples to be collected which, when combined should give a representative
sample of the lagoon contents.  Three samples are collected from each grid,
if possible:  one sample at or near the surface, one sample at mid-depth and
one., sample at the bottom.

Many different kinds of sampling devices have been developed to obtain
samples from a surface impoundment.  The sampling team,  in consensus with
the project leader,  should select  the equipment which best suits the needs
of a particular sampling situation.  Applicable equipment  includes:

o  Pond Sampler

   The pond sampler consists of an adjustable clamp attached to the
   end of a two or three piece telescoping aluminum tube that serves
   as the handle.  This device can be used to collect samples as far
   as 10 feet from the bank.  Note that the sampling methods listed
   in Appendix 1 of 40 CFR 261 for liquid wastes in impoundments
   require only this type of device for representative samples.

o  Rod and Clamp

   This device consists of six foot sections of aluminum rod which
   can be taped together to a desired length.  A chain clamp is
   secured on one end and holds the sample container.  This device
   is best used to obtain surface samples although subsurface samples
   can be obtained by manipulating the rods and clamp location.

o  Sub-Surface Grab Sampler

   This device consists of a long aluminum tube with two adjustable
   stainless steel clamps which hold a sample bottle.  A rod attached
   to the tube removes and replaces the sample bottle cap while the
   bottle is submerged.  Samples are obtained by placing a capped
   bottle in clamps, submerging the sampler in liquid and turning
   the handle of the rod to remove and replace cap.

o  Thief Sampler

   The thief sampler is applicable for obtaining bottom samples.
   The thief is designed so that a sample can be obtained within
   13 mm of the bottom of the  impoundment.  There are two basic types of
   thief.  One type is lowered into the impoundment with the valves open
   to permit the contents to flush through it.  When  the thief  strikes
   the bottom of the impoundment, the valves close, trapping a  bottom
   sample.  The other type has a projecting  stem on  the valve  rod which
   opens the valves when the stem strikes the bottom  of the  impoundment.

   The sample enters through the bottom valve and air is released simulta-
   neously through the top.   The valves snap shut when the thief is with-

o  Weighted Bottle Sampler

   This sampler consists of a bottle,  usually glass,  a weight or
   sinker, a bottle stopper, and a line that is used to open the
   bottle and lower and raise the sampler.   The weighted bottle
   sampler can be used to sample liquids in a pond,  lake or
   impoundment.  It cannot,  however,  be used to collect liquids
   that are incompatible or react chemically with the weight sinker
   and line.

   Although there are a few variations of this sampler, the sampling
   procedure is the same.  The sampler is lowered to the proper depth.
   The stopper is then pulled out with a sharp jerk of the chain or twine
   attached to the stopper.   The bottle is allowed to fill completely,  as
   evidenced by the cessation of air bubbles.  When full, the sampler is


7.L       Potential Hazards

During the facility inspection, the Hazardous Waste Ground-water Task Force
(HWGWTF) may encounter a number of potential hazards.   These hazards may be
present as contaminants in the physical environment;  in the soil,  surface
water, or as gases or vapors in the ambient air.   Other hazards may include
the effects of temperature, presence of machinery or heavy equipment,  and
associated noise levels.  It is important to anticipate as many unsafe or
potentially hazardous conditions or practices as  possible through adequate
planning and training.

Establishment of rules or procedures, and assignment of responsibilities is
paramount in reducing the potential risks involved during monitoring activi-
ties at these sites.  It also allows for prompt corrective actions in the
event of a dangerous occurrence or accident.  It must be emphasized that
individuals should maintain a high level of safety consciousness at all
times through use of personal common sense, good judgment, and adequate
technical training.  The following discussion represents potential hazards
that may be encountered during sampling assignments at the monitoring sites.
This list is not meant to be all-inclusive but does provide a general
compilation of the potential hazards involved.

7.1.1     Toxic Substances

Among the potential hazards that may be encountered at the monitoring site
are toxic or poisonous substances.  The Federal Hazardous Substances Label-
ing Act broadly defines "toxic" as any substance, other than a radioactive
substance, having the capacity to produce personal injury or illness to man
through ingestion,  inhalation, or absorption  through the body surface.  The
Toxic Substances Control Act currently maintains a Master File containing
over 2000 toxic substances  subject to regulation.

 7.1.2      Explosive Materials

 Explosive  gases  are often  formed  through biodegradation processes of
 underlying material.   These  gases may concentrate to dangerous levels in low
 areas  or  in sheltered areas  not subject to wind dispersal and mixing.  Any
 spark  or  flame,  thermal  or mechanical shock may cause detonation of highly
 reactive  material, or may  cause an explosive decomposition or reaction.  Gas
 analysis  meter readings  to determine the explosive limit are normally taken
 at  suspect locations.  Readings greater than 20% of the Lower Explosive
 Limit  (LED  generally warrant  a survey of the entire area, obtaining ground,
 waist,  and head  level readings.   The sampling team should evacuate the area
 immediately at any LEL reading approaching or greater than 50% and contact
 the fire  department.   Any  sampling equipment used at the site should be
 spark-free equipment.

 7.1.3      Corrosive Materials

 Corrosive  materials may  be present at the monitoring site in the form of
 solids, liquids,  or gases.  This  material, when  in contact with living
 tissue, will cause destruction of tissue by chemical reaction.  These same
 materials  may damage  clothing  as  well as protective garments worn by the
 individual.   Acids, bases, peroxides, and other  strong oxiders which may be
 present in waste materials or  environmental samples exhibit varying  degrees
 of  corrosivity.

 7.1.4      Flammable Materials

 Flammable materials are  substances having a  flash point  above  -6.7°C (20°F)
 and below 26.7°C (80°F)  (below 37.8°C  (100°F)  for liquids).  Flammable
.vapors in ambient air may explode or ignite  if  the vapor density of  the
 substance becomes high enough.  Vapors  may  include gasoline, and other
 petroleum based products,  solvents,  and other hydrocarbons,  methane  and
 natural gases,  carbon monoxide,  and  hydrogen sulfide.   Confined areas  lack-
 ing natural ventilation should be considered oxygen-deficient  and  possibly
 contaminated by hazardous gases  and  vapors  until proven safe by air  monitor-

7.1.5     HeaC Or Cold Stress

Frequently overlooked as a potential hazard is the effect of heat or cold
on the individual during sampling activities.   Protective clothing worn
during even warm weather sampling can cause accelerated fatigue,  dizziness,
and water loss.  During cold weather, additional undergarments should be
worn to retain body heat.  Each individual should adequately plan their
activities bearing in mind the physical conditions of the site as well as
their own personal limitations.

7.1.6     Oxygen-Deficient Atmosphere

Oxygen-deficient environments will generally be associated with confined
spaces or areas lacking adequate ventilation.   Oxygen levels should be
measured under these circumstances to ensure that the concentrations present
are at least 19.5%.  In situations where levels are below 19.5% oxygen,
forced ventilation into the confined area may be necessary to purge the area
of stagnant anaerobic gases and replenish acceptable oxygen concentrations.

7.1.7     Cancer-Causing Agents

There are numerous substances or agents which may be found in environmental
samples or onsite waste materials that are carcinogenic, or capable of
producing cancer.  Additionally, other substances may be present that are
mutagenic or teratogenic.  These substances, even present in very low con-
centrations, are a subject of concern.  Exposure to these agents or sub-
stances is reduced significantly by  donning appropriate field gear.

7.1.8     Irritants

Irritants are  substances which are not corrosive and in the immediate,
prolonged, or  repeated exposure' with living tissue, will induce  a local
inflammatory response.   Irritants apply to both skin and eyes.

7.1.9     Excessive Noise

High noise levels may be present at the monitoring site from heavy equipment
and machinery operations.  High noise levels could permanently impair normal
hearing unless proper protective headwear is worn.  Monitoring personnel
should not venture into high noise level environments without proper protec-

7.1.10    Biologically Active Materials

Certain materials or biohazardous agents could be present in some instances
that are capable of producing illness or disease through an infectous pro-
cess or by production of toxins upon exposure.  These- etiologic agents are
generally not persistent at high levels in the soil/water environment;
however, monitoring sites located in areas containing sanitary wastes must
be presumed as having these agents present.  Therefore appropriate steps
should be taken in these instances to limit exposure.

7.1.11    Radioactive Materials

Unlike other hazards, radiation does not require direct contact to cause any
harm.  Mere proximity to a strong radioactive source may cause physiological
damage.  With the increasing use of radioisotopes in medicine, research, and
diagnostic equipment, comes a greater probability in encountering this

Natural or background radiation is typically up to 0.2 milli-Roentgens/hour
(mR/hr).  Monitoring sites at which a radiation hazard is suspected should
be initially surveyed using a scintillation counter  to verify radiation
levels.  Levels up to 10 mR/hr can be tolerated if the period of exposure  is
limited to the time to  conduct sampling only.  At levels higher than  10
mR/hr,  the site should  be evacuated and a  health  physicist contacted.

7.1.12    Accidents Resulting in  Physical  Harm

Other hazards that may  be encountered during  monitoring  activities may

include machinery,  heavy equipment operations,and other traffic near or on
the site.  Presence of wreckage or litter may tear or snag protective clo-
thing.  Common sense, alertness, and adherence to all company safety rules
and regulations is mandatory.
7.2       Routes of Exposure

The routes of exposure include:

     o    Inhalation - breathing contaminated air
     o    Dermal exposure - skin contact with contaminated material
     o    Dermal absorption - skin contact and absorption of
          contaminated material
     o    Ingestion - eating or drinking of contaminated material

7.2.1     Inhalation

The most frequent source of general occupational poisoning and a common
route of exposure during monitoring situations is inhalation of hazardous
materials via the respiratory system.  It should be emphasized that even by
breathing relatively low concentrations of noxious gases, fumes, particu-
lates, and aerosols, toxic dosages can be inhaled in short periods of time.

Depending on the absorption characteristics of the substance within the
lungs and the physiological response, the impact may be so sudden and trau-
matic that the worker maybe rendered totally incapacitated and unable to
provide for his or her own safety.  Some individuals may exhibit extreme
sensitivity to certain contaminants and elicit anaphylactic shock.  Treat-
ment in this extreme situation must be immediate.

7.2.2     Dermal Exposure

Direct dermal irritation or sensitization represents another exposure route
that may occur.  Caustics and  acids represent the most common contact skin
irritants.  Severe chemical burns may increase one's susceptibility to

secondary infections.  Field personnel should also be aware of sunburn
hazards resulting from excessive exposure to.UV radiation.

Some chemicals, upon skin contact exposure,  may bring about sensitization.
Subsequent exposure to the same chemical may then cause contact dermatitis
(skin rashes).   Increased vascular permeability from allergic responses  may
result in localized edema, which in some cases may impair breathing,  swal-
lowing, or vision.

7.2.3     Dermal Absorption

The skin  barrier, normally effective in protecting underlying tissues from
foreign substances, can be penetrated by absorption processes or through
open cuts or wounds.  Some materials not normally able to penetrate the
skin may be carried by organic solvents.  Organic solvents gain entrance
into the body by removing the protective lipids and sweat that covers the
skin and then entering through hair follicles and sebaceous glands.

7.2.4     Ingestion

Poisoning through gastrointestinal absorption of ingested material is a far
less common form of exposure than that of inhalation or dermal contact.
However, exposure by this route can occur through ignorance or lack of
awareness of transmission processes.  Workers may inadvertently contaminate
temporary drinking water supplies, food, or cigarettes by not first washing
thoroughly.  Strict adherence to rules prohibiting eating, drinking or smo-
king at any location onsite and offsite only after decontamination should be
7.3       Exposure Prevention Protocol

The health and safety protocol developed for the HWGW Task Force centers on
exposure prevention, which  is accomplished  through  two objectives:
1) pre-survey identification of hazards, medical surveillance, training, and
equipment selection, and  2) onsite  supervision of safety practices, precau-

tionary testing,and equipment usage.   The items in the protocol,  which are
discussed below, include the following steps:

Pre-Survey Activities

     1)   Project team leader designates one or more persons to administer
          this protocol and to act as field safety supervisor.

     2)   Potential hazards associated with the site are identified from
          background information and site data.  Descriptions of possible
          hazards, along with recommendations for their minimization,  are
          compiled and distributed to all team members.

     3)   Applicable team personnel undergo medical surveillance testing.
          Testing is followed up annually (see Section 7.3.1).

     4)   Applicable team members are issued appropriate respiratory
          protection equipment.  Team members are trained in its use
          and maintenance.  Masks are fit-tested (see section 7.3.2).

     5)   A site health and safety plan is completed, which specifically
          describes the known or suspected hazards onsite; the identity
          of all safety supervisors who will be onsite; the locations,
          phone numbers, and contacts of local emergency services
          (hospital, fire department, etc.); and the protective clothing,
          equipment, and testing instruments that will be needed onsite
          (see Section 7.3.3).

Onsite Activities

     1)   Field safety supervisor designates "safe"  area onsite and tests
          atmospheric conditions to verify level of  protection needs  prior
          to personnel entry  to a suspect area  (see  Section 7.4).  If
          conditions warrant,  field safety supervisor  assigns  appropriate
          level of protection  requirements  (see  Section 7.5).
     2)   Field safety supervisor maintains visual  or  radio contact with

          sampling personnel,  who are assigned as a (minimum)  two-man team.

     3)   Field safety supervisor designates decontamination area and
          ensures compliance with decontamination procedures following
          sampling activities (see Section 7.7).

7.3.1     Medical Surveillance Program

To ensure the health and well-being of all personnel involved in groundwater
monitoring at hazardous waste sites, a program of medical surveillance should
be followed.  The program should consist of three main components:

     1)   Comprehensive health examination

     2)   Annual check-ups

     3)   Tracking and evaluation

Individuals directly involved in monitoring activities should have a com-
plete comprehensive health examination on file.  This is important not only
in verifying one's physical and menta-L fitness, but also in establishing
control background levels upon which subsequent test results maybe compared.
It is highly desirable that persons in the monitoring program be free of any
residual effects of previous hazardous materials exposure.

Examinations should then be repeated annually in the same manner as long as
the individual is involved with the monitoring tasks at these sites.  If the
sites monitored are known to contain higher than normal background radiation
(70.2 mR/hr), then the annual check-ups should include dosimetry (whole body

Tracking and evaluation of medical  files  should be  an assigned responsi-
bility  to the project safety officer.  Files should be reviewed and updated
as needed.  Any test results extending beyond normal limits should initiate
a corrective action that minimally  requires a retest of the given parameter.
If comparable results are obtained,  then  appropriate health officials should

be contacted to evaluate these results to determine if exposure has occurred.

7.3.2     Respiratory Protection Program

The protection program centers on the selection,  use,  and limitations of
respiratory equipment and chemical protective clothing.   In addition, the
incorporation of an organized program in training may be the most important
element in exposure prevention.  The protection program should require an
understanding and working knowledge of the following:

     1)   OSHA requirements
     2)   General requirements governing equipment
     3)   Fit testing procedures
     4)   Field testing procedures
     5)   Care and inspection of equipment
     6)   Record keeping
     7)   Training program

o    OSHA Requirements

The respiratory protection program should be designed to fulfill the requi-
rements of the Occupational Safety and Health Administrations  (OSHA) respi-
ratory protection standard 1910-134.  OSHA regulations call for the  estab-
lishment of authority and assignment of responsibilities and requirements
involving respiratory protection.  Procedures shall be developed in  the
selection of protection equipment based on the level of hazard present at
the site.

o    General Requirements Governing Equipment

General requirements include  the assignment  and  issuance of. respiratory
devices and chemical protective clothing by  a Safety Officer.  Only  indivi-
duals who have completed training  in  the use of  the equipment  and  are medi-
cally and physically capable  of wearing  the  gear safely will be allowed  to
don the equipment.  Figure 7.1 presents  an example user certification form.

     on	-
has rtctived hands-on training In the cart,  use.  and  limitatloo*  of  the
following respiratory protection devlce(s).
            fullfact Air Purifying Respirator
            Half-fact Kir Purifying Respirator
                                   has also been instructed and trained
in the proper fit-test Mthods for the above Barked respiratory devlce(s)
     On	i  	•  	           	
has satisfactorily passed the irritant saoke test for the following
respiratory protection device(s).
              Type of
Manufacturer  Device	  Unit Ho.     User	  Instructor
     At this examination on                     . 	, no contra-
indictions to the use of the above form(s) of respiratory devices have
been Identified.

                    (Physician's Signature)	
              Figure  7.1  User Training, Medical Clearance

o    Fit Testing Procedures

Procedures describing fit testing should be detailed to assure the  adequacy
of the seal between the face and the facepiece.   Failure to pass  a  fit  test
indicates an inadequate seal.   Those not passing a fit test will  be prohi-
bited from entering the site until the situation can be corrected.   Use of
jellies or creams to achieve a seal will not be  allowed.   The  fit testing
should employ the following tests:

          Qualitative Fit Tests
          Irritant Smoke Test
          Odorous Vapor Test

o    Field Testing Procedures

A positive and negative pressure sealing test will be performed in  the  field
every time a respirator is donned.

o    Care and Inspection of Equipment

Not only is the proper care and inspection of protective equipment  necessary
in exposure prevention but this equipment is expensive.  Proper handling,
cleaning, and storing of the gear will promote its longevity.   Protective
equipment care should include protocols for:

          Cleaning at site
          Washing and disinfection
          Inspecting during cleaning

Inspection guidelines should be established for the frequency and routines
to be followed for all protective equipment.  Inspections should include all
components or assemblies comprising the protective gear.  Minor defects may
be repaired or adjusted while major defects should be brought to the atten-

tion of the field supervisor and safety officer.   Defective devices should
be visibly marked or tagged as such with instructions not to use.

o    Record Keeping

All protective equipment records and documents will be maintained by the
Safety Officer.  Inspection and maintenance forms filled out by monitoring
personnel will be promptly returned to the Safety Officer.   An example of a
maintenance log form is shown in Figure 7.2.   The log also  serves as a
respirator assignment sheet and fit test verification.

o    Training Program

Training in the selection, use, and limitations of respiratory equipment and
chemical protective clothing are the most important elements in exposure
prevention.  Specifically, training should include:

          Concepts of proper fitting
          Donning and doffing procedures
          Clothing/gear inspection
          Maintenance and testing of respiratory devices and equipment
          Nature and scope of hazards  involved at site
          Corrective actions to be taken in the event that clothing
          or respiratory devices fail  or become impaired
          Contents of this protection  program
7.3.3     Field Safety Practices Enforcement

Enforcement of safety practices in  the field is established by:

     o    Defining a chain of command
     o    Assignment of duties and  responsibilities
     o    Adherence to a  formalized health and safety plan for each site





——  ON
                  UNIT NUMBER .

                 UNIT NUMBER





                            RETURN TO SAFETY OFFICER
                   Figure  7.2    Unit Issue Maintenance  Log

The establishment of a series of positions in an order of authority will
promote better vertical communication that is critically important in main-
taining a high level of safety during field work.   The assignment of speci-
fic duties and responsibilities ensures that all safety considerations are
employed.  Recommended responsibilities for the monitoring personnel should
include the following:

o    Safety Officer Responsibilities

          Hazard assessment to determine the type and concentration of air

          Respirator selection

          Workers training in the proper use of respirators

          Respirator fitting

          Maintenance and cleaning procedures

          Purchasing procedures and inventory control, including
          maintaining spare component parts for respirators

          Medical surveillance of employees using respiratory
          protection devices

          Documentation:  recordkeeping

o    Field Supervisor Responsibilities

          Review scope of hazard and respiratory protection require-
          ments with  Safety Officer before  start of job

          Review scope of hazard and respiratory protection require-
          ments with  crew before start  of job

          Monitoring of workplace

          Conduct respirator fit-tests

          Ensure that those individuals in their charge are complying
          with rules governing the use of respiratory protective  devices

o    Employee Responsibilities

          Comply with all safety procedures and regulations governing
          the use of respiratory protective devices

          Ensure that the respiratory device used fits properly

          Maintain, inspect, and clean respiratory devices according
          to manufacturers' direction and this program

          Inform supervisor of actual or potentially hazardous conditions

A formalized health and safety plan developed for each site visit
documents the level of safety to be employed.  Recommended contents of a
health and safety plan for site visits are presented as Appendix D.

7.4       Determination of Approach Level of Protection

When field activities are conducted where atmospheric contamination or any
other type of hazard is known or suspected to exist, personal protective
equipment must be worn.  Prior to  the  start of any field activities, the
field supervisor must designate  a  level of protection for  that job.  This
designation will inform the field  crew what hazards may be expected  in the
field and what personal protective equipment must be worn.  The  field super-
visor must use direct reading instruments  (when  available), such as  the
ENMET tritector, the Foxboro organic vapor analyzer,  the HNU  total organic
analyzer, or color  detection  tubes whenever hazardous  atmospheric  contami-
nants are known or  likely  to be  present.  This  information will  help desig-

nate the level of respiratory protection required.

7.4.1     Historical Data As An Indicator

All pertinent information sources should be consulted prior to the investi-
gation to gain preliminary data.  These include site history from state or
local files, on processes and operations, waste handling activities,  mate-
rial data sheets identifying contaminants and concentrations.   Reference
sources should be consulted to identify contaminant properties and classifi-
cations.   These include Department of Transportation (DOT) identification
number and Chemical Abstracts Service Registry Numbers (CAS) information,
the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS), or other
available data sources.

7.4.2     Pre-Entry Surveillance Criteria

Direct reading instruments such as the Foxboro organic vapor analyzer, HNU
total organic gas analyzer, and the EMMET tritector must be used to provide
a complete characterization of the airborne contaminants prior to conducting
field activities. 'The work area should be scanned while wearing the highest
level of protective equipment.  A lower level of protection may be desig-
nated based on the results of the initial scan.

All field crew members must be assigned to work in pairs.  In addition, two-
way radios should be used to maintain contact with a person in a "safe" area
who is equipped with the suitable respiratory and skin protection.  This
person is on standby to assist the two-man field team in the case of an

The field supervisor must be aware of the possibility of physical  stress  to
the field crew due to extremes of temperature.  Of special concern is  the
possibility of heat stress due  to working in a hot environment while wearing
personal protective equipment.

A  "clean" area should be established where the field  activities  can be
controlled.  Workers leaving the contaminated area must  go  through a  decon-

tamination process where the clothing,  tools and safety equipment are
cleaned.   This will prevent the migration of hazardous  materials  from  poten-
tially contaminated areas.

7.4.3     Monitoring During Work Performance

If monitoring activities are prolonged,  the air monitoring should be per-
formed periodically throughout the day to verify the adequacy of  the safety
equipment chosen.
7.5       Levels of Safety Protection

The following discussion outlines five levels of protection,  some of the
equipment required for each level of protection, and the rationale for
choosing each level.  When there is insufficient information on the type of
hazardous contaminants or their concentrations, the field supervisor will
assign Level B personal protective equipment until the pollutant concentra-
tions and health effects are known.  A complete equipment listing for each
level of protection is presented in Attachment 1.

Levels A and B represent the highest levels of protection, though level A
carries a higher degree of skin and eye protection.  Both require full
respiratory protection using a positive-pressure (pressure demand) self
contained breathing apparatus (SCBA) that is MSHA/NIOSH approved.  Both
require chemical resistant gloves and boots, and two-way radios.

Levels C and 0 represent lower levels of protection and are used when the
type of airborne contaminant is known and incorporate use of air purifying
respirators (MSHA/NIOSH approved).  Level D assumes unlikely skin and eye
exposure.  Periodic air monitoring should be performed to detect increased
contaminant levels, in which case upgrading to level B may be necessary.

Level E represents minimal protection and is designed for use when only skin
and eye protection is needed and airborne contamination is unlikely.

7.6       Emergency Procedures

At sites where the possibility of contamination or the severity of the
hazard warrants, emergency procedures should be prepared.   Emergency first
aid equipment and medical personnel, or someone who knows  how to provide
emergency first aid, should always be present and readily  available at the
work site.  The phone numbers of the local emergency services and the near-
est hospital should also be readily available (e.g., in the site health and
safety plan prepared beforehand).

When wearing a SCBA respirator in an atmosphere that is immediately danger-
ous to life or health, at least one additional person must be present with a
similar respirator to aid in case of an emergency.  Visual or verbal contact
from a safe area must be maintained at all times.

If a field worker knows or suspects that they have been contaminated with a
hazardous substance, they must immediately inform the field supervisor.  All
injuries must also be immediately reported to the field supervisor.  An
exposure report form is presented as Figure 7.3.

                              EXPOSURE REPORT
Job Site Location
Time Of Exposure_
Substance(s) Exposed To_
Was Substance In:  Air
Protective Equipment Used_
Cause of Exposure^
Area of Body Exposed_
Action Taken To Decontaminate
List Changes To Prevent  Exposure_
cc:  Employee
     Safety Officer
                       Figure  7.3   Exposure  Report  Form

7.7       Personnel Decontamination and Equipment Disposal

Following sampling, appropriate measures should be undertaken to decontami-
nate samples, equipment, and protective clothing.   For each two-man sampling
team, the "clean" man is required to organize and set up the decontamination
area.  Everything leaving the monitoring area should be presumed as poten-
tially contaminated, unless the level of hazard is shown to be within safe

The extent of personnel decontamination required at the site is dependent on
the following factors:

     o    Type of contaminant
     o    Amount of contaminant present
     o    Level of protection used
     o    Degree or duration of contact
     o    Location of contaminant
     o    Reason for leaving site

In general, the procedures involved in decontamination employ steps in
washing with special detergent solutions, rinsing with copious amounts of
water, or if the specific contaminant is known, then rinsing with a spe-
cialized solution known to inactivate, alter, neutralize, or increase its
solubility.  For explicit doffing and decontamination procedures, the reader
should refer to Appendix G of the Interim Standard Operating Safety Guide-
lines (U.S. Environmental Protection Agency, Office of Emergency and Reme-
dial Response, 1982).  This document provides stepwise procedures for decon-
tamination for the various levels of hazard protection.  The sequence of
decontamination and disposal for the five levels of hazard  is listed in
Appendix D of this protocol.


8.1       Preparation For Field Activities

8.1.1     Personnel Training and Qualifications

The selection of qualified personnel and their participation in training
activities is essential for the proper performance of inspection and sam-
pling procedures under the HWGW Task Force program.   Inspectors and sampling
personnel should be selected on the basis of their qualifications (education
and experience) that most nearly match the responsibilities assigned to them
under this program.

Personnel assigned onsite duties should have hands-on training to achieve
competence in safety and field activities. Preparation for onsite investiga-
tions must include detailed briefings, particularly for less experienced
personnel.  The requirement for planning and carefully-thought-out field
sequences must be stressed.

Personnel training should, at a minimum, comprise the following areas:

o    Inspection Personnel

     1)   Field Safety Techniques
               Safe and Restricted Zones
               Site Observations and Surveillance

     2)   Hazardous Materials
               Health Hazards
               Fire Hazards
               Storage and Transportation  (including DOT requirements)

     3)   Personal Protective Equipment
               Respirators and Self-Contained Breathing Apparatuses
               Protection Clothing -  Tyvek suits

     4)   Inspection Procedures
               Entry Denial
               CBI Handling and Data  Review
               Logbook Documentation
               Photographic Documentation
               Exit Briefing

o    Sampling Personnel

     1),  2),  3) above, plus:

     4)   Sampling Requirements
               Procedures (site selection, sampling,  field testing)
               Equipment (selection,  maintenance, operation)
               Field QA Requirements  (QC samples, handling, custody, etc.)

Training needs should be identified by the Core Team.  They should also
assume the responsibility of ensuring that the training is implemented and
that personnel certification is attained in the appropriate areas.  A record
of the type and duration of training for each individual should be kept as
part of the ongoing program of QA activities.  The need for refresher
courses or re-certification can be evaluated from the training records.

8.1.2     Pre-Inspection Strategy Meeting

The Phase III consensus meeting will include sampling (contractor) person-
nel, the Core Team and Regional Team leaders.  At this meeting, several
aspects of the proposed inspection that have a bearing on QA requirements

will be defined.  These areas include:

     o    probable existence and nature of groundwater contamination;
     o    details of monitoring system design;
     o    useful activities to be conducted during the inspection.

Decisions reached on these topics will determine the numbers and types of
samples to be taken, the analytical parameters  of interest,  the general
types of equipment needed, and the responsibilities of sampling and inspec-
tion personnel.  These details will be passed on to all parties involved in
the inspection, preferably at a pre-inspection strategy meeting following
the Phase III consensus meeting.  The purpose of such a meeting would be to
review and discuss the QA requirements in conjunction with the other inspec-
tion details, to reach a consensus on QA issues that are dependent on site-
specific characteristics, and to review site background information as it
applies to preparation of the facility inspection plan.

8.1.3     Staging.

Assembly of the equipment, instruments, and supplies needed for sampling at
a particular site should be accomplished in an orderly, controlled fashion.
Equipment staging should be initiated by selecting appropriate items from a
comprehensive checklist  (see Section 6.2).

All sampling equipment utilized  to collect samples during the  inspection
should be numbered so that this  equipment can be traced through field
records.  A log book should be established for this equipment, so that all
cleaning, maintenance, and repair procedures can be traced  to  the person
performing such procedures and specific repairs made.  All  equipment used to
collect groundwater samples shall be cleaned and repaired,  if  necessary,
before being stored at the conclusion  of field studies.  In addition,  all
portable instruments and  sampling equipment should be  tested and calibrated
in the laboratory before being  issued  for field studies.  The  cleaning
procedures conducted in  the field for  re-used sampling equipment and all
field repairs  shall be thoroughly documented in field  records.

8.2       Field Operations

8.2.1     Chain of Command
The organizational control should be diagrammed and described so that the
chain of command is fully illustrated prior to the initiation of field
activities for each facility inspection plan.   This organizational diagram
should illustrate the relationship between the Task Force and all parties
involved in quality assurance (e.g., NEIC SCC, SMO, etc.).

8.2.2     Inspectors Responsibilities

The responsibilities for each member of the combined inspection team should
be determined and outlined in the Field Investigation Plan.  At the end of
the first consensus meeting, the participants can provide recommendations
and guidance for the assignment of various responsibilities to the members
of the combined inspection team.

8.2.3     Sampling Personnel Responsibilities

The responsibilities of the sampling personnel in support of the quality
assurance aspect of the program are:

     o    to ensure that all sampling procedures are carried out in
          accordance with the sampling plan;
     o    to ensure that samples are collected, containerized, labeled,
          and handled in accordance with the  analytical and program
     o    to ensure that all required quality control samples are
          prepared and submitted for analysis;
     o    to document all equipment cleaning, instrument calibration,
          on-site measurements, and sample handling procedures  in  a
          standardized, reproducible format.

8.2.4     Quality Assurance/Quality Control Samples

The field sampling activities should be supported by preparing and submit-
ting several sets of quality control samples.   These include blanks,  spikes
and duplicates.
These samples should include trip blanks and field blanks.   Trip blanks are
used to determine if contamination is introduced from the sample containers.
These should be prepared by the sampling contractor selected for the indivi-
dual site to be inspected.  They are prepared by using distilled deionized
water of known high purity, and are sent with the other sample bottles to
the field.  One set of trip blanks for each analytical parameter group
(e.g., organics, metals, volatiles) should be prepared and submitted for
each day the sampling takes place.

Field blanks are used to determine if contamination is introduced by the
sample collection activities or sampling environment.  They are prepared by
bringing a quantity of distilled deionized water to the field and using this
water to prepare appropriate sample aliquots for each parameter.  This is
also the responsibility of the sampling contractor and should be done for
each day the sampling takes place.

Blanks should be submitted in the same manner as the other field samples,
with no distinguishing labeling or markings.  For the HWGW Task Force, it is
anticipated that blanks will be prepared and handled by the sampling

o    Spikes

Spikes are samples to which a known amount of a compound has been added and
are used to appraise the accuracy and precision of analyses performed by
the laboratory.  The standard analytical methods recommended for use  in this
program specify a certain amount of spiked samples to be included during
analysis of field samples  (e.g., one spiked sample for every ten field

samples).   Note that spiked samples will generally be prepared by the analy-
tical laboratory selected under the Contract Laboratory Program (CLP).

o    Duplicates

Duplicate samples are another method of checking on the precision of a
laboratory's analytical methods.  Duplicate samples should be taken at least
once for every analytical parameter to be tested at a particular facility.
At each sampling location where volatile organics are to be sampled,  dupli-
cate samples must be taken.
8.3       Equipment

8.3.1     Routine Maintenance/Calibration

All field equipment that is to be used for obtaining field measurements
must be calibrated prior to entering the field and at periodic intervals
during use.  Calibration records must be maintained to demonstrate the
precision and accuracy of field measurements made with a particular instru-

Calibration records will include:

     o    a unique identification number assigned to the device
          (e.g., factory serial number);
     o    the source and traceability of the standard(s) used for
     o    the name of the person performing the calibration, the
          date and notation as to whether it was a routine check
          or one required by malfunction  .

Equipment calibration should be further supported by routine maintenance,  as
required by the individual types of equipment in use (e.g., changing bat-
teries in portable meters, lubrication of moving parts of a sampling device
with non-contaminating materials).  Maintenance of auxiliary equipment, such

as portable generators, will also aid the sampling effort.

Maintenance records should be kept similar to calibration records and should
document the type of work done (routine checks,  emergency repairs,  etc.),
the person performing the work, and the identity of the equipment.

8.3.2     Decontamination

Decontamination of field equipment may be done onsite or offsite,  depending
on the availability of equipment that may be dedicated to one sampling
location.  Use of equipment at more than one location implies on site decon-
tamination to avoid carrying possible contaminants from one location to the

Onsite decontamination may be performed at each sampling location or at a
designated area at the facility.  Depending on the size of the facility,
location of sampling points, etc., one of these approaches may be more
efficient than the other.  The procedures, however, should always include a
thorough washing of all equipment with hot water and detergent, followed by
successive rinses with deionized water and appropriate solvents (hexane,
acetone, methylene chloride, etc.).  The waste solvents should be collected
in a container for proper disposal.

Offsite decontamination may be carried out in a similar manner, except  that
the equipment should be transported from the sampling location in doubled
polyethylene bags.

Decontamination procedures for smaller sampling equipment (e.g., soil
scoops, containers) are not necessary if this material is disposed of after
use.  Discarded sampling implements should be properly disposed of onsite or
p.ackaged for appropriate offsite  disposal.

8.4       Documentation

8.4.1     Field Forms and Personal Logs

Appropriate field sheets must be completed at the time of sample collection.
These would include RCRA Compliance Inspection checklists and applicable
Regional Field Sample Record forms.

In addition to sample tags and field sheets,  a bound field notebook should
be maintained by each member of the sampling team to provide a daily record
of significant events.  All entries must be signed and dated.   All notebooks
and logbooks should be kept for the permanent record.  In a legal proceed-
ing, notes, if referred to, are subject to cross-examination and admissible
as evidence.

Accountable documents include items such as logbooks, field data record,
correspondence, sample tags, graphs, chain-of-custody records, bench cards,
analytical records and photos.  Each document should bear a serialized
number and be listed, with the number, in a project document inventory
assembled at the project's completion.

All field logbooks, field data records, field laboratory logbooks, sample
tags and chain-of-custody records  should be numbered and assigned to the
Core Team leader for appropriate distribution and accountability.  The
logbook of  the team leader will document the transfer of other logbooks to
individuals who have been designated to perform specific tasks on the pro-
ject.  All pertinent information should be recorded  in these logbooks from
the time each  individual is assigned to the project  until the project is
completed.  Logbook entries should be  dated, legible, and contain accurate
and inclusive  documentation of an  individual's project activities.  The
logbook must contain only  facts and observations.  Language should be objec-
tive, factual, and free of personal feelings or other terminology which
might prove inappropriate.  Entries made by  individuals  other  than  the
person to whom the logbook was assigned are  dated and signed by  the  indivi-
dual making the entry.

Where appropriate, serialized Field Data Records (FDRs) in the form of indi-
vidual sheets or bound logbooks are maintained for each project,   the pro-
ject leader numbers the FDRs with the appropriate project code.   All onsite
measurements and field observations are recorded in the FDRs with all perti-
nent information necessary to explain and reconstruct sampling operations.
Each page of an FDR is dated and signed by all individuals making entries on
the page.  All project logbooks and FDRs are to be turned over to the
project leader and placed in the central document file when a project has
been concluded.

Assignment of all serialized sample tags to field personnel should also be
recorded in the project leader's logbook.  At no time are any sample tags to
be discarded.  Immediately upon discovery, tags that are lost, voided or
damaged, or transferred on split samples, are noted in the appropriate FDR
or logbook.

Other documentation of field activities, such as records of sample numbers
and chain of custody, is covered in Section 8.5.

8.4.2     Photographs

Photographs are important in documenting the cause and effect relationship
of hazardous materials migrating offsite, especially in the areas of
environmental damage and potential exposure.  Whenever samples are col-
lected, photographs should be taken to verify the written description  in  the
field logbook.  In all cases where a photograph is taken, the following
information must be written in  the logbook:

     1)   time, date, location, and, if  appropriate, weather conditions;

     2)   complete description  or  identification of  the subject  in  the
          photograph and reason why the  photograph was taken;

     3)   the sequential number of the photograph and  file  roll  number;

     4)   name of person taking photograph.

When the photographs are developed, the Information recorded in the field
logbook should be transposed onto the back of the photographs.   Photographs
and negatives are part of the project files and must be accounted for under
document control procedures.

8.5       Sample Handling

8.5.1     Containers

In general, the sample containers to be used for collecting groundwater,
surface water, and soil samples at hazardous waste facilities are specified
by the analytical methodology to be used (see "Methods for Chemical Analysis
of Water and Wastes",  U.S. EPA, 1983).

Water samples for organics analyses are collected in glass bottles equipped
with teflon-lined screw caps.  These water samples are to be preserved by
cooling with ice to 4°C.  Use of analytical contract laboratories requires
that duplicate samples be collected for volatiles.  Samples for volatiles
are collected in 40 ml glass vials equipped with teflon-backed silicon
septum screw caps.  Bottles and septa are washed with detergent, rinsed with
organics free water and dried 1 hour at 105°C.

Samples for extractables are collected in 1-gallon or four 1-liter glass
bottles with teflon-lined caps.  New bottles and liners are rinsed with
methylene chloride and dried by vacuum or other safe means until no solvent
remains.  Previously used bottles are washed with detergent, rinsed with
organics free water, dried and solvent-rinsed as above.

Water samples for metals analysis are collected in 1-liter high-density
polyethylene bottles with solid polyethylene or polyethylene-lined caps.
Bakelite caps are to be avoided.  The bottles are cleaned with dilute nitric
acid and washed well with distilled or deionized water.  The samples are
preserved with nitric acid to below pH 2.  Nitric acid concentration must
not exceed  0.15%  if the sample is  to be shipped via  air cargo.

Water samples for ammonia and TOC analyses are collected in 500 ml polyethy-
lene bottles.  The samples are preserved with sulfuric acid to below pH 2.
The samples are then stored at 4°C.  Water samples for pH and flouride
analysis are collected in 500 ml polyethylene bottles.  Water samples for
cyanide analysis are collected in 1-liter bottles and preserved with sodium
hydroxide to pH greater than 12.  Water samples from sulfide analysis are
collected in 1-liter polyethylene bottles.  Two ml of 0.04% zinc acetate is
added as well as NaOH to pH 9.  These samples should all be stored at 4°C.

Soil and sediment samples are collected in wide mouth glass jars equipped
with teflon-lined screw caps.  Samples are preserved by cooling with ice or
refrigeration at 4°C.  Bottles are cleaned with detergent, rinsed with tap
water and organics-free water.

In addition to analytical programs, the Contractor Laboratory Program provides
several supplementary services.  These activities have developed as a natural
adjunct to the program's analytical services.  One of these services is the
Sample Bottle Repository Program.  Since the HWGW Task Force is using the CLP
for sample analysis, sample containers will be obtained through the repository.

Under the Sample Bottle Repository operation, nine types of sample con-
tainers are available to CLP clients.  Bottles provided through this program
are precleaned and QC-tested according to prescribed procedures to ensure
that no contamination exists that might affect sample data results.

Clean, empty bottles and closures are shipped to users in protective card-
board cartons.   (Note that sample coolers and sample preserving agents are
not supplied through the Repository program.)

The following chart  (Table 8-1)  lists the types of bottles provided  through
this program, the case sizes  in which bottles are shipped, and  the. type(s)
of samples appropriate for collection in  each bottle  type.  Each bottle  type
is cleaned and QC tested by procedures directly related  to the  specific
analyses  that may be performed on  samples collected  in  the bottle.   These
containers match those required by  the sampling activities anticipated  for
the Task  Force site visits.


80 ounce amber glass bottle
with teflon-lined black
phenolic cap

40-ml glass via with teflon-
backed silicon septum cap
            1-liter high-density
            polyethylene bottle
            with poly cap

            120-ml wide-mouth glass
            16-oz wide-mouth glass jar
            with teflon-lined black
            phenolic cap

            8-oz wide-mouth glass jar
            with teflon-lined black
            phenolic cap
            4-oz wide-mouth glass jar
            with teflon-lined black
            phenolic cap
             1-liter  amber  glass bottle
             with teflon-lined black
             phenolic cap

             32-oz wide-mouth glass  jar
             with teflon-lined black
             phenolic cap
No. Per         Expected
 Case          Sample Type*

   6      Extractable Organics
          Low Concentration
          Water Samples

  72      Volatile Organics
          Low & Medium Concentration
          Water Samples

  42      Metals, Cyanide
          Low Concentration
          Water Samples

  72      Volatile Organics
          Low & Medium Concentration
          Soil Samples

  48      Metals, Cyanide
          Medium Concentration
          Water Samples

  96      Extractable Organics
          Low & Medium Concentration-
          Soil Samples
          Soil Samples
          Organics & Inorganics
          High Concentration
          Liquid & Solid Samples

 120      Extractable Organics
          Low & Medium Concentration
          Soil Samples
          Metals, Cyanide
          Low & Medium Concentration
          Soil  Samples
          Soil  Samples
          Organic &  Inorganic
          High  Concentration
          Liquid & Solid Samples

   30      Extractable  Organics
          Low Concentration
          Water Samples

   36      Extractable  Organics
          Medium Concentration
          Water Samples
      This  column specifies  the  only type(s)  of samples  that should be
      collected in each container.

The sampling contractor will contact the EPA Sample Management Office (SMO)
initially to become authorized to order from the Repository and to obtain a
supply of Delivery Order forms.  Thereafter,  the contractor will order
bottles directly from the Repository.   Since the Repository can respond only
to orders submitted by a SMO-designated representative,  the SMO will be
notified of any change in contractor representative designations.   Orders
will be placed following the guidance in "Users Guide to the CLP Program"
(U.S.  EPA, 1984).
8.5.2       Chain-of-Custody

All sample shipments will be accompanied by a Chain-of-Custody Record iden-
tifying its contents.   The  original record  will  accompany the shipment,  and
a copy will be retained by the Sampling Contractor.   Chain-of-custody requi-
rements have been extensively  described in numerous documents (e.g.,
"Enforcement Considerations for Evaluations of Uncontrolled Hazardous Waste
Disposal Sites by Contractors", U.S.  EPA;  NEIC,  1980).   In general,  as few
people as possible should handle the samples; until shipped or transferred,
custody will be the responsibility of the sampling  contractor.

Whenever samples  are split with a  facility,  it  is noted in the remarks
section of the custody  form.   The note  indicates with  whom the samples are
being split and is signed by both the sampler and recipient.  If the split
is refused, this will be noted and signed by both parties.  The person
relinquishing the samples to the facility  should request  the signature of a
representative of the appropriate party,  acknowledging receipt of the sam-
ples.  If a representative is unavailable or refuses to sign,  this is noted
in the "Remarks" space.   When appropriate,  as in the case where the repre-
sentative is unavailable, the custody record should contain a statement that
the samples were delivered to  the designated location at  the designated

Serialized Chain-of-Custody Records should be assigned and accounted  for  in
a manner similar  to that for the sample tags, as described below.  When
samples are transferred from  a field sampler or courier  to laboratory

personnel,  the analyst,  after signing,  retains the original custody record
and files it in a safe place.   A copy of the  custody  record should  be
returned to the sampler.

8.5.3       Labeling and Packaging

All samples collected for the Task Force should be labeled in a clear  and
precise way for proper identification in the  field and for tracking in the
laboratory.   Sample labels should have a pre-assigned,  unique  number that is
indelible;  the label should also be waterproof.   Preferably,  a two-part
label should be used so that the sample identification number can be affixed
to the sample bottle and can also be entered  in a field logbook at  the time
of collection, along with pertinent remarks.   The label to be attached to
the bottle should list only  the sample number; the label for the notebook
should include this number as well as:

     o    project code number
     o    station location and number
     o    date and time
     o    sample type (composite or grab)
     o    signature of sampler
     o    preservative indication (yes or no; type)
     o    analyses required
     o    additional remarks

Samples  should be packaged properly  for shipment and dispatched to the
appropriate laboratory for analysis, with a separate  custody record accom-
panying  each  shipment (e.g.,  one for each field laboratory,  one for samples
driven to laboratory).  Shipping containers should be padlocked or sealed
for shipment  to  the  laboratory.  Only metal or plastic ice chests should be
utilized as the outside shipping container for routine environmental sam-
ples.  This strong outside shipping container must be able to withstand a it-
foot drop on  solid concrete  in  the position most likely  to cause damage.
The drainage  hole at  the bottom of  each ice chest should be permanently
plugged  to prevent any possibility of  leakage through  the hole.  Each  ice
chest must be clearly marked with arrows  indicating  the proper upright

position of the container, a label indicating "THIS END UP"  on the  top,  a
label stating "ENVIRONMENTAL SAMPLES" on the lid,  and a sticker containing
the originator's name and address.

All field personnel should be cognizant of DOT criteria for  classifying
samples as hazardous material.   When there is reasonable doubt as  to  whether
or not a particular sample is subject to DOT regulations,  the shipper should
consult with the SMO or his/her supervisor prior to shipping the sample.

Each ice chest offered for shipment should be securely taped shut.  This
should be accomplished by wrapping reinforced tape at least  one complete
overlapping wrap around the ice chest near each end,  where the hinges are

Sample containers should be packaged in the following manner:

o    Glass Containers

1)   The container's screw-type lid should be tightened securely before
     it is placed in the shipping container.  Glass stoppers must be  held
     securely in place with wire or nylon reinforced tape.

2)   The containers should be separated in the shipping container by
     cushioning (e.g. styrofoam) or absorbent material (e.g. vermiculite
     to prevent breakage due to contact with other glass containers or solid

3)   The small glass vials for organic samples should be placed inside
     a larger plastic container to minimize breakage and to contain any
    . leakage.

o    Plastic Containers

1)   The cap should be tightened securely before  it  is placed  in the
     shipping container.

2)   Although the plastic containers  do  not  need  cushioning material
     between them, they do need to be protected from punctures from
     sharp objects.

All sample containers and vet ice should be  packed inside  a sturdy plastic
bag,  placed inside the shipping container as an inner  pack.  The plastic bag
will be tightly closed with wire,  nylon  reinforced tape or other positive
means after all of the sample containers and ice  have  been added to prevent
any leakage of material from the bag.

8.5.4     Transportation

Samples processed  through the CLP must be packaged for shipment in compli-
ance with current U.S.  Department  of  Transportation (DOT)  and commercial
carrier regulations.   All required government and commercial  carrier  ship-
ping papers must be filled out  and shipment  classifications made according
to current DOT regulations.   In general,  sample classification procedures
and shipping requirements are designed for samples containing less  than 10
ppm of any single  organic pollutant and less than 100 ppm of any single
inorganic pollutant,  although the  samples may well exceed these concentra-
tions.   Investigative team leaders must  exercise  judgment,  such that  if
samples are suspected of containing substantially higher  concentrations,
they be treated as Hazardous Samples. Questions concerning sample  packaging
may also be directed to  the SMO.

Sample Traffic Reports, Chain-of-Custody Records, and any other shipping/
sample documentation accompanying the shipment should be  enclosed  in  a
waterproof plastic bag and taped to the underside of the  cooler  lid.   In
general, preservatives added to routine  environmental  samples will not
affect the classification of the samples  for shipping purposes.   However,
preservatives in pure or concentrated form should hot  be shipped via  commer-
cial means.

Samples for  organics analysis  must be shipped "Priority One/Overnight."  If
shipment requires  more than a 24-hour period,  sample holding  times can be
exceeded compromising the integrity  of  the  sample analyses.

Samples for inorganics analysis should be held until sampling at the  facil-
ity is complete and shipped "Standard Air"  for  two-day  delivery.  Three  days
is the anticipated maximum period for collection of facility samples.

The SMO should be notified immediately after sample shipment,  and should be
provided with the following information:

     o    sampling contractor's name
     o    project number
     o    exact number(s) and type(s) of samples shipped
     o    the name of the facility and location from where  the
          samples are being shipped
     o    the laboratory that the samples were  shipped to
     o    carrier, airbill number(s), method of shipment
          (e.g., priority, two-day)
     o    shipment date and time
     o    irregularities or anticipated problems,  such as special
          handling needs, hazardous samples, etc.

Sample shipments  made after  5:00 P.M. EST should be called  in to the  SMO at
the start of business the next day (8:00  A.M. EST).   The SMO  must be  noti-
fied by 3:00 P.M.  EST  Friday  concerning information on  sample shipments
going out Friday intended for Saturday delivery/pickup.   CLP laboratories
remain open to  receive or pick-up Saturday shipments only upon advance
notification by the SMO and only when shipment  airbill numbers have been
provided to the SMO by the sampler.


9.1       Introduction

Upon completion of the review of the document package,  site inspection
notes, and sample analyses, the Team Leader (NEIC or Region) will draft a
facility compliance evaluation report.  The on-site"coordinator will collect
all completed checklists, forms and pertinent documents from members of the
combined inspection team.  The findings developed from the final debriefing
meeting at the end of the facility inspection should be incorporated in the
report which will focus on the following:

     1)   Observations and findings from the data review and the
          on-site inspection,

     2)   Conclusions covering regulatory compliance of the facility's
          ground-water monitoring program, and probable nature and
          level of groundwater contamination, and

     3)   Recommendations on technical activities necessary to achieve
          compliance or determine the nature and extent of contamination.

9.2       Scope of Meeting

Within one week after the  issuance of the draft report, the Regional Team
Leader should coordinate a second meeting of all team leaders and managers
from each organizational unit involved.  The purpose of the meeting is  to
review the facility evaluation report, reach a consensus on appropriate
changes and to develop appropriate action strategies for attaining compli-
ance with RCRA regulations and with the  Superfund .off-site policy.

If certain technical problems cannot be  resolved at  the meeting, the Region-
al Team Leader should compile a list  of  these technical problems and submit
to the Technical Advisory  Panel for review and guidance.

9.3       Technical Objectives

9.3.1     Status of Facility RCRA Compliance

The Facility Evaluation Report should combine the results of the site visit
with the background information from the Document Package to create a com-
plete profile of the facility's current or potential impact on the areal
ground water.  This profile should allow the Task Force to reach a consensus
on the degree that the prescribed technical objectives have been met, with
respect to the status of the facility's compliance with ground-water regula-
tions and requirements.

9.3.2     Identification of Appropriate Action

In order to decide appropriate action for a facility, the investigation team
members must agree on the ground-water monitoring compliance status of the
facility.  The EPA publication, "Ground Water Technical Enforcement Guidance
Document" (Draft, March 21, 1985) provides detailed technical guidance in
evaluating ground-water monitoring systems at commercial land disposal faci-
lities.  The document discusses the following issues:

     o    Characterization of Site Hydrogeology,
     o    Placement of Detection Monitoring Wells,
     o    Monitoring Well Design and Construction,
     o    Sampling and Analysis,
     o    Data Quality,
     o    Methods for Presenting Detection and Assessment Monitoring Data
     o    Statistical Analysis of Detection Monitoring Data, and
     o    Assessment Monitoring.

Based on a detailed site-specific evaluation by  the  team, the probable
sources of contamination, if any, can be  identified  and  the degree of conta-
mination can be  approximated.  The investigation team can then  identify the
appropriate action(s)  that will be required  to bring the facility  into
compliance.  Chapter 5 of the EPA publication,  "Compliance Order Guidance"
(Draft, March 21, 1985), provides detailed guidance  on how  to identify  and

design appropriate technical actions and how to incorporate these  actions
into an enforcement strategy that will correct present violations  while
advancing a facility toward permitting.

9.3.3     Schedule For Action

A preliminary implementation  schedule  should also be developed to  be
reviewed by the Facilities'  Management and be  incorporated into the Facility
Management Plan.  Limiting factors such as weather,  personnel availability,
scheduling conflicts,  and equipment availability should be considered to
insure the schedule is workable.

9.4       Recommendations

In finalizing the facility evaluation report,  the participants of  the con-
sensus meeting should agree on the appropriate actions and develop a  preli-
minary enforcement strategy to bring the facility into compliance. Areas
where the appropriate action may be focused on includes:

     o    Modification of the ground-water monitoring system
     o    Sample collection and handling procedures
     o    Leachate collection system
     o    Waste treatment and disposal unit design
     o    Data QA/QC including chain-of-custody procedures
     o    Waste analysis and waste management plans

These recommendations  will be incorporated into a comprehensive Facility
Management Plan (Chapter 10) to be prepared by the Region.

9.5       Technical Report

A draft report should be completed  and distributed by  the Region  (or NEIC in
the case of the first report for each Region)  to members of the combined
inspection team for review and comments,  two weeks after the completion of
the  field  inspection.

All involved groups will review the draft and the technical staff will meet
to comment and iron out disagreements.  NEIC or the Region will revise the
report accordingly and issue a second draft to the respective team leaders.

The Core Team, through the Director, will submit any additional technical
problems to the Technical Advisory Panel for review and advice.

The Regional Team Leader will schedule a consensus meeting of team leaders
and managers from each organization unit involved to resolve any remaining
disagreements and to discuss problems that developed in conducting the
evaluation.  This meeting will be kept to a small group to facilitate
discussion and agreement.  NEIC or the Region will finalize the report in
accordance with decisions made at the meeting.

10.0      FOLLOW UP

10.1      Development of a Facility Management Plan

Based on the findings and recommendations in the finalized technical report,
Regional EPA staff will prepare a draft Facility Management Plan.  This Plan
should describe the methods and procedures the Region will utilize to gain
facility compliance  with  rules,  regulations, orders, etc.,  and/or resolve
facility problems  identified in  the technical report.   Moreover,  the Plan
should identify the likely participating agencies,  as well as  their
respective responsibilities and the anticipated  administrative/enforcement
actions to be initiated by each agency.   The  following  is  a summary of the
major elements and areas of concern that should be addressed in the draft

     o    Overview of the facility's history of operations and compliance
          status (from the technical report);

     o    Definition of specific short and long-term objectives to be
          achieved by the facility;

     o    Outline  of available mechanisms for achieving compliance (from
          the technical report), such as issuing administrative orders
          and/or penalties, issuing new/modifying existing permit
          conditions, etc.  (EPA's draft report, "Compliance Order
          Guidance," March 21, 1985, provides a framework for developing
          administrative/enforcement actions against non-complying
          interim  status facilities.  Appendix C in this protocol
          describes the various  administrative/enforcement orders
          available under CERCLA and RCRA.);

     o    Identification of the"  likely mechanism(s). to be used for
          gaining  facility compliance or problem resolution;

     o    Identification of upcoming facility-related deadlines,  such
          as issuance/reauthorization of permits, enforcement action

          deadlines,  etc.;

     o    Identification of likely participating agencies;

     o    Establishment of roles,  responsibilities and actions to be
          initiated by each agency; and

     o    Establishment of liaison/coordinating mechanism(s)  and outline
          of procedures for coordinating actions from state and local

The Region will provide a draft copy of the Facility Management Plan to each
participating agency for review and comment.  One copy of the draft Plan
will also be provided to the Office of Waste Programs Enforcement (OWPE),
whose role is to ensure overall consistency in enforcement-related actions.

The RTL will schedule and conduct a meeting with team leaders and managers
from the various participating agencies to:  1) discuss the Plan and resolve
any problems, 2) conclude what actions should ensue, 3) develop a schedule
for initiating the identified actions, and 4) assign responsibilities  for
implementing those actions  and monitoring their progress.

10.2      Implementation of Facility Management Plans

Based on the results of the consensus meeting on the Facility Management
Plan, the identified responsible agency (Regional Office or State) will
implement appropriate  action(s) -- orders (see Appendix C),  modified/new
permit conditions, etc. --  according  to the plan's schedule and through
normal operating  channels.

The Core Team will assist the responsible agency in initiating the selected
corrective action by arranging for the OWPE and OSW  to resolve any issues of
interpretation and to provide any  assistance that is desired  in writing any
orders or permits.

The  schedule of corrective  action  will include  a timetable for meeting each

objective in the plan.   Each schedule will  be  facility-specific  and  should
reflect the following issues:

     o    magnitude of the problem,  as this may dictate the  expediency
          of the solution, and

     o    local factors, such as weather and availability of equipment
          and personnel.

The timetable will contain milestones by which progress towards  compliance
may be  assessed.

Actions to be initiated at facilities whose treatment,  storage or disposal
operations pose an actual or imminent threat to human health or the  environ-
ment should be expedited  to  eliminate or minimize  any  resulting damage(s).
Where such a threat is  determined by the responsible agency  (Region, State,
local)  to be imminent,  the Region will  initiate action by the Emergency
Response Team (ERT).   The ERT will  determine whether and to  what degree
additional immediate  action may need to be  initiated by the  appropriate
responsible agency.  At facilities  where the responsible agency determines
that an actual or  imminent  threat does  not  exist,  the schedule of actions
outlined in the Plan will apply.

10.3      Monitoring the  Progress of Initiated Actions

The Core Team will conduct a weekly  review with the RTL on the progress of
all actions taken  at each facility.  . The Core Team will then issue their
progress report to the  Director of the Task Force.   The Director will then
issue,  through his office, bi-weekly progress reports to the Senior  Manage-
ment Steering Committee and will brief  the Committee on the progress at
specific facilities where deemed appropriate.

10.4      Identification  of  Implementation  Problems

When a  facility does  not achieve the milestones identified  in the action,
the responsible agency will also teleconference/meet with the Core Team  and

RTL during the weekly facility review.   The responsible agency will discuss
what additional measures need to be initiated and what type and degree of
support,  if any,  may be required from the EPA Regional office or Headquar-
ters.   After concurring on the appropriate additional action (enforcement
order,  penalty, fine),  which reflects the facility's  degree of culpability
and noneorapliance,  the  appropriate agency will initiate that action.

Problems dealing with the administrative aspects  of the program will be
handled by the Operations Assessment Group.

The Core Team representative will communicate to the Operations Assessment
Group at Headquarters, problems with guidance, policies, regulations, avail-
ability of technology, organization,  skills, and any other identifiable
problem areas  that  may  impact the program.

10.5      Final Report

A final report will be compiled by the Core Team at  the conclusion of
activity which will summarize all of the activities of the Hazardous Waste
Groundwater Task  Force.

            APPENDIX A


                     Field Investigation Report*
GROUNDWATER MONITORING SYSTEM (Section to be completed before site visit)
Resource Documents:
     *  Field Investigation Protocol developed by U.S. EPA Region X

A.   Identification of Hazardous Waste and Regulated Units


A.   Identification of Hazardous Waste and Regulated Units

     1)   What HW are being land treated at this facility?
     2)   What groundwater regulated process units are utilized at this
     3)   How long have these HW been put into units?
     4)   What volume of HW and other liquids have been put into the
          regulated unit.
     5)   What is the chemical character of the materials being placed
          in the regulated unit?
     6)   If tests have been run,is a copy of the results available?
     7)   How long have these waste been deposited in the unit?
     8)   Are any closed fill areas at nor near the regulated units?
     9)   Are there ponds or lagoons within the regulated unit?
    10)   If yes, are the metered?
    11)   Are there any groundwater chemical analyses available?

B.   Regional Hydrogeologlcal Information

     1)   Has a geologic/hydrologic study been done by a qualified
     2)   Is a regional map of the site available?
     3)   Is a local map of the site available?
     4)   Are there any significant topographic features?
     5)   Has the geology of the site been mapped?
     6)   Is the geologic map available?
     7)   What type of formation underlies the region?
     8)   Is formation consolidated, unconsolidated, fractured?
     9)   Is formation heterogeneous enough to cause a possible
          differentiation in pollutant flow?
    10)   Are any streams, rivers, lakes or wetlands near the facility?
          Distance?  Direction?
    11)   Is there more than one aquifer beneath the site?  Are they
          hydraulically connected?

C.    Site Specific Hydrogeological Information?

     1)   Is there a site specific geohydrologic map available?
          What is the date of issue?
          Are any recent (post map date) changes evident?
     2)   Are local discharging wells noted?  Distance?  Direction?
     3)   Does pumping of surrounding wells change or reverse the direction
          of the hydraulic gradient?
     4)   Are potentiometric maps available?
          Is groundwater flow direction noted?
          Are the contours logical based on other maps?
          Is the facility along with the HW units plotted (Scale)?
          Are any seeps, springs, etc., shown near the facility?
          Are monitoring wells plotted?
          Is site potentiometric surface plotted?
          Is the indicated potentiometric surface compatible with
          regional hydrology?
               Are site flow lines indicated?
               What are the contour intervals?
               Are static water elevations shown?
     5)   Does the facility affect the groundwater surface?

D.    Monitoring Well Locations

     1)   Are logs of all wells and borings available from either onsite
          or offsite?
     2)   Are the monitoring wells completed in the same stratum as nearby
          water supply wells?  If no, please explain.  Are any types of
          geophysical logs available?  Were any discrete formation samples
          taken?  How were these samples taken?
     3)   Are any physical tests of aquifer materials available?
     4)   Have the elevations of the wells been surveyed to sufficient
          accuracy to determine gradient?
     5)   Is there sufficient distance between wells to establish a
          gradient on the potentiometric surface?
     6)   Do the regulated units create a groundwater mound?
     7)   Is the upgradient well(s) placed in a position to represent a
          background condition.
     8)   Does intermittent flow to the disposal site affect the ground-
          water mound?
     9)   Do the downgradient wells monitor the mounding at the water
    10)   Are the groundwater monitoring wells placed in a position such
          they can immediately detect any groundwater contamination from
          the regulated unit?
    11)   Does the master map clearly show the monitoring wells and their
          assigned identification numbers?

E.    Well Completion

     1)   Are the wells constructed of nonreactive materials?
          Casings?  Screens?  Gravel pack materials?
          Have any glues or solvents been used?
     2)   Have the wells been sealed to prevent downward migration of
          contaminants?  Bentonite?  Cement?  Other?  How?
     3)   Will these contact the water being sampled?
     4)   Are the wells capped and locked to prevent vandalism?
          If no, what security measures taken?
     5)   Are the wells protected against vehicular damage?
     6)   Are the wells completed in the first water bearing zone?
     7)   Is this the regional aquifer?
     8)   Is this a perched aquifer or zone?
     9)   Are the wells screened in water bearing materials?
          What type of screen was used?
          Size of openings?
    10)   Does the- screen extend above the water surface so as to detect
          "floating" contaminants or account for fluctuating water levels?
    11)   Are the wells gravel or sand packed around the screen?
          What materials were used in the pack?
          What was the source of those materials?
    12)   Are the wells screened at the correct level?
    13)   What was the method of drilling?  Auger?  Mud Rotary?  Air Rotary?
          Reverse Rotary?  Cable Tool?  Jetting?  Other?
    14)   Was the equipment cleaned prior to drilling?  How?
    15)   Were any additives, including non-formation water, used during
          or after drilling?
    16)   What precautions were taken to prevent cross-contamination
          during drilling?
    17)   Have the wells been developed?    By what  method?  Was any
          non-formation fluid used for jetting or surging?

F.    Sampling and Analysis Plan

     1)   Does the plan specify the procedures to be used to collect
          the required samples?
     2)   Does the plan specify the data and methods for in field
     3)   How soon after well completion was the first sample taken?
     4)   How is the plan deficient?

G.   Well Summary Table

     Please complete the following summary of pertinent well information.
     Four wells are the minimum considered adequate,  if more than four
     wells, use additional sheets.

                    Upgradient                    Downgradient

Well NumberWellWellWellWell

1)   Total depth
2)   Casing diameter
3)   Length of casing
4)   Screen length
5)   Screen slot
6)   Screened       From           From           From           From
     interval       To             To             To             To
7)   Gravel Pack    From           From           From           From
     interval       To             To             To             To
8)   Ground
9)   Height of Casing
     Above Ground
10)  Elevation of
11)  Depth to
12)  Elevation of
13)  Source of Data
                         Driller's Name	

H.   Map of facility
     Approx. Scale
     .   Monitor Well
     *  Water Supply Well

SAMPLING TECHNIQUE (Section to be completed during site visit)

Resource Documents:

A.   Well Purging

     1)   Well correctly identified?
     2)   Depth to water measured?
     3)   Depth to bottom measured or available from records?
     4)   Sounding equipment cleaned after use?
     5)   From where in the well is the water drawn?
          Is this depth consistently maintained?
     6)   Volume to remove calculated?
     7)   How do you determine that formation water is being sampled?
          Number of well casing evacuated?
          Stabilization of pH, eh, spec. cond. or temp.?
     8)   What method is used to purge the wells?
          If commercially available, what make and model number?
     9)   Why was this method selected?
          Has this procedure been maintained throughout the sampling program?
          If not, what other methods have been used?
    10)   What period of time usuals elapses between purging and sampling?
    11)   Water collected and stored if hazardous?
          How is this water disposed of?
    12)   Were the samples turbid?  Which?
          What precautions are taken to avoid cross contamination?
          Individual pumps or bailers?
          Is the same cable/rope used in all wells?
          Is the cable/rope cleaned?  wrapped?

B.    Sampling Equipment

     1)   What type of equipment is used?
     2)   Is it commercially available?  Make?  Model No.?
     3)   Sampling equipment clean?
     4)   Sampling equipment kept clean during use?
     5)   Sampling equipment appropriate for contaminants?
     6)   Sampling equipment properly cleaned in field if needed?

C.   Sampling Procedures

     1)   Does the same person/contractor/laboratory always take the
     2)   With what materials does the sample come in contact?
     3)   For VGA's, what is done to prevent sample aeration?
     4)   Are sample containers appropriate for analytes?  (See Appendix A)
     5)   Are preservatives used?
          Are they added in lab.?  field?
     6)   How are containers handled prior to taking sample?
          Are they washed, with what?
     7)   Are field blanks used?
          If yes, is the water source regularly tested?
     8)   Have the methods used been consistent since the program started?
          If no, what changes have been instituted?
     9)   Have laboratories been changed since analysis begun?  which?
    10)   Provide a list of methods that are being used by the lab. for
          analysis along with the detection limits for each parameter.
    11)   Are samples refrigerated after collection?
    12)   What is the average holding time before samples are analyzed?
    13)   Are time sensitive parameters measured  in the field or in the

D.    Field Measurements

     1)   pH - Meter warmed up?
          Calibrated with proper buffers (4 and 7,or 7 and 10)?
          Corrected for temperature?
          Measurements repeated until within 0.1 pH unit?
     2)   Conductivity - Calibrated with 0.01 N KCl standard?
     3)   Temperature - Measured as soon as sample taken?
E.   Sample Containers

     1)   Documentation of proper cleaning?
     2)   Correct containers  (see Appendix A)?

F.    Field QA/qC

     1)   Field QA/QC samples prepared?
               Samples preservative blank
               Transport/transfer blanks
     2)   Bottles prerinsed with sample water (except
     3)   Correct preservatives used (see Appendix A)?
     4)   Sample holding times not exceeded (see Appendix A)?
G.   Sample Labels

     1)   Integrity?
     2)   Required information?
               Unique sample number
               Name of collector
               Date and time of collection
               Place of collection
     3)   Optional information?
               Sample type
               Preservative used
               Analyses required
               Field information

H.   Sample Seals
     1)   Integrity?
     2)   Required information?
               Unique sample number (same as label)
               Name of collector
               Date and time of sampling
I.   Field Log Book

     1)   Bound?
     2)   Entries?
               Purpose of sampling
               Unique sample number
               Date and time of collection
               Names of all persons present
               Location of sample point (description and/or sketch)
               Description of sampling methodology
               Number and volume of sample taken
               Suspected composition of sample
               Name and address of field contact
               Sample distribution and transportation
               Field observations
               Field measurements
               Signature of sampler

J.   Chain of Custody Record

     1)   Required information?
               Sample number
               Signature of sampler
               Date and time of collection
               Place and address of collection
               Type of sample
     2)   Number and type of containers
     3)   Signature of custodian
     4)   Inclusive dates of possession
     5)   Signature of receiver
     6)   Description of shipping container
K.   Sample Analysis Request

     1)   Field Information?
               Name and phone number of collector
               Date and time of collection
               Collector's sample number
               Field information
               Analysis requested
               Special handling or storage
     2)   Laboratory information?
               Name of person receiving sample
               Date of sample receipt
               Analysis required

L.   Sample Shipping
     1)   Samples packed to prevent breakage?
     2)   Chain of custody record enclosed?
     3)   Sample analysis request enclosed?
     4)   Shipping container sealed?
M.   Sample Receipt

     1)   Condition of samples checked?
               Containers intact
               Preservative present
               Seal intact
     2)   Sample information checked?
     3)   Chain of custody record present?
     4)   Sample and seal information match chain of custody record?
     5)   Chain of custody record signed?
     6)   Request for analysis present?
     7)   Receipt of sample entered in laboratory log book?
     8)   Laboratory sample number assigned?

     9)   Sample stored  in secure area:

N.   Lab QA/QC

     1)   Lab quality assurance plan available?
     2)   Documentation of EPA acceptable methods?
     3)   Instrument calibration records available?
     4)   Copies of QA/QC control charts available?
     5)   Method accuracy and precision calculated and reported?

Resource Documents:

A.   Duplicate Sample Data

     Data Source:


B.    Other Data (Other than split Sample)
     Data Source:


                                "t"  STATISTICS
EPA 10 NO.

W        pH
E        Sp. Cond.
L        TOC
L        TOX
W        pH
E        Sp. Cond.
L        TOC
L        TOX
W        pH
E        Sp. Cond.
L        TOC
L        TOX
W        pH
E        Sp. Cond.
L        TOC
L        TOX


                      Upgradient Well

                      Well  #

Quarter 1
Sample Date
Water Elev.

(pH UNITS) (umhos/cm) (mg/1 ) (ug/1)
Quarter 2
Sample Date
Water Elev.
Quarter 3
Sample Date
Water Elev.
Quarter 4
Sample Date
Water Elev.
Background Mean
Background Van'




EPA ID NO.                                       SAMPLE  DATE
FACILITY	                      BACKGROUND WELL(S!
                        Significant Change       No Significant Change
Specific Conductance
                                            Upgradient well(s)
                                            Downgradient well (si




    Metals (dissolved)

         As,  Ba,  Cd,  Cr,  Pb,  Se, Ag
              200 ml
              Plastic or glass
             *Fi1ter  on site
              Add HN03  to pH  less t.nan 2
              6-month holding period

              100 ml
              Plastic or glass
             *Filter  on site
              Add HN03  to pH  less than 2
              28-day  holding* period

              50 ml
              Plastic or glass
              No preservative
              28-day holding period
              300 ml
              No preservative
              28-day holding period
              100 ml
              Plastic or glass
              Cold  (4 C)
              Add HN03  to  pH less tnan 2
              Analyze within 28  days

    Organochlorine  Pesticides and Herbicides

    Endrin, Lindane. Methoxychlor, Toxaphene
              500 mf
              Glass with teflon  lined cap       .            :
              Cold  (4 C) only, vf extracted within 48 hours
              Cold  (4 C) and adjust pH to 6 to 8 with NaOH or
              H2S04 if  extracted after 48 hours
              All samples  extracted within 14 days

         2,4-0;  2,4,5-TP
              500 ml
              Glass with teflon  cap
              Cold  (4 C)
              All samples  extracted within ? days


    An Ions
Mn, Na
 200 ml
 Plastic or glass
*Filter on site
 Add HN03 to pH less tnan  2
 6-month holding period
              50 ml
              Plastic  or glass
              No preservative
              28-day holding period
              50 ml
              Plastic  or glass
              Cold  (4  C)
              28-day holding  period
              500 ml
              Cold  (4  C)
              H3P04  to pH less  than  4
              1.0 gm CuS04 per  liter
              28-day holding  period


              25 ml
              No preservative
              Determine  on  site
              6-hour holding period

         Specific Conductance
              100 ml
              Cold (4  C)
              28-day holding period

         Total  Organic Carbon  (TOO
              25 ml
              Plastic  or glass
              Cold (4  C)
              H2S04  or HC1  to  pH less than 2
              28-day holding period

         Total  Organic Halogen (TOX,
              250 ml
              Glass  with teflon septum or liner
              No headspace
              Cold (4  '  C)
              24-hour  holding  period

         Semi-volatile Organics
              1  liter
              Glass, no  prerinse
              Refrigerate  at 4 C
                   If  residual chlorine present and sample will not be
                  extracted within 48 hours, add 35 mg sodium thiosulfate
                  per ppm  free chlorine/liter of sample.   Adjust pH to 7-10
                  with  NaOH or H2SQ4.  Record volume of acid or base used.
              All  samples  extracted within 7 days
           %  All  samples  analyzed witnin ^fl'days 4©

         Volatile Organics
              720 ml
              Septum vials
              No sample  agitation or entrained air
              Analyze  within 7 -days
              No preservatives
              No prerinse
                   If  known to be chlorinated, prior to shipment of
                  containers  add 1  u^/40 ml sodium tniosulfate to emoty
                  sample  containers
              Hold at  4  C

         APPENDIX B


     In the event that entry is denied or consent withdrawn, the Enforcement
Division nust be  contacted.   Normally an Enforcement Attorney will take the
necessary actions to  secure three seoarata documents and submit them to the
judge or magristrate in order to ootain a warrant, viz:

     1.   Application for a Warrant

          a.   Statement of  statutory and regulatory authority for the

          b.   Identification  of  the  site  or estaolisnment desired  ta
               be inspected  (and  if possible the owner  and/or operator
               of the site)..

          c.   Summary  of   the  factual  aackgrc'-.-d   far  the warrant  as
               stated in tne affidavit.

     2.   Affidavit

          a.   The  affidavit   should  contain   consecutively  numoerea
               paragrapns  which  provide  detailea  cescriations  of t.-.e
               facts wnich  support  tne issuance  of  a warrant.

          b.   The factual  description should recite or  incorporate the
               specific prcbaole  causa or neutral acininistrative  scneme
               •which,  led  to the'particular- estaol isnment's 'selection-
               for inspection.

          c.   "he  affidavit -nust be  signed  by a person with personal
j.    .An affidavit ;s a 5«or" statement «nicn, ".er?-':-a, -_j:
     ce  eitner  iotar; :2d  or  oersonaily  sworn  :a-":ro  vie
     .nagi strata.

3.    Draft War-ant

     The contents of  tbe warrant varies based an the type of
warrant  sougnt  (discussed  below).   The  warrant  snould  be
submitted in  sucn  a forn that the judge or magistrate merely
has to sign it  to make it valid.

a.    Civil specific probable cause war-ant  -  based  on some
     specific  reason  to  believe tnat the requirements  cf ^r.e
     statute  or  regulations  are  being  violated.    A  civil
     warrant  souia  be  sougnt only wnere  it can be  accurately
     stated in  the  affidavit tnat the purpose of tne insoec-
     tion  is   to  find  and  remedy  the  statutory   violation
     througn noncriminal proceedings.
     Therefore, this warrant will be usad when tne  inspection
     is. being  iiace  in  response  to  tne  aiscsvery of a poten-
     tial   or  actual violation  from anotner  source,  i.e.,  a
     citizen's  complaint  or  tnraugn   tne   reaort  screening
     process.   If possible, such a warrant snculc :e :stai.~ea
     rather than  a neutral  administrative  dissection scneme
     warrant (discussed belcw).

b.   Civil orgpaole cause based  on neutral acmim'strative  ;'n-
     scection  scneme,  i.e., showing, that ''raasonaole legisla-
     tive  or  administrative  standards  for  conducting an  . . .
     insoection  are satisfied  with ressect  :z  a  ^articular
     estaol isr.ment. ''   Marsnal 1  v.  2ar' ow' s  I-c. .  _ U^S.
     _ ,  90  S.  Ct.  1315 (1973).   A -arrant :asaa  :n  a
     neutral acninistrative process can  se issued only if  the
     facility  *':r   ^nicn  tne  warrant ;s  scugnt  «*as salectaa
     for  inspection tnrougn this neutral process.   Therefore,

          this type of warrant may be used for regularly scneduled
          inspections,  e.g.,   annual  inspections,   post  closure
          inspections, etc.

     c.    Criminal  warrant - obtained when  the  purpose of inspec-
          tion is to gather evidence for a criminal  prosecution in
          accordance with Rule 41 of the Federal  Rules of Criminal
          Procedures.    This  type of  warrant requires  a  specific
          showing of  probable  cause to  believe  that evidence of a
          crime  will   be  discovered.   It should  be  noted  that,
          oridinarily, evidence of a criminal violation discovered
          under a  civil  probable cause  warrant  will be admissible
          in court  (see  Section  IV, Exhibit 1,  p.  2).  Therefore,
          this type of warrant will be used only where the Agency
          is  reasonably  certain  that  criminal  violations  nave

4.    Securing a Warrant

     The following procedures  should be followed in  securing a warrant:

     a.    When an  inspector is refused entry, tne inspector should
          leave the premises immediately.

     a.    The inspector should then  immediately contact the desig-
          nated Regional  Enforcement Attorney to inform him/her of
          the situation.  The  inspector should at this  time report
          any exigent  conditions; i.e., dumping, etc.

     c.    The  Enforcement Attorney  will  assist the inspector in
          the preparation of the  necessary documents.

     d.    The Enforcement Attorney  will arrange  for  a  meeting with
          the  inspector and a U.S.  Attorney.   The  inspector will
          bring  a  ccpy of the approoriate draft warrant  ana affi-

     e.    The Enforcement  Attorney srould  'infers tne jcorcor-'ate

          Headquarters  Enforcement Attorney  of  any  refusal 3  to

          enter ana  5ena  a  cooy of a'' papers  fi'ed to  -eicct-ar-


     f.    The attorney will  tnen secure tne warrant and forward it
          to tne inspector;  and/or tne U.S. Marshall.

5.    Inspections with a Warrant Should Comply with the Following:

     a.    Use of a Warrant to Gain Entry

          i.   If  tnere  is  a high probaoility  that  entry  will be
               refused  even witn  a  -arrant  or  wnere  tnere are
               threats of violence, tne inspector snould be accom-
               panied by a U.S. Marsnall.

         ii.   The inspector should  never himself/herself attemot
               to "make any  forceful  entry of  the  estaolishment.

        iii.   If  entry  is  refused   to  an  insu=:tor  holding   a
               warrant out not  accomoanied oy a U.i.  .Marsnal1, tne
               inspector snould leave  the establ i snent and inform
               the Enforcement  Attorney.

     b.    Conducting "he Inspection

          i.   The inspection must be  conducted str*ct!y in accor-
               dance  with  the   warrant.   If  t~e -arrant  restricts
               tne insoection  to  certain  areas of t.-.e premises or
               to  certain  records,   tnose  restrictions   .nust  oe
               adhered to.

         ii.   If  sampling  is   authorized,  all  procedures  must be
               carefully  followed including  presentation  of re-
               ceipts  for  all  samples taken.    The faci'ity snould
               also  be informed of 'its right  to  retain'a portion
               of  the  samples  octalned by  the  inspector.    •  •

        iii.   If  records  or property are authorized  to oe taken,
               tne insoector nust  provide  receipts and maintain an
               inventory  of  ali  items removed from  tne premises.

5.   Procedures to be  Fol'-wec  'Joon Completion  of  tne  Inspection

          i.   Whoever  exec-tad tne  -ar-ant must  s;gn tne Seturn-
               of-Servica  fom indicating on wnom tne warrant «as
               served  and tne  oata of  service.

              ii.    Tne executed warrant  must oe suomitted to the J.3.
                    Attorney  for  formal  return  to trie  issuing  -nagis-
                    trate or judge.
             iii.    An inventory of any items wnicn were taon fr:m  -,e
                    premises must  be sucmitted  to  tne  court,  ana  re
                    inspector  must  be  present  to   certify  tnat   ne
                    inventory is accurate and complete.


     The purpose of  tne  site insoection  is to ootain  information, aata, and
in some cases samples, to assess the prcolem  and to develop tne project plan
for a  field investigation.   If samples  are  collected, estaolished samp'ing
methods and Chain-of-Custocy procedures must  be  followed.  The data from tne
samples may be used in enforcement actions.

     The investigation must be thorough.  Do  not attempt to rush througn the
insoection.  The inspection  is complete only  wnen the  objectives are met and
tne inspector is satisfied  that all data  and  information nave been collected
to assess  tne  situation.   A careful  review  of  the  field  notes  is "ecuired
before leaving tne area to  ensure that  the cojecti.ts  have been met.

     3efore  tne inspection is completed,  tne  i.'soector   should  zreoare   a
sketcn  of  the  siw,  in  tne  logboc* if  possible,  locating fixed reference
points and  locations of disposal and storage.   If samoies are collected, tne
sample locations should be  marked on the  sketch.  Inventory of visible  crjms
snould be  made  where possible and also  located  on tr.e sketc.n.  The contents
of the  drums  will  prooaoly  be  different  than tne contents specified  on the
labels; nevertr.e less,  the labels may provide  useful information.

     In  addition   to   the  drum inventory,  the  inspector  should  cneck for
sewers, drains, spills or liquid disposal  and.evaluate the. runoff  ootantia'l.
The potential  for. fires, explosions,'  and other  imminent nazaras  snoula a.lso
be sva'uatad.   If  tne situation requires an  emergency resocnse,  tne Oil ana
Hazardous  Materials  Cocrai.-ator in  the Regional Office  sncu'.a oe  contacted
immediately.  Observations  of soils and  exaossd suosurface iiater;3:s  snoulc
be made.   However, care  sr.ou':  :e  taken net  to  hanale mater;als *nich  may  be

          APPENDIX C

                        COMPREHENSIVE GROUND WATER
                             PCRA FACILITIES
EPA  I.D. ft    	
TYPE OF FACILITY: (Checx one or more)


                  I.   Was plan subraitced Co RA or SO by 11/19/81?

                  2.   Was plan certified by qualified geologist or
                      geotechnical engineer?

                  3.   Does plan specify:

                           number, location and depth of wells. (Evaluate
                           using items 4 and 5, p. 2).

                           sampling and analytical methods for those hazardous
                           waste or hazardous waste constituents in the facility?
                           (Evaluate using item 2, p. 3).

                           evaluation procedures including previously gathered
                           groundwater quality information?

                           schedule for implementation?

                  4.   Was the plan implemented by 11/19/81?

                  5.   Did the plan define:

                           rate and extent of migration of hazardous waste or
                           hazardous waste constituents?

                           concentrations of constituents?

                  6.   Was a report, based on the results of the implemented plan,
                      submitted to the RA or SD in a timely manner (as soon as
                      technically feasible)?

                  7.   Has the owner/opera tor continued to monitor quarterly?

                  8.   Are records of the analyses and evaluations resulting
                      from implementation of this plan kept at the site?

                  9.   Is there evidence that the required annual assessment
                      report including calculaced or measured rate of migration
                      has been submitted to the RA or SD?

	            1.   Do records indicate that all wells consistently yield
                      samples of ground water for analysis (look, for "DRY" or
                      other similar notations)?

	            2.   Is there at least one well indicated as being located
                      hydraulically upgradient of the waste management area?

3.   Are thera ac lease three wells Indicated ua beluy Located
     hydrnulically downgradient of Che waste management area?
     (Note: In the case of extremely small units, one or more
     of tlu'MO wall.'' wy h.-wi: hocn w.itved.  If so documentation
     should be provided.  Is it?  Who granted the waiver?

4.   What was the basis for locating the wells:

          Only topographic considerations

          Geotechnical consultant/borings

          Other (Specify)

5.   Are there any records regarding well construction on

     If no records are available on construction, can the
     owner/operator or anyone else supply any or all ot
     the following information based on recollection?  If
     any of this information is available, please describe
     in a report to be attached to this inspection
     details of the following:

          How were wells bored?

          What considerations were given to screening, packing
          and selecting appropriate aquifer flow zones for

               First water

               Geotechnical consultants recommendation (what was
               basis for this recommendation).

               Other (Specify)

          Describe procedures and specifications for sealing
          the annular space above the screened interval.

          How were wells developed?

          Who drilled wells (name or company if available)?

               Water well driller.

               Ground water monitoring specialist.

               Other (Specify)

          What is type and size of casing?

          What type, size and length of screen?

          Was bottom of well capped?

                           What mcchod is used to deceroine  water  Level
                           elevations  iti wells?
                           Electric water marker
                           Steel tape 	
                           Air line 	
                           Other (explain)
                           How were  ground  elevations  at wells determined?


	            1.    Is  there a. ground  water  sampling and  analysis  plan at  the

	            2.    Does this  plan include adequate  procedures  and techniques

                           Sample collection

                                How  are  wells  purged and samples  obtained?

                                Air  lift pump  	
                                Submersible  pump 	
                                Positive  displace-ent  pump 	
                                Centrifugal  pump 	
                                Peristaltic  or other suction lift pump 	
                                Are  all we 113 sampled  with  the  same  equipment and
                                procedures?  (Y/N) 	 If not, explain 	
                                Are  provisions  included  to  clean  equipment after
                                sampling  to  prevent  cross-contamination between
                                wells?  (Y/N) 	

                                Arc  organic  constituents to be  sampled? (Y/N)  	
                                If yes:

                                Are  samples  collected with  equipment  to minimize
                                absorption and  volatilisation?  (Y/N)  	
                                Describe  equipment	

          Sample preservation and shipment.

               Have standard sample preservation procedures been
               followed (filtration and preservation where
               appropriate)? (Y/N) 	

               Are samples refrigerated? (Y/N) 	
               Are sample holding period requirements adhered to?

               Are suitable container types used?  (Y/N)  	
               Indicate type of containers used 	
               Are provisions made to- ship samples under cold
               conditions (ice packs, etc.)? (Y/N) 	

          Analytical procedures.

          - •   Reference Table 2-3, p. 61 & 62, SW-963, Revised
               March 1983, Groundwater Monitoring Guidance for
               Owners and Operators of Interim Systems Facilities.
               The procedures should be appropriate for drinking
               water or similar samples.

          Chain-of-custody control.

3..   Has the owner/operator completed the first years
     quarterly analyls for the parameters found at 265.92 (b)
     (i), (2) & (3)?

4.   Were all parameters included each quarter tor all wells?

          Check below and note any deficiencies.

     (b) (i)                (b) (2)               (b) (3)

	   Arsenic             	 Chloride          	  pH
     Barium                 Iron              	  Spec. Cond.
     Cadmium             	 Manganese         	  TOC
     Chromium           .	 Phenols           	  TOX
~  • Fluoride            	 Sodium           .     .         .  .
     Lead    •           	 Sulfate
~   Mercury
	   Nitrate (as N)

    (This column continued on next page)

 	   2,4,5-TP Silvex
 	   Gross Alpha
 	   Gross Beta
 	   Co11 form

 5.   Who does analyls?

 6.   Has this responsibility changed  during  sampling  history?

 7.   Were four  replicate measurements for the  (b)  (3)  para-
      meters taken at Che upgradient well (s)?

 8.   Is there documentation that the  wells were  in place  by

      If not when were they installed? 	

 9.   Was the 1st quarterly  sampling  done by February 19,
      1982?  -

10.   Was the last quarterly sampling  done by November 19,

11.   On what date did the first saai-annual  monitoring
      occur? 	  This date should not be later than May 19,
      (Note: After first year moni:oring is completed  the  (b)
      (1) parameters are dropped and the (b)  (2)  are sampled

 12.   Were four  replicates taken or made for  each well in  the

 13.   Were groundwater elevations determined  at each well
      before sampling?


 1.   Is there an outline of a groundwater quality assessment
      program at the facility?

 2.   Does it describe a n.ore comprehensive program than  that
      specified at 265.91 and .92?

3.   Does lc appear Co adequately describe a program capable
     of determining:

          Win-time li.i" i rd(jn;i W.TMCP or \\:\:::\ rdons W.TSC.J con-
          stituents have entered groundwacer?

          The race and extent of migration of hazardous waste
          or hazardous waste constituents in groundwater?

          The concentrations of hazardous waste or hazardous
          waste constituents in groundwater?

4.   After obtaining the first (and/or subsequent) semi-annual
     values and concentrations for (b) (3) parameters (replicated
     and meaned for each well) did the owner/operator do the
     comparisons using the Students c-test at the 0.01 level of

5.   If Che upgradienc comparison indicated a significant
     change in one of the (b) (3) parameters, did the owner/
     operator submit notice in required annual report, if

6.   If comparison of downgradient wells indicates significant
     change in (b) (3) parameters, did owner/operator immediately
     resample to verify?

7.   If che verification was positive, did owner/operator pro-
     vide wriccen nocice Co RA/SD within 7 days?

8.   Within 15 days of this notification, d\d the owner/operator
     submit an assessment plan, based on his outline, which

     _•   Number, location and depth of wells?

          Sampling and analytical methods for those hazardous
          waste or hazardous waste constituents in the facility?

          Evaluation procedures, including previously gathered
          ground water quality information?

          Schedule for implementation?

9.   If an assessment plan was implemented, was the rate
     and extent (both areal and vertical) of migration
     as well as the concentrations determined in a
     timely manner?

10.    Wore those determinations reported  within  15  days  to  the
      RA or SD?

11.    If the determination was  that  hazardous  waste or hazardous
      waste constituents  had/have  entered the  groundwater,  has
      the owner/operator  continued to  mnke  the determinations
      referenced in  No. 9 above on a quarterly basis?

 12.   Is there evidence or documentation  that  the groundwater
      elevations have  been evaluated annually  to assess gradient
      relationship of  the wells?


 1.    Does  owner/operator  have  records  of  1st  year quarterly
      analyses of 265.92 (b) (1)  (2)  &  (3)  parameters?

 2.    Does  owner/operator  have  records  of  annual analyses of
      (b) (2) parameters and semi-annual analyses of (b) (3)?

 3.    Does  owner/operator  have  records  of  the  groundwater
      elevation  measuremencs required at 265.92 (e)?

 4.    Is  there documentation of the  following  reporting  re-

           Timely submissions (within 15 days  of analysis) of
           the ana-lysis of the  parameters  at 265.92 (b)  (1)
           with  concentrations  above  the MCL highlighted?

           By March  _l_, concentrations or values for the  para-
           meters at 265.92 (b)  (3)  for each well, with  the
           statistical comparisons required at 265.93  (b).
           This  report should note situations  where changes
           in upgradient have occurred.

           JW March  _1_, groundwater elevation evaluations and
           responses when  required.
 RECORD KEEPING  AND  REPORTING.                 .

 1.    Has  the  owner/operator  kept records  of  the  analyses  and
      evaluations  specified in the plans?

     Has che owner/operator, by March 1 of each year submitted
     the required report to the RA or SD which, at a minimum
     includes the calculated or measured rate of migration of
     hazardous waste or constituents in the groundwater during
     the reporting period?

1.   Are the wells located where they appear on any
     drawings or documents at the facility (Part A for

2.   Do all the wells appear to be of the same construction
     and/or as indicated in facility records?

3.   Are they capped or otherwise protected to prevent  vanda-
     lism or accidental introduction of contaminants?

4.   Does there appear to be an adequate number of wells  to
     monitor the facility?

5.   Does the upgradient well appear to be unaffected by  the
     facility (consider spills as well as proper gradient



SITE: ___^^_^__^_^_______^^_— PROJECT HO:
Location:  	 Region:  _
Primary Contact:   __	Phon« No.:
Plan Prepared By:  	Date:  	
Proposed Date of Investigation:              •	;	
Background Review is:      Complete:   	  Preliminary:
                                      State  has additional site data.
overall Hazard is:         High:       	   Moderate:  _
                           Low:        	   Unknown:	
Principal Operations:
 unusual Features (containers, buildings, dikes,  power  lines, terrain, etc.):
 History  (worker or non-worker injury, complaints from public,  previous agency

 Project  Manager:
Health Safety  Manager:


 Known or suspected materials,  contaminated  media,  storage container, etc.

 Circle which wastes are present and estimate  the  amount of waste  by category.

 Amount    Amount

 Unit of   Unit of
 Measure   Measure

 Paint     Oily
 Pigments  Wastes

 Metals    Other
 Sludges   (Specify):



Unit of
Unit of
Unit of
Unit of
Solvents         Liquors








                             Ferrous smelt-  Municipal


List known substances on the site
1.   Substance
   2.   Form
                                              3.  Toxicitv
                                             Amount*  Unit
                 Solid  Liquid  Vapor    High  Ned.  Low  None

Describe  hazards  talcing into account toxic and pharmacologic effects.
reactivity,  stability,  flannability, operational concerns,  sampling,
decontamination,  etc.

Peri««ter Establishment:    Hap/Skttch Attached  	  site Secured?
      Perimeter Identified 	  Zones of Contamination Identified
Personal Protection
Level of Protection Required:   A 	  B 	C 	D 	B_
Modifications:  	.
Level A  should be selected when  the highest  level of respiratory, skin,
eye, and mucuous membrane protection is needed.  The personal protection
equipment  required at Level A  includes:

    •  Positive-pressure  (pressure  demand), self contained breathing  apparatus
       (HSHA/NIOSH approved).
    •  Pully-encapsul-ating chemical resistant suit  (OSHA  response  suit).
    •  Cloves,  inner, chemical resistant.
    •  Boots, chemical  resistant, steel toe and shank (depending on suit  boot
       construction, worn over or under suit  boot).
    •  Underwear, cotton,  long-John type.  (Optional)
    •  Socks, cotton.
    •  Coveralls, cotton  (undersuits).   (Optional)
    •  Hard hat (under  suit).   (Optional)
    •  Nonsparking  tools.
    •  Explosion-proof  lantern.
    •  Two-way  radio communications (Intrinsically safe).
    •  Personal radiation detectors.

Level B  protection should be selected when the highest level of respiratory
protection la needed, but a lesser level of skin and eye protection.   Level B
protection Is the minimum level recommended on Initial site entries until
hazards have been further Identified and defined by monitoring,  sampling,  and
other reliable methods of analysis, and personnel equipment corresponding  with
thosv findings utilized.  The personal protection equipment required  at
Lewi B Includes:

    •  SCBA unit.
    •  Chemical resistant clothing (Neoprene splash suits or Saranex
    •  Gloves, outer, chemical resistant.
    •  Gloves, inner, chemical resistant.
    •  Boots, outer, chemical resistant, steel toe and shank.
    •  Boots, outer, chemical resistant. (Optional)
    •  Two-way radio.
    •  Hard hat. (Optional)

Level C  protection should be selected when the  type of airborne contaminant
is known, its concentration measured, criteria for using air purifying
respirators met. and when skin and eye exposure  is likely.  Periodic air
monitoring must be performed.  The personal protection equipment required  at
Level C includes:

    •  Pull-face, air-purifying  respirator  (MSHA/NIOSH approved).
    •  Chemical resistant clothing  (splash  suit, Saranex,  Tyvek).
    •  Gloves, outer, chemical resistant.
    •  Boots, chemical  resistant,  steel  toe and  shank.
    •  Boots, outer, chemical  resistant.   (Optional)
    •  Cloth  coveralls  (inside chemical  resistant  clothing).  (Optional)
    •  Two-way  radio.
    •  Hard hat.  (Optional)

Level 0  protection should be selected when skin and eye exposure is
unlikely, but when the type of airborne contaminant is known,  concentration
measured, and criteria for using half-face respirators net.  Periodic air
monitoring must be performed.  Level D personal equipment requirements include:

    •  Half-face air purifying respirator (MSHA/NXOSH approved).
    •  Single-use respirator (MSHA/NXOSH approved).  (Optional)
    •  Hard hat.  (Optional)
    •  Boots, steel toe and shank,  (optional)

Level B protection is designed for use when only skin and  eye protection is
needed and airborne contamination is unlikely.  Personal equipment
requirements for Level B  include:

    •  Hard hat (face shield).
   . •  Goggles or safety  glasses.
    •  Gloves, chemical resistant.  (Optional)
    •  Work gloves.
    •  Coveralls, long sleeve.
    •  Bar protection.   (Optional)
    •  Oust respirator.   (Optional)

Level  P  is primarily  a work uniform.   It should not be  assigned at  any site
where  respirator or skin  hazards exist.

Surveillance  equipment  and materials  needed to monitor  the site for identity
and concentration of  contamination:   	

Medical surveillance procedures for evidence of personnel exposure:

	  Level A - Segregated equipment drop, boot cover and glove wash, boot
cover and glove rinse, tape removal, boot cover removal, outer glove removal,
suit/safety hat removal, SCBA backpack removal. Inner glove wash, inner glove
removal, inner clothing removal, field wash, redress.

	  Level B - Segregated equipment drop, boot cover and glove wash, boot
cover and glove rinse, tape removal. boot cover removal, outer glove removal,
suit/safety boot wash, suit/SCBA/boot/glove rinse (tank change), safety boot
removal (splash suit removal) SCBA  backpack removal, inner glove wash, inner
glove rinse, faceplece removal, inner glove removal, inner clothing removal,
field wash, redress.
	  Level C - Segregated equipment drop, boot cover and glove wash, boot
cover and glove rinse, tape removal, boot cover removal, outer glove removal.
suit/safety boot wash, suit/safety  boot  rinse  (Canister or Mask Change),
safety  boot removal, splash suit removal, inner glove wash, inner glove rinse.
facepiece removal,  inner glove  removal,  inner  clothing  removal,  field  wash

	  Level D - Segregated equipment drop, boot and  glove wash, boot and
glove rinse.

        Level B - No formal decontamination required.

Decontamination Modification (personnel  surfaces,  materials,  instruments.
equipment, etc.):  	_	
Disposal Procedures (contaminated equipment,  supplies,  disposable washwater)

Overt Personnel Exposure:

Skin Contact:        ..

Potential or Actual fire or Explosion:
Call Pire Department: Phone:      	
Call Police: Phone:               	

Personnel Injury:

Call Ambulance/Hospital: Phone:   	
Call Versar Office: Phone:        	703-750-3000

Hospital Emergency Roon
Poison Control Center
Pire Department
Explosive Ordinance Disposal Unit
EPA Contact
State Contact
Site Water Supply
Site Telephone
site Radio
Site Other


     Personnel  authorized  to enter  HWS         Assignment           TLP  Badge  Mo.

            APPENDIX E


                                     EXAMPLE PHASED ORDER
     Pursuant to Section(s)  _ of the Resource  Conservation  an<-* s
(RCRA),  42 fJ.S.C. 69 _ ,  it is ordered t~at _ shall  ccnply witr, the
      within _ calendar davs  of  the eff> rtive  date of  this ORDER, respondent
      shall develop and submit for EPA aoproval a plan  for conductino a hydro-
      geologic investigation of the site.   The  plan should be designed to
      provide the  following information:

      a.   A description of  the regional geologic and hydrogeologic characteristics
          in the vicinity,  including:

             1)   local  stratioraphy (soil  and unconsolidated sediment  :over,
                 bedrock, structural features,  and formation origins)

             2)   regional hydrogeoloaic flow patterns

             3)   areas  of recharge and discharge
      b.   An  analysis  of  any topograohic or qeomorohic features  that  miaht
          influence  the around  water flow system (Note that  stereoscopic  ana I vs is
          of  aerial  photographs should aid in this  analysis).

      c.   A classification and  descript jn of the hydroceoloaic  properties  of
          all the  hydrogeologic units found at the  site (i.e., the  aouifers anrt
          any intervening saturated and unsaturated units),  includincr

             1)  hydraulic conductivity, porosity

             2)  texture, uniformity, Ixtholoqy

             3)  an  interpretation of hyaraulic interconnections between
                saturated zones

       d.  Using a topographic  map as a oa»e, isooach and structural  contour
          maps and  at least two geologic cross sections showing the  extent
           (depth, thickness,  lateral extent) of all hydrogeologic  units  within
          the facility property, identifying:

             1)  sand  and gravel deposits in unconsolidated  deposits

             2)  zones of significant fracturing or channeling  in consolidated

             3)  zones of higher oermeanil ity or lower oermeatulity that  micr.t
                direct or restrict the flow of contaminants

             4)  perched  aquifers

           5)  the uppernoct aauifer (Defined as the first saturated zone
               that may have a potential for miaration of contaminants)

    e.  A description of water level or fluid pressure monitoring including:

           1)  water level contour maps and vertical gradient sections

           2)  well or piezometer hydrographs

           3)  an interpretation of the flow system, including the
               vertical and horizontal components of flow

           4)  an interpretation of any change in hydraulic gradients

    f.  A desciption of marinade influences that may affect the hydrogeology of
        the site, identifying:

           1)  local water-supply and production wells with an approximate
               schedule of pumping

           2)  manmade hydraulic structures {pipelines, french drains, ditches1

    The plan should include a description of the field methods and other infor-
mation sources proposed for the study and a summary of which data will be col-
lected by each method.  The proposed methods should include, but are not
limited to:                               •

    a.  A program of soil borings, as reguired to adeguately describe
        the subsurface geology of the site. The proqram should provide
        for the presence of a oualified geologist or oeotechnical
        engineer to log and describe the materials encountered during
        the boring.  The program should also describe the methods pro-
        posed to stabilize selected holes until monitoring wells are

    b.  A sufficient number of piezometers to characterize around-water
        depth and gradient (both horizontal and vertical) over the
        entire area of the site.

    c.  The use of slug and/or pump tests as appropriate to determine
        hydraulic conductivities

    The plan shall contain a schedule for conducting the proposed hydrogeolgogic
    assessment and shall be submitted to:

                 Deputy Director, Air and Waste Management Division
                 Environmental Protection Agency
                 444 RCRA Way
                 Anytown, USA 00001

2.  Within 15 calendar days of the effective date of this ORDER, respondent shal'.
    develop and submit to EPA a list of proposed indicator parameters caoable of
    detecting leakaae of hazardous waste or hazardous constituents into ground

      water.   The parameters  should  be  representative of constituents at least as
      mobile  as  the most mobile  constituents  that could reasonably be derived frcn
      the facility's waste, and  should  be  chosen after considering:

      a.   the types, Quantities,  and concentrations of constituents in wastes
          managed at the  facility;

      b.   the mobility, stability, and  persistence of waste constituents or their
          reaction products in the unsaturated zone beneath the waste management

      c.   the detectaMlitv of the indicator  parameters, waste constituents or
          reaction products in ground water;

      d.   the concentration or value and the  natural variation (known or suspected)
          of  the proposed monitoring parameter in background around water.

      The list should  include the basis for selecting each prcoosed indicator
      parameter,  including any analyses or calculations performed.  The basis
      for selection must  include  chemical  analysis of the facility's waste and/or
      leachate as appropriate.

      The list should  also include parameters to characterize the site-specific
      chemistry  of ground water  at the^site,  including but not limited to the  .
      major anions and cations that  make up the bulk of dissolved solids in
      water (i.e.,  Cl~, Fe, Mn,  Ma*, S04,  Ca+, Mg*, K* 'XD'3, P04*, silicate,

3.  within 	 calendar days of written  approval by EPA, the respondent shall
   prorotly  implement the nydrogeoloaic assessment plan according to the
   terms and schedules contained therein.

4.  Within 	 calendar days after completion  of the hydroceoloaic investigation,
   the respondent will submit to EPA a full  report that provides the information
   described in paragraph 1.

5.  Also  within	days after the completion  of the hydroaeologic investigation, .
   the respondent will submit to EPA a plan  for the design and  installation of
   a  monitoring well  network that will meet  the following requirements:

   a.  The upgradient wells must be capable  of yielding samples that are
       representative of background water quality in the uppermost aguifer
       and are  not affected  by  the  facility. The number and location of the
       wells must be  sufficient tot. 1) characterize the spatial variability
       of background  water;  and 2)  meet the  needs of the statistical test
       proposed pursuant to  paragraph  	.

   b.  The downgradient wells must  be  capable of  immediately detectina any
       statistically  significant amounts  of  hazardous waste or  hazardous
       constituents that miorate from  the facilty into ground water.

   c. The monitoring system should be designed to operate  for  a period of no
       less  than thirty years.


  The plan should include che followina elements:

    a.  A description and map of proposed well locations, includino a survey
        of each well's surface reference point and the elevation of its ton
        of casino.

    b.  Size and depth of wells;

    c.  Desciption of well-intake design, includina screen slot size and lengtw
        filter pack materials and method of filter-pack emplacement.

    d.  Type of proposed well casing and screen materials.  The choice of wel
        materials should be made in light of the parameters to be monitored foi
        and the nature of the leachate that could potentially migrate fron the
        facility.  The well materials should: 1) minimize the potential of
        adsorption and desorotion of constituents fron the samples; aprt
        2) maintain their integrity for the exoected life of the syst«?r
        (at least thirty years).

    e.  Methods used to seal the well fron the surface and prevent downward
        migration of contaminants through the well annulus.

    f.  Description of the methods or procedures used to develop the wells.

    When developing this plan, the Respondent shall refer to the Technical
    Enforcement Guidance Document (EPA, 	 1985) to determine the methods
    and materials that are acceptable to the Agency.

6.  Also within	 davs after the completion of the hvdrogeolccic assessment,
    the Respondent shall sumbit a sampling and analysis plan capable of
    yielding representative samples for a comparison of UD- and downgradient
    wells.  The plan should include the following elements:

    a.  Well evacuation procedures including volume to be evacuated prior to
        sampling and handling procedures for purged well water

    b.  Sample withdrawal tecnnigues.  Sampling ecuipment and materials (tubinr.
        rope, pumps, etc.) shall be selected to yield representative samples ir
        light of parameters to be monitored for.  The sampling protocol will
        include field measurement of pH, conductivity, and temperature for
        each sample.

    c.  Sample handling and preservation technioues including provision for
        field-filtration of samples as appropriate.

    d.  Procedures for decontaminating sampling equipment between sampling event.

    e.  Procedures for measuring ground-water elevations at each sampling event

    f.  Chain of custody procedures to be used for all phases of sample managers -

    q.  Laboratory analytical techniaues, -includim FPA-annroved analytical
        methods and ouality assurance, ouality control orocedures.

    h.  Procedures for performing a cmarison of unoradient and downgradient
        ground water to determine whether contamination has occurred.   The nro-
        cedures should include:

         •  1)  A proposed method (statistical or otherwise) to compare up-
               qradient and downdradient well water that provides a reasonable
               balance between the probability of falsely identifying  and
               failing to identify contamination.

           2)  An accelerated samplim schedule to establish data for  the
               comparison.  In no instance shall sampling exceed 	 months.

           3)  A proposed method for data organization and presentation.

    When developing the sample and analysis plan and data presentation for-
    mat, the Respondent should propose methods deemed acceptable in the
    Technical Enforcement Guidance Document (EPA, April 1985).

7.  By no later than 	 davs after EPA approval of the well network plan,
    Respondent shall complete the installation of the well network.

8.  By no later than 	 davs after the installation of the monitoring  network,
    Resoondent shall implement the sample and analysis plan, perform the
    comparison and submit the results to EPA for review.
9.   If there is a statistically significant difference between ungradient  and
    downgradient well water, the Respondent will develop a ground-water asses-
    sment plan capable of determining the following:

    a.  The extent of migration of hazardous constituents into around water

    b.  The concentration of each Appendix VTII constituent throughout the
        plume or the maximum concentration of earh Appendix VTII in the

    c.  Background concentrations for all Appendix VIII constituents detected
        in ground water.

    d.  Waste/leachate characteristics including specific gravity,  viscosity,
        solubility in water, and octanol-water partition coefficient.

    e.  Soil properties including cation exchange capacity, organic content,
        and temperature.

    The plan should describe the methods oroposed to accomplish the above
    objectives including  indirect and direct techniques.  The sampling and
    analysis plan developed pursuant to paragraph fi should be revised to meet

      the new objectives of this monitoriro nhase.  The nlan should include an
      expeditious schedule for the implementation of the above assessment, anc4
      should be submitted to EPA no later than 15 days after the confirmation

10.   Within _^ calendar days of F3>A approval of the assessment plan,  the Resc-
      will begin to execute the plan according to the terms and schedules cont
      therein.  Within 	 days of the completion of the assessment, the Respor
      will submit the results to the Agency, including all raw data collected,
      calculations performed, and an interpretation of the findings.

11.   Based on the results of the study, the Respondent will fulfill his/her
      informational obligations pursuant to S270.14(c)(7)  or (8) and suonit the
      results to EPA no later than 	 months after the completion of  the
      ground-water assessment described in paragraph nine.

12.  All plans, reports, and schedules required by the terms of this ORDER are,
     upon approval by EPA, incorporated into this ORDER.  Any nonconpliance wi
     such approved studies, reports, or schedules shall be termed noncompliance
     with this ORDER.

13.  In the event of Agency disapproval (in whole or in part) of any plan requ.r
     by this ORDEP, EPA shall specify any deficiencies in writing.  The ^esponde
     shall modify the plan to correct the deficiencies within __ days from rec
     of disapproval by EPA.  The modified plan shall be submitted to EPA in
     writing for review.

     Should the Respondent take exception to all or part of EPA's disapproval, -
     Respondent shall submit to EPA a written statement of the grounds for the
     exception.  Representatives of EPA and the Respondent may confer in perso-
     or by telephone- in an attempt to resolve any disagreement.  If aareenenc
     is reached, the resolution shall be reduced to writing and signed bv
     representatives of each party.  In the event that resolution is not
     reached within 15 days, the Respondent shall modify the plan as requirec
     by EPA.

14.  In the event that EPA believes the respondent has failed to:

     a.  Comply with the milestones contained in paragraphs 3, 7, a, or 10;

     b.  Provide the plans and information described in paragraphs 1,  2, 4, 5,
         6, 9t 9, 10, or 11;

     EPA will notify the respondent of the failure and shall provide the.
     respondent fifteen days in which to remedy the failure.  If the resp-.ndert
    'does not remedy the failure within fifteen days, (s)he shall nay stipulate
     penalties from the date of the violation as follows:

     a.  S500.00 per day for failure to comply with a milestone listed above;

     b.  S100.00 per day for failure to provide a plan or  information listed abc

15.   Notwithstanding  ccrnliance with fie terms of this ORDER,  Pesoondent nav
     be  required to take further actions as necessary, inc.ludina additional
     qround-water ronitorina and/or assessment, to ccm<» into conpliance
     with RCRA,  or  other applicable state of Federal law.


Abatement Action

     Sec. 106(a) In addition to any other action taken by a State or local
government, when the President determines that there may be an imminent and
substantial endangerment to the public health or welfare or the environment
because of an actual or threatened release of a hazardous substance from a
facility, he may require the Attorney General of the United States to secure
such relief as may be necessary to abate such danger or threat, and the
district court of the United States in the district in which the threat
occurs shall have jurisdiction to grant such relief as the public interest
and the equities of the case may require.  The President may also, after
notice to the affected State, take other action under this section
including, but not limited to, issuing such orders as may be necessary to
protect public health and welfare and the environment.
     (b) Any person who willfully violates, or fails or refuses to comply
with, any order of the President under subsection (a) may, in an action
brought in the appropriate United States district court to enforce such
order, be fined not more than $5,000 for each day in which such violation
occurs or such failure to comply continues.
     (c) Within one hundred and eighty days after enactment of this Act,  the
Administrator of the Environmental Protection Agency shall, after consulta-
tion with the Attorney General, establish and publish guidelines for using
the imminent hazard, enforcement, and emergency response authorities of this
section and other existing statutes administered  by the Administrator of
the Environmental Protection Agency to effectuate the responsibilities
and powers created by this Act.  Such guidelines shall to the extent
practicable be consistent with the national hazardous substance response
plan, and shall include, at the minimum, the assignment of responsibility
for coordinating response actions with the issuance of administrative
orders, enforcement of standards and permits,  the gathering of
information, and other imminent hazard and emergency powers authorized by
(1) sections 311(c)(2),  308,  309, and 504(a) of  the Federal Water
Pollution Control Act, (2) section 3007, 3008,  3013, and  7003  of  the
Solid Waste Disposal Act,  (3)  sections 1445 and  1431 of  the Safe  Drinking

Water Act, (4) sections 113 and 114, and 303 of the Clean Air Act,  and
(5) section 7 of the Toxic Substances Control Act.
RCRA 3007


     Sec. 3007. (a) ACCESS ENTRY.--For purposes of developing or assisting
in the development of any regulation or enforcing the provisions of this
title, any person who generates, stores, treats, transports, disposes of, or
otherwise handles or has handled hazardous wastes shall, upon request of any
officer, employee or representative of the Environmental Protection Agency,
duly designated by the Administrator, or upon request of any duly designated
officer, employee or representative of a State having an authorized hazar-
dous waste program, furnish information relating to such wastes and permit
such person at all reasonable times to have access to, and to copy all
records relating to such wastes.  For the purposes of developing or
assisting in the development of any regulation or enforcing the
provisions of  this title, such officers, employees or representatives
are authorized --
      "(1) to enter at reasonable times any establishment or other place
where hazardous wastes are or have been generated, stored, treated, disposed
of, or transported from;
      "(2) to inspect and obtain samples from any person of any such wastes
and samples of any containers or labeling for such wastes.  Each such
inspection shall be commenced and completed with reasonable promptness.   If
the officer, employee or representative obtains any samples, prior to
leaving  the premises, he shall give  to  the owner, operator, or agent in
charge a receipt describing the  sample  obtained and if requested a portion
of each  such sample equal  in volume  or  weight to the  portion retained.   If
any analysis is made of such samples, a copy of the results of such analysis
shall be furnished promptly to  the owner, operator, or agent in charge.
      "(b) Availability To  Public  (1) Any records, reports,  or information
obtained from  any person under  this  section shall be  available  to  the  pub-

lie,  except chat upon a showing satisfactory to the Administrator (or the
State, as the case may be) by any person that records,  reports,  or informa-
tion, or particular part thereof, to which the Administrator (or the State,
as the case may be) or any officer,  employee or representative thereof has
access under this section if made public,  would divulge information entitled
to protection under section 1905 of title  18 of the United States Code,  such
information or particular portion thereof  shall be considered confidential
in accordance with the purposes of that section,  except that such record,
report, document, or information may be disclosed to other officers,
employees, or authorized representatives of the United States concerned
with carrying out this Act, or when relevant in any proceeding under this
     "(2) Any person not subject to the provisions of section 1905 of title
18 of the United States Code who knowingly and willfully divulges or dis-
closes any information entitled to protection under this subsection shall,
upon conviction, be subject to a fine of not more than $5,000 or to
imprisonment not to exceed one year, or both.
     "(3) In submitting data under this Act, a person required to provide
such data may - -
     "(A) designate the data which such person believes is entitled to
protection under this subsection, and
     "(B) submit such designated data separately from other data submitted
under this Act.
A designation under this paragraph shall be made in writing and  in such
manner as the Administrator may prescribe.
     "(4) Notwithstanding any limitation contained in this section or any
other provision of law, all information reported to, or otherwise obtained
by,  the Administrator (or any representative of the Administrator) under
this Act shall be made available, upon written request of any duly author-
ized committee of the Congress to such committee (including records, re-
ports, or information obtained by representatives of the Environmental
Protection Agency).
RCRA 3008(a)

Federal Enforcement

     "Sec. 3008 (a) Compliance Orders.-- (1) Except as provided In paragraph
(2), whenever on the basis of any information the Administrator determines
that any person is in violation of any requirement of this subtitle,  the
Administrator may issue an order requiring compliance immediately or  within
a specified time period or the Administrator may commence a civil action in
the United States district court in the district in which the violation
occurred for appropriate relief, including a temporary or permanent injunc-
     "(2) In the case of a violation of any requirement of this subtitle
where such violation occurs in a State which is authorized to carry out a
hazardous waste program under section 3006, the Administrator shall give
notice to the State in which such violation has occurred prior to issuing an
order or commencing a civil action under this section.
     "(3) If such violator fails to take corrective action within the time
specified in the order, he shall be liable for a civil penalty of not more
than $25,000 for each day of continued noncompliance and the Administrator
may suspend or revoke any permit issued to the violator (whether issued by
the Administrator or the State).
RCRA 3013

Monitoring, Analysis, and Testing

     "Sec 3013(a) Authority of Administrator.-- If the Administrator deter-
mines, upon receipt of any information, that  --
     "(1) the presence of any hazardous waste at a facility or site at which
hazardous waste  is, or has been, stored, treated, or disposed of, or
     "(2) the release of any such waste from  such facility or site may
present a substantial hazard to human health  or the environment, he may
issue an order requiring the owner or operator of such facility or site  to
conduct such monitoring, testing, analysis, and reporting with respect

to such facility or site as the Administrator deems reasonable to ascertain
the nature and extent of such hazard.
     "(b) Previous Owners and Operators --In the case of any facility or
site not in operation at the time a determination is made under subsection
(a) with respect to the facility or site,  if the Administrator finds  that
the owner of such facility or site could not reasonably be expected to have
actual knowledge of the presence of hazardous waste at such facility  or site
and of its potential for release, he may issue an order requiring the most
recent previous owner or operator of such facility or site who could
reasonably be expected to have such actual knowledge to carry out the
actions referred to in subsection (a).
     "(c) Proposal --An order under subsection (a) or (b) shall require the
person to whom such order is issued to submit to the Administrator within 30
days from the issuance of such order a proposal for carrying out the
required monitoring, testing, analysis, and reporting.  The Administrator
may, after providing such person with an opportunity to confer with the
Administrator respecting such proposal, require such person to carry out
such monitoring, testing, analysis, and reporting in accordance with such
proposal, and such modifications in such proposal as the Administrator deems
reasonable to ascertain the nature and extent of the hazard.
     "(d) Monitoring, Etc., Carried Out By Administrator.  --  (1) If the
Administrator determines that no owner or operator referred to in subsection
(a) or (b) is able to conduct monitoring, testing, analysis,  or reporting
satisfactory to the Administrator, If the Administrator deems any such
action carried out by an owner or operation  to be unsatisfactory, or  if  the
Administrator cannot initially determine that there  is an  owner or operator
referred to in subsection  (a) or  (b) who is  able to  conduct such monitoring,
testing, analysis, or reporting, he may --
     "(A) conduct monitoring, testing, or analysis  (or any combination
thereof) which he deems  reasonable  to ascertain  the  nature and extent  of the
hazard associated with  the  site  concerned, or
     "(B) authorize a State  or "local authority or  other person to carry  out
any such action,and require, by  order, the owner or  operator  referred to in
subsection  (a) or  (b) to reimburse  the Administrator or other authority  or
person for  the costs of such activity.
     "(2) No order may  be  issued under this  subsection requiring

reimbursement of the costs of any action carried out by the Administrator
which confirms the results of an order issued under subsection (a)  or (b).
     "(3)For purposes of carrying out this subsection,  the Administrator or
any authority or other person authorized under paragraph (1) may exercise
the authorities set forth in section 3007.
     "(e) Enforcement.-- The Administrator may commence a civil action
against any person who fails or refuses to comply with  any order issued
under this section.  Such action shall be brought in the United States
district court in which the defendant is located, resides, or is doing
business.  Such court shall have jurisdiction to require compliance with
such order and to assess a civil penalty of not to exceed $5,000 for each
day during which such failure or refusal occurs.
RCRA 7003

Imminent Hazard

"Sec. 7003(a) Authority of Administrator
     Notwithstanding any other provision of this Act, upon receipt of
evidence that the handling, storage, treatment, transportation or disposal
of any solid waste or hazardous waste may present an imminent and
substantial endangerment to health or the environment, the Administrator may
bring suit on behalf of the United States in the appropriate district court
to immediately restrain any person contributing to such handling, storage,
treatment, transportation or disposal to stop such handling, storage,
treatment, transportation, or disposal or to take such other action as may
be necessary.  The Administrator  shall provide notice to the affected State
of any such suit.  The Administrator may also, after notice to the affected
State, take other action under this section including, but not limited to,
issuing such orders as may be necessary to protect public health and the
     "(b) Violations  -- Any person who willfully violates, or fails or
refuses to comply with, any order of the Administrator under subsection  (a)
may, in an action brought in the  appropriate United  States district court to

enforce such order, be fined not more than $5,000 for each day in which
such violation occurs or such failure to comply continues.