Hazard Ranking System Issue Analysis:
Consideration of Contaminant Concentration
                  MITRE

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    Hazard  Ranking System  Issue Analysis:
Consideration of Contaminant Concentration
                    Thomas F. Wolfinger
                         June 1987
                        MTR-86W40
                         SPONSOR:
                   U.S. Environmental Protection Agency
                        CONTRACT NO.:
                         EPA-68-01-7054
                      The MITRE Corporation
                       Civil Systems Division
                       7525 Colshire Drive
                      McLean, Virginia 22102-3481

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  Department Approval:
MITRE Project Approval:
                                       .
                                                JUk.
                             ii

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                              ABSTRACT

     This report examines the issue of the extent to which
concentration data can play an increased role within the Hazard
Ranking System (HRS) for the evaluation of uncontrolled waste sites.
The report examines general limitations in concentration data,
limitations arising from programmatic constraints in the site
evaluation program, and limitations arising during the data
development process.  The report concludes that there is a large
number of important limitations that restrict the utility of
concentration data in the HRS.  The report also examines, to the
limited extent possible, the potential costs of developing
representative concentration data at uncontrolled waste sites.
Several options for increasing the role of concentration data in the
HRS are described.  These options were designed within the context of
limitations in the availability and extent of concentration data.

Suggested Keywords:  Superfund, Hazardous ranking, Hazardous waste,
Concentration, Hazardous constituents.
                                 iii

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                           ACKNOWLEDGMENT

     The author would like to acknowledge the contributions of
John A. Cioffi of the Chemical and Biological Systems Department of
the MITRE Corporation.  Mr. Cioffi's preliminary work on the issue of
the use of concentration data in the Hazard Ranking System formed the
basis for many of the ideas, examination, and conclusions contained
in this report.
                                  iv

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                          TABLE OF CONTENTS
                                                                  Page

LIST OF ILLUSTRATIONS                                              vii
LIST OF TABLES                                                    vlii

1.0  INTRODUCTION                                                   !

1.1  Background                                                     1
1.2  Issue Description                                              3
1.3  Scope and Approach of Analysis                                 5
1.4  Organization of the Report                                     6

2.0  GENERAL LIMITATIONS IN CONCENTRATION DATA                      9

3.0  LIMITATIONS ARISING FROM PROGRAM CONSTRAINTS                  13

3.1  Funding Constraints                                           13
3.2  Time Constraints                                              14
3.3  Variation in Levels of Expertise                              14
3.4  Quality Control and Quality Assurance                         15

4.0  LIMITATIONS IN CONCENTRATION DATA QUALITY                     17

4.1  Spatial Variation                                             18

     4.1.1  Environmental Data                                     20
     4.1.2  Wastes                                                 45

4.2  Temporal Variation                                            48

     4.2.1  Environmental Data                                     49
     4.2.2  Wastes                                                 56

4.3  Limitations in the Data Development Process                   57

     4.3.1  Sampling                                               58
     4.3.2  Handling                                               75
     4.3.3  Analysis                                               78
     4.3.4  Interpretation                                         90

5.0  COSTS                                                         93

5.1  Problems in Estimating Costs                                  93
5.2  Media                                                         96
5.3  Contaminants                                                 100

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                    TABLE OF CONTENTS (Concluded)
5.4  Number of Sampling Locations
5.5  Number of Samples Per Location                               HI
5.6  Unit Sampling, Handling, and Analysis Costs                  H4
5.7  Illustrative Example                                         117

6.0  SUMMARY OF PRECEDING DISCUSSIONS AND IMPLICATION             H9
     FOR THE HRS

7.0  OPTIONS FOR EMPLOYING CONCENTRATION DATA                     123

7.1  Basic Philosophy                                             123
7.2  Benchmarks                                                   126
7.3  Options                                                      127

     7.3.1  Options in the HRS Release Category                   127
     7.3.2  Options in the HRS Waste Characteristics              131
            Category
     7.3.3  Options in the Targets Category                       142

8.0  OVERALL CONCLUSIONS AND RECOMMENDATIONS                      147

9.0  REFERENCES AND BIBLIOGRAPHY                                  153

APPENDIX A - COMMENTS ON THE HRS RELATED TO HAZARDOUS             177
             WASTE CONCENTRATIONS

APPENDIX B - DATA QUALITY                                         183
                                 vi

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                        LIST OF ILLUSTRATIONS


Figure Number                                                     Page

     1          DCE Profile at Site in February 1984               23

     2          PCE Profile at Site in February 1984               24

     3          Thomas Solvent Ground Water Total VOC              26
                Concentration Profile, August 1984

     4          Vertical Distribution of Representative            27
                Organic Compounds From Upgradient and
                Dowugradient Multilevel Monitoring System

     5          Vertical Distribution of Representative            28
                Inorganic Compounds From Upgradient and
                Downgradient Multilevel Monitoring System

     6          Vertical Nitrate and Dissolved Oxygen              32
                Distribution in Shallow Sandy Aquifer (after
                Hendry et al., 1983)

     7          Range and Mean for Vinyl Chloride Monitoring       40
                Near BKK Landfill, West Covina, California

     8          Isoarea Map of Kriging Estimate of Lead            43
                Concentrations (ug/g) in Soil

     9          Fluctuations of Nitrate Concentrations in          51
                Water from Individual Shallow Wells Over Time

     10         Change in Shallow Plume Over Time, as Measured     53
                by Em Conductivity

     11         Water Quality Fluctuations with Time of Pumping    67
                                 VI1

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                            LIST OF TABLES
Table Number
     1          Horizontal Variation in Ground Water                30
                Contamination Biscayne Aquifer/Dade County,
                Florida

     2          Vertical Variation in Ground Water                  31
                Contamination Biscayne Aquifer/Dade County,
                Florida

     3          Spatial/Temporal Variability in Atmospheric         34
                Benzene Concentrations:  Kin-Buc Landfill
                (1976)

     4          Spatial/Temporal Variability in Atmospheric         35
                Carbon Tetrachloride Concentrations:  Kin-Buc
                Landfill (1976)

     5          Spatial/Temporal Variability in Atmospheric         36
                Chloroform Concentrations:  Kin-Buc Landfill
                (1976)

     6          Ranges of Landfill Gas Concentrations at BKK        38
                Landfill

     7          Coefficients of Variations (%)  for Soil             41
                Parameters Reported in Mason (1983)

     8          Examples of Spatial Variation in Surface Water      44
                Contaminant Concentrations

     9          Spatial Variability in Waste Concentration          47

     10         Concentrations of Total Organic  Compounds in        52
                Water from Four Long Island,  New York  Wells
                Over a One-Year Period  (1977-1978)

     11         Potential Sources of Bias  in Sampling  Ground        63
                Water

     12         Sampling Methods for Airborne Organics             71

     13         Sampling Equipment  for  Particular Waste  Types       76
                                viii

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                     LIST OF TABLES  (Continued)


Table Number                                                      Pa8e

     14         RCRA Appendix VIII Compounds for Which No          80
                Suitable Analytical Parameter Methodology
                or Standards Exist, or for Which a Surrogate
                Has Been Suggested as an Analyte

     15         Acceptable Ranges for Precision and Accuracy       81
                in the EPA Contract Laboratory Program

     16         CLP Performance Evaluation Sample Results,         83
                1982

     17         Analysis of CLP Performance Evaluation Sample      84
                Data, 1982

     18         Summary of Inter-Laboratory Comparison             85

     19         Summary of Inter-Laboratory Comparison             86

     20         Comparison of Gas Chromatography (GC) and Gas      88
                Chromatography/Mass Spectroscopy (GC/MS)
                Results

     21         Magnitude of Laboratory Variability                89

     22         Ranges of Selected Organic Contaminant             92
                Concentrations in Urban Air

     23         Summary of Sampling Costs                          99

     24         Recommended Media in Which to Sample RCRA         101
                Appendix VIII Hazardous Constituents

     25         Expected Confidence Intervals for a Parameter     113
                Mean as a Function of Number of Samples

     26         Example Representative Pre-Sampling Costs         116
                Ten^Well Sampling Field

     27         Hypothetical Examples of Release Category         130
                Option

     28         Illustrative Concentration Factor Table           133
                                 ix

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                      LIST OF  TABLES  (Concluded)


Table Number                                                      Page

     29         Hypothetical Examples of Concentration Factor     135
                Option

     30         Illustrative Concentration Factor                 139

     31         Illustrative Toxicity Factor Matrix               141

     32         Illustrative Table for Evaluating Population      144
                (Ground Water Pathway)

     33         Illustrative Tables for Evaluating Population     145
                (Air  Pathway)

     34         Guidance on Concentration Data Development:       149
                Selections from the Literature

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1.0  INTRODUCTION




1.1  Background




     The Comprehensive Environmental Response, Compensation, and




Liability Act of 1980 (CERCLA) (PL 96-510) requires the President to




identify national priorities for remedial action among releases or




threatened releases of hazardous substances.  These releases are to




be identified based on criteria promulgated in the National




Contingency Plan (NCP).  On July 16, 1982, EPA promulgated the




Hazard Ranking System (HRS) as Appendix A to the NCP (40 CFR 300;




47 FR 31180).  The HRS comprises the criteria required under CERCLA




and is used by EPA to estimate the relative potential hazard posed




by releases or threatened releases of hazardous substances.




     The HRS is a means for applying uniform technical judgment




regarding the potential hazards presented by a release relative to




other releases.  The HRS is used in identifying releases as national




priorities for further investigation and possible remedial action by




assigning numerical values (according to prescribed guidelines) to




factors that characterize the potential of any given release to




cause harm.  The values are manipulated mathematically to yield a




single score that is designed to indicate the potential hazard posed




by each release relative to other releases.  This score is one of




the criteria used by EPA in determining whether the release should




be placed on the National Priorities List (NPL).

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     During the original NCP rulemaklng process and the subsequent

application of the HRS to specific releases, a number of technical

Issues have been raised regarding the HRS.  These Issues concern the

desire for modifications to the HRS to further improve its

capability to estimate the relative potential hazard of releases.

The issues include:

     •  Review of other existing ranking systems suitable for
        ranking hazardous waste sites for the NPL.

     •  Feasibility of considering ground water flow direction and
        distance, as well as defining "aquifer of concern," in
        determining potentially affected targets.

     •  Development of a human food chain exposure evaluation
        methodology.

     •  Development of a potential for air release factor category
        in the HRS air pathway.

     •  Review of the adequacy of the target distance specified in
        the air pathway.

     •  Feasibility of considering the accumulation of hazardous
        substances in indoor environments.

     •  Feasibility of developing factors to account for
        environmental attenuation of hazardous substances in ground
        and surface water.

     •  Feasibility of developing a more discriminating toxicity
        factor.

     •  Refinement of the definition of "significance" as it relates
        to observed releases.

     •  Suitability of the current HRS default value for an unknown
        waste quantity.

     •  Feasibility of determining and using hazardous substance
        concentration data.

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     •  Feasibility of evaluating waste quantity on a hazardous
        constituent basis.

     •  Review of the adequacy of the target distance specified in the
        surface water pathway.

     •  Development of a sensitive environment evaluation methodology.

     •  Feasibility of revising the containment factors to increase
        discrimination among facilities.

     •  Review of the potential for future changes in laboratory
        detection limits to affect the types of sites considered for
        the NPL.

     Each technical issue is the subject  of one or more separate but

related reports.  These reports, although providing background,

analysis, conclusions, and recommendations regarding the technical

issue, will not directly affect the HRS.   Rather,  these reports will

be used by an EPA working group that will assess and integrate the

results and prepare recommendations to EPA management regarding future

changes to the HRS.  Any changes will then be proposed in Federal

notice and comment rulemaking as formal changes to the NCP.   The

following section describes the specific  issue that is the subject of

this report.

1.2  Issue Description

     It is intuitively and intellectually attractive that knowledge of

the actual concentrations resulting from  releases from uncontrolled

waste sites should lead to better characterizations of the risks

associated with the sites.  The extent of (actual or potential) damage

to human health or the environment caused by a release of hazardous

substances is a function of dose which is, in turn, directly related

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to the concentration of the substance found at the point of  exposure




and the duration of time that the concentration is maintained.




Thus, risk from contaminant releases is a direct function of the




exposure concentrations.




     Individuals and organizations commenting on the MRS and its




subsequent application to uncontrolled waste sites and other releases




have expressed several considerations.  The commenters have indicated




that concentration data are needed to:  1) determine if a contaminant




has been released from the site, 2) estimate the quantity of




hazardous substances present at the site, and 3) determine the human




and environmental threat posed by the substances at or released from




the site.  A more extensive review of the comments received by EPA




concerning the concentration issue can be found in Appendix A.




     Currently, concentration data are used in the HRS to determine




whether a release of contaminants has occurred, termed an "observed




release".  These data are also used to assist in determining the




substances present at the site.




     The avoidance of increased reliance on concentration data to




assess site risks using the HRS is based on:  1) the current




role of the HRS as a screening tool, 2) shortcomings in the



representativeness of concentration data, 3) the quality of data




that can be collected, 4) the costs of data collection,  and 5)




limitations in inferring exposure concentrations from environmental



and waste concentrations.

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1.3  Scope and Approach of Analysis




     Several different types of concentration data can be developed




during preliminary assessments (PA) and site inspections (SI).




Generically, the types of data can be grouped by media as follows:




     •  Ground water




     •  Surface water




     •  Soil




     •  Air




     •  Wastes




For the purposes of this report, the first four media are considered




"environmental" media as are samples collected from those media.




For example, ground water is considered an environmental medium and




ground water samples are considered environmental samples.   For




purposes of distinction, waste samples are considered separately.   A




sixth medium of concern, sediments, is discussed, as applicable,




under the categories of soil or wastes.




     Several factors determine the role that concentration data can




play in any regulatory or scientific program.  The primary factor  is




the objectives of the program.  Of nearly equal importance, however,




are the inherent limitations in concentration data, the programmatic




constraints placed on the development of such data, and the quality




of the data that can be developed in support of the program given




programmatic and other constraints.  The role of the data should




further the achievement of the objectives within the constraints

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posed by the quality and other limitations of the data.  In the




context of the HRS, the objective of the program is to develop a




ranking of uncontrolled waste sites in a fashion that reflects the




relative, multi-media, risks of the sites as accurately as possible




within the resource and knowledge constraints of the program.  The




resulting list of sites is used in evaluating sites for further,




more detailed, investigation.  Given this objective, a thorough




understanding of the limitations in concentration data is needed to




define the appropriate role for concentration data in the HRS.




     In order to determine the appropriate role for concentration




data, an examination of the limitations in concentration data




developed during activities such as preliminary assessments and site




inspections was undertaken.  The purpose of this examination was to




delineate the limitations in such data that would restrict its use




in the HRS.  Once the limitations were understood,  options of




employing concentration data within the HRS were developed.




1.4  Organization of the Report




     This report presents the results of an examination of the




nature of concentration data developed during PAs and  Sis  and the




results of the effort to develop options for  using  such data  in the




HRS.  Sections 2,  3, and 4 discuss  the  limitations  associated  with




the types of concentration data collected during site inspections as




they relate to the utility of such  data in  the HRS.  A  limited




discussion of the probable costs associated with developing

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representative concentration data is presented in Section 5.




Section 6 discusses the implications of data limitations for  the




use of concentration data in the HRS while Section 7 presents




several options for using concentration data within the framework




of the HRS.  These options were developed to make optional use of




the concentration data as warranted by limitations in the data.




Ultimately, the question of which uses of concentration data  are




acceptable, given the limitations, must be decided by EPA.  Section 8




presents the overall conclusion and recommendations of the issue




analysis.  A bibliography is presented in Section 9.   Appendix A




contains a discussion of the comments made by interested parties on




the issue of using concentration data in the HRS.   Appendix B




contains a short discussion on the meaning of representativeness in




terms of concentration data.

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2.0  GENERAL LIMITATIONS IN CONCENTRATION DATA




     A principal limitation with concentration data is that they




rarely represent the concentrations to which individuals will




actually be exposed.  This limitation is important in assessing risk




since human health risk from environmental contamination is a




function of exposure concentrations; there are generally no simple




relationships between overall environmental or waste concentrations




and exposure concentrations.  This limitation may be minimized when




sampling is performed at the point of exposure, although other




problems may arise when sampling "exposure" concentrations.  For




example, samples drawn from drinking water taps are likely to yield




samples representative of exposure concentrations, although such




data may suffer from interferences from nonsite-related contaminants




(such as chloroform arising from water chlorination or lead from




lead solder in pipes).  Moreover, the technology of sampling




exposure concentrations is, in some cases, not in an advanced stage




of development.  For example, special equipment was developed to




assess personal airborne contaminant exposure during the Total




Exposure Assessment Methodology (TEAM) EPA project (Wallace, 1985).




     A second important limitation in concentration data is that




concentration data are fundamentally retrospective in nature.  At




best, the data represent contaminant concentrations at the sampling




locations at some point in the past.  This point may be a few minutes




or several months in the past.  As such, concentration data are

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never totally complete.  It is only with the aid of models (Including




simple models that assume that conditions and concentrations will




not change over time) that one can infer future concentrations from




past concentrations.  The importance of this limitation in terms of




the utility of concentration data in the HRS depends upon the




objectives for the use of the data in the HRS.  If the purpose of




the HRS remains to assess relative risks associated with actual or




potential contaminant releases, then this limitation may be critical.




     The above limitations are important; however, in perform-frig risk




assessments scientists have found it necessary to accommodate then.




A third important limitation associated with concentration data




arises from the statistical nature of concentration data.  Even




given a high state of quality control for a particular data set, one




cannot be certain of the true concentration.  Ihere is always some




probability that the true contaminant concentration is significantly




higher or lower than that Indicated by the data.  In general, the




probability that the true concentration will be significantly higher




(or lower) than the estimated concentration will decrease as the




representativeness of the concentration data increases.  Conversely,




uncertainty will increase as the degree of representativeness




decreases.  This is particularly important if the data set




represents only a portion of the true spatial/temporal distribution



of concentrations,  or if it represents  only one  of the many




spatial/temporal concentration distributions  associated with the





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site due to problems of specificity, homogeneity,  accuracy, and




completeness.  This is discussed further in Section 4.




     Further, the temporal limitation discussed above could act to




increase the uncertainty associated with inferences associated with




low levels of detected contamination.   This concern is  particularly




important when inferring that a site poses no risk to individuals




living near the site or when inferring that the site will not




release contaminants (e.g., when contaminants have simply not yet




been released from the site).
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3.0  LIMITATIONS ARISING FROM PROGRAM CONSTRAINTS
     Several aspects of the current structure of the CERCLA
preliminary assessment and site inspection (PA/SI) program limit the
representativeness and utility of the concentration data developed
for use in evaluating sites.  The most important of these aspects are:
     •  Funding constraints
     •  Time constraints
     •  Variation in levels of expertise
     •  Current quality assurance and quality control (QA/QC) program
Since the PA/SI program would likely be revised in concert with
revisions to the HRS, these aspects of the program may become less
limiting in the future.
3.1  Funding Constraints
     Currently, a site inspection cost is about 35-50 thousand dollars
(Caldwell, 1986).  Preliminary assessment costs are a relatively minor
component of overall PA/SI costs.   Some site inspections cost less
than the average while others cost considerably more.  Given the range
of costs associated with data development (addressed in Section 5),
it is certain that the availability of monetary resources will
restrict the extent of the collection of concentration data at most
sites.   The effects of these constraints are seen in the current
program, in part in the emphasis on ground water and soil sampling*
and on the number of samples taken.
*This emphasis also derives from a perception that ground water
 and soil contamination are the sources of the principal component
 of site risks.
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3.2  Time Constraints



     A similar constraint arises from the need to inspect sites as




quickly as possible to ensure that the risks from those sites




requiring cleanup are mitigated as soon as possible.  This, generally




implicit, time constraint is reflected in the Congressional




discussions on requirements for sites to be placed on the NPL, for




remedial investigations  to be performed, and for sites to be cleaned




up by specific dates.  This concern  is addressed in the Superfund




Amendments and Reauthorization Act of 1986 Conference Report.  The




Joint Conference Committee states in this report that the requirement




that the HRS  rank sites  as accurately as possible does not require




that long-term monitoring be conducted during site inspections and




that the role of the HRS is to expeditiously identify sites for




response actions.  This  time constraint restricts the duration of




sampling and, together with other resource constraints, may restrict




the spatial,  media, and  contaminant  completeness of the data




development effort.




3.3  Variation in Levels of Expertise




     A third limitation arises from the wide mix of interested




parties involved in concentration data development.   The PA/SI




program is designed to make use of a  wide  range  of  resources




available to the Federal government,  State and local governments



and other interested  parties.   The use of these  resources is




generally desirable  for many reasons  including cost and time savin





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However, three aspects of this practice are of concern if increased




reliance is to be placed on concentration data.   First, are the




differences in the objectives for which the samples are collected.




For example, some samples are collected to ensure investigator safety,




utilizing measurements to support short-term acute effects risk




assessments.  This objective frequently results in the use of




specialized sampling techniques that may not yield sufficiently




reliable data to support longer-term chronic risk determinations.




     The second aspect of concern is the wide variation in the quality




of the data developed outside of EPA.   This variation results in part




from variations in the level of technical expertise available to




interested parties that might develop concentration data.  This




variation indicates the need for using trained professionals in site




inspections, as indicated by Glaccum, Benson, and Noel, 1982, to




ensure the representativeness of data collected.  The final aspect is




the degree of control that EPA can exercise over concentration data




development activities in order to ensure that adequate QA/QC




practices are employed by all parties collecting data to support site




evaluations.  Almost all of the Superfund program is implemented by




the States and the degree to which EPA can ensure QA/QC for site




inspections conducted by such other parties is problematic.




3.4  Quality Control and Quality Assurance




     A final programmatic constraint relates to potential problems in




the field and laboratory quality control and quality assurance program






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that is applied to the concentration data,  particularly to  those




data developed outside of the EPA PA/SI program.   The uncertainty of




data that have not been developed subject to a uniformly applied,




comprehensive field and laboratory QA/QC program must be considered




to be high.  Increased reliance on concentration data in the HRS




would require accompanying changes in the QA/QC program, especially




in regard to data developed outside of EPA, to insure that the




concentration data were developed properly, in all cases, to the




extent possible given current capabilities.




     The Superfund program is not alone in requiring a high state of




QA/QC for the collection of concentration data.  Cooperative efforts




with other organizations can help promote consistency in data




collection.  Other organizations emphasizing the need for




concentration data QA/QC in decision making include the American




Chemical Society (Keith, Lawrence H. et al., 1983), the U.S.




Geological Survey (Claassen, 1982) and parts of EPA outside of




the Superfund program (Scalf et al., 1981; Riggin, 1983; and Gosse




et al., 1986).
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4.0  LIMITATIONS IN CONCENTRATION DATA QUALITY




     The purpose of this chapter is to present a general discussion




of the limitations, uncertainties, and confounding factors that




affect the quality of concentration data and its utility in the




HRS.  Quality, as discussed in Appendix B, is determined by comparing




the representativeness of a data set with the requirements for




representativeness imposed by the uses to which the data will be




put.  The determination of what constitutes an acceptable degree of




representativeness is an issue that must be resolved by the user (in




this case, EPA) based on the objectives of the program and the role




the data play in achieving those objectives.




     It is apparent in examining the literature that a large number




of factors interact to affect concentration data.   These factors




determine the degree to which the results of a particular sampling




program are representative.  These factors generally fall into two




categories, those reflected in "natural" variation in concentrations




(i.e., arising from variation in the environmental and waste disposal




processes that influence concentrations) and those of human origin




that relate to errors and resulting variations in concentrations




that arise during data development.  A lack of knowledge of these




factors and the degree to which they affect an individual data set




increases the uncertainty associated with that data set, limiting




its usefulness.  These factors include, for example, contamination




of well samples by materials used in well construction, temporal






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variations  in atmospheric characteristics inducing variations in




contaminant concentrations, safety considerations in sampling sealed




drums,  spatial variations in  soil contaminant  concentrations caused




by differential  deposition  patterns, gaps in knowledge  of how to




analyze nonnormal  data,  and gaps in  technologies and procedural




standards for determining sample concentrations for many contaminants




of concern.  A large  amount of  information  has been published




concerning  such  confounding factors  (e.g.,  Barcelona, 1983; Driscoll,




1986;  Fetter, 1983; Geraghty  and Miller, Inc.  and American Ecology




Services, Inc.,  1985;  Gillham et al.,  1983; Keith et al., 1983a and




I983b;  Scalf et  al.,  1981;  Sgambat and Stedinger, 1981; Weber and




Mims,  1981; and  Zachowski and Borgianini, 1984).  Procedures to




partially alleviate the  effects of these factors have been developed




in many cases.   A  truly  comprehensive  discussion of these factors in




all five of the  media  of interest is beyond the scope of this paper.




     This chapter  deals  with  an overview of these factors and their




implications for limiting the use of concentration data in the MRS.




The factors play greater or lesser roles depending on the media to




be evaluated.  The chapter  is divided  into  three sections, the first




two address spatial and  temporal variability,  respectively.  The




third section addresses  limitations in the data development process.



4.1  Spatial Variation




     Spatial variation is the  first  of  the  two  natural sources of



variation in concentration  data.  Spatial variation is defined as





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the variation in a parameter of interest (e.g., contaminant




concentrations) seen at a given point in time, between different




locations on or near a site.  It is important to note that both




horizontal and vertical spatial variation are important at many




sites.  Spatial variation in contaminant concentrations is three




dimensional and is induced by several environmental factors and the




spatial variability of these factors.  Factors of particular




importance include transport media characteristics (e.g.,  for ground




water, the direction of flow, stability, porosity, and soil clay




content), contaminant and waste characteristics (e.g., for air, the




physical state, vapor pressure, solubility, and molecular  weight);




and site characteristics (such as location and containment of




deposited materials).  These characteristics may act singly to




induce variations or may interact, such as in the case of




photodegradation.




     Spatial variation is a critical factor in determining the




number, density, and location of sampling points.  Generally, those




sites expected to have a high degree of spatial variability would




require a greater number of sampling locations to ensure a given




level of representativeness in the data.  Conversely, spatially




homogeneous sites (those with a low degree of spatial variability)




would require fewer sampling locations.  As might be expected, few




sites are spatially homogeneous in any of the five media of concern.
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     A major problem in dealing with spatial variation is determining




the degree of spatial variability.  It is necessary to know the state




of variability  to determine how many samples must be collected to




obtain an adequate representation of the range and arithmetic mode of




site concentrations.  A determination of the degree of homogeneity




itself may require extensive  sampling.




     4.1.1  Environmental Data




     This section discusses examples from  the literature illustrating




the extent and  importance of  spatial variation in the four




environmental media.




     Ground Water.   Several authors indicate that there is a fairly




high degree of  spatial variability  in ground water conditions and




contaminant concentrations (e.g., Berg, 1982; Driscoll, 1986; Gillham




et al.,  1983; Gosse  et al., 1986; McKown,  Schalla, and English, 1984;




Nazar, Prieur,  and Threlfall,  1984; Quinn,  Wittmann, and Lee, 1985;




Sgambat  and Stedinger, 1981;  and U.S. Environmental Protection




Agency,  1977 and 1985b).   Many indicate that spatial variability is




most evident in the vertical  direction (Driscoll, 1986; Singh et al.,




1984; and U.S.  Environmental  Protection Agency, 1985b).  As noted by




Sgambat  and Stedinger (1981). ground water is not well mixed,  in any




dimension.




     Among the  parameters that vary spatially and might affect ground




water contaminant concentrations  are (McKown, Schalla, and English



1984):






                                20

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     •  Horizontal and vertical conductivity




     •  Coefficient of storage




     •  Porosity




     •  Specific yield and retention




Additional parameters include hydraulic gradient and rate of




transport, contaminant chemical properties,  geochemical and




biological properties of the aquifer matrix, and discharge/recharge




parameters.  Of particular importance are discontinuities in soil




strata, particularly with regard to fractures (Gillham et al.,  1983




and Gosse et al., 1986).  It is important to note that contaminants




do not necessarily move in the same direction and at the same speed




as the ground water (Aller et al.,  1985).




     A final, critical set of parameters that affect the spatial




distribution of contaminant concentrations are the location and




release characteristics of the waste site and any other possible




contamination sources (such as other, unrelated sites).




     The extent of spatial variability in ground water contaminant




concentrations can be seen in studies by Sgambat and Stedinger




(1981); Quinn, Wittmann, and Lee (1985); Nazar, Prieur, and Threlfall




(1984); Singh et al. (1984); and Gillham et al. (1983).




     For example, Sgambat and Stedinger (1981) reproduced a table in




their article showing the results of an analysis of variance (ANOVA)




conducted on observed nitrate concentrations in shallow wells located




on Long Island, New York.  The ANOVA indicates that 70 percent of






                                 21

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 the total variation in nitrate concentrations could be accounted




 for by well-to-well (or  spatial) variation.  About 27 percent could




 be accounted  for  by within-well variation  (temporal and  other well-




 specific variation) while  only about  3  percent was considered to be




 due to measurement error.   The authors  believe that the  spatial




 variation in  concentrations was due to  spatial variation in the




 principal sources of  nitrate contamination:   cesspool leachate and




 lawn  fertilizers.




      Quinn, Wittmann, and Lee (1985)  analyzed the spatial




 distribution  of contamination at  the  Verona  Well  Field near Battle




 Creek, Michigan as part  of a CERCLA remedial investigation (RI).




 Figures  1 and 2,  illustrate the spatial distribution of  1,2-




 dichloroethene (DCE)  and tetrachloroethylene (or  perchloroethylene,




 PCE)  in  the area of the  well field.  The study identified three




 probable sources of DCE  and PCE:   two Thomas Solvent facilities and




 the railroad  marshalling yard.  DCE concentrations ranged from over




 10,000 near one of the sources, declining  to 50 ug/1 and below




 within the well field.   Environmental PCE  concentrations arising




 from  the Thomas Solvent  facilities  (the southern  PCE plume) have a




 much  smaller  range, from 50  to 100  ug/1  near the  source,  and below



 detection limits  further out.  Concentrations in  the eastern PCE




 plume range from  about 100 ug/1 to below detection limits within



 the boundaries of the  well field.   The authors stress  that the  two




wells immediately downgradient of  the  facility (source) showed no





                                22

-------
    Thomas.
    Solvent
    Annex
Thomas Solvent
Raymond  Road
                                                           0   300  600
                                                             Scale
                                                             In Feet
          Note: Contour lines show 1,2 DCE concentration pg/l (Dashed where inferred)
          Source: Quinn, Witman, and Lee, 1985.
                                    FIGURE 1
                    DCE PROFILE AT SITE IN FEBRUARY 1984
                                        23

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Thomas Solvent         ,
Raymond Road    lKf'\$
                                                         0  300 600
                                                            Scale
                                                            In Feet
          Note: Contour lines show PCE concentrations in ?g/l (Dashed where inferred)


          Source:  Qulnn, Wltman, and Lee, 1985.
                                       FIGURE 2
                      PCE PROFILE AT SITE IN FEBRUARY 1984
                                          24

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contanilnation above the detection limit.  Presumably, these two wells




missed the plume, indicating the importance of vertical variability.




     The importance of hydraulic and chemical characteristics in




determining contaminant spatial distributions is also evident in




this study.  The authors indicate that the probable causes for the




differences in spatial distributions of concentrations between the




DCE plume and the southern PCE plume are:  1) the higher retardation




factor for PCE and 2) the fact that DCE is a transformation product




of PCE.  Wide variation in the concentrations in the eastern plume




is indicated in Figure 2, a map of the railroad yard PCE




concentrations.  Contaminant concentrations ranged from 1,000 to




10 ug/1 within a distance of less than 400 feet.




     A wide variation in ground water contaminant concentrations




is also indicated by the spatial distribution of soil gas VOC




concentrations, illustrated in Figure 3.  Within a distance of




less than 200 feet, soil gas VOC concentrations range over 5 orders




of magnitude.




     The potential for variability in the vertical dimension is




further evident from the concentration profiles presented in Nazar,




Prieur, and Threlfall (1984) (Figures 4 and 5).  These samples were




taken in the area of an abandoned chemical plant that produced




specialty intermediates.   There is a large degree of vertical




variation in the concentrations of both organic and inorganic




contaminants.  For example, chlorobenzene ranges from about 0.01 mg/1






                                 25

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     \
          7   /
         RAYMOND   RD
                                         m
                                    30 50
                                    1—(—
                                    Scale
                                    In Feet
100
Note: Contour lines show total groundwater VOC concentrations in
Source: Quinn, Witman, and Lee, 1985.
                    FIGURE 3
    THOMAS SOLVENT GROUND WATER TOTAL
  VOC CONCENTRATION PROFILE, AUGUST 1984
                        26

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0.0 -
10.0 -
50.0 -1—
  001
                Water Table
                  jenac	^ oichloroethane
                     Chlorobenzene
         Upgradient

         I   I  I  I I I I I I     I   I  I I  I I I I I     I  i  I I  I I I I I
                    0.10
                                     1.00
                               Concentration (mg./L)
100.00
                                   Water Table
40.0 -
50.0 -
          Downgradlent
   0.01
  Source: Nazar, Prleur, and Threlfall, 1984.
                                     100
                               Concentration (mg./L)
                                                                      100.00
                              FIGURE 4
     VERTICAL DISTRIBUTION OF REPRESENTATIVE ORGANIC
     COMPOUNDS FROM UPGRADIENT AND DOWNGRADIENT
                 MULTILEVEL MONITORING SYSTEM
                                  27

-------
30.0 -
50.0-
         Upgradlent

         I   I  I I  I I I ll
                                                   X
                                          So"
                                                          I   I  I  I I I I I
                                    100
                              Concentration (mgJL)
                                                    1000
                                                                    10.000
 0.0 -
10.0 -
 0                10


Source. Nazar, Prleur, and Threltall, 1984
                                    100
                              Concentration (mg/L)
                                                                   10,000
                             FIGURE 5
   VERTICAL DISTRIBUTION OF REPRESENTATIVE INORGANIC
    COMPOUNDS FROM UPGRADIENT AND DOWNGRADIENT
               MULTILEVEL MONITORING SYSTEM
                                28

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(at a depth of less than 10 feet) to about 10 mg/1 (at a depth of




between 200 and 300 feet).  Iron concentrations also exhibit strong




variations ranging from about 20 mg/1 at less than 100 feet,




reaching a maximum of over 5,000 mg/1 at between 100 and 200 feet,




and returning to a concentration below 100 mg/1 at a depth of about




400 feet.  Nazar, Prieur, and Threlfall believe that the overall




vertical distributions of the upgradient and downgradient




contaminant concentrations indicate the presence of multiple sources.




     Sometimes when specific sources of contamination are unknown




and/or multiple sources are present, a large area, such as an aquifer




can be designated as a site.  Such sites can have marked spatial




variation.  Both horizontal and vertical variations in ground water




contaminant concentrations were found in a study of contamination in




the Biscayne aquifer in Florida (Singh et al., 1984).  As indicated




in Tables 1 and 2, contaminant concentrations varied by up to two




orders of magnitude between locations within the aquifer and between




the three depths sampled.  In another aquifer, significant vertical




variation in nitrate and dissolved oxygen concentrations was




observed by Gillham et al., 1983 (Figure 6).




     Air.  Overall, the atmosphere is the most variable medium of




concern associated with uncontrolled waste sites.  Atmospheric




conditions and contaminant concentrations can change significantly




within the space of seconds and within distances measured in feet.




Contaminant concentrations can vary over orders of magnitude, in







                                 29

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                              TABLE 1

         HORIZONTAL VARIATION IN GROUND WATER CONTAMINATION
               BISCAYNE AQUIFER/DADE COUNTY, FLORIDA
                               (ug/1)
Area
Hialeah
Upper Miami Springs
Lower Miami Springs
Airport (36th Street)
58th Street Landfill
Unsewered Industrial
Area
Mean
Total VOC
57
33
20
10
6.2
1.1
Mean
Chloride
23
17
8.7
3.5
0.31
0.25
Trans-1, 2-
dichloroethene
28
7.3
3.6
1.1
0.53
0.25
Source:  Singh et al.,  (1984).
                                 30

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                              TABLE 2

          VERTICAL VARIATION IN GROUND WATER CONTAMINATION
               BISCAYNE AQUIFER/BADE COUNTY, FLORIDA
                               (ug/1)
Parameter
Vinyl Chloride
Trans-1, 2-Dichloroethene
Total VOCs
Upper
Level
0.35
0.36
7.8
Middle
Level
12
6.7
22
Lower
Level
10
4.3
19
Source:  Singh et al.,  (1984).
                                31

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    0.0
CD
TD
c
    2.0 -
    4.0 -
1   6.0-
m
ZL.
Q.
    8.0
    10.0
                       N03 -(mgL-i)

                       10
20
 1
 DO (mgL1)
10          20
                         Water Table
                       • Location of Sampling points

                       • Measured Data


      Note:  The dashed-lines represent the weighted average concentrations

      Source: Gillham et al., 1983.
                                  FIGURE 6
       VERTICAL NITRATE AND DISSOLVED OXYGEN DISTRIBUTION
          IN SHALLOW SANDY AQUIFER (after Hendry et al., 1983)
                                     32

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both time and space as the wind direction shifts and plumes meander.



Spatial variation in the atmosphere has been identified as important in



determining concentrations by several authors including Gosse et al. ,



1986; Riggin, 1983; and Zachowski and Borgianini, 1984.  Spatial



variability in atmospheric contaminant concentrations arises from



three different sources:  variation in the atmosphere itself (e.g.,



wind speed, wind direction, and stability),  variation in locations



and release characteristics of contaminant sources,  and effects of



terrain.  Each of these sources of variation play an important role in



determining the spatial (and temporal) distribution  of atmospheric



contaminant concentrations.



     The extent of spatial variation in atmospheric  contaminant



concentrations is illustrated by sampling data reported in Pellizzari,



1978 (Tables 3 through 5).  These data are abstracted from an extensive



set of sample data based on several days of  sampling conducted on and



near the Kin-Buc Landfill in New Jersey.  Analyses were performed for



a large number of organic contaminants.  The data presented in this



report are for benzene, carbon tetrachloride, and chloroform.  Temporal



average (mean) benzene concentrations varied by more than a factor of


          3           3
2 (13 ug/m  to 30 ug/m ) between locations within a  one-mile



radius of the site.   Individual benzene concentrations varied by over



an order of magnitude off-site.   The highest detected on-site



concentration (July 1,  191,000 ng/m ) was nearly 30  times the lowest



detected off-site concentration taken at the same time (6,875 ng/m ) .





                                 33

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                               TABLE  3

             SPATIAL/TEMPORAL VARIABILITY  IN ATMOSPHERIC
          BENZENE CONCENTRATIONS:  KIN-BUG LANDFILL (1976)
                               (ng/m3)
Locations*
Date
6-29

6-30

7-1

Mean
RSD
Time**
1207
1607
1029
1457
1006
1425


Tower
Marina
20,343
7,718
NS
trace
15,969
10,156
13,457
42%
Meadow
Road
93,750
14,093
5,906
NS
NS
6,875
30,156
141%
East
NS
10,656
NS
NS
7,000
27,343
14,500
72%
On-Site
NS
NS
NS
NS
trace
191,000
NA

 *Locations:  •  Tower Marina is approximately 1 mile from the site
                 at a direction of 255 degrees.
              •  Meadow Road is approximately 0.25 miles from the
                 site at a direction of 345 degrees.
              •  The East location is approximately 0.1 miles from
                 the site at a direction of 40 degrees.
**Approximate time sampling began at each location.

 NA:  Not applicable.
 NS:  Not sampled.
RSD:  Relative standard deviation (or coefficient of variation);  the
      ratio of the sample standard deviation to the sample mean.

Source:  Adapted from Pellizzari, 1978.
                                 34

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                               TABLE 4

             SPATIAL/TEMPORAL VARIABILITY IN ATMOSPHERIC
    CARBON TETRACHLORIDE CONCENTRATIONS:   KIN-BUG LANDFILL (1976)
                               (ng/nr)
Locations*
Date
6-29

6-30

7-1

Mean
RSD
Time**
1207
1607
1029
1457
1006
1425


Tower
Marina
ND
12,687
NS
1,127
ND
3,125
5,646
109%
Meadow
Road
ND
13,687
trace
NS
NS
625
7,156
129%
East
NS
7,250
NS
NS
ND
7,000
7,125
2%
On-Site
NS
NS
NS
NS
ND
10,600
NA

 *Locations:  •  Tower Marina is approximately 1 mile from the site
                 at a direction of 255 degrees.
              •  Meadow Road is approximately 0.25 miles from the
                 site at a direction of 345 degrees.
              •  The East location is approximately 0.1 miles from
                 the site at a direction of 40 degrees.
**Approximate time sampling began at each location.

 NA:  Not applicable.
 ND:  Not detected.
 NS:  Not sampled.
RSD:  Relative standard deviation (or coefficient of variation); the
      ratio of the sample standard deviation to the sample mean.

Source:  Adapted from Pellizzari, 1978.
                                 35

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                               TABLE 5

             SPATIAL/TEMPORAL VARIABILITY IN ATMOSPHERIC
         CHLOROFORM CONCENTRATIONS:  KIN-BOC LANDFILL (1976)
                               (ng/m3)
Locatioas*
Date
6-29

6-30

7-1

Mean
RSD
Time**
1207
1607
1029
1457
1006
1425


Tower
Marina
6,389
1,999
NS
186
17,222
944
5,348
132%
Meadow
Road
ND
trace
12,333
NS
NS
2,500
7,416
94%
East
NS
trace
NS
NS
8,334
260
4,297
133%
On-Site
NS
NS
NS
NS
19,444
27,200
23,322
24%
 *Locations:   •   Tower  Marina  is  approximately 1 mile from the site
                  at  a direction of  255 degrees.
               •   Meadow Road is approximately 0.25 miles from the
                  site at a  direction of 345 degrees.
               •   The East location  is approximately 0.1 miles from
                  the site at a  direction of 40 degrees.
**Approximate  time sampling began at each location.

 ND:  Not detected.
 NS:  Not sampled.
RSD:  Relative standard  deviation (or coefficient of variation);  the
      ratio of the sample standard  deviation to the sample mean.

Source:  Adapted from Pellizzari, 1978.
                                36

-------
Similar variations can be seen in the carbon tetrachloride and




chloroform concentration data.  Measured chloroform concentrations




varied 100-fold between the East location and the on-site location




on July 1.




     The sources of the variation seen at Kin-Buc are undetermined.




The site is located near a chemical plant and the New Jersey




Turnpike.  An analysis of the full data set indicates that both of




these sources contribute to organic contamination near the landfill.




The data also indicate that the landfill is emitting organic




contaminants (e.g., the 191 ug/1 measurement on-site).  The




difficulty in determining the contribution of the landfill supports




the observation of Riggin (1983) that the determination of waste




site contributions to polluted atmospheres may require a spatial




sampling resolution of tens or hundreds of meters; finer than was




used in the Kin-Buc study.




     The potential for spatial variation in atmospheric




concentrations near waste sites is also evidenced by the data on




landfill gas contaminant concentrations presented in California




Department of Health Services, California Air Resources Board, and




South Coast Air Quality Management District, 1983 (Table 6).   As can




be seen in this table, the measured emission concentration varied




greatly at BKK Landfill in California,  by as much as two, possibly




three,  orders of magnitude.   Furthermore, emissions were not always




detected.  It is uncertain,  however,  whether these data represent






                                 37

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                              TABLE 6

        RANGES  OF  LANDFILL  GAS CONCENTRATIONS AT BKK LANDFILL




	Compound	Range (ppa)

Vinyl Chloride                                          83 - 12,800

Vinylidene Chloride                                     ND - 1,200

Acetylene Bichloride                                    ND - 800

Trichloroethylene                                       ND - 1,000

Tetrachloroethylene                                     KD - 1,500

Ethylene Dichloride                                     ND - 5,000

Benzene                                                 10 - 2,000

Chlorobenzene                                           ND - 500


ND:  Not detected.

Source:  Adapted from California Department of Health Services,
         California Air Resources Board, and South Coast Air Quality
         Management District, 1983.
                                38

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spatial or temporal variation, although it is likely that both are




involved since BKK has a large number of gas vents.  Regardless of




the source of the variation, vinyl chloride concentrations around




BKK Landfill vary greatly from location to location (see Figure 7).




     Soil.  Soil contaminant concentrations and other soil




characteristics also exhibit a significant degree of spatial




variation (Bruehl, Chung, and Diesl,  1980; Flatman, 1984;  Ford and




Turina, 1985; Gosse et al., 1986; Mason, 1983;  and Schweitzer and




Black, 1985).  Variation in natural parameters  as well as variations




in waste deposition and migration patterns, induce variations in




soil contaminant concentrations.




     At an investigation at an unnamed site, Bruehl, Chung,  and Diesl




(1980) measured chromium concentrations in soils ranging from 20 to




280,000 mg/kg.  This compares with an average site background




concentration of about 100 mg/kg.  In contrast, these authors note




that naturally occurring chromium concentrations in soils in the




United States range from 5 to 3,000 mg/kg.




     Mason (1983) summarizes the results of several studies  of




variability in soil properties (see Table 7).  Mason states  that




coefficients of variation (the ratio of the sample standard  deviation




to the sample mean) in natural soil properties  reported in the




literature range from a low of 1 to 2 percent to as high as




850 percent.   As indicated in the table, natural soil properties




and phosphorus properties of soils varied over  a range from 6 to






                                 39

-------
     60
      40
      20
  .a
  Q.
  0.
  B   10
  ra
  0)
  o
  c
  o
  O
0   A
                                         /-^. Mean for
                                         ^-' Laboratory 1

                                          A Mean for
                                            Laboratory 2
                                      o

                                       _L
                                                  _L
                   A         B          C         D          E          p

                                      Monitoring Stations

Source: California Department of Health Services, California Air Resources Board, and south Coast Air
       Quality Management District,  1983.
                                     FIGURE 7
           RANGE AND  MEAN FOR VINYL CHLORIDE MONITORING
              NEAR BKK LANDFILL, WEST COVINA, CALIFORNIA
                                        40

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                              TABLE  7

         COEFFICIENTS OF VARIATIONS (%) FOR SOIL PARAMETERS
                      REPORTED IN MASON (1983)
      Original Sources
                    Parameter
Range (%)
White and Hakonsen (1979)

Mathur and Sanderson (1978)
                    Plutonium

                    Natural soil
                    constituents
 62 - 840

5.6 - 75.2
Harrison (1979)

Hind in,


May, and Duns tan (1966)

Phosphorus
properties
Insecticide
residue*
11 - 140

156

*Soil square 30 inches on a side.

Original Sources:
Harrison, A. F., "Variation of Four Phosphorus
Properties in Woodland Soils," Soil Biology and
Biochemistry, Vol. 11, 1979, pp. 393-403.

Hindin, E., D. S. May, and G. H. Dunstan,
"Distribution of Insecticide Sprayed by Airplane
on an Irrigated Corn Plot, Organic Pesticides in
the Environment, A. A. Rosen and H. F. Kraybill,
eds.,(Advances in Chemistry Series Number 60),
American Chemical Society, Washington, DC, 1966,
pp. 132-145.

Mathur, S. P- and R. B. Sanderson, "Relationships
Between Copper Contents, Rates of Soil Respiration
and Phosphatase Activities of Some Histosols in
an Area of Southwestern Quebec in the Summer and
Fall, Canadian Journal of Soil Science, Vol. 58,
No. 5, 19/», pp. 125-134.

White, G. C. and I. E. Hakonsen, "Statistical
Considerations and Survey of Plutonium
Concentration Variability in Some Terrestrial
Ecosystem Components," Journal of Environmental
Quality, Vol. 8, No. 2, 1979, pp. 176-182.
                                 41

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140 percent.  Variation  in  plutonium  concentrations was significantly




higher; coefficients of  variation  ranged  from over 60 percent to




840 percent.  Mason also notes  that insecticide  residue concentrations




have been seen to vary significantly  (156 percent coefficient of




variation) within a soil square 30 inches on  each side.




     Flatman  (1984) and  Schweitzer and Black  (1985) present estimates




of the spatial distributions  of lead  contamination in soil at the




Dallas Lead Smelter site.   These estimates, seen in Figure 8, were




created using the estimation  method known as  kriging.  As can be seen




from the figure, soil lead  concentrations vary considerably, ranging




from less than 100 ug/g  to  over 2,500 ug/g.   It  is interesting to note




both the non-uniform shape  of the  contamination  isoareas and the




location of zones of less than  100 ug/g within higher contamination




zones.




     Surface  Water.  Depending  on  the size and other characteristics




(such  as degree of turbulence)  of  a water body as well as the




location and  other characteristics of contaminant sources, surface




water  contaminant concentrations may  vary greatly or nearly




not-at-all.   Well-known  phenomena  that lead to significant spatial




variation in  surface water  bodies  include thermal stratification, in




lakes  and impoundments,  and for large water bodies, the formation of




contaminant plumes (Gosse et  al.,  1986).




     Table 8  illustrates spatial variation in contaminant




concentrations in streams at  two CERCLA NPL sites, Whitehouse Oil






                                 42

-------
   12500
   10500
    8500
S   6500
    4500
    2500
     500
          Site: DMC
                        |   |  <100


                        frX'l  100 < 250

                        K,'j|  250 < 500


                        P%;|  500 < 1000

                        \fffj\  1000 < 2500


                        till  2500 < 5000
                                           I
                I
         I
            500
                   2500
                          4500
6500    8500

X (feet)
10500   12500
       Source: Flatman, 1984.
                                 FIGURES
                 ISOAREA MAP OF KRIGING ESTIMATE OF
                  LEAD CONCENTRATIONS (ug/g) IN SOIL
                                     43

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                               TABLE 8

           EXAMPLES OF SPATIAL VARIATION IN SURFACE WATER
                     CONTAMINANT CONCENTRATIONS
    Location

    Upstream
    Downstream
  Whitehouse Oil Pits (ug/1)

     Distance (ft)    Iron    Magnesium
           300
         1,000
         2,500
         3,800
1,200
1,700
1,000
1,200
700
2,200
1,700
1,700
                     Zinc

                      20
                      80
                      30
                      70
    Location

    Upstream
    Downstream
     Fields Brook (ug/kg)

Distance (ft)   Trichloroethene  Tetrachloroethene
       10
      635
    1,429
    1,694
    2,118
    2,753
    3,547
    3,812
    6,989
    7,011
    9,107
    9,319
 ND
7.5
                                          74
                                          64
                                          41
                                          61
                                          25
                                          NQ
  ND
62-65
  51
  31
  72
                                                            48
                                                            NQ
ND:  Not detected.
NQ:  Not quantifiable.

Note:  Distance is measured upstream or downstream from the probable
       point of entry of contaminants from the source to the surface
       water body.

Source:  Adapted from Burger and Kushner,  1986.
                                 44

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Pits, and Fields Brook.  At the Whitehouse Oil Pits site, a sizeable




relative increase in magnesium and zinc concentrations was detected




between the upstream and the downstream samples accompanied by a




smaller relative increase in iron concentrations, all within a




distance of 1,300 feet of the probable point of entry of contaminants




from the site.  Both magnesium and iron concentrations remained




somewhat stable for almost 3,000 feet downstream while zinc




concentrations fluctuated, declining by over 50 percent and then




more than redoubling within the same distance.




     At Fields Brook, concentrations of both trichloroethene and




tetrachloroethene increased significantly between upstream and




downstream sampling points.  Concentrations of both contaminants




decline with distance, although both exhibit fluctuations at




different distances from the site.  Although the reason for these




fluctuations is unknown, it is probable that they are caused by a




combination of measurement error and/or the presence of additional




contaminant sources.




     4.1.2  Wastes




     The concentration of hazardous substances in the wastes at a




site varies considerably at different locations at the site.  Even




at a given location, waste concentrations may vary with depth.  The




reasons for this variation are straightforward.  Variation arises




from different patterns in the original deposition of wastes;  from




physical,  chemical, and biological processes that act on the wastes






                                 45

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after deposition; and from differences in the migration patterns of




the waste constituents.




     An example of the extent of on-site variation in waste




constituent concentrations is indicated in Table 9.  These data were




abstracted from site inspection and remedial investigation reports




as part of the HRS issue analysis  of waste constituent concentrations




(Wusterbarth, 1986).   The values shown in the table represent the




sum of the concentrations of CERCLA contaminants found in the wastes




at various locations on each site.  As can be seen from the data,




there is  significant variation in  total hazardous substance




concentrations within  sites.  Relative standard deviations range




from a low of 47  percent in the waste pile(s) at the Micronutrients




International site to  a high of 265 percent at the drum portion of




the Morgantown Ordnance site.




     The  data also support the conclusion drawn by others (e.g., in




Ford and  Turina,  1985) that concentrations of hazardous constituents




in drummed waste  is highly variable between drums.  The relative




standard  deviations of the hazardous substance concentrations




measured  in drums are consistently above 100 percent while the ranges




are very  large (generally over two to about five orders of magnitude)




indicating a high degree of spatial variation in waste contaminant




concentrations.




     Ford and Turina  (1985)  also  indicate  that waste contaminant




concentrations may vary with depth  within a drum, as a result of






                                46

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                                       TABLE 9

                       SPATIAL VARIABILITY IN WASTE CONCENTRATION
                          (SUM OF HAZARDOUS CONSTITUENT;  ppm)
Site Name
Cosden Chemical
Morgantown Ordnance
Hunterstown Road
Cleve Reber
Old Mill
Cecil Lindsay
Mill Creek
Micronutrients Int.
Texarkana Wood
Preserving
Laskin Poplar
Laskin Poplar
Old Inger
Number of
Type Samples Mean
Drum
Drum
Drum
Drum
Drum
Drum
Drum
Pile
Pond
Sludge
Tank
Sludge
Tank
Liquid
Tank
5
8
28
7
11
3
4
10
5
4
32
9
143,629
110,243
50,843
11,158
136,764
352,391
30,537
201,194
84,605
30,298
3,750
486
Standard
Deviation
266,393
292,660
92,715
14,462
159,130
365,028
46,829
94,641
78,261
45,509
3,193
560
RSD
(%)
185
265
182
130
116
104
153
47
93
150
85
115
Min.
427
202
4
17
61
4,870
469
38,678
494
3,751
28
2
Max.
610,400
834,120
459,060
41,374
451,800
732,712
99,765
339,759
163,100
98,339
12,882
1,431
Source:  Wusterbarth,  1986.

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stratification.  The extent  to which  the data in Table 9 represent

horizontal versus vertical variation  is unknown.

4.2  Temporal Variation

     Temporal variation  is the second of  the two  "natural"  sources

of variation in  concentration data (i.e.,  variation resulting from

environmental and waste  disposal processes as opposed to human  error).

Temporal  variation  is  defined as the  variation in a parameter of

interest  at a given location at  different points  in time.   The  effect

of undetected  temporal variation on data utility  is similar to  that of

spatial variation.   Together, the two represent the "natural" variation

in estimated  contaminant concentrations.   Temporal variation is caused

by many of  the  same factors that induce spatial variations.  Generally,

temporal  variations in contaminant concentrations arise  from temporal

variations  in  environmental factors such as flow  rates and  stability.

However,  temporal variations in  contaminant concentrations  may  arise

from the  interaction of  spatially varying and temporally varying

factors.  For example, a flood may inundate a landfill located  in the

flood  plain releasing  additional contaminants into a stream. This

phenomenon can be viewed as  arising from  the interaction of a

temporally varying  factor (stream flow) and a spatially  varying factor

(waste  concentration).   Similarly;  spatial  variations can arise from

the  interaction of  temporally and  spatially varying factors such as

the  interplay of atmospheric deposition and solar  radiation in

determining soil contaminant concentrations of photodegradable

materials.
                                 48

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     Temporal variation is a critical factor in determining the




frequency and duration of sampling.  As in the case of spatial




variation, those sites with a high degree of temporal variation




generally require a greater sampling frequency and longer sampling




duration to achieve a particular level of representativeness.




Conversely, sites that are temporally homogeneous generally require




lower sampling frequencies and durations.   Few sites and media are




temporally homogeneous.




     4.2.1  Environmental Data




     This section discusses examples from the literature illustrating




the extent and importance of temporal variation in determining




contaminant concentrations in the five environmental media.




     Ground Water.  Natural temporal variation in ground water




contaminant concentrations at a specific location and the




characteristics that determine those concentrations is considered




to be small (Sgambat and Stedinger, 1981).  These and other authors




indicate, however, that in areas affected by human activities,




temporal changes in ground water contaminant concentrations may be




relatively large, although the variation is usually evident only on




a seasonal or longer scale (Everett, 1981; Gillham et al., 1983;




McKown, Schalla, and English, 1984; Nacht, 1983; Possin, 1983;




Schuller, Gibb, and Griffin,  1981; and Sgambat and Stedinger,  1981).




As cited by these and other authors, causes of temporal variation in




ground water quality and other related parameters include:






                                 49

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     •  Variations in contaminant source release characteristics.




     •  Changes in recharge patterns due to climatic variation.




     •  Variations in water use patterns.




Everett (1981) also indicates that seasonal variations are likely in




areas characterized by the presence of highly permeable soils and




geologic materials lying above the water table and in areas in which




wells tap the shallow portions of aquifers.




     The extent of temporal variation of ground water contaminant




concentrations is illustrated by information contained in Sgambat




and Stedinger, 1981 (Figure 9 and Table 10) and Benson, Glaccum, and




Beam, 1981.  The former figure shows nitrate concentrations in a




single well varied by a factor of three over the period of




approximately one year.  The ranges and standard deviations of the




concentration of total organic compounds in the four wells listed in




Table 10, further illustrates the extent of temporal variation.  In




two of the four wells, the standard deviation exceeded the mean




while in the  third it was nearly 80 percent of the mean.




     As an additional example, Benson, Glaccum, and Beam (1981)




illustrate the  temporal variation in the extent of contamination in




a shallow plume  arising from a spill as measured by Em conductivity




 (Figure 10).




      In contrast, in  their investigation of contamination in  the




Biscayne Aquifer in Florida, Singh et al.  (1984) found little




 variation  in  contaminant concentrations over a period of six months.






                                 50

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           12
Well 1
           12
Well 2
      O)
      E
           0
          12
Well 3
              III  I  I  I 1  1 1  1  I  I  I  I I I  I  I  I  I  I  I  I
              III  I  I  I I  I  I  I  I  I  I  I I  I  I  I  I  I  I  I
           0 I  I  I  I  I  I I  I  I  I  1  I  I  I I  I  I  I  I  I  I  I  I
           16
          12
Well 4
                I  I  I  I I  I  I  I  I  I  I  I I I  I  I  I  I  I  I  I  I
             JFMAMJJASOND
JFMAMJJASOND
                             Time, in Months
    Source: Sgambat and Stedinger, 1981.

                         FIGURE 9
       FLUCTUATIONS OF NITRATE CONCENTRATIONS
 IN WATER FROM  INDIVIDUAL SHALLOW WELLS OVER TIME
                            51

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                             TABLE  10

             CONCENTRATIONS*  OF TOTAL ORGANIC COMPOUNDS
           IN WATER FROM FOUR LONG ISLAND,  NEW YORK WELLS
                 OVER A ONE-YEAR  PERIOD (1977-1978)
Well No.
N-8326
N-8327
N-5962
S-27259
Number of
Analyses
25
14
13
9
Mean
93
148
33
19
Standard
Deviation
110
115
17
30
Range
0
4
10
1
- 430
- 455
- 46
- 79
Concentration in ug/1.

Source:  Sgambat and Stedinger, 1981.
                                52

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 Point of Spill
Regional  Ground-Water Flow
                              I Acre
     A)  I Day
B)  26  Days
  Source:  Benson, Glarcson, and Beam, 1981.
                            FIGURE 10
               CHANGE IN SHALLOW PLUME OVER TIME,
                 AS MEASURED BY Em CONDUCTIVITY
                                53

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     Air.  As stated previously, the atmosphere is probably the most




variable medium of concern with regard to measurements of contaminant




concentrations and other related characteristics from uncontrolled




waste sites.  Contaminant concentrations at a  given location can vary




over orders of magnitude within a  period of hours.  Numerous authors




identify  temporal variation  as  important in determining  concentrations




(for example, Gosse  et  al. ,  1986;  Riggin,  1983;  and Zachowski and




Borgianini, 1984).   The same factors that  determine spatial




variability,  also  determine  temporal variability:  variation in the




atmosphere itself  (e.g., wind speed, wind  direction, and stability),




variation in  locations  and release characteristics of contaminant




sources,  and  effects of terrain.




     The  extent  of  temporal  variability in atmospheric concentrations




can  be  seen in  the  data presented  earlier  on Kin-Buc Landfill (as




reported  in Pellizzari, 1978; see  Tables 3 through 5).   Concentrations




of benzene,  carbon  tetrachloride,  and chloroform varied  substantially




over a  three  day period, particularly at the Meadow Road location.




The  temporal  coefficients  of variance (or  relative standard




deviations) at this  location were  141 percent,  129 percent, and




94 percent, respectively.  Variation at the East location  (0.18 km




from the landfill) was  high  for both  benzene and chloroform




(72 percent and 133 percent,  respectively), while variation in




measured carbon tetrachloride concentrations  was small  (about




2  percent).  A particularly high degree of  variation was  seen  at th






                                 54

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on-site location.  Within a matter of four hours, detected benzene

                                                           3

concentrations increased from a trace level to 191,000 ng/m , while



carbon tetrachloride concentrations increased from below the detection


                    3

limit to 10,600 ng/m .  Chloroform concentrations were relatively


                                        3               3
more stable, increasing from 19,444 ng/m  to 27,200 ng/m .  The



on-site benzene concentration variation clearly illustrates the



problems that temporal variation in concentrations can cause in



assessing site risks.  A single measurement taken in the morning



would indicate that the site posed no risk from benzene emissions.  A



measurement taken only four hours later would lead to the opposite



conclusion.



     Surface Water.  It is well known that surface water contaminant



concentrations and other characteristics exhibit a significant degree



of temporal variability, both short-term and longer-term (e.g.,



seasonal).  The sources of variation include changes in the locations



and release characteristics of contaminant sources, natural variation



in background contaminant concentrations, and climatic variations in



rainfall and other factors (Gosse et al., 1986 and Sherwani and



Moreau, 1975).  According to Gosse et al. (1986), sampling surface



water bodies should be sensitive to a number of temporally varying



factors including:



     •  Mixing



     •  Freeze over



     •  Dry/wet seasons
                                 55

-------
     •  Flow and elevation




     •  Micro- and macrobiotic communities




     •  Runoff patterns




     •  Diurnal variations in chemistry




     •  Contaminant sources




     •  Plant growth patterns




     Soil.  The extent of temporal variation in soil contaminant




concentrations is problematic.  Significant variation is possible due




to chemical and biological transformation and degradation.  This




possibility is illustrated by the previously discussed Verona Well




Field ground water example in which a plume of DCE originated from a




source of PCE through chemical transformation (see Figures 1 and 2).




     4.2.2  Wastes




     Temporal variations  in waste contaminant concentrations is also




problematic.  Significant variations in waste concentrations over




time are possible due to  differences in contaminant transformation,




degradation, and migration patterns.  Especially important in this




context is the potential  for waste concentrations to decline over




time as materials escape  into the environment.  A "site" may have




little or no hazardous constituents remaining in it (and thus have




low waste constituent concentrations) but may have created a




substantial plume of contaminated ground water.   in such cases,




waste quantity as indicated by the quantity of hazardous constituents




remaining on a site (calculated from waste contaminant  concentrations)





                                 56

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may be a very poor indicator of the potential magnitude and duration




of releases from the site.




     Additionally, contaminants not deposited at the site may be




created at the site through chemical interactions.  The previously




discussed Verona Well Field ground water example illustrates this




point.  No DCE was deposited at the site and yet DCE can now be found




at the site.  This phenomena is also evidenced by the generation of




methane and vinyl chloride in municipal landfills (see, for example,




Lipsky and Jacot, 1985).




4.3  Limitations in the Data Development Process




     In addition to the natural factors affecting data quality,




numerous factors of human origin also affect data quality in each of




the four semi-independent stages of the data development process:




     •  Sampling




     •  Handling




     •  Analysis




     •  Interpretation




     The following discussion addresses each of these stages




separately.  It is important to note that the problems identified




in data development vary greatly in importance from site to site.




Further, many of the problems are well known and their effects can




be minimized by the use of proper procedures, reinforced by a




comprehensive QA/QC program.
                                 57

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     4.3.1   Sampling




     Several  factors interact to adversely affect the quality of data




obtained from  environmental and waste samples.  So«e of these factors




are environmental  in nature while others are related to sampling




techniques and  technologies.




     4.3.1.1   Environmental Factors.  A comprehensive discussion of




the environmental  factors affecting contaminant concentrations  is




beyond the scope of  this report.  However, numerous authors (e.g.,




Barcelona et al.,  1985;  Berg, 1982; Driscoll, 1986; Ford and Turina,




1985; Ford, Turina,  and  Seeley,  1984;  Geraghty and Miller, Inc. and




American Ecology Services,  Inc., 1985;  Gibb,  Schuller, and Griffin,




1981; Gillham et al. ,  1983;  Gosse et al. ,  1986; Kazaann, 1981; Mason,




1983; McKown, Schalla, and  English,  1984;  Nacht, 1983; Riggin, I983?




Scalf et al., 1981;  Schuller,  Gibb,  and Griffin, 1981; Sisk, 1981;




Tirsch and Male, 1983; U.S.  Environmental  Protection Agency, 1977;




U.S. Environmental Protection  Agency. 1985a and I985b; and Zachowski




and Borgianini, 1984) have emphasized the  importance of adequately




characterizing the site-specific environment  before a sampling plan




is developed and sampling activities are begun.   The aspects of the




environment to be characterized  consist of the  major components of




the processes that determine concentrations (e.g.,  media flow rates,




directions, and diffusion characteristics).   Knowledge of these




factors is also necessary to assess the representativeness of the




samples once they are taken.
                                 58

-------
     The types of background environmental information that should be

collected at a particular site, before sampling, depend on the

physical characteristics of the site, the types of wastes deposited

at the site, and the nature of the threat posed by the site (e.g.,

human health).  Several authors have expressed opinions on the

minimum information that they feel is necessary to determine sampling

locations, frequencies, and methods for ground water and air

sampling.  These authors indicate that such sampling parameters must

be developed on a site-specific basis.  They believe that it is not

possible to develop values for such parameters generically.   The

principal guidance documents on ground water sampling (Barcelona

et al., 1985; Claassen, 1982; Gibb, Schuller, and Griffin, 1981;

Gosse et al., 1986; Scalf et al., 1981; U.S. Environmental Protection

Agency, 1977; and U.S. Environmental Protection Agency,  1985a and

1985b, as well as other authors) list the following as important

ground water parameters that should be assessed before sampling:

     •  Ground water flow gradient

     •  Ground water flow rate

     •  Aquifer transmissivity and related parameters (e.g.,
        conductivity, porosity, and permeability)

     •  Extent of fracturing

     •  Locations of recharge/discharge areas

The feasibility of measuring many of these parameters within the

confines of a PA/SI is open to question (Gerstein, 1986).  The use

of other information (e.g., regional ground water flow parameters),

                                 59

-------
while possible, may not provide sufficiently accurate, site-specific




values.  This concern is reinforced by the known effects of drinking




water well capture zones on local ground water flow patterns (see,




for example, Quinn, Wittmann, and Lee, 1985 and Absalon and




Starr, 1980).  The removal of water from aquifers by pumping




drinking water wells may affect the local hydraulic gradient.  The




regional gradient may be determined largely by geologic conditions




and may be unaffected by pumping the wells.  The size of the




affected area and the degree of change in the gradient will depend




on local conditions such as the rate of pumping, the number of




wells, and local hydraulic conditions.




     A similar set of background information requirements to support




air sampling is indicated by authors such as Riggin (1983) and Gosse




et al. (1986).  These authors list the following parameters that




should be assessed prior to sampling:




     •  Wind speed




     •  Wind direction




     •  Temperature




     •  Pressure




     •  Relative humidity




     •  Precipitation patterns




     •  Locations and characteristics of sources




Ideally, these parameters would be evaluated at the site,  although




the data are more frequently available only from the nearest airport.






                                 60

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The limitations, however, in using such "regional" information to




infer local conditions has been noted by authors such as laccarino




et al., 1984, particularly in areas of complex terrain.




     Thus, it is clear from the literature that a fairly extensive




program of background data collection and sampling is needed prior




to contaminant sampling to ensure that the samples are as




representative as possible within the limitations (e.g., cost and




time constraints) placed on the sampling program.  However,  such




extensive background data collection is rarely performed in  support




of current site inspections.  At best, information from secondary




sources, often regional information, is used to infer local




conditions.  The lack of actual site specific knowledge of these




important environmental parameters increases the uncertainty in the




data, limiting its usefulness.  As a simple final example, without




site specific information on the wind direction during air sampling




(as is the case for some site investigations, one cannot determine




if a sample constitutes a background (i.e., upwind) sample or a site




(downwind) sample.




     4.3.1.2  Sampling Techniques and Technologies.  In addition to




the environmental factors, several factors of human origin can




adversely affect the quality of concentration data during the




sampling process.  Two inter-related concerns arising from the need




to produce representative data with minimal errors, are of particular




importance during sampling.   These concerns are:  1) that the






                                 61

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samples collected represent to the greatest extent possible, in situ




concentrations at the instant of sampling and 2) that the samples




do not become contaminated during the sampling process.  Several




additional concerns common to most media can be identified.  These




include the potential for sample contamination from a wide variety




of sources, potential for interaction between the sample and the




environment after the sample has been taken, gaps in sampling




technology (both in terms of contaminants that can be sampled and in




terms of critical operating parameters such as minimum sampling




times), lack of standardization and validation of some existing




techniques, cross-contamination between samples taken with the same




sampler, safety considerations that might preclude the collection of




otherwise needed samples (e.g., in buried drums), and the potential




for needed, but unvalidated, modifications to sampling equipment to




meet  site-specific conditions.  The following discussion illustrates




these concerns in each of the five environmental media and in wastes.




      Ground Water.  The literature yielded more information on




problems associated with ground water sampling technologies and




techniques than for any of the other media, reflecting, as indicated




by several authors, the relative difficulties inherent in ground




water sampling in comparison with other media.  Gillham et al. (1983)




presents the best overall discussion of the alteration in chemical




concentrations that can be induced in ground water samples.  Table 11




lists the sources of sample bias identified in their analysis.






                                 62

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                                                              TABLE   11
                            POTENTIAL  SOURCES  OF  BIAS  IN  SAMPLING  GROUND  WATER
INORGANIC AND
RADIOACTIVE
PARAMETERS
                    DIRECT
                                                                               INDIRECT
INORGANIC
Contamination  Parameters
    Electrical Cond.
    PH
    Redox Condition
Non Toxlo Conatltuenta
    Chloride
    SuIfate
    Sodium
    Ammonium
    Calolum
    Magnesium
    Iron, Manganese
Toxlo Constituents
    Nitrate
    Fluoride
    Araenlo
    Selenium
    Barium
    Cadmium
    Chromium
    Lead
    Silver
    Mercury
RADIOACTIVE
    Radium
    Gross Alpha and Beta
temperature, suspended  particles, precipitation, adsorption / exchange

O>2 degassing, precipitation of carbonates and oxides
oontaot  with akin
precipitation of gypsum,  reduction
adsorption / exchange,  leaohlng from glass, oontact with akin
adsorption / exchange,  volatilization at  low pH

adsorption / exchange
adsorption / exchange,  precipitation
denltrlfloatlon, nitrification
precipitation
adsorption / exchange /  leaohlng from sampling equipment,
  precipitation
                          adsorption  / exchange, precipitation, degasalng
  degassing,  changes In Eh,  pH

J 0, Invasion, temperature,  mloroblal aotl
                                                                                                                                     vlty
                                                                                                02 Invasion, C0?  degassing
                                                                      C0» degassing,  0-  Invasion
                                       ' Cross-contamination Is a problem  for all parameters, but la
                                         Indicated  here as a source of bias only If It Is  especially
                                         likely to  occur.
Source:   Gilham  et  al.,  1983.

-------
                                            TABLE   11   (Concluded)
 BIOLOGICAL
 AND ORGANIC
 PARAMETERS
                     DIRECT
                                                                                    INDIRECT
 BIOLOGICAL
     Colifora Bacteria
 ORGANIC
 Drlnklng-Water SKla.
     Endrln
     Llndana
     Methoxychlor
     Touphene
     2,»-D
     2,*,1-1T Sllvex
 Quality  Paraaatera
     Phenols
 Contamination Parantera
     Total Organic Carbon
     Total Organic Halogai
 Caaollne Coaponanta
     B«nz«n«
     Tolu«na
     I»l«n«
     Mathjrl t-butyl  «th*r
                           croaa-contaalnatlon
aorptlon,  orono-oontaalnallon ,
   blodagradatlon during atoraga
                           aorptlon,  oroaa-oontaalnatlon ,l«aohlng,
                              blodegradatlon during atoraga
aorptlon,  oroaa-oontaailnatlon ,  leaching, volatlllr.atlon,
   blodagradatlon during atoragA
dlffualon through plaatloo"] aorptlon, oroaa-conta>lnatlon
                         J    laaohlng, volatllnation,
                               blodagradation during atoraga
                                                               0. Invasion, pH, precipitation of
                                                                  other  ooapounde
                                                                                          0  Invasion
                                        •  Croaa-oontaalnatlon la  a  problaai for all  paraautara, but la
                                          Indicated here aa a source of blae only IT It  le (specially
                                          likely to ooour.
Source:  Gilham et  al.,   1983.

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     Possibly the most frequently identified problem in ground water




sampling is the problem of sample contamination by stagnant casing




water (see, for example, Berg, 1982; Driscoll, 1986; Gibb, Schuller,




and Griffin, 1981; Gosse et al., 1986; McKown, Schalla, and




English, 1984; Nacht, 1983; Scalf et al.,  1981; and Sisk,  1981).




Concentrations in the casing water are not representative  of the




concentrations actually in the aquifer.  Thus, this water  must be




purged from the well before sampling.  Generally, most authors




recommended purging between 4 and 10 well volumes from the well to




achieve a level of no more than 5 percent casing water. McKown,




Schalla, and English (1984), however, raise the possibility that




purging of five well volumes may not appreciably decrease  the




probability of significant sample contamination.  These authors




indicate that greater reliance should be placed on natural purging.




In either case, the resultant observed concentration may not reflect




risk with respect to the actual concentration of pollutants to which




the user is exposed (e.g., in water from a tap).




     Additionally, numerous authors have identified problems with




ground water sampling techniques and technologies.  Most authors,




such as Barcelona et al. (1985) and Claassen (1982) stress the




importance of not overly disturbing the geomedia during well




construction and sampling so as to ensure that natural conditions




are maintained and in-situ conditions are sampled.
                                 65

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     Both Driscoll (1986) and Claassen (1982) identified pump and




well residues as important sources of sample contamination.




Driscoll specifically identifies entrained sediments as a source of




contamination.  Claassen (1982) identified the problem of




contamination of ground water by chemicals resulting from the




degradation of well materials in old wells.  Ihis problem is of




particular interest since current PA/SIs rely heavily on existing




wells in order to reduce sampling costs.




     Several other authors have identified well construction and




drilling equipment as potential sources of sample contamination (for




example, Absalon and Starr, 1980; Fetter, 1983; Geraghty and Miller,




Inc. and American Ecology Services, Inc., 1985; Gillham et al., 1983;




and Keith et al., 1983b).




     Along similar lines, McKown, Schalla, and English (1984) note




the effect that well diameter has on estimates of transmissivity,




indicating that transmissivity estimates in two inch diameter wells




range over two orders of magnitude.




     The duration of pumping has been specifically identified as an




important contributor to sample uncertainty by Driscoll (1986);




Geraghty and Miller, Inc. and American Ecology Services, Inc. (1985);




Nacht (1983); Keith et al. (1983b); and Sgambat and Stedinger (1981).




Figure  11 illustrates the changes that can occur in contaminant




concentration and related parameters during pumping.  As indicated




in this figure, contaminant concentrations as well as other






                                 66

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350


300


250
 25

 20


 15

 10
 15



 10
 EC, ^mho/cm
 Cl, mg/L
- N03, mg/L
26.0
25.5
      Temp., °C
             1
                               10
                                                 100
                  Time after Start of Pumping, Minutes
   Source: Keith et a/., 1983b.
                         FIGURE 11
WATER QUALITY FLUCTUATIONS WITH TIME OF PUMPING
                             67

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indicators of the stability of the ground water environment may vary




considerably over time as a result of pumping.  Claassen (1982) also




identified the importance of pump operation in adversely affecting




sample quality.




     Time for withdrawal of samples from a well and the possibility




of changes in the water samples during withdrawal have been identified




as important sources of uncertainty (Driscoll, 1986; Gillham et al.,




1983; Geraghty and Miller, Inc. and American Ecology Services, Inc.,




1985; Ford and Turina, 1985; and Scalf et al., 1981).  The concern is




that the water environment of the sample will change even during the




short time for withdrawal, altering the contaminant concentrations.




Particular phenomena identified include degassing and volatilization




of volatile compounds  (Gillham et al., 1983), introduction of oxygen




and  possible changes in the oxidizing/reducing nature of the sample




(Gillham et al., 1983), changes in the carbon dioxide concentration




in the water (Geraghty and Miller, Inc. and American Ecology Services,




Inc., 1985), changes in biological activity (Geraghty and Miller, Inc.




and American Ecology Services, Inc., 1985), and changes in sample pH




and  temperature  (Driscoll, 1986; Gillham et al., 1983; Ford and




Turina, 1985; and Scalf et al., 1981).  As noted by Ford and Turina




(1985), the rates of many chemical reactions (including gas exchange,




microbial growth) double with each increase of 10 degrees Centigrade




in temperature.  They  also note that the presence of sunlight and




oxygen may produce near instantaneous changes in sample chemistry.






                                 68

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     Gillham et al. (1983) also identify the potential for sample




contamination arising from sampler and well materials (e.g.,




bentonites and plastics).  Geraghty and Miller, Inc. and American




Ecology Services, Inc. (1985) also identify the possibility of




contamination by the sampling apparatus.




     The problem of cross contamination arising from using the same




drilling or sampling equipment in two different locations was noted




by Absalon and Starr (1980); deVera et al. (1980); and Seanor and




Brannaka (1981).




     Gibb, Schuller, and Griffin (1981) indicate that the type of




pump used can have an adverse effect on sample quality.  The use of




air or nitrogen pumps appears to affect sample concentrations while




peristaltic pumps or bailing do not.  This conclusion is supported by




Seanor and Brannaka (1981) who indicate that air squeeze, piston,




jet, and submersible pumps are those most likely to cause




contamination problems.




     The extent of these problems was investigated under laboratory




conditions by Ho (1983).  Ho investigated the effects that transport




line materials, pump rate, lift (travel distance in the sampler), and




initial contaminant concentration had on final sample concentration.




He determined that all were important factors in determining sample




concentration although to differing degrees for different




contaminants.   Overall,  he found that line material was the most




consistently important factor, pump rate was important for volatiles,






                                 69

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and initial contaminant concentration was important for the more

volatile compounds.  Lift was found to be important for compounds
                                      _2      3
with Henry's constants greater than 10   atm-m /mol.


     Air.  The most common problems associated with techniques and


technologies for air sampling cited in the literature, disregarding


those directly related to the extreme spatial and temporal

variability of the atmosphere and its effects on contaminant

concentrations, are gaps in the availability of sampling equipment


(Ford, Turina, and Seeley, 1984; Gosse et al., 1986; Harrison,

undated; Riggin, 1983; and Zachowski and Borgianini, 1984).


     This problem is primarily apparent in the lack of commonly


accepted methods for the sampling of many organic vapors, gases, and


particles.  Ford, Turina, and Seeley (1984) note that currently

available portable equipment is unable to detect certain compounds of

possible interest in site investigations.  This problem is primarily

related to limitations of sorbents such as Tenax and to limitations


in field gas chromatography.  Gosse et al. (1986) present

a list of methods available for sampling organic vapors and gases


(Table 12).  It is interesting to note the relatively small number of

compounds listed and the lack of methods for maleic anhydride, methyl

acetate, and phthalic anhydride in this short list (all CERCLA


hazardous substances).  Riggin (1983) also notes that no standard

methods are available for many toxic air pollutants at low ambient


concentrations.  This is addressed by Harrison (undated) who
                                 70

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                                         TABLE  12
                       SAMPLING METHODS  FOR  AIRBORNE ORGANICS
 Hazardous Constituent
  Tenax    Charcoal   Cryogenic  Hl-Vol   DNPH
Cartridge  Cartridge  Trapping   PUF    Impinger
Other
Acetaldehyde
Acrolein
Acrylonitrile
Ally! chloride
Benzene
Benzyl chloride
Carbon tetrachloride
Chlorobenzene
Chloroform
Chloroprene
Cresol
Cumene
1,4-DCB
1,2-DCB
Dichlorome thane
Dioxin
Epichlorohydrin
Ethylbenzene
Ethylene oxide
Formaldehyde
X
X
X X
X X
XXX
X X
XXX
X X
X X
X X
X
X X
X X
X X
X X
Aarvan, 1981
X
X X
X X
X
Source:   Gosse et al.,  1986.

-------
                                       TABLE  12   (Concluded)
                                         TABLE 8-13  (continued)
  Hazardous Constituent
  Tenax    Charcoal   Cryogenic  Hl-Vol    DNPH
Cartridge  Cartridge  Trapping    PDF    Impinger
                                                                                       Other
  Hexachlorobutadlene
  Hexachlorocyclopentadiene
  Hydrogen cyanide
  Maleic anhydride
  Methyl acetate
  N-Dlmethylnitrosamine
  Naphthalene
  Nitrobenzene                  X
  Phenol                        X
  Phosgene
  Phthalic anhydride
  PCBs
  Propylene oxide
 1,1,2,2-tetrachloroethane      X
 Tetrachloroethylene            X
 Toluene                        X
 1,1,1-Trichloroethane          X
 Trichloroethylene              X
 Vinyl chloride
 Vinylidene  chloride
 Xyleae                        X
              X
              X
              X
              X

              X
              X
              X
                         X
                         X
X
X
X
X
X
X
X
                                                  No method  identified
                                                  No method  identified
                                                  ASTM STP 721,  198  p.  80-91
                                                  NIOSH Method  3502
                                                  Ruggle,  et  al.,  1979
                                                  No method identified
Source:   Gosse  et  al.,   1986.

-------
states that the analysis of low molecular weight hydrocarbons at low




concentrations requires a difficult chromatographic separation.




     Although the exact reasons for the problems encountered are not




discernible, Weber and Mims (1981) rejected the walk-through survey




method for detecting organic compound leaks because of severe




problems with the reproducibility of organic compound measurements




using portable devices.  To the extent that walk-through surveys of




chemical plants are similar to air contaminant surveys of waste sites




with portable equipment, this study raises questions about the use




of portable equipment surveys in site inspections.   Ford, Turina,




and Seeley (1984) also note problems of insensitivity and slow




response time in organic samplers.




     The problem of equipment gaps affects more than simply the




samplers.  Zachowski and Borgianini (1984) found that no suitable




sampling pumps were available to support their investigations of




uncontrolled waste sites in New Jersey.  The authors had to fabricate




their own pump in order to calculate daily exposures using a 24-hour




sampling period and relatively low flow velocities.  This problem is




also noted by Ford, Turina, and Seeley (1984).




     In comparison, the state of the art in particle sampling is




fairly well advanced (see, for example, Farthing, 1982; Harrison,




undated; and Stevens, 1984).  The outstanding problems in these




areas are concerned with the details of sampler design and with the




extraction of organics from filter media.






                                 73

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     Overall, these problems indicate the possibility that, given the




variability of air concentrations and the wide range of contaminants




found at uncontrolled waste sites, concentrations of concern for some




contaminants may not be detected during site inspections.




     Wastes.  Four problems were identified with techniques and




technologies for sampling wastes.  The primary problem associated




with waste sampling is maintaining sampling personnel safety (see,




for example, Wetzel, Wagner, and Tafuri, 1982).  This problem also




occurs in sampling any environmental media.  It is a more significant




problem in sampling waste, however.  As noted by Ford, Turina, and




Seeley (1984), care must be taken to minimize disturbance to the




waste matrix during sampling.  Some of the reasons for this are the




same as for ground water, as discussed above.  Unlike ground water,




however, sufficient disturbance of the wrong wastes may cause them to




explode or otherwise react with serious consequences.  For these




reasons, for example, it is considered unwise to sample the interiors




of  landfills unless waste locations and waste characteristics are




known.




     Associated with the need to minimize disturbance for safety




reasons and  to ensure collection of a representative sample is the




need to avoid increasing the mobility of wastes that are not




currently mobile.  For example, drilling into a landfill not only may




pose a safety risk, but it may also cause an increase in the rate of




release of gaseous contaminants from the landfill.  Further, drilling
                                  74

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through waatea into ground water may increase the rate of waste




migration to ground water.




     Accessibility is a third problem in waste sampling which is also




common to sampling any environmental media.   It may be extremely




difficult or hazardous to sample wastes in certain locations, e.g., from




the middle of a large surface impoundment or from buried containers.




This difficulty has led to the development of specific technologies




such as dippers with telescoping handles (Gosse et al., 1986).




     Finally, according to Gosse et al. (1986), different sampling




techniques are needed to sample wastes at different sites depending on




the type of waste and waste management unit  (see Table 13).   Waste




samplers have been developed to address most types of wastes in most




types of waste management units.  However, Gosse et al.  note that




equipment for the following situations must  be selected or designed on




a site-specific basis:  sludges, sand or powdered granules from waste




piles, landfills, land treatment facilities, surface impoundments




(including ponds and lagoons), and pits as well as sand or powdered




granules from tanks and other containers.




     Other Media.  The problems associated with the techniques and




technologies of sampling soils, surface water, and sediments are




similar to the problems already discussed.




     4.3.2  Handling




     Generally, once a sample has been taken,  it must be transported




to an analysis location.  This location may  be off-site (such as an
                                 75

-------
                                         TABLE   13
                 SAMPLING  EQUIPMENT FOR PARTICULAR WASTE TYPES
Source Unit Type
Storage Waste piles. Ponds,
tanks landfills, lagoons.
Waste Type Drua or bins & Land treataent & pits
Free flowing COLIWASA* Weighted N/A Dipper
liquids and glass tube bottle
slurries
Sludges Trier Trier a «

Moist powders Trier Trier Trier, Trier,
cr granules scoop scoop
Irv powder j Thief Thief Thief Thief
or granules
Sand or Auger a a a
packed powders
and granulea
Large Large Large Large Large
grained Trier Trier Trier, Trier,
solids scoop scoop
Other Waste Saaple Sources
Sacks Open bed Closed Convery
and baga truck bed truck belt Pipe
N/A N/A COLIWASA* N/A Dipper
glass tube

N/A Trier Trier Shovel, Dipper
scoop
Trier Trier Trier Shovel, Dipper
acoop
Thief Thief Thief Shovel, Dipper
scoop
Auger Auger Auger Dipper dipper


Large Large Large Trier Dipper
Trier Trier Trier

•Adapted frosi U.S. EPA, 1982.
 This situation can present significant logistical sampling problems) equlpMnt Bust be specifically selected or designed
  based on sit* and wast* conditions.
N/A - Hot applicable.

 Source:   Gosse et al.,  1986.

-------
EPA Contract Laboratory) or on-site (as in a mobile laboratory).




Alternately, there may be no appreciable handling component as in the




case of automatic sampling and analysis equipment such as mobile gas




chromatography/mass spectroscopy (GC/MS) units.  In any case, the




problems encountered in handling samples, though important, are not




as numerous as those of sampling and analysis.




     There is one pervasive problem associated with sample handling.




This is the need to minimize changes in the sample between the time




of sampling and the time of analysis.   This problem is noted by




numerous authors including Berg, 1982; Geraghty and Miller, Inc. and




American Ecology Services, Inc., 1985; Gillham et al., 1983;




Kirchmer, 1983; Plumb, 1984; Riggin, 1983; and Schuller, Gibb, and




Griffin, 1981.




     There are two semi-independent aspects to the problem.  First,




the integrity of the sample must be maintained and sample




contamination avoided.  This usually means that the sample must be




sealed and handled in a sealed container.  This is required to




minimize the interaction between the sample and the atmosphere and to




prevent the accidental introduction of foreign substances into the




sample.  Sealing prevents, for example, outgassing of volatiles from




liquid and sorbent samples and changes in sample chemistry that may




induce changes in contaminant concentrations.  These problems are




similar to those discussed previously concerning the interaction of




samples with the non-in-situ environment.
                                 77

-------
     The second aspect of the problem is that of sample stability.  A




minimum of "natural" changes in sample chemistry should be allowed to




occur between the time of sampling and time of analysis.  Naturally




occurring reactions (those that were in progress in-situ) that would




otherwise affect contaminant concentrations should be halted.  This




commonly requires that the sample be either frozen or preserved with a




preservative such as hydrochloric acid.




     These two aspects of the handling problem also interact to create




the need to minimize the interaction between the sample and its




container.  This problem is particularly wellknown in regard to liquid




samples where care must be taken to prevent loss of metals through ion




exchange with the container material (Fitzgerald, 1986).




     An additional problem, noted by Geraghty and Miller, Inc. and




American Ecology Services, Inc. (1985), is the potential contamination




that may occur when an aliquot of a sample is withdrawn from a sample




for analysis.




     4.3.3  Analysis




     Once a sample has been taken and transported (if necessary)  to a




laboratory, the process of analyzing that sample begins.  As mentioned




above, the analysis may be performed off-site, on-site, or as an




integral part of sampling.  Though it presents more problems than that




of handling, the analysis component of data development is considerably




more amenable to control than the sampling component.  The analysis




component occurs generally in a laboratory where conditions are,  in




principle, controllable.



                                 78

-------
     One of the most critical problems with sample analysis, one noted




by many authors (including Geraghty and Miller, Inc. and American




Ecology Services, Inc., 1985; Gurka et al., 1982; Keith et al., 1983a;




Kirchmer, 1983; Plumb, 1984; and Riggin, 1983), is the lack of




consistent, acceptable analytical methods for many contaminants of



concern at the concentrations encountered at waste sites.  Table 14



presents a list of over 90 RCRA hazardous constituents for which there



are analytical problems (Gosse et al., 1986).  These constituents



represent almost 25 percent of the RCRA hazardous constituents (all of




which are CERCLA hazardous substances).  EPA has recently proposed




changes in required ground water analyses for RCRA facilities, reducing




the list of RCRA contaminants to be analyzed in part because of




analytical constraints (51 FR 26632, 24 July 1986).  In addition,



Fitzgerald (1986) indicates that a significant number of CERCLA




contaminants cannot be analyzed by the EPA Contract Laboratories at




this time.  Overall, these gaps in analytical capabilities lead to



possibly undetected gaps in the coverage of contaminant compounds at



sites.




     In support of this contention, Keith et al. (1983a) note the



acceptable ranges for accuracy and precision employed in the EPA



Contract Laboratory Program (see Table 15).  The acceptable accuracy




of 200 percent indicates that the estimated concentration of a




contaminant may be consistently twice as high as the true value and




still be acceptable.
                                 79

-------
                               TABLE  14
    RCRA  APPENDIX  VIII COMPOUNDS   FOR  WHICH NO  SUITABLE
   ANALYTICAL PARAMETER  METHODOLOGY OR STANDARDS EXIST,
OR  FOR WHICH A  SURROGATE  HAS  BEEN  SUGGESTED AS AN ANALYTE
 l-acetyl-2-thiourea
 acrylamide
 aflatoxins
 aldicarb
 5-(aminomethyl)-3-isoxazolol
 amitrole
 auramine
 azaserine
 benz(c)acridine
 benzenearsonic acid
 benzo(j)fluoranthene
 brotnoacetone
 brucine
 chlorambucil
 chlornaphazine
 citrus  red  no. 2
 cycasin
 2-cyclohexyl-A,6-dinitrophenol
 cyclophospharaide
 daunomycin
 diallate
 dibenz(a,h)acridine
 dibenz(a,j)acridine
 7H-dibenzo(c,g)carbazole
 dichlorophenylarsine
 1,2:3,4-diepoxybutane
 diethylarsine
 diethylestilbesterol
 dihydrosafrole
 3,4—dihydroxy- -(methylamino)
   methyl benzyl  alcohol
 2,4-dithiobiuret
 3,3-dimethyl-l-(methyl thio)-
   2-butanone, 0-[(methyl amino)
   carbonyl] oxime
 endothal
 ethyl carbamate
 ethylenebis dithiocarbamic acid,
   salts and esters
 ethylenethiourea
 2-fluoroacetamide
 fluoroacetic acid,  sodium salt
 formic acid
 hydrazine
 hydroxydimethylarsine oxide
 iron dextran
 lasiocarpine
 lead subacetate
 maleic hydrazine
 raelphalan
 mercury fulminate
methanethiol
raethomyl
2-methylaziridine
methylthiouracil
mitomycin C
n-methyl-n'-nitri-n-nitrosoguanidine
n-napthyl-2-thiourea
N,N-diethyIhydrazine
n-nitrodiethanolamine
4-nitroquinoline-l-oxide
n-nitroso-n-ethylurea
n-nitroso-n-methylurea
n-nitroso-n-methylurethane
n—nitrosoarcosine
n-nitrosomethylvinylamine
n—nitrosonornicotine
n-phenylthiourea
n-popylamine
nickel carbonyl
nicotine and salts
nitrogen mustard-N-oxide and
  hydrochloride  salt
nitroglycerine
l-(o—chlorophenyl)  thiorea
o,o,o-triethyl phosphorothionate
o,o-diethyl S-methyl ester of
  phosphorodithioic acid
octamethylpyrophosphoramide
phenyl mercury acetate
phenylenediamine
phosphine
propylthiouracil
reserpine
saccharin and salts
selenourea
streptozotocin
strychnine and salts
sym-trinitrobenzene
tetraethyl lead
thiosemicarbazide
thiourea
thiuram
toluenediamine
0-toluidine hydrochloride
tris(1-aziridinyl)  phosphine sulfide
trypan blue
uracil mustard
warfarin and salts
 Source:   Gosse et al.,  1986
                                    80

-------
                              TABLE 15

                ACCEPTABLE RANGES  FOR PRECISION AND
          ACCURACY  IN  THE EPA CONTRACT LABORATORY  PROGRAM
Class of Compound
Volatiles
Acids
Base/Neutrals
Precision (%)
15
40
50
Accuracy (%)
40 -
50 -
15 -
200
200
200
Source:  Keith et al.,  1983a.
                                 81

-------
     Gurka et al. (1982) summarize the results of an early (pre-1983)




performance evaluation performed on the CLP EPA Contract Laboratory




Program (CLP) (see Tables 16 and 17).  For example, the authors note




that at that time several laboratories were unable to detect




benzidine and endosulfan II.  The results for chloroform, a common




waste site contaminant, regarded from a low of 14 ug/1 to a high of




303 ug/1, in comparison with a true value of 120 ug/1.  All but one




laboratory estimated the concentration as below 70 ug/1.  Further,




for endrin there was about a five order of magnitude difference




between the highest and lowest measurement among the laboratories.




These data also indicate a wide variation between laboratories.  A




similar evaluation is not available for the CLP program at the




present time.




     Isaacson, Eckel, and Fisk (1985) list three factors most likely




to account for the low occurrence of many compounds found at waste




sites:  non-optimum analytical methodologies, degradation of




compounds




prior to analysis, and incorporation into sample matrices.  Low




occurrence compounds are those that were either:  1) undetected




in the CLP Analytical Data Base of the EPA National Enforcement




Investigation Center Data Base or 2) detected at less than one-tenth




the average frequency of compound occurrence in each data base.




     The problem of inter-laboratory differences is also a common




problem outside of the CLP.  As indicated in Tables 18 and 19,




analytical results can vary markedly between laboratories.




                                 82

-------
                                     TABLE   16
            CLP PERFORMANCE EVALUATION  SAMPLE RESULTS,  1982
Contractor L»boratorle«
Conpound
Chlorobenzene
1.1,2, 2,-Tetrachloro-
ethane
Hethylene chloride
1,1, 2-Trlchloro-
ethane
Chlorofom
1 , 4-Dlchlorobenzene
Napthalene
Acenapthalene
Isophorone
llexachlorocyc lo-
pentadlene
ftenzldlne
Dlbenz(a,h)anthracene
N-Nltroao-dlphenyl
anlne
2-Chloronapthalene
4-Nt tropheaol
PentacKlorophenol
Phenol
1-BHC
p.p'-DDD
Endoaulfan II
Endrln
1
46

NDb
20

10
14
160
100
40
100

380
ND
ISO

330
50
375
210
170
ND
140
ND
ND

95

59
99

150
69
ND
41
60
3200

280
ND
ND

1300
220
160
220
98
130
213
NO
180

57

110
31

160
42
100
200
100
590

710
42
120

830
170
279
190
82
120
150
300
220

32

63
ND

100
37
140
140
70
660

200
160
80

580
100
360
230
no
100
150
170
300

41

10
65

121
43
ND
133
ND
ND

1105
ND
29

926
130
246
429
80
148
ND
224
0.06

51

94
54

130
36
160
170
96
370

ND
10
62

520
130
ND
520
69
130
150
50
180

60

107
58

152
31
116
98
86
ND

747
ND
10

1016
132
443
285
248
ND
218
ND
222

64

18
88

148
61
214
223
109
ND

1818
ND
ND

894
I7S
ISO
304
II)
61
136
150
159

39

ND
35

148
303
ND
2710
1220
ND

4600
ND
120

13400
1800
2050
1840
1330
SI2
167
ND
212
10
29

76
16

120
39
140
130
75
290

530
ND
160

610
100
285
280
130
ND
200
ND
ND
II
38

63
69

100
37
96
131
70
222

ND
ND
95

493
113
168
238
6
140
130
160
160
12
42

90
55

112
40
285
285
169
ND

ND
ND
ND

1118
220
754
1080
160
99
197
197
217
A
40

68
68

85
50
130
150
84
280

360
20
50

510
120
180
360
120
160
240
20
240
EPA 1
B
39

73
64

115
51
121
129
83
280

441
ND
76

396
103
344
454
104
113
119
190
189


C
^J

99
17

94
40
120
130
100
200

440
33
190

10
130
190
360
75
130
290
ND
220


D
a

a
a

a
a
186
180
143
328

461
5
237

722
123
144
462
87
S
231
5
345

e
42

90
II

103
40
152
168
106
220

190
8
345

780
157
262
326
82
117
174
23
340
True
Value
80

100
160

150
120
260
200
95
300

500
400
175

600
150
400
350
200
150
200
175
250
* Laboratory ~n- did not analyze the aanple for volatile organic*.
b ND - Not detected.
 Source:  Gurka  et  al.,  1982.
                                        83

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                                 TABLE   17
ANALYSIS  OF CLP  PERFORMANCE EVALUATION  SAMPLE  DATA,   1982
Laboratory No.
No.
1
2

3
4

5
6
7
8
9

10
11
12

13
14
15
16
17
18
19
20
Compound
Chlorobenzene
1,1,2.2-Tetra-
chloroethane
Methylene chloride
1.1,2-Trlchloro-
e thane
Chloroform.
1 ,4-Dlchlorobenzene
Napthalene
Acenapthalene
Hexachlorocyc lo-
pentadiene
Benzldlne
Dibenzanthracene
N-Nitroso-
dlphenylamine
2-Chloronapthalene
4-Nttrophenol
Pentachlorophenol
Phenol
beta-BHC
p,p'-DDD
Endosulfan II
Endrln
1
46

ND
20

10
41
160
100
40

380
ND
180

350
50
375
210
170
ND
140
ND
ND
3
57

110
31

160
42
180
200
110

710
42
120

830
170
270
190
82
120
150
300
200
6
51

94
54

130
36
160
170
58

ND
10
62

520
130
ND
520
69
130
150
50
180
9
39.5

ND
35.1

148
30.3
ND
2710
1220

4600
ND
120

13400
1800
2050
1840
1330
512
167
ND
212
True
Value
80

100
160

150
120
260
200
95

500
400
175

600
150
400
360
200
150
200
175
250
Mean3
49.5

75
54.2

116.0
44.3
165
160
96

617
78.3
109

851
143
294
368
122
132
186
179
219
Standard Performance Perfornance
Deviation Window Window
(S.D.) 0.5T 3T Mean +2 S.D.
17.4

29.6
26.3

42
10.7
53.4
69.5
35.8

450
70.9
74.4

309.0
48
169
237
48
33
50
84
87
40

50
80

75
60
130
100 -
47.5

250
200
87.5

300
75
200
175
100
75
100
87.5
125 -
240

300
480

450
360
780
600
285

1500
1200
525

1800
450
1200
1050
600
450
600
525
750
14.7

15.8
1.6

32.3
22.9
58.4
20.2
26.4

0
0
0

249
47
0
0
26
46
86
11
45
84.3

134.0
- 107.0

- 200.0
- 66.7
- 272.0
- 300.0
170.0

1517
- 220
258

1468
239
632
- 842
218
178
286
247
393
  The Hated mean values for compounds No. 1 to 5 are baaed on 16 laboratories.  The mean
  values  for compounds No. 6 to 13 are based on 16 laboratories and do not Include  values
  reported by laboratory No. 9. Mean values for compounds No. 14 to 20 are based on 17
  laboratories and do not Include values reported by laboratory No. 9.
Source:  Gurka  et  al.,  1982.
                                        84

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                              TABLE 18

               SUMMARY OF INTER-LABORATORY COMPARISON
Compound
Trichloroethylene
Tetrachloroethylene
Carbon Tetrachloride
1,1,1 trichloroethane
1,2 dichloroethane
Vinyl Chloride
Benzene
1,4-dichlorobenzene (as VOC)
1,1 dichloroethylene
Results
(20 ug/1)
23 +
22 +
20 +
22 +
21 +
20 +
21 +
23 +
23 +
3.0
2.6
2.6
3.0
3.5
11.3
3.5
3.9
6.4
Variation (%)
13
12
13
14
17
57
17
17
28
Source:   Adapted from Geraghty and  Miller,  Inc.  and American Ecology
         Services,  Inc.,  1985.
                                 85

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                              TABLE 19

               SUMMARY OF INTER-IABORATORY COMPARISON
Compound
2-Chlorophenol
1, 4-dlchlorobenzene
(as extractable)
Dimethyl Phthalate
Heptachlor
PCB-1260
Results
(200 ug/1)
156 + 47
144 + 56
13 + 5.6*
41 + 159
171 + 73
136 + 58
Variation (%)
30
39
43
388
43
43
*Results for 20 ug/1.

Source:  Adapted from Geraghty and Miller,  Inc.  and American Ecology
         Services, Inc., 1985.
                                 86

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     An additional problem is that different equipment may yield




different results when analyzing the same samples.  Geraghty and




Miller, Inc. and American Ecology Services, Inc. (1985) present the




data listed in Table 20, comparing the results of an analysis of a




soil sample using gas chromatography (GC) and GC coupled with mass




spectroscopy (MS).  The results show that there can be an order of




magnitude difference in the analysis of the same sample using




different equipment.




     Overall laboratory variability in ground water contaminant




analysis is summarized in Table 21.  As indicated in this table, good




precision and accuracy can be achieved in laboratories although the




laboratory variability for TCE (one of the most common waste site




contaminants) is large.




     Riggin (1983) notes that one problem with many techniques used




to analyze air filter and other samples is that the techniques are




destructive in nature.  This is important since it implies that




samples must be collected in sufficient quantity to allow the sample




to be split whenever more than one analysis is to be undertaken using




a destructive technique.  The list of destructive techniques includes




gas chromatography/mass spectroscopy, the principal analytical method




used to analyze waste samples for organic contaminants.




     Numerous other problems are noted by various authors.  Kirchmer




(1983) notes that there are numerous sources of bias and other




problems in laboratory analyses.  These include:
                                 87

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                              TABLE 20

              COMPARISON OF GAS  CHROMATOGRAPHY (GC) AND
        GAS CHROMATOGRAPHY/MASS SPECTROSCOPY (GC/MS)  RESULTS
                        (SOIL SAMPLE - ug/kg)
Compound
1, 1-Dichloro ethane
t-1 , 2-Dichloroethane
1,1, 1-Trichloroethane
Tetrachloroethane
GC
32
64
240
27
GC/MS
310
1,900
1,200
140
Source:  Adapted from Geraghty and Miller,  Inc.  and American Ecology
         Services, Inc., 1985.
                                 88

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                              TABLE 21

                MAGNITUDE OF LABORATORY VARIABILITY
      Component
Precision (%)
Accuracy (%)
Indicators
  pH, Special Conductivity
  TOG, TOX
  TON, TOG, COD, IDS

Organics

Inorganics
  Nonmetals
  Metals
  ICAP

Trichloroethylene
     10
    5-10
   10-50

   19-48
    5-20
    4-6
   10-25

 50 to 1,000
   10
  5-20
 up to 50

 up to 50
  0-11
  2-7
   10

50 to 1,000
Source:  Geraghty and Miller, Inc. and American Ecology Services,
         Inc., 1985.
                                 89

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     •  Sample instability




     •  Interferences




     •  Biased calibrations




     •  Biased blank correction




     Plumb (1984) identifies the following as being of particular




importance; impurities in purge gases, potential for compound




outgassing, inter-sample contaminant carry-over, and other




interferences.  McKown, Schalla, and English (1984) also discuss




the problem of interferences and contamination, noting that in one




occurrence, the benzene concentration in distilled water to be used




in field blanks was 33 ug/1.  These authors also identify the problem




of possible absorption of contaminants during filtration as a problem




of concern.




     4.3.4  Interpretation




     As indicated by Schweitzer (1981), interpretation of hazardous




waste site concentration data is more of an art than a science.  It




is a characteristic of such data that different persons can come to




different conclusions upon viewing the same data.  This phenomena




arises for several reasons.  First, the variability in the environment




and the potential for error discussed previously make interpretation




difficult.  Second, it is frequently difficult to differentiate




background from site-related contaminant concentration,  particularly




in a highly varying medium such as the atmosphere.   As an example




consider the ranges of background contaminant concentrations in urban
                                 90

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air reported in Riggin (1983) (Table 22).  Detecting site emissions




in an urban environment in the presence of other sources is a complex




task.  The applicability of advanced techniques, such as receptor




modeling (see, for example, Core, 1981), of such cases awaits




consideration.  Similarly, the lack of standards for many contaminants



(as noted by Zachowskl and Borgianini (1984) and others) makes the




interpretation of the risk from contaminant concentrations difficult.




Third, at many sites data are lacking on the local direction of flow



of the media during and preceding times of sampling.  Lacking such




data, the designation of a sample as "background" and another as a




"site sample" is subjective at best.  Fourth, there are no uniformly




acceptable methods for analyzing concentration data.  Many statistical




methods suffer from reliance on unrealistic assumptions, such as



normality, and are thus not generally applicable.  Recently developed



methods, such as variography and kriging (e.g., Moore and Mclaughlin,




1980 and Flatman, 1984), have also been criticized (e.g., Journel,




1984).




     Finally, it is unreasonable to expect that a single set of




techniques for interpreting concentration data can be developed.




There is too much variation between sites, too many gaps in




background information, and too many deficiencies in interpretive




techniques to allow development of a uniformly applicable collection




of such techniques.
                                 91

-------
                              TABLE 22

               RANGES OF SELECTED ORGANIC CONTAMINANT
                     CONCENTRATIONS  IN URBAN AIR
                                (ppb)
   Contaminant	Concentration Range

Methylene Chloride                                    0.049 - 9.4

Chloroform                                            0.019 - 5.1

Carbon Tetrachloride                                   0.11 - 2.9

Trichloroethylene                                     0.005 - 2.5

Benzene                                                0.11 - 37.0

Formaldehyde                                            6.6 - 41.0


Source:  Riggin, 1983.
                                 92

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5.0  COSTS




     This chapter presents a limited discussion of the costs




associated with developing concentration data at uncontrolled waste




sites.  A discussion of the general problems with estimating data




development costs is presented followed by discussions of the



principal factors that determine site-specific costs.  The chapter




concludes with an illustrative example of the magnitude of sampling




costs.



     It would be desirable to estimate the resources, both in terms




of time and money, necessary to collect representative concentration




data, to the limits provided by current technology and knowledge,



within the context of a preliminary assessment (PA) and site




inspection (SI).  Regrettably for reasons discussed below, this




cannot be done generically.  This chapter presents what information




is available in order to provide an indication of a lower bound on




the costs of developing representative data.  Based on this




information, a considerable increase in resources would be needed to



collect representative concentration data at all waste sites for all




media.  Even a ten-fold increase in the current average per-site SI




expenditures may not be sufficient.




5.1  Problems in Estimating Costs




     The first problem in estimating costs for developing




representative concentration data is the problem of specifying the




necessary degree of representativeness.  As indicated in Appendix B,
                                 93

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this is a significant problem since representativeness is poorly




defined and can only be assessed subjectively.  Moreover, the




necessary degree of representativeness depends on the objectives of




the program the data are  to  support and the uses to which the data




will be put as part of the program.   Since the exact  objectives of




the HRS and the specific  role that concentration data are to play




within the HRS are still  being  reviewed by EPA, no clear-cut,




unequivocal set of requirements can be stated.




     For the purposes of  this discussion, therefore,  the following




subjective statement of the  representativeness requirements for




concentration data will be used:  the data will be of sufficient




quality to support inferences (either subjectively or through models)




of the degree of risk posed  by  current and near-term  releases of




contaminants from the sites  and resulting exposures.  In order to




meet this requirement, three-dimensional profiles of  contaminant




concentrations will be required in both environmental media (i.e.,




ground water, surface water, air, soils, and  sediments) and wastes.




The sampling, handling, and  analysis  process  must be  performed




according to a comprehensive QA/QC procedure.  All sample analyses




used in the HRS must achieve the standards for accuracy and




precision established for the EPA Contract Laboratory Program.




Finally, estimates must be developed  for all  contaminants of concern,




to the extent possible given limitations on the state of sampling




and analysis technology.






                                 94

-------
     Second, as indicated by numerous authors (including Barcelona

et al., 1985; Berg, 1982; Claassen, 1982; deVera et al., 1980; Ford,

Turina, and Seeley, 1984; Ford and Turina, 1985; Gibb, Schuller, and

Griffin, 1981; Gosse et al., 1986; Hanisch and McDevitt, 1984;

JRB Associates, 1985; iMason, 1983; Nacht, 1983; Plumb, 1984;

Popkin, 1983; Porcella, 1983; Riggin, 1983; Scalf et al., 1981;

Sisk, 1981; Turpin, 1983; and U.S. Environmental Protection Agency,

1977, 1985a, and 1985b) numerous site-specific factors play critical

roles in determining many of the components of a sampling plan and

thus would affect the costs associated with a sampling effort.  A

partial list of these factors would include:

     •  Types of contaminants present at the site.

     •  Degree of heterogeneity in the environment surrounding the
        site.

     •  Site characteristics, including location of wastes and
        release characteristics.

     •  Size of the site and the surrounding potentially affected
        area.

     •  Demographics of the surrounding population.

     •  Relative importance of various transport and exposure
        pathways.

     This problem would not be critical if, in general, there tended

to be similarities among uncontrolled waste sites, in terms of these

critical factors.  Even after a cursory review of the sites on the

National Priorities List, one is struck by the wide variety of sites.

Sites range from traditional waste disposal sites (e.g., landfills,
                                 95

-------
surface impoundments, piles, tanks, containers,  and landfarms) to




contaminated sediments, well fields, roads and soil, to identify




just a few of the variations encountered during preliminary




assessments and site inspections.  There have been almost 500




different contaminants identified as being present at the 888 sites




proposed or listed on the NPL through Update 5.   Sites are located




in both urban and rural areas, in both fairly homogeneous and




heterogeneous areas.  There have been fairly small sites (Kin-Buc




Landfill is about 20 acres) and very large sites (BKK Landfill is




nearly 300 acres and there are even larger sites measured in terms




of square miles).  Nearly any setting in the United States may




contain a CERCLA waste site.  In total, it is not possible to define




a reasonably small number of generic "sites" and to thus estimate




costs for different cases.  However, certain components of total




costs, as well as other factors that affect costs, can be evaluated.




The following sections address some of these costs and factors with




regard to:




     •  Media




     •  Contaminants




     •  Sampling locations and numbers of samples




     •  Unit sampling and analysis costs




5.2  Media




     The cost of any particular sampling effort  depends on the




environmental media and waste to be addressed.   Total  costs  for any
                                 96

-------
particular site would not be simply equal to the sum of costs




incurred as a result of sampling each applicable media, due to




economies of scale in manpower, mobilization, and other cost




components.  Soil and air sampling could be performed concurrently




rather than on separate trips, for example.




     Based on a subjective assessment of the difficulties to be




encountered in developing representative data (as indicated in




Sections 2 through 4), as well as the limited data available in




reports cited above, an attempt has been made to provide an




approximate ranking of the media of concern in terms of the relative




costs to collect representative concentration data in each medium.




Ground water is probably the most expensive medium in which to




sample.  Costs to install wells are high,  and the background data




requirements necessary to ensure development of representative




samples are extensive.  Unit installation costs are high,  and it




would appear that in the best of situations a minimum of four wells




are needed to obtain valid concentration data (U.S. Environmental




Protection Agency, 1977 and 1985b).  Further, several wells may have




to be installed at each location, each screened in a different part




of the aquifer(s) of concern to develop data in all three dimensions.




Also, at least three parameters that have been mentioned as




prerequisites for sampling (gradient, transmissivity, and




conductivity)  are expensive to develop on a site-specific basis




(see Gerstein, 1986).   It is problematic whether regional estimates
                                 97

-------
are sufficiently accurate to be used instead.  Overall, the




difficulties inherent in ground water sampling and the resulting




high unit costs indicate that it would be the most expensive medium




from which to develop representative concentration data.




     Waste sampling is probably the second most expensive type of




sampling due to extreme spatial variability, safety considerations,




and potentially high unit costs of sampling.  Air is probably less




expensive, even though it is the most variable medium.  Air sampling




equipment is fairly well developed for both vapors and particulates.




Air sampling to ensure investigator safety is routinely performed




during all site investigations (U.S. Environmental Protection




Agency, undated) so unit costs should not be too extreme.




     Finally, it is likely that soil and surface water are the least




costly media to sample.  Despite its high degree of spatial




variability, soil sampling costs are probably relatively low.  The




high spatial variability would indicate the need for many sampling




locations but this could be offset by low unit sampling costs and




the potential for compositing samples (see Mason, 1983).  Similarly,




the high temporal variability and potential for spatial variability




in large water bodies would be offset by the low unit sampling costs.




     Overall, handling and analysis costs should be roughly




comparable for each media.




     These conclusions are nearly consistent with the ordering of




costs indicated by JRB Associates (1985)  and presented in Table 23.
                                 98

-------
                              TABLE  23

                     SUMMARY OF SAMPLING COSTS*

                                             Nominal          Complex
Hydrogeologic Investigation**                 Case             Case

  Develop plan, select contractors           4,000             8,000
  Perform tasks (tasks undefined)             1,000+            3,000+
  Sample wells                               5,600+           10,000
  Analyze samples                            variable         variable
  Report preparation                         8,000            16,000
  TOTAL (exclusive of analysis costs)        18,600+          37,000+

Onsite waste sampling

  Lagoons                                    1,540+           12,850+
  Drums and barrels                          7,040+           23,400+

Surface water, leachate and sediment,
  sampling and analysis                      6,100+           9,800+

Air quality sampling and analysis             1,520+           1,660+
 *Exact coverage of costs is unknown.
**Note:  For comparison, the reader should note the results of a
         recent (January 1987) EPA Region 1 analysis of data gathering
         costs which indicates that a current site investigation
         requires 300-400 hours of technical level of effort hours
         (including analytical) at a cost of $27,000 to $51,000.

Source:  JRB Associates, 1985.
                                 99

-------
The validity of the JRB Associates cost data, however, could not




be verified as the report provides little, consistent documentation




concerning their underlying assumptions or derivation.




5.3  Contaminants




     One of the principal determinants of the cost to develop




representative concentration data at a site is the list of




contaminants whose presence is suspected at or near the site.




This list includes, for any given site, not only the contaminants




known to have been deposited on the site, but also any of their




transformation products that might pose a risk as well.  Analysis of




additional contaminants may also be required to support advanced




interpretive techniques (e.g., receptor modeling).  As discussed




in Section 2, in many cases special monitoring instruments are




required to measure the concentration levels of many of these




contaminants.  Also, it is important to note in this context that




there are over 700 substances that are considered hazardous under




CERCLA.  Gosse et al. (1986) present a partial list of these




contaminants and the principal media of concern for each (see




Table 24).  The EPA Contract Laboratory Program analyzes for only




130 organic contaminants plus 27 metals and cyanide as part of their




routine analysis of water and soil samples.   Special analytical




services to address additional contaminants (e.g., PCB or TCDD) are




also available on a special request basis.
                                100

-------
                            TABLE  24
           RECOMMENDED MEDIA IN WHICH TO SAMPLE RCRA
              APPENDIX VIII  HAZARDOUS  CONSTITUENTS
Ground
water
acenaphthalene
acenaphthene
acetaldehyde
acetonitrile
acetophenone
2-acetylaminof luorene
acetyl chloride
acrolein
acrylonitrile
aldrin
allyl alcohol
alpha-BHC
aluminum phosphide
4-aminobiphenyl
aniline
anthracene
antimony (total)
aramite
aroclor 1016
aroclor 1221
aroclor 1232
aroclor 1242
aroclor 1248
aroclor 1254
aroclor 1260
arsenic (total)
arsenic acid
arsenic pentoxide
arsenic trioxide
asbestos
barium (total)
barium cyanide
benz(a)anthracene
benzene
benzene, dichloromethyl
benzenethiol
benzidine
benzo(a)pyrene
benzo( b ) f luoranthene
benzo(ghi)perylene
benzo(k) fluoranthene
p-benzoquinone
X
X

X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X




X

X
X

X
X
X
X
X
X
X
Surface
water
X
X

X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X




X

X
X

X
X
X
X
X
X
X
Saturated
soil
X
X

X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X




X

X
X

X
X
X
X
X
X
X
Unsaturated Subsurface
soil gas Air
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X


X




X
X









X
X
X
X
X
X
X
X



X



X








Source:  Gosse  et  al.,  1986.
                               101

-------
                     TABLE  24  (Continued)
Ground
water
benzot rich lor ide
benzylchloride
beryllium (total)
beta-BHC
bromodichlorome thane
b romome t hane
4-bromophenyl phenyl
ether
2-butanone peroxide
butyl benzyl phthalate
2-sec-butyl-4,6-
dinitrophenol
cadmium (total)
calcium chromate
calcium cyanide
carbon disulfide
carbon oxyfluoride
carbon tetrachloride
chloral
chlordane
chloroacetaldehyde
p-c hlo roan i line
chlorobenzene
chlorobenzilate
2-chloro-l , 3-butadiene
p-chloro-m-cresol
chlorodibromome thane
chloroethane
b is ( 2-c h loroethoxy )
methane
bis(2-chloroethyl) ether
2-chloroethyvinyl ether
l-chloro-2 , 3-epoxypropene
chloroform
bis(2-chloroisoprpyl )
ether
chlorome thane
bis(chloromethyl ) ether
chloromethyl methyl ether
2-chloronapthalene
2-chlorophenol
3-chloropropene


X
X
X
X

X

X

X
X


X

X

X

X
X
X
X
X
X
X

X
X
X

X

X
X


X
X
X
Surface
water


X
X
X
X

X

X

X
X


X

X

X

X
X
X
X
X
X
X

X
X
X

X

X
X


X
X
X
Saturated
soil


X
X
X
X

X

X

X
X


X

X

X

X
X
X
X
X
X
X

X
X
X

X

X
X


X
X
X
Unsaturated
soil
X
X
X
X
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
Subsurface
gas Air

X
X









X




X




X

X
X






X
X X







X
Source:  Gosse et al.,  1986.
                               102

-------
                     TABLE 24  (Continued)
Ground
water
3-chloropropionitri le
chromium (total)
chrysene
copper (total)
copper cyanide
crotonaldehyde
creosol
cumene
cyanide
cyanogen
cyanogen bromide
cyanogen chloride
ODD
DDE
DDT
delta-BHC
deno(l ,2, 3-cd)pyrene
di-n-butyl-phthalate
di-n-octyl phthalate
di-n-propylnitrosamine
dibenzo(a,e)pyrene
dibenzo(a.h) anthracene
dibenzo(a,h)pyrene
dibenzo(a, i)pyrene
1 , 2-dibromo-3-chloro-
propane
dibromome thane
1 , 2-dibromoethane
tris (2 , 3-dibromopropyl )
phosphate
m-dichlorobenzene
o-dichlorobenzene
p-dichlorobenzene
3, 3 '-dichlorobenzidine
trans-l,4-dichloro-
2-butene
dichlorodif luoro-
me thane
1, 1-dichloroethane
1 ,2-dichloroethane
trans-1 ,2-dichloroethene
1 , 1-dichloroethylene
1 , 2-dichloroethylene
X
X
X
X




X



X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X

X

X
X
X
X
X
X
Surface
water
X
X
X
X




X



X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X

X

X
X
X
X
X
X
Saturated
soil
X
X
X
X




X



X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X

X

X
X
X
X
X
X
Unsaturated
soil
X
X
X
X
X
X


X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X

X

X
X
X
X
X
X
Subsurface
gas Air

X




X
X























X
X




X
X
X

X X
X X
Source:  Gosse et al.,  1986.
                             103

-------
                    TABLE 24  (Continued)
Ground
water
die h lor ome thane
2 ,4-dichlorophenol
2 ,6-dichlorophenol
2 ,4-dichlorophenoxy-
acetic acid
1 , 2-dichloropropane
cis-1 ,3-dichloropropane
trans-l,3-dichloro-
propene
dieldrin
o,o-diethyl o-2-parazinyl
phosphor othionate
o,o-diethyl phosphoric
acid, o-p-nitrophenyl
ester
diethyl phthalate
diisopropylf luoro-
phosphate
3, 3'-dimethoxybenzidine
dimethoate
p-dimethylaminoazo-
benzene
7, 12-dimethylbenz(a)
anthracene
dimethyl benzene
3,3'-dimethylbenzidine
dimethylcarbatnoyl
chloride
1 , 1-diraethylhydrazine
1 , 2-dimethylhydrazine
, -dimethylphenethyl-
amine
2,4-dimethylphenol
dimethyl phthalate
dimethyl sulfate
m-dinit robenzene
4, 6-dinitro-o-cresol
2,4-dinitro phenol
2, 4-dinitro toluene
2,6-dinitrotoluene
1 ,4-dioxane
diphenylamine
1 , 2-diphenylhydraz ine
X
X
X

X
X
X

X
X

X



X


X


X

X

X





X
X
X

X
X
X
X
X
X
X
X
Surface
water
X
X
X

X
X
X

X
X

X



X


X


X

X

X





X
X
X

X
X
X
X
X
X
X
X
Saturated
soil
X
X
X

X
X
X

X
X

X



X


X


X

X

X





X
X
X

X
X
X
X
X
X
X
X
Unsaturated Subsurface
soil gas Air
X XX
X
X

X
X
X

X
X

X


X
X

X
X
X

X

X
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
Source:  Gosse et al.,  1986,
                            104

-------
                      TABLE  24  (Continued)
Ground
water
disulfoton
endosulfan I
endosulfan II
endrin
endrin aldehyde
ethyl benzene
ethyl cyanide
bis(2-ethylhexyl)
phthlate
ethyl methacrylate
ethyl methanesulfonate
ethylene oxide
ethyleneimine
famphur
f lourene
fluoride
fluorine
fluouranthene
formaldehyde
garama-BHC
g lye idyl aldehyde
heptachlor
heptachlor epoxide
hexachlorobenzene
hexachlorobutadiene
hexachlorocyclo-
pentadiene
hexachlorodibenzo-p-
dioxins
hexachlorodibenzofurans
hexachloroe thane
hexachlorophene
hexachloropropene
hexaethyltetraphosphate
hydrocyanic acid
hydroflouric acid
hydrogen sulfide
icocyanic acid,
methyl ester
iodome thane
isobutyl alcohol
isodrin
X
X
X
X
X

X

X
X

X

X
X
X

X

X

X
X
X
X

X

X
X
X
X
X






X
X
X
Surface
water
X
X
X
X
X

X

X
X

X

X
X
X

X

X

X
X
X
X

X

X
X
X
X
X






X
X
X
Saturated
soil
X
X
X
X
X

X

X
X

X

X
X
X

X

X

X
X
X
X

X

X
X
X
X
X






X
X
X
Unsaturated Subsurface
soil gas Air
X
X
X
X
X

X

X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X

X

X
X
X
X
X
X
X
X
X

X
X
X
X





X





X






X





X

X







X
X
X





Source:  Gosse et al.,  1986.
                              105

-------
                     TABLE  24  (Continued)
Ground
water
kepone
lead (total)
lead acetate
lead phosphate
maleic anhydride
malonitrile
mercury (total)
methacrylonitrile
methane
met hapyri line
methoxychlor
3-methycholanthrene
methyl acetate
2-methylactonitril
4)4'-methylene bis
(2-chloroaniline)
methyl ethyl ketone
methyl hydrazine
methyl methacrylate
methyl tnethanesulfonate
methyl parathion
mustard gas
napthalene
1 ,4-napthoquinone
1-napthylamine
2-napthylamine
nickel (total)
nickel cyanide
4-nitophenol
nitric oxide
p-nitroaniline
nitrobenzene
nitrogen dioxide
nitrogen mustard and
hydrochloride salt
n-nitrosodi-n-
butylamine
n-nitroso diethylatnine
n-nitrosodimethylamine
n-nitrosodiohenyl-
amine
n-nitroso raethy lethyl-
amine
X
X



X
X
X

X
X
X



X
X

X
X
X

X
X
X
X
X

X

X
X




X
X
X

X

X
Surface
water
X
X



X
X
X

X
X
X



X
X

X
X
X

X
X
X
X
X

X

X
X




X
X
X

X

X
Saturated
soil
X
X



X
X
X

X
X
X



X
X

X
X
X

X
X
X
X
X

X

X
X




X
X
X

X

X
Unsaturated
soil
X
X
X
X
X
X
X
X

X
X
X

X

X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X

X


X


X


Subsurface
gas Air

X


X

X

X



X









X


X





X






X




Source:  Gosse et al.,  1986.
                               106

-------
                     TABLE  24  (Continued)
Ground
water
n-nitrosomorpholine
n-nitrosopi peri dine
n-nitrosopyrrolidine
5-nitro-o-toluidine
ortho cresol
osmium (total)
osmium tetroxide
para cresol
paradelyhe
parathion
pentachlorobenzene
pent achlo rod ibenzo-p
dioxins
pentachlorodibenzo-
furans
pen tachloroe thane
pentachloronitrobenzene
pentachlorophenol
phenacetin
phenanthrene
phenol
phorate
phosgene
phthalic anhydride
2-picoline
potassium cyanide
potassium silver
cyanide
pronamide
1,3-propane sultone
propylene oxide
2-propyn-l-o
pyrene
pyridine
resorcinol
safrole
selenium (total)
selenium sulfide
seleniuos acid
silver (total)
silver cyanide
silvex
X
X
X
X
X
X

X

X
X

X

X
X
X
X
X
X
X
X


X



X


X
X
X
X
X
X


X

X
Surface
water
X
X
X
X
X
X

X

X
X

X

X
X
X
X
X
X
X
X


X



X


X
X
X
X
X
X


X

X
Saturated
soil
X
X
X
X
X
X

X

X
X

X

X
X
X
X
X
X
X
X


X



X


X
X
X
X
X
X


X

X
Unsaturated Subsurface
soil gas Air
X
X
X
X
X
X
X
X
X
X
X

X

X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X
X



















X

X
X






X











Source:  Gosse et al.,  1986.
                              107

-------
                     TABLE 24  (Continued)
Ground Surface Saturated Unaaturated
water water soil soil
sodium cyanide
strontium sulfide
sulfide
2,4,5-T
1,2,4, 5-tet rach loro-
benzene
2,3,7, 8-tetrachloro-
dibenzo-p-dioxin
tetrachlorodibenzo-p-
dioxins
tetrachlorodibenzo-
furans
tetrachloroethene
1,1,1, 2-tetrachloro-
ethane
1,1,2, 2-tetrachloro-
ethane
2,3,4,6-tetrachloride
tetraethyldithio-
pyro phosphate
tetraethylpyrophosphate
t e t ran i t rome t hane
thallic oxide
thallium (I) acetate
thallium (I) carbonate
thallium (I) chloride
thallium (I) sulfate
thallium (total)
thallium selenite
t hioacetamide
toluene
toluene diisocyanate
toxaphene
t ribromome thane
1 ,2 ,4-t rich lor obenzene
t richloroethene
1,1, 1-t rich loroe thane
1,1,2-trichloroethane
trichlorome thane thiol
t rich lor omonof luoro-
methane
2,4, 5— t rich lor ophenol


X
X

X

X

X

X
X

X

X
X

X







X


X

X
X
X
X
X
X
X

X
X


X
X

X

X

X

X
X

X

X
X

X







X


X

X
X
X
X
X
X
X

X
X


X
X

X

X

X

X
X

X

X
X

X







X


X

X
X
X
X
X
X
X

X
X
X
X
X
X

X

X

X

X
X

X

X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
Subsurface
gas Air









X


X X



X
X












X X




X X
X X
X




Source:  Gosse et  al.,  1986.
                              108

-------
                          TABLE  24  (Concluded)
                      Ground   Surface  Saturated  Unsaturated  Subsurface
                       water    water      soil       soil         gas      Air
2,4,6-trichlorophenol
1,2, 3-t rich loropro pane
vanadic acid,
ammonium salt
vanadium (total)
vanadium pentoxide
vinyl chloride
xylenes
zinc (total)
zinc cyanide
zinc phosphide
X
X


X

X

X


X
X


X

X

X


X
X


X

X

X


X
X

X
X
X
X

X
X
X






X X
X



Source:   Personal correspondence with  Robert April (EPA-OSW-LDB).
         "Guidance on Issuing Permits  to Facilities Required  to
         Analyze Ground Water for Appendix VIII Constituents."
Source:   Gosse et  al.,  1986.
                                     109

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5.4  Number of Sampling Locations




     The required number of sampling locations (in three dimensions)




needed to achieve representative samples depends heavily on site and




waste specific conditions.  The two most critical site specific




factors are the size of the potentially affected area and the size




of the zones of homogeneity at the site.  A zone of homogeneity (in




three dimensions) is a volume of space in which it can be assumed




that the distribution of contaminant, in the medium in question is




homogeneous.  Since each zone of homogeneity must be sampled in at




least one location, the number of sampling locations must generally




exceed the ratio of these two sizes.  Moreover, multiple samples




should be taken within each zone of homogeneity to account for




sampling and other random errors.  Statistical sampling theory




provides some approaches for estimating the number of samples needed




within each zone, depending on the desired level of confidence.




However, most of these approaches depend on assumptions that are,  at




best, unlikely to be true about contaminant concentrations at




uncontrolled waste sites (e.g., normality of the contaminant




distribution).  Further, they also require some knowledge about the




parameters of the distribution such as the coefficient of variation




which is almost always unknown.   Overall, there is no objective set




of approaches that can be employed routinely to estimate the number




of sampling locations needed at a given waste  site.   Judgment is




required.
                                 110

-------
     As an example of the number of sampling locations that might



be required to sample ground water, the draft RCRA Ground-Watej:



Monitoring Technical Enforcement Guidance Document of August 1985



(U.S. Environmental Protection Agency, 1985b) indicates that a



minimum of four wells are required (one upgradient, three



downgradient) while a spacing of one well each 150 feet (or less) is



required whenever, for example, liquid wastes are present.  This



density of wells is required to support a detection monitoring



system, i.e., one that would detect a release, but not necessarily



characterize the concentrations of that release from the site.  In



general, more wells would be needed to assess the extent and



concentrations of a release.  The installation of even four wells



would be expensive in terms of current site inspection costs at many



sites (see Gerstein, 1986).



     As another example, Hanisch and McDevitt (1984) present a method



for estimating the number of sampling locations required in a zone



of homogeneity of area A (in square meters).  In their equation, the


                                        1/2
number of locations must exceed 6 + 0.1A   .  Thus, the number of


                                                      2
sampling points in a homogeneous zone of size 10,000 m  in a



surface impoundment of area must exceed 16.



5.5  Number of Samples Per Location



     There are three aspects to consider in determining the number



of samples to be taken at each sampling location:  frequency,



duration,  and replication.  The first two are determined by the
                                 111

-------
temporal variability of the contaminant concentrations in the




potentially affected area and the type of health (and other) effects




expected as a release of the release (e.g., acute or chronic).  For




example, assessments of chronic effects risks might require long-term




average concentrations requiring possibly less frequent samples over




a long period of time, while assessments of acute effects risks may




require that a great many samples be taken in a short period of time.




In between, the assessment of risks of subchronic effects may require




fairly frequent sampling over a relatively long period of time.




     Replication, the third aspect to the number of samples,




addresses the need take multiple samples to account for uncertainty




brought on by random sampling errors.




     With the exception of replication, there are again no objective




approaches to assessing the frequency or duration of sampling.




However, representative sampling would, in principle, require a




fairly large number of samples at each location, if for no other




reason than to account for random errors.




     Provost (1984) presents a table that is useful in estimating




the  sampling frequency needed to achieve specified confidence




intervals about a mean as a function of a known coefficient of




variation and an assumption about the underlying distribution (see




Table 25).  As indicated in this table, for example, 24 samples from




a normally distributed process with a coefficient of variation of




50 percent would yield a 95 percent confidence interval about the
                                 112

-------
                                                  TABLE 25

       EXPECTED CONFIDENCE INTERVALS  FOR A PARAMETER MEAN AS  A FUNCTION OF NUMBER  OF SAMPLES


         Expected Confidence Intervals for a Parameter Mean aa a Function of Number of Samples (Measurements)
Expected
Variability
Measurement
(Coefficient
of Variation
51
10Z
25Z
50Z
100Z
200Z
500Z
1000Z
10000Z
of
95Z Confidence Interval About the Mean Estimate ( percent )b
Distribution n - 4
)a (Model) (Quarterly)c
Normal Model
Lognormal Model
Normal Model
Lognormal Model
Normal Model
Lognormal Model
Normal Model
Lognormal Model
Normal Model
Lognormal Model
Lognormal Model
Lognormal Model
Lognormal Model
Lognormal Model
+8.0
+8.1, -7. 5
+15
+17, -15
+40
+48, -32
+80
+110, -53
+160
+280, -73
+650, -87
+1700, -94
+3000, -96
+13000. -99
n - 6 n - 12
(Bl-monthly)c (Monthly)0
+5.2
+5.4", -5.1
+11
+11, -9. 9
+26
+2 9, -23
+52
+62, -39
+110
+104, -58
+280, -74
+570-85
+900-90
+2300, -96
	 L 	 _ 	 _-
+3.2
+3. 2, -3.0
+6.4
+6. 5, -6.1
+16
+17, -14
+32
+35, -26
+64
+70, -41
+124.-55
+220, -68
+300, -7 5
+590, -85
n - 24 n - 52
(Seml-monthly)c (Weekly)c
+2.1
+2.1, -2.0
+4.2
+4. 3, -4.1
+11
+1 1 , -9 . 9
+21
+22, -18
+42
+42, -30
+71, -42
+120, -53
+150, -60
+260, -7 2
+1.4
+1.4
+2.8
+2. 8, -2. 7
+6.9
+7.1,6.6
+14
+14, -12
+28
+26, -21
+43, -30
+65, -40
+82, -4 5
+130. -57
n - 365
(Dally)c
+0.5
+0.5
+1.0
+1.0
+2.6
+2. 6, -2. 5
+5.2
+5.0, -4. 8
+11
+9.0, -8. 2
+14, -12
+20, -17
+24, -20
+37, -27
  value  for  the coefficient la assumed  In this table.  If  the coefficient of variation  Is greaterthan 100Z,
  the normal model Is not realistic.
 bn - number of samples or data points.
 cMonltorlng frequencies required for the specific value of  n If the duration of study  was one year.
Source:   Provost,  1984.

-------
mean of about 21 percent.  This means that in practice if semi-




monthly samples were taken at a sampling location that experienced




temporal variations of 50 percent (expressed as the coefficient of




variation), then one would be 95 percent confident that the true




average lay within 21 percent of the sample average.




5.6  Unit Sampling, Handling, and Analysis Costs




     The development of generic cost estimates is also hampered by a




lack of data on unit costs for background information collection,




sampling, handling, and analysis in many of the media and under the




conditions applicable to uncontrolled waste sites.  The compilation




of such a unit cost data set is beyond the scope of this report.




However, some unit costs estimates were identified as part of this




review.  Additional unit cost information concerning ground water




sampling can be found in Gerstein, 1986.




     Few cost data concerning background information collection




could be collected.  The only indication of the magnitude of these




costs is the current cost of Preliminary Assessments.  These




assessments currently cost approximately $1,200 per site.  It




is likely that the cost of background information to support




representative data development (e.g., ground water flow direction)




would be substantially higher.




     Some very limited information is available on sampling,




handling, and analysis costs.  As discussed previously, Table 23




presents cost data derived from JRB Associates, 1985.  The quality
                                 114

-------
of these data is unknown, given the lack of adequate documentation.




Further, based on the limited documentation provided in that report,




some of the estimates (e.g., the estimates for air sampling) appear




to be unreasonably low when compared with the requirements of




representative data development.  It should be stressed, however,




that the JRB Associates report is a draft report.




     Table 26 presents an example of the costs to  establish a ground




water sampling well field consisting of 10 wells drilled to a depth




of 100 feet each (adapted from Gerstein, 1986).  A representative




mobilization cost (including plan development, contracting, and




other administrative costs) is estimated to be about £6,000.  A




representative cost to install each well is estimated to be $4,000




(or about $40 per foot).   Unit costs cited in the  literature ranged




from $30 per foot to $100 per foot (JRB Associates,  1985 and U.S.




Environmental Protection Agency, 1985c).  A representative cost to




determine hydraulic gradient by potentiometric mapping (a necessary




prerequisite to sampling) is estimated as $4,500.  A representative




cost to determine hydraulic conductivity (a second necessary




prerequisite) by either a bailing test or a slug test is estimated




to be ijl,500 per well, or $15,000 overall.  These  costs do not




include costs for site security or disposal of drilling waste (a




potentially hazardous waste regulated under RCRA), nor do they




include any increased costs that might result from additional




concerns for worker safety over and above normal drilling risks.
                                 115

-------
                               TABLE 26

              EXAMPLE REPRESENTATIVE PRE-SAMPLING COSTS
                       TEN-WELL SAMPLING FIELD
              Cost Component
Costs ($)*
Mobilization

Well installation (10, 4-inch diameter wells,
  100 feet deep)

Potentiometric Mapping

Conductivity Tests (10 wells at $1500/well,
  slug or bail test

Total
 6,000**

40,000


 4,500

15,000


65,500
 *Costs do not include site security, disposal of drill spoils, or
  additional costs associated with worker safety.
**Note:  EPA Region 1 currently (January 1987) experiences a $55,000
         mobilization fee for a ten-well drilling program, in
         addition to costs of drilling and installation of wells.

Source:  Gerstein, 1986.
                                 116

-------
EPA Region 1 currently experiences a $55,000 mobilization fee for a




10-well drilling program, in addition to the cost of drilling and



installation of wells.




     Consistent unit cost information for collecting ground water




samples is not available.  JRB Associates (1985) listed costs




ranging from $300 to $400 per well.  The average costs for RCRA




Interim Status facilities is estimated to be $200 per well (U.S.




Environmental Protection Agency, 1985c).  The assumptions concerning




the number of samples taken and the cost component (e.g., manpower)



included in both these estimates are unknown.




     In contrast, consistent information was available on the cost



of analyzing water and soil samples using the CLP (Kolb, 1986).  The




current average analytical cost for the standard organic and




inorganic analyses are about $960 and $140, respectively.  The




costs for special analytical services are variable.




     Finally, little information was available on the cost of QA/QC




programs, although Schweitzer (1981) states that quality assurance




costs range from 0 to 20 percent of monitoring costs.




5.7  Illustrative Example




     To put this information into perspective, consider as an example




the 10-well field discussed above.  If the ground water were subject




to a temporal variation of 10 percent (expressed as the coefficient




of variation) during the period of concern and a 95 percent




confidence interval of +15 percent were desired, then, under a
                                 117

-------
normality assumption, 4 samples would be required at each well




(see Table 25).  Thus, a total of 40 samples would be required




at an expected analysis cost of J>44,000.  Assuming (probably




conservatively) that the sampling costs for these samples was $200




per well, a cost of $2,000 would also be incurred.  Thus, assuming




the 10 wells provided spacially representative data, the total cost




to develop representative concentration data under this scenario




(for ground water only) would exceed itllO,000, exclusive of handling,




QA/QC, interpretation, and administrative costs.




     Average total costs to develop representative data over all




media can only be inferred, at best, from this limited information.
                                 118

-------
6.0  SUMMARY OF PRECEDING DISCUSSIONS AND IMPLICATION FOR THE HRS




     Representative data is necessary to have a high degree of




confidence in decisions made based on the results of analyses on




that data.  The lower the degree of representativeness (i.e., the




lower the quality), the higher the uncertainty in the results and




the lower the confidence in the decisions.  The point at which the




degree of representativeness of the data becomes too low to support




the decisions to be made is determined by the decision-maker.  Thus,




it is EPA's responsibility to determine if the concentration data




developed as part of PA/SIs is of sufficient quality to support




particular uses of that data in the HRS to aid in deciding whether a




site is placed on the NPL.  However, as indicated previously, truly




representative data may be very expensive to develop at some sites




and may be beyond the capabilities of the program to develop




routinely.




     Many factors act to limit the quality of PA/SI concentration




data, thereby increasing its uncertainty.  Some factors are inherent




in the nature of concentration data; such data alone cannot indicate




future conditions, the data rarely reflect actual exposure




concentrations, and there is always a chance that actual




concentrations are significantly higher or lower.  Other factors are




programmatic in nature.  They arise from constraints on time and




resources, variations and limitations in the level of experience of




those evaluating sites, and from any gaps in a comprehensive QA/QC
                                 119

-------
program.  Still others are technological in that there are gaps in




sampling equipment and standard analytical techniques for some field




situations and contaminants.  A fourth set of factors arise from




difficulties in the acquisition, handling, analysis, and




interpretation of samples and sample data.  There are numerous




opportunities for introducing error into the development of




concentration data.  Undetected temporal and spatial variation in




environmental processes induce potentially undetected variation in




environmental concentrations.  The lack of information on these




processes at each site increases the uncertainty associated with




concentration data developed for that site.  Further, without




careful management, it is likely that samples will not be




representative of in-situ conditions and that they will become




contaminated.  These problems of sampling management arise in all




areas except the interpretation component of the data development




process.  Uncertainty in results is further increased by the




necessary assumptions that must be made in order to analyze sampling




results.  The degree to which these assumptions diverge from reality,




increases the uncertainty still further.




     Overall, there are numerous reasons to question the




representativeness of even the best concentration data set,  i.e.,




those data sets that have been carefully developed and analyzed




subject to an extensive QA/QC program.   Data developed without such




QA/QC can, at best, be considered suspect.






                                120

-------
     This discussion indicates that the role that concentration data




play in the HRS and in NPL decision-making should not be too




extensive, even if a good QA/QC program were to be implemented as




part of the PA/SI program.  Concentration data should be only one of




many factors considered in evaluating the risk posed by a site at




this stage of the assessment process.  Further, the limitations in




the data that could reasonably be developed from a site inspection




program on a routine basis indicate that any concentration data



factors should not be weighted heavily in the HRS.
                                 121

-------
7.0  OPTIONS FOR EMPLOYING CONCENTRATION DATA




     This chapter presents several options for using concentration-




based factors in the HRS.  These factors are designed to improve the




accuracy of the HRS in evaluating risk without exceeding the




limitations in concentration data discussed in the previous chapters.




The discussion also identifies changes in the site inspection program




that should be implemented if the options are incorporated into the




HRS.  Without these programmatic changes, the uncertainty in the




concentration data would be very high and the use of these




concentration data in the factors presented would be questionable.




7.1  Basic Philosophy




     A combination of factors determined the basic philosophy towards




employing concentration data that is reflected in the options




discussed below.  These factors include the possible objectives of




the HRS, the wide variation in the characteristics of uncontrolled




waste sites and the limitations in concentration data discussed




previously.  The objective of the HRS is assumed to be to




expeditiously identify sites for possible response action based on




their relative risks (U.S. House of Representatives, 1986).  The




objective requires that the HRS be applicable to all potential




CERCLA sites.  This, in turn, requires that any concentration




factors be applicable to all sites as well.  In the interest of




maintaining simplicity in the HRS, no special options were developed




to assist in evaluating the occasional sites with extensive
                                 123

-------
concentration and other environmental data.  Rather, the options and




factors discussed below employ data that could be collected at any




site within the constraints of a reasonable site inspection.




     The basic approach embodied in all of the options is to assign




additional points to sites with current problems, as indicated by




concentration data, without putting at a disadvantage those sites




that appear to lack current problems (as indicated by available




concentration data).  There are several reasons for adopting this




type of approach.  First, as discussed previously, sampling by its




nature is retrospective.  It indicates past problems only.   The data




can be used to infer present or future problems only by the use of




either implicit or explicit environmental models.  Alone,




concentration data tell nothing about future problems.   Second,




environmental concentration data can only be employed when they also




demonstrate an observed release.  Concentrations that do not exceed




background levels cannot be reliably associated with the site in




question.  Thus, the risk posed by these concentrations cannot be




associated with the site and should not be included in the evaluation




of the risk posed by the site being evaluated.  Third,  it is a




characteristic of any statistical analysis that many low values do




not completely rule out the existence of high values.  This is




embodied by the statement that "lack of evidence is not evidence of




lack".  Fourth, the data collected during site investigations can




rarely be considered as representative in all media.   The cost and
                                124

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time requirements associated with developing concentration data that




is representative of environmental concentrations in both space and




time across the five media of concern are likely to be excessive.




Finally, the uncertainty in the environmental concentration data




developed during site inspections is such that the measured data




indicate at best the lower limit of the maximum possible exposure




concentrations, even considering possible dilution and mass removal




effects.  If a particular contaminant concentration is measured in




the environment then the potential clearly exists for someone to




become exposed to that concentration either at the time the




measurement was taken or at some time in the future.  Thus, for a




given contaminant, the maximum detected concentration determines a




"worst-known-case" of potential exposure.  Moreover, the uncertainty




in the data generally indicate that the possibility exists for true




environmental concentrations to exceed detected concentrations




either at the same location (due to sampling, handling and analysis




uncertainty), at some other location (due to spatial variation), or




at some other time (due to temporal variation).  It is unlikely that




sampling will find the true maximum concentration.  For similar




reasons, the maximum detected waste concentration indicates a lower




bound on the maximum possible waste concentration.




     These considerations taken together indicate that little




reliance should be placed on low concentration values determined




during site inspections in determining that little risk exists from
                                 125

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the site.  However, the existence of high concentration values does


indicate that some risk may exist.  Thus, the approach taken in


these options is that sites with "high" observed contaminant


concentrations should be assigned extra points while those with


"low" contaminant concentrations should not be overly penalized.


The definitions of "high" and "low" concentrations require the


determination of benchmarks against which to assess the measured


concentration values.


7.2  Benchmarks


     Benchmarks determine whether an observed concentration of a


contaminant can be considered to be "high" or "low" (or "medium,"


etc.).  Benchmarks establish a metric to gauge the relative magnitude


of observed concentrations.  For example, a concentration of

          3
4,000 mg/m  of sulfur hexafluoride in a workplace might be

                                                3
considered low while a concentration of 500 mg/m  of trichloro-


ethylene in the same workplace would be considered high.   In the


former case the concentration is below the threshold limit value


(TLV) of 6,000 mg/m3 of sulfur hexafluoride while the latter

                                                           3
concentration exceeds the trichloroethylene TLV of 270 mg/m


(American Conference of Governmental Industrial Hygienists, 1985).


     Thus,  within the context of employing concentration  data within


the HRS, risk-related benchmarks have to be determined.  These

benchmarks need to be determined for each chemical of interest in a


consistent fashion.  Further,  since the HRS employs separate
                                126

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migration pathways (and to a lesser degree exposure pathways in




evaluating toxicity) and since the risk posed by an exposure to a




given concentration of a contaminant frequently differs depending on




whether the contaminant is ingested or inhaled, separate pathway




specific benchmarks have to be developed.  Additionally, since the




HRS addresses both human health and environmental risks, separate




benchmarks reflecting these two types of risk may have to be




developed for each contaminant and pathway.  The feasibility of




developing a collection of suitable benchmarks for use in the HRS is




problematic and remains an important outstanding issue in the use of




concentration data in the HRS.  The options discussed below assume




that an acceptable set of benchmarks can be developed.  The




development of such benchmarks is beyond the scope of this paper.




7.3  Options




     Options for employing concentration data in the HRS were




developed in each of the three evaluation categories:   release,




waste characteristics, and targets.  The options were developed so




as to be employable in any of the HRS migration pathways.  No special




ground water, surface water, or air options were developed.  The




options are discussed, by HRS factor category, in the following




sections.




     7.3.1  Options in the HRS Release Category




     The HRS currently employs concentration data in determining




whether an observed release has occurred.  The benchmark in this
                                127

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case is the background contaminant concentration.  A release category




value of 45 is assigned whenever the observed site concentration




significantly exceeds the background concentration in the medium




being examined, else, the site is evaluated based on its potential




to release.  The maximum potential to release value is also 45.




     An alternate approach of similar structure can be readily




defined employing a risk based benchmark as well as the background




benchmark, as follows.  If the observed concentration of any




contaminant in the environment* significantly exceeds the background




concentration for that contaminant (i.e., constitutes an observed




release) and also exceeds a benchmark concentration for that




contaminant and pathway, then a maximum observed release value of,




for example, 45 would be assigned.  If the observed concentration




significantly exceeds the background concentration but is lower than




the benchmark, then a lower value of, for example, 40 would be




assigned.  If the observed concentration does not significantly




exceed the background concentration, then the site would be




evaluated based on its potential to release since no observed




release can be attributed to the site.  The maximum potential to




release value might be set equal to the value for an observed




release that does not exceed the benchmark or it might be set equal




to the maximum observed release value.  Either variation is




reasonable.






*Waste concentrations cannot be used to evaluate the release category.





                                128

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     Table 27 illustrates this scoring approach.  At both Sites 1




and 2, the observed site concentrations significantly exceed background




and exceed the benchmark as well.  Thus,  a release category value of




45 is assigned to both the sites.  At Sites 3 and 4, the observed




concentrations exceed background, but do not exceed the benchmark.




Thus, these sites are assigned values of 40.  At Sites 5 and 6, the




observed concentrations do not significantly exceed background and




hence the sites are assigned values of 0 regardless of whether the




observed concentrations exceed the benchmark.  (It is noted that a




background level above the benchmark would presumably trigger an




investigation to identify an alternate source.)




     A shortcoming of this approach is evident in comparing the last




two hypothetical sites (7 and 8).  At both sites, the observed site




concentration of the contaminant in question significantly exceeds the




background concentration.  Thus, observed releases have occurred at




both sites.  Also, the observed concentration at Site 7 significantly




exceeds the benchmark while at Site 8 it only slightly exceeds the




benchmark.  Therefore, Site 7 poses a much greater risk than Site 8,




in principle, due to the presumably higher concentrations to which the




people around the site will be exposed, all other factors being the




same.  Thus, Site 7 should receive a higher value, in principle, than




Site 8.  However, due to the structure of this option both sites would




receive the same release category value (45) and site pathway scores,




all other factors being the same.  This consideration argues for a
                                 129

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                    TABLE 27




HYPOTHETICAL EXAMPLES OF RELEASE CATEGORY OPTION
Site
1
2
3
4
5
6
7
8
Benchmark
Concentration
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Background
Concentration
0.1
1.0
0.01
0.01
5.0
0.1
1.1
0.1
Site
Concentration
2.0
10.0
0.5
0.1
5.0
0.1
11.0
1.1
Assigned
HRS Value
45
45
40
40
0
0
45
45
                       130

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more refined evaluation approach employing varying levels relative to




the benchmark with associated levels of valuation (e.g., one-tenth of




the benchmark could be assigned one-tenth of the value, i.e., 4.5).




However, such an option is not presented here since it would place




too great a reliance on the concentration data in determining scores.




Using data of debatable validity in such an important fashion would




be questionable.




     One should note that the adoption of this option would change




somewhat the role that the release category plays in the HRS.



Currently, the release category reflects the likelihood that the




site has, is, or will release a significant quantity of contaminants



into the environment.  By establishing two levels of release values,




an implicit evaluation of the magnitude of the release is made



current, detected releases above benchmarks are evaluated higher




than potential future releases or undetected, current releases that




may or may not exceed benchmarks.  Thus, the release category would



address the probabilistic aspects of risk as well as a component of




the hazard aspects.



     7.3.2  Options in the HRS Waste Characteristics Category




     Two options for reflecting concentration data in the waste




characteristics category were developed.  The first envisions a




separate concentration factor, the value of which could be added to




the toxicity and waste quantity factor values to determine the




overall waste characteristics value.  As in the previous options,
                                 131

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this factor would be evaluated based on environmental concentration




data, not waste constituent concentration data.  The second envisions




modifying the waste quantity factor, changing it to reflect the




quantity of hazardous constituents found at the site rather than the




quantity of wastes containing hazardous substances.  This latter




option uses waste concentration data.  A third option for




incorporating concentration data in the toxicity factor is also




discussed.  This option is presented as an example of a potential




approach that requires strict confidence in the representativeness




of the concentration data.




     In the first option, the maximum detected environmental




concentration of each contaminant in an observed release would be




compared with both the background concentration for that contaminant




and the benchmark concentration.  Those concentrations that do not




significantly exceed background (and thus are ilot "observed




releases") would be rejected from further consideration in




evaluating factors related to environmental concentrations.  If all




concentration data are rejected or if no concentration data are




available, then the concentration factor is assigned a value of 0.




For each remaining concentration datum, the ratio of the datum to




the benchmark is calculated and the contaminant with the highest




ratio chosen.  The concentration factor would then be evaluated




based on the calculated ratio for that contaminant using a factor




table such as is illustrated in Table 28.   This option is designed
                                 132

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                   TABLE 28

   ILLUSTRATIVE CONCENTRATION FACTOR TABLE*


 Ratio (0/B)                              Factor Value

Greater than 1                                 5

  0.1 - 1.0                                    4

Less than 0.1                                  0
*Values are provided for illustrative purposes only.

B:  Benchmark concentration.
0:  Observed site concentration.
                      133

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to be used as an addition to the toxicity factor.  An example of the




approach is given in Table 29.




     The concentration of three contaminants in Table 29 (contaminants




1, 2, and 3) significantly exceed background and can be used in




evaluating the concentration factor under this option.  Since the




maximum site concentrations of contaminants 4 and 5 do not




significantly exceed background, these concentrations cannot be




attributed to the site and hence would be rejected from further




consideration in evaluating the concentration factor.  This rejection




is indicated despite the high site to benchmark concentration




associated with contaminant 4.  There is probably a risk at the site




due to high environmental concentrations of contaminant 4, yet it




cannot be unquestionably associated with the site.  Given the high




background concentrations, it is equally probable that the risk




arises from other contaminant sources.




     The ratios of the concentrations of the three contaminants are




calculated and the contaminant with the largest ratio is identified




(contaminant 2, ratio 20).  Using the illustrative factor table




presented on Table 28, the concentration factor score for this site




would be 5.




     Although the values listed in Table 28 are illustrative and




subject to change, two relationships embodied in the example table




are important and should be maintained if the option is adopted.




First, the maximum score (5) is smaller than the current maximum
                                 134

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                                TABLE 29

          HYPOTHETICAL EXAMPLES OF CONCENTRATION FACTOR OPTION*
Contaminant
1
2
3
4***
5***
Benchmark
Concentration
1.0
0.5
0.1
1.0
1.0
Background
Concentration
0.1
1.0
0.01
45.0
0.1
Maximum Site
Concentration
2.0
10.0
0.1
40.0
0.1
Ratio**
2
20
1
40
1
  *Environmental sample.
 **Rejected since detected concentrations do not demonstrate an
   observed release.
***Ratio of maximum site  concentration to benchmark concentration.
                                 135

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scores for the toxicity factor (18) and the waste quantity factor (8).




This embodies the conclusion that due to the uncertainty associated




with concentration data and the associated inferences about current




and future risk, this factor is less important than the others in




determining the site pathway score.  Also, it minimizes the




disadvantage associated with sites that lack observed releases.




Second, a relatively small ratio (e.g., at least one-tenth of the




benchmark) is needed to receive nearly the maximum value for the




factor.  This reflects a belief that the uncertainty in concentration




data is high and that concentration measurements near the benchmark




(i.e., within one-tenth of the benchmark) indicates the probable




presence of an exposure situation of concern.  These relationships




are consistent with the basic philosophy discussed previously.




     In the second option, the waste quantity factor would be




evaluated based on either the total quantity of wastes containing




hazardous substances at the site or the total quantity of hazardous




substances found in the wastes at the site.  The former approach is




that currently used in the HRS.  It would be employed whenever




detailed, complete, representative data on waste constituent




concentrations are lacking at the site.  The latter approach could




be taken only if such data were available.  Distributions of the




concentrations of the waste constituents would be developed from the




waste analyses.  The mean (or some other measure of tendency such as




the median, the mode, or the 95th percentile) of the distribution of
                                 130

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each substance would then be calculated and multiplied by the total

waste quantity to yield the quantity of that substance present at

the site.  The sum of the quantities of each substance would then

be calculated and used to evaluate the waste quantity factor.*

     The principal difficulty with this approach is the data

requirement.  Such analyses are rarely available as they are

difficult and hazardous to perform, as discussed in Section 4.  An

alternate approach would be to use the highest concentration of each

hazardous constituent detected in the waste instead of some parameter

of the distribution.  These concentrations would then be multiplied

by the total quantity of wastes present to yield the quantity of each

substance present.  These quantities would then be summed to form an

estimate of the total quantity of hazardous substances present.   This

approach has the advantage of relying on the highest concentration

and would, in principle, tend to be conservative (i.e.,  over estimate

the quantity and thus the risk).  However, unless a sufficient number

of samples have been taken at a sufficient number of locations,  there

is no guarantee that the highest detected concentration is greater

than the actual average concentration.  Further, both approaches

rely on the completeness of the analyses, i.e., chemical analyses
*It should be noted that this approach is potentially inconsistent
 with the current definition of the HRS waste quantity factor.   The
 HRS currently evaluates waste quantity on an "as received" basis.
 This may differ significantly due to temporal factors from the
 waste quantity indicate as being present at the time of sampling.
                                 137

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must be performed for each CERCLA hazardous substance.  This




would prove difficult in those cases where acceptable methods of




analysis do not exist.




     A final difficulty in these approaches lies in  the definition of




the factor evaluation table.  One approach would be  to transform the




existing hazardous waste quantity table  (47 FR 31180, 12 July 1982)




into a hazardous substance quantity table.  The availability of




information required to do this translation is examined in




Wusterbarth, 1986.  The possibility of employing other approaches




needs to be examined.




     As stated previously, a third option for incorporating




concentration data into a toxicity factor was examined.  In this




option, the toxicity factor would be evaluated in terms of a




concentration factor and a severity factor, as follows.  Each




contaminant would be assigned a pathway-specific toxicity benchmark




and a severity index.  The benchmark would be defined as discussed




previously while the severity index would reflect the severity of




the effects associated with exceedances  of the toxicity benchmark




for any single contaminant (evaluated, for example,  on a scale of




0  to 3).  For each contaminant at the site, the ratio of the maximum




detected contaminant concentration to the benchmark  concentration




would be determined as in the previously discussed concentration




factor.  The concentration factor would  then be evaluated using this




ratio as indicated in Table 30 (for example).  The overall toxicity
                                 138

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                   TABLE 30

      ILLUSTRATIVE CONCENTRATION FACTOR*


  Ratio (0/B)                           Factor Value

Greater than 10                              5

  1.0 - 9.99                                 4

  0.1 -  0.99                                3

 0.01 - 0.099                                2

0.001 - 0.0099                               1

Less than 0.001                              0
*Values are provided for illustrative purposes only.

B:  Benchmark concentration.
0:  Observed site concentration.
                      139

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factor value for each contaminant would then be determined for each




contaminant using Table 31 (for example).  The highest calculated




toxlcity factor value for any single contaminant present in an




observed release would be used as the site toxicity factor value (as




in the current HRS toxicity factor).  For sites lacking observed




releases, a presumptive concentration factor value of, for example,




three could be used as a default and the toxicity factor evaluated




as indicated.




     There are several potential problems with this approach that




makes its implementation unreasonable.  First, it may not be possible




to develop acceptable toxicity benchmarks for all CERCLA substances.




This problem affects the previously discussed options, as well,




although it is even more important in this option as the toxicity




factor is the major determinant of the waste characteristics




value.  Problems in defining these benchmarks include differing




benchmarks for different effects from exposures to the same




contaminants, treatment of threshold versus nonthreshold contaminant/




effect pairings, establishment of de facto acceptable risk levels




for carcinogens, and treatment of contaminants/effects pairings with




nonlinear dose response relationships.  Second, the feasibility of




defining a system for evaluating the severity of effects given




benchmark exceedances is also questionable.  The development of such




a system would encounter the difficult problems of effectively




establishing the relative worth of different types of effects, for
                                 140

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             TABLE 31




ILLUSTRATIVE TOXICITY FACTOR MATRIX






               Concentration Factor Value


Severity
Index



0

1
2
3
0
0

0
0
0
1
0

1
2
3
2
0

2
4
6
3
0

3
6
9
4
0

4
8
12
5
0

5
10
15
                141

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example, losing ones eyesight as compared with contracting cancer.




Finally, this option would place too great an emphasis on the




concentration data.  This approach relies heavily on the




representativeness of the concentration data; the weakest aspect of




the data.  No provision would be Bade for reflecting the risks




associated with possibly every toxic contaminants found at the site




that were not detected in an observed release.  Further, as with the




waste quantity factor, there would be no guarantee that the highest




detected concentration even exceeds the current, average exposure




concentration unless the data were truly representative.  In such




circumstances, the toxicity factor value would probably understate the




risks to both maximum and "average" exposed individuals.  Additionally,




as discussed previously, the present detected concentrations aay not




reflect future conditions and thus could understate (or overstate) the




risk from the site.  In total, these considerations make the adoption




of this, otherwise attractive option, scientifically questionable.




     7.3.3  Options in the Targets Category




     Two options for reflecting concentration data in the targets




category were developed.  The first is fairly simple.  All of the




current target factor tables reflect the distance from the site to the




exposed population.  One option for incorporating concentration data




would be to give added emphasis to those people who are known to be




exposed to contaminant concentrations that exceed background or




benchmarks by adjusting the values in the current MRS target distance
                                 142

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factor value matrix (as illustrated in Table 32 for the ground water




pathway).




     An alternate, more complex approach is described below.  A two-




tiered approach could be adopted in evaluating the value for exposed




population.  First, the number of people within a specified distance of




each sampling location with a concentration exceeding background and




benchmarks would be evaluated using a "currently exposed" population




factor table.  The remaining people within another, greater specified




distance of the site would be evaluated using a second, "potentially




exposed" population factor table.  The effective, per-person value




would be lower in the second table than in the first table.  The




resulting "currently exposed" and "potentially exposed" values would




be added to form the population factor value.  If the sum exceeds the




maximum for the factor (e.g., 30), the maximum factor value would be




used.  An illustrative table for this option, using the air pathway,




is presented in Table 33.  Using this example, if 350 people were




exposed to above benchmark contaminant concentrations arising from




the site, then a "currently exposed" population value of 24 would be




assigned.  If an additional 15,000 people were potentially exposed




within a radius of 4 miles, then a "potentially exposed" population




value of 21 would be assigned.  The sum of the exposed population




values (45) exceeds the maximum value (30) and therefore, a population




factor value of 30 would be assigned to the site.
                                 143

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                              TABLE 32

            ILLUSTRATIVE TABLE FOR EVALUATING POPULATION
                       (GROUND WATER PATHWAY)
Population Served
0
1-100
101-1,000
1,001-3,000
3,001-10,000
10,000+

0
0
30
35
40
40
40

2,000'
0
10
20
30
35
40
Distance
1 mile
0
8
16
24
32
35
to Nearest Well
1 mile
0
6
12
18
24
30
2-3 mile
0
4
8
12
16
20
3 mile
0
0
0
0
0
0
Adapted from 47 FR 31231 (July 16, 1982).
                                144

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                              TABLE 33

     ILLUSTRATIVE TABLES FOR EVALUATING POPULATION (AIR PATHWAY)

                    Currently Exposed Population


       Population within 1/2 mile*                   Value

                    0                                   0
                   1-10                               15
                  11-100                              18
                 101-300                              21
                 301-500                              24
                 501-1,000                            27
                  1,000+                              30
                   Potentially Exposed Population
                                      Distance to Population
                                     from Hazardous  Substance
0-4
miles
0
9
12
15
18
21
0-1
mile
0
12
15
18
21
24
0-1/2
mile
0
15
18
21
24
27
0-1/4
mile
0
18
21
24
27
30
      Population

          0
         1-100
       101-1,000
     1,001-3,000
     3,001-10,000
       10,000+
*Total number of people residiag within 1/2 mile of  any  critical
 location as well as transients such as workers in factories,  offices,
 restaurants,  motels,  or students.   Critical locations are those
 locations at which measured contaminant concentrations  exceed
 benchmarks and significantly exceed background.
                                 145

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8.0  OVERALL CONCLUSIONS AND RECOMMENDATIONS




     Several conclusions can be drawn from the previous discussion.




Concerning the quality of concentration data, the data currently




developed as part of site inspections is not of uniform quality and




is not generally of sufficient quality to support its expanded use




in the HRS.   Further, within the constraints of a preliminary




assessment (PA) and site inspection (SI) program, it is unlikely




that concentration data that is representative in space and time




could be developed for most sites.  The difficulties in developing




representative concentration data combine with resource and time




constraints  to make development of such data infeasible at many




sites.  Thus, in some cases, the concentration data developed during




site inspections would be of questionable scientific validity




overall.  While it is possible to ensure that each individual datum




is scientifically valid, generally an insufficient number of samples




will be taken to ensure overall representativeness.




     Despite these considerations, it is possible to employ




concentration data in an expanded fashion in the HRS.  However, the




limitations  of the data must be recognized and, thus, the uses of




the data must be limited accordingly.  The options discussed




previously illustrate several appropriately limited methods for




using concentration data to more accurately reflect site risks




within the framework of the HRS.
                                 147

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     The adoption of any of these options would require changes in




the PA/SI program to ensure that the concentration data at all sites




across all media meet minimum quality standards.  These changes would




include the development and distribution of uniform guidance for




preliminary assessments and site inspections.  Such guidance should




include not only guidance on site sampling, sample handling, sample




analysis, and data interpretation but should also include guidance on




the development of background information necessary to develop a valid




sampling plan.  The development of such plans should be required for




all, nonemergency, site inspections.  Selected references that could




be employed in developing such guidance are provided in Table 34.




     In order to ensure that the guidance is followed and quality




standards are maintained, a vigorous quality assurance (QA) and




quality control (QC) program should be implemented, particularly in




regard to site inspections not performed by EPA.  Such a program




would encompass not only laboratory QA and the ongoing EPA




Headquarters QA of site documentation packages, but would also




include QA/QC of:




     •  Preliminary assessment and background site information.




     •  Site sampling plans and their execution.




     *  Sampling and handling procedures.




Without such a program, the concentration data developed will be of




varying quality and will too often be of insufficient quality to




warrant its use.
                                 148

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                               TABLE 34

              GUIDANCE ON CONCENTRATION DATA DEVELOPMENT:
                    SELECTIONS FROM THE LITERATURE
Multi-Media

Berg, Edward L., Handbook for Sampling and Sample Preservation of
Water and Wastewaters, (EPA-600/4-82-029), U.S. Environmental
Protection Agency, Cincinnati, OH, September 1982.

Ford, Patrick J., Paul J. Turina, and Douglas E. Seeley,
Characterization of Hazardous Waste Sites - A Methods Manual - Volume
II;  Available Sampling Methods, Second Edition, (EPA-600/4-84-076),
U.S. Environmental Protection Agency, Las Vegas, NV, December 1984.

Ford, Patrick and Paul Turina, Characterization of Hazardous
Waste Sites - A Methods Manual - Volume I;  Site Investigations,
(EPA-600/4-84-075), U.S. Environmental Protection Agency,
Las Vegas, NV, April 1985.

Gosse, Michelle et al., Continuing Releases at RCRA Facilities
Preliminary Draft, Remedial Investigation Guidance, (WR4818), GCA
Corporation, Bedford, MA, April 1986.

U.S. Environmental Protection Agency, Test Methods for Evaluating
Solid Waste;  Physical/Chemical Methods, (SW-846), U.S. Environmental
Protection Agency, Washington, DC, May 1980.

U.S. Environmental Protection Agency, Guidance on Remedial
Investigations Under CERCLA, (EPA-540/G-85-002), U.S.  Environmental
Protection Agency, Washington, DC, June 1985.

Groundwater

Barcelona, M. J. et al., Practical Guide for Ground-Water Sampling,
(EPA-600/2-85-104), U.S. Environmental Protection Agency, Ada, OK,
September 1985.

Claassen, Hans C., Guidelines and Techniques for Obtaining Water
Samples that Accurately Represent the Water Chemistry of an Aquifer,
(Open File Report 82-1024), U.S. Geological Survey, Lakewood, CO, 1982.

Gibb, James P., Rudolph M. Schuller, and Robert A. Griffin, Procedures
for the Collection of Representative Water Quality Data from Monitoring
Wells, (ISWS/COOP-7/81), Illinois State Water Survey.  Champaign,  IL,
1981.

-------
                          TABLE 34  (Continued)


Groundwater (Concluded)

Nacht, S. J., "Monitoring Sampling Protocols," Ground Water Monitoring
Review, Vol. 3, No. 3, Summer, 1983, pp. 23-29.

Popkin, Barney P., "Guidelines for Ground-Water Quality Assessments for
Hazardous Waste Facilities," Ground Water Monitoring Review, Vol. 3,
No. 2, Spring 1983, pp. 65-70.

Scalf, Marion R. et al., Manual of Ground-Water Quality Sampling
Procedures, (EPA-600/2-81-160), U.S. Environmental Protection Agency,
Ada, OK, September 1981.

Sisk, Steven W., NEIC Manual for Groundwater/Subsurface Investigations
at Hazardous Waste Sites, (EPA-330/9-81-Q02), U.S. Environmental
Protection Agency, Denver, CO, July 1981.

U.S. Environmental Protection Agency, Procedure Manual for Ground
Water Monitoring at Solid Waste Disposal Facilities, (SW-611), U.S.
Environmental Protection Agency, Washington, DC, 1977.

U.S. Environmental Protection Agency, RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document, (Draft), (EPA-600/4-84-076),
U.S. Environmental Protection Agency, Washington, DC, August 1985.

Air

Riggin, R. M., Technical Assistance Document for Sampling and Analysis
of Toxic OrganicTompounds in Ambient Air, (EPA-600/4-83-027), U.S.
Environmental Protection Agency, Research Triangle Park, NC, June 1983.

Turpin, Rodney D., "ERT's Air Monitoring Guides for Uncontrolled
Hazardous Waste Sites," Proceedings of the Fourth National Conference
on Management of Uncontrolled Hazardous Waste Sites, Held on October 31-
November 2, 1983 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring,  MD, 1983, pp. 82-84.

U.S. Environmental Protection Agency, Field Standard Operating
Procedure for Air Surveillance, (F.S.O.P. 8), U.S. Environmental
Protection Agency, Washington, DC,  undated.

Soil

Mason, Benjamin J., Preparation of  Soil Sampling Protocol;  Techniques
and Strategies, (EPA-600/4-83-020), U.S. Environmental Protection
Agency, Las Vegas, NV, May 1983.

                                 150

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                         TABLE 34 (Concluded)
Wastes
deVera, Emil R. et al., Samplers and Sampling Procedures for Hazardous
Waste Streams, (EPA-600/2-80-018), U.S. Environmental Protection
Agency, Cincinnati, OH, January 1980.

Hanisch, R. C. and M. A. McDevitt, Protocols for Sampling and Analysis
of Surface Impoundments and Land Treatment/Disposal Sites for VOCs,
(DCN 84-222-078-11-12), Radian Corporation, Austin, TX, September 28,
1984.

Laboratory

Plumb, Russel H., Jr., Characterization of Hazardous Waste Sites - A
Methods Manual - Volume III;  Available Laboratory Analytical Methods,
(EPA-600/4-84-038), U.S. Environmental Protection Agency, Las Vegas,
NV, May 1984.

B ioassessment

Porcella, D. B., Protocol for Bioassessment of Hazardous Waste Sites,
(EPA-600/2-83-054), U.S. Environmental Protection Agency, Corvallis,
OR, July 1983.
                                 151

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9.0  REFERENCES AND BIBLIOGRAPHY

Absalon, John R. and Robert C. Starr, "Practical Aspects of Ground
Water Monitoring at Existing Disposal Sites," Proceedings of the
First National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 15-17, 1980 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1980, pp. 53-58.

Adams, William M., Stephen W. Wheatcraft, and John W. Hess,
"Downhole Sensing Equipment for Hazardous Waste Site Investigations,'
Proceedings of the Fourth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 31-November 2,
1983 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1983, pp. 108-113.

Aller, Linda et al., DRASTIC;  A Standardized System for Evaluating
Ground Water Pollution Potential Using Hydrogeologic Settings,
(EPA-600/2-85-018), U.S. Environmental Protection Agency, Ada, OK,
May 1985.

American Conference of Governmental Industrial Hygienists, Threshold
Limit Values and Biological Indices for 1985-1986, American
Conference of Governmental Industrial Hygienists, Cincinnati,  OH,
1985.

Amster, Michael B., Nasrat Hijazi, and Rosalind Chan, "Real Time
Monitoring of Low Level Air Contaminants for Hazardous Waste Sites,"
Proceedings of the Fourth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 31-November 2,
1983 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1983, pp. 98-99.

Astle, Alice D., Richard A. Duffee, and Alexander R. Stankunas,
"Estimating Vapor and Odor Emission Rates from Hazardous Waste
Sites," Proceedings of the Third National Conference on Management
of Uncontrolled Hazardous Waste Sites, Held on November 29-
December 1, 1982 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1982, pp. 326-330.

Baker, Lynton W., An Evaluation of Screening Models for Assessing
Toxic Air Pollution Downwind of Hazardous Waste Landfills, Masters
Thesis, Office of Graduate Studies and Research, San Jose State
University, San Jose, CA, May 1985.
                                 153

-------
Balfour, W. David, Bart M. Elkund, and Shelly J. Williamson,
"Measurement of Volatile Organic Emissions from Subsurface
Contaminants," Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 77-80.

Barcelona, M.J. et al., Practical Guide for Ground-Water Sampling,
(EPA-60U/2-85-104), U.S. Environmental Protection Agency, Ada, OK,
September 1985.

Barcelona, Michael J., "Chemical Problems in Ground-Water Monitoring
Programs," Proceedings of the 3rd National Symposium on Aquifer
Restoration and Ground Water Monitoring, Held on May 25-27, 1983 in
Columbus, OH, D. M. Nielsen, ed., Water Well Journal Publishing
Company, Worthington, OH, 1983, pp. 263-271.

Ben-Hur, David, James S. Smith, and Michael J. Urban, "Application
of Mobile MS/MS to Hazardous Waste Site Investigation," Proceedings
of the Fifth National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on November 7-9, 1984 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1984, pp. 53-58.

Benson, Richard C. and Robert A. Glaccum, "Site Assessment:
Improving Confidence Levels with Surface Remote Sensing,"
Proceedings of the First National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 15-17, 1980 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1980, pp. 59-65.

Benson, Richard C., Charles M. Thomas, and Lynn Yuhr, "An Approach
to Long-Term Groundwater Monitoring," Proceedings of the Sixth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 4-6, 1985 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1985,
pp. 112-115.

Benson, Richard, Robert Glaccum, and Paul Beam, "Minimizing Cost and
Risk in Hazardous Waste Site Investigations Using Geophysics,"
Proceedings of the Second National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 28-30,1981 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1981, pp. 84-88.

Berg, Edward L., Handbook for Sampling and Sample Preservation of
Water and Wastewa'ters, (EPA-600/4-82-029), U.S. Environmental
Protection Agency, Cincinnati, OH, September 1982.

                                 154

-------
Berhardt, David E., Richard 0. Gilbert, and Paul B. Hahn,
"Comparison of Soil-Sampling Techniques for Plutonium at Rocky
Flats," TRAN-STAT Statistics for Environmental Studies, Number 22,
(PNL-SA-11034, DE83005561), Richard 0. Gilbert, coordinator, Batelle
Memorial Institute Pacific Northwest Laboratory, Richland, WA,
January 1983.

Blackman, William C. et al., "Chemical Composition of Drum Samples
from Hazardous Waste Sites," Proceedings of the Fifth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 39-44.

Bruck, John M., Eugene W. Koesters, and William R. Parker, "Air
Monitoring at a Major Hazardous Waste Cleanup Site:  Objectives/
Strategy/Results," Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 72-76.

Bruehl, Donald H., Neville K. Chung, and Warren F. Diesl, "Geologic
Studies of Industrially-Related Contamination:  Soil and Ground
Water Investigations," Proceedings of the First National Conference
on Management of Uncontrolled Hazardous Waste Sites, Held on
October 15-17, 1980 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1980, pp. 78-84.

Bryan, Robert J., "Ambient Air Quality Surveillance," Air Pollution,
Third Edition Volume III Measuring, Monitoring, and Surveillance of
Air Pollution, Arthur C. Stern, ed., Academic Press, New York, NY,
1976, pp. 343-392.

Burger, Carol J. and Lawrence M. Kushner, Hazard Ranking System
Issue Analysis;  An Assessment of the HRS Target Distance Limit for
Surface Water, (MTR-86W84), The MITRE Corporation, McLean, VA,
October 1986.

Caldwell, Steven, U.S. Environmental Protection Agency, Washington,
DC, personal communications to Thomas Wolfinger, The MITRE
Corporation, 1986.

California Department of Health Services, California Air Resources
Board, and South Coast Air Quality Management District, Ambient Air
Monitoring and Health Risk Assessment for Suspect Human Carcinogens
Around the BKK Landfill in West Covina, California Department of
Health Services, March 1983.
                                 155

-------
Chang, Ruth and Robert D. Stephens, "The Application of Mass
Selective Detector for the Screening of Environmental Pollutants in
Toxic Waste," Proceedings of the Sixth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 4-6, 1985 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1985, pp. 102-106.

Claassen, Hans C., Guidelines and Techniques for Obtaining Water
Samples that Accurately Represent the Water Chemistry of an Aquifer,
(Open File Report 82-1024), U.S. Geological Survey, Lakewood, CO,
1982.

Clay, Paul F. and Thomas M. Spittler, "The Use of Portable
Instruments in Hazardous Waste Site Characterizations," Proceedings
of the Third National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on November 29-December 1,  1982 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1982, pp. 40-44.

Cook, David K., "Selection of Monitoring Well Locations in East  and
North Woburn, Massachusetts," Proceedings of the Second National
Conference on Management of Uncontrolled Hazardous Waste Sites,  Held
on October 28-30, 1981 in Washington, DC, Hazardous Materials
Control Research Institute, Silver Spring, MD, 1981, pp. 63-69.

Core, John E., Receptor Modeling Technical Series, Volume 1;
Overview of Receptor Model Application to Particulate Source
Apportionment, (EPA-450/4-81-016a), U.S. Environmental  Protection
Agency, Research Triangle Park, NC, July 1981.

Cox, Robert D., Kenneth J. Baughman,  and Ronald F. Earp, "A
Generalized Screening and Analysis Procedure for Organic Emissions
from Hazardous Waste Disposal Sites," Proceedings of the Third
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 29-December 1, 1982 in Washington,  DC,
Hazardous Materials Control Research Institute, Silver  Spring, MD,
1982, pp. 58-62.

Crawley, W. W., R. L. Shiver, and D.  C. Anderson,  "In Situ Sampling
of Hazardous Waste Surface Impoundments," Proceedings of the  Sixth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 4-5, 1985 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1985,
pp. 80-83.

Cullis, C. F. and J. G. Firth, Detection and Measurement of
Hazardous Gases, Heinemann, London, 1981.
                                 156

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Dawson, Gaynor W., Jill M. Meuser, and Mary C. Lilga, Dioxin
Transport form Contaminated Sites to Exposure Locations;  A
Methodology for Calculating Conversion Factors, (EPA-600/8-85-012),
U.S. Environmental Protection Agency, Washington, DC, June 1985.

deVera, Emil R. et al., Samplers and Sampling Procedures for
Hazardous Waste Steams, (EPA-600/2-80-018), U.S. Environmental
Protection Agency, Cincinnati, OH, January 1980.

Devary, Joseph L. and Ronald Schalla, "Improved Methods of Flow
System Characterization," Proceedings of the Fourth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on October 31-November 2, 1983 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1983,
pp. 117-122.

Di Nitto, Richard G., William R. Norman, and M. Margret Hanley, "An
Approach to Investigating Groundwater Contaminant Movement in
Bedrock Aquifers:  Case Histories," Proceedings of the Third
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 29-December 1, 1982 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1982, pp. 111-117.

Driscoll, Fletcher G., Groundwater and Wells Second Edition, Johnson
Division, St. Paul, MN, 1986.

Driscoll, J. N., A. G. Wilshire, and I. W. Bodenrader, "New
Continuous Monitoring Systems for Measurement of Hazardous
Pollutants," Proceedings;  National Symposium on Recent Advances in
Pollutant Monitoring of Ambient Air and Stationary Sources, (EPA-600/
9-84-019), Held on May 8-10, 1984 in Raleigh, NC, U.S. Environmental
Protection Agency, Research Triangle Park, NC, November 1984,
pp. 91-95.

Duvel, William A., "Practical Interpretation of Groundwater
Monitoring Results," Proceedings of the Third National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 29-December 1, 1982 in Washington, DC, Hazardous Materials
Control Research Institute, Silver Spring, MD, 1982, pp. 86-90.

Ehrenfeld, John and Jeffery Bass, Handbook for Evaluating Remedial
Action Technology Plans, (EPA-600/2-83-076), U.S. Environmental
Protection Agency, Washington, DC, August 1983.
                                 157

-------
Engels, J. L. et al., "Survey of Mobile Laboratory Capabilities and
Configurations," Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 45-48.

Evans, R. B., R. C. Benson, and J. Rizzo, "Systematic Hazardous
Waste Site Assessments," Proceedings of the Third National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 29-December 1, 1982 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1982,
pp. 17-22.

Everett, L. G. et al., Monitoring Groundwater Quality;  Methods and
Costs, (EPA-600/4-76-023), U.S. Environmental Protection Agency, Las
Vegas, NV, May 1976.

Everett, L. G. et al., "Vadose Zone Monitoring Concepts at
Landfills, Impoundments, and Land Treatment Disposal Areas,"
Proceedings of the Third National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 29-December 1,
1982 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1982, pp. 100-106.

Everett, L. G., L. G. Wilson, and E. W. Hoylman, Vadose Zone
Monitoring for Hazardous Waste Sites, (EPA-600/X-83-064), U.S.
Environmental Protection Agency, Las Vegas, NV, October, 1983.

Everett, Lome, Groundwater Monitoring, General Electric Company,
Schenectady, NY, 1980.

Everett, Lorne G., "Monitoring in the Zone of Saturation," Ground
Water Monitoring Review, Vol. 1, No. 1, Spring 1981, pp. 38-41.

Farthing, William E., "Particle Sampling and Measurement,"
Environmental Science and Technology, Vol. 16, No. 4, April 1982,
pp. 237A-244A.

Fellows, Charles R. and James H. Sullivan, "Refined Strategies for
Abandoned Site Discovery and Assessment," Proceedings of the Fourth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on October 31-November 2, 1983 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1983, pp. 37-42.

Fetter, C. W., "Potential Sources of Contamination in Ground-Water
Monitoring," Ground Water Monitoring Review, Vol. 3, No. 2, Spring
1983, pp. 60-64.

                                 158

-------
Fitzgerald, Jerry M., Hazard Ranking System Issue Analysis:
Laboratory Limits of Detection, (MTR-86W77), The MITRE Corporation,
McLean, VA, July 1986.

Flatman, George T., "Using Geostatistics in Assessing Lead
Contamination Near Smelters," Environmental Sampling for Hazardous
Wastes, (ACS Symposium Series 267), Glenn E. Schweitzer and John A.
Santolucito, eds., American Chemical Society, Washington, DC, 1984,
pp. 43-52.

Ford, Karl and Paul Gurba, "Health Risk Assessments for Contaminated
Soils," Proceedings of the Fifth National Conference on Management
of Uncontrolled Hazardous Waste Sites, Held on November 7-9, 1984 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1984, pp. 230-231.

Ford, Patrick J., Paul J. Turina, and Douglas E. Seeley,
Characterization of Hazardous Waste Sites - A Methods Manual -
Volume II;  Available Sampling Methods, Second Edition, (EPA-600/
4-84-076), U.S. Environmental Protection Agency, Las Vegas, NV,
December 1984.

Ford, Patrick and Paul Turina, Characterization of Hazardous Waste
Sites - A Methods Manual - Volume I:  Site Investigations, (EPA-600/
4-84-075), U.S. Environmental Protection Agency, Las Vegas, NV,
April 1985.

Friedman, Paul H. and Duane Geuder, "Quality Control Attributes of
Process Analytical Data," Proceedings of the Fifth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 29-34.

Furst, George A., Valerie Tillinghast, and Thomas Spittler,
"Screening for Metals at Hazardous Waste Sites:  A Rapid Cost-
Effective Technique Using X-Ray Fluorescence," Proceedings of the
Sixth National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on November 4-6, 1985 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1985,
pp. 93-96.

GCA Corporation, Guidelines for Air Quality Maintenance and
Analysis.  Volume 11;  Air Quality Monitoring and Data Analysis,
(EPA-450/4-74-012), U.S. Environmental Protection Agency, Research
Triangle Park, NC, September 1974.
                                 159

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Geraghty and Miller, Inc. and American Ecology Services, Inc., The
Fundamentals of Ground-Water Contamination, Geraghty and Miller,
Inc., Tampa, FL, 1985.

Gerstein, Robert E., Hazard Ranking System Issue Analysis;
Geohydrology, (MTR-86W62), The MITRE Corporation, McLean, VA,
October 1986.

Gibb, James P., Rudolph M. Schuller, and Robert A. Griffin,
Procedures for the Collection of Representative Water Quality Data
from Monitoring Wells, (ISWS/COOP-7/81), Illinois State Water
Survey, Champaign, IL, 1981.

Gilbert, Richard 0., "Field Sampling Designs, Simple Random and
Stratified Random Sampling," IRAN-STAT  Statistics for Environmental
Studies, Number 24, (PNL-SA-11551, DE83016826), Richard 0. Gilbert,
coordinator, Batelle Memorial Institute Pacific Northwest
Laboratory, Richland, WA, August 1983.

Gilbert, Richard 0., "Field Sampling Designs:  Systematic Sampling,"
TRAN-STAT  Statistics for Environmental Studies, Number 26,
(PNL-SA-12180, DE84-008651), Richard 0. Gilbert, coordinator,
Batelle Memorial Institute Pacific Northwest Laboratory, Richland,
WA, April 1984.

Gillham, R. W. et al., Groundwater Monitoring and Sample Bias, (API
Publication 4367), American Petroleum Institute, Washington, DC,
June 1983.

Gilkeson, Robert H. and Keros Cartwright, "The Application of
Surface Electrical and Shallow Geothermic Methods in Monitoring
Network Design," Ground Water Monitoring Review, Vol. 3, No. 3,
Summer 1983, pp. 30-42.

Glaccum, Robert A., Richard C. Benson, and Michael R. Noel,
"Improving Accuracy and Cost-Effectiveness of Hazardous Waste Site
Investigations," Ground Water Monitoring Review, Vol. 2, No. 3,
Summer 1982, pp. 36-40.

Gleit, Alan, "Estimation for Small Normal Data Sets with Detection
Limits," Environmental Science and Technology, Vol. 19, No. 12,
December 1985, pp. 1201-1206.

Gosse, Michelle et al., Continuing Releases at RCRA Facilities
Preliminary Draft, Remedial Investigation Guidance, (WR4818), GCA
Corporation, Bedford, MA, April 1986.
                                 160

-------
Gruenfeld, Michael et al., "Management of Analytical Laboratory
Support at Uncontrolled Hazardous Waste Sites," Proceedings of the
Second National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 28-30, 1981 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1981,
pp. 96-102.

Gurka, D. F. et al., "Analytical and Quality Control Procedures for
the Uncontrolled Hazardous Waste Sites Contract Program," Proceedings
of the Third National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on November 29-December 1,  1982 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1982, pp. 45-51.

Hagger, Christopher and Paul F. Clay, "Hydrogeological  Investigation
of an Uncontrolled Hazardous Waste Site," Proceedings of the Second
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on October 28-30, 1981 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1981,
pp. 45-51.

Hanisch, R. C. and M. A. McDevitt, Protocols for Sampling and
Analysis of Surface Impoundments and Land Treatment/Disposal Sites
for VOCs, (DCN 84-222-078-11-12), Radian Corporation, Austin, TX,
September 28, 1984.

Harman, H. Dan, Jr., "Detailed Stratigraphic and Structural Control:
The Keys to Complete and Successful Geophysical Surveys of Hazardous
Waste Sites," Proceedings of the National Conference on Hazardous
Wastes and Hazardous Materials, Held on March 4-6, 1986 in Atlanta,
GA, Hazardous Materials Control Research Institute, Silver Spring,
MD, 1986, pp. 19-21.

Harman, H. Dan, Jr. and Shane Hitchcock, "Cost Effective Preliminary
Leachate Monitoring at an Uncontrolled Hazardous Waste  Site,"
Proceedings of the Third National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 29-December 1,
1982 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1982, pp. 97-99.

Harrison, Roy M., Recent Advances in Air Pollution Analysis,
University of Lancaster, Lancaster, England, undated.

Hatayama, Howard K., "Special Sampling Techniques Used  for
Investigating Uncontrolled Waste Sites in California,"  Proceedings of
the Second National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 28-30, 1981 in Washington. DC. Hazardous
Materials Control Research Institute, Silver Spring, MD, 1981,
pp. 149-153.
                                 161

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Ho, J. S-Y, "Effect of Sampling Variables on Recovery of Volatile
Organics in Water," Journal of the American Water Works Association,
December 1983, pp. 583-586.

Holdren, M. W., D. L. Smith, and R. N. Smith, Comparison of Ambient
Air Sampling Techniques for Volatile Organic Compounds,(EPA-600/
4-85-067), U.S. Environmental Protection Agency, Research Triangle
Park, NC, October 1985.

Hwang, Jack C. et al., "Feasibility Studies of Groundwater Pollution
Source Identification from Actual Field Monitoring Well Data,"
Proceedings of the Fifth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 7-9,  1984 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1984, pp. 1-5.

Hwang, Seong T., "Statistical Considerations in Groundwater
Monitoring," Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 346-349.

laccarino, T. et al., "A Superfund Site Atmospheric Study:
Application to Remedial Response Decision-Making," Proceedings of
the Fifth National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on November 7-9, 1984 in Washington,  DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1984, pp. 66-67.

Isaacson, Peter J., William P. Eckel, and John F. Fisk, "Low
Occurrence Compounds:  Analytical Problem or Environmental
Process?," Proceedings of the Sixth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 4-6, 1985 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1985, pp. 130-135.

Jacot, Brian J., "OVA Screening at a Hazardous Waste Site,"
Proceedings of the Fourth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 31-November 2,
1983 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1983, pp. 76-78.

Janisz, Amelia A. and W. Scott Butterfield, "Biological Sampling at
Abandoned Hazardous Waste Sites," Proceedings of the Third National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 29-December 1, 1982 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1982,
pp. 52-56.

                                 162

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Johnson, Michael G., "The Stratified Sample Thief - A Device for
Sampling Unknown Fluids," Proceedings of the Second National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on October 28-30, 1981 in Washington, DC, Hazardous Materials
Control Research Institute, Silver Spring, MD, 1981,  pp. 154-157.

Journel, Andre G., "New Ways of Assessing Spatial Distributions of
Pollutants," Environmental Sampling for Hazardous Wastes, (ACS
Symposium Series 267), Schweitzer, Glenn E. and John A. Santolucito,
eds., American Chemical Society, Washington, DC, 1984, pp. 109-118.

JRB Associates, Remedial Action Costing Procedures Manual, (Draft),
U.S. Environmental Protection Agency, Cincinnati, OH, September 1985.

K. B. Brown and Associates, Inc., Hazardous Waste Land Treatment,
(SW-874), U.S. Environmental Protection Agency, Washington,  DC,
September 1980.

Kaczmar, Swiatoslav, Edwin C. Tifft, Jr., Cornelius B. Murphy, Jr.,
"Site Assessment Under CERCLA:  'The Importance of Distinguishing
Hazard from Risk'," Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 221-225.

Katz, Morris, "Advances in the Analysis of Air Contaminants,"
Journal of the Air Pollution Control Association, Vol. 30, No. 5,
May 1980, pp. 528-557.

Kazmann, R. G., "An Introduction to Ground-Water Monitoring," Ground
Water Monitoring Review, Vol. 1, No. 1, Spring 1981,  pp. 28-29.

Keith, Lawrence H. et al., "Principles of Environmental Analysis,
Analytical Chemistry, Vol. 55, 1983, pp. 2210-2218.

Keith, Susan J. et al., "Dealing with the Problem of Obtaining
Accurate Ground-Water Quality Analytical Results," Proceedings of
the 3rd National Symposium on Aquifer Restoration and Ground Water
Monitoring, Held on May 25-27, 1983, in Columbus, OH, D. M.  Nielsen,
ed., Water Well Journal Publishing Company, Worthington, OH, 1983a,
pp. 272-283.

Keith, Susan J. et al., "Sources of Spatial-Temporal Variability in
Ground Water Quality Data and Methods of Control," Ground Water
Monitoring Review, Vol. 3, No. 2, Spring 1983b, pp. 21-32.
                                 163

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Kerfoot, H. B., J. A. Kohout, and E. N. Amick, "Detection and
Measurement of Groundwater Contamination by Soil-Gas Analysis,"
Proceedings of the National Conference on Hazardous Wastes and
Hazardous Materials, Held on March 4-6, 1986 in Atlanta, GA,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1986, pp. 22-26.

Kirchmer, Cliff J., "Quality Control in Water Analyses,"
Environmental Science and Technology, Vol. 17, No. 4, 1983,
pp. 174A-181A.

Kirchmer, Cliff J., Margaret C. Winter, and Barbara A. Kelly,
"Factors Affecting the Accuracy of Quantitative Analyses of Priority
Pollutants Using GC/MS," Environmental Science and Technology,
Vol. 17, No. 7, 1983, pp. 396-4U1.

Kolb, Sean, U.S. Environmental Protection Agency, Washington, DC,
personal communication to Thomas Wolfinger, The MITRE Corporation,
September 1986.

Kolybe, Albert C., Jr., "The Need for Accuracy in a Regulatory
Agency," Accuracy in Trace Analysis:  Sampling, Sample Handling,
Analysis - Volumes I and II, (NBS Special Publication 422),
D. Philip LaFleur, ed., National Bureau of Standards, Gaithersburg,
MD, 1974, pp. 3-8.

LaFleur, Philip D., ed., Accuracy in Trace Analysis;  Sampling,
Sample Handling, Analysis - Volumes I and II, (NBS Special
Publication 422), Proceedings of the 7th Material Research
Symposium, Held on October 7-11, 1987 in Gaithersburg, MD, National
Bureau of Standards, Gaithersburg, MD, 1974.

Lappala, Eric G. and Glenn M. Thompson, "Detection of Groundwater
Contamination by Shallow Soil Gas Sampling in the Vadose Zone Theory
and Applications, " Proceedings of the Fifth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 7-9, 1984 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 20-28.

Liggett, Walter, "Detecting Elevated Contamination by Comparisons
with Background," Environmental Sampling for Hazardous Wastes, (ACS
Symposium Series 267), Glenn E. Schweitzer and John A. Santolucito,
eds., American Chemical Society, Washington, DC, 1984, pp. 119-128.

Lipsky, David and Brian Jacot, "Hazardous Emissions from Sanitary
Landfills," Proceedings for the 78th Annual Meeting of the Air
Polluation Control Association, Held on June 16-21, 1985 in Detroit,
MI, Air Pollution Control Association, Pittsburgh, PA, 1985.

                                 164

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Liu, M. K. and J. Arvin, Methodology for the Design of an Optimal Air
Quality Monitoring Network, (EPA-600/4-81-002), U.S. Environmental
                               alogy
                               V-600/
Protection Agency, Las Vegas, NV, February 1981.
Liu, M. K. et al., "Methodology for Designing Air Quality Networks:
I Theoretical Aspects," Environmental Monitoring and Assessment,
Vol. 6, 1986, pp. 1-11.

Lodge, James P., Jr., "Accuracy in Air Sampling," Accuracy in Trace
Analysis;  Sampling, Sample Handling, Analysis - Volumes I and II,
(NBS Special Publication 422), Philip D. LaFleur, ed., National
Bureau of Standards, Gaithersburg, MD, 1974, pp. 311-320.

Mack, James P. and Thomas J. Morahan, "Equipment for Data Collection
at Hazardous Waste Sites - An Overview for Environmental Management
Professionals," Proceedings of the National Conference on Hazardous
Wastes and Hazardous Materials, Held on March 4-6, 1986 in Atlanta,
GA, Hazardous Materials Control Research Institute, Silver Spring,
MD, 1986, pp. 1-7.

Mason, Benjamin J., Preparation of Soil Sampling Protocol;
Techniques and Strategies, (EPA-600/4-83-020), U.S. Environmental
Protection Agency, Las Vegas, NV, May 1983.

McKee, C. R. and A. C. Bumb, "The Importance of Unsaturated Flow
Parameters in Designing a Monitoring System for a Hazardous Waste
Site," Proceedings of the National Conference on Hazardous Wastes
and Environmental Emergencies, Held on March 12-14, 1984 in Houston,
TX, Hazardous Materials Control Research Institute, Silver Spring,
MD, 1984, pp. 50-58.

McKown, Gary L., Ronald Schalla, and C. Joseph English, "Effects of
Uncertainties of Data Collection on Risk Assessment," Proceedings of
the Fifth National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on November 7-9, 1984 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1984,
pp. 283-286.

Mernitz, Scott, Roger Olsen, and Ken Staible, "Use of a Portable
X-Ray Analyzer and Geostatistical Methods to Detect and Evaluate
Hazardous Metals in Mine/Mill Tailings," Proceedings of the Sixth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 4-6, 1985 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1985,
pp. 107-111.
                                 165

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Mooney, Gregory A. and Russell W. Bartley, "Characterization of
Organic Wastes for Evaluation of Remedial Action Alternatives,"
Proceedings of the Fifth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 7-9, 1984 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1984, pp. 35-38.

Moore, Stephen F. and Dennis B. Mclaughlin, "Mapping Contaminated
Soil Plumes by Kriging," Proceedings of the First National Conference
on Management of Uncontrolled Hazardous Waste Sites, Held on
October 15-17, 1980 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1980, pp. 66-70.

Moss, M. E. and G. D. Tasker, "Progress in the Design of Hydrologic-
Data Networks," Reviews of Geophysics and Space Physics, Vol.  17,
No. 6, September 1979, pp. 1298-1307.

Morin, Joanne O'Neill, "Development and Application of an Analytical
Screening Program to Superfund Activities," Proceedings of the Sixth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 4-6, 1985 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1985,
pp. 97-101.

Moylan, Craig A., "Hazardous Materials Training for First Responders:
Concepts and Future Needs," Proceedings of the Sixth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 4-6, 1985 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1985, pp. 71-73.

Myers, Jeffrey C., "Objective Quantification of Sampling Adequacy and
Soil Contamination Levels Around Point Sources Using Geostatistics,"
Proceedings of the National Conference on Hazardous Wastes and
Hazardous Materials, Held on March 4-6, 1986 in Atlanta, GA,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1986, pp. 92-97.

Nacht, S. J., "Monitoring Sampling Protocols," Ground Water
Monitoring Review, Vol. 3, No. 3, Summer 1983, pp. 23-29.

Nadeau, Royal J. et al., "Measuring Soil Vapors for Defining
Subsurface Contaminant Plumes," Proceedings of the Sixth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on November 4-6, 1985 in Washington, DC, Hazardous Materials Contro1
Research Institute, Silver Spring, MD, 1985, pp. 128-129.
                                 166

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Nazar, Andrzej, James Prieur, and Daniel Threlfall,  "An Integrated
Ground Water Monitoring Program Using Multilevel Gas-Driven Sampler
and Conventional Monitoring Wells," Ground Water Monitoring Review,
Vol. 4, No. 4, Fall 1984, pp. 43-47.

Nelson, James D. and Robert C. Ward, "Statistical Considerations and
Sampling Techniques for Ground-Water Quality Monitoring, Ground
Water, Vol. 19, No. 6, November-December 1981,  pp. 617-625.

Oppenheimer, J. A., A. D. Eaton, and L. Y. C. Leong,  Multielement
Analytical Techniques for Hazardous Waste Analysis;   The State-of-
the Art. (EPA-600/4-64-028), U.S. Environmental Protection Agency.
Las Vegas, NV, April 1984.

Pellizzari, Edo D., Measurement of Carcinogenic Vapors in Ambient
Atmospheres, (EPA-600/7-78-062), U.S. Environmental Protection
Agency, Research Triangle Park, NC, April 1978.

Perazzo, James A., Richard C. Dorrler, and James P.  Mack, "Long-Term
Confidence in Ground Water Monitoring Systems," Ground Water
Monitoring Review, Vol. 4, No. 4, Fall 1984, pp. 119-123.

Peters, James A., Keith M. Tackett, and Edward C. Eimutis,
"Measurement of Fugitive Hydrocarbon Emissions from a Chemical Waste
Disposal Site," Proceedings of the Second National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
October 28-30, 1981 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1981, pp. 123-128.

Plumb, Russel H., Jr., Characterization of Hazardous Waste Sites -
A Methods Manual - Volume III:  Available Laboratory Analytical
Methods, (EPA-60Q/4-84-U38J, U.S. Environmental Protection Agency,
Las Vegas, NV, May 1984.

Popkin, Barney P., "Guidelines for Ground-Water Quality Assessments
for Hazardous Waste Facilities," Ground Water Monitoring Review,
Vol. 3, No. 2, Spring 1983, pp. 65-70.

Porcella, D. B., Protocol for Bioassessment of Hazardous Waste
Sites, (EPA-600/2-83-054), U.S. Environmental Protection Agency,
Corvallis, OR, July 1983.

Possin, Boyd N., "Groundwater Systems and Hazardous Wastes Sites - A
Basic Conceptual Framework," Proceedings of the Fourth National
Conference on Management of Uncontrolled Hazardous Waste Sites, Held
on October 31-November 2, 1983 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1983,
pp. 114-116.

                                 167

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Powell, David H. et al., "Use of Detector Ratios for Contaminant
Screening by High-Pressure Liquid Chromatography," Proceedings  of
the Fourth National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on October 31-November 2, 1983  in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1983, pp. 86-93.

Priznar, Francis J. and Lucy P. Sibold, "Site Inspection Sampling
Strategy to Support the Hazard Ranking System Scoring," Proceedings
of the Sixth National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on November 4-6, 1985 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1985, pp. 74-79.

Provost, Lloyd P., "Statistical Methods in Environmental Sampling,"
Environmental Sampling for Hazardous Wastes, (ACS Symposium
Series 267), Gleen E. Schweitzer and John A. Santolucito, eds.,
American Chemical Society, Washington, DC, 1984, pp. 79-96.

Quimby, Jay M., Robert W. Cibulskis, and Michael Gruenfeld,
"Evaluation and Use of a Portable Gas Chromatograph for Monitoring
Hazardous Waste Sites," Proceedings of the Third National Conference
on Management of Uncontrolled Hazardous Waste Sites, Held on
November 29-December 1, 1982 in Washington, DC, Hazardous Materials
Control Research Institute, Silver Spring, MD, 1982, pp. 36-39.

Quinn, Kenneth J., Steven G. Wittmann, and R. Damon Lee, "Use of
Soil Gas Sampling Techniques for Assessment of Groundwater
Contamination," Proceedings of the Sixth National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 4-6, 1985 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1985, pp. 157-163.

Rhodes, Raymond C. and E. Gardner Evans, Precision and Accuracy
Assessments for State and Local Air Monitoring Networks, (EPA-600/
4-86-012), U.S. Environmental Protection Agency, Research Triangle
Park, NC, February 1986.

Riggin, R. M., Technical Assistance Document for Sampling and
Analysis of Toxic Organic Compounds in Ambient Air,(EPA-600/
4-83-027), U.S. Environmental Protection Agency, Research Triangle
Park, NC, June 1983.

Ritzert, C. John, "Sampling Plan Design for Hazardous Wastes,"
Proceedings of the National Conference on Hazardous Wastes  and
Environmental Emergencies, Held on March 12-14, 1984 in Houston, TX,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1984, pp. 141-145.
                                 168

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Rogoff, Marc J., Summary of EPA Symposium on Land Disposal of
Hazardous Waste, (WP-81W406), The MITRE Corporation, McLean, VA,
July 31, 1981.

Russell, Sue, National Priorities List Quality Assurance Team, The
MITRE Corporation, McLean, VA, personal communications to Thomas
Wolfinger, The MITRE Corporation, 1986.

Ryan, Robert M., "Texas Experience in Ambient Air Sampling for Toxic
Wastes," Proceedings of the Sixth National Conference on Management
of Uncontrolled Hazardous Waste Sites, Held on November 4-6, 1985 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1985, pp. 125-127.

Sachs, Lothar, Applied Statistics;  A Handbook of Techniques,
Springer-Verlag, New York, NY, 1982.

Sayers, William T. and Wayne R. Ott, "Use and Interpretation of
Water Quality Data," Accuracy in Trace Analysis;  Sampling, Sample
Handling, Analysis - Volumes I and II, (NBS Special Publication
422), Philip D. LaFleur, ed., National Bureau of Standards,
Gaithersburg, MD, 1974, pp. 91-107-

Scalf, Marion R. et al., Manual of Ground-Water Quality Sampling
Procedures, (EPA-600/2-81-160), U.S. Environmental Protection
Agency, Ada, OK, September 1981.

Schmidt, Charles E., W. David Balfour, and Robert D. Cox, "Sampling
Techniques for Emissions Measurements at Hazardous Waste Sites,"
Proceedings of the Third National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 29-December 1,
1982 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1982, pp. 334-339.

Schmidt, Charles E. and M. W. Eltgroth, "Off-Site Assessment of
Air Emissions from Hazardous Waste Disposal Facilities," Proceedings
of the Fourth National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on October 31-November 2, 1983 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1983, pp. 293-295.

Schuller, Rudolph M., James P- Gibb, and Robert A. Griffin,
"Recommended Sampling Procedures for Monitoring Wells," Ground Water
Monitoring Review, Vol. 1, No. 1, Spring 1981, pp. 42-46.
                                 169

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Schweitzer, Glenn E., "Risk Assessment Near Uncontrolled Hazardous
Waste Sites:  Role of Monitoring Data," Proceedings of the Second
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on October 28-30, 1981 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1981,
pp. 238-247.

Schweitzer, Glenn E. and Stuart C. Black, "Monitoring Statistics"
Environmental Science and Technology, Vol. 19, No. 11, November 1985,
pp. 1026-1030.

Schweitzer, Glenn E. and John A. Santolucito, eds., Environmental
Sampling for Hazardous Wastes, (ACS Symposium Series 267), American
Chemical Society, Washington, DC, 1984.

Seanor, Arthur M., Anna L. Pisano, and Larry K. Brannaka, "Quality
Assurance to Assure Quality of Field Sampling," Proceedings of
the National Conference on Hazardous Wastes and Environmental
Emergencies, Held on March 12-14, 1984 in Houston, TX, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1984,
pp. 123-128.

Seanor, Arthur M. and Larry K. Brannaka, "Influence of Sampling
Techniques on Organic Water Quality Analysis," Proceedings of the
Second National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 28-30, 1981 in Washington,  DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1981, pp. 143-148.

Sgambat, Jeffrey and Jery R. Stedinger, "Confidence in Ground-Water
Monitoring, Ground Water Monitoring Review, Vol. 1, No.  1, Spring
1981, pp. 62-69.

Sherwani, Jabbar and David H. Moreau, Strategies for Water Quality
Monitoring, (UNC-WRRI-75-107), University of North Carolina Water
Resources Research Institute, June 1975.

Singh, Udai P. et al., "Sampling the Biscayne Aquifer for Toxic
Pollutants," Proceedings of the Second Conference on Management of
Municipal, Hazardous, and Coal Wastes, (DOE/METC-84-34), Held on
December 5, 1983, in Miami, FL, U.S. Department of Energy,
Washington, DC, September 1984, pp. 422-431.

Sisk, Steven W., NEIC Manual for Groundwater/Subsurface
Investigations at Hazardous Waste Sites, (EPA-330/9-81-002),
U.S. Environmental Protection Agency, Denver, CO, July 1981.
                                 170

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Smart, Glenn R. and David K. Cook, "The Design of Monitoring Well
Systems to Meet RCRA Requirements," Proceedings of the National
Conference on Hazardous Wastes and Environmental Emergencies, Held
on March 12-14, 1984 in Houston, TX, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1984, pp. 68-71.

Spear, Richard and Peter Franconeri, "Installing Groundwater
Monitoring Wells at a Hazardous Waste Site," Proceedings of the
Second National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 28-30, 1981 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1981, pp. 89-95.

Spittler, Thomas M., "Field Measurements of PCB's in Soil and
Sediment Using a Portable Gas Chromatograph," Proceedings of the
Fourth National Conference on Management of Uncontrolled Hazardous
Waste Sites, Held on October 31-November 2, 1983 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1983, pp. 105-107.

Spittler, Thomas M., Richard Siscanaw, and Moira Lataille,
"Correlation Between Field GC Measurements of Volatile Organics and
Laboratory Confirmation of Collected Field Samples Using the GC/MS
Extended Abstract," Proceedings of the Third National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on
November 29-December 1, 1982 in Washington, DC, Hazardous Materials
Control Research Institute, Silver Spring, MD, 1982, p. 57.

Stephens, Robert D., "The Stringfellow Industrial Waste Disposal
Site:  A Technical Assessment of Environmental Impact,"  Proceedings
of the First National Conference on Management of Uncontrolled
Hazardous Waste Sites, Held on October 15-17, 1980 in Washington,
DC, Hazardous Materials Control Research Institute, Silver Spring,
MD, 1980, pp. 15-20.

Stern, Arthur C., ed., Air Pollution, Third Edition Volume III
Measuring, Monitoring, and Surveillance of Air Pollution, Academic
Press, New York, NY, 1976.

Stetter, J. R. et al., "Portable Instrument for the Detection and
Identification of Air Pollutants," Proceedings;  National Symposium
on Recent Advances in Pollutant Monitoring of Ambient Air and
Stationary Sources, (EPA-600/9-84-019), Held on May 8-10, 1984 in
Raleigh, NC, U.S. Environmental Protection Agency, Research Triangle
Park, NC, November 1984, pp. 73-81.
                                 171

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Stevens, Robert K., Sampling and Analysis of Atmospheric Aerosols,
Presented at the Advanced Research Workshop on Environmental Monitoring
of Architectural Conservation, Rome, Italy, June 11-14, 1984.

Sullivan, David A. and Jerome B. Strauss, "Air Monitoring of a
Hazardous Waste Site," Proceedings of the Second National Conference
on Management of Uncontrolled Hazardous Waste Sites, Held on
October 28-30, 1981 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1981, pp. 136-142.

Swaroop, R. and 0. S. Ghuman, "Subsampling of Hazardous Waste,"
Proceedings of the Fifth National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 7-9, 1984 in
Washington, DC, Hazardous Materials Control Research Institute, Silver
Spring, MD, 1984, pp. 90-93.

Thibodeaux, Louis J. et al., "Air Emission Monitoring of Hazardous
Waste Sites," Proceedings of the Third National Conference on
Management of Uncontrolled Hazardous Waste Sites, Held on November 29-
December 1, 1982 in Washington, DC, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1982, pp. 70-75.

Thomas, John M., "Field Sampling for Monitoring, Migration and Defining
the Areal Extent of Chemical Contamination," Proceedings of the Fifth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 7-9, 1984 in Washington, DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1984,
pp. 85-89.

Tirsch, F. S. and J. W. Male, River Basin Water Quality Monitoring
Design, (Water Resources Research Center Publication Number 141),
Massachusetts University, Amherst, MA, March 1983.

Todd, David K. et al., Monitoring Groundwater Quality;  Monitoring
Methodology, (EPA-600/4-7b-026), U.S. Environmental Protection Agency,
Las Vegas, NV, June 1976.

Townsend, Richard W., "Air Monitoring of Hazardous Waste Sites,"
Proceedings of the Third National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on November 29-December 1,
1982 in Washington, DC, Hazardous Materials Control Research
Institute, Silver Spring, MD, 1982, pp. 67-69.

Tucker, William A. and Carolyn Poppell, "Method for Determining
Acceptable Levels of Residual Soil Contamination," Proceedings of the
National Conference on Hazardous Wastes and Hazardous Materials, Held
on March 4-6, 1986 in Atlanta, GA, Hazardous Materials Control
Research Institute, Silver Spring, MD, 1986, pp. 87-91.

                                 172

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Turpin, Rodney D., "ERT's Air Monitoring Guides for Uncontrolled
Hazardous Waste Sites," Proceedings of the Fourth National
Conference on Management of Uncontrolled Hazardous Waste Sites,  Held
on October 31-November 2, 1983 in Washington,  DC, Hazardous
Materials Control Research Institute, Silver Spring, MD, 1983,
pp. 82-84.

Turpin, Rodney D., "On-Site Air Monitoring Classification by Use of
the ERT Two-Stage Collection Tube," Proceedings of the Fourth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on October 31-November 2, 1983 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1983, pp. 85.

U.S. Environmental Protection Agency, Ambient Air Monitoring
Guidelines for Prevention of Significant Deterioration (PSD),
(EPA-450/4-80-012), U.S. Environmental Protection Agency, Researeh
Triangle Park, NC, November 1980a.

U.S. Environmental Protection Agency, Enforcement Considerations for
Evaluations of Uncontrolled Hazardous Waste Disposal Sites, U.S.
Environmental Protection Agency, Denver, CO, April 1980b.

U.S. Environmental Protection Agency, Field Standard Operating
Procedure for Air Surveillance, (F.S.O.P. 8),  U.S. Environmental
Protection Agency, Washington, DC, undated.

U.S. Environmental Protection Agency, Guidelines;  Air Quality
Surveillance Networks, (AP-98), U.S. Environmental Protection
Agency, Research Triangle Park, NC, May 1971.

U.S. Environmental Protection Agency, Guidance for Air Quality
Monitoring Network Design and Instrument Siting (Revised), (Draft,
OAQPS Number 1.2-012), U.S. Environmental Protection Agency,
Research Triangle Park, NC, September 1975.

U.S. Environmental Protection Agency, Guidance on Remedial
Investigations Under CERCLA, (EPA-540/G-85-002), U.S. Environmental
Protection Agency, Washington, DC, June 1985a.

U.S. Environmental Protection Agency, Procedure Manual for Ground
Water Monitoring at Solid Waste Disposal Facilities, (SW-611), U.S.
Environmental Protection Agency, Washington, DC, 1977.
                                 173

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U.S. Environmental Protection Agency, Proceedings;  National
Symposium on Recent Advances in Pollutant Monitoring of Ambient Air
and Stationary Sources, (EPA-600/9-84-019), Held on May 8-10, 1984
in Raleigh, NC, U.S. Environmental Protection Agency, Research
Triangle Park, NC, November 1984.

U.S. Environmental Protection Agency, RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document, (Draft), (EPA-600/4-84-076),
U.S. Environmental Protection Agency, Washington, DC, August 1985b.

U.S. Environmental Protection Agency, Resource Document for the
Ground-Water Monitoring Strategy Workshop, U.S. Environmental
Protection Agency, Washington, DC, March 1985c.

U.S. Environmental Protection Agency, Site Inspection Training
Course, U.S. Environmental Protection Agency, Washington, DC,
undated.

U.S. Environmental Protection Agency, Test Methods for Evaluating
Solid Waste;  Physical/Chemical Methods, (SW-846), U.S.
Environmental Protection Agency, Washington, DC, May 1980c.

U.S. Environmental Protection Agency, Third Annual National Symposium
on Recent Advances in Pollutant Monitoring of Ambient Air and
Stationary Sources  Agenda, Abstracts, Attendee List, Held on
May 3-6, 1983 in Raleigh, NC, U.S. Environmental Protection Agency,
Research Triangle Park, NC, May 1983.

U.S. House of Representatives, Superfund Amendments and
Reauthorization Act of 1986 Conference Report, (Report 99-962),
U.S. House of Representatives, Washington, DC, 1986.

Vukovich, Fred M., Walter D. Bach, Jr., and C. Andrew Clayton,
Optimum Meteorological and Air Pollution Sampling Network Selection
in Cities Volume 1;  Theory and Design for St. Louis, (EPA-600/
4-78-030), U.S. Environmental Protection Agency, Research Triangle
Park, NC, June 1978.

Vukovich, Fred M., Walter D. Bach, Jr., and C. Andrew Clayton,
Optimum Meteorological and Air Pollution Sampling Network Selection
in Urban Areas, (NSF/RA-77Q454), National Science Foundation,
Washington, DC, December 1977.

Wallace, Lance A. et al., "Personal Exposures, Indoor-Outdoor
Relationships, and Breath Levels of Toxic Air Pollutants Measured
for 355 Persons in New Jersey/1 Atmospheric Environment, Vol. 19,
No. 10, 1985, pp. 1651-1661.
                                 174

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Walther, Eric G., "Study of Subsurface Contamination with Geophysical
Monitoring Methods at Henderson, Nevada," Proceedings of the Fourth
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on October 31-November 2, 1983 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring,  MD,
1983, pp. 28-36.

Weber, Dennis D. et al., "Spatial Mapping of Conductive Ground Water
Contamination With Electromagnetic Induction," Ground Water
Monitoring Review, Vol. 4, No. 4, Fall 1984, pp. 70-77.

Weber, Robert C. and Kenneth Mims, Evaluation of the Walkthrough
Survey Method for Detection of Volatile Organic Compound Leaks,
(EPA 600/2-81-073), U.S. Environmental Protection Agency,
Cincinnati, OH, April 1981.

Wetzel, Roger et al., "Drum Handling Practices at Abandoned Sites,"
Land Disposal of Hazardous Waste - Proceedings of the Ninth Annual
Research Symposium, (EPA-600/9-83-018), Held on May 2-4, 1983 in
Ft. Mitchell, KY, U.S. Environmental Protection Agency, Cincinnati,
OH, September, 1983, pp. 414-426.

Wetzel, Roger, Kathleen Wagner, and Anthony N. Tafuri, "Drum
Handling Practices at Abandoned Sites," Proceedings of the Third
National Conference on Management of Uncontrolled Hazardous Waste
Sites, Held on November 29-December 1, 1982 in Washington, DC,
Hazardous Materials Control Research Institute, Silver Spring, MD,
1982, pp. 169-174.

Wilson, L. G., Monitoring in the Vadose Zone;  A Review of Technical
Elements and Methods, (EPA-6QO/7-89-134), U.S. Environmental
Protection Agency, Las Vegas, NV, June 1980.

Wolfinger, Thomas F., Hazard Ranking System Issue Analysis;
Carcinogenic Risk Analysis of the Air Pathway Target Distance Limit,
(MTR-86W140), The MITRE Corporation, McLean, VA, October 1986.

Wusterbarth, Arlene, Hazard Ranking System Issue Analysis;
Relationship Between Waste Quantity and Hazardous Constituent
Quantity, (MTR-86W141), The MITRE Corporation, McLean, VA,
September 1986.

Wyeth, Robert K., "The Use of Laboratory Screening Procedures in the
Chemical Evaluation of Uncontrolled Hazardous Waste Sites,"
Proceedings of the Second National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 28-30, 1981 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1981, pp. 107-109.

                                 175

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Zachowskl, Michael S. and Stephen A. Borgianini, "Problems and
Pitfalls of Trace Ambient Organic Vapor Sampling at Uncontrolled
Hazardous Waste Sites," Proceedings;  National Symposium on Recent
Advances in Pollutant Monitoring of Ambient Air and Stationary
Sources, (EPA-60U/9-84-019J, Held on May 8-10, 1984 in Raleigh,  NC,
U.S. Environmental Protection Agency, Research Triangle Park, NC,
November 1984, pp. 82-90.

Zar, Jerrold H., "Power and Statistical Significance in Impact
Evaluation," Ground Water Monitoring Review, Vol. 2, No. 3, Summer
1982, pp. 33-3T:
                                176

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                             APPENDIX A




    COMMENTS ON THE HRS RELATED TO  HAZARDOUS WASTE CONCENTRATIONS






     Comments on the HRS related to hazardous  waste  concentrations




have been related to the appropriateness and the manner of




considering concentration data in the scoring  of Superfund sites




(Federal Register, 1982).  A number of these comments have called




for the inclusion of concentration data in at  least  three factors




used in the HRS; however, the comments have not specified how the




data should be obtained, analyzed, or incorporated in the HRS.  This




section briefly describes the current rating factors considered in




the HRS, outlines comments addressing the modification of three of




these factors to account for concentration data, and summarizes




commentors1 suggestions for implementing the modifications.




     The HRS assigns three scores to a hazardous site, or facility.




One of these scores is designed to reflect the potential for harm




from substances that can explode or cause fires, and a second is




designed to reflect the potential harm from direct contact with




hazardous substances at a facility.  Since these two scores are




used to identify facilities requiring emergency attention, and since




the commentors did not indicate that concentration data should be




obtained to determine these scores, they will not be considered




here.  The third score, however, is designed to rank facilities




across the nation of possible inclusion on the National Priorities




List, which includes those sites slated for further government




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investigation and possible remedial action (Casler and Ramsey,




1985).  This "site migration score" reflects the potential for harm




to humans or the environment from migration of a hazardous substance




away from the facility by three routes:  ground water, surface




water, or air.  To determine the site migration score, a separate




score is first determined for each of the three separate migration




routes using a two-step process.  First, numerical values are




assigned to the factors for each migration route.  Second, the




values for each site are combined to yield the individual migration




route scores, none of which can exceed 100.  The site migration




score is then determined by combining the three route scores into a




single score that also cannot exceed 100 Federal Register, 1982).




     Comments regarding the incorporation of concentration data in




the MRS have focused on the surface water and ground water routes.




Both of these routes are scored by considering three major




categories of factors:  "release" (incorporating the subordinate




categories "observed release," route characteristics," and




"containment"), "waste characteristics," and "targets".   The




comments received by the EPA nave concerned observed releases and




waste characteristics.  (For a detailed explanation of the HRS and




the scoring of rating factors, refer to Federal Register, 1982).




     The HRS considers that observed releases of hazardous




substances have occurred if hazardous substances attributable to the




site are found in the environment at a "significantly higher level






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than the background level" (Federal Register, 1982), regardless of




regulatory limits (e.g., drinking water standards).   If there is




direct evidence of an observed release, a value of 45 is assigned to




the "observed release" category.  If no such evidence exists, a




score of 0 is assigned to the factor.  (However, in this case,




alternative values for "route characteristics" and "containment" are




assigned, with a combined maximum value of 45).  Commentors have




objected to the lack of consideration given to concentration levels




in the assignment of the score for observed release, arguing that




low concentrations of hazardous substances can be detected in many




locales (i.e., not just Superfund sites) and that these low




concentrations are not necessarily harmful.  One of the commentors,




the Chemical Manufacturers' Association, suggested that scores from




0 to 45 be assigned to the "observed release" category according to




6 concentration ranges (Chemical Manufacturers' Association, 1982).




No rationale for this suggestion, or the specified ranges, was




provided.




     The HRS also considers waste characteristics, which include the




two rating factors, "toxicity/persistence" and "quantity".  For both




the surface water and ground water routes, the maximum values for




these factors are 18 and 8, respectively.  The score for the




category is derived by summing the two factor values; therefore, the




maximum category score is 26.  The single toxicity/persistence value




is determined by first assigning separate numerical values  to the






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toxicity and the persistence of the hazardous substance using scales

of 0 to 3, and then extracting an appropriate value (0 to 18) from a

matrix having toxicity and persistence values along its axes.  (The

numericl values assigned to toxicity and persistence are determined

by consulting guidance materials provided by the EPA).  The hazardous

waste quantity value  is determined by assigning a numerical value to

the estimated quantity of hazardous waste at the site, using an

integer scale from 0  to 8 (Federal Register, 1982).

     Commentors have  objected  to the lack of consideration given

to concentration data in the assignment of values for toxicity/

persistence  and quantity, arguing the toxicity and the actual

quantity  of  hazardous substances in the waste are both functions of

concentration.  More  specifically, these commentors have stated that

concentrations of hazardous substances could be within regulatory

limits, and  thus not  pose a substantial hazard to human health

(Homestake Mining Company, 1982).  Commentors also have stated that

estimating waste quantities without consideration of waste

concentrations result in incorrect estimates and possible inequities.

They indicate that such results are possible since sites are evaluated

on the total quantity of waste (e.g., quantity of hazardous compounds

and the nonhazardous  material with which it was mixed before the

mixture was dumped on the site) rather than the "actual" quantity of

the hazardous substance (i.e., excluding the nonhazardous material)

(American Mining Congress, 1983; Chemical Manufacturers'  Association,

1982).
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     No guidance was given by any of the commentors regarding the




methods of obtaining appropriate concentration data or incorporating




the data in the HRS.  Additionally, the commentors did not suggest




methods of considering the many substances for which there are no




regulatory limits.




     In summary, the issues raised by commentors regarding the




incorporation of concentration data in the HRS reflect concern about




observed releases and the "actual" quantity and toxicity of hazardous




wastes at Superfund sites.   Since concentration data are not used in




the HRS, except to identify observed releases, commentors contend




that sites with low concentrations of wastes could receive site




scores that are inappropriately high.  None of the commentors,




however, have addressed the issues of how concentration data should




be obtained.  This is important, as will be "discussed in the




following section, since there is great variability in the size,




nature, and characteristics of Superfund sites, and since the extent




of concentration data required to characterize a site also may vary




along a broad continuum.
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                             APPENDIX B




                            DATA QUALITY






     An assessment of the quality of waste site data generally




requires the comparison of certain characteristics of the data with




specified standards.  These standards are designed to ensure that




the data are representative of the conditions at the site or in the




vicinity of the site, as applicable.  A set of concentration data




for a particular contaminant from a site would be considered




representative if the distribution of the data in time and space,




within the data set, matched the temporal and spatial distribution




of true concentrations from the site.  As has been noted by others




(e.g., Barcelona et al., 1985), representativeness must be assessed




subjectively, as the true distribution of conditions from the site




is not known.




     There are six aspects of representativeness of a data set that




are amenable, to a varying degree, to objective assessment (adapted




from Sachs, 1982 and Ford and Turina, 1985):




     •  Specificity




     •  Homogeneity




     •  Accuracy




     •  Precision




     •  Sensitivity




     •  Completeness
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     An individual contaminant concentration measurement would be




considered specific if the measurement reflected the level of that




particular contaminant in the environment and was free from




interferences caused by the presence of other contaminants.  In part,




a measurement is specific if it reflects what it claims to reflect.




Thus, for example, a set of benzene data would be considered specific




if the data reflected the levels of benzene, and only benzene, in




the environment.  Alternately, it would be considered not specific




if the data that were labeled as "benzene" actually reflected levels




of total aromatic hydrocarbons rather than benzene.  It is not




always possible to completely rule out interferences and thus ensure




that data are specific.  However, this should be done to the extent




possible.




     An additional aspect of specificity is related to the concept




of homogeneity.  A set of data is considered homogeneous if the




individual data points are derived from samples that were drawn from




the same distribution (i.e., to the extent possible, they have the




same characteristics; all controllable factors are the same).  Data




sets that combine samples from multiple distributions are considered




to be nonhomogeneous.  As related to specificity, the distribution




reflected in a homogeneous data set must be the intended




distribution.  For example, if two wastes are present on an




uncontrolled waste site and a differentiation between the




concentrations of contaminants in these wastes is needed, then two






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distinct, homogeneous data sets should be developed, one reflecting




samples of the first waste, the second reflecting samples from the




second waste.  In this case, a single combined nonhomogeneous data




set would be useless in determining concentrations in the individual




wastes.




     Accuracy is related to the statistical concept of bias.   An




individual measurement is considered accurate if it can be expected




that the measured value is the true value.  Operationally, a data




set is considered sufficiently accurate if the average difference




(or ratio) between the measured values and the true value is




acceptable based on the intended use of the data.  An important




characteristic of accurate data is that it tends to be equally




distributed above and below the true value.  It is free from




systematic error; error that causes a generally consistent bias



upwards or downwards.  Also, data can be accurate even though the




individual measurements differ significantly from each other (on




average the differences must cancel each other out).




     An immediately apparent problem with the concept of accuracy is




that its assessment requires that the true value be known at the




time of measurement.  If the true value were available, the average




difference between the measured values and the true value could be




used as a measure of accuracy.  This estimate of the average




difference could then be used to determine whether a data set were
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sufficiently accurate.  However, the true value is rarely known,




generally only when standard solutions are being used.




     As an illustration of the concept of accuracy, consider the




benzene data set exhibited in Table B-l.  Assume these values




represent the results of 10 replicate benzene samples taken in




surface water at the same place and time.  Assume also that the true




value of 25 mg/1 was also known.  These data would be considered




accurate since their average is equal to the true value.




Alternately, if their average were actually 24, the data might be




considered sufficiently accurate depending on the purpose for which




they are intended.  Accuracy is typically a relative measure rather




than an absolute measure.




     The concept of precision is frequently confused with that of




accuracy as both address the extent to which the measured values




deviate from the true values.  As noted above, accurate data may




exhibit wide variations between individual data points.  Precision




is a measure of the degree of this variation.  It is a measure of




the degree of agreement between separate measurements of the same




quantity.  The most common measure of precision is the square root




of the average of the squared deviations of eacn data point from the




sample average (i.e., the sample standard deviation of the data).




If the estimation method is accurate, then precision can be estimated




as the average distance between the individual measurements and the




average of the measurements.  Precise data is characterized by a
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                     TABLE  B-l

ILLUSTRATIVE EXAMPLE OF BENZENE CONCENTRATION DATA
              ACCURACY AND PRECISION


  Sample Number                    Value (mg/1)

        1                               17
        2                               43
        3                               26
        4                                9
        5                                7
        6                               19
        7                               31
        8                               49
        9                               21
       10                               28

  Average                               25

  Standard Deviation                    13.5

  Coefficient of Variation              54%
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clustering of most of the measurements around the average value.




An excellent discussion of the differences between accuracy and




precision, using a "bulls-eye" analogy is presented in Kirchmer, 1983.




     Again referring to the example data set in Table B-l, the




estimated precision of this data is 13.5, or as it is often stated,




54 percent of the mean value of 25.




     Estimation of precision requires multiple measurements at the




same point in space and time or an assumption of spatial or temporal




stability of the factor being measured.  The acquisition of multiple




samples may be very difficult or the assumption of stability




unacceptable.




     Sensitivity, as described by Sachs (1982), is a measure of the




minimum quantity of a substance that can be differentiated from




zero.  If the data set contains measurements listed as "not detected"




or "not quantified" then the data set cannot be considered to be




completely representative of the actual environmental concentrations.




The "not detected" or "not quantified" reading may be as low as zero




or as high as the detection or quantification limits, respectively.




Thus, some error must be introduced in either assuming "not detected"




concentrations equal zero or equal the detection limit (the two most




common approaches to addressing "not detected" data).  Special




interpretative techniques that may require additional sampling,




analysis, or interpretative assumptions (e.g., knowledge of the
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conditional distribution of the concentrations below the detection

limit) are needed to analyze data containing readings below levels

of detection or quantification (Gleit, 1985).

     The final important aspect of representativeness of a data set

is completeness.  There are no objective measures of completeness.

A complete data set would reflect all significant variations in

environmental or waste concentrations that occur in both space and

time.  Further, the data set would include measurements of all

contaminants of concern, across all media of concern.  Without

complete knowledge about the site, estimates of the degree of

completeness of a data set are not determinable.

     Overall, the principal consideration in determining the quality

of concentration data in terms of its intended usefulness in a

particular application is the degree to which the data are

representative of the actual concentration levels from the site.

In assessing the degree of representativeness, several questions

must be asked reflecting the five most important aspects of

representativeness:

     •  Specificity:  Do the data represent the parameters that they
                      should, and, if not, is the difference
                      acceptable?

     •  Homogeneity:  Are the data homogeneous, do they come from
                      the same distributions?  Were sampling'
                      conditions the same for all samples within
                      each data set?
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•  Accuracy:
•  Precision:
•  Sensitivity:
•  Completeness:
Are the data sufficiently accurate?  Do we
expect the estimated values to be the true
values on average?  Have systematic errors
been eliminated or controlled to an
acceptable degree?

Are the data reproducible?  Do replicate
values cluster around the average or are they
widely variable?  Have all source of
unintended variation been eliminated or
controlled to an acceptable degree?

Are the levels of detection and quantification
low enough to show important variations in
concentrations?

Are all significant variations in
concentrations reflected in the data?  Have
all contaminants of concern been measured?
Have all media of concern been sampled?
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