United Stales
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
OSWER Directive 9345.1-02
October 1987
Superfund
vvEPA
Expanded Site Inspection
Transitional Guidance
For Fiscal Year 1988
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EXPANDED SITE INSPECTION (ESI) TRANSITIONAL GUIDANCE
FOR FY 1988
OSVER Directive 9345.1-02
U.S. Environmental Protection Agency
Office of Emergency and Remedial Response
401 M Street, SV
Washington, DC 20460
October 1987
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OSVER Directive 9345.1-02
NOTICE
The information in this document has been funded, wholly or in part, by
the United States Environmental Protection Agency under Contract
No. 68-01-7347 to Ecology and Environment, Inc. It has been subject to
peer and administrative reviev and has been approved for publication as
an EPA document.
This document is intended to present guidance on the conduct of expanded
site investigations to obtain data to determine if there has been a
release or potential for release of contaminants to the environment
serious enough to varrant expenditure through the national Superfund.
ii
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OSVER Directive 9345.1-02
PREFACE
This Expanded Site Inspection (ESI) - Transitional Guidance manual
is designed to provide the reader vith a consolidated ready reference of
general methodologies and activities for conducting site inspection vork
on sites projected to make the National Priorities List (NPL). The
manual has been compiled, vith substantial input from EPA Regional
pre-remedial staff, and contains procedures that have been used
successfully to execute EPA site investigation vork nationvide.
The "new" pre-remedial program under the Superfund Amendments and
Reauthorization Act (SARA) is evolving and in a state of flux. It vill
remain in flux until final promulgation of both the revised Hazard Rank-
ing System (HRS) and the "nev" National Contingency Plan (NCP). As
discussed in Chapter 1, the ESI concept first proposed in Fall 1986 is
being modified; hence the term "transitional" in the title.of this
manual. Progress is being made, hovever, to establish a more standard-
ized and efficient program for evaluating hazardous vaste sites through-
out the country. This guidance, is applicable for FY 1988 and vill be
superseded vhen final guidance is issued on conducting Sis under the
revised HRS.
When following document guidelines, the reader must realize that
every hazardous vaste site is unique and every vork assignment is dif-
ferent. Not all methodologies and activities discussed in this guidance
vill be applicable to all sites. In addition, many of the described
procedures vill undoubtedly vary somevhat from region to region.
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OSVER Directive 9345.1-02
CONTENTS
PAGE
CHAPTER SUMMARY 1-1
CHAPTER 1 INTRODUCTION 1-2
1.1 Purpose and Use 1-2
1.2 Changes to the ESI Concept 1-2
1.3 ESI Objectives 1-4
1.4 Comparison of Sis and ESIs 1-5
1.5 References 1-9
CHAPTER SUMMARY 2-1
CHAPTER 2 ESI DATA QUALITY OBJECTIVES 2-2
2.1 Introduction 2-2
2.2 DQO Development Process 2-2
2.3 ESI DQO Stage 1 - Identification of Decision Types .. 2-4
2.4 ESI DQO Stage 2 - Identification of Data Uses/Needs.. 2-10
2.5 References 2-16
CHAPTER SUMMARY 3-1
CHAPTER 3 PREPARATION OF ESI WORK PLANS, SAMPLING PLANS, AND
HEALTH AND SAFETY PLANS 3-3
3.1 Introduction 3-3
3.2 Work Plan 3-3
3.3 Sampling Plan 3-6
3.4 Health and Safety (HiS) Plan 3-12
3.5 References 3-14
CHAPTER SUMMARY 4-1
CHAPTER 4 FIELD INVESTIGATION PROCEDURES 4-3
4.1 Introduction 4-3
4.2 Approach to Site Characterization 4-3
4.3 Technical Investigations 4-6
4.4 Investigation Techniques 4-10
4.5 References 4-17
CHAPTER SUMMARY 5-1
CHAPTER 5 ESI SUPPORT TO RI SCOPING AND DEVELOPMENT OF RI
WORK PLAN 5-2
5.1 Existing and ESI Site Data 5-2
5.2 Limited Field Investigation 5-3
5.3 Preliminary Evaluation of Potential Impacts 5-4
5.4 Community Relations and Enforcement Support 5-4
5.5 References 5-5
CHAPTER SUMMARY 6-1
CHAPTER 6 DATA EVALUATION OPTIONS AND ESI REPORT FORMAT 6-2
6.1 Data Evaluation Options 6-2
6.2 Report Format 6-3
6.3 Turnover Meeting 6-3
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OSVER Directive 9345.1-02
ACKNOWLEDGMENTS
This document vas developed under direction of the Office of
Emergency and Remedial Response. Paul Beam (EPA, HSED) served as EPA
project director. Jeff Tuttle of Ecology and Environment, Inc. served as
TOD project manager. A Work Group vas formed to provide input from
various EPA Regions and HQ programs, and to comment on draft guidance as
it developed. This group consisted of the following individuals:
Amy Brochu (Region 2)
Carol Bronick (OVPE)
DeCarlo Ciccel (Region 6)
Steve Hooper (OERR)
Bob Jourdan (Region A)
Ken Kryszczun (Region 3)
Mike Nalipinski (Region 1)
Carole Petersen (Region 2)
Jeff Rosenbloom (Region 9)
Dave Schutz (OVPE)
Helpful suggestions and comments on drafts were provided by the
following:
Paul Clay (NUS Corporation)
Bob Ogg (CH2M Hill)
Steve Paquette (COM, Inc.)
Bob Stecik (NUS Corporation)
Neil Teamerson (NUS Corporation)
vii
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OSVER Directive 9345.1-02
CHAPTER 1 SUMMARY
VHAT IS THE PURPOSE OP THIS GUIDANCE? WHAT ARE THE OBJECTIVES AND
BENEFITS OP CONDUCTING EXPANDED SITE INSPECTIONS (ESIs)?
o ESI - NEW COMPONENT OF THE PRE-REMEDIAL PROGRAM
- Provides additional support to HRS scoring
- Supports scoping of remedial investigation (RI) and development
of RI work plan
- Shortens remedial planning process
o CHANGES TO THE ESI CONCEPT
"New" pre-remedial approach encompasses a tvo-tiered SI process
* Medium priority equivalent to Screening SI (SSI)
* High priority equivalent to Listing SI (LSI)
- FY 1988 ESIs equivalent to LSIs under the revised HRS and NCP
- Principal LSI objective - score site under the revised HRS;
secondary objective - provide scoping support to the RI program
o ESI VERSUS "TRADITIONAL" SI
Collects more comprehensive site background and chemical
contamination data
- Uses more resources (i.e., LOE hours, sample dollars) on high
priority sites
- Uses field analytical screening methods, soil borings, monitoring
veils, and surface geophysical techniques to characterize sites
o ESI - RECOMMENDED LEVEL OF RESOURCES
- Total level of effort: 1500 hours
- Number of Contract Laboratory Program samples: 20-303
A
- Number of monitoring veil installations: 3-6
aPredicted averages. Actual numbers vill vary on' a site-specific basis.
1-1
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OSVER Directive 9345.1-02
1.0 INTRODUCTION
1.1 PURPOSE AND USE
This transitional guidance describes the goals, scope, procedures,
and desired results of expanded site inspections (ESIs) conducted under
the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), as amended in 1986 by the Superfund Amendments and
Reauthorization Act (SARA). The document Is intended for use by EPA,
its Field Investigation Team (PIT) contractors, and State agencies in
planning for and preparing ESIs in FT 1988. Nev screening SI (SSI) and
Listing SI (LSI) guidance vill be prepared and distributed at the
beginning of FT 1989 (Section 1.2).
EPA has developed a structured process to determine what, if any,
cleanup actions are appropriate for potential hazardous vaste sites
included in CERCLIS, EPA's national inventory of such sites. The
process is in two major phases: the first phase leads to proposal of
sites for the National Priorities List (NPL). This "pre-reraedial phase"
previously consisted of four activities—discovery, preliminary
assessment (PA), site inspection (SI), and scoring on the Hazard Ranking
System (HRS). ESIs are a new component of the pre-remedial phase.
The second or "remedial" planning phase involves detailed
evaluation of a site to identify the precise magnitude and extent of
contamination and the most technically sound and cost-effective
alternatives for correcting problems at the site. This remedial
planning phase includes tvo activities—a remedial investigation (RI)
and a feasibility study (FS).
PAs and Sis are limited to determining if a site ever handled
hazardous substances and/or if there has been a release or potential for
release of contaminants into the environment serious enough to varrant
expenditure through the national Superfund. They are not intended to
determine the exact magnitude or extent of contamination. A simple
estimate of the magnitude of release is made when the site is scored
under the HRS, and a more comprehensive estimate is made during the RI.
ESIs are intended to help narrov the data gap and reduce the
elapsed time betveen pre-remedial activities and the start of RI field
vork. With the more detailed ESI data available, the remedial
contractor can begin timely remedial action at sites which pose more
serious health and environmental threats. ESIs vill not only yield HRS
scores and proposals for the NPL, they vill also provide the remedial
contractor with a more complete overviev of the site and vaste
characteristics, expediting the remedial planning process. Finally,
ESIs vill provide data to bring enforcement action or initiate
negotiations vith potentially responsible parties (PRPs).
1.2 CHANGES TO THE ESI CONCEPT
The pre-remedial process has been modified since the initial
proposal of the ESI concept (Expanded Site Inspection Concept Paper,
1986). Hence, ESI selection procedures have changed.These changes are
1-2
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OSVER Directive 9345.1-02
best illustrated in a discussion of the "new" pre-remedial program to
support the revised HRS.
Guidance is being prepared for the revised preliminary assessment
(PA) which vill require collecting more data following guidelines of a
PA Checklist, off-site reconnaissance for most sites, and application of
the Site Screening Analysis technique, a standardized method for
calculating probable HRS scores. The revised PA vill average 75-80
hours versus 40 hours for the "old" PA, and result in better screening
of sites on which SI resources vill be expended.
PAs vill be used to establish priorities for subsequent Sis:
o High priority - This recommendation will generally comprise
those sites that are highly likely to score above the cut-off
upon application of the current HRS at the end of an SI. Sites
• in this category are the most likely to be placed on the NPL.
All high priority sites will receive an LSI after final
promulgation of the revised HRS.
o Medium priority - This recommendation vill generally comprise
those sites that have some, but not high, likelihood to score
above the cut-off upon application of the current HRS at the end
of an SI. Sites in this category, expected to be the largest
'category, vill receive Screening Sis under the new HRS.
Screening Sis will be roughly equivalent to today's standard SI.
o No further action - This recommendation represents all other
sites and will generally include (1) sites that never received
CERCLA hazardous substances; (2) sites where the CERCLA
hazardous substances are clearly not releasing, and have no
potential to release into the environment and no removal action
is required; and (3) sites with no potential to score 28.5 or
higher upon application of the current HRS at the end of an SI.
Only in rare instances will sufficient cause or information be available
for a site to go directly from a PA to an LSI. Generally, a site will
undergo an SSI before an LSI.
The SI process under the revised HRS will be two tiered and include
components of the present ESI concept. The vast majority of sites vill
receive a screening SI (SSI) to:
o Collect additional data to calculate a better preliminary HRS
score.
o Establish priorities among sites most likely to qualify for the
NPL.
o Identify the most critical data requirements for an LSI, the cop
tier.
An SSI will not have rigorous data quality objectives (DQOs).
Based on the refined preliminary HRS score, the SSI will drop out of the
Federal CERCLA purview (i.e., NFA), be referred to another applicable
Federal program, or to top tier, LSI status.
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OSVER Directive 9345.1-02
Sites most likely to qualify for the NPL are candidates for LSIs
which vill address all data requirements of the revised HRS and satisfy
NPL-type DQOs. Formal HRS packages vill be prepared only for LSI sites.
LSIs vill also provide data to support scoping of the RI and development
of the remedial vork plan.
The major objective of the tiered SI process is to ensure that
limited LSI resources are applied only to the highest priority sites
bound for the NPL. The difference betveen the tiered SI approach and
the ESI concept discussed in this transitional guidance is mainly one of
emphasis:
o ESIs support HRS scoring and RI scoping/vork plan development.
The two tiered SI process under the revised HRS and NCP vill
emphasize the HRS support objective.
o ESI efforts under the current HRS in support of the remedial
planning process are similar to LSI efforts under the revised
HRS (i.e., "HRS 2" vill emphasize more thorough source and site
characterization; collection of monitoring veil data;
consideration of the "nev" on-site pathway).
o Total level of effort (LOE) is similar. An ESI averages
1,300-1,500 hours, versus 1,500 hours for the combination of an
SSI (average 500) and LSI (average 1,000).
Nev SI guidance, concerning both SSIs and LSIs, vill be issued in
early FY 1989. Until that time, the terminology SI and ESI vill
continue to be used. In the interim, this guidance vill serve as the
foundation for planning and conducting ESIs. Today's ESI sites could
represent the first generation of LSI sites to be addressed under the
revised HRS.
1.3 ESI OBJECTIVES FOR FY 1988
ESIs are intended to:
o Provide additional data in support of revised HRS scoring.
o Provide the first generation of information for sites evaluated
using the revised HRS.
o Identify situations requiring removal action.
o Provide more information on site characteristics, contaminant
sources (vaste type and volume), and migration pathvays to the
remedial contractor for timely development of the RI vork plan.
o Shorten the remedial planning process.
o Encourage better communication and transfer of information
betveen pre-remedial and remedial contractors.
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OSVER Directive 9345.1-02
1.4 COMPARISON OP Sis AND ESIs
The ESI differs from the traditional SI in a number of ways. ESIs:
o Collect more comprehensive site background information.
o Collect additional chemical contamination data—for example,
increased sampling, surface geophysics, field analytical
screening, and installation of monitoring veils.
o Formalize transfer of data from the pre-remedial contractor to
the remedial contractor.
o Use more resources in terms of:
- average LOE - 1,500 hours (FIT and EPA)
approximate number of Contract Laboratory Program (CLP)
samples - 20 to 30
- approximate number of monitoring veil installations - 3 to 6.
Table 1-1 compares the overall approach of conducting Sis to ESIs.
The major difference, the increased scope of the field investigation in
an ESI, is highlighted in Table 1-2. Differences in approach are
reflected by the increased use of field screening techniques (i.e.,
field gas chromatograph analysis and geophysical surveys), collection
and analysis of additional CLP samples, drilling of boreholes for
subsurface sampling, and installation of ground vater monitoring veils.
Table 1-3 estimates LOEs for the various components of a typical ESI, as
veil as subcontractor and equipment expenditures.
Field screening procedures can help obtain the most from ESI
resources by targeting sampling efforts, supporting CLP data, and
shortening the period between sample collection and data evaluation.
Field screening procedures include:
o Visual observation, vhich is valuable in characterizing vaste
sources and providing evidence of contamination, especially in
soils, sediments, surface vater, and ground vater.
o Geophysical screening techniques, vhich can obtain information
on:
- hydrogeologic features
existence and general direction of subsurface contamination
boundaries of buried trenches and lagoons
location of buried drums and tanks.
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OSVER Directive 9345.1-02
TABLE 1-1
COMPARISON OF OVERALL SI AND
ESI APPROACHES
SI APPROACH
1. Review of PA/background information
2. Site reconnaissance
3. Preparation of project plans
4. Field investigation
5. Report and HRS scoring
ESI APPROACH
1. Sane as SI
la. Consideration of
information requirements
of PA Checklist
Ib. Completion of off-site
reconnaissance
Ic. Prescoring of site and
selection for ESI
Id. Collection of additional
background information
2. Same as SI
3. Same as SI
4. Increased scope over SI.
. More field analytical
screening, geophysical
surveys, sample collec-
tion, and monitoring
veil installations
5a. Increased detail over SI
report. Summary of
background information,
data interpretation, and
recommendations
5b. Formalized transfer of
information from ESI
personnel to RI/FS
personnel
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OSVER Directive 9345.1-02
TABLE 1-2
COMPARISON OP PIBLO INVESTIGATIONS UNDER SI
AND 8SI APPROACHES
Sampling principles
Field screening
Approximate number
of samples for
Contract Laboratory
Program
Monitoring veil
installation
SI APPROACH
Demonstrate that
release has occurred
Pocus sampling to
determine maximum
population exposed
or proximity to sen-
sitive environments
Collect sufficient
background samples
to identify contri-
butions from other
sources
Minimize and
prioritize on-site
sampling
Sample air releases
Limit use of field
screening techniques
10-15*
Rely largely on
existing veils.
Focus on aquifer of
concern
ESI APPROACH
Same as SI plus
determination of
general extent of
contamination
Same as SI
Same as SI
Sample on-site to
provide location and
preliminary charac-
terization of all
vaste sources
Same as SI plus
preliminary deter-
mination of extent
of release
Maximize use of field
screening techniques
to characterize
sources and make pre-
liminary determination
of extent of contami-
nation
20-30'
Install 3-6 veils.*
Focus on one or more
aquifers to make
preliminary determi-
nation of extent of
contamination
'Predicted averages.
Actual numbers vill vary on a site-specific basis.
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OSVER Directive 9345.1-02
TABLE 1-3
ESTIMATED LEVEL OF EFFORT FOR ESI
TASK
Review of existing data/
site reconnaissance
Work plan development
Field sampling/screening
Air
Geophysical
Surface water
Ground water
(< 8 wells)
Off-site sampling
Data validation
Data evaluation
HRS scoring
Report preparation
AVERAGE
LOE (hours)
100
160
50
150
40
500
80
100
80
120
120
1,500
AVERAGE
SUBCONTRACT &
EQUIPMENT ($)*
1,000
20,000
40,000
3,000
64,000
'Excluding laboratory costs.
1-8
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OSVER Directive 9345.1-02
o Analytical screening procedures, which can be used for both
inorganic and organic compounds to:
- identify contaminants present
- provide quantitative or seraiquantitative estimates of
contaminant levels
- provide preliminary determination of the extent of
contamination in soils, air, and water
- optimize CLP sampling efforts.
Analytical screening procedures utilize portable monitors and
Instrumentation such as photo and flame ionization detectors, field gas
chromatographs, and x-ray fluorescence.
1.5 REFERENCES
Existing guidance or information on the status of evolving guidance
can be obtained from EPA Headquarters, Site Assessment Branch, Hazardous
Site Evaluation Division, Office of Emergency and Remedial Response
(OERR).
Contacts; Penny flansen (FTS-475-8103)
Jim Jovett (FTS-475-8195)
o Expanded Site Inspection Concept Paper, September 1986, Document
Control No.:999-PM1-RT-DCLQ-1.
o Pre-remedial Strategy for Implementing SARA (Draft), August
T91F7:
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OSVER Directive 9345.1-02
CHAPTER 2 SUMMARY
WHAT ARE DATA QUALITY OBJECTIVES (DQOs) FOR AN ESI? BOV VILL
CONSIDERATION OP DQOs BENEFIT PREPARATION OF WORK PLANS, SAMPLE PLANS,
AND HEALTH AND SAFETY PLANS?
o DEVELOP DQOs
- Three DQO stages: (1) identify decision types; (2) identify data
uses/needs; (3) design data collection program.
o IDENTIFY DECISION TYPES
- Identify major decisions: (1) propose for NPL; (2) scope of RI
work plan.
- Identify and involve data users: (1) EPA Regional Project
Officers; (2) FIT and State project managers and staff; (3) EPA
enforcement personnel; (4) State agency personnel; (5) Agency for
Toxic Substances and Disease Registry; (6) remedial staff and
contractors.
- Evaluate available information confirmed by off-site
reconnaissance during the PA and on-site reconnaissance prior to
SI or ESI field work. Update assessment of site conditions.
- Develop a conceptual model which illustrates probable
contaminant(s), migration pathvay(s) and potential route(s) of
exposure.
o IDENTIFY DATA USES/NEEDS
- Identify data uses: (1) HRS documentation; (2) general site
characterization; (3) RI verk plan development; (4) preliminary
risk assessment; and (5) enforcement support.
- Identify data types: (1) matrix (air, soil, vater); (2)
concentration (high, medium, environmental); (3) field screening
vs. CLP quality; (4) quality assurance; (5) grab versus composite
samples; and (6) geophysical data.
- Identify data quality needs: (1) appropriate analytical levels;
(2) contaminants of concern; and (3) required detection limits.
- Identify data quantity needs: (1) satisfy confidence levels
desired; (2) satisfy QA/QC requirements; (3) satisfy HRS
requirements; and (4) satisfy the general site characterization
objective.
- Evaluate sampling/analysis options. Consider the "phased"
sampling approach - use field screening data to target CLP
samples.
o DESIGN DATA COLLECTION PROGRAM (Chapter 3).
2-1
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OSVER Directive 9345.1-02
2.0 ESI DATA QUALITY OBJECTIVES
2.1 INTRODUCTION
Data quality objectives (DQOs) must be developed for each ESI based
on proposed end uses of data generated from sampling and analytical
activities. These DQOs are qualitative and quantitative statements
which outline the decision-making process and specify the data required.
ESIs have two objectives:
o Support an HRS score that allows proposing the site for the NPL.
o Expedite the remedial planning process.
2.2 POP DEVELOPMENT PROCESS
Site-specific DQOs are identified during project scoping and
development of sampling and analysis plans. They are established to
ensure that data of sufficient quantity and quality are collected to
satisfy ESI objectives. Data conforming to the DQO process described in
this guidance can be used to assess the uncertainty associated with each
of the primary objectives of the ESI program. ESI DQOs are addressed in
more detail in Data Quality Objectives (DQOs) for Pre-remedial Response
Activities (draft).In addition, remedial DQOs are discussed in Data
Quality Objectives (DQOs) for Remedial Response Activities (1987).
DQOs are developed through a three-stage process (Figure 2.1). The
first two — identification of decision types and identification of data
uses/needs — are discussed in this chapter. Stage 3 — design of data
collection program — is the basis for Chapter 3.
ESIs are undertaken at sites having probable contaminant problems
identified during PAs and Sis. With careful phasing of sampling and
site characterization activities, valid data from one phase can help
guide subsequent phases. Field screening-type analyses, including
geophysics, soil vapor measurements, and certain chemical analyses,
provide rapid turnaround of results and help target more costly and
time-consuming sampling efforts (i.e., well placement and CLP sampling
decisions).
It may not be possible to identify at the outset all the data needed
to complete an ESI. A phased approach to sampling, however, will help
identify data gaps'as field work progresses, and provide control to the
complex sequence of investigative activities. Application of the DQO
process to a phased investigation should improve data validity.
2.3 ESI DQO STAGE 1 - IDENTIFICATION OF DECISION TYPES
Stage 1 of the DQO approach is an inherent part of the project
scoping effort and guides development of ESI work plans. The major
elements include:
2-2
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STAGE 1
IDENTIFY DECISION TYPES
• IDENTIFY MAJOR DECISIONS
• IDENTIFY A INVOLVE DATA USERS
• EVALUATE AVAILABLE DATA
• DEVELOP CONCEPTUAL MODEL
STAGE 2
IDENTIFY DATA USES/NEEDS
• IDENTIFY DATA USES
• IDENTIFY DATA TYPES
• IDENTIFY DATA QUALITY NEEDS
• IDCNTWY DATA QUANTITY NEEDS
• EVALUATE SAMPLING/
ANALYSIS OPTIONS
STAGE 3
DESIGN DATA COLLECTION PROGRAM
• ASSEMBLE DATA COLLECTION
COMPONENTS
• DEVELOP DATA COLLECTION
DOCUMENTATION
FIGURE 2-1
ESI OOO THREE-STAGE PROCESS
from P«l« Quality ObJ»cUy»» fur R««»»dUI H»»pon«»
• •• U.S. EPA. March I»O7>
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OSVER Directive 9345.1-02
o Identification of major decisions
o Identification of and involvement of data users
o Evaluation of available information
o Development of a conceptual model
2.3.1 Identification of Major Decisions
The tvo major factors affected by the outcome of an ESI are the NPL
decision and the RI scoping/support decision. The more rigorous of
these tvo factors, vith respect to DQOs, is the NPL decision.
HRS-quality data must support:
o Determination of an observed release to ground water, surface
water, soil, or air. Under the existing HRS, EPA has established
general guidelines to demonstrate an observed release by
comparing background contaminant concentrations to release
concentrations:
- order of magnitude (10-fold) for a single contaminant
two to three fold for multiple contaminants
- three times the instrument detection limit when undetected in
background
o Determination of waste quantity, waste characteristics, and site
characteristics to calculate an HRS score based on route
characteristics.
While quantitative assessment of the data is required for an observed
release, a qualitative assessment may suffice for a route score.
The ESI DQO process as it affects RI scoping involves determining
how to judiciously focus RI/FS resources. It is not to make public, NPL
determinations, but rather to assist with internal management decisions.
2.3.2 Identification and Involvement of Data Users
A list of potential data users should be developed at the outset of
the OQO process (Figure 2-2). The primary data users are those involved
in ongoing ESI activities, for example, the EPA Regional Project Officer
and the FIT or State ESI project manager and staff.
Secondary data users include all those who rely on ESI output to
support programmatic activities. They provide input to the RPO and
other primary data users during DQO development by establishing generic
needs and, on occasion, site-specific data needs. A typical list of
secondary data users for an ESI might include EPA enforcement personnel,
State agency personnel, the Agency for Toxic Substances and Disease
Registry (ATSDR), and most importantly, EPA's remedial staff and the
RI/FS contractor.
2-4
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HEADQUARTERS
MRS OA
REMEDIAL CONTRACTORS
DIVISION MQMT
- PROGRAM A PROJECT
OVERSIGHT
ENFORCEMENT
- NEGOTIATIONS
u«
STATE
- NPL CONCURRENCE
REMEDIAL ACTION DECISIONS
DQO
DECISION MAKERS
PNIMAMV DATA U«KN«
-COMTNACTCMI'* MTI MAN,
-•TATC PfK>J«CT MANAQCN
ICTATC-LCAP MCkJKCTI
EMERGENCY RESPONSE
- REMOVALS
VO
£
u>
IT
TECHNICAL SUPPORT
- HEALTH ASSESSMENTS
L*g**tf
INPVV
1>
OUTPUT
(ESDXOTHERS)
- UPON RESOUEST BY RPO
SAMPLING/ANALYTICAL SUPPORT
REGULATORY REQUIREMENTS
2-2
DECISION MAKER DATA INTERACTION
»r o»l»«rii«>»« »»f
**>A. btenfc 1MIT)
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OSVER Directive 9345.1-02
2.3.1 Evaluation of Available Information
Review and evaluation of information available for a site is an
early step in the ESI process. This review provides the basis for
additional on-site activities and serves as the foundation for ESI
scoping and work plan preparation. Following the initial evaluation,
data are confirmed by on-site reconnaissance which:
o Uses field instruments to obtain data on any volatile chemical,
radioactive, or explosive hazards on-site and to determine
site-specific health and safety concerns.
o Determines if site conditions pose an imminent danger to public
health.
o Confirms information contained in previous documents.
o Records observable data missing in previous documents.
o Updates site conditions.
o Inventories possible off-site sources of contamination.
o Obtains data such as location of access routes and sampling
points, and identifies logistical considerations for the field
investigation.
Aerial photographs and detailed maps (i.e., topographic, geologic,
potentiometric surface) of the site are useful to the initial
reconnaissance. Photos and maps should provide a scaled compilation of
the best available information about the site and include:
o Site topography.
o Pertinent physical site features, (e.g., buildings, water bodies,
water courses, wetland areas, access points, property boundaries,
wooded or vegetated areas).
o Identification and delineation, as possible, of the areas of
waste storage or contamination, both historic and existing.
The maps and/or photos should include a reasonable area outside
known site boundaries to illustrate land use on adjacent properties and
to identify potentially sensitive off-site receptors. Along with the
project log book, they provide an efficient tool to confirm existing
site conditions, record field notes and instrument measurements, and
identify potential future sampling locations.
Tasks such as geophysical surveys and limited field screening and
analysis may be performed during an initial site visit if an approved
health and safety plan is in place. This initial 'sampling' may help
determine the variability of contaminants, provide background
information, or determine changes in site conditions. Confirmatory
activities which may be undertaken during the initial visit include
2-6
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OSVER Directive 9345.1-02
locating, numbering, labeling, photographing, securing, and recording
the condition of on-site stored waste and ground-water monitoring wells;
identifying the number of occupied residences in the vicinity of the
site; and determining the adequacy and condition of the site security
system.
2.3.4 Development of Conceptual Model
A conceptual model describes an uncontrolled hazardous waste site
and its environs, presenting hypotheses regarding the contaminants
present on-site, their routes of migration, and their potential impact
on sensitive receptors. Hypotheses presented (based on PA, preliminary
HRS score, and REP score information) are tested, redefined and modified
during the ESI. The basic elements of a conceptual model (Figure 2-3)
should be expanded to prepare a general description of the site and its
environs. An illustration of site conditions (Figure 2-4) should
accompany the written description.
The conceptual model developed during the ESI work plan will be
expanded on and become more detailed as field work and sampling
progress. A final version should be part of the ESI report and should
incorporate the following factors:
o Population and environments at risk.
o Known and potential routes of exposure.
o General spatial distribution of contaminants.
o Atmospheric dispersion potential and proximity of targets.
o Amount, concentration, hazardous properties, and form of
contaminants as deposited versus as dispersed.
o Hydrogeological factors (i.e., soil permeability, depth to
saturated zone, hydraulic gradient).
o Climate (rainfall, seasonal variations, etc.).
o Extent to which the source can be adequately identified and
characterized.
o General extent to which the substances have migrated or are
expected to migrate from their area of origin and whether
migration poses a threat to public health, welfare, or the
environment.
2.4 ESI POO STAGE 2 - IDENTIFICATION OF DATA USES/NEEDS
Stage 2 of the ESI DQO process defines specific data uses,
identifies the necessary quality and quantity of data required to
support the ESI, and designates appropriate sampling and analytical
methods. The major elements of State 2 are identification of:
2-7
-------
SOURCE
RECEPTORS
o
i
I
09
r»
r*
I"*
<
VARIABLES:
CONTAMINANTS .
CONCENTRATION
TIME OF DISPOSAL
LOCATION
MEDIA
RATE OF MIGRATION
TIME SINCE DISPOSAL
PERSISTENCE/MOBILITY
OF CONTAMINANTS
TYPE
SENSITIVITY
POTENTIAL
EXPOSURE
CONCENTRATION
noune 2-3
OP A CONCEPTUAL MODCT.
Ao«vt
-------
POTENTIAL SOURCES
VOLATILIZATION
PERCHED
WATER TABLE
VOLATILIZATION
CONTAMINATED
SOIL9
I
-------
OSVER Directive 9345.1-02
o Data uses
o Data types
o Data quality needs
o Data quantity needs
o Evaluation of sampling/analysis options
2.4.1 Data Uses
Data developed during an ESI vill be used for:
o HRS documentation. Data require a comparison of background
contaminant concentrations with release concentrations to
determine an observed release. HRS documentation vill generally
require Levels IV and V CLP data (analytical levels are defined
in Section 2.4.3.1).
o Site characterization. Data are used to determine the general
nature and extent of contamination at the site. They are
generated through the sampling and analysis of waste sources and
environmental media. This effort vill usually be Level I or
Level II combined vith some CLP data (Level IV).
o Development of RI work plan. Data help the remedial contractor
develop the work plan. Data needs will depend on the unique
source, pathvay, and receptor characteristics of each site. Less
rigorous levels of data (i.e., Levels I-III) are adequate, but
all Levels of data may be useful for this purpose.
o Preliminary risk assessment. Data are used to evaluate the risk
posed by a site to public health and the environment. Some of
the data must be qualitative, describing chemical/physical
properties, toxicity, persistence, and mobility of contaminants.
The data must also be quantitative (Level II) so that they may be
compared vith health risk criteria set by ATSDR.
o Enforcement support. Data are used to help the enforcement
program identify potentially responsible parties (PRPs). For
known PRPs, data are used to link their wastes to those found
on-site and to pollutants released off-site. For unknown PRPs,
site wastes can be compared to pollutant profiles of their waste
streams. Identifying PRPs vill, in most instances, require
Levels IV and V CLP data.
2.4.2 Data Types
The general purposes for which data vill be collected during the ESI
are defined early in the scoping process. Then, data quality needs can
be defined and sampling and analysis options systematically evaluated.
Data types include:
o Matrix (air, soil, water)
o Concentration (high, medium, environmental)
o Parameters (field screening versus CLP analysis)
2-10
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OSWER Directive 9345.1-02
o Quality assurance (blanks, replicates and spike samples)
o Grab versus composite samples
o Geophysical data
The data types specified in Stage 2 should not be limited to
chemical parameters, but may also include, as appropriate, physical
parameters such as permeability, porosity, conductivity, resistivity,
electromagnetic properties, magnetic response, and acoustic impedance.
These physical parameters are needed to better evaluate the location of
contaminants and the extent of, or potential for, migration.
2.4.3 Data Quality Needs
Data quality should be considered as the uses and types of data are
determined. Important factors in defining data quality include:
o Appropriate analytical levels
o Contaminants of concern
o Required detection limits
EPA PIT and other EPA contractor personnel review all field
procedures used by site inspection teams and all analytical results
generated by CLP. This review assesses compliance with standard
operating (i.e., chain-of-custody) and CLP procedures. Data validation
is described in more detail in User's Guide to the Contract Laboratory
Program (1984).
2.4.3.1 .Appropriate Analytical Levels
EPA has set various analytical levels (Table 2-1) for determining
data quality:
o Level I. Field screening or analysis using portable instruments.
Results are often not compound-specific and not quantitative but
can indicate "hot" and "not so hot" spots. Results available
immediately.
o Level II. Field screening or analysis using more sophisticated
portable instruments. The quality of data generated is highly
variable, depending on the use of suitable calibration standards,
reference materials, sample preparation equipment, and the
training of the operator. Results available almost immediately.
o Level III. All analyses performed in an off-site laboratory that
may or may not follow CLP procedures. QA/QC and documentation
are less rigorous than CLP protocols. Results delayed.
o Level IV. CLP Routine Analytical Services (RAS). All analyses
are performed in an off-site CLP laboratory following CLP
procedures. QA/QC protocols and documentation are rigorous.
Results delayed.
2-11
-------
TAIL! l-»
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• TBBTATIVB IDBBTirICATIOB
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-------
OStfER Directive 9345.1-02
o Level V. Analysis by Non-Standard (NS) methods. All analyses
are performed in an off-site laboratory that may or may not be a
CLP laboratory. CLP Special Analytical Services (SAS) are level
V. Results delayed.
2.4.3.2 Contaminants of Concern
Most ESIs require identifying the contaminants posing the most
serious health and environmental threat in terms of toxicity,
persistence, and mobility. This identification is key to preparing an
HRS package and supporting an ATSOR preliminary health assessment.
To increase the likelihood of detecting a release, the analyses
requested should be as broad as possible while still reflecting
knowledge gained from any previous field work. Typically, CLP RAS
organics and metals are requested and a CLP SAS may be requested for
nonroutine hazardous substances.
2.4.3.3 Required Detection Limits
The detection limits selected must be compatible with the data
quality requirements for each ESI objective, and the sampling and
analysis methods selected must be capable of accurate measurement at the
level of concern. The analytical options are:
o HRS/enforcement support. Levels IV and V detection limits may be
optimal but are not always required.
o General site characterization. Levels I and II for sample
analysis, and adherence to standard operating procedures for
geophysical and well installation work, should be adequate.
o Preliminary risk assessment. Level II and Level IV and V data
should be adequate.
2.4.4 Data Quantity Needs
The confidence levels desired and cost limitations imposed should
help determine data quantity and sampling needs. Data to substantiate
an HRS score have the most rigorous DQOs, generally requiring three or
more saaples, including background and release, for each migration
pathway. In addition, one or more samples of the waste source should be
collected to link waste constituents with contaminants detected as
observed releases. Necessary duplicates and blanks should also be
considered when determining data quantity needs.
For general site characterization, the investigator might consider
the sampling requirements illustrated in Figure 2-5. Field analytical
screening and geophysical survey results (i.e., portable gas
chromatography, soil gas monitoring) will be maximized by establishment
of a sampling grid. The size of the grid selected is based on the
site-to-target-area ratio, and the probability of target detection
(Figure 2-5(1) and Table 1). Figures 2-5(2) and 2-5(3) illustrate hov
2-13
-------
OSVER Directive 9345.1-02
FIGURE 2-5
DATA QUANTITY NEEDS AND
SPATIAL SAMPLING REQUIREMENTS
*M el •••• AS
1: •uWfittt $•« W tt
A&/AI • iO«aw
•roUWity
~*
Ottection
100
M
to
78
80
40
30
Aa/Al.10
18
13
10
8
8
4
3
AI/AI • 100
160
130
100
80
SO
40
30
Aft/At • 1000
1600
1300
1000
800
500
400
300
The inoaaly shovn in Figure 1 My rtprtscnt • burl*d trench, • group of
buried druaa, • ground vattr eontaainant pluic or a natural geologic
feature. The nuaber of samples necessary to detect an anoaaly is shovn
in Table 1. The table provides a convenient Mans of estimating the
nueber of sasiples required if a level of confidence is established and
the six* of the anouly and the search area can be estimated.
The saaples *ay be soil saaples, ground vater saaples or any other
localised Mans of sampling.
To estlawte saaple requlrevents and site coverage required:
1) Establish the overall are* of interest.
2) Estiaate the einiaal site of anouly to be detected - deteraine
the site to target area ratio.
3) Determine the confidence level desired considering cost
limitations.
4) Establish the nueber of sample points using Table 1.
5) Knowing the nuaber of saaples and the area of interest use
Figure 2 to establish approximate sample grid spacing. A
rectangular sample grid is assumed.
6) If continuous coverage is employed, use the spacing obtained in
Pirgure 2 and the overall area of interest to find the number
of line miles of continuous profiling from Figure 3.
(Modified from Technos Inc., Application Guidelines - Selected
Contemporary Techniques for Subsurface Investigations!
2-14
-------
OSWER Directive 9345.1-02
to select grid or line spacing depending on whether station data or
continuous line profile data are to be collected. The sampling logic
implied in Figure 2-5 should help guide development of the ESI sample
plan.
2.4.5 Evaluation of Sampling/Analysis Options
Following identification of data users, data types, and data quality
needs, sampling and analysis options can be evaluated. Sampling
strategies to support the HRS are presented in Site Inspection Sampling
Strategy for Supporting Hazard Ranking System Scoring (J985)i
The evaluation should consider:
o Sampling and analysis components
o Sampling and analysis approach (phasing).
2.4.5.1 Sampling and Analysis Components
The project site manager oust involve technical personnel familiar
with analytical techniques during this stage of the DQO process.
Analytical approaches to be considered consist of Levels I - V variable
as to cost, time required for analysis, and quality of resulting
analytical data.
All sampling activities should be conducted and documented so that
sound decisions concerning HRS and RI work plan development can be made.
If sufficient data are collected using appropriate protocols, and the
data are valid for NPL decisions, then they should be admissible as
evidence in future litigation.
2.4.5.2 Sampling and Analysis Approach (Phasing)
Data collection activities for each uncontrolled hazardous waste
site must be designed to maximize use of available and collected data.
A phased ESI approach, with field screening and geophysical techniques
to direct sample collection, will ensure adequate sampling and analysis.
Subdividing the data collection program into several phases enables use
of data collected during one phase to direct data collection in
subsequent phases (i.e., geophysical surveys to select monitoring well
locations; field analytical indicators to select CLP samples).
The time required to receive analytical data from laboratories often
results in delays in additional sampling. Using field techniques for
assessing contaminant concentrations or'media characteristics allows the
ESI to proceed more efficiently.
Direct reading instruments which should be considered for evaluating
a sampling/analysis approach include:
o Organic vapor analyzer (OVA)/HNU
o Portable gas chromatograph (GC)
o Portable x-ray fluorescence (XRF)
2-15
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OSVER Directive 9345.1-02
o Portable atomic absorption spectrometer (AA)
o Hydrogen sulfide analyzers
o Mercury vapor analyzers
o Respirable particulate meters
o Radiation detectors
o pH and conductivity meters
Other field techniques which can assess site conditions without
extensive laboratory support include:
o Soil gas monitoring
o Ground-penetrating radar surveys
o Electromagnetic surveys
o Magnetometer surveys
b Seismic refraction surveys
o Resistivity surveys
The phased sampling approach can be conceived of as a large
"inverted funnel" vhereby large numbers of samples are initially
analyzed quickly and inexpensively in the field, with smaller numbers of
samples analyzed further in a laboratory at a higher level of
sophistication. If parameters are selected for screening purposes, a
percentage of samples should be analyzed completely to verify
assumptions made for chemicals present or of concern. The type and
design of the analytical approach are determined by how data will be
used. Strategic selection of samples for analysis at each level
provides a higher degree of certainty for the overall data set without
sacrificing either the quantity of samples to be analyzed or the quality
of data collected.
2.5 REFERENCES
Existing guidance or information on the status of evolving guidance
can be obtained from EPA Headquarters Site Assessment Branch, Hazardous
Site Evaluation Division, Office of Emergency and Remedial Response
(OERR).
Contacts; Penny Hansen (FTS-475-8103)
Ji« Jowett (FTS-A75-8195)
o Data Quality Objectives for Pre-remedial Response Activities, in
preparation, FT 1988.
o Data Quality Objectives (DQOs) for Remedial Response Activities -
Volumes 1 and 2, OSVER Directive 9335.0-7B, March 1987.
o Site Inspection Sampling Strategy to Support HRS Scoring (Draft),
OSVER Directive 9345.1-01, January 1986.
o User's Guide to the Contract Laboratory Program, OSVER Directive
9240.0-01, July 1984.
2-16
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OSVER Directive 9345.1-02
CHAPTER 3 SUMMARY
WHAT IS THE FORMAT AND CONTENT OF ESI WORK PLANS, SAMPLING PLANS, AND
HEALTH AND SAFETY PLANS?
0 VORX PLAN
- Major objectives:
* Provide specific guidance for all field work
* Provide a mechanism for planning site activities and obtaining
EPA approvals
- Background:
* Summarize existing site data
* Describe site
* Discuss data gaps
- General considerations:
* Investigation procedures
* Personnel requirements
* Equipment requirements
* Subcontractor procurements
* Vaste disposal procedures
* Special training requirements
0 SAMPLING PLAN
- Determine contaminants of interest
- Discuss sampling rationale and frequency
- Develop operational plans -for sampling. Identify:
* Team members
* Sample report/documentation requirements
* Analytical and sample handling requirements
* Sampling equipment
* QA samples
* Decontamination procedures
o HEALTH AND SAFETY PLAN
- Describe known site hazards
- List key personnel
- Identify levels of protective gear required
- Evaluate hazards (i.e., toxicological assessment of known or
suspected contaminants)
3-1
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OSVER Directive 9345.1-02
- Outline site monitoring program (i.e., survey instruments needed)
- Identify field vork areas and outline site access control
procedures
- Prescribe personnel decontamination procedures
- Compile emergency information
3-2
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OSVER Directive 9345.1-02
3.0 PREPARATION OP ESI WORK PLANS, SAMPLING PLANS, AND
HEALTH AN SAFETY PLANS
3.1 INTRODUCTION
Vork plans, sampling plans, and health and safety plans are prepared
after the necessary data have been collected at the PA stage and the
site has been prescored to determine potential data gaps. These plans
document procedures to be used, resources needed, and the rationale
behind the tasks to be undertaken during the ESI, thus ensuring that all
necessary planning and reviev have been completed before field
activities begin. The plans also provide the basis for later
interpretation of the results of the ESI, and documentation of the
procedures and technical approach used for eventual remedial work and
possible future enforcement actions.
3.2 VORK PLAN
The ESI vork plan establishes the level of effort and specific field
activities. The plan:
o Provides specific guidance for all field vork.
o Provides a mechanism for planning site activities and obtaining
EPA approval.
o Provides a basis for estimating field costs.
o Targets sampling activities to those that are necessary and
sufficient.
o Provides a common point of reference for all parties to
coordinate site activities.
The vork plan must outline site-specific data needed to:
o Support the HRS.
o Characterize the site (sources, migration pathways, and
receptors).
o Support health studies conducted by ATSDR.
o Develop preliminary risk assessments.
o Support enforcement actions.
At a minimum, the ESI vork plan should include sections outlined in
Table 3-1. During the ESI, the vork plan may require revision to
reflect the need for more detailed information or greater focus on a
particular problem.
3-3
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OSVER Directive 9345.1-02
TABLE 3-1
SUGGESTED FORMAT FOR ESI WORK PLAN
Introduction
o Objectives
o Site background
o General work plan considerations
o Evaluation of existing data (PA information)
ESI Data Quality Objectives (Chapter 2)
o DQO Stage 1 - Identification of decision types
o DQO Stage 2 - Identification of data uses/needs
Sampling Plan (Section 3.3)
o Chemicals of potential interest (based on disposal records and
known industry feedstocks)
o Sample types to be taken
o Nap of preliminary sample, veil installation, and geophysical
survey locations (based on file information and reconnaissance)
o Sample locations and frequency
o Analytical and standard operating procedures
o Sample QA/QC
o Sample decontamination
o Sampling reports/documentation
o Sample delivery
Health and Safety Plan* (Section 3.4)
o Description of known hazards and risks
o List of key personnel
o Levels of protective gear required
o Hazard evaluation
o Site monitoring program
o Field vork areas/access control points
o Decontamination
o Emergency information
Field Investigation Procedures (Chapter 4)
o Sampling
o Geophysical surveys
o Installation of monitoring veils
o Mobilization and demobilization considerations
Community Relations Plan
Project Schedule and Costs
"Often a stand-alone document completed once Work/Sampling Plans are
approved.
3-4
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OSVER Directive 9345.1-02
3.2.1 Objectives
Work plan objectives describe the precise reasons for field
investigation and sampling efforts, as veil as the ultimate use of the
data.
3.2.2 Site Background
The site background is described based on existing file information
and on data compiled during the PA. Background information should
consist of:
o A description (cultural, topographic, geologic) of the site and
surrounding area, including any limitations on conducting field
activities.
o A discussion of knovn and suspected contamination sources and a
listing of probable transport pathways.
o A list of information sources.
o A discussion of data gaps.
3.2.3 General Considerations
The work plan provides for efficient scheduling of resources such as
manpower, equipment, and laboratory services. The "general" section
should include material on the following subjects, which may be further
detailed in subsequent sections:
o Investigation procedures. Outlines specific standard operating
procedures (SOPs) and field quality control procedures during the
ESI.
o Personnel requirements. Identifies all persons needed to conduct
field activities, including support personnel, and their specific
responsibilities.
o Equipment requirements. Identifies all safety and sampling
equipment and supplies.
o Subcontractor procurements. Describes any contractual services
needed to accomplish field vork (i.e., drilling).
o Vaste disposal procedures. Requires that all wastes generated
during field activities be disposed of in accordance with
Resource Conservation and Recovery Act (RCRA) regulations. In
many cases, it may be possible to dispose of wastes on-site
assuming the owner/operator grants permission.
o Special training requirements. Specifies training required if
new equipment or procedures are to be used.
3-5
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OSVER Directive 9345.1-02
3.2.3 Evaluation of Existing Data
Existing data should be evaluated for quality and reliability before
field work begins to develop effective work and sampling plans. In most
instances, little quantitative information will be available unless Sis,
Technical Assistance Team (TAT) responses, or emergency removals have
been conducted at the site. If analytical data exist, the following
information should be available for HRS documentation purposes:
o Sampling date
o Sampling team or person in charge
o Sampling location and description
o Collection technique
o Field preparation technique
o Chain-of-custody procedures
o Laboratory preparation techniques
o Laboratory analytical method
o Laboratory detection limits
o QA/QC samples taken
o Field replicates taken
o Rinsate data
3.3. SAMPLING PLAN
The ESI sample plan is incorporated into the overall work plan and
identifies sampling locations, rationale, logistics, and frequency. To
meet the objectives of the ESI, it should define the number of samples
for each matrix necessary to support the HRS and characterize the site.
The sample plan should also consider data sensitivity, which potentially
involves application of statistical techniques to determine confidence
levels in data collected. Extensive statistical analysis, however, is
inappropriate for general pre-remedial vork.
3.3.1 Contaminants of Interest
The waste constituents known or likely to be found at each site and
in surrounding environmental media need to be identified (Table 3-2).
They may be determined from site data, including records identifying
wastes deposited, site history, site operations, and generators of
wastes deposited at the site. Field screening methods may also be
appropriate to determine the contaminants of interest.
3-6
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OSVER Directive 9345.1-02
TABLE 3-2
POTENTIAL INDUSTRY-SPECIFIC CONTAMINANTS
MINING
Metal and Coal Mining Industries
PH
Sulfate
Nitrate
Chloride
Total dissolved
solids
Phosphate
Copper
Nickel
Lead
Chemical Oxygen
Demand (COO)/
Biological
Oxygen Demand
(BOD)
Total Organic
.Carbon (TOC)
PH
Heavy metals
COD/BOD
pH
Total dissolved
solids
Heavy metals
Zinc
Tin
Vanadium
Radium
Phenol
Selenium
Iron
Chromium
Cadmium
Uranium
PAPER AND ALLIED PRODUCTS
Pulp and Paper Industry
Phenols
Sulfite
Color
Biocides
CHEMICALS AND ALLIED PRODUCTS
Organic Chemicals Industry
Alkalinity
TOC
Total phosphorus
Magnesium
Silver
Manganese
Calcium
Potassium
Sodium
Aluminum
Gold
Fluoride
Cyanide
Nitrogen
Phosphorus
Total dissolved
solids
Phenols
Cyanide
Total nitrogen
Inorganic Chemicals, Alkalies, and Chlorine Industry
Acidity/alkalinity
Total dissolved solids
Chloride
Sulfate
COD/BOD
TOC
Mercury
Chlorinated benzenoids Chromium
& polynuclear Lead
aromatics Titanium
Phenols Iron
Fluoride Aluminum
Total phosphorus Boron
Cyanide
Arsenic
3-7
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OSVER Directive 9345.1-02
TABLE 3-2 (Continued)
POTENTIAL INDUSTRY-SPECIFIC CONTAMINANTS
CHEMICALS AND ALLIED PRODUCTS
Plastic"Materials and Synthetics Industry
COD/BOD
pH
Phenols
Total dissolved
solids
Sulfate
Phosphorus
Nitrate
Organic nitrogen
Chlorinated ben-
zenoids and
polynuclear
aromatics
Ammonia
Cyanide
Zinc
Mercaptans
Ammonia
Chloride
Chromium
Total dissolved
solids
Nitrate
Calcium
Dissolved solids
Fluoride
pH
Phosphorus
Nitrogen Fertilizer Industry
Sulfate COD
Organic nitrogen Total iron
compounds pH
Zinc Phosphate
Sodium
Ammonia
Chromium
COO/BOO
PH
Phenols
Sulfide
Total dissolved
solids
pH
Chloride
Sulfate
Ammonia
Phosphate Fertilizer Industry
Acidity
Aluminum
Arsenic
Iron
Cadmium
PETROLEUM AND COAL PRODUCTS
Petroleum Refining Industry
Chloride
Color
Copper
Cyanide
Iron
Lead
Mercaptans
Mercury
Nitrogen
Sulfate
Uranium
Vanadium
Radium
Nitrogen
Odor
Total phosphorus
Sulfate
TOC
Turbidity
Zinc
PRIMARY METALS
Steel Industry
Cyanide Chromium
Phenols Zinc
Iron
Nickel
3-8
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OSVER Directive 9345.1-02
TABLE 3-2 (Continued)
POTENTIAL INDUSTRY-SPECIFIC CONTAMINANTS
ELECTRIC, GAS, AND SANITARY SERVICES
Pover Generation Industry
COO/BOO Copper Phosphorus
Polychlorinated Zinc Orgnaic biocides
biphenyls Chromium Sulfur dioxide
Total dissolved Other corrosion Heat
solids inhibitors
Oil and grease
Municipal Sevage Treatment
pH . Nitrate Sulfate
COD/BOD Ammonia Copper
Alkalinity Chloride Tin
Detergents Sodium Zinc
Total dissolved Potassium Various organics
solids
(From NEIC Manual, Ground Vater/Subsurface Investigations at Hazardous
Waste Sites, July 19gl)
3-9
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OSWER Directive 9345.1-02
3.3.2 Sample Types
The sampling plan should identify 'the number of each sample type to
be collected, describe collection methods, and specify each sampling
location with a brief rationale for the selected location. The plan
should differentiate between analyses performed in the field using
screening techniques, and those performed at a contract lab.
Samples are generally taken to:
o Define background conditions
o Characterize the source
o Characterize transport pathways in a preliminary fashion
o Define receptor impacts and effects
Figure 3-1 presents an ESI sample form.
3.3.3 Sampling Locations and Frequency
A site map should be prepared pinpointing and describing sample
locations, as well as sample type (soil, sediment, water), volume, and
number. General criteria for determining locations are:
o Select enough locations to delineate source, background, general
spatial extent of contamination, actual (or potential) pathways,
and impact on susceptible receptors, as well as to support
simplified modeling needs.
o Minimize the number of samples according to the "necessary and
sufficient" philosophy while still meeting ESI objectives.
The sampling plan should clearly state levels of confidence
considered adequate. These levels are determined in part by the ESI
objectives (i.e., HRS support and remedial contractor support) and by
the guidelines in Chapter 2.
Sampling frequency depends on site environment and the most probable
pathways for transport. Pathways or receptors affected by seasonal
variations or weather patterns may require multiple sampling (i.e., ESI
investigator can recommend further sampling to the remedial contractor).
For a more detailed discussion on sampling preparation, see Site
Inspection Sampling Strategy to Support HRS Scoring (Draft) (1986).
3.3.4 Operational Plans
Clearly specified responsibilities and procedures contribute to safe
and cost-effective field sampling. A sampling operations plan should
contain:
o List of team members to ensure availability of required
expertise.
3-10
-------
FlftftC VI
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OSVER Oirtetiv* 9345.1-02
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3-11
-------
OSVER Directive 9345.1-02
o Sampling reports/documentation describing all sampling forms to
be completed (i.e., log books, chain-of-custody, sample receipt
forms, sample traffic reports, sample tags, custody seals).
o Analytical and sample handling requirements. Discusses analyses
to be run on each sample (volatile organics, metals, PCBs, etc.),
specific levels of sample quality (i.e., Level I-V), appropriate
preservation techniques and materials, tools needed for sample
collection, and containers for storage. Much of this information
can be referenced to SOPs for field sampling procedures. Figure
3-1 is a useful format for documenting the above information on a
sample-specific basis.
o Lists of equipment required and procedures for use.
o Collection plan vith a map of sample locations and sample types.
The phased approach to sampling should be strongly considered
(i.e., geophysics to target monitoring veil locations and field
screening to target CLP samples). In addition, the specific
sampling duties of each field team member should be
discussed—vho will take samples, maintain the logbook, monitor
the site for releases, etc.
o QA sample plan. Identifies the number and type of QA samples
(i.e., number of blanks, duplicates, and spikes).
o Decontamination procedures and equipment. Disposal permits may
be necessary to dispose of the waste generated in field
activities.
o Sample delivery. Identifies final disposition of all samples
(i.e., lab analysis locations, if known, and persons to whom any
splits are to be delivered).
3.4 HEALTH AND SAFETY (H & S) PLAN
A major concern in pre-remedial investigations is the protection of
the health and safety of the investigative team, as well as the general
public. EPA, corporate, and State health and safety programs and
written site-specific safety plans are a means for assuring overall safe
operations. All parties must implement the applicable regulations to
protect workers and the general public.
3.4.1 Regulatory Overview
The Occupational Safety and Health Administration (OSHA) published
an interim final rule (December 1986) governing employees engaged in
"hazardous waste operations" (29 CFR 1910.120). The rule explicitly
applies to pre-remedial activities, as well as RIs. Other regulations
protect the health and safety of hazardous waste response workers and
the general public:
o U.S. Department or Transportation (DOT) regulations (49 CFR
171-178).
3-12
-------
OSVER Directive 9345.1-02
o Resource Conservation and Recovery Act (RCRA) regulations
governing the storage, transport, and disposal of
investigation-derived vastes.
o State occupational safety and health rules, which may be more
stringent than Federal regulations. State rules should be
consulted to determine applicability to site activities.
For an in-depth discussion of hazardous vaste site health and safety
considerations see the NIOSH/OSHA/USCG/l/SEPA publication entitled
Occupational Safety and Health Guidance Manual for Hazardous Vaste Site
Activities (October 1995).'
3.4.2 Site-Specific Health and Safety Plans
A vrltten H & S plan is prepared for each ESI. It assesses site
hazards and outlines specific procedures to protect vorkers, as veil as
limitations on activities. The plan is often prepared after the work
plan and sample plan are completed. Early preparation of the H & S
plan helps identify potential problems, including the availability of
adequately trained personnel and equipment.
All H & S plans should be prepared in accordance vith EPA's Standard
Operating Safety Guide Manual, November 1984, and then approved by the
H & S director. The H & S plan should include:
o Description of known hazards and risks. Describes location,
topography, climate,, current status of vastes and other materials
on-site, legal status, site security, and vaste types,
quantities, locations, etc. (Much of this information can be
incorporated by reference to other portions of the vork plan or
PA report). Reviews resources such as roads, water supply,
electricity, and telephone. Also states the purpose of the ESI,
lists planned actions and dates, and forms the basis for the
prescribed protective strategies.
o List of key personnel. Describes the H & S responsibilities of
each team member, including the Project Team Leader and Site
Safety Officer. The H & S Director approves personnel to help
ensure that they have the proper medical and training
certifications (i.e., first aid and cardiopulmonary resuscitation
(CPR)).
o Identification of levels of protective gear required. Specifies
level (A, B, C, or D) for each activity (i.e., sampling,
drilling, decontamination) and describes the modifications
required for initial site entry. Criteria should be set, based
on preliminary monitoring data, for changing the level as needed.
Vhen the types and amounts of chemicals are not known, a
worst-case scenario should be assumed.
o Evaluation of hazards. Summarizes toxicological data on wastes
known or suspected to be present. Particularly important is an
analysis of exposure routes and information regarding permissible
3-13
-------
OSVER Directive 9345.1-02
exposure levels, such as the threshold limit values (TLVs) or
OSHA permissible exposure limits (PELs). Synergistic or additive
effects should be analyzed. Physical factors such as potential
heat stress, frostbite, radiation, falls, electrical shock,
unstable ground or structures, barriers, and heavy equipment
(i.e., drill rig) use should be examined.
o Description of site monitoring program. Outlines in detail the
monitoring requirements based on the hazard evaluation. For many
sites, however, total organic vapor analyses, rather than
analyses for specific compounds, are most practical. Survey
instruments include: organic vapor analyzer (OVA), explosimeter,
oxygen meter, draeger tubes, and radiation detectors. These
tools should be used only as preliminary indicators, since expert
judgment is required to interpret monitoring data and select
optimal protection strategies.
o Identification of field work areas and access control procedures.
Includes a map designating the exclusion area (control area),
contamination reduction area, support area, and command post. In
addition, access control points must be identified to regulate
entry and exit from the exclusion area. Finally, the
contamination reduction area or personnel decontamination station
should be located upwind, of the exclusion area to prevent
contamination moving off-site.
o Decontamination procedures. Prescribes the requirements for
decontamination, including equipment, solutions, and step-by-step
procedures (may suffice to reference SOP documents). The problem
of waste disposal of investigation-generated wastes should also
be addressed. Certain waste streams may require RCRA permits.
o Emergency information. Provides telephone numbers for police,
fireT ambulance, and hospital, and a map clearly outlining the
fastest route to the hospital. Other useful emergency
information includes telephone numbers of the PRP, EPA poison
control center, and consulting physicians and toxicological
experts. Standard procedures for reporting emergencies should
also be included.
3.5 REFERENCES
Existing guidance or information on the status of evolving guidance
can be obtained from EPA Headquarters Site Assessment Branch, Hazardous
Site Evaluation Division, Office of Emergency and Remedial Response
(EORR).
Contacts; Penny Hansen (FTS-475-8103)
Jim Jowett (FTS-475-8195)
o NIOSH/OSHA/USCG/USEPA, Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities, October 1985.
3-14
-------
OSVER Directive 9345.1-02
o Revised HRS/SI Bulletins, prepared periodically beginning Fall
1987.
o Site Inspection Sampling Strategy to Support HRS Scoring (Draft),
OSVER Directive 9345.1-01, January 1986.
o Standard Operating Safety Guide Manual, OSVER Directive
9285.1-Olfl, November 1984.
3-15
-------
OSVER Directive 9345.1-02
CHAPTER 4 SUMMARY
WHAT ARE THE MAJOR OBJECTIVES OF THE ESI FIELD INVESTIGATION AND VHAT
GENERAL SITE CHARACTERIZATION METHODS SUPPORT DATA COLLECTION
REQUIREMENTS?
o SITE INVESTIGATION OBJECTIVES
- Substantiate representative HRS Score
- Make preliminary identification of contaminant source(s),
pathvay(s), and potential receptors
- Generally determine area of contamination
0 -DATA COLLECTION REQUIREMENTS
- Contaminant source investigation - to determine toxicity,
persistence, and mobility of pollutants
- Geologic investigation - to determine influence on water and
contaminant transport
- Ground vater investigation - to determine rate, general
direction, and concentration of transported contaminants
- Surface vater investigation - to identify potential surface
vater runoff pathways, and concentrations of contaminants
- Atmospheric investigation - to document an observed air release
and to define the path and rate of dispersion of airborne con-
taminants
o GENERAL SITE CHARACTERIZATION METHODS
- Field analytical screening.techniques
* Organic vapor analyzer (OVA) and field gas chromatograph (GC)
measure:
(1) soil vapors in the vadose zone
(2) headspace of vater and soil samples
(3) vapors from boreholes and monitoring veils
(4) ambient air samples
- Surface geophysical techniques
* Ground penetrating radar (GPR) - locate buried vastes and map
stratigraphic horizons
* Electromagnetics (EM) - characterize subsurface contaminant
plumes and continuity of low-permeability layers
* Resistivity - characterize contaminant plumes
4-1
-------
OSVER Directive 9345.1-02
•
* Seismic refraction - determine depth and thickness of soil
and rock layers, depth to bedrock, and potential location of
water table
* Hagnetometry - locate buried vastes and map geological struc-
ture influencing waste migration
Installation of monitoring veils
* Veils can contribute to:
(1) characterization of geology beneath the site
(2) identification of ground water conditions
(3) determination of depth and general extent of contamination
4-2
-------
OSVER Directive 9345.1-02
4.0 FIELD INVESTIGATION PROCEDURES
4.1 INTRODUCTION
The objectives of an ESI field investigation include those of a
traditional SI (i.e., sampling to document an HRS score), in addition
to collecting general data to help future contractors develop the RI
work plan. Furthermore, ESIs vill provide data to bring enforcement
action or initiate negotiations vith PRPs. Enough information must
be collected and analyzed to:
o Substantiate a representative HRS score.
o Make a preliminary identification of contaminant source(s),
pathvay(s), and potential receptors.
o Generally determine the area of contamination.
Potential source types, release modes, migration modes, and
routes of exposure associated vith hazardous waste sites are illus-
trated in Figure 4-1. The vide range of vaste effects and their
interactions may necessitate further vork to characterize wastes,
geology, ground vater and surface vater hydrology, atmospheric condi-
tions, and environmental and human health effects.
4.2 APPROACH TO SITE CHARACTERIZATION
To help the remedial contractor develop the RI vork plan, the
ESI must compile existing data to provide a clear picture of the
overall problems at a site. Sources of existing data include the PA
and information on any previous response/field activity. Much of
this compilation and reviev should have been completed as part of
preparing the ESI vork plan and sample plan.
The site characterization effort should also screen potential
sources, pathvays, and receptors to provide the basis for subsequent
RI field vork and the preliminary evaluation of remedial alterna-
tives.
4.2.1 Data To Be Collected
Data to be collected during an ESI include, but are not limited
to, the following:
o Environmental setting: Description of the layout of the site
and surrounding areas; topography; location of vastes; vaste
types; normal and unusual meteorological conditions; surface
drainage patterns; geologic features; ground vater occur-
rence, flov direction, and rate; and soils.
o Hazardous substances; Analytical data (mostly field screen-
ing data) characterizing vastes, including type, quantity,
physical form, concentration, disposition, and conditions
affecting release.
4-3
-------
RELEASE MODES
MIQRATION MODES
CONSUMPTION MOOES
BURIAL SITE
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Flour* 4- 1. OVERVIEW OF EFFECTS AND INTERACTIONS AT A
REPRESENTATIVE HAZARDOUS WASTE SITE
(From Ouldanc* on Remedial lnv««llo«Uon» under CERCLA. II.9. EPA. Jun» 1O86)
-------
OSVER Directive 9345.1-02
o Environmental concentrations; Analytical data on contamina-
tion of air, soil, surface water, and ground water both on
and near the site. Should be sufficient to generally define
the origin, extent, direction, and rate of movement of
contaminants.
o Potential impact on receptors; Data describing the human
populations and environmental systems susceptible to contami-
nant exposure via the transport pathways from a site.
Permits ATSDR to generally assess potential exposures.
4.2.2 General Characterization Methods
ESIs imply use of technical approaches no* necessarily part of
the traditional SI including:
o Increased use of field screening techniques (i.e., portable
GC), which can:
- identify contaminants present
- provide semiquantitative estimates of concentrations
- determine the general extent of contamination in soils,
air, and water
- optimize CLP sampling efforts (i.e., minimize the number of
"no-detection" samples).
o Surface geophysical surveys which:
- delineate hydrogeologic features
- determine subsurface contamination and general direction of
flow
- locate boundaries of buried trenches and lagoons
- locate buried drums and tanks
- delineate general site geology (i.e., depth to bedrock,
lateral and vertical variations in soil and rock types).
o Installation of monitoring wells, which enable the investiga-
tor to:
- collect ground water samples
- conduct aquifer/aquitard tests
- characterize all aquifers of concern
- measure fluctuations in the water table
- estimate direction of ground water flow
- determine general subsurface stratigraphy
- collect subsurface soil/sediment/bedrock samples.
o Careful visual observations (with photo documentation), which
help to:
- identify source/origin of contaminants
- identify type/condition of containers
- estimate migration potential
- Prepare detailed site map (size, boundaries, buildings,
etc.).
4-5
-------
OSVER Directive 9345.1-02
While these efforts are generally applicable to all sites, the
scope of work should be developed on a a case-by-case basis.
4.3 TECHNICAL INVESTIGATIONS
ESI technical investigations should focus on characterizing
waste sources, transport pathways, and receptors. These investiga-
tions can be categorized as studies of waste sources, geology, ground
water hydrology, surface water hydrology, atmospheric conditions, and
contaminants of concern.
4.3.1 waste Sources
Characterizing waste sources involves collection of data
describing the physical and chemical properties of waste materials
and how they are contained. Relevant data can be grouped into two
categories: (1) waste characteristics, such as the types and quan-
tities of contaminants that have been or may be released to the
environment and (2) facility data that characterize how these con-
taminants may be released (Table 4-1).
It may be necessary to collect data on the types of contami-
nants, location and volume (horizontal and vertical extent) of
sources, and variation of concentrations within the sources. Vhen
extensive grid sampling is required over three dimensions, field
screening techniques should be used, with a limited number of CLP
samples collected in key locations.
Geophysical surveys (Section 4.3) can effectively map the loca-
tion and extent of buried waste deposits and ground water contaminant
plumes, as well as define site geologic conditions when correlated
with a limited number of subsurface samples collected at key loca-
tions. Aerial photography and infrared imagery can aid in defining
sources by documenting site activities over time and by providing the
basis for interpreting ecological impacts resulting from stressed
biota.
4.3.2 Geology
Site geology has a marked influence on release of contaminants,
water movement, contaminant transport, and feasibility of remedial
measures. Ground water flow and potential contaminant migration are
influenced by folds, faults, joints, and fractures (Table 4-2).
Stratigraphic information may be used to identify aquifers and
confining formations so that the aquifers most likely to transport
contaminants can be delineated.
4.3.3 Ground Water Hydrology
To characterize contaminant transport in ground water requires
determining the hydrologic properties of aquifers (Table 4-3). The
general direction of ground water flow can be estimated by comparing
static water elevations in a series of wells completed in the same
zone of an aquifer. The flow rate can be estimated using data on
4-6
-------
TAMLt 4-1 SOUP.CI AMD PACILITf IMrOINATIOH HCIOIO fOB 1*1*
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o Concent rat !<>•• ••%•*•!•• «v«iititl** *ad comc»mt r*t Ion* Sit* laipectton ••••>! !•* «*d
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direct ceatcct; aey dictate reipenae
e *••«•• di«cker«e peiata Provide peiaita for accidental or Site iaapectiaa
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• Napa and Survey* tecate eilctlMf atructnre* and falatlae; aapa IOSOS. c*«aty, S«r*eyl>« (i.e., fer
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(Modified fr*« Qyldance en ienedlal Invoa t loot loa* Under CI»CLA. U.S. IP». Jaa* l»»»l.
-------
TABLB 4-1 OBOLOaiC IltrolNATIO* MCBDBD fOR Bit*
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mrO»MATIO» »ttP«D
TAPLC 4-1 OBOUHP WATIB IMFOBNATIO* •BCOIO FOB CSIl
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-------
OSVER Directive 9345.1-02
ground water surface gradients, and hydraulic conductivity and
porosity; the flow rate can be determined more precisely by aquifer
tests, if necessary. The direction and extent of contaminated ground
water plumes can often be identified by using geophysical surveys.
4.3.4 Surface Water Hydrology
If contaminants could be transported via surface water runoff,
sampling should be performed to evaluate the types and levels of
contaminants present. Surface water pathways depend greatly on
weather conditions (Table 4-4). Therefore, data should be collected
at specific locations under known meteorological conditions and
through periods (if possible) representing natural cycles in ambient
conditions.
4.3.5 Atmospheric Investigations
The MRS revisions will probably require more extensive charac-
terization of the air pathway. Data on the characteristics of an
observed or potential release and atmospheric conditions may be
required to help define the path and dispersion of airborne contami-
nants (Table 4-5).
4.3.6 Contaminants of Concern
Before the potential for human or environmental exposure can be
analyzed, the chemicals on which the analyses will focus must be
selected. The goal is to choose chemicals that represent the most
serious hazard in terms of prevalence, persistence, toxicity, and
mobility. If enough information is available, the "indicator" chemi-
cal should be selected when the ESI sample plan is being prepared.
Sampling data for contaminants of concern will be used by the ATSDR
to conduct a Public Health Assessment before the remedial alterna-
tives are selected.
4.4 INVESTIGATION TECHNIQUES
Traditional Sis encompass only sampling to score a site for the
NPL. ESIs, however, have the added objective of providing the reme-
dial contractor with the "big picture," so that RI/FS activities may
begin in a timely fashion. A number of investigation techniques are
available (Table 4-6) from which project managers can select to solve
site-specific problems. To help determine the spatial sampling
requirements for each technique, see Section 2.4.4.
For more detailed descriptions, including instrument calibration
and operation procedures, see Quality Assurance/Field Operation
Methods Manual (1986), contractor SOPs, and instrument user manuals.
No single technique/approach will solve every ESI problem.
Combining SI sampling/analysis approaches does, however, provide a
complete site picture with greater confidence levels and in a
cost-effective manner.
4-10
-------
TABLC 4-4 JUB.PACK WAT IP, IPJPOP.NATIO* n«(DCO POP. (SI*
A»p»opp.iATt coiitcrto* NCTBODS
•.ATlOBAtC PP.IIIAP.T ~~~ SICONDAP.V
OIAIMAOI PATTIB.BS:
o Overland flow, P*t*rBlne If everland or ckanael flew Tepograpklc ••pa, *lt* Aerial pkete*.
topoarapby. ckannel c*B recwlt in en-alt* or off-*lt« flow Inspection
flow pattern, trlbw- and If pattern* form ceatavlnant
tary ra I a11onifcip*
SUHPACC WATCI •OOKSl
• Plow, atraam wldtb*/ ••(•*•!•• volnne and velocity, trana- Pnbllc afancy data *nd Aorlal pfcetea.
deptk*. ckeanel P*rt tl«*a, dilwtion potential, atlaaea; catalof*, aapa, »m4
elevatien*. fleodlnf ••tontlal *pr*ad of contamination fcandbooi* for backfrewnd data
tendenci *•
Structure* poteirmlna effect •• centanlnant trana- Pwbllc afancy napa/rocord*
p*rt/>ltifatl*n
Prodlct centanlnant patkway* for inter- Public a«ency report*/ V*.t*r level
coptlve actlena (I.e., elurry valla) curvey* •<
StflPACK WATBB QUALITTI , 2
O
• ••. tanperatnra. total ••toralne capacity of wator t* carry Pwbllc afency c*npat*rl*od flaapllnf and analyai* ^
• wapended aellda, coBtanlnanta, water/**dl*>*nt data filea, kandbeoka, 4
cendwct I v| ty. **llalty »)*r 111 l*nln« llteratnr* •
apoclfic centamlnant . ^
concentr*tIon* U»
»^
(Hedlfled fron) Owldanca on kenedlal Inve*tl«atiena Pnder CtkCLA, O.S. BPA, *••• ItlS.I O
-------
TAILt 4-9 ATNOSmKUC IMrolNATIOB •ICOSO fO« CSIa
A»r«omiAT« COLUCTIOB HCTBOOI
MCCOCO RATIONALI PNIHAIT SCCoajDABf
LOCAL CLINATC:
• Proclpl tat ton Dofin* racharfo. • v«p« r • 1 1 on pat«nti«l, ••ttencl €!!••(• c*at*r IUCCI O«-*lt« •••••r«>«Bt •/
pr*k«bl« tr«»*part direction National Oc*«nic and Atno*- •••or*atlea«
• Tonporaturo pnoric Adnl n I • t r • t i on , loenl
voathor
• Mintf tpood/diroct Ion
MKATMCB
o Storai Ootornino offoct of •••thor octrono* MCC, Stato onor^oncy ptannlnf
orrico*
• Mood* O
• wind* gj
••LIAS! CBA«ACT««I«TICf I O
*1
• Dl roct ion/»po*d of Oototmino dlcnoralon cncract or 1 «t ici Information from aonrco Oa-«lto air nonitorln« •
pluno *o*onont of roloaao facllltf. Koatnor aorvicoa, atationa ^
•ir nonitoriaf ••rvlcoa M-
• Contaminant con- (1*14 seroonlnf
controtlona. tochnio,«o« *O
' »-
u»
•
(Hodlfiod from ainldanco on «onodlal inooat l^at tona Ondor CI»CLA. U.S. irA. Jano lffl».) V*
- - o
K>
-------
TABLB 4-4
•UBPACB OBOPNTSICAL TECHNIQUES Poll BASABDOUS WASTE IITI INVBSTiaATlONS
(Modified fro* Technoe Inc., Application Ouldellaea -
Selected Contemporary Tec
OBOUND-
PBNBTBATINtt
BADAB
BVALUATION OP NATOBAL NSOLOatC AND
NTDBOLOOIC CONDITIONS
Depth and thlcknaaa a( aail and rack t*
leyere aad vertical varlatlena
Mapping lataral variatlana In aell I
and rack (frecturaa, karat faaturea.
ate. 1
- Depth af water taala }
•VALUATION OP SOBSUBPACB CONTAMINATION
AND POST CLOSUBB NONITOBINtt
Inorqeaice (hle,b total dlaaelved aellda
(TDSI and electrically conductive)*
Carly oarnlnfl ceatemlmamt datactloo
Detailed lataral •applaf
Vertical aatant
Chaaaea of plume with time (flew
^ directloa and ratal
1 Organic* (typically aon-conduct 1 ve ) •
J^ - Be r ly •aralae, ceatamlaant detectlun
- Detailed lataral mapping ,
Vertical aiteat
- Chan«aa ef pl«me with tlma (flew
direction and ratal
LOCATION OP BOBIBD WASTBS AND DILINBATION
OP TBBNCN BOUNDABIBS
Bulk waate trenchea — wltaaut metal
Bulk waata treachea — with metal
Deptk and lateral eateat •(
trenchea and laadfllla
Detection af It-fallen ateal drum*
Batlmetaa af depth aad eju-aatlty of
>S-fallam ateel druma
LOCATION OP UTILITIBS
•uried plpea aad tamka 1
Potential pathway* at centemlneat 1
ml«retlon vie camdulte amd permeable
trench backfill
Abandoned wella with metal caalna )
*The varloua appreachea are In 9oneral equelly applic
bniquea for Sub»urf
•LBCTBO- BBSIS-
NAONBTICS TIVITT
I 1
1 I
2 1
a
i
a
NA
1
1C NA
2 NA
NA NA
able to both the ia
ace Invaat 1
SKISHIC
BCPBACTION
1
J
1
NA
• A
NA
NA
NA
NA
NA
NA
)
)
1
NA
NA
1
NA
NA
t u r a t ed and
flatten!) .
NBTAL
DBTCCTOB T
NA
•A
•A
NA
NA
NA
NA
NA
NA
NA
NA
•|
1*
NA
|"
2
_•
»*
2
2
unea tur a tad
NA4NC-
OMBTBT
NA
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
NA
1
1
b
l"
2
K
1°
aonea .
t a 1 a to
OBOANIC
VAPON
ANALTBBBS
NA
NA
NA
NA
NA
NA
NA
1
1
2
1
4
• mV
•*1
NA"
d
NAd
4
NA
A
NA"
e p e a
1 .
O
tfl
O
-------
OSVER Directive 9345.1-02
ESI techniques include but are not limited to:
o Field screening
- organic vapor analyzers (OVA)
- field gas chromatographs (GC)
- soil/gas monitoring.
o Surface geophysical techniques (Table 4-6). They can provide
valuable information, but their use must be evaluated on a
case-by-case basis. In most instances, complementary tech-
niques should be used to confirm data and resulting interpre-
tations. Geophysical techniques include:
- ground-penetrating radar
- electromagnetics
- resistivity
- seismic refraction
- metal detection
- magnetometry.
o Installation of monitoring veils.
4.4.1 Portable Organic Vapor Analyzers (OVA/GC)
Portable field screening instruments can measure organic vapors
to levels of low ppm to low ppb. Instrument response is a function
of the organic chemicals' volatility and quantity. Typically, the
OVA and GC are used at stations, but the OVA can also make continuous
measurements along profile lines. Types of samples to be monitored
include:
o Soil vapors in the vadose zone (i.e., soil/gas monitoring)
o Head space of water and soil samples
o Vapors from boreholes and monitoring veils
o Ambient air
The OVA/GC techniques are susceptible to interference from other
airborne vapors. Instruments must be handled by experienced and
qualified technical personnel to ensure reliable results. The tech-
niques provide different analytical levels of data, vith the OVA
providing semiquantitative data on total organics (Level I), and the
field GC providing qualitative and semiquantitative data on specific
constituents (Level II).
4.4.2 Ground-Penetrating Radar (GPR)
The GPR instrument responds to changes in electrical properties,
vhich are a function of soil and rock material and moisture content.
Data are generally in the form of a picture-like display (continuous
two-dimensional profiles). The unit can be pulled by hand or
vehicle, at rates of 0.5 to 5 mph, and tens of acres or more can be
surveyed in a day. In general, the instrument provides:
4-14
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OSVER Directive 9345.1-02
o High resolution profiles (depending on antenna frequency).
o Varying depths of penetration (depending on antenna frequency
and soil moisture/clay content) — typically less than 15 to
20 feet, and rarely in excess of 50 feet.
4.4.3 Electromagnetics (EM)
The EM instrument measures bulk electrical conductivity, vhich
is a function of the soil and rock density, percent saturation, and
conductivity of pore fluids. Depth of investigation varies depending
on instrument coil spacing and configuration. Both station and
continuous profile measurements can be made to depths of up to ISO
feet.
In general, EM surveys provide excellent lateral resolution
(profiling) but limited vertical resolution (sounding); as a result,
EM methods are often combined with other geophysical investigations
i.e., GPR). The technique is susceptible to interference from metal
pipes, cables, fences, vehicles, and noise from pover lines.
4.4.4 Resistivity
The resistivity instrument measures bulk electrical resistivity,
vhich is a function of the soil and rock matrix, percentage of satu-
ration, and conductivity of pore fluids. Resistivity surveys result
in good vertical resolution to depths of 100 feet, and may also be
used for lateral profiling. One drawback is that the instrument
requires direct ground contact, allowing only station measurements to
be made (less efficient than continuous profiles). The technique is
susceptible to interference from metal pipes, fences, and cables.
4.4.5 Seismic Refraction
The seismic refraction technique measures seismic velocity of
rock, which is a primary function of soil and rock density. Data
output is in the form of two-dimensional cross sections, and Informa-
tion on the depth and thickness of soil and rock layers are obtained.
Measurements can be made to depths of 100 feet or more but are
station-specific. Collection of continuous profile data is time
consuming because geophone arrays must be moved, but seismic data can
provide a complete subsurface picture across a site. Seismic surveys
are susceptible to acoustic noise and vibrations, although available
equipment can filter ouch of this interference.
4.4.6 Metal Detectors
Metal detector response is a function of object depth and sur-
face area. Continuous profiles are obtainable, and both ferrous
(iron) and non-ferrous metals may be detected. Instruments can be
hand carried or vehicle mounted and detect single 55-gallon drums at
depths up to 8 feet or large masses of drums up to IS feet. Measure-
ments are susceptible to interference from trash metal, nearby metal
pipes, fences, etc.
4-15
-------
OSVER Directive 9345.1-02
4.4.7 Magnetometry
Magnetometer response is a function of an object's iron content
and its depth and mass. Station or continuous profile measurements
are possible, and magnetometers may be hand carried or vehicle
mounted. Depth of resolution is greater than that of metal detec-
tors; single 55-gallon drums can be identified at depths up to 18
feet and large masses of drums up to 60 feet. Measurements are
susceptible to interference fro« steel pipes, fences, vehicles, and
buildings.
4.4.8 Monitoring Veil Installations
In the past, monitoring veils have not been routinely installed
vhen gathering data for HRS scoring. Field teams will sample exist-
ing private and municipal veils; hovever, the ESI objective of
supporting the RI could, in many instances, warrant installing
moni tofing veils.
Monitoring veils and aquifer tests can contribute to:
o Characterization of geology beneath the vaste site
- depth to bedrock
- correlation of stratigraphic units between soil/rock
borings
- core/interval sampling to identify the depth and extent of
contamination
- identification of the confining layer/formation
- identification of zones of potentially high hydraulic con-
ductivity
- indication of unusual or unpredicted geologic features such
as fault zones, facies changes, and buried stream deposits.
o Identification of ground vater conditions
- depth to vater table
- direction of horizontal and vertical flov of ground vater
- seasonal/temporal, naturally and artificially induced
variations in ground vater flov
- hydraulic conductivities of significant hydrogeologic units
underlying the site
- possibility of aquifer interconnections.
o Determination of depth and extent of contamination
- necessity for both ungradient and dovngradient veils
- field screening/CLP analysis of veil samples.
Veil placement decisions should be based on field screening and
geophysical surveys. Veils upgradient of the site as veil as dovn-
gradient are necessary to provide background information. At least
three veils are required to estimate hydraulic head, flov gradients.
and flov directions.
4-16
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OSVER Directive 9345.1-02
4.5 REFERENCES
Copies of existing guidance or information on the status of
evolving guidance can be obfined from the EPA Headquarters Site
Assessment Branch, Hazardous Site Evaluation Division, Office of
Emergency and Remedial Response (OERR).
Contacts; Penny Hansen (FTS-475-8103)
Jim Jovett (FTS-475-8195)
o Geophysical Techniques for Sensing Buried Wastes, EPA
Contract No. 68-03-3050
o Quality Assurance/Field Operations Methods Manual (Draft),
Volumes 1-4, OSVER Directive 9355.0-14, March 1986
4-17
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OSVER Directive 9345.1-02
CHAPTER 5 SUMMARY
HOW WILL BSIs SUPPORT RI SCOPING AND DEVELOPMENT OP RI WORK PLANS?
0 RI SUPPORT
- Collect data to assess general nature and extent of contamination
- Prepare ESI report in format compatible vith RI work plan
o LIMITED FIELD INVESTIGATION (DATA COLLECTED BEYOND THE MINIMUM FOR
BRS SCORING):
- Conduct preliminary geophysical investigations
- Install monitoring veils
- Monitor air
- Use screening techniques extensively
- Prepare detailed site maps shoving the locations of wastes,
veils and samples; probable extent of contamination; and poten-
tial areas for further study.
5-1
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OSVER Directive 9345.1-02
5.0 ESI SUPPORT TO RI SCOPING AND DEVELOPMENT OF RI VORK PLAN
A principal ESI objective is to provide the remedial contractor
with site information beyond that required for the HRS to facilitate
development of the RI work plan. The ESI can:
o Collect and analyze existing and ESI data to assess the
general nature and extent of contamination.
o Complete limited field investigation to characterize all
three migration pathways. Activities include:
- collection of analytical field screening data
- installation of monitoring veils
- application of surface geophysical techniques.
o Determine existing and potential impacts from the site on
public health and the environment.
o Provide limited support to ATSDR, community relations, and
enforcement.
o Organize information in a format compatible with RI work
plans.
The RI scoping and vork plan development process is described in
EPA's revised RI/FS Guidance Document. ESIs are not designed to
completely replace these preliminary RI/FS efforts, but they should
both support and help shorten the remedial planning process.
5.1 EXISTING AND ESI DATA
ESI field vork vill help to understand site conditions through
extensive site screening data, more CLP samples, monitoring veil
data, and geophysical survey data. The field vork should:
o Investigate the hazardous vastes disposed of at a site.
Sample results should be summarized in terms of physical and
chemical characteristics, contaminants identified, and
concentrations present,
o Reviev records of site disposal and operating procedures to
identify vastes on-site, vaste haulers and vaste generators
when vaste records are unavailable, or vaste products (vhich
may be inferred from manufacturing processes used by
identified vaste generators).
o Summarize existing site-specific and regional information to
help identify surface, subsurface, atmospheric, and biotic
migration pathvays. Information should include site geology,
hydrogeology, meteorology, and ecology. Regional information
can help to identify background soil, vater, and air quality
characteristics. Summarize results of ESI sampling and docu-
ment soil, vater, air, and/or biotic contamination.
5-2
-------
OSVER Directive 9345.1-02
o Compile demographic and land use information to help identify
potential human receptors. Locate residential, municipal,
and industrial veils. Describe surface water uses surround-
ing and dovnstream of the site (upstream if the surface vater
body is tidally influenced).
o Describe the ecology of the site and surrounding areas,
identifying threatened, endangered, or rare species, or
sensitive environments protected under both State and Federal
statutes.
o Summarize any community relations activities during the
pre-reraedial stage (i.e., lists of individuals and groups
that have expressed concern about the site; appropriate
Federal, State and local officials; locations for meetings;
and media).
Existing data should be analyzed for a preliminary understanding
of the nature and extent of contamination and the pathways, recep-
tors, and existing or potential impacts of the site. QA information
should be provided and data certainty assessed. The data analysis
should consider:
o Comparability of data (i.e., time of sampling).
o Analytical methods used.
o Detection limits.
o Analytical labs used (if any).
o Sample collection and handling procedures used.
The remedial contractor will benefit from the compilation of a
site description and chronology of significant events, previous site
visits, sampling, legal actions, regulatory violations, changes in
ownership, and prior cleanup and removal actions.
The site description should include a detailed map delineating
topography, geology, land use, waste locations, sampling locations,
and other pertinent details. The general extent of contaminant
migration should be illustrated for later investigation.
5.2 LIMITED FIELD INVESTIGATION
Collection of additional site-specific data beyond the minimum
required for HRS scoring can help to increase understanding of a site
and provide valuable support to the RI scoping process. Normally, an
ESI is limited to easily obtainable data and rapid results. Examples
of tasks are:
o Preliminary geophysical investigations.
5-3
-------
OSVER Directive 9345.1-02
o Limited sampling (both CLP and field screening data) and
analysis of sources, soil, sediment, and surface water.
o Sampling and analysis of residential veils.
o Monitoring veil installations, water-level measurements,
aquifer testing, sampling, and analysis,
o Air monitoring.
o Preparation of a detailed site map.
If ESI data are later determined insufficient for satisfying RI
scoping objectives, the remedial contractor may have to conduct addi-
tional sampling during development of the RI work plan. This should
be possible using existing ESI Health and Safety and Sampling Plans.
RI Quality Assurance Project Plans (QAPP) and Field Sampling Plans
(FSP) may be unnecessary for this scoping effort.
5.3 PRELIMINARY EVALUATION OF POTENTIAL IMPACTS
A conceptual model (Section 2.3.4) based on limited information
on vaste sources, pathways, and receptors should be developed to
evaluate the potential health and environmental impacts posed by a
site. The initial version of the conceptual model, developed early
during preparation of the ESI work plan, should be updated and
improved once field work is complete.
Sample analysis, determination of the general extent of con-
tamination, semiquantitative estimates of directions and rates of
contaminant transport, and identification of potential receptors
should produce a comprehensive data base useful to the RI contractor
in planning the RI. Conceptual model results will help to:
o Substantiate the level of health and environmental threat
implied by the HRS score.
o Establish the timing of remedial/removal response.
o Improve RI sampling to determine the precise extent of
contaaination.
o Identify preliminary remedial alternatives.
o Support the RI contractor and ATSDR in evaluating potential
health and envi ronmental exposures.
5.4 COMMUNITY RELATIONS AND ENFORCEMENT SUPPORT
The final ESI report should include a section summarizing
pre-remedial community relations activities. The section should
present the issues and concerns of the community, the history of site
community relations, citizens' preferences for site information, and
5-4
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OSVER Directive 9345.1-02
a list of individuals,'groups, and government officials vho have
participated in community relations activities.
Communication vith enforcement personnel should be established
early in the ESI process. Periodic updates concerning site history,
site ownership, disposal practices, and waste generators and trans-
porters should be provided to the Regional Office of Waste Programs
Enforcement to help identify PRPs and support initial cost-recovery
efforts.
5.5 REFERENCES
Existing guidance or information on the status of evolving guid-
ance can be obtained from EPA Headquarters Site Assessment Branch,
Hazardous Site Evaluation Division, Office of Emergency and Remedial
Response (OERR).
Contacts; Penny Hansen (FTS-475-8103)
Jim Jowett (FTS-475-8195)
o Guidance on Remedial Investigations Under CERCLA, OSVER
Directive 9355.0-06B, June 1985 (revisions per SARA due in
Fall 1987).
o Superfund Exposure Assessment Manual (Draft), OSVER Directive
9285.5-01, January 1986.
5-5
-------
OSVER Directive 9345.1-02
CHAPTER 6 SUMMARY
WHAT INTERPRETATION AND REPORTING PROCEDURES SHOULD BE USED TO
SUMMARIZE ESI DATA?
0 DATA EVALUATION (PRELIMINARY SITE CHARACTERIZATION)
- Prepare complete HRS package
- Summarize source and pathway data:
* Detailed base nap with supporting overlays of sample
locations, veil placements, geophysical survey lines, and
interpretative comments
* Contour maps summarizing important geologic, hydrologic, and
atmospheric data
* Summaries of sample results and supporting documentation
* Narrative summarizing findings most relevant to the RI
scoping effort
* Supporting appendices of all data
0 FINAL ESI REPORT
- Standardized presentation compatible with RI vork plan format
- Complete documentation of data for use in RI decision-making and
enforcement support
o TURNOVER MEETING
- FIT contractor or State should compile all information for
transfer to the remedial contractor
- Meeting will focus on the key aspects of site data and
significant ESI results
6-1
-------
OSVER Directive 9345.1-02
6.0 DATA EVALUATION OPTIONS AND ESI REPORT FORMAT
Data collected from various investigative activities must be
evaluated to determine if they meet ESI objectives and presented in a
format useful for making decisions during the RI.
6.1 DATA EVALUATION OPTIONS
Data evaluation or preliminary site characterization efforts
determine the general extent of contamination and the probable
severity of hazards at a site. The quantities, types, forms, and
concentrations of contaminants at and around a site should be
described, followed by a quantitative evaluation of observed and
potential releases. Important outputs of the evaluation vill be the
completed HRS package and a thorough interpretation of all collected
data.
The site characterization effort should include:
o A description of the environmental setting, including impor-
tant geologic, hydrologic, and atmospheric data. These data
should be presented as contour maps illustrating important
features of potential migration pathways and other informa-
tion for development of the RI work plan. A base map (refer-
enced to permanent benchmarks) of the site and surrounding
region should be completed early in the ESI planning process.
Subsequent overlays of sample locations, well placements,
geophysical survey lines, etc., should be developed as the
ESI progresses. Finally, a detailed site map highlighting
results should be prepared.
o A description of the hazardous substances found, including
types, quantities, forms, and containment. Appropriate
analytical detection limits and compliance with established
data quality objectives should be described.
o A description of contaminant levels found in media at and
near the site. Concentration contour maps should be provided
in an overlay format for comparison with pathway data.
o A summary of findings most relevant to the objectives of site
characterization and to development of RI work plans.
o Supporting appendices of all data (i.e., raw sampling and
geophysical survey data).
A model can be a valuable adjunct to site characterization
efforts. However, it is an artificial representation of a physical
system and is only an alternative way of characterizing and assessing
a site. A model cannot replace field data, nor can it be more
accurate than those data. A model can:
o Improve the conceptual understanding of contaminant migration
over time.
6-2
-------
OStfER Directive 9345.1-02
o Help to define future RI sampling requirements by identifying
inconsistencies and uncertainties in existing data.
o Provide a structure for organizing, manipulating, and
graphically presenting field data.
ESI models should be simplified analytical and semi-analytical
models that estimate site conditions with relatively lov accuracy and
resolution. The objective is to provide general estimates of site
conditions. More extensive (i.e., higher accuracy and resolution)
modeling will be done in the remedial stage.
6.2 REPORT FORMAT
The final ESI report should be presented in a format that:
o Ensures that all major ESI objectives are adequately addressed.
o Produces comparable presentations nationvide.
o Promotes high quality results.
o Ensures adequate documentation and complete data for use in RI
decision-making and enforcement support.
The suggested format (Table 6-1) is not intended as a compendium of
site information, and not all of the identified sections vill be
relevant to a given ESI-.
RI scoping and vork plan development vill be most efficient when
the remedial contractor has all available information. Hence, the
contractor should receive existing site file information along vith
the final ESI report (Table 6-2).
6.3 TURNOVER MEETING
EPA should ensure that all site data and ESI results are
transferred to remedial contractors at the appropriate time. The FIT
contractor or the State should compile all logbooks, data sheets,
validation summaries, maps, file reports, geophysical survey results,
and log borings. FIT or State personnel and remedial contractors
should attend a "turnover" meeting to discuss key site data and
important ESI results. The FIT or State budget for an ESI should
provide hours for this meeting, including the preparation of the
necessary materials. Similarly, work assignments for an RI/FS
should, as the initial task, request attendance at a turnover
meeting.
6-3
-------
OSVER Directive 9345.1-02
TABLE 6-1
ESI REPORT FORMAT
EXECUTIVE SUMMARY
1.1 INTRODUCTION
1.1 Site Background
1.2 Nature and Extent of Problem
1.3 .ESI Summary
1.4 Overview of Report
2.0 SITE CONDITIONS
2.1 Demography
2.2 Land Use
2.3 Geology
2.4 Natural Resources
2.5 Climatology/Meteorology
3.0 HAZARDOUS SUBSTANCES
3.1 Types of Wastes
3.2 Characteristics and Behavior of Vaste Components
4.0 GROUND WATER
4.1 Soils
4.2 Hydrogeologic Factors
4.3 Ground Vater Conditions
5.0 SURFACE VATER
5.1 Sediments
5.2 Flood Potential
5.3 Drainage
5.4 Surface Vater Conditions
6.0 AIR
7.0 HEALTH AND ENVIRONMENTAL CONCERNS
7.1 Potential Receptors
7.2 Environmental Impacts
8.0 QUALITY ASSURANCE/QUALITY CONTROL
8.1 Satisfaction of Data Quality Objectives
8.2 Documentation of Field and Analytical Data
9.0 COMMUNITY RELATIONS AND ENFORCEMENT SUPPORT
10.0 RECOMMENDATIONS TO RI CONTRACTOR
10.1 Special Site Concerns
10.2 Collection of Additional Data
REFERENCES
APPENDICES
6-4
-------
OSVER Directive 9345.1-02
TABLE 6-2
SITE FILE INFORMATION
1. Pre-remedial Response
o Discovery
- Initial investigation reports
- PA report
- SI report (if applicable)
- Sampling and analysis data
o ESI Planning
- ESI work plan
- Sampling plan
- Health and safety plan
o Actions by State and Other Agencies
- Correspondence
o Community Relations
- Correspondence
- List of people to contact (i.e., local officials, civic
leaders, environmental groups)
2. Photos and Graphics
o Photographs
o Naps and illustrations
o Other graphics
3. Enforcement
o Correspondence with OVPE
o Preliminary identification of PRPs
4. Contracts
o Site specific contracts
o Procurement packages
o Contract status notifications
o List of contractors
6-5
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