Site Inspection
      Training Course
   Hazardous Site Control Division
U. S. Environmental Protection Agency
        Washington, D.C.

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                     SITE INSPECTION TRAINING COURSE


DAY 1                                                        MANUAL SECTION


0£QQ-0930   EPA Headquarters Program Review                         TAB 1

            *   Review discovery through NPL process   current status of discovery,
               PA, SI, NPL update
            •   Overview of remedial process
            •   Emergency/Enforcement considerations

            •   Instructor: Lucy Sibold, U.S. EPA

0930-1015   Managing Site Inspections                                  TAB 2

            *   Standard Operating Procedures
            •   Quality Assurance
            •   Background Data Collection - explain why important,  and sources of
               information

            •   Instructors:  Lucy Sibold  U.S. EPA
                           Diane Trube, NUS Corporation
                           Steve Hann, NUS Corporation

1015-1030   Break
1030-1200   Managing Site Inspections (Continued)                       TAB 2

            *   Preparation  of  Work  Plans/Safety  Plans/Sampling  Plans  -  discuss
               format/content of work plan, safety plan, sampling plan
            •   QA review of documents
            •   Personnel Assignments/Team Organization
1200-1300   Lunch
1300-1500   Managing Site Inspections (Continued)                       TAB 2

            *   Mobilization/Equipment/Decontamination/Demobilization/Waste
               Disposition
            •   Site Access/Community Contacts
            *   Sampling.   Discussion of  legal considerations    need for control of
               custody, etc.

            •   SI Documentation
            *   QA of Analytical Data
            •   Laboratory QA considerations.

1500-1515   Break

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DAY 1 (Cont.)                                                   MANUAL SECTION
1515-1700   Criteria for Further Action                                  TAB 3

            *  Discussion of criteria
            '  Presentation of example case histories - practical exercise
            •  Discussion of case history evaluations

            •  Instructor: Lucy Sibold, U.S. EPA

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DAY 2                                                      MANUAL SECTION



0&06-1000   Hazard Ranking System (MRS)                              TAB 4

            •  HRS Concept
            •  Problems associated with scoring
            •  Example problem

            •  Instructor:  Channing Johnson, MITRE Corporation

1000-1015   Break


1015-1200   HRS Exercise                                             TAB 4

            *  Additional  example problem assigned to course participants


1200-1300   Lunch


1300-1400   Hazard Ranking System (Continued)                        TAB 4

            •  Answer  additional questions re:  HRS


1400-1500   Sampling Plan  Development                                TAB 5

            *  Purposes and objectives of sampling  for an SI
            •  HRS sampling strategy
            •  Example sampling plan format

            •  Instructor(s): Jerry Oskvarek/Mac Castor, Ecology 
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DAY 3                                                        MANUAL SECTION


0200-0915   Sample Collection Techniques (Continued)                   TAB 6

0915-1000   Sampling Quality Assurance                                TAB 7

            •  Overview and examples of the aspects of sampling having the greatest
               potential for errors.
            •  Field logbook procedures

            •  Instructor(s):  Jerry Oskvarek/Mac Castor, Ecology & Environment, Inc.

1000-1015   Break


1015-1130   Hazard Recognition                                       TAB 8

            *  Description  of   types   of   hazards  related  to  physical/chemical
               properties of materials
            •  Description of activities which may alter degree of hazard

            •  Instructor:  John Walsh, NUS Corporation

1130-1300   Lunch


1300-1*30   Elements of Site Operations                                TAB 9

            •  Team Organization/Size/Roles
            •  Levels of protection
            *  Work Zones  Exclusion  zone, contamination reduction zone, support
               zone, etc.
            •  Communications  Radios, line of site, etc.

            •  Instructor: Gary Smith, NUS Corporation

1430-1*45   Break


H
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DAY it


OSOO-1000   Time Period #1


1000-1200   Time Period #2


1200-1300   Lunch


1300-1500   Time Period #3


1500-1600   Course Wrap-Up
                                                               MANUAL SECTION

Practical Exercise #1  Safety Overview                                 TAB 11

            •  Toxicology  Overview  -  Discussion  of  toxicology  as  it  relates  to
               personal safety/potential for exposure.
            •  Respiratory  Protection  -  Refresher/Introductory  discussion   and
               demonstration of respiratory protection principles and equipment.
            •  Levels of  Protection    Discussion  and demonstration  of protective
               clothing and equipment ensembles for site inspections.

            •  Instructor: Gary Smith, NUS Corporation

Practical Exercise #2  Field Monitoring Instruments                   TAB 12

            °  Operation/check-out procedures
            •  Calibration requirements
            •  Exercises  with instruments

                  Explosimeter
                  C>2 meter
                  Draeger tubes
                  Radiation meter
                  OVA
               -  HNu

            •  Instructor: Jack Peterson, NUS Corporation

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Day * (Cont.)

Practical Exercise S3  Site Inspection Exercise                        TAB 13

            •  Course participants organize field team
            •  Group given background data for a site, including site map
            •  Reference materials available  course manual, Sax, etc.
            •  Each group to  prepare a  project work plan,  safety plan, sampling
               plan on basis of information provided
            •  Group   will  designate  one  person  to  give  a  one-half  hour
               presentation  on the approach
            •  Instructor critique

            •  Instructor: Jerry Oskvarek/Mac Castor, Ecology & Environment, Inc.

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                       1.0 SUPERFUND PROGRAM


1 .1  INTRODUCTION

           The Comprehensive  Environmental  Response,  Compensation
     and Liability Act (CERCLA or Superfund) was passed; on December 11,
     1980.   Among many things this law authorizes EPA to respond to
     releases or threats  of releases into the environment of hazardous
     substances, or of a  pollutant or contaminant which may present an
     imminent or substantial  danger to public health, welfare or the
     environment.

           There are three primary ways sites can be  cleaned up with
     CERCLA authority:

           0  enforcement

           0  removal

           0  remedial

1. 2  ENFORCEMENT

          CERCLA grants EPA broad authority to take action against
     responsible parties, including owners, operators and generators,
     to bring about response  action at sites.   Responsible parties can
     be held liable for up to 3 times the cost of clean up if the Fund
     has to clean up a site.

1.3  REMOVAL

          The "removal" program is more commonly referred to as the
     "emergency" program.  The removal program (particularly immediate
     removals) allow EPA  to respond to releases more  quickly than the
     longer term remedial program without having to wait for National
     Priorities List (NPL) listing.  Recent proposed  amendments to the
     National Contingency Plan (NCP)-EPA's  plan for how it will address
     releases of hazardous materials-proposes to expand the removal
     authority to cover situations not routinely thought of as
     "emergencies".  Releases or threats  of releases  at or near the
     surface, independent of  whether they pose an immediate threat,
     may be addressed under the removal program.  This will be discussed
     in greater detail in Tab 3-Decision  Criteria.

          The primary limitation to "removal" actions is they can cost
     no more than $1 million  and last no more than 6  months unless
     continued response (1) is required to prevent, limit or mitigate
     an emergency, (2) there  is an immediate risk, (3) and no one else
     will provide the assistance.

          The two key groups that oversee  "removal" actions are  the
     Coast Guard and EPA.

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                                -2-


         The Coast Guard primarily responds to releases of hazardous
     materials in coastal areas and will support EPA at inland areas
     when requested.  EPA primarily responds to inland releases through
     its contract technical assistance team (TAT)  and Emergency Response
     Cleanup Services Contracts (ERCS).  The TAT contractor, among
     other things, has responsibility for:

          0 conducting preliminary assessments (for "removal" actions)

          ° directing removal actions

         The ERCS contractor has responsibility for implementing the
     selected removal actions including:

         0 containment and countermeasures

         0 cleanup, mitigation, and disposal

         ° site restoration

         0 analytical services

         If State personnel confront ''emergency" situations, and the
     State is unable to take response action or force responsible
     parties to take response actions, the site should be promptly
     referred to the EPA Regional office for action.
1.4  REMEDIAL
     1.4.1 DISCOVERY

          Discovery is the process of identifying previously unknown
     potential hazardous waste sites.  Sources for this information
     could include:

          0 informal community site notification hot lines

          0 mandated Federal/State site notification programs

          0 historical or recent aerial photoimagery

          0 Federal/State/local government records

          0 land use records

          0 other sources

          All sites that are discovered by EPA or States^ are entered
     into EPA's Emergency and Remedial Response Inventory System
     (ERRIS).   This system recently has been merged into CERCLIS.
     As of today, there are over 19,000 potential hazardous waste
     sites in EPA's ERRIS system.

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                                  -3-
           ERRIS is not  a  comprehensive  list of  all  potential site
      in the country—only those  that  have  been  reported to EPA.
      EPA estimates that by 1986,  the  ERRIS list could grow to over
      22,000.

1.4.2  PRELIMINARY ASSESSMENTS

           The  purpose of  a preliminary  assessment  is  to examine
      the list  of potential hazardous  waste sites contained in
      ERRIS to  determine if a  site merits  further action.   If
      warranted, further action could  include emergency response  or
      additional study such as a  site  inspection.  A preliminary
      assessment should  characterize the hazardous substances
      present,  potential pollutant dispersal pathways, the  population
      and resources which  might be affected, facility  management
      practices, and readily known potential responsible parties.
      At this stage the  person conducting  the PA should begin
      gathering data to  support HRS scoring.

           To complete a preliminary assessment, the following
      types of  tasks are appropriate:

           0 interviews  with Federal,  State, and local
          government personnel, and fire departments

        0 files, reports,  and  court cases

        0 review of U.S. Geological Survey, Soil Conservation
          service,  State Water Resources Offices,  or other
          comparable institutions  with geological, hydrological
          and topographical data

        0 review of State  and  local private and  public
          well  logs

        0 review of federal and local  meterological
          data

        0 review of land use data  from local planning  agencies

        ° review of available  aerial  imagery

        0 review of flood  insurance rate maps available
          through the U.S. Dept.  of Housing and  Urban  Development

        0 off-site reconnaissance  of  site  (windshield  survey)

        Preliminary assessments  are not  limited  to the tasks outlined
   above.  A State may gather  other information  essential to the
   assessment.   However, a preliminary assessment is not "intended  to
   give a full  and complete picture of the site.  A preliminary
   assessment is, by design, a quick,  low  cost review  of existing
   data to determine if  the site  potentially poses a problem and,  if
   so, what type of follow-up  work should  be undertaken.  Accordingly,
   States should not undertake tasks in  a  preliminary   assessment

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                            -4-


that are not consistent with these objectives.  These assessments
take up to 40+ workhours, on average, to complete.

1.4.3 SITE INSPECTION

     The purpose of a site inspection is (1) to determine if
further action is warranted or (2) to better define the extent of
the problem at a site and provide a data base sufficient to apply
the EPA Hazard Ranking System (HRS).  Further action could
include additional investigations, emergency response, NPL listing,
or enforcement.  To accomplish these objectives, site specific
data on the hazardous substances present, pollutant dispersal
pathways, types of receptors, and site management practices is
gathered.  The scope of an inspection can vary depending upon the
nature of existing information on the site.  In general, an
initial site inspection does not include a detailed hydrological
assessment of the site.  Recent EPA experience indicate that a
site inspection usually requires up to 175 recent workhours and
more in some cases.

    The following types of tasks are appropriate for a site
inspections.

     0 screen site with portable field instuments for aire releases,
       radioactivity, buried drums/tanks

     0 collect/analyze on and off-site soil, sediment
       and water samples

     ° collect/analyze ground water samples

     0 collect/analyze air samples

     0 collect analyze samples from open drums or lagoons

     0 survey and document site, structures, topography,
       lagoons, drainage, drums, bulk tanks, monitoring
       wells, roads, access points, boundaries, etc.

     0 document location of potentially affected homes, public
       buildings, natural areas, other populations, etc.

     0 review operator records

     0 HRS scoring (optional).

Under the CERCLA State PA/SI program, an average of 10-12 samples
per site is routine.  States should try, where feasible, to limit
sample collection to this amount.  However, this amount may not be
appropriate considering the size, complexity, nature of the
pathways and the amount of existing reliable analytical data.
If is impossible to effectively score the site with 12 samples
then it is appropriate to collect more.

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                            -5-
1.4.4 SITE INSPECTION FOLLOW-UP

     A site inspection follow-up is an optional activity.  In most
cases, follow-up site inspections will only be necessary for
complex sites where additional data is needed to substantiate an
HRS Score or to strengthen an HRS score.   Follow-up site
inspections might also be needed to:

     ° further define the extent or potential for contamination

     0 more extensively determine the identity/quantity of waste
       materials or contaminants disposed on site

     0 better identify/quantify target populations or
       environments

     An appropriate task under this activity includes drilling
wells to obtain better data on the presence of contaminants in
ground water.  High technology subsurface survey work may be
needed during a site inspection follow-up.   The more conventional
techniques can often provide enough data to score a site for the
NPL.  However, where conventional techniques will not be adequate
more sophisticated technology is appropriate.

1.4.5 HRS/NPL

     The Hazard Ranking System (HRS) is a model developed and
designed to rate the relative severity of a hazardous waste site
against other sites.  The HRS computes a score from 1 to 100 for
each candidate site.  The score is based on (1) the relative
potential of substances to cause hazardous situations, (2) the
likelihood and rate at which the substances may affect human and
environmental receptors, and (3) the severity and magnitude of
potential effects.

     The National Priorities List (NPL) is a compilation of the
highest priority sites in the country.  Each site included on the
NPL was scored using the HRS.  Congress mandated that EPA publish
and update this list on a regular basis.

     A site must be listed on the NPL eligible for remedial action.

     Depending upon the scope of each State's cooperative agreement,
some States will be scoring all sites where they have done a site
inspection.  In other States, the Regional office will perform
the scoring.  EPA-HQ is recommending to the Regions that all sites
that receive a site inspection be scored unless there is a
documented reason for not scoring this site.  An example for this
might be a situation where there is no affected population or
sensitive environment.                             —

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                            -6-


     It is important to note at this time that enforcement activitA
is not specifically relevant to NPL considerations.  EPA's policy *
is to score all sites regardless of their enforcement status.
This will ensure fair and equitable treatment of all sites.
Ultimately it is the Regions responsibility to recommend sites
for NPL consideration.  However, States are the prime source of
sites recommended by the Regions.  States also have a role in
reviewing and commenting on Regional recommended sites.

     The following is an outline of the chronology by which sites
are submitted for NPL consideration:

     0 Apply HRS scoring system

     0 Submission of information/NPL package

     0 Regional quality control

     0 HQ quality assurance audit

     0 Sites that pass QA published in Federal Register

     ° Sites pass through 60 day public comment period

     0 Sites successfully passing  through comment period are
       published as final in Federal Register.

     0 Litigation

     When a site is submitted to EPA Headquarters for NPL
consideration, the submittal must  contain the following
components :

     * Complete set of HRS worksheets

     e Documentation record

     0 Bibliography of information sources

     0 Short narrative summary for press release

     Once a site has been scored using the HRS and submitted for
NPL consideration, the Region performs a quality control review.
This QC review involves:

     ° Ensuring that submittal is  complete

     0 Ensure correct arithmetic and language

     0 Ensure scores for individual factors are appropriate based
       on information in documentation record

     0 Resolve and correct with preparer any errors or discrepancies

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                            -7-
 Headquarters QA involves:

     0 Ensure accurate interpretation of technical data and
       arithmetic assignment of HRS values

     0 Ensure consistent interregion EPA policy application

     0 Ensure equitable treatment for all sites nationally

     ° Ensure technically valid professional judgement exercised


1.4.6  REMEDIAL INVESTIGATION (RI)

     A remedial investigation is an investigation intended
to gather the data necessary to:

     0 determine more precisely the nature and extent of problems
       at the site

     0 establish cleanup criteria for the site

     0 identify preliminary alternative remedial action

     0 support the technical and cost analyses of the
       alternatives.

     In order to conduct a remedial investigation and' all
activities subsequent to a remedial investigation, the site
must be listed on the NPL.

1.4.7  FEASIBILITY STUDY (FS)

A feasibility study is intended to:

     0 evaluate alternative remedial actions from a
       technical, environmental, and cost-effectiveness
       perspective

     0 recommend the cost-effective remedial action

     ° prepare a conceptual design, cost estimate for budgetary
       purposes, and a preliminary construction schedule

1.4.8  REMEDIAL DESIGN (RD)

     In this phase of a remedial action, the selected remedy
in clearly defined in a bid package so  that the remedy can  be
implemented.  It can take the  form of a site cleanup  plan,  a
relocation plan or engineering drawings and specifications.

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1.4.8  IMPLEMENTATION/CONCTRUCTION/REMEDIAL ACTION (RA)

     The construction phase is the phase at which actual clean up
occurs based upon the designs prepared in the design phase.
Implementation can range from building containment structures,
removal of drums, installation of fences, relocation of residents,
provision of alternative water supplies, installation of site
monitoring systems, construction of clay caps, etc.

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                               -9-
            REMEDIAL PROCESS FOR  FUND LEAD SITES
  DISCOVERY
   AND
 IHVESTHUTIOI
  REMEDIAL
  PLANNING
  REMEDIAL
IMPLEMENTATION
                           Figure 1.

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- I
Pfc
oc&DuK.e3

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SITE INSPECTION - OVERVIEW
          BACKGROUND DATA COLLECTION
          PREPARATION OF:
                WORK/SAMPLE PLANS
                SAFETY PLANS
            PERSONNEL ASSIGNMENTS/
              TEAM ORGANIZATION
             MOBILIZATION/EQUIPMENT
                 SITE ACCESS/
             COMMUNITY RELATIONS
          FIELD WORK:
                 SAMPLING
                 OTHER FIELD ACTIVITIES
                DECONTAMINATION/
                DEMOBILIZATION/
                WASTE DISPOSITION
            REVIEW OF ANALYTICAL DATA
                WRITE SI REPORT

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STANDARD OPERATING PROCEDURES
2.1.0    INTRODUCTION:

        Standard Operating  Procedures (SOPs) are  those  established methods  which are
        followed  routinely  for  specific  tasks,  including  those  tasks  which  produce
        evidentiary data and information.  They  are part of the foundation upon which an
        office should build a major part of its work.  The SOPs are  a  necessary instrument
        within the structure  of an office.  By implementing SOPs the  office should be able
        to assure itself of the following:

        o   all applicable work will be performed from sound technical guidelines

        o   work performed will be of high quality, thus reducing the probability of errors

        o   documentation of the work in the event of future court  action

2.1.1    PURPOSE:

        The  purpose  of  this  section  is  to  discuss  the  rationale   for  developing  and
        maintaining Standard  Operating  Procedures  (SOPs)  for  activities that  require
        Quality  Assurance and Quality Control.

2.1.2    APPLICABILITY:

        Standard Operating Procedures (SOPs) are instituted into the routine and repetitive
        tasks  that produce  data  that will be incorporated into the Hazardous  Ranking
        System (MRS)  model and used as evidentiary  information. It is the standardization
        of these  instituted  procedures  that  become  an  integral part  of  the Quality
        Assurance and Quality Control of the evidentiary information.

2.1.3    DEFINITIONS:

        Standard  Operating  Procedures  (SOPs)  -   operations, analyses,  or  activities
        composed of specific functions that are prescribed, documented, and accepted as
        the norm for the performance of routine tasks.

        Quality  Assurance  (QA)  The total integrated  program for  assuring the reliability
        of monitoring and measurement data.

        Quality  Control  (QC)    The routine application of  procedures for obtaining
        prescribed standards  of performance in the monitoring and  measurement process.

        Comparability - A  measure of the confidence with  which one  data  set  can  be
        compared to another.

        Completeness     A  measure  of  the amount of  valid data obtained  from  a
        measurement system compared to  the amount that was expected.

        Precision  -  The degree  of  agreement between  repeated  measurements  of  one
        property using the same method or technique.

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STANDARD OPERATING PROCEDURES
2.1.4   DISCUSSION:

       Standard Operating  Procedures are operations, analyses or actions composed  of
       specific functions that are prescribed, documented and accepted as the norm for the
       performance of routine tasks.  SOPs do not deviate  from the specific activity and
       are  specific  in  direction  and  applicability.    Briefly,  SOPs   are  documented
       compilations of detailed instructions for repetitive tasks.

       The purpose of  Standard Operating Procedures is to assure the data produced from
       the  repetitive  tasks  are quality  assured.    SOPs are  an  instrument  of  Quality
       Assurance and  Quality Control.  SOPs  assure quality control because  each task is
       performed  in exactly the  same prescribed manner each  time, never  deviating in
       procedure from site to site, no matter who performs the  task.   It is  this strict
       compliance with no deviation that eliminates variable influences in the functions of
       the task, leaving only variables for which the procedure is being monitored.

       The  repeated   continuity  in  the  execution  of   tasks  produces  data  that   has
       comparability,  completeness,  and precision.   The  data  must  be  analyzed  for
       comparability, completeness, and precision.  Following the analysis for  these three
       criteria the data can  be incorporated into the MRS model and used as  evidentiary
       information.

2.1.5   RESPONSIBILITIES:

       SOPs  are designed and  written by experts in  the field  for  which the SOPs  are
       applied. The SOPs  must be tested  and  proven before they are  implemented.  They
       must also be generally accepted so data generated from the SOPs are comparable to
       other  sets of data.  When SOPs are proven,  accepted, and documented they must be
       implemented into  the  task regime  of  the  office.   It is  the responsibility of  the
       responsible manager and the QA/QC Manager to implement the SOPs into  the  task
       regime.  Once  implemented the responsible manager  must insure  that the SOPs are
       used and provide constant training to reinforce the SOPs importance in establishing
       evidentiary information.

2.1.6   PROCEDURES:

       The following list identifies many  of the activities associated with Site Inspections
       for which SOPs  will prove invaluable. An example SOP follows.

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STANDARD OPERATING PROCEDURES



  o    Quality  Assurance Review and  Validation of  Inorganic Analysis  Data
       Packages

  o    Data Review, Reduction, and Reporting

  o    Ground-Water Well Sampling

  o    Tap-Water Sampling

  o    Ground-Water Level Measurement

  o    Determination of Ground-Water Flow and Water-Table Contour Mapping

  o    Preliminary Assessments

  o    Administration and Management of Sampling and Analysis

  o    Chain of Custody

  o    Sample Packaging and Shipping

  o    TCDD Sampling

  o    Identification of Equipment Requiring Calibration

  o    Monitoring, Measuring, and Test Equipment Maintenance

  o    Preparation of Geotechnical Framework

  o    Field Classification of Soil and Rock Samples

  o    Sampling

  o    Site Inspections

  o    Organization of the Field Team

  o    Control of Contaminated Material

  o    Legal Considerations

  o    Rapid Field Screening of Hazardous Substances

  o    Measurement of Dissolved Oxygen Concentration

  o    Field pH Measurement

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STANDARD OPERATING PROCEDURES








     o    Specific Conductance Measurement




     o    Decontamination




     o    Respiratory Protection




     o    hNu Photoionization Detector Operation




     o    Organic Vapor Analyzer Operation




     o    General Safety Guidelines Applicable to All Field Operations

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   QUALITY ASSURANCE
2.2.6  PROCEDURES


      Document Control and Record-Keeping

      All  evidentiary documents, correspondence  and  reports  are  assigned a  unique
      document  control  number,  in  accordance with Table  1.  These  numbers  are
      recorded  on  a  Document Control Records Log (Figure 2.2-1), which is  maintained
      with the documents in the project file.

      Files are  kept in a  limited access area and must  be signed out.  Periodic file audits
      are  performed to  check  the completeness of the  files, and  to  insure  compliance
      with document log procedures.

      Telephone conversations are  also  documented as  they  may  be referenced  as
      sources. Figure 2.2-2 is a sample telecon note form.

      Document Review and Approval

      Appropriate  Document  and Report  Review  Logs (Figures  2.2-3  and  2.2-4)  are
      attached to each deliverable by  the author.  As the document is passed through the
      review  system  it undergoes technical and editorial reviews (Figures 2.2-5 and 2.2-
      6).  If approved, it is initialled and passed to the  next higher level. If  correction or
      clarification is necessary, the document  is returned with comments to the author.

      A Quality Assurance officer, in additon  to reviewing the document itself,  checks
      the  review  logs to see that the document  is being reviewed and approved  by the
      appropriate personnel.

      Photographic Documentation of Field Activities

      During  off-site and on-site investigations,  photographs can provide information
      which can be used to help assess the magnitude of the problem and document visual
      proof of  potential  hazards. Because such information  may provide evidence in
      support of  legal action, photographs and  negatives must conform  to document
      control requirements.

      Activities related  to the collection  of  photographic evidence during  on-site  and
      off-site investigations are to be included in the  work plan.  Photographs will help
      document  observed site conditions  and will increase  the  evidentiary  value of
      samples collected  in the field.

      Photographs are important  in documenting the cause-and-effect relationship of the
      off-site migration of hazardous  materials, especially  with respect to environmental
      damage and potential   exposure  to  the  public.   Photographs should  clearly
      demonstrate proper  field  procedures.   Specifically  during on-site  inspections,

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   QUALITY ASSURANCE
2.2.0  INTRODUCTION

       Decisions concerning  the control and management of hazardous wastes or the need
       for enforcement actions must be based on analytical  data generated during site
       investigations.   Since management decisions can  be no better than the data on
       which they are based, it is imperative that the data be of high quality.  To  obtain
       quality data, data that are scientifically and legally defensible, and data  that have
       the requisite  levels  of  precision  and accuracy  with minimum expenditures of
       resources, it is necessary to develop a comprehensive and well-documented Quality
       Assurance (QA)  program. A Quality Assurance program must be incorporated into
       every activity involved  in the Site Inspection, including sampling site selection, the
       collection,  preservation,  and   transportion  of   samples,  the  calibration  and
       maintenance of  instruments, and the processing, verification,  and  reporting of the
       data.  If  careful attention is  not paid to each of these items,  it is highly probable
       that invalid data  will   be  produced.   Such  data  waste resources, lead to bad
       management decisions, and hinder enforcement actions.

2.2.1  PURPOSE

       The purpose of a Quality Assurance system is:
          a.     to  provide evidence of compliance with established operating procedures,
          b.     to  insure that  standard   review  and  approval  procedures have  been
                followed, and
          c.     to  provide a  method of evidentiary document identification and control.

2.2.2  APPLICATION

       All evidentiary  documents, including field log books, photographs and photo  logs,
       telecommunication memos, laboratory data, equipment calibration  records, sample
       management, and training records.

       All deliverables, including work plans, safety plans, sample plans, Site Inspection or
       Hazard Ranking  System  reports, and sample trip reports.

2.2.3  DEFINITIONS

       None.

2.2.4  DISCUSSION

       None.

2.2.5  RESPONSIBILITY

       Quality Assurance procedures are to be followed by all  personnel involved  in any
       aspect of a  site  investigation.  The project manager is ultimately  responsiclc for
       the compliance  with  Quality Assurance Procedures  in  the  p'v;^ration lor, and
       during, the site investigation.  However, the project manager may delegate sample
       management and documentation  to  a  sample management oi*f'
-------
SUBJECT
NUMBER
REVISION
PAGE 3 OF 9
EFFECTIVE DATE
                                   -  TABLE  1

                   EXAMPLE TDD BASED DOCUMENT CONTROL NUMBERS

                                 Phased Work Assignments

         Based on a hypothetical work assignment identified with TDOf 02-MOl-Ol with ail

         vork activities are crganized with a two phase approach.
Project Control
Documents - Phase I
Document      _ Work Assignment    Document Code      Revision
Control Number — TDD Number    •*• and Phase Number * Number
Vl'ork Plan
Safety Plan
Safety Plan Follow-up
Report
Sampling Plan
Project Control
Documents - Phase 2
Work Plan
Safety Plan
Safety Plan Follow-up
Report
Sampling Plan
Deliverablea - Phase I
Sample Trip Report
?hoio Log
Deliverable^ - Phase 2
Sample Trip Report
Photo Log
02-S60l-01-'*'l-0
02-S601-01-S1-0
02-S601-01-SF1-0
02-S601-OUSP1-0

02-S601-01-VC2-0
02-S601-01-S2-0
02-360I-01-SF2-0
02-S601-01-SP2-0
02-S601-01-STR1-0
. 02-S601-01-PL1-0
C2-3SOI-01-STR2-0
02-S601-01-PL2-0
02-3601-01
02-S601-01
02-3601-01
02-3601-01

02-3601-01
02-3601-01
02-3601-01
02-S601O1
02-3601-01
02-S601-01
02-S601-01
:2-3601-Ol
Wl
si
SFl
SPl

W2
S2
SF2
SP2
STR1
PL1
5TR2
PL2
0
0
0
0

0
0
0
0
0
0
0
0

-------
                                          FIGURE 2.2-1
HUS CORPORA JION
SUPERfUND DIVISION
                                          QUALITY ASSURANCE RECORDS LOG \
fOO/TOO/WA:
O'2-VGGI-OI^
                tilt:
                               SITE NO.:
             CCC)C
                                               OFFICE:
REGION II FIT
EDISON, NJ
• OO/IOO/WA MANAGERS
    L C  '
DOCUMENT CUSTODIAN:
     L S^orx'n
                  PROJECT NOJ
                      0400.01
                                                                                               or 9
                        RECORD DESCRIPTION
                                                                 DOCUMENT NO.
                                                        DATB COMPLETED
             ~Di

 pi >c... ( oa
    i.|  hoc, k"
                                  02 -S&OIOl
                                                              02- ?££>» Oirt-S i-O
                                                                  ^6o/-0/fl-^-2-
                                                                       -OtH SP-0
                                 02-84,01-0 \ a -P-l
                                                                      i -Oi lO -STK'-O

-------
                                   FIGURE 2.2-2
Page 5 of 9
NUS CORPORATION
TELECON NOTE
CONTROL NO:
                               DATE:
                                                              TIME:
DISTRIBUTION:
BETWEEN:
                                        OF:
                                                                  PHONE:
AND:
                                                                                      INUS)
DISCUSSION:
ACTION ITEMS:

-------
                               FIGURE 2.2-3                                Page 6 of 9
                                                            Rev. 0
                      DOCUMENT/REPORT REVIEW LOG
Document Title:
Project Name:
Project Number:
Document/Report Number:
Revision Number:
Correspondence Date:
Reviewer                             Initial                Date
Author
Project Manager
Chief Project Manager
Assist. Regional Project Manager
Regional Project Manager
QA Representative
Other
(to De used to review all technical documents)
Comments:

-------
 SITE/PROJECT NAME:

 TDD:    ___	
                            REPORT REVIEW CHECKLIST
                                  FIGURE 2.2-4
                                                             Page 7 of 9
            BRIC:
DATE:
 PROJECT MANAGER:.
 DOCUMENT NAM£r__
 DOCUMENT NUMBER:
                                REVIEWERU);
           REVIEW F.LEMENT<2)        INITIAL(3)

 I.     1$ the report organized in
       the proper format ?	       	

 II.     Is the text readable and
       letter perfect? 	       	

 III.    Are the figures and tables
       readable, letter perfect
       and self explanatory? 	       	

 IV.    Are the tables and figures
       numbered correctly? 	       	

 V.     Are the table of contents,
       list of tables and  list of
       figures correct? 	       	

 VI.    Are the tables, figures and
       references correctly identified
       in the report text? 	       	

VII.    Is the information and data
       presented in the tables, figures
      'and text consistent in the report?  	

 VIII.   Are the pages in the report
       numbered correctly? 	       	

 IX.    Is information and data pres-
       ented in the report consistent
       with the field notes? 	       	

 X.     Is critical background/historical
       information documented in the
       project file?	           	
                                      DATE
          COMMENTS*1*)
NOTES:
            (1)
QC review personnel must be independent of those directly involved in tr.e
report preparation.
Indicate "NA" if the task is not applicable to the report review.
Initial only when review comment is iisposiTioned.
Continue on  reverse Side if necessary.
            Review Approval; QA  Representative Initial,"Ja:e

-------
                                                                       Page 8 of 9
                                FIGURE 2.2-5
                        DATA PRESENTATION/EVALUATION
                          TECHNICAL REVIEW CHECKLIST
SITE/PROJECT NAME:	
TDD:    	    BRIC:    	       DATE:
PROJECT MANAGER:	  REVIEWER^:	
DOCUMENT NAME:	
DOCUMENT NUMBER:
           REVIEW ELEMENT            INITIAL^)     DATE           COMMENTS*3)
I.      Analytical data listed
       in the data presentation/evaluation
       report tables correctly
       presents the values listed
       in the lab data pack
           a)  Values	  	   	  	
           b)  Units  of measurement	 	   	  	
           c)  Significant figures	   	   	  	
II.     The information presented in
       the tables in the data presentation/
       evaluation report are verified
       from the analytical results
       presented in lab data pack	
III.    Can the tables in the data
      presentation/evaluation report stand alone?
           a)  Titles and headings	  	
           b)  Explanative notes 	  	
NOTE:  (D  QC review personnel must be independent of those who tabulated the analytical
             lab data.
        (2)  Initial only when review comment is dispositioned.
        (3)  Continue on reverse side if necessary.


        Review Approval; QA Representative Initial/Date   	/	

-------
                                                             4/12/3*
                                                             Rev. 0
                               FIGURE  2.2-6                Page 9 of 9
                          TECHNICAL DOCUMENT
                            RECORD OF REVIEW
Reports will not be signed for transmittal to a client without a copy of the Record
of Review attached to the report following the cover sheet. The Record of Review
is not transmittted to the client.
Document Title:
Project Name:
Project Number:             	Brie:
Document/Report Number:  	
Revision Number:           	Due Date:
Report Status ( ):           Draft	   Final
Author/Project Manager:    	
Correspondence Date:       	
                                Approval*
Reviewer                        (Initial)               Date
Author                          	         	
Project Manager                 	         	
Chief Project Manager	         	
Health 
-------
     QUALITY ASSURANCE
photographs  shall be  taken  at various locations  to document conditions  and
provide proof of potential hazards.  During sampling activities, photographs must
be taken to document sample locations and help demonstrate that samples were
properly obtained. Subjects of interest for which a  photo may be taken are listed
below:

1. Sampling  locations.
2. Sampling  activities.
3. Over-all views of the site,  showing  physical characteristics  such as ponds
   and hills or man-made features such as roads and buildings.
4. On site and adjacent land use.
   Entrances, fences, access roads and gates.
   Posted notices and signs displaying ownership, permits, land use, etc.
   Drums or  stockpiles.
           5.
           6.
           7.
           8. Leachate seeps, pools, discolored water or oil-stained soil.

           A 35-mm color print and slide should be taken of each subject of interest.  A
           polaroid-type camera is a recommended back up.

           Avoid using  unusual filters,  lenses or films.  If these  are  used  for any  reason,
           document the reason and specify  the equipment used in the field logbook.   All
           photos are  to be documented chronologically  in  a  tabular form  in  the field
           logbook.   Documentation is illustrated in the following  example:
Date
Time Photographer  Sample //  Roll //  Frame // ID //    Description of Photo
mm/dd/yy  0945    A.Thomas     123
mm/dd/yy  0950    A. Thomas     123
                             IP
                            Print
                             IS
                            Slide
J. Smith &. B. Jones
sampling at //I Main
Street.  Looking SE.
Note dump in back-
ground.
           In accordance with the example above, please note the following guidance when
           generating a photo log.

           o  Indicate  the  time when  photos and slides  are taken using the 24-hour clock.
              Example:  3:00 pm would translate to 1500 hours.
           o  When applicable, a sample  number should be referenced on a site  sketch or
              photo location map.
           o  When indicating the film roll number, use a suffix of a P or S to indicate print
              or slide film respectively.

-------
QUALITY ASSURANCE
      o   Indicate the sequential frame numbers for both  slides and prints. The frame
         numbers  in the photo  log  will be chronological  but may not be in  sequence
         with the number sequence indicated on the developed  slide or print negatives.
      o   The  description of photo  should be  detailed enough to describe  the scene
         depicted.
      o   If practical, include in the  photo  some object to indicate  scale.
      o   A sign indicating site name, sample number, date and  time may be included in
         the photo.  This will avoid confusion in the event photos or negatives are mis-
         ordered or misplaced.
      o   Label the photo or slide with ID number, site name, date  and  description.

Mapping


Maps can be invaluable  in the planning of field work and  in the documentation of  that
work.  However, it is important to keep in mind that maps prepared in the office or in
the  field are evidentiary documents and must be  treated with the same  care and
quality assurance considerations as other evidentiary  documents.

Whenever possible, site maps should be obtained or prepared prior to  site visit. Work,
safety and sampling plans are much easier to describe with the use of various types of
maps.  It is also easier  to mark site features on a  map during site inspections than to
attempt   verbal  descriptions  or to  make  many   quick sketches  (although  verbal
descriptions and sketches  are helpful for  confirmation of details). Site features  that
should be identified on maps include (but are not limited to):

      1.  location of wastes, drums,  stained soil, tanks, etc.

      2.  physically hazardous areas

      3.  sampling and monitoring locations

      '4.  buildings and man-made  features

      5.  areas of stressed vegetation

      6.  points  of entry  and egress

      7.  areas of suspected contamination


Figures  2.2.-7  to  2.2-14  illustrate various  types  of maps  typically  used   for  site
inspections. Site maps may be  obtained from the site owner or manager  (these tend to
have the  best detail), or can be developed  from topographic maps, tax  maps, or  road
maps.  A rough map is  sufficient prior  to  site work,  and can be completed  as work
progresses.  In  some cases, a particularly detailed  map  may  need to be simplified to
make one area or aspect of the  site clearer.

After  work is completed, the  site  map should be  re-drawn neatly,  utilizing  drafting
methods if possible. In addition to a detailed site map, other types of maps which may
be useful in work and sampling plans are:

-------
      1.  Regional maps showing the site's relationship to surrounding areas

      2.  Emergency maps, showing directions to hospitals, fire houses, or telephones

      3.  Topographic maps

      4.  Geologic, groundwater, or soil  maps,  to  help the reader understand complex
         site conditions


These maps may be combined in different way  to  show many features on a single map.
For instance, a topographic  map can be  used as base map for the regional setting and
emergency routes combined.

If a  map is to be sketched in the  field,  be  sure the map is  clear and all features are
labeled.   Use established  mapping  symbols whenever  possible  (See  Figure  2.2-15).
Indicate  landmarks which  can  be identified  on  other  maps or aerial photos.  For
example, a building corner makes a better  landmark than a  forked tree, because the
building  may be found on  photos or topographic  maps, and there is  less chance for
confusion and error.

In any map, be sure to:

      1.  indicate north

      2.  indicate scale  (if possible, measure  some feature of the site which can be
         used  later to reflect scale, such  as  the length of a  building, diameter of
         standing tanks, width of a road, etc.).

      3.  clearly label  all features  and include a legend if symbols are used

      '4.  indicate flow directions of streams

      5.  indicate direction of slopes

      6.  be as specific as possible, for instance say "blacktop paved road" rather than
         simply "road"


Remember the  site may  be  re-visited  sometime in the  future, and someone else may
have  to find your precise  sampling locations.


2.7   RECORDS

      Approved  QA   checklists   and   logs  are   maintained  in  the  project file.
      Photographs, negatives, maps and other quality assured documents are also to be
      kept in the project file.

-------
1 — '•-«' \ <„— - — -
\YYlirU:
|

3id£ .
,
Aj\jp \ M



t)
               FIGURE 2.2-7

-------
T]
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3J
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to
k>
i
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                                           VALLEY BROOK AVENUE
                            MEADOWS .„;.
                              '"' ••NJM3-S2
                           ..  "'  k NJM3-SW2
                      ,   ' NJM3-SW 1^
                      " -.     NJM3-S1
NJM3-S4
                                                       OLD
                                                   FOUNDATION
            A L 1 Y L CHI
OMlOt f \
TANK 3 V_^
                                                                 NJM3-S6
                                                     MAINTENANCE
                                                      BUILDING
                                                SAMPLE LOCATION MAP
                                                    (NOT TO SCALE)
                                                                            PAVED
                                                                            DRIVE
                                                                                     .NJM3-S6
                                                       LEGEND:
                                                       • SOIL SAMPLE
                                                       B SEDIMENT SAMPLE
                                                       A SURFACE WATER SAMPLE
                                                               IMUS
                                                               CORPaRATTOKI
                                                            A Halliburton Company

-------
                                                          .--tt:.
Tl

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c
33
m
to
 I
 '  ',' \   F::"

                  Vf.'".-   /   ^

-------
   PVAc
TANK FARM
                                                                 DIRT ROAD

                                                                 ACCESS ROUTE
                                                               X PARKING LOCATION
                          (NOT TO SCALE)

                                 FIGURE 2.2-10
                                                                 _J CCDRPORATXDN
                                                                  A Halliburton Company

-------
  PVAC
TANK FARM
                                 LEGEND:
                                 • SOIL SAMPLE
                                   WELL SAMPLE
          SAMPLE LOCATION^ MAP
 rjus
A Halliburton Company
                FIGURE 2.2-11

-------
                                                                               WELL c
TANK FA»M
                                                       PHOTO NUMBER AND
                                                       DIRECTION OF SIGHT

                                                            LOCATIONS
                    PHOTO LOCATION MAP
                                                                  A Halliburton Company
                              FIGURE  2.2-12

-------
TANK FAWM
                                         S-3\*'  BORROW PIT

                                   LAGOON B
                                                  LEGEND:
                                                  • SOIL SAMPLE LOCATIONS
                                                        LOCATIONS
                  SAMPLE LOCATION MAP
                       FIGURE 2.2-13
                                                              A HaHiburton Company

-------

                                    E5.__»--^-H£?
                                   • t- * -v	- - ^-

                                   d&uTiCs-^:
(QUAD) BELVIOERE, N.J.
                SITE  LOCATION MAP









                   3CALE:  1'»2000'




                   FIGURE 2.2-14
     FIGURE  1


  IMUS
  CXDR=CDRATOSI
A Halliburton Company

-------
                   UNITED STATES
        DEPARTMENT OF  THE  INTERIOR
               GEOLOGICAL SURVEY
                                                                               TOPOGRAPHIC
                                                                  MAP INFORMATION AND  SYMBOLS
                                                                                 MARCH 1978
o
o
o
<
u
                                            QUADRANGLE MAPS AND SERIES
        Quadrangle maps cover four-sided areas bounded by parallels of latitude and meridians of longitude Quadrangle size is given in
            minutes or degrees.
        Vtap series are groups of maps that conform to established specifications for size, scale, content,  and other elements
        Map scale is the  relationship between distance on a map and the corresponding distance on the ground.
        Map scale is-expcessed as a numerical ratio and shown graphically by bar scales  marked in feet, miles, and kilometers
                                             NATIONAL TOPOGRAPHIC  MAPS
Series
•:-mmute
"'-. * 1 5-minule
Puerto Rico "^-minute
5-mmute
Alaska 1 63.360
Intermediate
U S 1 :50.000
I S 1 1.000.000
Antarctica I 250 000
Antarctica 1 500.000
Scale
14.000
i 15.000
:o.ooo
6i 500
63 J60
100.000
:50.ooo
1.000.000
iso.ooo
1 500000
1 inch represents
:.000 feet
about 1.083 feet
about 1 667 feet
nearlv 1 mile
1 -niie
nearlv I 6 miles
nearlv 4 miles
neartv 16 miles
nearly 4 -niles
nearly 8 miles
i centimeter
represents
140 meters
-50 meters
200 meters
615 meters
nearlv 634 meters
! kilometer
I 5 kilometers
10 kilometers
15 kilometers
5 kilometers
Standard
quadrangle si«
' latirude-longtrudei
"^ * ~ i mm
Tli " 15 mm
'"ix ^ mm
:5x 15 mm
1 5X 10 to 36 mm
30*60 mm
1'* ? or ]•
4°*6"
l"x 3' to 15°
rx TV
Quadrangle
ire a
square -nuesi
49 to *n
98 to 140
•1
*- 'o is:
10" to 131
1 568 to 1140
4 580 to « 1*3
"i.~i* to o:. -59
4 089 to 1 336
13 I "4 to 30.462
                         CONTOUR LINES  SHOW LAND SHAPES AND ELEVATION
The shape of the land, portrayed by contours, is the distinctive characteristic of topographic maps
Contours are imaginary lines following the ground  surface at a constant elevation above or below sea level
Contour interval is the elevation difference represented by adjacent contour lines on  maps.
Contour intervals depend on ground slope and map scale. Small contour intervals are used for flat areas; larger intervals are used
     tor mountainous terrain.
Supplementary dotted contours, at less than the regular  interval,  are used  in selected flat areas.
Index contours are  heavier than others and most have elevation figures.
Relief shading, an overprint giving a three-dimensional impression, is used  on selected maps
Orthopliotomaps.  which  depict terrain and other map features by color-enhanced photographic images, are available for
     selected areas
                             COLORS  DISTINGUISH  KINDS  OF MAP  FEATURES
Black is used for manmade or cultural features, such as roads, buildings, names, and boundaries.
Blue is  used tor  water or  hydrographic  features, such as lakes, nvers.  canals, glaciers, and swamps
Bruvvn is used tor relict or hypsographic features—land shapes portrayed by contour lines
Green  is used  tor woodland cover, with patterns to  show  scrub, vineyards,  or orchards
Red emphasizes  important  roads and is used to show public land subdivision lines, land grants, and tern.e  and field lines
Red tint indicates urban areas,  in wnich only  landmark buildings are shown.
Purple is used to show office revision from aenal photographs  The changes are  not field checked
                             INDEXES  SHOW  PUBLISHED TOPOGRAPHIC MAPS
Indexes For each  State. Puerto Rico and the Virgin  Islands of the United States, Guam. American Samoa, and Antarctica
     show available published maps. Index maps show quadrangle location, name, and survey date  Listed also are special maps
     jnd sheets, with prices. map dealers. Federal distribution centers, and map reference libraries, and instructions tor ordering
     maps  Indexes and a  booklet describing topographic  maps ore  available free  on request.
                                       HOW  MAPS CAN BE  OBTAINED
Mail orders tor maps ot areas east of the Mississippi  River,  including Minnesota. Puerto Rico, the Virgin Islands of the United
     States, -inu Antarctica should be addressed  to the Branch of Distribution. U. S  Geological Survev. I 200 South Eads Sireet.
     Arlington. Virginia 22202.  Maps of areas  west ot the Mississippi River,  including  Alaska. Hawaii.  Louisiana.  American
     Samoa, anJ Guam should be ordered from the Branch ot Distribution. L . S Geological Survev  Bo\ 25286. Federal Center.
     Denver. Colorado "<0225  A single order combining both  eastern  and western  maps may be placed with either office
     Residents ot  Alaska may order Alaska maps or an index, tor Alaska trom the Distribution Section. I   S. Geological Survev.
     Federal BuildinK-Box  12.  101 Twelfth  Avenue,  Fairbanks. Alaska *WOl. Order by map  name. State, and series On an
     order amounting tcr S300 or more at the  list price, a  30-percent discount is  allowed.  No other  discount is applicable
     Prepayment  is required and must accompanv each order Pavment  may be made by money order or check payable to the
     L'   S Geological Sunev  Your ZIP code is required.
Sales counters are maintajned m the following U  S   Geological Survev offices, where  maps of the area may be purchased  in
     person:  1200 South Eads Street. Arlington. V a . Room 1028. General Services Administration Buildinz. 19th & F Streets
     NW. Washington. D  C . 1400 Independence Road. Rolla. Mo  . 345  Middlefteld Road. Menlo Park. Calif.. Room 7638.
     Federal Building. 300 North Los Angeles Street. Los Angeles. Calif . Room 504. Custom House. 555 Battery  Street. San
     Francisco. Calit  . Building  41. Federal Center.  Denver. Colo .  Room 1012. Federal Building. I%1 Stout Street. Denver
     Colo.. Room 1C45. Federal Building.  I 100 Commerce Street.  Dallas. Texas: Room S105. Federal Building,  125 South
     State Street.  Salt Lake Citv. Utah. Room  IC402. National Center.  12201 Sunnse Vallev Drive. Resion, Va .  Room 67S.
     U.  S. Court  House. West 920 Riverside Avenue. Spokane. Wash..  Room  108. Skyline  Building. 508 Second Avenue.
     Anchorage.  Alaska: and Federal Building.  101  Twelfth Avenue.  Fairbanks.  Alaska.
Commercial dealers sell U  S. Geological  Survev maps at  their own prices. Names and addresses of dealers are listed in each
     State index.
0
0
                                                                                                                           ui
                                                                                                                           O
                                                  OOS  S9 t  31VDS  J.OOJ
                                            FIGURE  2.2-15

-------
                                        TOPOGRAPHIC  MAP  SYMBOLS
                                           ,4RiA"CN5  vV'ut-  S£  FOUND CN OLDER MAPS
i:;-;>r  . gp^j  -3ra sjr'ace
3-' :: - •,  -cad  ~3'd or  -nnroved s^r'ace

: 3:  • c -?r : ;• - 5 •. •,;: c ~ 3 ~•?~^ - • .-:AP

^a.  - i-Aav  d - J "g sf o 25 "eet :- ess
j3>  ^ gn^3y  : .-d'~g str z exceed ^g 25 'eet
                                                                     Bo',nda'"?s  National
                                                                        5:ate
                                                                        Court,. 3ansn  T,unic
                                                                         "C^'CC'3!ed   t/. '' age  '0<
                                                                        = e;e',3! ;- Nat :^~a' jr S'a'
K>3":* ;3«e  5 ~g:e  fac< anc ^u  • O'e :-ac
^3  ':ac   i:-ee- ar-d :a' .^e
5- :;e  -zi-  i"?  '}•  'C3d
                                                                    o^vnsn.Q or range 
-------
. 3

-------
  BACKGROUND DATA COLLECTION
  AND PRELIMINARY ASSESSMENT
  2.3.0   INTRODUCTION

         Background  file searches are  performed and data are  reviewed  prior to  any
         planning of field work. Some of the information may have been summarized in a
         preliminary assessment, however additional data gathering not reported in the PA
         will probably be necessary.

  2.3.1   PURPOSE

         The collection of background data should be conducted keeping in mind that the
         goal of this information  search  is to  answer as much  of the questions  the HRS
         model asks as possible, to identify the areas which require a  sampling program or
         site visit to complete, and  to  prepare  a safety plan.    It  is  necessary for the
         persons doing the information search be familiar with the HRS model.

         Of particular  interest to  the  HRS  are the  potential  targets  which  may  be
         adversely  affected  by the  site.   These include  on-site workers, the general
         public,flora and fauna and those which may have contact with  contaminants via
         air, surface water, or groundwater.

         The purpose of  a preliminary assessment is to  provide the  preliminary  data and
         evaluations required to determine what action to undertake  next; e.g., no further
         action, emergency  action,  or  additional  investigation.    The objective   of  a
         preliminary assessment is to characterize the  site by  examining the  following
         areas:

         1.  the hazardous substances present
         2.  pollutant dispersal  pathways
         3.  types of receptors
         4.  facility management practices
         5.  potential responsible parties

         The first four of these areas should be considered in order to properly assess the
         hazard present at the site.  The fifth area will be  important should the  state or
         EPA attempt to recover from the responsible parties the costs incurred.

         In addition to obtaining information for the hazard assessment of the site, and for
         the development of  work  and sampling plans, information can be collected for the
         completion of a  safety plan.  This includes the location of  the nearest hospital,
         fire-fighting facilities, local ambulance  service, and  police station.  If unusual
         hazards  exist on  site, these agencies may  be contacted prior to field  work to
         prepare them for possible emergencies.

2.3.2     APPLICABILITY

         Figure 2.4-1  illustrates  the generic  areas  that must  be  assessed in  order to
         properly characterize  the hazard associated  with a potential hazardous waste site.
         These are  used  in all  stages  of  site  characterization.   However,  since  the
         preliminary assessment occurs early in the  process, it  often identifies data gaps
         and provides guidance for  subsequent  field  work.   The four areas  of  hazard
         assessment are described  below:

-------
                                                 FIGURE 2.4-1
                                                                                                    Page 2 of 60
HAZARDOUS SUBSTANCE
  CHARACTERISTICS
o Hazard Potent 1*1
o Quant it iei
o Phyaical Character-
    i«t ici
o Environmental
     POTENTIAL
POLLUTANT DISPERSAL
     PATHWAYS
  o Geological
  o llydrolofical
  o Honitorin| Data
  o Cllnatolo|ical
      RECEPTOR
   CHARACTERISTICS
o Receptor Identity
o Proximity
o Receptor Senaitivit;
o Epl demlological
 SITK  HAHACEMEHT
    PRACTICES
o Security
o Containaient  Prac-
    ticea
o Treatment Prac-
    tice*
o General Manage-
    ment Quality
           GENERIC AREAS OF HAZARDOUS SUBSTANCE SITE ASSESSMENT

-------
BACKGROUND DATA COLLECTION
AND PRELIMINARY ASSESSMENT


Characterization of Hazardous Substances

Hazardous substance  characterization  is perhaps the most important component of the
assessment.  The complete identification and quantification of all hazardous chemicals  or
materials present at a site are rarely achievable.  Nevertheless, it is important to try  to
identify hazard characteristics such as human and environmental  toxicity,  flammability,
infectiousness,  water  solubility,  volatility,  soil-binding  affinity,  and  persistence.   In
general,  substances of high  hazard activity, long  persistence, large  quality,  or high
migration potential tend to present high risks in uncontrolled situations.

Identification of Pollutant Dispersal Pathways

The  identification  of  dispersal  pathways  involves an  examination   of  the  physical
environment of the site in order to identify  routes of exposure to receptors.  In addition,
it  may involve a search for existing  monitoring data  that could  support suspicion  of
pollutant  movement.   Figure 2.4-2 illustrates some dispersal  pathways.   Geologic and
hydrologic site  features are generally  the  most important.  Porous geologic formations
promote  subsurface migration, especially when coupled  with  ground water, which serves
as a transporting medium.   Thus,  soil  and  bedrock type and depth  to  ground water are
important to below-ground pollutant movements.  Climatologic  features such as rainfall
and prevailing wind  direction affect  surface dispersal by  promoting  water and  wind
erosion of contaminated  soil particles.   In addition,  rainwater  can  transport surface
pollutants vertically through  soils to groundwater.


Identification of Receptors

Receptor  identification  involves   determining whether any  sectors  of  the public  or
environment are subject to exposure to  hazardous substances. Since  water  movement is a
major  transporting  mechanism, this effort  commonly includes the identification of  local
water resources threatened by toxic chemicals or other site hazards. In this way, the risk
of exposure of the  local  population is  evaluated.  Critical natural habitat areas such  as
those  occupied  by  endangered species should also  be  identified.   In addition,  land-use
patterns  around the site should be identified.  Food-producing areas such as farms, cattle
ranches,  dairies, and recreational fishing and hunting  areas could provide the link  between
toxic contamination and human exposure.
Characterization of Site Management Practices

The characterization  of site management practices at waste disposal facilities includes a
review of site security  practices and specific disposal or containment procedures, such as
the  use  of   impermeable   liners,  leachate  collection  systems,  waste  compatibility
assurance, and gas collection systems.

-------
                                             FIGURE  2.4-2
                                                                                                                                              of (,()
                                                       Aliborni
                                                       Pinicln
                                                               Deposition on Cfopi.
                                                              Indiucl Hum in fipoiuii
                                                                  vii Ingiilion.
                                                             Bioiccumulilion in Cuiinj
                                                           Gimi tnd Agriculluril
        Ouicl
Humin ind (nviiorvninlil
           vii Dirmil
  Conlicl ind Inhililion
   ol Piniclti u Git
                                                                                           fiih Sunmi
                                                                                          Bioictunwlitlon.
                                                                                        Hum in Eipoiuii *ii
                                                                                      Fuk mil Sidifliinl Conlicl
                                                                                       a O'uicl Utt ol Will/
                                                        Surlici fronon ol
                                                          Conliminilid
                                                          Soil Pirtitlii
Oownwild Migdlion
  in Soil Moiiiuri
                  Aquifer Coniiminilion
                                            HaiBfdous-Wajte Dispersal Pathways

-------
  BACKGROUND DATA COLLECTION
  AND PRELIMINARY ASSESSMENT


  2.3.3    DISCUSSION

           The information that is  obtained  from a preliminary assessment undergoes an
           interdisciplinary evaluation and  results in a  qualitative estimate of  the  hazard
           potential at the site.   It is  useful  to  keep in  mind the EPA  Hazard Ranking
           System when determining the hazard posed  by an  individual  site.  The Hazard
           Ranking System (HRS) is the EPA authorized system for ranking hazardous waste
           sites.  It is used as a means for applying uniform technical judgement regarding
           the potential hazards presented by a  site relative to other  sites.  The HRS will be
           discussed in greater depths later in this course.

2.3.*      PROCEDURE

          Compilation of  a background file  begins  with the collection  and  review of
          pertinent data regarding the site.  The review of pertinent information serves to
          establish the  specific  site inspection needs  and identify missing  elements be
          determined at the site.

          Examples of the type of information sought are described in Table 2.

          Data sources  most frequently  used for preliminary  assessments are provided in
          Tables  3 through 6.   These  lists represent  starting points;  they should  not be
          considered complete  lists of all sources available.  Additional  data sources follow
          these lists.

          In practice, it would  be unusual if even half of these  sources were checked during
          a preliminary assessment.    However, it   is  important  to  note   that  these
          information sources exist. Many will  have to be checked in order to complete the
          site inspection that will ordinarily follow the preliminary assessment.

          Detailed  references  should be maintained for all  sources used, whether  texts,
          journals, maps or personal communications. (See Figure 2.^-3.)

-------
SUBJICT
      BACKGROUND DATA COLLECTION
      AND PRELIMINARY ASSESSMENT
                                            NUMBKR
RIVI8IOM
                              6  of  60
•FFtCTIVl DAT!
                                      TABLE 2
                                  INFORMATION NEEDED
                          o  The identity of the site owner
                             or owners

                          o  Right of access information

                          o  The types, quantities, and disposal
                             methods of hazardous waste present

                          o  Accessibility to potential sampling
                             sites

                          o  The local topography and drainage
                             patterns

                          o  The local hydrogeology

                          o  The location of any nearby or onsite
                             potable or monitoring wells

                          o  Records of public complaints regarding
                             problems associated with the site or
                             drinking water

                          o  Past regulatory action at the site
                          o  Locations and numbers of the nearest
                             hospital and fire department

-------
SUBJECT
BACKGROUND DATA COLLECTION
AND PRELIMINARY ASSESSMENT
NUMIEff
RrvtaioM
'*<» 3 or 60
emcTive OATI
                                 TABLE 3
      Sources of Information for Characterization of Hazardous Substances
Review management records

a.  Waste inventories
b.  Storage inventories
c.  Shipment manifests
d.  Permits

Search for Waste Generator Records

Interview

a.  Site Personnel
b.  Neighbors
c.  Government Inspectors

Review Official Agency Files

a.  Permit Application
b.  Site Inspection Reports
c.  Sampling or Monitoring data

Consult Toxicology and Hazardous Substances References

a.  Chemical Hazard Response Information System
b.  Hamilton and Hardy, Industrial Toxicology
c.  Sax, Dangerous Properties of Industrial Materials
d.  Patty, Industial Hygiene and Toxicology
e.  ACGIG, Threshold Limit Values for Chemical Substances and
    Physical Agents in the Workroom Environment.
f.  Miedl, Hazardous Materials Handbook
g.  Hauley, Condensed Chemical Dictionary
h.  The Merck Index
i.   CRC  Handbook of Chemistry and Physics
j.   NFPA Hazardous Materials Manual

Consult Industrial Processes  References

Professional Organizations

a.  American Chemical Society
b.  American Institute of Chemical Engineers

-------
     BACKGROUND DATA COLLECTION
     AND PRELIMINARY ASSESSMENT
                                      TABLE
                       Sources of Information for Identification of
                             Pollutant Disposal Pathways

1.    Geological and Soil Data

     a.   USGS Topographic Maps (Identifies surface drainage  features)
     b.   Other USGA  Publications (Geological and water resources)
     c.   State Geological Survey Offices
     d.   USDA Soil Conservation Service  Publications and Soil Surveys
     e.   Drillers' Logs

2.    Hydrology

     a.   USGS Water  Resources Reports
     b.   USGS Stream Flow Records

3.    Climatological Data

     a.   National Climatic Data Center (Ashville, N.C.)
     b.   Meteorology  Departments of Local Universities

'4.    Local Health  Departments

-------
SUBJECT
     BACKGROUND DATA COLLECTION
     AND PRELIMINARY ASSESSMENT
                                             NUMBER
REVISION
                       PAOC  10 Qf 60
                       EFFECTIVE DATE
                                      TABLE 5



                  Sources of Information for Receptor Characterization


     1.   Maps and Aerial Photographs

          a.    USGS
          b.    State Department of Transportation
          c.    Local Planning Groups
          d.    Utility Companies (right-of-way maps)
          e.    County Road Commissions
          f.    County Soil  Surveys - USDA
          g.    Aerial Survey companies

     2.   Local Water Departments

     3.   US Public Health  Service Files and Publications

     *.   County Agricultural Extension Offices

     5.   Federal and State Fish and Wildlife Departments

     6.   Local Universities

     7.   Local Naturalists  or Environmental Groups

          a.    American Littoral Society
          b.    Audoban Society

     8.   Medical Reports

     9.   Local Newspapers

     10.  Local Weil Drillers

     11.  GEMS Population  and Housing Data Retrieval System (available through US EPA
          only)

-------
SUBJECT
BACKGROUND DATA COLLECTION
AND PRELIMINARY ASSESSMENT
NUMBER
REVISION
PA« 11 OF 60
EFFECTIVE DATE
                                TABLE 6



           Sources of Information for Site Management Practices



1.     Site Records

2.     Personal Interviews with Site Workers

3.     Federal, State and Local Regulatory Agency Files
      (Routine Inspections or Compliance Violations).

4.     Aerial Photographs

5.     Occupational Safety and Health Administration
      (OSHA) Files and National Institute of Occupational
      Safety and Health (NIOSH) Files

6.     Fire Departments

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                                                 Page 13 of 60
                  DRAFT

    GRAPHICAL EXPOSURE MODELING SYSTEM

                  (GEMS)

               USER'S GUIDE
              Prepared for:

   U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
       EXPOSURE EVALUATION DIVISION
                Task No.4
          Contract No. 68016618
     ^William Wood - Project Officer
              Hall - Task Manager
               Prepared by:

       GENERAL SOFTWARE CORPORATION
           8401 Corporate Drive
         Landover, Maryland 20785
         Sutmitted:  June 25, 1984

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                                                              Page 15 of 60
           MASTER AREA REFHTOCZ FILE (MART)  OP THE 198i CBGOS

Sourea

     The Master  Area  Reference  File (MARF)  is a  proprietary  product of
Donnelly Marketing,  Inc., a subsidiary of  Dunn  and Bradstreet,  and is
available only to EPA users  and to contractors engaged in EPA projects.

Description

     The complete  corrected MAW of the 1980 Census, with geographic
coordinates for small  geographic  areas,  is installed  for  GEMS  on a
separate disk pack.  It consists of four subfiles, one for each major
census geographic region, and is available  to users  when that disk  pack is
mounted.  The file has a variety of  location  identification information,
including  region,  state, county, place,  census  tracts and enumeration
districts or  block  groups  (See Figure  C-l  for illustrations).   It  also
contains population count  by  race, the number  of occupied and  owner-
occupied housing  units, group quarters, and number of  families for  all the
enumeration districts/block  groups  for  the continental United States,
Hawaii, and Alaska.

     CEDPOP,  a  subset of  the  MARF  of  the 1980 Census, is accessible
through GEMS.  In addition to total   population and household counts, the
file includes geographic  coordinates  for the population-weighted centre id
of each census block group or enumeration  district  (BG/ED)  in the file.

Use

     The complete MARF  80  Census  file,  installed  in GEMS on a separate
disk, is expected to be  used heavily by  GEMS  users to  identify  household
and population by racial  groups at any required geographic  level.  County
aggregate populations  have already been created from this file.

     CEDPOP was  interfaced  with ATM80  in GEMS to  provide  estimates of
population  sizes  exposed  to  concentrations of  airborne  chemicals around  a
release site and  with  BOXMOD80 to provide population estimates within area
source regions.   The population centroids  are  identified, and populations
are accumulated  in sectors  (typically the  sixteen  wind  direction sectors)
surrounding  the  center  point within a  user-specified  number  of radial
distances out from the center.

     The  CEDPOP• file also is  accessed  by  CENSUS  DATA and   RADII-5
procedures under the GICDATA  HANDLING  operation  in GEMS.   CENSUS DATA
accumulates  population  and   housing  counts  by up  to  ten  user-specified
radial distances and  from one-to-sixteen sectors.   The PADII-5  program
tabulates  the  same  information 'except  housing counts) and displays  the
cancroid locations  for -isar-specified circular distances  around a canter
DO inc.

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 GAGE
 IFDDIR
IFDIND
Master Area Reference File
(MARF) 1980 census
parameters:  agriculture, climate,
vegetation, forestry,  air quality,
land,   natural  areas,   population,
water  ojiality,  terrain  (soils)  and
wildlife.

Th«  GAGE dataset contains primarily
stream  flow  rates   monitored
consistently by  approximately  99,500
stream gaging stations throughout the
country, and some estimated flows.

IFDDIR  contains  industrial facility
data for  approximately  28,000 direct
dischargers excluding publicly owned
treatment works
HD31C contains  limited   industrial
facility data  for  approximately
12,000  indirect dischargers  which
discharge through  other  facilities,
usually POTWs.

This dataset contains a  variety of
location  identification information,
population count by race,  the number
of  occupied  and  owner-occupied
                    TABLE 2-2.  GEMS Datasets  (Continued)
       DATASET NAME
               DESCRIPTION
  Meteorological Data
  Publicly Owned  Treatment Works
  (POTWs)
  number   of  families  for   all    the
  enumeration district/block  groups  for
  continental USA, Hawaii,  and Alaska.

  Several meteorological data files  are
  contained  in  this  category:   (1)  the
  Stability  Tabular  Array (STAR)  data
  file has meteorological  data  for  334
  first order  weather  stations  in  the
  continental  USA,  (2)  A master  index
  file  (STARSEL),  and  (3)  An  auxiliary
  file (AUX).

  This  dataset  contains  1982  survey
  data on  the unit  treatment process,
  the  influent and effluent and hour
  rates,  and the  population   served by
  33,000 publicly  owned treatment works
  around the country.

-------
o
I
en
     SMS A
                              Urbanized
                              Araa
                                               Central  City
                                                      Census
                                                      Tract
                                           Blockt
                                           Group
Block
                   Inside  Urbanized  Area
    The entire SMSA  la subdivided into  cenaua tracts.

    blocks and block groups do not have symbolized boundaries
    ae do the other  ^reaa, but are identified by number.
                                                              County
                                      Hlnor Civil
                                      Dlvltloo
                                              •    T\
                                                                                                      DUtclct
                                                                           '. Mace Over 10.000 Population
                                n
                 I
                                                                    Place Under 10.000
                                                                    Population
                      EnuaeratIon
                      District
Block • .
Numbering
Area
                                                                                                       Hock
                             Outside Urbanized Area
                                                             •lock*
         Figure C-l.   Geographic  Hierarchy Inside and Outside Urbanized Areas  (UA's)
                                                                                                               13
                                                                                                               (a
                                                                                                               OQ
                                                                  ON

                                                                  O

-------

I I-IG V.'i stv.ooil Houli.
                       ••i
                               I   \
       '******_*'*' *•*' '*'
                                    \
             //////// / 7 I  L
'fl-—/-
/ / / /
/  / /  r
                                   \ \ \ \
                                 \ \ \ \ \ \
                                 \ \  y \ v
           XXX//////
\  \ \ \ \ \ \
                                 V A \ V
                    /L7T
 \ \ \ \
        //////// n
 \\\\N
     ''////////11 \
                             CATALOG OF

                             U.S. GOVERNMENT

                             AND R&D DOCUMENTS

                             ON MICROFICHE
                                   Page 17 of 60

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                                                                                                 Page IS of 60
Aerial photographs have become an invaluable tool
for all those interested in studying the surface of
Earth: scientists, engineers. land-use planners.
environmentalists, cartographers, and many others.
  The great boom in aerial photography in the past
few decades has produced millions of photographs
of the United Slates. These range from high-
alcitude pictures of large areas to low-level photos
showing smaller section! with greater detail such as
cities, towns, and rural areas. Almost all of this
vast store of aerial photographs is readily available
for purchase: the price per print depends on its size
and type.
  Aerial photography records maintained by the
U.S. Geological Survey (USCS) go back many
years, is early as the late 1930's for certain areas.
Most early photographs  on record were taken on
black-and-white film. Later  the use of color and
color-infrared film was introduced.
  Photos are available from low-altitude flights—
often below 10.000 feet. These photos show detail of
towns, streets, houses, and even backyards. Other
photos were taken at high altitudes, some as hieh as
60.000 feet or more. These show less detail but cover
a large area. If  you ire  interested in photographs
                                         How   To   Order
                                         Aerial   Photographs
                                        U.S. Department of tfia Interior
                                        Geological Survey
                                        National Cartographic
                                        Information Center (NCIC)
                  .
V.V      ^i^_ '---'->  *- -'"1 "
Htqn-UMua* color-infrared cxxno, 1.65.500-
                                                                                 Higti-aimud* cdot photo. l:32.75O-scal«
                                                               .\
                              "^'-1  r"J^   taken from the very highesc altitudes available ask tr
                               --,./.;.-   j  ,-U.S. Geological Survey for information on satellite
                              ,', ,!;. ~ . ]   images.
                                 ' ',: ' '•     People want  aenal photos for different reasons
                              ,	•-••- ."   Some want them tor decorative purposes, such a^ .
                                • ij,  '    framed photo on the  wall or under ;he class cop o;
                              i;'.    ~"    a table. Others  might warn to examine some :err^:
                                         feature, or to determine whether rains ha\c erovii-
                                         a panicular hillside.  Still others micht  'Aani older
                                         aenal photos to study changes in the locale o\er tr
                                         years. The National Cartographic Information Cen..
                                         (NCIC). which is pan of the U'.S. GeoIo^icaJ Sun^
                                         National Mapping PrOCTum. can prmide >ou with
                                         assistance in finding the nght aerial photosrapn.


                                         How To Identify the Right Area

                                         Before you order >our aenal photos,  you must
                                         identity the area that you want >hown in the phi1'
                                         If you can send NCIC the geographic coordinate
                                         (longitude and latitude! of the area that sou are
                                         interested in. we will be able to research your
                                         request immediately

-------
 we strongly recommend circling or pinpointing the
 area on a USGS topographic map. If you do not
 have a map. you can obtain a State index to
 topographic maps from NCIC. The index will tell
 you how to purchase the correct map from the
 Geological Survey.
   If you are not able to use a L'SGS  map. you can
 use a State or local highway map. or some other
 suitable map. to indicate the area that you want
 shown on the photograph. Or you can make a
 sketch. The more specific you can be in
 pinpointing the area, the better. Indicate whether a
 specific feature, such as a lajce. landmark, house.
 or  crossroads should appear in the photo.

 Enlargements

 The standard print size of an aerial photo sold by
 NCIC is 9"  x 9".
   Excellent results can be obtained by enlarging
 these prints.  Details that are barely perceptible  in
 smaller prints become readily visible  in the
 enlargements. For example, at a scale of 1:24.000,
                                                  i mm UN me pnoiograpn ucpinb i.uuu teet on me
                                                  ground; at 4X enlargement. 1  inch equals 500 feet.
                                                   Enlargements are available  in the following
                                                  sizes:
                                                      2X (18 x  18 inches)
                                                      3X (27 x  27 inches)
                                                      4X (36 x  36 inches)
                                                   Prices range  from S3 to $100 depending on size
                                                  and on whether the photographs you order are
                                                  black-and-white or color.

                                                  How To Order Aerial Photographs

                                                  If you know exactly what photograph you want,
                                                  you can order directly from NCIC or the
                                                  Geological Survey's EROS Data Center.  Mark
                                                  your map or sketch  with the precise  area desired in
                                                  the coverage, fill out the checklist below and the
                                                  appropriate enclosed pricelist/order form, and make
                                                  out a check or  money order for the exact amount
                                                  (prepayment required) to the U.S. Geological
                                                  Survey. Send these  with your name, address.
                      organizational attiliation. and telephone J
                        National Cartographic Information Cenil
                        U.S. Geological Survey
                        507 National Center
                        Reston, Virginia 22092
                        Telephone: 703/860-6045
                        or
                        U.S. Geological Survey
                        EROS  Data Center
                        User Services Section
                        Sioux Falls. South Dakota 57198
                        Telephone: 605(594-6511

                        or contact the followina office:
Aerial Photograph Ordering Checklist

   If you do not have a precise idea of what you
want, please  fill out the checklist below as best
you can and send it *ith your marked map or
sketch to NCIC  A researcher will be assigned to
your inquiry and will advise you on the
photographs available and the cost.
   Please include your davtime or work telephone
number in  all correspondence so that  you can be
contacted if necessarv
Name:
Street address:

City and State .
                                            ZIP:
Telephone: ires): _

           (work):  _

Company affiliation
Soec;f:c Area.

State. 	

Town' 	
                                      County
Ma'*ea map encloses  CH

Section, 'ownsnip. and range (if known)'

Geographic coo-Cir.ates:
                                     Sketch enclosed  D
Feature that you specifically wanl to see'
Black-and-white'  ;	'•

Color-infrared.  LJ
                                     Color  LJ

                                     No preference  Cj
Date of Photography

Year: 	
Time of year, if you have a specific requirement'

Spring: LJ                           Fall: • _

Summer: LJ                         Winter:  L3

Oldest  availaole:  O                  Most recent avaiiacie: Jl

No preference' CH


Level of Desired Ground Detail'
Lew altitude, large scale — Maximum detail: CD

High altitude. small scale — Minimum eetaii  _

Size: (not available for all aeral pr.ciocaprs'

Standard ccrr=c:     9   9   LT

                   3X 1 27" - 27')  H
                                                                                                                          2X(1S' <  :35 .

                                                                                                                          4X ,26    36  >
                                                                             Stereoscooic:
                                                                             Do \ou wanl a series of overlapping cnotos for viewing throucn a ste",
                                                                             Yes  D                              No.  D                 I

                                                                             Purpose.

                                                                             We can advise you c" 'he best selection  avaiiacie if ycu ces:-ce »r.
                                                                             intenc to use tre photograons tor:
                                                  -c-
                                                                                                                   Page  19 of  60 _

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Now Available. . .


LAND  USE  AND

LAND  COVER  AND

ASSOCIATED  MAPS
In the Geological  Survey  Open File

    The Geological Survey  is now  compiling  land use and land cover and
associated maps for the entire United States. These maps will help satisfy
a longstanding need  for a consistent  level  of  detail, standardization  of
categories, and consistent use  of scales of compilation for a type of data
used  by  government  land-use  planners, land  managers,  and  resource-
management  planners. Once the bench-mark series of maps is completed,
updating of the maps  will provide a much-needed tool for  analyzing trends,
problems  in  local  and regional areas throughout the  entire  United States,
and changes in land use patterns.
    The land use  and land  cover maps  are compiled  using a classification
system that  has  i framework of 9  general Level  I  categories that  are
further subdivided  into 37 more specific  Level  II categories.
    The classification system,  as developed  with the assistance of a com-
mittee  of representatives from  the  Geological Survey,  the  National Aero-
nautics  and   Space   Administration,  the  Soil Conservation  Service,  the
Association of American  Geographers, and the International Geographical
Union, can be used with  data from conventional  sources  and from remote
sensors on high-altitude aircraft  and satellites. The system and  the cate-
gories are  explained in Geological Survey Professional  Paper 964, available
from the Survey (see order forml.
    A minimum mapping unit of 10 acres (4  hectares), is used for all urban
areas  and  bodies  of  surface  water. It  is also used for  mapping  surface
mines,  quarries,  and  gravel  pits,  and  in  certain agricultural  areas. A
minimum  mapping  unit of  40 acres US  hectares)  is  used  for all other
categories.
    Aerial photographs and  other remotely sensed data serve as  the primary
sources  used in compiling  the land use and  land cover  maps. Secondary
sources  include earlier land use maps  and  other maps prepared  by (laid-
survey  methods.  The  secondary  source  maps are generally  available  at
larger scales and  for small areas  such  as  parts of  metropolitan rejicns.
After  compilation, the Survey's land use and  land cover maps  are checked
carefully for accuracy.

                        ASSOCIATED MAPS
    Sets  of  ':ur  associated naps are prepared at the same scale as  the
land use ana  land cover maps in order to relate the land use  and land cover
m:DS to other data. For example, land use data cjn be combined  with the
SGCioEconomic  data compiled  by the  Bureau of  the  Census   or  can  be
ccrr.oarcd to  nydrologic data compiled lor hydrologic units. These associated
m:ps are:

          :.i;,P                        CHARACTERISTICS
PC'JT::;i u::iTS
 ^"c;i2G;C UlilTS
Ct'.S'.C CC'J'iTY
  S'jZ3l'il$!Gi'IS
                             Depicts  ccunty  c.-d  Siats  bourdzrus  as
                               sh:.vn  on  U.S.  Geological  Survey  ta;o
                               maps.

                             Delineates hydrclagic units, as est:2lisr,3d
                               by the  Water Ss::urc:s Council :nd p-i-
                               listed  :y tr.e S.;,:/s V/at:r  R3jc':r::s
                               Division on  1 :!5.CCC so:!:  S!:te rr.:".

                             Shows  rr:r:r  ci'.il ii.isirns or  erjiv::;rt
                               areas.  Ce-c'-i  tracts  a!:-a  r3  $!•;  n
                             Ddlin:;::s s'jr:c; :.sn;r:r.;: ;: :  rr.ir.i7.;:.-
                               m::;i.->5  :-. !  s.:3 of -',0 :c:;s  ''.w  ;-.::•
                               t:-:;  ;:r  l:-:s :.!,-i-::-?rjd ':/ Fc::r:l
                               :;s::!:s.  S-:::n:::  o'.vr.er;h:;  r;;its
                               are not ;r:..n.

                   £.',::  MAPS A;:O  ::.:.? SCALES
     1 3  '.-: .;: :rd ':-J  c:v:r and ;$sc:i:::: ~::s :;» i-;-?::!;!  '::;:;
 : :"  ;'  - --;-' ~;:: :l  "'- L1 S G::l;;i::i i.r,:,  :t  sc:ics 01 1 1;0,.:0
 ,1  ncn on  i-,;  rap  r;pre:::.!;  ::cut  ; miUs on ;h« ground)  or 1 i:a.::o
                                           Page 20 of 60
MOO.OOO-scale  planimetric base  maps become available, more  land  use
and land cover and associated maps will be prepared at that  scale.

                   STATUS OF AVAILABLE MAPS
    The land use and land cover and associated maps  currently available
are shown in the "Indei to Land Use and Land Cover and Associated Maps"
published by the U.S. Geological Survey (see order form).

                         ORDERING MAPS
    Master sets of the land  use  and land cover and associated maps for a
particular area are  on open  file  and ire available for reproduction at the
U.S. Geological Survey National Cartographic Information Center unit  that
has responsibility for that area, as shown on the map  below.
    Copies of land use and  land  cover and associated maps are available
on the following types of material to permit a wide range of graphic inter-
pretation and application:
    (1) Stable base film positive, clear or matte.
    (21 Semi-stable diazo foil, matte.
    13) Paper diazo.
Copies of the maps may be purchased from:

    Eastern National Cartographic     Mid-Continent National Cartographic
       Information Center
    U.S. Geological Survey
    S36 National Center
    Reston. VA 22092
    Telephone: (703) 860-6338
    FTS 928-6338
    Rocky Mountain National
       Cartographic Information
       Center
     U.S. Geological Survey
     Box 25046, Stop 510
     Federal Center, Building 25
     Denver, CO 80225
     Telephone: (303) 234-4879
     FTS 234-2326
                                                                                                             Information Center
                                                                                                           U.S. Geological Survey
                                                                                                           1400 Independence Road
                                                                                                           Rolla. MO 63401
                                                                                                           Telephone: (314) 364-3630
                                                                                                           FTS 276-91 07
                                                                                                           Western National Cartographic
                                                                                                             Information Center
                                                                                                           U.S. Geological Survey
                                                                                                           345 Middlefield Road
                                                                                                           Menlo Park,  CA 94025
                                                                                                           Telephone: (415) 323-8111
                                                                                                             'ext241D
                                                                                                           FTS 467-2427
                                                                                            TECHNICAL  INFORMATION
                                                                            Technical information about land use and land  cover  and associated
                                                                        maps may be obtained from:
                                                                                         U.S.  Geological Survey
                                                                                         Geography Program
                                                                                         Land Information and Analysis Office
                                                                                         710 National Center
                                                                                         Reston, VA 22092
                                                                                         Telephone: (703) 860-625S
                                                                                         FTS 928-6256
                                                                              AREAS OF RESPONSIBILITY  FOH U^ilTS  OF THE !IAT;::iAL

                                                                                        CARTOGRAPHIC INFORMATION CENTER

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                                                                                  Page 21 of 60
Order Form

\: = il order form to: U.S. Geological Survey, Branch of Distribution, 12CO South Eads Street, Arlington, VA 22202

Enclosed (find) $	(check or money order payable to U.S. Geological Survey).

P'esse send 	copies of USGS Professional Paper 964 at $0.75 per copy (postpaid) to:
      sena
_ copies of "Index to Land Use and Land Cover and Associated Maps" (free) to:

 Name	

 Street Address	

 City and State	 ZIP Code 	
U.S. Geological Survey
Branch of Distribution
1200 South Eads Street
Arlington, VA 22202
Cr;::al Business
Penalty fcr Private Use, S300
                                       Postage and Fees Paid
                                       U.S. Department of the Interior
                                       INT-413
/Yovv Available,..
             USE AMD
                              AK1D
!n  the  G:-c!cncal Survey Opan File
 ,'oo/c far Land
      2nd  Oihsr Resource Planning
                             and  '.'s
                                                  LAMO USE Af>0 LAND COVER
                                                    POLITICAL 'JN.TS
                                                      HYIROLOG'C U'ilTS
                                   CZ'.'SUS COUNTY SU3CIVIS:Oi,5
                                     EDERAL LAND
                                                 ..-, N e - i -i. r

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                                                                                 Page 22 of 60
    This form is used to request a geographic search for Aircraft data over a point or area
  of interest. Aircraft coverage is not available for areas outside of the United States.

    Data from this inquiry form  will  be  used to initiate a computer Geosearch. The results
  will be returned on a computer listing along with a decoding sheet, from which
  photography can be selected and ordered.

  Complete the form as follows:

  A. Enter your NAME,  ADDRESS, and ZIP CODE clearly. Enter a PHONE number where
     you can be reached during business hours.

  B. Complete the required  information for either the POINT SEARCH or AREA
     RECTANGLE inquiry, which includes the geographic LATITUDE and LONGITUDE coor-
     dinates. If coordinates  are  not available, please supply the GEOGRAPHIC NAME AND
     LOCATION or a map with the area of interest identified. Minimizing  your area of in-
     terest will allow for a faster and more critical retrieval  of information.

  C. Complete all other information.

  D. Complete the COMMENTS  portion of the inquiry. Will it be used for interpretation,
     analysis, or will it be framed and placed  on a wall? This information will assist our
     technicians in determining whether the products available  will satisfy your
     requirements.

  E. Return the completed form to the  EROS  DATA CENTER.
 FORMATION OR ASSISTANCE VIAY ALSO BE OBTAINED FROM THE FOLLOWING U.S. GEOLOGICAL SURVEY. NATIONAL CARTOGRAPHIC
                                   INFORMATION CENTER OFFICES
    a;;c.-.ci Center
      .-.ci Ce
j5:cn. VA 22C32
Ti - ^ : 6 ; 2 3
;T-I  703 £60-6323
Vid Continent '.'3'jping
 Center
14CO Independence Road
Ro''a, MO 65-101
FTS, 277-OS51
Comm: 31 4, 3-11 -OSS 1
Rockv Mountain Mapamg
 Cem^r
Stop 504, Denver F-^c^ral  Western Mapping Center
 Center              345 MicL^iieid ROJG
Denver CO 80225       Vonlo Park CA 34QZ5
FTS  234-232S         FTS ^67-2426
Ccnm 3C3 23-V-2325    Comm: a 1 5. 323-3 1 1 1
National Scace Tecrn r :•:;>
 laboraton-js
NSTL Station, MS 3r529
FTS -194-35-11
Comm- 601 688-3544

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                                                                                                         Page 23 of 60
   RETURN COMPLETED FORM TO:  ^sc
                        User S«rvic« S.ction     Commr 605/594-6151   TWX- ai n KBS mm
                        Sioux Falls. SO 57198    FTS: 784-7151       * ™/X. 910-668-0310
                                                                                                DATE.
NAME.
ADDRESS.
                                      COMPANY.
                                     . CITY/STATE.
                                                                                                              .ZIP.
PHONE (HOME).
.(BUSINESS).
-EROS ACCOUNT N0._
_REF. NO..
POINT SEARCH

lm»q«r» <*>rh inv CQ«*r«q« ov«r

AREA RECTA*G,t
1 AT


LONG. LONG.
i-niq«rv with anv co»*nq« within
I
POINT NO. 1
I AT * ' .,
LONG * ' ^

AREA MO. 1

1 AT * ' »
LONG. * ' ft TCI


POINT NO. 2
IAT • ' _
lONO * ' ui

AREA NO. *





POINT NO. 3



AREA NO 3
' ,
U '
• V* -cj
(1
, nfcjrt • _ -V TO i


            If my of th« «OQV« gtograoFuc r*f«rvfK*« cannot &• crovtdtd. pMo*
                                                                   i by GEOGRAPHIC NAME AND LOCATION lincHidt • TI»O if ooitib'

J?GE
[5 000-2S 0001

a
3LAC* t AHITE
PSEFEBflEO SCALE
a
MEDIUM
'25 000-30,0001
PREFERRED FORMAT
a
COLOR

a
SMALL
60.000-GHEATEHI

a
COLOR t.NFBAREO
                     •«EFSR«EO TIME OF
                                [j  ALL COVERAGE

                                Q  LATcST COVERAGE

                                Q  SPE: PIC DATES __
                                                                                      MINIMUM QUALITY RATING •

                                                                                        a     a      G
                                                                                       POOR)
                                                                                f"I '
                                                                              NOTE:
                                                                              Classification of percent of cioud ccver is subiecTive
                                                                              and is relative to the amount of ciouds appearing or.
                                                                              the imagery and not on their location,
                                       FOR INFORMATION OR ASSIS7A(\CE PLEASE CONTACT
                                          U S. GEOLOGICAL  SUnVEY,  EROS DATA CENTER
                                                    SIOUX  FALLS, SO 57198
                                             COMM: 605/59'i-6151 -FTS.  784-7151
C o m m 2 n t s'

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                                                                                 Page 26 ot bu
UNITED  STATES  DEPARTMENT  OF THE  INTERIOR
                          GEOLOGICAL SURVEY
                                            SPECIAL MAPS AS FOLLOWS (continued)     PRICE
                                              rteridmK*r»                                            2.00
                                              Golf Hammock                                          2.00
                                              UJuGtorg*                                            2.00
                                              Lake OkMcholw*                                        2.00
                                              Lake Seminol*                                          2.00
                                              Okefenok** Swunp                                      2,00
                                              Penaaeola Bar                                          2.00
                                              3anibl* Island                                          2.00
                                              The Everglade*                                         2.00
                                            G«ortia. Color Moaale                                     O.2S
                                            Hartford; Color Photomap                                  3.2S
                                            N«w Jvwr, Color Howk                                  2.00
                                            Upp«r Chcaapuk* Bay, Color Im*g« (1:250,000)                3.25
                                            Uppw ChoapMlu Bar, Color Imag* (1:900.000)                2.50
                                            Vataajoknll. Inland. Color Imag* (falD                       2.00
                                            VatnajokulL Inland, Black * Whit* Imag* (winter)             2.00
 MAPS, BY SERIES NAMKQB SCALE         PRICE
 Standard Topographi* »«dr«ig0fett.00* 138.000; ka.SOO)*  tt.00
 Orthophotomap*
 Orthophotoquad*
 1:50.000 Topographic Quadrangle* (DMA)
 1:25,000 (7H' z 16') Metric Topographic Qoadrangi*
 1:100,000 Map* (Including BLM Sorfac*/Mineral Mngt.)
 1:125.000 Map*
 1:260,000 Map* (Including Antarctic A Alaaka Boundary S*h**>
 County Map* (1:60,000 * U100,000)
 SUM BaM (No Contour*—1:600,000 * 1:1.000,000)
 Stat* BaM (Topographic * R»U«f—1:500,000)
 International Map* of th*  World (1:1.000,000)
 National Park Map*
Coastal Ecological Inventory Map*
 National Atlas Separates
 Map* 2-A A 2-B
 Map3-A
 M*p3-B
 Map* 5-A; 5-B; 5-C; 5-D
 Map6-A
 Map* T-A; 7-B; 7-C
    10-A
    11-A
Map 18-A
NOTE:
  'Includes New Map*. Revision* (Standard and Interim)
   and Reprint*
            SPECIAL  MAPS AS FOLLOWS
Regional Maps:
  Adirondack Region (NY)                                  3.25
  Appalachian Region                                      2.50
  Greater Atlanta Region  (GA)                              3.25
  Greater Atlanta Region  Slop* (GA)                          3.25
  Greater Pittsburgh Region iPA)                            3.25
Antarctica:
  Ellsworth  Mountains, Blue-tone Mosaic                      3.25
  McMurdo Sound Region, Black and Whit*  Image              2.50
  McMurdo Sound Region. Black and White  [mage              2.00
  McMurdo Sound Region. Blue-tone [mage                     3.25
  Victoria Land Coaat, Blue-tone Mosaic                       3.25
Chesapeake  Bay and Vicinity Winter, Color  Mosaic              3.25
 Florida. Color Mosaic                                       5.00
 Florida, Color Image:
  Apaiachee Bay                                          2.00
  Charlotte  Harbor                                        2.00
2.00
2.00
2.00
3.25
3.2S
3.2S
3.25
3.25
2.50
3.25
3.2S
3.2S
3.28
2.50
5.00
2. SO
3.25
2.00
3.25
2.00
2.50
1.00
 .50
                                            THEMATIC MAPS
                                            Baa*m*nt Rock Map of North America
                                            Baaement Rock Map of U.S.
                                            Bougacr GraTity Anomaly Map of the U.3.
                                            Coal Field* of Alaaka
                                            Coal Field* of the U.S.
                                            Geologic Map of North America
                                            Geologic Map of (State)

                                            Geologic Map of the U.S.
                                            Hydrologic Unit Map of (State)
                                            Tectonic Map of North America
                                            World Seunucity Map
              1.25
         (set) 5.00
              1.50
              3.00
              3.50
         (set) 3.00
 (for 1st sheet) 8.00
(p*r add. sheet) 4.00
         (set) 8.00
   from 2.00 to 8.00
         '•«t> 8.00
              2.50
                                             Prices for other "Hiematic Maps varies.  P!ea<* check with your Dis-
                                             tribution Center or Public Inquinee Office for individual map pnc».
                                             A's  Antarctic Geologic Mape
                                             C's  Coal Investigations
                                             GPs  Geophysical Investigation*
                                             GQ'j  Geologic Quadrangles
                                             HA's  Hdrologic Investigations
                                             1's  Miscellaneous Investigations
                                             L's  Land Use/Land Cover Series
                                             MF's  Miscellaneous Field Studies
                                             MR's  Mineral Investigations  Resource
                                             OC's Oil & Ga* Investigations Charts
                                             OM's  Oil & Gaa Investigation* Map*

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                                                                               Page 27 of 60
                               United States Metropolitan Areas

Aerial color photographs of metropolitan areas within the United States are available from the EROS Data
Center. Photographs have been chosen which are of high quality and have a minimum of cloud cover. The
scale of the selected photographs ranges from about  1:60,000 (1 inch a 1 mile) to 1:125,000 (1 inch = 2
miles). The majority of the preselected photographs are color infrared: others are natural color.

Please note that most large urban areas encompass more land area than can be covered by a single
photograph, and that the majority of the photographs available indude the central business districts. If
other portions of the city are desired, describe the area of interest on  the Geographic Computer Search in-
quiry form, or contact us about your requirements by letter, telephone, or personal visit.
Aerial color photography is available over these metropolitan areas:
Akron. OH
Albany, NY
Albuquerque, NM
Anaheim. CA
Anchorage, AK
Atlanta, GA
Baltimore. MO
Baton Rouge. LA
Beaumont. TX
Bethlehem. PA
Billings, MT
Birmingham. AL
Boston. MA
Bridgeport. CT
Buffalo, NY
Canton. OH
Charleston, SC
Chattanooga, TN
Cheyenne, WY
Chicago,IL
Cincinnati, OH
Cleveland. OH
Columbus, OH
Dallas. TX
Davenport, LA
Denver, CO
Detroit. MI
El Paso, TX
Fargo, ND
Hint. MI
Ft. Lauderdale, FL
Ft. Wayne, IN
Ft. Worth. TX
Fresno,  CA
Gary, IN
Grand Rapids, MI
Greensboro, NC
Greenville, SC
Harrisburg, PA
Hartford, CT
Honolulu, HI
Houston. TX
Huntington. WV
Indianapolis. IN
Jersey City. NJ
Kansas City, MO
Knoxville. TN
Lansing, MI
Las Vegas.  NV
Lincoln. NE
Long Branch, NJ
Long Island. NY
  (Queens-Nassau County)
Los Angeles. CA
Louisville, KY
Memphis, TN
Miami, FL
Milwaukee, Wl
Minneapolis, MN
Mobile, AL
Nashville, TN
New Brunswick, NJ
New Haven, CT
New Orleans, LA
New York City, NY
Newark, NJ
Norfolk, VA
Oklahoma Cry,  OK
Omaha. NE
Orlando, FL
Oxnard, CA
Patterson. NJ
Peoria. IL
Philadelphia. PA
Phoenix AZ
Pittsburgh. PA
Pocatello. ID
Portland, OR
Providence. Rl
Raleigh/Durham, NC
Richmond, VA
Rochester. NY
Sacramento, CA
St. Louis. MO
St. Paul, MN
St. Petersburg, FL
Salt Lake City, UT
San Antonio, TX
San Bemadino. CA
San Diego. CA
San Francisco, CA
San Jose, CA
Scranton, PA
Seattle, WA
Shreveport. LA
Sioux Falls. SD
Springfield, MA
Syracuse, NY
Tacoma, WA
Tampa. FL
Toledo. OH
Tucson, AZ
Tulsa. OK
Utica/Rome. NY
Washington. DC
West Palm Beach, PL
Wichita, KS
Wilmington. DE
Worcester, MA
                                                                              (US0018 June
                                          Survev £S
                                                        ~ter. Jou« :j

-------
Distinction between M.ip Scales*
                                                     ic  Ser ies :
                               1:24.Olio-Scale (1  Inch >  2,000 feetj
                                    Area Shown =  1  square mile

                            These maps cover approximately 57 square
                            miles and are used where detailed land
                            surface Information Is  required.   They ire
                            used for energy and ulneril  exploration,
                            for natural resource and water Management.
                            for agricultural and census  area  statis-
                            tics, for outdoor recreation activities,
                            and for many engineering studies  and
                            surveys.  ApproMlnwtely 54.000 maps are
                          ^ required to cover the conterminous U.S.
                               1:100,000-Srale (I inch • I.Smiles)
                                   Area Shown z 16 square nlles

                            fiich of these maps cover an area equal to
                            3? of Ihr I:24.0UO-scale maps from which
                            the content is derived.   These naps are
                            used for count/wide or broad area studies
                            where less extensive detail is required.
                            They are used as a null I-purpose base for
                            displaying various Information,  such as,
                            Important farmlands, wetlands. Federal
                            land ownership and subsurface Mineral
                            rights, and for State and county Manage-
                            ment planning.  Appro*.  I.BOO naps arc
                            required to cover the conterninous U.S.
                                 I.200.000-Srale (I Inch • 4 nlles)
                                   Area Shown • 107 square nlles

                            fach of these naps covers an area equal to
                            \2H of the l:24,000-scale naps and conn In
                            significantly less detail.  These naps are
                            used for broader area or regional planning.
                            They are used for water resource studies,
                            for civil defense and disaster relief
                            coordination, and as bases for air pollu-
                            tinn, aeronautical charts, land-use, and
                            weather records.  Appro*.  450 naps are
                            required to cover the conterminous U.S.
                                1:500.1100 Siale  (I  inch • 8 nlles)
                                  Area Shown B  415 square nlles

                            These maps generally cover a State and are
                            used to display studies. Inventories and
                            management activities requiring detail
                            appropriate to * statewide overview.  They
                            are also used to help  In locating inter-
                            state utilities, to delineate drainage
                            basin boundaries and as a base to prepare
                            State Highway and other naps   They are
                            avaiUMe as a planlmetric. topographic.
                            nr stu
Ot)
 ft
 Ix)
 CO
o\
O

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                                                                      Page 29 of 60
          NATIONAL CENTER FOR GROUND WATER INFORMATION DATA BASE
                       500 West Wilson Bridge Road
                        Worthlngton, Ohio  43085
                            (614) 846-9355
Every Issue
Journals Regularly Indexed
     Several  Times/Yr.
Canadian Water Well
Ground Water
Ground Water Age
Ground Water Monitoring
 Review
Johnson Driller's Journal
Journal American Water
 Works Association
Journal of Hydrology
Journal Water Pollution
 Control Federation
Pacific Ground Water Digest
Water Resources Bulletin
Water Resources Research
Water Well Journal
     Agricultural  Engineering
     Agua
     Drill Bit
     Drilling-OWC
     Environmental  Monitoring
      and Assessment
     ES A T, Environmental
      Science 4 Technology
     Geothermal Energy
     Geothermal Resources
      Council Bulletin
     Irrigation Age
     Irrigation Journal
     Journal of Soil  and Water
      Conservation
     Journal of the Environmental
      Engineering Division (ASCE)
     Journal of the Hydraulics
      Division (ASCE)
     Journal of the Irrigation
      and Drainage Division (ASCE)
     Journal of the National  Water
      Well Association of Australia
     Journal of the Mew England
      Water Works Association
     OPFlow
     Soviet Hydrology
     Water Engineering & Management
     Water Research
     Water Techno!ogy
     Western Water
 Few Times/Yr.

AAPG Bulletin
Arab Water World
Bottled Water  Report
Drilling Contractor
Earthqake Information
 Bulletin
EPA Journal

EOS
Garber-Well ington
 Gazette
Geol ogy
Geological Society of
 America Bulleti^',/
Geotlmes
JPT. Journal  of
 Petroleum Technology
Oil & Gas Journal
Services
Water Conditioning
World Oil
World Water

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                                                                          Page 30 of 60
                            NOAA PRICES FOR LANDSAT
                          DATA, PRODUCTS AND SERVICES
                           EFFECTIVE OCTOBER 1, 1982

PRODUCTS AND SERVICES	PRICE	

Archive

  Imagery Products
  70 mm film positive (B & W)                                   5  26.
  70 mm film negative (B & W)                                      32.
  10 in. film positive (B & W)                                     30.
  10 in. film negative (B & W)                                     35.
  10 in. paper (B & W)                                             30.
  20 in. paper (B & W)                                             58.
  40 in. paper (B & W)                                             95.
  10 in. film positive (color)                                     74.
  10 in. paper (color)                                             45.
  20 in. paper (color)                                             90.
  40 in. paper (color)                                            175.
  16 mm microfilm (B & W)                                          60.
  35 mm slide (color), from an existing collection                  4.
  16 mm microfilm (color, 100' roll)                              150.

  Digital Products
  9-track, 800 BPI CCT; MSS Scene - all available bands         $ 650.
  9-track, 1600 BPI CCT; MSS Scene - all available bands          650.
  9-track, 6250 BPI CCT; MSS Scene - all available bands          650.
  9-track, 800 BPI CCT; RBV (Single-subscene)                     650.
  9-track, 1600 BPI CCT; RBV (Single-subscene)                    650.
  9-track, 800 BPI CCT; RBV (set of 4 subscenes)                 1300.
  9-track, 1600 BPI CCT; RBV (set of 4 subscenes)                1300.
  14-track, High Density Tape (variable content)               Variable

  Generation of Color Composite (false color IR)-add to product
                                                 price          S 195.

  Special Acquisition Data and Products
       (Special Acquisition signifies Landsat D MSS scene data that are  not
       scheduled for routine collection, but which are provided upon user
       request.)

    Delivery of preprocessed digital data, to the
    requestor's site via communication satellite;
    per MSS scene collected at a time and place specified
    by the requestor  ...                                        $ 790.

    Delivery to the requestor of a frame of standard MSS
    imagery (not a color composite); per MSS scene
    collected at a time and place specified by  the
    requestor ...                                               S 880.

    Delivery to the requestor of a computer compatible
    or high density digital tape; per MSS scene collected
    at a time and place specified by the requestor  ...          $1000.

                                    - OVER -

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                                                                        Page 31 of 60
         Acquisition Daca and Products (cone.)
PRICE
   Surcharge  for delivery of a color compostca to che user
   originally requesting che special acquisition of an
   MSS  scene;  per scene ...                                     S 150.

   Surcharge  applied when che requestor establishes a aaxiaum
   allowable  cloud cover condition for che collection of an
   MSS  scene;  per scene ...                                     $ 250.

 Subscription Services
   Undsac  aieroCATALOG
    Annual
    World  (Monthly  Update)
    forth  Zone  (Monthly Update)
    South  Zone  (Quarterly Update)
    Polar  Zone  (Quarterly Update)
    Region 1  (Monthly Update)
    Region  2  (Monthly Update)
    Region  3  (Quarterly Update)
    Region  4  (Quarterly Update)
    Region  5  (Quarterly Update)
    Region  6  (Quarterly Update)
    Region  7  (Quarterly Update)
    Region  8  (Quarterly Update)
    Region  9  (Quarterly Update)
    Region  10 (Quarterly Update)

    Current Edition
    World
    North  Zone
    South  Zone
    Polar  Zone
    Region  I
    Region  2
    Region  3
    Region  4
    Region  5
    Region  6
    Region  7
    Region  8
    Region  9
    Region  10

nicroIMAGE  -icr.e  (landsat  D)
  Annual by World,  Zones,  and  Regions

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PREPARATION OF WORK PLANS, SAFETY PLANS AND SAMPLING PLANS


2.4.0     INTRODUCTION

         The information used  to develop work plans, safety plans and sampling plans will
         be based on data collected during the  PA  and the background data collection
         step.  In the sampling plan the preparer should specify as  much as possible the
         number  and location  of  samples.   Prior site reconnaissance can  be helpful  in
         identifying the locations.    Often an "off" site  reconnaissance has  been done
         during the PA and may be sufficient.  If the site is particularly  large or complex
         it may  be  necessary  to perform  an on-site reconnaissance.  For the sake  of
         keeping  travel  costs to a miniumum  it may be possible, without  compromising
         the  usefulness  of the  sampling  plan, to conduct  an on-site  reconnaissance the
         morning  of or day  before  the  actual  samples  are collected.    An  on-site
         reconnaissance  prior  to sampling  is routinely  conducted to screen the site  for
         safety purposes and it may  be  effective to couple  these efforts  together.

         Both site reconnaissance and site inspections require the  completion of work and
         safety plans.  In  addition, site  inspections  require sampling plans.   However,
         sampling plans  and  safety procedures are discussed in detail later in  Tabs 5 and
         9.

2.4.1     PURPOSE

         The purpose of  a work plan is to provide a  scope of work and technical approach
         for site  inspections  (Sis) and site reconnaissance to insure the safe and efficient
         performance of work on site. The  work  plan includes:

         o    Safety Plan

             The  purpose  of a safety plan is to provide  a description of the potential
             physical  or chemical  hazards present at  the  site,  to provide  emergency
             information in  case of  injury or illness,  and  to describe the  dermal and
             respiratory protective clothing or  equipment  required  of  all  personnel  for
             each phase of the field work.

         o    Sampling Plan

             The  purpose of a sampling plan is to specify  the  location of each sample to
             be taken,  to detail  all  sampling and  decontamination procedures,  and  to
             identify the personnel  to perform each task.

2.4.2     APPLICABILITY

         Work, safety and sampling plans  are  necessary for all  site inspections.  Work
         plans  and  safety plans  should  be prepared  if a prior  site  reconnaissance  is
         necessary.

2.4.3     DEFINITIONS

         None

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PREPARATION OF WORK PLANS
         DISCUSSION

         To simplify  the work plan, standardize  the format as much as possible.  Much of
         the work can be simplified by simply referencing Standard Operating Procedures,
         Operating Guidelines, or Quality Assurance Procedures.  The work  plans  are
         adapted to the specific site, based on known  or anticipated conditions.  Provision
         can be  made  for on-site modification of the technical  approach, if there is a
         possibility that on-site conditions may differ from that which  was anticipated.

         Basically, work plans should include the following:

         o   A summary of background information on the site with emphasis on how  this
             information can be used to identify investigation objectives.

         o   A  statement of objectives  and goals of the investigation.  Typical goals
             include  hazardous  substance  inventory  and  documentation  of  pollutant
             migration.

         o   Investigation methods required to characterize  the site.  Often this includes
             a  sampling plan,  including  sample  types,  sampling  locations,   sampling
             procedures, and  field quality control.

         o   Personnel requirements.

         o   Equipment needs.

         o   Any non-standard equipment and/or contract services which may  be  needed
             to complete the investigation.

         o   Methods used  to control contaminated  materials including decontamination
             procedures, solutions to be used and storage or disposal obligations.

         o   Special  training  requirements.

         o   Organization of  special teams.

         As this list indicates, the work  plan allows the investigation  team to efficiently
         schedule  such  resources as  manpower, equipment  and   laboratory ser/ices in
         advance of a proposed investigation.  The work  plan is thus  an essential  tool in
         the investigation of hazardous substance sites.

         A  comprehensive   site-specific  safety  plan  must  be   developed before   an
         investigation team   is  permitted  to  go  on-site.   Hazardous  substance  site
         investigations  may   present  extraordinary  hazards  to  personnel.  Therefore,
         certain basic safety  principles  must  be adhered to  at  all  times.  The  major
         emphasis of  safety  planning for site  investigation  should be to develop safety
         consciousness, to integrate safety knowledge with field procedures, and to avoid
         both chemical contamination and physical hazards.

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PREPARATION OF WORK PLANS
         This section will discuss  the development of work plans.  Safety procedures and
         safety plans are discussed in depth later in Tab 9.  Sampling plans are  discussed
         in Tab 5.

2.4.5     RESPONSIBILITY

         The project  manager is responsible for  the completion of work plans and safety
         plans.   When  completed,  the work plan and  safety plan  undergo  technical
         reviews.   The  plans  should  be signed, indicating approval  by  all appropriate
         personnel.  The plan should have a  cover sheet  which is signed by the author
         (usually  the project manager), the QA Representative, and any other appropriate
         personnel.

2.*.6     PROCEDURE

         After  a  background   information   search  is  completed  for  a   site,  a  site
         reconnaissance may be deemed necessary.  The background information is  then
         utilized as the basis for determining a technical approach and safety plan.

         The author  of the Work Plan must have a thorough understanding of the site, its
         surroundings, and the  nature and extent of possible contamination and hazards.
         It is necessary to  be familiar with all the information  which has  been assembled
         during the background data review and preliminary assessment.

         The HRS forms should be completed as much as  is possible using  the available
         information.   This will  help  to  point out the  specific  areas which  require
         sampling or additional  data for scoring.  The work plan can then concentrate on
         these areas.

         The scope of work must  be  clearly defined.   What on-site or off-site work will
         be  required0  Will other agencies or  contractors be involved,  or  will all work be
         conducted as an "in-house" project0

         There may  be other factors  which must be considered  as they may greatly affect
         the project:

         o   Time  How much time is allotted  for this project0 Is  the schedule flexible,
             or are there stringent deadlines?
         o   Budget  - What are the budget limitations?   How  many sample analyses can
             be included?  If the project runs several days, living expenses for employees
             may be  necessary.
         o   Personnel Availability
         o   Equipment Availability
         o   Training -  Will special training  be required to efficiently perform the work?

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PREPARATION OF WORK PLANS
         Special  considerations must  be given to aspects  of  the  work which  may  vary
         greatly from site  to site.

         o     Hazards -  What physical or chemical hazards may be encountered?  How
               will  they affect the time, expense, personnel requirements or equipment
               needed  for the project? Safety for the project team and  the public  is of
               primary importance.
         o     Site  Location - Is the  site accessible?  How far is it from the laboratory
               or "home office"? Will samples need to be shipped to the laboratory?
         o     Timing  - Can  site be  adequately  sampled  at  this time or  year, or will
               frozen  ground  or  swampy  conditions  limit  sampling?    Is  the  site
               frequented at certain  times by the public, for example, a playground after
               school hours?   Will work  performed  in  the winter  be limited  by short
               daylight hours?  Have  recent rains or dry periods affected water levels?

         An example Work Plan format follows.

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                                                WPF 2/1/85
                                                Page 1 of 11
                                 Work Plan No.
                                 Revision
               NUS CORPORATION
                  WORK PLAN
                    FOR THE
                    Located in
                   Prepared by

                    Region II

                 Raritan Plaza III
                Fieldcrest Avenue
            Edison, New Jersey   08837
Preparer:
Date:
Re view/Approval:
                             QA Representative

Date:
Review/Approval:
                             State SI Program  Manager

Date:

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                                                             WPF 2/1/35
                                                             Page 2 of 11
                             WORK PLAN FOR A
                WORK ASSIGNMENT REQUIRING FIELD WORK

                            PROJECT SUMMARY

TDD No:   AJ'/A  fo  5-fo.V
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                                                                WPF 2/1/85
                                                                Page 3 of 11
                         PROJECT SUMMARY (cont'd)


Deliverable/Final Product (e.g. reports, etc):
Deliverable/Final Product To Be Reviewed By (  ):

	  Chief Project Manager

	  Editorial Review (Non-Technical Review)

                Non-Editorial Technical Review Committee - List Names
	  QA Representative (to ensure document was subject to the
                appropriate review process)

AJ//3  fo  S Varc, Assistant Regional Project Manager

AJ//3  f-o  StoAc  Regional Project Manager


Site History/Description:
 Prepare brief description of the site (landfill, drum storage, etc.), conclusions from
 past data assessments, and indicate the current or past operators.

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                                                                WPF 2/1/35
                                                                Page H of 11
                             PROJECT OVERVIEW

Technical Approach (reference sampling plan, if attached):
                      Attach Additional Sheets If Necessary


Personnel Assignments (provide each dicipline and number of personnel required)

NOTE: Please provide detailed description of duties and responsibilities.

Chemists:
Hydrogeologists:
Toxicologists:
Environmental
Scientists/
Engineers:
Others:

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                                                              WPF 2/1/85
                                                              Page 5 of 11
                        PROJECT OVERVIEW (cont'd)



Schedule of Activities:


             	See attachment:   Ref#:	Date:


Referenced Background Data:

List background reference material
                     Attach Additional Sheets If Necessary
Safety and Health Considerations:

Refer to the attachment A, the site safety plan which has been approved by the
Regional Safety Officer and RPM.

              Ref//:                     Date:
                                        (Safety Officer Approval Date)

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                                                              WPF 2/1/85
                                                              Page 6 of 11
         ESTIMATED COST ASSOCIATED WITH ANALYTICAL SUPPORT
                                                                  Total Analysis*
Type of Analysis         Unit Cost($)*          No. of Samples        Costs($)
                        Total Cost of all Analysis Requested:
Reference and attach additional pages if necessary.
*If required, include  Special Analytical Services (SAS) cost estimates.

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                                                               WPF 2/1/85
                                                               Page 7 of 11
                         PROJECT OVERVIEW (cont'd)

Required Resource List (for equipment, list major items only):

Reference to attached list is acceptable

         Item                 When Needed              Remarks
Interface/Planning Requirements:  (reference attachments if necessary)


IiuerEd'ze with EPA:
Interface with other State/Local Agencies:
Site Access Arrangements (site contact, etc.):
Training Requirements:

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                                                               WPF 2/1/85
                                                               Page 8 of 11

                       RECORDS AND DOCUMENTATION

Check off records that  will be generated during this project:

General:

	  Work Assignment document/     	 Photographs
          close-out

	  Work Plan                      	 Drilling Logs

	  Safety Plan                    	 Correspondence (Telecon
                                                     Notes, Memos, Letters,
	  Sampling Plan                              etc.)

	  Log Books                      	 Reports, Memos, etc.
          Chain of Custody Records

          Traffic  Reports
      	  Special Analytical Svcs. Pkg.

          List


          Airbills


Other (list below or
(reference
attachment)


Quality Assurance:

	 Records of Non-Editorial Reviews	  Project Kickoff Meeting:
                                               Work Plan/Safety Plan
	 Records of Editorial Reviews             Distribution, Documenta-
                                               tion, Notes, etc.

	 QA Records Log                 	  Calibration Records
                                               (for HNu, OVA, etc.)

Procurement Documents  (list below requests for bids and proposals, subcontract
                         consultant agreements, etc.):
Other Records (list below):

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                                                              WPF 2/1/85
                                                              Page 9 of 11


                   REFERENCED STANDARD OPERATING
                   GUIDELINES FOR PROJECT ACTIVITIES


Please check off the following tasks that will be performed during the course of
the project.  Then, at the bottom of the page and on subsequent pages, describe
fully, for each task, the appropriate procedures and actions that will be taken
to provide both quality assurance and quality control.  If a given task  has
standard operating guidance (SOG) that is documented, please refer to that
guidance.  The primary reference would be  State Agency Standard Operating
Procedures.  List others as appropriate.

           Document/Section            Description

         	Ambient Air Sampling (OVA, HNU, etc.)

         	 Ground-Water Sampling

         	 Surface-Water Sampling

         	Soil/Sediment Sampling

         	 Tap Water Sampling

         	 Land Surveying

         	Electrical Resistivity Survey

         	Electromagnetic Survey

         	 [Magnetometer Survey

         	Metal Detection Survey

         	 Ground Penetrating Radar Survey

         	Seismic Survey

         	 Water Level Measurements

         	 Perimeter Survey

         	 Site Inspection

         	Soil Borings/Well Installation

         	Bedrock Fracture Analysis

         	 Pump/Permeability Tests

         	Preparation of Water Table Maps

         	Preparation of Bedrock Contour  Maps

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                                                         WPF 2/1/85
                                                         Page 10 of 11
                  REFERENCED STANDARD OPERATING
                  GUIDELINES FOR PROJECT ACTIVITIES
Others (list below):
                            Determination of Ground-Water Flow

                            Decontamination Procedures

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                                                               WPF 2/1/85
                                                               Page 11 of 11
                               APPLICABILITY
The folding portions of the NUS Superfund Division Quality Assurance Manual
are applicable to the performance of specific work elements defined in
TDD ///L/M fu StoA-t. •  The quality assurance  procedures recognized in Region II
FIT follow applicable operating guidelines provided in the preeceeding section of
this work plan.
       ( )   Number
       	   QAP 2.5
       	   QAP 3.1
       	   QAP 4.1
       	   QAP 4.2
       	   QAP 5.1
       	   QAP 5.2
       	   QAP 6.1
       	   QAP 7.1

              QAP 7.2

       	   QAP 7.3

       	   QAP 7.4
       	   QAP 7.5
       	   QAP 8.1
       	   QAP 8.2
       	   QAP9.1.F2
       	   QAP 9.2.F2
       	   QAP 10.1
       	   QAP 11.1
       	   QAP 11.2
       	   QAP 12.1

       	   QAP 13.1

       	   QAP 14.1

       	   QAP 15.1

       	   QAP 16.1

       	   QAP 17.4
       	   QAP 17.6
                Subject
Work Plans
Control of Remedial Design Activities
Field Data Collection
Data Reduction, Validation, and Reporting
Preparation  of Procurement Documents
Subcontractor Quality Assurance Requirements
Preparation  of Instructions and Procedures
Identification of Controlled Evidentiary
Documents
Issuance and Distribution of Controlled
Documents
Development, Documentation, Verification, and
Retention of Software Programs
Technical Reports
Interim Document Review Procedure
Control of Procurement Activities
Evaluation and Selection of Subcontractors
Chain of Custody
Sample Control
Analysis Techniques
Offsite Reconnaissance
Onsite Inspections
Implementation of Measuring and Test  Equipment Controls
Materials
Packaging, Marking, Labeling, and Shipping of
Samples from  Hazardous-Waste Sites
Nonconformance Reporting, Evaluation, and
Disposition
Implementation and Documentation of  Corrective
Actions
Storage and Retrieval of Quality Assurance
Records
Preparation for Audit
Quality Notices

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                                              WPF
       ATTACHMENT A






        SAFETY PLAN






(Must have Identifying Control #)

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                                               WPF
       ATTACHMENT B






       SAMPLING PLAN






(Must have Identifying Control //)

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, 5-      .r  fa****.*-

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QUALITY ASSURANCE
REVIEW PROCEDURES
2.5.1     PURPOSE
         To ensure completeness and that the appropriate quality assurance requirements
         have  been  met and  are in compliance  with established plans  and manuals (i.e.
         State Agency Quality Assurance Manual).

2.5.2     APPLICABILITY

         The   Quality    Assurance    review   procedure   is   applicable    to    all
         Work/Safety/Sampling Plans, and  other deliverables and records, including the
         MRS Model.

2.5.3     DEFINITIONS

         None

2.5.*     DISCUSSION

         None

2.5.5     RESPONSIBILITIES

         Prior   to    the   commencement   of   field   activities,   a   comprehensive
         Work/Safety/Sampling  plan  should  be  reviewed  and  approved  by   various
         disciplines  within the management structure of the office.

         Initially, upon completion of  the plan by the Project Manager, it is reviewed by
         the State Office  Site Investigation Coordinator.  The Health and Safety Officer
         then reviews the Health and Safety  portion of the  plan and once approved  the
         entire  Work/Safety/Sampling  Plan  is  given  to  the  office  Quality  Assurance
         Manager. It is the responsibility of the  Quality Assurance Manager to review  the
         entire  Work/Safety/Sampling  Plan  to ensure  that  the  implementation  of  all
         quality assurance requirements and  procedures  as  defined  in established  plans
         and manuals are satisfied.  Once the  Quality Assurance Manager approves  the
         Work/Safety/Sampling plan it is given to the responsible Office Manager  for final
         approval.

2.5.6     PROCEDURES

         In  addition to ensuring that all  quality assurance requirements are  met,  the
         Quality  Assurance   Manager   reviews  the   Work/Safety/Sampling  Plan   for
         consistency and completeness.

         The following highlights  the  type  of information generally checked by  the
         Quality Assurance Manager:

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                   QUALITY ASSURANCE REVIEW
                               EPA
                            STATE OFFICE
                        STATE SI COORDINATOR
HEALTH AND SAFETY
SITE PROJECT MANAGER
QA MANAGER
                         SITE PROJECT TEAM

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  QUALITY ASSURANCE
  REVIEW PROCEDURES
       o     Document contains proper approval signatures
       o     Consistency  of  Project  and  Document/Report  Numbers  throughout  entire
             Work/Safety/Sampling Plan
       o     Overall Scope of Work detailed in a Summary of Assignment section
       o     Logical account of site history and site description
       o     All letters, reports, etc. to be generated are described completely
       o     All major items which are planned to be used are included (OVA, hNu, etc.)
       o     Critical phases or points of the project, if major in scope, are outlined.
       o     Sampling plan is attached with proper date and document number
       o     Completeness   of   individual   responsibilities  and  consistency  of   names
             throughout Work/Safety Plan
       o     Activities or tasks to be performed  during scope of work are checked off and
             proper Standard Operating Guidelines sections  are referenced.
       o     Applicable Quality Assurance Requirements and Procedures are  notated and
             checked off
       o     In Sampling Plan, Operating  Guidelines sections consistent with those listed in
             the  work plan  should be referenced.  Should  not see "blanket" reference  to
             guidelines.


2.5.7   RECORDS

       A  copy of the  work  plan is retained in the appropriate project  file once completed.
       Once the site inspection is completed, the  field logbook is also incorporated into the
       project file.

       The  logbook is  considered a controlled evidentiary document and can be  used in  legal
       proceedings. It is a necessity that the logbook provides proper documentation and a
       clear picture  of all  field activities.   These field  notes may  be used to  prepare
       responses to interrogatories filed by attorneys during litigation  involving a site.  (A
       portion of an example interrogatory  is included at the end of this section).

       The  following provides an example of the type of information that may be extracted
       from the logbook:

       1)    All personnel on site  during field activities.
       2)    A complete description of each sample.
       3)    The exact depth from which  each sample was taken.
       *0    The date  and time that each  sample was taken.
       5)    The  decontamination  procedure(s)  used   to  ensure  there  were  no  cross-
             contamination  of  samples.
       6)    The  results of  any  field measurements taken during the  collection  of  each
             sample.

       Figure  2.5-1 provides an  example of typical logbook entries.   Each logbook  page
       must be signed by the person taking the field documentation as  well as by a second
       person to ensure the clarity and completeness of  the field notes.

-------
                                     FIGURE 2.5-1
       i»:
                         .J". /
                        V. .S.n//Ji-
 •IIMU-n- .r^n ma IPO
             I no
\n T-o „_       .,   , _Jt:, ,1 ^_,!^^_C
                                        ,•)!>'
        6.
       ii/ULL _ Wo  rc
                                                          G.
                                                     '
                                                  HOP

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QUALITY ASSURANCE
REVIEW PROCEDURES
2.5.7.1   AUDITS
         Audits are also a function of the overall Quality Assurance program in an office.
         These audits  are conducted to verify  compliance with  the  established quality
         assurance program.

         Generally, two types of in-house audits  are performed:

         o     Internal audits of Project Related Files and Activities
         o     Internal audits of Onsite Activities

         AUDITS OF PROJECT RELATED FILES AND ACTIVITIES

         When  an  audit  is  conducted  on  Project   Related Files  and  Activities,  an
         evaluation of  the file contents is made. The  following provides a guidance on the
         type of information an auditor would look for:

         o     Are complete project plans available?
         o     Are approval signatures affixed on applicable plans/documents?
         o     Are all revisions to  the plan accounted  for?
         o     Is the logbook present?
         o     Does the logbook contain legible signed and dated entries?
         o     Is document of review apparent?

         AUDITS ON ONSITE ACTIVITIES

         Audits of onsite  field activities are conducted  to ensure onsite compliance with
         established quality  assurance  procedures and  guidelines.   While on  site  the
         auditor would make many procedural checks, including the following:

         o     Was  a  sampling plan generated  and/or revised to  meet the actual work
              performed and approved?
         o     Is there a site safety plan onsite with approval signatures0
         o     Is  a  site  sketch present in  the logbook which  depicts locations  where
              samples were collected?
         o     Is project logbook signed and dated following each entry and correction?
         o     Are samples collected in the appropriate types of containers as specified in
              the project sampling plan?
         o     Is  the  sample  collection being  conducted according  to  the appropriate
              Standard Operating Guidelines?

         Both type of audits are  important, as they  help identify problem areas, if any,
         with  project related work procedures.   By  implementing these  audits,  any
         necessary corrective action to  the procedures or overall program can be made.

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    SAMPLE






INTERROGATORY

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     (o)  the size and volume of such sample.
 11.  for  each and every testing and analysis identified in your  ansver  to
     interrogatory 10(h), please state fully and in complete detail:
     (b) the location where such testing and analysis  took place, including  but
        not limited to, street address,  town and state;
     (c) a complete description of all procedures and  protocols  followed  in
        conducting such testing and analysis;
     (d) the precise quantitative and qualitative results of such testing and
        analysis;
    (e) the precise reasons such testing and analysis was conducted;
    (f) the exact cost of such testing and analysis;
    (9) the date and time of day of such testing and  analysis;
    (h) the quality assurance and control procedures  used for such  analysis;
    (i) the detection limits of such testing and analytical methods;  and
    (j) the volume, and weight of the sample of  such testing and analysis.
12.  For each and every soil sample removed by the  plaintiff, its agents,
    servants or employees from property  owned by                            or
    its predecessor,  please state fully and in  complete detail:
    (a) a  complete description of such sample;
    (b) the exact location from which such sample  was taken, giving
        measurements in feet and inches  from fixed objects and  boundaries;
    (c) the exact depth in feet and inches from which such sample was taken;
    (d) the name and address of each person taking such sample;
    (e)  the name and address of each person present when  such  sample was taken;
    (f)  the date and time of day such sample was taken;
    (g)  the exact legal authority relied upon in taking such samples,
        including the full citation of each statute and other  law relied upon;
    (h) a  complete description of any and all testing and analysis done on
        such sample;
    (i)  the rationale for collecting such samples  at  the  identified location;

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     (j) the procedures foe collecting such sample;
     (k) the chain of custody focn used to transfer such sample;
     (1) the decontamination procedures used to ensue* there were no
         cross-contamination of  samples;
     (m) sample preservation and shipment procedures for such sample; and
     (n) the results of any field measurements taken during the collection of
         such sample.
 i3.  For each and every testing  and analysis identified in your answer to
     interrogatory 12(h), please state fully and in complete detail:
     (a) the name, address,  employer and occupation of each person conducting
         such testing and analysis;
     (b) the location where such testing and analysis took place, including but
         not limited to, street  address, town and state;
     (c)  a complete description  of all procedures and protocols followed in
         conducting such testing and analysis;
     (d)  the precise quantitative and qualitative results of such testing  and
         analysis;
     (e)  the precise reasons'such testing and analysis was conducted;
     (f)  the exact cost  of  such  testing and anaylsis;
     (g)  the date  and tune of day of such testing and analysis;
     (h)  the quality assurance and control procedures used for such  analysis;
     (i)  the detection limits of such testing and analytical methods;
     (]}  the  volume  and weight of the sample of such testing and analysis; and
   •  (k)  the  type of equipment used for such testing and the calibration
        results of such equipment.
14.  For each and every water  sample removed by the plaintiff, its agents,
    servants or employees from property owned by
    please state fully and in complete detail:
    (a)  a complete description of such sample;
 '   (b)  the exact location from which such sample was taken, giving
        measurements in feet and inches from fixed objects and boundaries;
    (c)  the exact depth in feet and inches from which such sample was  taken;
    (d)  the name and address of each person taking such sanple;
    (e)  the  name and address of each person present when such sample was  taken;
    (f)  the  date and time of day such sample was taken;

-------
    (g) the «xact legal authority  relied upon in taking such samples,
        including the full citation of each statute and other law relied upon;

    (h) a complete description of  any and all tasting and analysis don* on
        such sample;

    (i) the elevation of the water surf act froa which such sample was taken;

    (j) the rational* for collecting such sauries at th« identified location;

    (k) the procedures for collecting such sample;

    (1) the chain of custody form  used to transfer such sample;

    (m) the decontamination procedures used to ensure there were no
        cross-contamination of samples;

    (n) sample preservation and shipment procedures for such sample;

    (o) the results of any field measurements taken during the collection  of
        such .sample;  and

    (p) the size  and volume of such sample.
r
'.5.  For «ach and  every testing and analysis identified in your answer  to
    interrogatory l4(h), please state fully and in complete detail:

    (a)  the name, 'address,  employer and occupation of each person conducting
        such testing  and analysis;

    v. ,  the location where  such testing and analysis took place, including but
        not  limited to, street address, town and state;

    (c)  a complete description of all procedures and protocols followed in
        conducting such testing and analysis;
                                                x
    (d)  the precise quantitative and qualitative results of such testing and
        analysis;

    (e)  the precise reasons such testing and analysis was conducted;

    (f)  the exact cost of such testing and analysis;

    (g)  the date and time of day of such testing and analysis;

    (h)  the quality assurance and control procedures used for such analysis;

    (i)  the detection limits of such testing and analytical methods;  and

    (]}  the volume and weight of the sample of such testing and analysis.

    For each and every water sample removed by the plaintiff r  its  aqents,
    servants or employees from property owned by                            or
    its  -edecessors, please state fully and in complete detail:

-------
                                      -9-
     (f ) t!» exact cost of such testing and analysis;
     (9) the date and tia» of day of  such  testing and analysis;
     (h) the quality assurance and control procedures used for such analysis;
     (i) the detection limits of such testing and analytical methods; and
     (j) the volume and weight of the sample of such testing and analysis.
 18. with respect to       statement  that  "The         River is the discharqe
     point for essentially all the groundvater leaving the
     site,' as stated in the     Design studies Report for Bnergency Action.
     Page 11,  please summarize and list the specific data that were evaluated
     to maXe this assessment.
 13.  With respect to       statement  that  sediments underlying the
     River  contained significant levels of volatile or organic constituents,
     please state fully and in complete detail:
     (a)  the specific concentrations  detected;
     (b)  the specific contaminants detected;
     (c)  the exact  location such specific  concentrations were located, giving
         measurements in feet  and inches from fixed objects and boundaries;
     (d)  how the  headspace  analyses relate to analyses of the sediments;  and
     (e)  the specific procedures and  protocols used for sample collection and
         analysis.
 20.  Please  state fully and in complete detail how aquifer coefficients were
     determined such as transmissivity/ porosity, and hydraulic conductivity.
 21.  Please  describe fully  and in complete detail all Laboratory Quality
    Assurance/Quality  Control Programs used for all soil and water sampling,
    testing and analysis perforoed in connection with the plaintiff's
    investigation of  the .site.
 22. Please  state fully and in complete detail the rationale for determining
    monitoring well locations.
 23. Please  state fully and in complete detail the rationale for determining
    well screen depths.
 24. Please  state fully and in complete detail each manner in which the site
    investigations  performed  by      changed the original remedial
    investigation worX plan proposed by the NUS Corporation in May,  1383.
    Jlmji. JLULL Li A. ilium
    Lumi »Lllj in Uie- ULiiuLj u£  Uiu ujfce.
26.  For each and every planned and/or on-going interim remedial or other
    action being taken by the plaintiff, its agents,  servants and employees at
    the site,  please state fully and in complete detail:

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                                                                  A  j
                              SDEXILEA
     AS USED IN THIS SCHEDULE/ THE WORD "DOCUMENTS" SHALL INCLUDE, BUT
 NOT BE LIMITED TO, THE FOLLOWING:  PAPERS, BOOKS,  RECORDS,  LETTERS,
 PHOTOGRAPHS/ TANGIBLE THINGS, CORRESPONDENCE, COMMUNICATIONS,  TELEGRAMS,
 CABLES, TELEX MESSAGES, MEMORANDA, NOTES, NOTATIONS, LABORATORY WORK
 PAPERS, OTHER WORK PAPERS, LEDGER SHEETS, TRANSCIPTS, MINUTES, REPORTS
 AND RECORDINGS OF TELEPHONE OR OTHER CONVERSATIONS, OR OF INTERVIEWS, OR
 OF CONFERENCES, OR OF OTHER MEETINGS, AFFIDAVITS,  STATEMENTS,  SUttWUES,
 OPINIONS, REPORTS, STUDIES, DRAFTS OF REPORTS, DRAFTS OF STUDIES,
 ANALYSES, BULLETINS, NOTICES, ANNOUNCEMENTS, ADVERTISEMENTS, INSTRUCTIONS,
 CHARTS, MANUALS, BROCHURES, PUBLICATIONS, SCHEDULES, JOURNALS, STATISTICAL
 RECORDS, DESK CALENDARS, APPOINTMENT BOOKS, DIARIES, LISTS, LOGS, FIELD
 LOGS, TABULATIONS, SOUND RECORDINGS, COMPUTER PRINTOUTS, GAS CHRCMATOGRAMS
MASS SPECTRA, DATA PROCESSING, PROGRAM LIBRARY, DATA PROCESSING INPUT
AND OUTPUT, MICROFILM, BOOKS OF ACCOUNT, RECORDS,  INVOICES, DIAGRAMS,
 GRAPHS, GRAPHS OR MATERIALS WITH HANDWRITING OR OTHER PRINTING.ON THEM,
BOOKS, LIBRARY REFERENCES, TEXTBOOKS, TREATISES, GOVERNMENT PUBLICATIONS,
                                       s
AND ANY OTHER DOCUMENTS OF ANY KIND WHATSOEVER CONCERNING OR RELATED IN
ANY WAY TO THE CLAIMS ASSERTED BY THE UNITED STATES,

-------

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PERSONNEL ASSIGNMENTS
2.6.1  PURPOSE

      Careful  consideration must  be given to the personnel assigned to each task to
      insure safe and efficient work.

2.6.2  APPLICABILITY

      Proper personnel assignments are an integral part of executing site inspections.
      Assigning the right task to  the  most appropriate individual assures  quality data
      production.

2.6.3  DEFINITIONS

      None

2.6.4  DISCUSSION

      Inspections  at  sites containing  potentially hazardous  materials  present  many
      hazards,  physical   conditions  and  situations   requiring  a  wide   variety  of
      administrative controls, technical expertise and  scientific  support to ensure  the
      safe collection of reliable data.

      Team  size and  organization should  be  tailored to meet site  specific conditions
      including, but not limited to the following considerations:

      o     Nature and extent of problem
      o     Site safety considerations
      o     Scope of work
      o     Budget considerations

      Collectively,  the above considerations will  establish the number of  functions to be
      carried out by team  members.  The  number and complexity of the functions will
      then determine  the number of personnel required to safely and expeditiously carry
      out the work. In any circumstance, each team  member will have to  assume more
      than one function.  For safety  reasons, no less than  two people should  ever perform
      a  site entry,  even  for a  simple  reconnaissance which does not involve  sampling.
      This application  of the "buddy system" provides a way to ensure that assistance is
      available in the  event of a mishap.  Even the simplest  sampling efforts require  a
      practical minimum of  three people, each  of whom must assume  more than  one
      function. An  example three-person sampling team might have functions distributed
      as follows:

             Person 1                  Person 2                Person 3

             Project Manager          Safety Officer           Monitoring Equipment
             Log book                 Decontamination        Sampler
             Photography             Sample tracking
                                      Emergency response

      Team  functions are discussed in further detail below.

-------
PERSONNEL ASSIGNMENTS
General Staffing

The basic staffing requirements  of a site inspection should include individuals  with  the
expertise necessary  for successful completion of the project.    If. possible, each team
should  consist of individuals with varying backgrounds.   The disciplines  desirable for a
particular site depend on  the  nature of the site, and  the availability of personnel.   For
example, a chemical engineer would be useful while  at a chemical plant, while a biologist
or  botanist would be useful  in  a  more  wooded, or  wetland,  area.  Other  disciplines
typically  desirable include Geology, Environmental  Science,  Soil Science, Toxicology or
Public Health.

Team Functions

In addition  to disciplinary  considerations for team composition, each member is assigned a
specific project  function.   Project functions  may  include  but  are not  limited  to  the
following:

    o     Site  Project Management

         The Site Project  Management function includes insuring that all steps in the  site
         inspection  are  performed  in accordance with the requirements  defined in  the
         standard  operating  procedures.    Also,  the  Project  Manager  is  ultimately
         responsible  for the final  selection of sampling locations at the study site, the  use
         of safety procedures, and all  other  decisions made in the field  that might be
         critical to the success of the study.  He or she must document or  assign someone
         to document the  justification for each decision in the field log, as well  as in  the
         subsequent study  report.  The Project Manager must therefore be experienced in
         field  investigation procedures  and possess  the  necessary  technical expertise to
         conduct such studies.

    o     Site Safety Officer

         The site safety officer observes all field operations and personnel, or may remain
         at the  decontamination  area  in order to monitor all  downrange operations.
         Downrange  personnel are either in  the  safety  person's line  of sight  or other
         individuals are located between the safety person and the downrange personnel in
         order to maintain an unbroken,  person-to-person line  of sight.   The  specific
         responsibilities of the site safety  officer are as follows:

               1.   Monitors the work time and physical condition of all personnel.

               2.   Makes  all decisions concerning protective  equipment and monitors all
                  activities to remove  personnel  from  any unsafe work conditions or
                  unsafe  work acts.

If  the  site  safety officer  goes into the work  area  to observe work practices, he/she is
replaced at the decontamination area by another person, who assumes the  safety officer's
responsibilities and emergency action authority.

-------
PERSONNEL ASSIGNMENTS
   o  Samplers/Field Personnel

These are the individuals who complete all downrange operations.  On large teams, extra
field personnel may assist with decontamination or command post operations.

Other Team Functions

If the site or level of protection requires more personnel, the on-site personnel described
below are used:

   o  Decontamination personnel
   o  Rescue person
   o  Photographer
   o  Documentation personnel
   o  Air monitoring personnel
   o  Quality assurance personnel
   o  Community contact
   o  Equipment supervisor

It is possible that one person can  fulfill the responsibilities of several  positions.

Typically, the basic team consists of the project manager and safety officer. If sampling
is  required, a sampler is  added,  and  someone  assumes the responsibilities of  sample
management. A  separate sample management officer is preferred if  enough personnel are
available.   To avoid  confusion,  and  to efficiently complete the  abundant paperwork
involved in  sample management, limit the sample management to one or  two people.

If  the site  is more complex, or if  time is limited,  more personnel  may  be  added.  For
instance, one person for air monitoring, another for decontamination.

If the site is large, or  if several areas are  to be sampled simultaneously,  sampling teams
can be established,  each with a team leader,  safety officer, and samplers.  The Project
Manager would then oversee all work through  the team leaders.

2.6.5  RESPONSIBILITY

      The  selection of the project team is the responsiblity of the Project Manager,  who
      should be  familiar with the experience  and background of available personnel.

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                  TWO-PERSON  TEAM
PERSON I- "clean"  Person

   -PROJECT MANAGER
   -LOG BOOK
   -PHOTOGRAPHY
   -MONITORING EQUIPMENT
   -DECON OF PERSON II
PERSON  II- "dirty" Person

    -SAFETY OFFICER
    -SAMPLING
    -DECON OF PERSON I
                  SHARED: SAMPLE MANAGEMENT
                         MOBILIZATION
                         DEMOBILIZATION

 ADVANTAGES
    1. LESS PERSONNEL-RELATED COSTS

 DISADVANTAGES
    1. BUSY FIELD TEAM-MAY GET HECTIC
   2. AWKWARD DECON PROCEDURES
   3. NO EMERGENCY OR RESCUE PEOPLE AVAILABLE
   4. FIELD WORK TAKES LONGER-WOULDNT WORK ON LARGER SITES
   5. QC DIFFICULT TO MAINTAIN
   6. LIMITS SOME TYPES OF WORK WHERE MANPOWER IS NEEDED
                           FIGURE 2.6.1

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                    THREE-PERSON  TEAM
METHOD 1

PERSON l-'clean"
-PROJECT MANAGER
-LOG BOOK
-PHOTOGRAPHY
-MONITORING INSTRUMENTS
-DECON
-SAMPLE MANAGEMENT
PERSON H-"dlrty°
-ASSISTS SAMPLER
-DECON
-SAFETY OFFICER
-ASSISTS WITH SAMPLE
  MANAGEMENT
-MOBILIZATION
PERSON Ill-'dlrty"
-SAMPLER
-DECON
-DEMOBILIZATION
METHOD  2
PERSON l-Offslte
          "clean"
-SAFETY OFFICER & RESCUE
-SAMPLE MANAGEMENT
-MOBILIZATION
-COMMUNITY CONTRACT
PERSON ll-Onsite
	 "clean"
-PROJECT MANAGER
-PHOTOGRAPHY
-MONITORING INSTRUMENTS
-LOG BOOK
-ASSISTS SAMPLER
-DECON
-ASSISTS WITH SAMPLE
   MANAGEMENT
-MOBILIZATION
PERSON III- "dlrt\

-SAMPLER
-DECON
-DEMOBILIZATION
-MOBILIZATION
     ADVANTAGES

        1. MORE MANPOWER AVAILABLE
        2. EASIER TO MOBILIZE & DEMOBILIZE
        3. BETTER SAFETY AND RESCUE SYSTEM
        4. BETTER DECON PROCEDURES
    DISADVANTAGES

         1. STILL TOO DIFFICULT TO MAINTAIN SAMPLE QC (Too many hands)
         2. PROJECT MANAGER TOO BUSY, MAY CONTAMINATE EQUIPMENT
         3. NO 'LINE OF SITE" ON LARGE SITE
         4. SAFETY OFFICER TOO BUSY TO WATCH FIELD PROCEDURES
         5. MORE LIKELY TO MISS DOCUMENTATION
                               FIGURE 2.6.2

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              FOUR-PERSON TEAM
PERSON l-Offslte "clean1
   -SAMPLE MANAGEMENT
   -MOBILIZATION
PERSON Il-Onslte "clean"
   -SAFETY OFFICER
   -DECON
   -RESCUE
   -MONITORING INSTRUMENTS
   -DEMOBILIZATION
PERSON III- Onslte "clean"
  - PROJECT MANAGER
  - LOG BOOK
  - PHOTOGRAPHY
  -COMMUNITY CONTACT
PERSON IV- "dirty"
   -SAMPLER
   - MOBILIZATION
   - DEMOBILIZATION
             FOUR-PERSON TEAM


ADVANTAGES

   1. BEST USE OF PERSONNEL
   2. CLEAN ZONES ISOLATED FROM CONTAMINATED AREAS
   3. EFFECTIVE SAMPLE MANAGEMENT
   4. SAFETY OFFICER CAN FOCUS ON HEALTH AND SAFETY
   5. PERSONNEL AVAILABLE ON SITE IN CASE OF DIFFICULTIES
   6. LINE OF SITE EASIER TO MAINTAIN
   7. CONTINUOUS AIR MONITORING IS POSSIBLE
   8. MOST ROUTINE  WORK CAN BE COMPLETED SAFELY
                   FIGURE 2.6.3

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2.7

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MOBILIZATION
2.7.1       PURPOSE
           The purpose  of  this section is to emphasize the importance of mobilization  on
           large and small projects.
2.7.2       APPLICABILITY
           Mobilization  is an integral part of  site investigations.  The mobilization phase,
           when properly executed,  helps the site  investigation run smoothly and properly,
           thus producing data that can be used in the MRS model.
2.7.3       DEFINITIONS

           None

2.7.*       DISCUSSION

2.7.4.1     PRE-MOBILIZATION
           Prior to the start of  mobilization, the Project Manager (PM) must familiarize
           himself/herself  with the Scope of Work.   The  Project Manager must have  a
           complete understanding of  the  project in order to mobilize the proper personnel
           and equipment for the project.

           The  Project Manager must establish a sequence of field activities for the project
           once he has familiarized himself with the Scope of Work.  The sequence of Field
           Activities  must  follow an orderly and  logical  pattern  that  is designed  to
           complete the project in a reasonable time period based on the Project  Manager's
           available resources.  The PM's  resources may be limited by available personnel,
           equipment,  and  budget.  The lack of available  resources becomes the limiting
           factor for a project.  The limiting factors must be identified in the early stages
           of project planning and mobilization  to foresee  and avoid future problems  and
           make appropriate contingency plans.

           The  project can be divided  into phases after a sequence of field activities has
           been established.    The phases  should  break the  project  up  into major work
           categories.    Examples of  phases  are  mobilization,  on-site  reconnaissance,
           sampling,  sample  management and  demobilization.   For  more complicated
           projects where  wells  are  drilled  and  samples  mailed to a  lab,  there  may  be
           additional steps for drilling and sample shipping.

           At this point  in the pre-mobilization stage, an appropriate project time frame
           can  be established.  The time frame for the job  is from  the start to finish and  is
           based on the estimated time needed to complete the job.  Limiting factors must
           be taken into consideration when determining  the  project time  frame.   The
           limiting factors will have the biggest influence on  the project time frame.

           Time frames can be established for each phase of the project.  The time  frames
           can  be  plotted on  a chronologic bar chart  to see where each phase begins and
           ends and its relative duration with  respect to the project (See Figure 2.7-1).

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       PHASE
SITE RECEIVED

REVIEWED BACK-
QROUND/P A

OBTAIN SITE ACCESS
NOTIFY LAB FOR SPACE


PREPARE W/S PLAN FOR SI

OBTAIN LAB CONFIRMATION

QA W/S PLAN FOR SI

MOBILIZATION

CONDUCT SI

DEMOBILIZATION

 LAB DATA  RECEIVED FOR
   PRELIMINARY DATA REVIEW

QUALITY ASSURED DATA
   RECEIVED

PREPARE SI REPORT.MRS

QA SI REPORTERS
                                                              WEEKS
                                  1         2
                                 _J	L
 3
_L
 8
_JL
                                                                                       12
                                             13
 14
_J
                                                  SITE INSPECTION SCHEDULE
                                            FIGURE 2.7-1

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MOBILIZATION
            To further  understand  the complexity  of  the problem,  the following RCRA
            regulations  should be consulted in the Code of Federal Regulations:

               o  40CFR Part 260  - Hazardous Waste  Management:  General
               o  40CFR Part 261  - Identification and Listing of Hazardous Waste
               o  40CFR Part  262 - Standards  Applicable to Generators  of Hazardous
                  Waste
               o  40CFR Part 263 - Standards Applicable to Transporters  of Hazardous
                  Waste
               o  40CFR Part 264   Standards for Owners and Operators of  Hazardous
                  Waste Treatment, Storage and Disposal Facilities

            The degree to which the disposition  of investigation-derived wastes poses a
            problem is  typically dependent upon  whether the  site is  inactive  and/or
            abandoned,  or, active.  At abandoned or inactive sites disposable clothing and
            decontamination fluids  can generally be left on-site.  If  the site is active, or
            if there are signs that an  abandoned site is frequented by  people  (hunters,
            children on  trail bikes,  etc.)  arrangements may have to be made to transport
            and dispose of the waste off-site.  In  some instances, arrangements  can be
            made with  the site  operator to accommodate the disposal of investigation-
            derived  waste.   If off-site  removal  and disposal are required, the project
            manager  should  insure that a  mechanism exists  to  procure the  proper
            transport and disposal services.

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                        EXPENDABLE EQUIPMENT
                                    Quantity                  Amount
Item                                Packaged                 Required
CHEMICALS

Acetone                            5 gal.
Acetone                            1 gal.
Trichloroethane                     5 gal.
Trichloroethane                     1 gal.
Methylene-chloride                  5 gal.
Methylene-chloride                  1 gal.
Hexane                             1 gal.
Gasoline                            1 gal.
Gasoline                            5 gal.
Nitric Acid                          1 gal.
Nitric Acid                          5 ml.
Sodium  Hydroxide                    1 liter
Motor Oil                           1 qt.
2-Cycle Oil                          1/2 pt.
Alconox                            1 gal.
Baking Soda                         2 Ib. box
BOOTS

Butyl Rubber Boots
Hip Boots Size
SAMPLE CONTAINERS

40 ml. VOA Bottles                  1 each                      |C
Yi gal. Amber Bottle                  1 each                       ; C
1 liter Amber Bottle                 1 each                   	
8 oz. Glass Jars                      1 each                       . o
1 liter Plastic Bottles                1 each                        
-------
                   EXPENDABLE EQUIPMENT (Conf d)
                                 Quantity                Amount
Item                             Packaged               Required
GLOVES
Neoprene
Viton
Butyl Rubber
Cotton Work
Latex
Leather Work
P.V.C. Surgical
CHEMICAL RESISTANT COVERALLS

Tyvek SM                                                	
Tyvek MED                                              	
Tyvek LG                                                	
Tyvek XLG                                                 / Q
Tyvek XXLG                                             	
Saranex SM                                              	
Saranex MED                                             	
Saranex LG                                              	
Saranex XLG                                                / 0
Saranex XXL                                             	
SAMPLE TUBES

Glass Tube .5 mm x 300 mm         1 each
Glass Tube 1 mml x 300 mm         1 each
P.V.C. Tube 2" x 10'                1 each
P.V.C. Tube V x 1C'                1 each

-------
                     EXPENDABLE EQUIPMENT (Con?d)
 Item
Quantity
Packaged
Amount
Required
 FILM

 C-135-36-100-Prints
 C-135-36-200-Prints
 C-l 35-36-WO-Prints
 C-135-2
-------
MOBILIZATION
2.7.4.2     Mobilization
           Two major considerations that a Project Manager must keep in mind during the
           mobilization phase are personnel and equipment.

           Manpower  assignments should  be  made keeping scope  of work  and personnel
           expertise in mind.  Different projects will have a varying degree of complexity
           requiring the Project Manager to adjust his personnel requirements accordingly.
           In  addition, the scope  of  certain  projects  may  dictate  that  an "expert" in a
           particular technical area be included.  If such a need arises, the Project Manager
           should recognize the  requirement in  advance,  and plan  for the appropriate
           individual to be included on the project team.

           An  equipment  list  should be made  in the early  stages of  mobilization.   A
           preprinted  equipment  list for  all  similar projects makes equipment securing
           simpler.   The  Project Manager  should  distribute the  equipment  list  to  all
           concerned field personnel  for their input.

           Once the equipment needed  for a  project is realized, it  is the responsibility of
           the  Project Manager  to  make sure  such  equipment  is secured.   Using the
           complete equipment list with all required  equipment for the project checked off,
           the Project Manager or his designee  should obtain  the equipment in advance of
           the projected  field work.  (See example  of equipment list at the end  of this
           section.)

           On  large  scale or  long  term  projects,  it may be  necessary to  establish an
           extensive  command post consisting of offices,  personnel  decontamination units,
           and eating facilities.  The establishment  of the  command post will require the
           appropriation of local  utilities  such as  electric, water and  telephone services.
           Electric, water and telephone services can often be arranged if the local utilities
           are contacted well in  advance.  Additional charges are  incurred if the  service
           needed  is not  readily  available.   These  costs  will be  included  in the  project
           budget.   Generators,  bottled  potable  water, and radio communications are
           alternatives if the site is  so remote that utilities are unavailable, or prove not to
           be cost-effective.

           Subcontractors may  be needed  for site inspections.  They include well drillers,
           geophysical investigators, labor contractors, heavy equipment contractors, etc.
           The  Office  Manager   should require subcontractors to  sign  a subcontractor's
           agreement.   The subcontractor's agreement  delineates the  Scope  of  Work
           expected  from  the  subcontractor,  the time  frame  which  is  expected of the
           subcontractor  and the  cost of the  subcontractor's phase.  The  Project Manager
           will  expect the subcontractor  to meet OSHA  standards.  If  the subcontractor
           does  not meet  OSHA standards,  the  Project  Manager  should  either consider
           another subcontractor  or  supply the subcontractor with  the necessary equipment
           to meet the standards.  In either  case, the Project Manager should expect  to
           train the  subcontractors in  the use  of  the necessary  dermal  and respiratory
           protective equipment needed for the project. The Project Manager  must  receive
           in  writing the  obligations  of  the subcontractor regarding safety requirements and
           the subcontractor's responsibilities  for their phase in the project.

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              PROJECT

              MANAGER
                       REQUESTS

                       SAMPLES
  PROJECT

  MANAGER
          REQUESTS
         .SAMPLES
COORDINATES
SAMPLES
AND RELAYS
SAMPLE
REQUIREMENTS
                        REQUESTS
                        3AMPLES
 V"'
   OFFICE
  SAMPLING
[COORDINATOR
           PROCUREMENT OF
SAMPLE SPACE FOR SITE INSPECTIONS
               ARRANGES FOR
               LABORATORIES
               AND RELAYS
               CONFIRMATION
                                       OFFICE

                                      SAMPLING

                                    COORDINATOR
                                    NOTIFIES
                                    PROJECT MANAGERS

-------
MOBILIZATION
2.7.4.2.1     General

            The  Project  Manager should  reorganize  wherever necessary.   Plans will
            continually change and the Project Manager must be prepared  to accept and
            deal with the changes.

            Changes are  more easily handled if the Project Manager plans  the project to
            allow for changes to  take  place  without  the interruption of the rest of  the
            project. This is accomplished using several planning methods.

                1.  Do  not make plans  contingent  upon  another phase wherever  possible.
                   The  domino theory applies to this situation.  Should one plan which is a
                   prerequisite  of another  fail, then other phases or plans are adversely
                   affected.

               2.  Keep procedures simple.  Complicated procedures have many  intricate
                   steps  subject  to  breakdowns and  malfunctions.   The  reduction  of
                   intricate steps reduces the possibility  of breakdowns  and  malfunctions.

               3.  Flexibility  in  planning.    Allow  and anticipate  changes  in  plans
                   throughout the project.   Prepare alternative plans  and  procedures in
                   case of breakdowns  and malfunctions. The more flexible a project  is,
                   the smoother the operation will go.

               >+,  Allow  overkill.  Plan for  more supplies than you need  within budget
                   constraints.  Miscalculations and changes in plans  will  stress your
                   inventory.   Excess  inventory will  eliminate  project  downtime  if
                   circumstances require the  Project Manager to change plans.

            These  steps will  help the project run smoothly and prevent costly man-hour
            loss due to  project downtime that results from unanticipated problems.

2.7.4.2.2    Long Term  VS. Short Term

            Short  term  projects  will  not  require  the  extensive equipment lists,  large
            budgets,  subcontractors and purchasing  that  are  required  by  long  term
            projects.  However, a greater  amount of preplanning and  flexibility may  be
            required for short term  projects due to a  less tolerant budget, a less variable
            equipment  list, and a lesser degree of attention that is given to a smaller
            project. For  these  reasons, short term projects are often  more difficult  to
            plan and generally more troublesome to execute.

            The decision  to treat  a project  as a large or small one is usually dependent on
            the budget  and  the amount of importance the project demands.  The nature of
            the  project  could  determine  whether  establishing  a  command  post  is
            necessary.  The advantages of establishing a  command post  are:

            a) Better communications leading to improved project management.

            b) The  separation of the clean  work zone from contaminated areas, reducing
              chemical exposures, and  improving worker productivity.

            These  steps  and considerations  aid  the  Project  Manager in  successfully
            mobilizing a  project of small or large magnitude.

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MOBILIZATION
2.7.4.3      Demobilization
            Demobilization  from  a site  involves  the completion  of  work  efforts and
            departing the site in a manner that will leave all site conditions at their pre-
            inspection status.

            Unless  special  arrangements  are  made,  all materials  generated from  the
            decontamination of equipment or personnel should be containerized and taken
            off site for disposal.

            Appropriate  paperwork and  log  books should  be  reviewed  by the  Team
            Leader/Project   Manager  to  assure  all   pertinent  information  has been
            recorded and proper QA sign-offs are complete.

            Any  chain of  custody  or sample splitting and documentation should  be
            reviewed  to assure the validity of sample data.

            The Team Leader or his representative should  meet with the site contact if
            present to give  notice of their departure, leave  receipt of samples and  sample
            splits if requested, and answer any  questions.
2.7.4.3.1    Decontamination
            Decontamination is designed  to control the spread of contamination to clean
            areas   by   physically  removing  contaminants   and/or  converting  them
            chemically into innocuous substances.  How extensive decontamination must
            be  depends on a number of factors, the most important being the types of
            contaminants  involved.   The  more harmful the  contaminant,  the  more
            extensive and thorough decontamination must be.

            Decontamination methods and equipment  needs  for  each different level of
            safety  shall be  described later  in the  course.   The  exact  procedure is
            determined by the conditions of  the particular site  and activities that will
            occur  there.   For  most  site  inspections,  disposable  clothing is bagged  or
            drummed,   left  on  site  or  disposed  of  appropriately.   Non-disposal
            contaminated tools, equipment, or  clothing are either decontaminated  with
            the appropriate solutions  at the site, or containerized and brought away from
            the site to be decontaminated later.
2.7.4.3.2    Waste Disposition
            The problem of handling and properly disposing of investigation-derived waste
            is ongoing.  Many questions need to be answered including the following:

               1.  When is the waste considered hazardous?
               2.  If we create waste through our field sampling  and decontamination
                   activities are we considered RCRA generators?
               3.  How do we transport the waste?
               4.  Where do we store the waste?
               5.  What mechanisms are in place to dispose of the waste?

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                    EXPENDABLE EQUIPMENT (Confd)
Item
Quantity
Packaged
Amount
Required
MISCELLANEOUS

Aluminum Foil
17# Drums 55 gal.
170 Drums 35 gal.
Kimwipes
pH Paper
Plastic Roll 10' x 25'
Trash Bags O gal.
Vermiculite
500' roll
1 each
1 each
box
2 rolls
1 roll
20 box
1 bag
  _£/_
Item
Quantity
Packaged
Amount
Required
WRITE IN:
•Preservatives, calibrating solutions, sample packing materials, and special items of
equipment are  the responsibility of the Project Manager.
                                   DEPARTURE DATE:
GROUP MANAGER

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                            NON-EXPENDABLE EQUIPMENT


       Equipment                                 Amount Required
CAMERAS

Cannon AE1
Polariod One Step
Polaroid SX70
Camera bag
Binoculars
AIR MONITORING

HNU Photoionization Detector                       	
Draeger Tubes                Type ^ £tf -4-  t^> £        j. ;
Organic Vapor Analyzer                              	/
OVA Chart Recorder                                	
Explosimeter                                           /
Combination Explosimeter and O2 Indicator            	
Oxygen Indicator                                       /
Draeger Tube Hand Pump                               /
H2S Gas Indicator                                      /
Mercury Sniffer                                     	
Photovac
METERS

Radiation Mini-Alert
Conductivity Meter
pH Meter
Resistivity Meter (Bison)
Resistivity Meter (Soil Test)
Metal Detector
SURVEYING EQUIPMENT

Optical Rangefinder
Level, Hand 2X
Brunton Transit w/case
Compass
200' Fiberglass Measuring Tape
300' Fiberglass Measuring Tape

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                        NON-EXPENDABLE EQUIPMENT (confd)
       Equipment                                Amount Required
PUMPS AND LIQUID SAMPLING EQUIPMENT

Double Diaphragm Pump 1"
Submersible Pump 1"
Submersible Pump 2"
Pitcher Pump 2"
Bacon Bomb Sampler
Kernmerer Sampler
LG Well Kit Sampler
SM Well Kit Sampler
SS BaiJer
Teflon Bailer
Bottom Filling Bailer
SOIL SAMPLING EQUIPMENT

Spoons Lg
Spoons Sm
Spatula Lg
Spatula Sm
Scoops
Trowel
Large Stainless Steel Bucket
Medium Stainless Steel Bucket
Small Stainless Steel Bucket
Split Spoon Sampler
3" Bucket Auger
3.5" Hand Auger
Dredge
DECON EQUIPMENT

Indian Tank
Heavy Duty Sprayer
John Deer Power Spray w/gas can
50' Sec. Garden Hose
Mop
Lg Hdl Dairy Brushes
SM  Hdl Dairy Brushes
Scrub Brushes
Bottle Brushes
'•Vhisk Brushes
\lire Brushes

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                        NON-EXPENDABLE EQUIPMENT (conf d)
       Equipment                                 Amount Required
POWER EQUIPMENT

Digger Mobile
3 HP Water Pump w/gas can
Generator w/gas can
Power Auger w/gas can
Extension Cord-Heavy  Duty 100"
Extension Cord-Light Duty 25"
Remote Drum Opener
PERSONAL PROTECTION

Hard Hat
Safety Goggles
Safety Glasses
Splash Shield
Full Face Respirator
Respiratory Cartridges
Butyl  Rubber  Apron
Encapsulated  Suits
Life Vests
Rain Jacket
Rain Pants
SELF CONTAINED BREATHING APPARATUS

WlSCBA
Dual Purpose SCBA
CASCADE System
i*5 cu. ft. Composite Tanks
Umbilical Breathing Air Lines (50' Sec)
Umbilical Breathing Air System
330 cu. ft. Class "D" Breathing Air Cylinder
STANDBY SAFETY EQUIPMENT

2Z/f Fire Extinguishers
02 Resuscitator
Stretcher
E-;e \Vash
Trauma Kit

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                        NON-EXPENDABLE EQUIPMENT (conf d)
       Equipment                              Amount Required
HAND TOOLS

Hacksaw
Post Hole Digger
Bung Wrench
Rake
Saw
Ax
Shovel
MISCELLANEOUS

Beeper
Ventilation Smoke Tube Assy.
Isotemp Oven
Wind Speed and Direction Finder
Garbage Can
Clipboard
S3 qt. Ice Chest
40 qt. Ice Chest
Write In:
                                                  Departure Date   ,3 - ?1
Group Manager   ,/. .  C, •  t~ £ P <-
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2

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2.7     SITE ACCESS

2.7.1    Introduction

Prior  to entering a site a number of key people should be contacted.  This section
will describe the reasons why  and the procedures to follow in  contacting certain
groups.   In  all  cases,  the inspector  should  at  least  consider  whether these
individuals would be interested in knowing if you are going on site. In many cases,
they may  aid you in your study.  Prior contact may ease your efforts and prevent
any possible  future negative repercussions, both legal and political,  from having
failed to properly inform affected parties.

The key people can be categorized into four groups:

           health and safety support persons
           community/neighborhood contacts
           municipal, city, county, state, or Federal persons
           owner/operator

2.7.2    Health and Safety Support Contacts

These people are discussed  in  greater  detail in  Section  4-1  on health and safety.
Briefly, these  might include police, emergency  medical technicians  (ambulance),
hospital staff,  firemen, etc., who would help  to  protect the safety of  individuals
working on site.

2.7.3    Community Contacts

It  is  difficult  to  remain  unobtrusive  while  conducting  site inspections in a
residential area while  wearing obtrusive protective  clothing   such as respirators,
bright protective coveralls,  boots    and carrying imposing equipment   HNU,
radiation  detection meters, etc.  Considering  the increased  national awareness of
the hazardous  waste problem, the presence of "official  looking people" in protec-
tive clothing may alarm residents.
                                      SA-1

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EPA CERCLA Cooperative Agreements (CAs) require States to take into consider-
ation community  relations when  undertaking Fund-supported work.  For  post-NPL
activities  (RI/FS, RD)  States are required  to have a community  relations plan
(CRP) submitted with the funds application.  For pre-NPL activities (i.e., PAs, Sis,
SIFs) States are asked to consider community interests prior to undertaking SI field
work.   No  overall plan is necessary, however, States are  required to  notify the
appropriate  individuals  in advance of conducting an SI where community concerns
might arise from  the presence of field  inspectors.  This would most likely occur at
sites located in or near  residential areas.

At a minimum, States must assess, as part of their  background data collection step,
whether some level of controversy exists or is likely to develop due to SI activities.
State community  relations coordinators (if  they exist) and EPA regional community
relations coordinators may be helpful in providing starting points and contacts.

If after assessing the  possibility of  controversy,  the  State decides there  may be
local interest, the State should identify appropriate  contacts  to call or visit.  The
discussion   should  remain  as  factual  as  possible,  avoiding  opinions  or  raising
expectations for  future action.   The contact should  clearly understand that the
agency  conducting the inspection does not know  if there  is a problem  but  is
attempting to look into  the problem.  The State should:

            explain the purpose of the activity
            identify the  location of the site
            explain the tasks to be performed
            identify a contact  for further information

The local contact should  be  asked if there are  other possible  interested parties,
whether an  additional  meeting  should  be held  or  flyers distributed, and  if the
contact  is interested in  receiving results of  the SI.

After the meeting, State staff should write up a summary of the discussion as soon
as possible for  future references.  Staff should prepare a final list of all interested
officials and citizens with pertinent titles and  affiliations, addresses,  and phone
                                      SA-2

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numbers.  The list will be included in any subsequent Community Relations plan for
the site.

In no situation, should an inspector arrive at  the door of a 3rd  party local resident
seeking access to their property  to  take samples, (especially  wearing protective
clothing) without prior contact.

The following person is your EPA Regional Community Relations coordinator:
2.7.*    Municipal/County/State/Federal Contacts

Prior  to initiating  field work  for  an SI,  it  is advisable to contact  local health
department officials, other local affected  agencies, and affected Federal agencies.
These groups are a  resource for information on site  practices, site  history, site
compliance records, etc.  Often they will have knowledge of other investigations or
enforcement activities  that could potentially conflict  with  the SI or  could affect
their  enforcement  efforts.   Where  appropriate,  the interferences  should  be
minimized. Ongoing efforts by other agencies in and of itself are not sufficient
reason to cancel or  postpone an inspection   but where  adjustments can be  made,
without compromising the health and safety of the public or the environment,  these
should at least be considered.

2.7.5    Owner/Operator

Overview

Site inspections (Sis) are  influenced by a variety of legal concerns that must be
appreciated from  the outset.  Although an  inspection  may  be authorized by any
number of federal or state statutes, there are overall constitutional, statutory, and
evidentiary legal  requirements that define  the  broad  procedural limits of each
phase of an investigation.  An inspector  always must  be aware that the primary
                                      SA-3

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function is to gather accurate data in accordance with the fundamental principles
of law, so as to:

           Insure that the data gathered can be used  effectively in  enforcement
           proceedings,

           Protect the rights of the inspected party and third parties and minimize
           the inspector's potential liability, and

           Minimize the risk to affected third parties.

Unless  legal concerns are  properly respected, the accuracy of inspection data may
be  rendered suspect, the  safety of third parties may be jeopardized,  data may be
excluded  from legal proceedings on  evidentiary grounds, and  the  inspector  may
leave him- or herself open to criminal and civil  penalties as well as potential third-
party liability.

2.7.5.1  Site  Access

The owner, operator, or person in charge of a site (hereinafter, the owner) does not
have an absolute right to  control who enters his or her property.  The site owner
must submit to an inspection by authorized  governmental representatives but he or
she is entitled to insist that the entry on his  or her premises be made in accordance
with accepted  legal procedures.  The site owner has the right either to consent to
an  inspection or to refuse  to allow  the  inspector  to  enter his  or  her   premises
without a proper  warrant.

2.7.5.2  Consensual Entry

The  inspector should attempt  to obtain the consent of the agent in charge of the
site  before seeking a warrant.   Guidelines governing consensual entry are  outlined
below.

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Gaining owner/operator consent by advance notification is recommended for most
all  site inspections.   CERCLA does not  specifically  require  obtaining  advance
consent but in most situations  it is generally  appropriate (e.g., where  the owner's
representative is not at the site).  Advance consent should  be followed-up with a
written notification.  The person notifying the owner/operator should inform them
of the types of activities to be conducted (samples collected, pictures taken, visual
observation, etc.).  The notifier should also advise the site owner of his  or her right
to split samples and to  prepare containers  if  sample splitting will occur.   The
CERCLA  requirement   for  offering  split samples  and  receipts  should  take
precedence over individual  state laws if the state is operating with  Federal  funds.
In cases where ownership of an  abandoned  site cannot be determined or notice of
any sort  is impossible,  the  need for obtaining a  warrant  should be discussed with
counsel.   Advance  notification  may not be  appropriate  in  situations  where the
inspectors anticipate destruction of evidence (see  discussion on consensual entry).

The inspector  must avoid even the appearance of coercing the owner to consent to
his  or her entry.   An  entry  will  be considered  voluntary—even  if  the  owner
complains  or   otherwise  expresses his  or  her  displeasure   with  the  regulatory
inspection—as long  as the owner allows the inspector to enter the  premises.  If, on
the other hand, the inspector has gained  entry  by offering  a  verbal  or  physical
threat, the entry ultimately may be determined to be invalid, and any  information
obtained during the inspection could be suppressed at trial.

When the  inspectors arrive at the site, they should always present  their credentials
and  inform  the owner/operator or designee  of  the  nature  of the work and the
authority  for conducting the SI.

The owner may withdraw his or her consent at any time.  Withdrawal of consent is
equivalent to  refused  entry.   A  warrant should  be secured  to  complete  the
inspection.  However, any  information gathered  before the withdrawal of consent,
including  samples and photographs, can be used  in a  legal  proceeding.  Likewise,
any  information obtained while an inspector is  in  an area open to the  public is
admissible in  a legal proceeding.  This "plain view" theory has its limits, however.
                                     SA-5

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Any  mechanical aids—such as binoculars, detection equipment,  telephoto  lenses,
aerial photography, etc.—used by the inspector either in an area open to the public
or after  consent  has  been withdrawn, may result in the  suppression of  such
information at trial.

The  person  giving  the  consent  should  be  presented  with  a statement to sign
acknowledging the owner's consent.   The statement  should be retained by  the
inspector and  included in the inspection  report as documentation of the consent
given.

Consent may be given with conditions.  In general this should  be avoided. However,
if the conditions  do not significantly  interfere with the  conduct of  the SI,  the
inspectors may chose to proceed. Any conditions then must be accurately noted in
the log book.  For  example, the owner may limit the places  where  inspectors can go
or employees with whom to interview, or the owner of a facility may  require the
inspectors to sign hold-harmless agreements and confidentiality  agreements as a
prerequisite  to entry.  Although the legal validity of hold-harmless agreements is
doubtful, in  most cases  the  inspector  should  not  sign such agreements.   State
employees should  consult with  their  lawyers  and/or  the  region to  determine
whether such agreements  are justified or  should be treated as a  refusal  of entry.
Before  visiting the site, the inspector should be informed  about  which  conditional
consent entry guidelines are to be followed.  As an alternative, the inspector should
refuse to sign  anything, even the visitor's log, and offer instead a blank sheet of
paper with entry/exit times or, a previously prepared statement  that contains the
following information:

           Inspector's name, title, and employer;
           Physical description;
           Some form of identification (driver's license, ID  card);
           Brief general description of  the activities to be conducted at the site;
           and
           Entry/exit times.
                                     SA-6

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The  inspector  may  have to consider obtaining a warrant if  the  owner/operator
limits the inspection to the point  that it prevents the inspectors  from obtaining
important information.

2.7.5.3  Nonconsensual Entry

If consent cannot be obtained or is withdrawn, the inspector  should seek a warrant
to obtain entry. The inspection must be conducted strictly in accordance with the
warrant. If the warrant restricts the inspection to certain areas of the premises or
certain  records, those restrictions  must be adhered to.  Failure to adhere strictly
to the applicable  limitations on the scope  of  an inspection could jeopardize the
admissibility of information obtained during an inspection.

When an inspector is refused entry, he or she should note the identity of the person
refusing entry, the date and time of refusal,  the reasons given  for  refusal, and
other pertinent details.  He or she  should then leave  the premises and  immediately
notify his or her manager and the appropriate agency  attorney to obtain a warrant.

2.7.5.4  Warrantless Entry

If an emergency exists  or  there  is  no time to obtain  a warrant and owner consent
cannot be obtained, a  warrantless  inspection is permissible.  This would include
situations where there is a potential for destruction of evidence or where evidence
of a suspected violation may disappear  during  the time that it takes to obtain a
warrant.

Similarly, some courts  have  held  that inspections under  the  Federal Insecticide,
Fungicide,  and Rodenticide  Act (FIFRA) and  the Toxic Substances  Control Act
(TSCA)  involving industries  that are  highly  regulated are not subject to warrant
requirements.  Inspectors should consult with counsel before entering a site without
consent and without a warrant. Inspectors should consider requesting  assistance or
backup from local police in this event.
                                      SA-7

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2.7.6   Other Issues

2.7.6.1  Limitations of Inspection

All  inspections are  limited  in  their  scope by  the  statute.   CERCLA
specifies that the inspector is empowered only to:

           enter specified establishments at "reasonable times"
           commence  and complete with reasonable  promptness to inspect and
           obtain samples of wastes, substances, containers, or labeling.

The scope of the inspection in a consensual situation may be limited by the consent
of the site owner.  The owner's ability to withdraw or place limits on the  scope of a
consensual  inspection  at any  time  can  narrow  significantly  the  scope  of any
inspection.  Finally, an  inspection undertaken  with a  warrant (nonconsensual)  is
controlled by the terms of the warrant.

2.7.6.2 Use of Contractors as Inspectors

Each of  the  various  acts authorizing  regulatory  inspections sets forth specific
restrictions governing  the use of contractors to government agencies.   Although
CERCLA allows for use  of contractors to conduct inspections (CERCLA 104(e)(l)
and  (f)), other acts are not as clear and will continue to be the focus of litigation.
Any contractor conducting inspections should clearly announce his or her contrac-
tor status and corporate  affiliation when identifying him- or herself and  should
display appropriate credentials verifying his  or her  designation as an authorized
representative.  The agency employing  the contractors should also be prepared to
send state personnel to a site if the owner expresses reservations about  allowing a
contractor onto a site.

Where the inspector is a private  contractor, his  or  her employer  should provide
adequate information on  the health hazards of working  with hazardous substances.
Similarly,  Section  104(f) and (g) of  CERCLA  requires contractors funded under

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CERCLA  cooperative  agreements  to  comply  with federal health  and  safety
standards and pay minimum wage.

In addition to  possible criminal and  civil penalties imposed by OSHA for violation
of Federal Health and Safety laws,  common law  theories of gross  negligence are
likely to be applicable to an employer's failure to properly inform and protect his
employees, and potential liability to private employers and government agencies is
great.

2.7.6.3  Walk-Around Right of Owner

The  question  frequently  arises about  the extent to which the site owner  may
accompany an inspector as he or she reviews operations,  interviews employees, and
so on.

Every reasonable effort should be  made to afford walk-around  rights to the site
owner.  If multiple work sites are involved, it may be appropriate for one or more
owner representatives to accompany the inspectors.   However, the  inspector may
deny right  of accompaniment to  any person  whose conduct interferes with a full
and  orderly  inspection  or  poses any  threat to  the health and  safety  of the
inspectors.

Site  employee representatives can  provide valuable  information  to  the inspector,
but care should be taken to  insure  that the  employees  contacted are knowledge-
able, e.g.,  designated union  representative,  safety committee representative,  or
person familiar with the operations  in question. In the case of an inspection where
health  concerns are  paramount, the  inspector  may wish  to have  an  employee
representative accompany him during  portions of the  inspection.   Avoid  use  of
people who have "axes to grind".

If data are sought from  an area where  trade secret information  is maintained, the
inspector  should  ascertain  from  the  site   owner  whether any   accompanying
employee   representative is authorized  to  enter  the  area.   Similarly,  if  the
information sought has been  declared classified by a  federal government agency in

                                     SA-9

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the interests  of national security, only persons authorized to have access to such
information may accompany the inspector.

2.7.6.14-  Confidentiality

States are strongly encouraged to avoid accepting data that requires confidential
treatment.  If the owner insists on the confidentiality of data, states should have
their attorneys evaluate  whether their data qualifies under State and Federal laws
and  regulations for confidential  treatment.  It is extremely  difficult to deal with
confidential  data  if the  site is ever  listed on the  NPL.  Plus, it is  an incredible
burden  to store and control confidential data.  Under CERCLA 104(e)(2) and USC
Title IS, Section   1905, the owner of a hazardous  substance  facility has certain
legally recognized rights  to "trade secret" and "confidential"  information which the
inspector must be aware of and  protect.  Failure  to do  so  can result in criminal
penalties against  the inspector and civil suits against governmental agencies.  Site
inspectors  should  be thoroughly knowledgeable of the specific regulations of their
agency  as well as state and federal regulations if you are ever going to deal with
this  type of information.

Confidentiality/disclosure regulations provide that the owner of confidential infor-
mation  has the right to assert a  claim of confidentiality.  An inspector gathering
information by consent of the owner or  by warrant must recognize that such a
claim may be asserted by the owner at any  time.  If an inspector is confronted with
such a claim,  he should adhere  to  the guidelines described below.

First, the assertions of confidential claims  may be accompanied by the  withdrawal
of consent to  inspect certain areas. Such limitations on the scope of the inspection
should be noted in the log book.  Further inspection of information  for  which
consent has been withdrawn can only be conducted pursuant to a warrant.

Second,  if   the  owner/operator  asserts   confidential  claims  on   information
authorized  for  gathering  under  a  warrant  or  if  the owner/operator  asks for
confidential treatment but does not withdraw consent, the inspector may continue
to gather information  as long as procedures governing confidential  treatment of

                                     SA-10

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information are  followed.   For example,  such  procedures may require that all
information claimed to be confidential,  including photographic prints or negatives
and  environmental  samples,  be  labeled  confidential,  be  maintained  in  locked
segregated  files,  and not  be disclosed except  in  accordance  with established
procedures.

In a situation where  a confidential  claim  is asserted, the  inspector should advise
the  owner/operator  that  CERCLA  104(e)(2)(c)  specifies  that  the  owner must
designate  the  confidential material  in writing, and therefore  the owner must
follow-up the verbal request in writing immediately. The letter must identify

           material which is entitled to business confidential treatment
           reason to substantiate claim referencing appropriate legal authority.

EPA  regulations  governing  treatment  and  handling  of  confidential  data  are
delineated in 40  CFR Part  2,  Subpart B, Sections 2.201-2.309 (41  FR  36902,
September 1, 1976; amended 43 FR 39997 September 8, 1978).
                                    5A-11

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g, <}

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                         2.9 SAMPLING

2.9.1 INTRODUCTION

           Sound conduct of sampling is the next most important
      factor in ensuring that the data gathered can be used effec-
      tively in enforcement proceeding - next to proper site
      access procedures.  It is possible that the data gathered
      will provide the basis for future legal actions, including:

           0 State Enforcement

           0 EPA/NPL Listing

           0 EPA Enforcement/CERCLA

           There are two major areas where the admissibility/
      integrity of sampling can be compromised.  The following
      sections discuss these considerations in greater detail.

2.9.2 TECHNICALLY SOUND SAMPLING

            Defendants may be able to challenge the integrity of
      analytical results used against them if technically sound
      sampling is not used.  Error and bias can be introduced in a
      host of ways if inspectors are not properly versed in correct
      procedures.

      SOP' s

           The first way to reduce the likelihood of error is
      establishing Standard Operating Procedures (SOP's).  SOP's
      should be established covering all sampling activities.
      SOP's should be developed for each sampling devise, each
      instrument, and tailored to as many generic situation as
      routinely addressed.  For example, procedures for collecting
      surface water samples may vary depending upon whether the
      sample is collected from a turbulent stream or a relatively
      stagnant lagoon or lake.

           Where non-routine situations are confronted and
      deviation from established SOP's are made, notation of this
      should be made in the field log book.

           More detailed discussion on the content and scope of
      SOP's was discussed earlier.

      SAMPLE QA

           Once analytical data are received from the  laboratory,
      the results and backup QA data must be reviewed  to ensure that
      conclusions reached about the nature of  contamination are
      legitimate.  Past experience, has taught  the value of reviewing

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                                -2-
      the analytical data before making the raw data available.
      On the other hand seemingly "poor" analytical results may
      still be viable, if only qualitatively,  as long as it clearly
      understood how error was introduced in the result and what are
      the limitation of the results.
      GOOD FIELD TECHNIQUE

           Sound SOP's and analysis cannot make up for poor field
      technique.  SOP's are good only if they are followed.
      Proper field technique should never compromised due to
      inconvience.

2.9.3 PROCEDURALLY SOUND SAMPLING

           Analytical data may be determined to be inadmissible in
      court or considered unvalid if improper procedures are followed
      regardless of whether the analytical results are sound.

      CERCLA REQUIREMENTS

           CERCLA 104(e)(l) requires an inspector, upon leaving
      the premises, to offer the owner/operator

           0 a receipt of sample results, and

           ° an equal portion of samples

           From a practical perspective, the inspector should ask
      the owner/operator in advance of entering the site if he/she
      wants splits of samples rather than waiting until exiting the
      site.  Typically, the owner/operator should provide their
      own sample bottles.  In some unusual situations, it might be
      appropriate for the inspector to provide the bottles for the
      split samples.  The owner/operator should be instructed to
      be sure their sample bottles are properly cleaned.  It is
      advisable to bring an extra set of sample bottles in the
      event of any unusual developments.  Owners/operators sometimes
      change their minds at the last minute and decide they want
      split samples.  If this occurs, you may have to oblige.

           If the owner/operator declines a split of the samples,
      log this in your field logbook and have owner sign log book
      or a document declining splits.

           CERCLA 104(e)(l) also requires an inspector to provide
      the owner/operator with the results of the sample analyses,
      promptly.  Analytical data is not "official" until it has
      passed through a quality assurance check.

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                          -3-
CHAIN-OF-CUSTODY

     The purpose of chain-of-custody is to trace the
possession of a sample from the time of collection, until
it or the derived data is introduced as evidence in legal
proceedings.   Custody records should, therefore, trace a
sample from its collection, through all transfers of custody,
until it is delivered to the analytical laboratory.  At this
point, internal laboratory records should document sample
custody until its final disposition.

      Since it may not always be possible to know ahead of
time if a sample will be used as evidence in future legal
actions, it is a good common sense to institute chain-of-
custody in all instances.   Use of such SOP practices on a
project-to-project basis will contribute to the consistency
and quality of the generated data.

     Chain-of-custody involves (1) proper assignment of
unique sample identification numbers, (2) use of sample
tracking, chain-of-custody forms in the field,  (3) use of
custody seals, (4) documentation of sample locations numbers
or other relevant notations in field logbook or sample
receipt forms, and (5) use of chain-of-custody forms in
laboratories.  Each of these are discussed in greater detail
in the following sections.

     Sample Identification

     Preprinted, preserialized sample collection tags
are necessary to identify samples collected for shipment to
the analytical laboratory.  Specific analysis tags may also
be issued by the analytical laboratory after the sample has
arrived.  Each sample should be identified with a unique
project and sample number to clearly distinguish the sample
from others collected at the site and other projects.  For
each sample collected, including duplicates and field blanks,
a sample tag should be completely filled in with waterproof
ink.   The tags should cover a minimum of the following
informat ion:

     0 Project Code

     0 Location Number

     0 Date of Collection

     0 Time of Collection

     0 Location Description

     0 Signature of Sampler

     0 Remarks

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                          -4-
See Figure 1 on page 6 for an example of an appropriate
sample collection tag.  The remarks are located on the back
side of the tag.

    The source  from which the sample is collected shall be
clearly marked  in such a way to maintain traceability.  The
exact location  of each sample shall be recorded in the
logbook and documented on a site map.

     After sample analysis and appropriate quality assurance
checks have been make, original sample collection tags are
to be stored in a document file.  Maintaining such files and
records is an important aspect of sample traceability and
provides a needed cross referencing tool that can be used
to correlate any one of the identifying numbers and sources
(e.g., collection tag, laboratory number, master log, etc.)
with a specific sample.

    Chain-of-Custody Forms

    There are many transfers of custody during the course
of a sampling program, from time of collection through final
sample disposition, and all samples should be accompanied by
a Chain-of-Custody Record to document these transfers.  See
Figure 2 on page 7 for an example form.

     The custody records are used for a packaged lot of
samples (cooler); more that one sample will usually be
recorded on one form.  More than one custody record sheet
may be used for one package, if necessary.  Their purpose is
to document the transfer of a group of samples traveling
together; when  the group of samples changes, a new custody
record is initiated.  The original of the custody record
always travels  with the samples.

     In general, the following procedures should be followed
when using the  custody record sheets.

     ° The originator fills in all requested information
       form the sample tags (except in the case of air collec-
       tion media and external QC samples which will be
       accompanied by custody forms from the originating
       facility).  Always use water proof ink.

     0 The person receiving custody checks the sample tag
       information against the custody record.  He also checks
       sample condition and notes anything unusual under
       "Remarks" on the custody form.

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                         -5-
     0  The orginator signs in the to left "Relinquished by"
       box and keeps the copy.

     °  The final person receiving custody signs in the
       adjacent "Received by" box and keeps the orginal.

     °  The Date/Time will be the same for both signatures
       since custody must be transferred to another person.

     °  When custody is transferred to the Sample Bank or an
       analytical laboratory, there may be blank signature
       spaces left.  If this occurs a line should be drawn
       through unused signature boxes as is done for a
       personal check.

     0  In all cases, it must be readily seen that the same
       person receiving custody has relinquished it to the
       next custodian.

     0  If samples are left unattended or a person refuses
       to sign, this should be  documented and explained on
       the custody record.

     Custody Seals

     Custody seals are narrow strips of adhesive paper used
to demonstrate that no tampering has occurred.  They may be
used on sampling equipment or a well head (temporarily)  ,
but they are intended for use on a sample transport container
which is not secured by a padlock.  They are generally not
intended for use on individual  sample containers.
     Receipt for Samples Form

     When is becomes necessary to split samples with another
party, a separate receipt for samples form is prepared and
marked to indicate with whom the samples have been split.
The signature of the person receiving the split is required
and if this person refuses to sign, it should be noted in
the "Received by" space.

     This form complies with the requirements of both CERCLA
104(e) and RCRA 3007(a)(2).  A copy of the completed form
should be given to the person receiving the split samples
one of the above described individuals, even  if the offer
for split samples is declined.  See Figure 3 on page 7 for
an example receipt form.

     Laboratory Custody Procedures

     State laboratories or State contract laboratories must
have a designated sample custodian who implements a system

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                         -6-
to maintain control of the samples.  This includes accepting
custody of arriving samples, verifying that information on
the sample tags match the chain-of-custody record, assigning
unique laboratory numbers and laboratory sample tags and
distributing the samples to the analysts.

     The designated custodian is also responsible for retaining
all original identifying tags, data sheets and laboratory
records and retaining them in a permanent file or returning
them to the project leader/inspector for filing.

     Questions/Problems Concerning Custody Records

     If a discrepancy between sample tag numbers and custody
record listings is found, the person receiving custody should
document this and properly store the samples. It is recommended
that the discrepancy be resolved before analyzing the samples
and using precious lab space and funds.

     The responsible person receiving custody should attempt
to resolve the problem by checking all available information
(other markings on sample container, type of sample, etc.).
He/She should then document the situation on the custody
record an in the project logbook and notify the project QA
Manager promptly.

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             -7-
          Figure  1.
        Sample Tag
N 1000
                CurtraM Oi|.
                COO.TOC
                 • Hj.0fl.il
                 Mimu. Nioia

-------
                           CHAIN OF CUSTODY RECORD
       iPHOJtCTNAUt

                    Figure  2.  - Chain-of-Cus'tod^ Form
                    Figure 3,  - Receipt of Sample Form
                            ftECIIFT FON 1AMKCI
L-i-
                                                               349

-------
 CUSTODY SEAL
 Signature
Example of EPA Chain-of-Cuatody Seal

-------
S/
re

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                  2.10 SITE INSPECTION-FINAL REPORT
2.10.1  INTRODUCTION

        The guidance governing preliminary assessments and site
        insections  performed by States under EPA cooperative
        agreements  requires States to submit the following documents
        as part of  the final SI.   These components are:

              °  Narrative SI Report

              0  2070-13  Form

        Depending upon the workplan negotiated between the State
        and EPA,  some States will be required to submit one
        additional  component:

              0  HRS score package (score sheets, documentation
                 record,  attachments)

        It is important to note that the 2070-13 Form will be
        replaced  by a form which will in effect merge the 2070-13
        and HRS documentation form.  When this form becomes available.
        States will be asked to complete this form in place of the
        2070-13 form.

2.10.2  NARRATIVE SITE INSPECTION REPORT

        The following is  the recommended outline for the site
        inspection  narrative report.  States may adjust the
        outline as  appropriate, however, the information identified
        below should be presented in whatever format the State
        uses.

             0  Summary

             °  Site Background

             0  Environmental Setting

             0  Site Map, Photographs, Sketches

             0  Waste Characteristics

             0  Laboratory Results

             0  Toxicological Characteristics

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             0  Conclusions and Recommendations

             0  Bibliography

             0  Appendices

2.10.3  FILES

        The State must retain a file of non-reference documents
        compiled and used in preparing the final site inspection
        report.  This report will eventually serve as the basis
        for substantiating work under the site inspection.  If the
        site is eventually listed on the NPL, the file will also
        become, by reference, background for the official
        administrative record for the EPA.  If the site is to
        withstand any possible administrative and technical challenges
        by the .responsible party it is important that the file be
        complete and well organized.  The file will also serve as
        the basis for substantiating State work in the event of a
        grant audit.  Although frequently different individuals
        maintain a personal file it is important to have one file
        which consolidates copies all of background documents.

        The file should contain but not be limited to:

             0  Background Reports

             0  Memorandums

             0  Workplan/Sampling Plan

             0  Records of Communication

             0  Maps

             °  Photographs

             0  Field Log Books

             0  Laboratory Reports

             0  Sample tapes, Chain-of-Custody Forms, etc.

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OP

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QUALITY ASSURANCE
OF ANALYTICAL DATA
2.11.1      PURPOSE
           The Quality Assurance of data is performed  to assure the reliability of all data
           generated from sampling efforts and any related field activity.
2.11.2     APPLICABILITY
           The  Quality  Assurance  of data  is necessary  to ensure  that  only  accurate,
           reliable, and  valid data  is used in the generation of reports  and deliverables,
           including the  Hazardous Ranking System (HRS) Model.
2.11.3     DEFINITIONS
           Quality Assurance  the  total  integrated program for assuring the reliability of
           monitoring and measurement data.

           DISCUSSION

           To understand  the  concepts of why  data is  Quality  Assured,  it is  helpful to
           understand  the  process  by which  such data is generated,  from  the   initial
           sampling effort to  the  time it is incorporated  into final reports, including the
           HRS Model.

           The  flow  diagram  presented as Figure 2.11-1  tracks  a normal set of samples
           from  the  initial sampling  effort  to  resulting  final  use  as Quality  Assured
           generated data for incorporation into the HRS Model.

           Though each individual state office may follow their own office specific routing
           system  for  the  Quality  Assurance of data, this example provides the general
           procedure by which data should be processed before it can be  considered valid.
2.11.5     RESPONSIBILITIES
           The responsibility for the procurement, review, and Quality Assurance of data
           is shared jointly by the  sampling team, the State Office  Data Coordinator, and
           the State Office Quality Assurance Division.
2.11.6     PROCEDURES
           The  following summarizes the major procedures used  in the overall  scheme of
           data Quality  Assurance once  the State Office has  initially  received  a data
           package.

           \t first, a Preliminary Data Review is conducted on the data package. This can
           be done by a  member of  the sampling  team familiar with laboratory and data
           reporting  procedures.

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                                                               PROPER PACKAGING AND
                                                               CHAIN OF CUSTODY
STATE OFFICE
DATA COORDINATOR
:

MISSING DATA
 FORWARDED
                      CALLS FOR
                     MISSING DATA
                                                               ANALYZES SAMPLES AND
                                                               REPORTS RESULTS
                                                               DATA TO STATE FOR
                                                               PRELIMINARY DATA REVIEW
                                                               COMPLETES PRELIMINARY
                                                               DATA REVIEW
                                          STATE OFFICE
                                        DATA COORDINATOR
      STATE OFFICE
    DATA COORDINATOR
                         COMPLETED
                        DATA PACKAGE
        IF NO MISSING DATA,
      |  COMPLETED DATA PACKAGE
STATE OFFICE
 QA DIVISION
                                          STATE OFFICE
                                        DATA COORDINATOR
QUALITY ASSURES DATA
                     SENDS DATA TO SAMPLING
                     TEAM PROJECT MANAGER
                                                               COMPLETES HRS MODEL
                                          STATE OFFICE
                                        DATA COORDINATOR
                      QUALITY  ASSURANCE OF ANALYTICAL  DATA
                                       FIGURE 2.11-1

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QUALITY ASSURANCE
OF ANALYTICAL DATA


    The scope of the Preliminary Data Review should include:

        U   Ensuring that all deiiverables set forth in  the laboratory contract are included
            within the data package.
        2)   Checking that the completeness of the forms is acceptable within the scope of
            the contract.
        3)   "Flagging"certain data within  the  package which falls outside  the acceptance
            criteria range.
        >+)   Complete a checklist of questions which summarize and present  key items in
            the data package (See example on following pages)
        5)   Deliver  data  package, checklist, and a list of missing documents to the State
            Office Data Coordinator.

        It is the responsibility of the Data Coordinator to review the checklist and list of
        missing documents and then contact the laboratory to secure such documents.  The
        Data Coordinator  then delivers the data package, and  if necessary, any missing
        documents forwarded by  the laboratory, to the Quality Assurance  Division of the
        State Office.

        The Quality Assurance  Division performs  the actual qualitative  analysis of the
        data.   Based  upon the sampling  results  in  the data  package, the information
        presented  from the Preliminary Data Review,  and their own expertise, they either
        accept or reject various components of the data package.  This function performed
        by  the Quality Assurance Division  is generally the most intensive part of the  Data
        Quality Assurance process.

2.11.7   RECORDS

        The data package itself serves as a record of what data are accepted or rejected by
        the Quality Assurance Division.

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             CHECKLIST FOR PRELIMINARY REVIEW

    OF CONTRACT LABORATORY PROGRAM ORGANICS DATA
                            Revision 5
                             1/24/85
Site Name:
Case // and/or SAS // :

CLP Laboratory:	

Contract // :
CLP Data Received from Laboratory on:

Preliminary Review completed on:	
Laboratory contacted about Missing Information on:
Supplemental Information received from Laboratory on:

Preliminary Reviewed Data submitted
to the Monitoring Management Branch on:	
Preliminary Reviewer:

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                                                         Revision 5
                                                         1/24/85
      CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA
REVIEW CRITERIA                                         YES       NO
1.0    Cover Letter

1.1    Is the Narrative or Cover Letter present?

1.2    Are the following items contained in the Narrative
      or Cover Letter:

      a.  Case Number and/or SAS Number

      b.  Contract Number
2.0    GC Screen Data (Optional)

2.1    Is the GC Screen Data Sheet present?
      (See Attachment 2.1)

2.2    Are all the sample numbers listed on the GC Screen
      Data Sheet?

2.3    Are the GC Screen Chromatograms present for the
      samples and blanks?  If no, please list the missing
      Chromatograms below.

      Missing Chromatograms:	

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                                                        Revision 5
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  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                      YES       NO


3.0   Organic Analysis Data

3.1   Are the four W  Organic Analysis Data Sheets (VOA,
     BNA, Pesticides and Tentatively Identified Compounds)
     present for each of the following. (See Attachment
     3.1) If no, please list the missing Data Sheets below.

     a. Samples and/or fractions as appropriate	       	

     b. Matrix spikes and matrix spike duplicates         	

     c. Blanks                                          	       	


     Missing Data Sheets:

     VOA:
     BNA:
     Pesticides:
     TIC:
3.2   Are the Reconstructed Ion Chromatograms for each sample,
     the mass spectra for the identified compounds, and the
     Data System Printouts (Quant, list) included in the
     sample package for each of the following. If not, please
     list the missing Reconstructed Ion Chromatograms,
     mass spectra, and Data System printouts below

     a. Samples and/or fractions as appropriate           	       	

     b. Matrix spikes and matrix spike duplicates          	       	
        (Mass spectra not required)
     c. Blanks
     Missing Reconstructed Ion Chromatograms and Data System Printouts:
     Missing Mass Spectra:_

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   CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANIC DATA (cont'd)


REVIEW CRITERIA                                      YES       NO


3.3   Are the mass spectra for the standards present for    	      	
     compounds identified in the samples?
     Missing Mass Spectra:
     Are the mass spectra for the tentatively identified
     compounds and associated "best match" spectra
     included in the sample package for each of the
     following.  If no, please list  the missing numbers
     below.

     a. Samples and/or fractions as appropriate

     b. Matrix spikes and matrix spike duplicates
        (Mass Spectra not required)
     c. Blanks

     Missing Mass Spectra:	
4.0   Surrogate Percent Recovery Summaries


4.1   Are the Surrogate Percent Recovery Summaries present
     for each of the following matrix:

     a. Water (See Attachment 4.1)                      _

     b. Soil (See Attachment 4.2)                        _


4.2   Are all the samples listed on the Surrogate Percent
     Recovery Summaries for each of the following matrix:

     a.  Water (See Attachment 4.1)                      _

     b. Soil (See Attachment 4.2)

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                                                        Revision 5
                                                        1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)

REVIEW CRITERIA                                      YES       NO
4.3  Are the surrogate percent recoveries listed for all    	
     the blanks?
4.4   Are all the water data within the specified limits
      presented in Attachment 4.1 for the following parameters:
      (Please circle the outliers in red.)
      a.  Volatiles                                        	
      b.  Semi-Volatiles                                   	
      c.  Pesticides
4.5   Are all the soil data within the specified limits
      presented in Attachment 4.2 for the following
      parameters:  (Please circle the outliers in red.)
      a.  Volatiles
      b.  Semi-Volatiles
      c.  Pesticides
5.0   Reagent Blank Summary

5.1   Is the Reagent Blank Summary present?
      (See Attachment 5.1)
5.2   Is there at least one blank listed on the Reagent
      31ank Summary for every twenty (20) samples?
6.0   Matrix Spike Duplicate/Recovery Form
6.1    Is the Matrix Spike Duplicate/Recovery Form present?
      (See Attachment 6.1)
6.2  Is there one duplicate listed on the Matrix Spike
     Duplicate/ Recovery Form for every twenty (20)
     samples?

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                                                      Revision 5
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  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)



REVIEW CRITERIA                                     YES       NO


7.0   GC/MS Tuning and Mass Calibration Forms
7.1   Are the GC/MS Tuning and Mass Calibration forms present
     for the following:

     a.  Bromofluorobenzene (BFB)                      	
        (See Attachment 7.1)

     b.  Decafluorotriphenylphosphine (DFTPP)           	
        (See Attachment 7.2)

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                                                       Revision 5
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  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA
7.2   List the time and date that the Volatile fractions were run below:
Sample Number
Instrument
Time
Date
7.3   List the time and date that the BFB samples were run below:
     Instrument
  Time
                                                  Date

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                                                       Revision 5
                                                       1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA
7.4   List the time and date that the Semi-Volatile fractions were run below:
Sample Number
Instrument
Time
Date
7.5   List the time and date that the DFTPP samples were run below:
     Instrument
  Time
  Date

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                                                        Revision 5
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      CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA


REVIEW CRITERIA                                      YES       NO
7.6   Are the bar graph spectrum and mass/charge (m/z)
     listings for the BFB provided for each twelve (12)
     hour shift? If no, please list the missing spectrum
     and listings below.

     Missing spectrum and listings:
7.7  Are the bar graph spectrum and mass/charge (m/z)
     listings for the DFTPP provided for each twelve (12)
     hour shift?  In no, please list the missing
     spectrum and listings below.

     Missing spectrum and listings:
7.8  Is the Cross Reference Table present
     (Refer to Attachments 7.1 and 7.2)
3.0  Instrument Tune and Performance Summary (Optional)
8.1   Is the Instrument Tune and Performance Summary
     present?  (See Attachment 8.1)
8.2   Are the BFB and DFTPP Performance Results found
     within the specified criteria presented in
     Attachment 8.1?

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                                                          Revision 5
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   CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                        YES       NO


9.0    Initial Calibration Data Sheets


9.1    Are the Initial Calibration Data Sheets present and
       completely filled out for all compounds for the
       following fractions:

       a. Semi-Volatiles (See Attachment 9.1)               	       	

       b. Volatiles (See  Attachment 9.2)                                	
9.2     Are the semi-volatile data within the specified
       limits presented in Attachment 9.1?
       (Please circle outliers in red.)
9.3    Are the volatile data within the specified limits
       presented in Attachment 9.2?
       (Please circle outliers in red.)
10.0   Calibration Check Sheets


10.1   Are the Calibration Check Sheets present and
       completely filled out for all compounds for
       the  following fractions:

       a.   Semi-Volatiles (See Attachment 10.1)

       b.   Volatiles (See Attachment 10.2)


10.2   Are the semi-volatile data within the specified
       limits presented in Attachment 10.1?

       (Please circle outliers in red.)
10.3   Are the volatile data within the specified limits
       presented in Attachment 10.2?
       (Please circle outliers in red.)

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                                                            Revision 5
                                                            1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                     YES      NO

11.0  Standards Data Package
11.2  Are the Reconstructed Ion Chromatograms, Data System
      Printouts (Quant, list), and  work sheet calculations
      present for the following:
      a.   Samples                                     	
      b.   Blanks                                       _
      c.   Matrix  spikes                                	
      d.   Matrix  spike duplicates                       	

11.3  Are the Gas Chromatograms and Data System Printout
      present for  the following:
      a.   Pesticide Standard                           _
      b.   PCS Standard
                                      10

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                                                             Revision 5
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  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA

11.4   List the times and dates that the Pesticide/PCB samples were run,
      if the laboratory has not summarized them in a table.
Sample Number
Instrument
Time
                                     Date
11.5   List the times and dates that the Pesticide/PCB Standards were run,
      if the laboratory has not summarized them in a table.
     Instrument
  Time
  Date
                                      11

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                                                         Revision 5
                                                         1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA                                       YES      NO
12.0   Detection Limits
12.1    Is the list of currently calculated detection
       limits present?  (The limits should not be the
       same for all of the parameters.)
13.0   Package Copies


13.1   Are all the xeroxing of readable quality?
                                       12

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                                                       Revision 5
                                                       1/24/85

        CHECKLIST FOR PRELIMINARY REVIEW OF CLP DATA (cont'd)
REVIEW CRITERIA
14.0   Reagent Blank Chronology
14.1   List the time and date that a reagent blank or instrument blank
      was run on instrument for each of the fractions listed below:
Sample Number

     VOAs
Instrument
Time
     BNAs
Pesticides/PCBS
Date
                                     13

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                                                              Revision 5
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  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGAN1CS DATA (cont'd)
                Review Criteria Supplemental Information Table
Review Criteria
Sample
Number
Instument
Time
Date

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QUALITY ASSURANCE
OF ANALYTICAL DATA
2.11.1      PURPOSE
           The Quality Assurance of data is performed to assure the reliability of all data
           generated from sampling efforts and any related field activity.
2.11.2     APPLICABILITY
           The  Quality Assurance  of data  is necessary  to ensure  that  only accurate,
           reliable, and valid  data  is used in the generation of reports  and deliverables,
           including the Hazardous Ranking System (MRS) Model.
2.11.3     DEFINITIONS
           Quality Assurance   the  total  integrated program for assuring the reliability of
           monitoring and measurement data.
2.11.4      DISCUSSION
           To understand  the  concepts of why data is   Quality  Assured,  it is  helpful to
           understand the  process  by which  such data  is  generated,  from  the   initial
           sampling effort to  the  time it is  incorporated into final  reports, including the
           MRS Model.

           The  flow  diagram  presented as Figure  2.11-1  tracks  a normal set of samples
           from  the  initial sampling  effort  to  resulting  final  use as Quality  Assured
           generated data for incorporation into the MRS  Model.

           Though each individual state office may  follow their own office specific routing
           system for the  Quality  Assurance of data, this  example provides the  general
           procedure by which data should be processed before it can be  considered valid.
2.11.5      RESPONSIBILITIES
           The responsibility for  the procurement, review, and Quality Assurance of data
           is shared jointly by the sampling team, the State Office Data Coordinator, and
           the State Office Quality Assurance Division.
2.11.6     PROCEDURES
           The following summarizes the major procedures used  in the overall  scheme of
           data Quality  Assurance once  the State Office has  initially  received  a data
           package.

           At first, a Preliminary Data  Review is conducted on the data package. This can
           be done by a  member of the sampling  team familiar with laboratory and data
           reporting  procedures.

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                                                               PROPER PACKAGING AND
                                                               CHAIN OF CUSTODY
                                         STATE OFFICE
                                        DATA COORDINATOR
                      CALLS FOR
                     MISSING DATA
                                                               ANALYZES SAMPLES AND
                                                               REPORTS RESULTS
                     DATA TO STATE FOR
                     PRELIMINARY DATA REVIEW
                                                               COMPLETES PRELIMINARY
                                                               DATA REVIEW
                                          STATE OFFICE
                                        DATA COORDINATOR
MISSING DATA |
 FORWARDED !
      STATE OFFICE
    HATA COORDINATOR
                         COMPLETED
                        DATA PACKAGE
        IF NO MISSING DATA.
        COMPLETED DATA PACKAGE
STATE OFFICE
 QA DIVISION
                                          STATE OFFICE
                                         DATA COORDINATOR
QUALITY ASSURES DATA
                     SENDS DATA TO SAMPLING
                     TEAM PROJECT MANAGER
                                                                COMPLETES MRS MODEL
                                           STATE OFFICE
                                        DATA COORDINATOR
                      QUALITY ASSURANCE OF ANALYTICAL DATA
                                       FIGURE  2.11-1

-------
QUALITY ASSURANCE
OF ANALYTICAL DATA


    The scope of the Preliminary Data Review should include:

        U   Ensuring that all deliverables set forth in  the laboratory contract are included
            within the data package.
        2)   Checking that the completeness of the forms is acceptable within the scope of
            the contract.
        3)   "Flagging"certain data within  the  package which falls outside the acceptance
            criteria range.
        k)   Complete a  checklist of questions which summarize and  present  key items in
            the data package (See example on following pages)
        5)   Deliver  data  package, checklist, and a list of missing documents to the State
            Office Data Coordinator.

        It is the responsibility of the Data Coordinator to review the checklist and list of
        missing documents and then contact the laboratory to secure such documents.  The
        Data Coordinator  then delivers the data package, and if necessary, any  missing
        documents forwarded by  the laboratory,  to the Quality Assurance Division of  the
        State Office.

        The Quality  Assurance  Division performs  the actual  qualitative  analysis of  the
        data.   Based  upon the sampling  results in the data  package,  the information
        presented  from the Preliminary Data Review, and their own expertise, they either
        accept or reject various components of the data package.  This function performed
        by  the Quality Assurance Division  is generally the most intensive part of the  Data
        Quality Assurance process.

2.11.7   RECORDS

        The data  package itself serves as a record of what data  are accepted or rejected by
        the Quality Assurance Division.

-------
             CHECKLIST FOR PRELIMINARY REVIEW

    OF CONTRACT LABORATORY PROGRAM ORGANICS DATA
                            Revision 5
                             L/2WS5
Site Name:
Case // and/or SAS // :

CLP Laboratory:	

Contract // :
CLP Data Received from Laboratory on:

Preliminary Review completed on:	
Laboratory contacted about Missing Information on:
Supplemental Information received from Laboratory on:

Preliminary Reviewed Data submitted
to the Monitoring Management Branch on:	
Preliminary Reviewer:

-------
                                                          Revision 5
                                                          1/24/85
      CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA
REVIEW CRITERIA                                         YES       NO
1.0    Cover Letter

1.1    Is the Narrative or Cover Letter present?

1.2    Are the following items contained in the Narrative
      or Cover Letter:

      a.   Case Number and/or SAS Number

      b.   Contract Number
2.0    GC Screen Data (Optional)

2.1    Is the GC Screen Data Sheet present?
      (See Attachment 2.1)

2.2    Are all the sample numbers listed on the GC Screen
      Data Sheet?

2.3    Are the GC Screen Chromatograms present for the
      samples and blanks?  If no, please list the missing
      Chromatograms below.

      Missing Chromatograms:	

-------
                                                        Revision 5
                                                        1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                      YES        NO


3.0   Organic Analysis Data

3.1   Are the four W  Organic Analysis Data Sheets (VOA,
     BNA, Pesticides and Tentatively Identified Compounds)
     present for each of the following. (See Attachment
     3.1) If no, please list the missing Data Sheets below.

     a. Samples and/or fractions as appropriate           	        	

     b. Matrix spikes and matrix spike duplicates         	        	
     c. Blanks                                          	        	


     Missing Data Sheets:

     VOA:
     BNA:
     Pesticides:
     TIC:
3.2   Are the Reconstructed Ion Chromatograms for each sample,
     the mass spectra for the identified compounds, and the
     Data System Printouts (Quant, list) included in the
     sample package for each of the following. If not, please
     list the missing Reconstructed Ion Chromatograms,
     mass spectra, and Data System printouts below

     a. Samples and/or fractions as appropriate           		

     b. Matrix spikes and matrix spike duplicates         	       	
        (Mass spectra not required)

     c. Blanks
     Missing Reconstructed Ion Chromatograms and Data System Printouts:
     Missing Mass Spectra:^

-------
                                                        Revision 5
                                                        1/24/85

   CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANIC DATA (cont'd)


REVIEW CRITERIA                                      YES       NO
3.3   Are the mass spectra for the standards present for    	      	
     compounds identified in the samples?
     Missing Mass Spectra:
     Are the mass spectra for the tentatively identified
     compounds and associated "best match" spectra
     included in the sample package for each of the
     following.  If no, please list  the missing numbers
     below.

     a. Samples and/or fractions as appropriate

     b. Matrix spikes and matrix spike duplicates
        (Mass Spectra not required)
     c. Blanks

     Missing Mass Spectra:	
4.0   Surrogate Percent Recovery Summaries


4.1   Are the Surrogate Percent Recovery Summaries present
     for each of the following matrix:

     a.  Water (See Attachment 4.1)                       _

     b. Soil (See Attachment 4.2)                         _


4.2   \re all the samples listed on the Surrogate Percent
     Recovery Summaries for each of the following matrix:

     a.  Water (See Attachment 4.1)                       _

     b. Soil (See Attachment 4.2)

-------
                                                        Revision 5
                                                        1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                      YES       NO
4.3  Are the surrogate percent recoveries listed for all    	       	
     the blanks?
     Are all the water data within the specified limits
     presented in Attachment 4.1 for the following parameters:
     (Please circle the outliers in red.)
     a.  Volatiles                                        	
     b.  Semi-Volatiles                                   	
     c.  Pesticides
4.5   Are all the soil data within the specified limits
      presented in Attachment 4.2 for the following
      parameters:  (Please circle the outliers in red.)

      a.  Volatiles

      b.  Semi-Volatiles

      c.  Pesticides
5.0   Reagent Blank Summary


5.1   Is the Reagent Blank Summary present?
      (See Attachment 5.1)
5.2   Is there at least one blank listed on the Reagent
      Blank Summary for every twenty (20) samples?
6.0   Matrix Spike Duplicate/Recovery Form
6.1    Is the  Matrix Spike Duplicate/Recovery Form present?
      (See Attachment 6.1)
6.2   Is there one duplicate listed on the Matrix Spike
      Duplicate/ Recovery Form for every twenty (20)
      samples?

-------
                                                      Revision 5
                                                      1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)



REVIEW CRITERIA                                     YES       NO


7.0   GC/MS Tuning and Mass Calibration Forms
7.1   Are the GC/MS Tuning and Mass Calibration forms present
     for the following:

     a.  Bromofluorobenzene (BFB)                      	
        (See Attachment 7.1)

     b.  Decafluorotriphenylphosphine (DFTPP)           	
        (See Attachment 7.2)

-------
                                                      Revision 5
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA
7.2   List the time and date that the Volatile fractions were run below:
Sample Number
Instrument
Time
Date
7.3   List the time and date that the BFB samples were run below:
     Instrument
                             Time
                      Date

-------
                                                     Revision 5
                                                     1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA
7.4   List the time and date that the Semi-Volatile fractions were run below:
Sample Number
Instrument
Time
Date
7.5   List the time and date that the DFTPP samples were run below:
     Instrument
  Time
  Date

-------
                                                        Revision 5
                                                        1/24/85

      CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA
REVIEW CRITERIA                                      YES       NO
7.6  Are the bar graph spectrum and mass/charge (m/z)
     listings for the BFB provided for each twelve (12)
     hour shift?  If no, please list the missing spectrum
     and listings below.

     Missing spectrum and listings:
7.7   Are the bar graph spectrum and mass/charge (m/z)
      listings for the DFTPP provided for each twelve (12)
      hour shift?  In no, please list the missing
      spectrum and listings below.

      Missing spectrum and listings:
7.8   Is the Cross Reference Table present
      (Refer to Attachments 7.1 and 7.2)
8.0   Instrument Tune and Performance Summary (Optional)
S.I   Is the Instrument Tune and Performance Summary
     present?  (See Attachment 8.1)
3.2   Are the BFB and DFTPP Performance Results found
     within the specified criteria presented in
     Attachment 8.1?

-------
                                                         Revision 5
                                                         1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)


REVIEW CRITERIA                                       YES        NO


9.0     Initial Calibration Data Sheets
9.1     Are the Initial Calibration Data Sheets present and
       completely filled out for all compounds for the
       following fractions:
       a. Semi-Volatiles (See Attachment 9.1)

       b. Volatiles (See Attachment 9.2)
9.2    Are the semi-volatile data within the specified
       limits presented in Attachment 9.1?
       (Please circle outliers in red.)
9.3    Are the volatile data within the specified limits
       presented in Attachment 9.2?
       (Please circle outliers in red.)
10.0   Calibration Check Sheets


10.1   Are the Calibration Check Sheets present and
       completely filled out for all compounds for
       the following fractions:

       a.   Semi-Volatiles  (See Attachment 10.1)

       b.   Volatiles (See Attachment 10.2)


10.2   \re the semi-volatile data within the specified
       limits presented in Attachment 10.1?
       (Please circle outliers  in red.)
 10.3   Are the volatile data within the specified limits
       presented in Attachment 10.2?
       (Please circle outliers in red.)

-------
                                                             Revision 5
                                                             1/24/85
  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)



REVIEW CRITERIA                                      YES      NO


11.0  Standards Data Package
11.2  Are the Reconstructed Ion Chromatograms, Data System
      Printouts (Quant, list), and work sheet calculations
      present for the following:
       a.   Samples                                      	

       b.   Blanks                                       _

       c.   Matrix spikes                                 	

       d.   Matrix spike duplicates                        	


11.3   Are the Gas Chromatograms and Data System Printout
       present for the following:

       a.   Pesticide Standard                            _

       b.   PCB Standard
                                      10

-------
                                                             Revision 5
                                                             1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA

11.4   List the times and dates that the Pesticide/PCB samples were run,
      if the laboratory has not summarized them in a table.
Sample Number
Instrument
Time
                                     Date
11.5  List the times and dates that the Pesticide/PCB Standards were run,
      if the laboratory has not summarized them in a table.
     Instrument
  Time
   Date
                                      11

-------
                                                       Revision 5
                                                       1/24/85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
REVIEW CRITERIA                                      YES      NO


12.0   Detection Limits
12.1   Is the list of currently calculated detection
      limits present? (The limits should not be the
      same for all of the parameters.)
13.0  Package Copies


13.1  Are all the xeroxing of readable quality?
                                      12

-------
                                                     Revision 5
                                                     1/24/85

        CHECKLIST FOR PRELIMINARY REVIEW OF CLP DATA (cont'd)
REVIEW CRITERIA
14.0   Reagent Blank Chronology
      List the time and date that a reagent blank or instrument blank
      was run on instrument for each of the fractions listed below:
Sample Number

     VOAs
     BNAs
Instrument
Time
Date
Pesticides/PCBS
                                    13

-------
                                                             Revision 5
                                                             1/2W85

  CHECKLIST FOR PRELIMINARY REVIEW OF CLP ORGANICS DATA (cont'd)
               Review Criteria Supplemental Information Table
Review Criteria
Sample
Number
Instument         Time
 Date
./   /
                                                                  /  /

-------
                             GC SClHtN DATA SHEET
Laboratory Name

    Number 	
Sample
ID Number







Fraction
VOA
B/N/A
Pesticides
Dioxin

VOA
B/N/A
PtscicidM
Oioxin
VOA
B/N/A
taiicid«s
Oioxin
VOA
B/N/A
Pesticides
Oioxin
YOA
8/N/A
Pesticides
Oioxin
VOA
B/N/A
Pesticioes
Oioxin
VOA
B/N/A
Pesticides
Oioxin
GC
Detectable*
Medium Level




-






























Date
Qt
SCJ 8 CM






























.-'




Level of
CC/MS
Analysis**



































Date
of
Anaiviij



















^















    ^Answer Yei or No.

    •indicate -M- lor medium level CC/M2 truly«is;
     indicate 1." (or low level COM2 uialyiu.

-------
                        ATTACHMENT 3.1


                      ' 9v*M I^MBBWBI OMW
                    >i»l TO/M7.]««

                            Organic* An*Jy*» Orta Shwt
        O Ma:.
TOO 3
'5 3S
74- i*- 3
«•> 86 J
'C7-0« 2
7t 43 3
71 55 «
i 08 05 «
?S 27 4
                                            CeranaNa:
                                Vairtte Compound*
                       Om l
                             Momur» (0«e»m»at
          )  1  l-Trienlerovinin*

                                             7J-34.J
                                               »7
                                             '0081 02-8
                                             7J-00-J
                                             71.4J.J
                                                  0'
                                             no- 75 •
                                             127. IS
                                             '089(3
                                             108 90 7
                                             130.41 <
                                             '00 42 S
                                                       1122
                                                       1  1 2
                                                       $'¥'•«*
                                                                ^...1 !•..« >« t^*B


                                                                • «SC Ht
                                                                                 4 M
                   form I.   Organio An*lysi§  Data Sheet,
                                        B-28
                                                                                      5/84

-------
                             ATTACHMENT  3.1
f 0. •»•!•,
                       • UJ11
                                Orvantea Aiwiysia Data Slwvt
                         Dm*
CAS
•2 75 »
lOf-H-2
•2 43 3
M
S4' 75.1
'06-44-7
100-S1-4
tS
   44-7
3M34 32 »
104-44-4
    44-7
47-72-1
98 94 3
78
98 74 4
10S 67 J
65 85-0
l tl-41-1
120-43-2
120-42-t
»i-20-3
1O4-47-4
67 «4-3
4» SO-7
»l 47 4
9'  44 7
44 74-4
131  11 3
:04 Ml
9»
           l 3
           1  2 4.T>KfMo>oe>tl«n*
           2 4 4 Ti<
                                                   CAS
                                                  SI 28 1
                                                  132 «4-»
                                                  1J1.14.J
                                                 i«o« ":L
                                                  64.44-2
                                                  •7QOS-72.3
                                                  •4-7J.7
                                                  100-01-4
                                                  •6-IO-4
                                                  101 4S-J
                                                  1 14-74.1
                                                  87 84-J
                                                  123  12 7
                                                  84-74-2
                                                  20S-44-0
                                                  »2 J7 i
                                                  129-00-0
                                                  IS ««.7
                                                  54 44 3
                                                  1 1 7 »t-7
                                                  2'S-Oi »
                                                  117 M-0
                                                  207 0»-»
                                                  W 32 •
                                                     3» 4
                                                  13 70 J
                                                  '»» 24 2
                                                             «.CM«H4«««
                                                             1 3
                               Pom  I.    (continued),
                                                                                           4 M
                                          B-29
                                                                                               5/84

-------
ATTACHMENT 3.1
	
• mil
       Organic* Analytic Data Sn««t
                      3)
 Cane/Oil **cnr

  CAS
)1» 14 «
JH-IS-7
J1»-l« 1
SI «» »
?« **-l
304 00-2
102*. 5' 3
!S9-*I «
60-57 t
11 iS »
72-20-*
3321 : 45 »
73 54-«
7*21 »7-«
1031-07 t
SO- 29- 3
7J-43 S
S34M-70-J
S7-7«.»
8001 35 2
I2S74-I' 2
H '0*-28 2
11 141 -l(-i
S34«9 21 9
12872 21 «
110*7 »». i
nos«.§2 5
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s»n-a«c
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->«0't£n"x EsaixH
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« 4 -001
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4 4 300
Eftdfi" Aidt^vo*
En4fllu»4n SuKll*
4 4 -OOT
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^OIiO"(»«»
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Araeier ' :«S
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Aionix-' 290



























         V. • vtfuffw •< t«* ntriei lull
        Fora  I'   (continued).
                 B-30
                                                            5/8-

-------
                            ATTACHMENT 3.1
0 !•«
             L *MM2Uti TO/UM
                        Orytnica Analytu O«U Sh««t
                                 (Pig* «)

                       T«ntativ«ly ld*ndfMd Compounds
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                                form I »in 9
                          Form  I.   (continued).
                                   B-31
                                                                             5/84

-------
                    WATER SURROGATE PERCENT RECOVERY SUMMARY
CD
I
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at

»-»
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» VALUES >
**ADVISOR1
Comment


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TTACHMENT*.!
                                     FOBU II

-------
                      SOIL SURROGATE PERCENT RECOVERY SUMMARY
     CAM No
ta
70
it
L«- U-*_

t*«
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•A.

























• VALUES
**ADVISOR
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7-*, I MTIAII i~>, , , . , ,
                                      FORMH

-------
REAGENT BLANK SUMMARY
  Cankado
                               CentMlMa..
ot

*-
o
                                                            H

                                                            >
                                                            n
                                                            rn

                                                            H
           FORM
                                                4/C4
  Reagent Blank Summary

-------
Coot) No.
                             WATER MATRIX SPIKE/MATRIX  SPIKE DUPLICATE RECOVERY


                             	  CoMioclor 	 CoaUool No. 	
ASTERISKED VALUES AM OUTSIDE OC
BHJ:
      VOAi.

      0/N_

      ACIO-

      MSI -
             .•ui ol.
                                     •unfcfc OC Mt>

                                     •um* OC k"N»
                                     •uiiM* OC IMii
                                                    NICOViHV:
                                                               VOAt.
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•/N
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SAMPLE NO








COMPOUND
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N^tMlMO Dl«t ^OpyUMM
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-™tt
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                                                                                                          n


                                                                                                          m


                                                                                                          ON
                                                                                     I	;   MiMfOCIMM
m

OD
                                           FOAMM


                    For*  III.   HS/HSD  Result* (water).
                                                                                          4/84

-------
               N*.
      SOIL MATRIX SPIKE /MATRIX SPIKE DUPLICATE RECOVERY

                                                              M«	
              L**«l.
u>
I
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VOA
SMO
SAMflt NO



I/N
SMO
SAMPLE NO













	
COMPOUND

I.I 0«*ioloi«l»n>
fiKfcloitMltMna
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         'ASUHISKIO VAIUCS AME OUTSIDE oc nuns
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               MSI _
         ComnwnU: _
-OUI Ol .
. Out ol _
. oo< al .
. out «l .
 Hrto OC HnUlt
   OC *««.ll
 lKtl OC IHMII
iMite OC IUMII
                                                                 MECOVEMV:
                                                                             VOA.	•«•<
                                                      rtsn
•uuldi OC IM*i
     OC IMu
     OC Itorio
•ullU* OC IMU
                                                        FORM IN
                                 Fora 111.   MS/MSI) Keaulta («oll).

-------
                         ATTACHMENT 7.2
               QC/MS TUNING AND MASS CALIBRATION
                0«eafluorotriph«nylpho«phln« (DFTPP)
                      Contnaar
                                                  Contract No.
   UkiO.
                      On*

                      Ora
                              Autftonod It:
   •*   IOM A*UNOAMCI OIITIIIIA
                                         MI Ltrtvt
   11
                    I
        ^ «•> 1 J» «•
                                                                C   )'
   17?
   IfT
        MM) 1J3»«<
        100-
               «oo%««
i     	


THIS HMOKMAWCI TUM A*»un ro Tut
     . ILANKS ANO
UM»U 10















L>« 10















OATI Of AM4.TIU















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                                                                    4/84
                                 FORM V
             Form V-   DFTPP Tuning «nd H*is  C«libr«cion.
                                                                         5/8-

-------
                           ATTACHMENT 7.1
              GC/MS TUNING AND MASS CALIBRATION
                      Bromofluorob«nz«n« (BFB)
Ctm
Irmr
Life I0
          10
Camneior
0«it 	
                                                 Tim*
                      DM* A«tuM Autnortnd By:
  IK<*   IOM ASUMOANCI CRITERIA
                                          WULATIVt
H
7i
M
M
IT3
174
m
171
tT7
U.O • 40.0% *< Do MB •»>
X.O • H.0% «f tn* am MM
•Mt OM4. 100% r*ttti«« •Aunoin^
1.0 • 1 .0% at it* MM «•»
LM> m*n 1 .0% »< o» MM mt
QTMIV mwi H.0% a< ltd M« auk
S.O . 1.0% H m-» 174
b«mr tMn tS.0%. awf M in*n 101 0% at mm* 174
ii • (J% «1 «M» 17*






( J1
C )'
C 3J
' V«k» HI •rtmnmn * % ra* 17«.
'Viluc •» HramMmt « » («•!» 174.
THIS HMfOHMANCS TUNC APPLIU TO THC FOLLOWING
       i LAX US AND STANDARDS.
&I.I 10
















LAI IO















OATI OF ANALYSIS















TIME OF ANALYSIS















4/34
                                  FORM V
             Fona V.  BFB  Tuning and Hass  Cdlibracion.
                                 B-43
                                                                        5/84

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                       INSTRUMENT TUNE AKO PERFORMANCE  SUHHAXT
 CASE NO.
 LOW LEVEL"
 WATER
                     CONTRACTOR
                     MED. LEVEL
                     SOIL/SED.
            CONTRACT NO.
            HIGH LEVEL
            OTHER (SpecTTTT
DFTPP and BFB Performance Results:
~"  The DFTPP performance results were reviewed and found to be within the
— specified criteria.
    The BFB performance results were reviewed and found to be within the
— specified criteria.
           DFTPP
      Ion Abundance Criteria
              percent or mass
Hess
—5T
  68
  70
 127
 197
 198
 199
 275
 365
 441
 442
 443
                                     Mass
                        198
less then 2 percent of mass 69
less than 2 percent of mass 69
40-60 percent of mess 198
less than 1 percent of mass 198
base peak, 100 percent
5-9 percent of mass 198
10 - 30 percent of mass 198
greater than 1 percent of mass 198
present but less mess than 443
greater than 40 percent of mass 198
17-23 percent of mass 442
            BFB
     Ion AbundTnce Criteria
     15-40 percent of mass 95
 75  30 • 60 percent of mass 95
 95  base peak, 100 percent
 96  5-9 percent of mess 95
173  less then 2 percent of mess 174
174  greater than 50 percent of mass 95
175  5-9 percent of mess 95
176  greater than 95 percent.
     but less than 101 percent of 174
177  5-9 percent of mess 176
 Deviations;
 Date/T1me7lnstniB«nt   File  Nunber  Compound
                                          m/z
             Required
             Abundance
                                                                      Observed
                                                                      Abundance
 Caments:
                                                           Revision Date 1/83

-------
                               ATTACHMENT 9.2

                             Initial Calibration Data
                            Voiatrl* HSL Compound!
C«MNo: 	
Contractor _
ComnetNo:.
Instrument I 0  .
Ctlioritien Oil*
             Minimum XT for SPCC • 0.30O   M««imum % ftSO (or CCC * 30%
        IP
                                    "'100
                                            "'
                                              no
           "»JOO
                                                                    «MO
                                                                           CCC-
1  I .o«">o'o«t'>«"«
   •>cnioro«in«A«
2 tultn
Vinyt «£tll»
Tf»nt-l
(122
Stvrtn*
                    m* •«•>«• •> u«/
                                          cce-c*
        Fora VI.   Initial Calibration -  Volatlla  HSL  Compound!
                                      B-45
                                                                                   5/84

-------
                          ATTACHMENT 9.1
                             Mttt Caflbratton Data
CiUWMiUf. «

Caiman*.
         IO _

Calibration 0«tr
             MJniwtwn I? for SPCC « O.MO   MMvmjm % (WO 1
                                                                         «*«.
 fc«.3 Cy»«»u»i".i»u«i"ui<»*«i"»""
TT
TT

                 ir» • 11 «*
CCC-

    Fora VI.    Initial  Calibration -  Semi-Volatile  HSL  Compounds
                                      3-46

-------
                             ATTACHMENT 9.1
                             tnhtel Calibration O«t>
                                     HSU Compounds
 CM* No: _
 Contractor: .
 Con if set No:
ln«rum«nt IO _
Cllibrvuon 0*t«:
             Minimum iff for SPCC « O.OM   Maximum % KSO for CCC m 3O%
                                                                      wee
 I. «-Qi ..... imimm
 2. i

 0>-n-Oe>vi Pttm«ra
 ••nalg.
CCC-
                                        (II-
    Form  VI.   Initial  Calibration  - Semi-Volatile HSI. Compounds
                                     B-47
                                                                           9/3i  Rev

-------
                             ATTACHMENT 10.2
                         Continuing Calibration Chock
                           VotatHo HSL Compounds
CM* No:
                                       Calibration 0«tt

                                       Tim«: ^___^__
Contract No: _

Inotrumont IO:
Laboratory 10
                                       Initial Calibration Date:
            Minimum *f for SPCC it 0.30O    Mi«imum *0 for CCC * 28%
'so-
 so
 CCC Ciiwrac
          Fora VII.  Continuing Calibration  Data -  Volatllt*
                                                                               5/84

-------
                ATTACHMENT 10,1


                 Continuing Calibration Ch*efc
                 S«m~»

AAilin*

2 CIMO»«««»»«OI
t 3 0«f"»foe»*»«
4 M«i«vton»i9<
n.nntrqtff.0""-*1 Jainmin*
N*< K4C ^ 'O' O*t" • f *
Nn'ae»f«»n«
W0"0'0^»
J Niiraenvnoi
J 4.0i"««l''»lon«"<»
ScntOK Acid
004 2 CMo»0»tnO«»*i««T»«I>«
2 4.0'eniofoen«noreannin«
"•UC^'O'OOwHO^"*
4.CMoro.J.M«..,18"«-o.

2 4 6 Tr>cniof9en«no«
2 4 i T.,cn>o>oo"«~J<
2 Cn>oran«ontn««n*

Oim»ir>»' *nin«i4i*
Acvf^aonmv**^*
3 K'facn.i.n*
A• 2S%


•




•









•



•



•
•

•






•



Ucc












• •























• •

Form VII.   Continuing Calibration  Data  - Semi-Volatiles
                           B-50

-------
                             ATTACHMENT 10.1
                         Continuing Calibration Chock
                         Somivotetilo HSL Compounds
CM* No:
                                               Ott*
Contr»ctWo:
                                      Tim«:
Libor»tory 10:
                                           Calibration 0
-------

-------
     LABORATORY QA CONSIDERATIONS
2.12.1    PURPOSE
         To ensure  that  proper laboratory space  is available to accommodate  samples
         needed to accurately portray  existing conditions  at  a site.   This also  takes  into
         account any  sample allocation requirements and/or limitations imposed by the
         laboratory or laboratories on a week by week basis.
2.12.2    APPLICABILITY
         The availability of lab space  and allocation of  samples is a necessary part of
         planning  and scheduling site  investigations.  Laboratory  arrangements must be
         completed before a site inspection can be conducted.

2.12.3    DEFINITIONS

         None

2.12.4    DISCUSSION

         The process by  which  sample space  is  procured  is discussed in general terms.
         Each  individual  state  office  may  adhere  to  office  specific  guidelines  for
         scheduling and planning sample space.

2.12.5    RESPONSIBILITIES

         The personnel directly involved in  the procurement of samples include:

           1)    Field Project  Manager, who determines the number of samples needed.
           2)    State Office  Sampling Coordinator, who assembles sampling needs on a
                weekly  basis and relays this information to a Sample Management Office.
           3)    Sample Management Office liaison, who arranges  for the laboratories to
                be used for each site investigation.

2.12.6      PROCEDURES

           It is the responsibility of the Field Project Manager of each individual site to
           convey his/her sample requirements to  the Sampling Coordinator.

           During the early part of the week, the  Sampling Coordinator should assemble
           the sampling requirements  needed  for the  following  week's  sampling efforts.
           This information is presented to  the  Sample Management  liaison, who  in turn
           arranges for the  designation of  laboratories to be used.   Once the laboratories
           are known and  the number of  samples  requested  by site are confirmed,  the
           information is  conveyed  back to the  Sampling Coordinator,  who notifies  the
           respective Field Project  Managers.

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LABORATORY QA CONSIDERATIONS
2.12.7    RECORDS

         Organic and Inorganic Traffic Reports are retained to identify the samples sent to
         the laboratory.

         Among  the information  included  on the Traffic Reports  are sample  number,
         laboratory,  sampling office, sample matrix, concentration,  sample description,
         and shipping information.

-------
               PROJLCI

               MANAGER
                        REQUESTS

                         SAMPlES
  PHOJEC1

  MANAQEH
          H L U U( SIS
          SAMHl t S
                PROJECT

                MANAGER
    ^REQUESTS

     SAMPLES
COORDINATES
SAMPLES
AND RELAYS
SAMPLE
REQUIREMENTS
   OFFICE
  SAMPLING
[COORDINATOR
            PROCUREMENT OF
SAMPLE  SPACE FOR SITE INSPECTIONS
                ARRANGES FOR
                LABORATORIES
                AND RELAYS
                CONFIRMATION
                                         OFFICE

                                        SAMPLING

                                      COORDINATOR
                                     NOTIFIES
                                     PROJECT MANAGERS

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                    3.0 DECISION CRITERIA
3.1 INTRODUCTION

         After the inspector has completed gathering and
    evaluating all the appropriate data,  a recommendation must be
    made on what next to do with the site.   There are four possible
    categories of options that EPA has  developed.  To foster
    consistent decision making across all EPA Regions and all
    States funded under EPA's CERCLA program. States should adopt
    this approach.  In this way, the public can be sure that
    decisions made in one Region or State are consistent with
    decisions made in another Region or State.   For the most part
    the criteria to be presented applies  to both PA's and Si's
    because the two activities vary only  in the quantity and
    depth of information available for  a  site.

         In most cases where no data are  available, the
    investigator should presume the worst until he/she has obtained
    information to lead one to conclude otherwise.

         The four major disposition catagories  are:

              0 no further CERCLA action  (NFA)
              0 further CERCLA action (FA)
              0 further non-CERCLA action (pending)
              0 emergency action (removal)

         A site recommended for emergency action is the only
    situation where a site might be categorized into two categories.
    A site should not be both FA and pending.

3.2 NFA

         A decision for NFA should be particularly well justified.
    An NFA decision removes the site from any further CERCLA or
    State consideration.  A decision for NFA should address all
    routes of exposure-air, surface water, ground water, direct
    contact, fire and explosion.  A NFA decision should be supported
    with information that there is no potential for exposure to
    hazardous substances or pollutants through these routes.

         The criteria are:

              0 site does not exist

              0 site is part of another site already listed on NPL

              0 no hazardous wastes or hazardous waste generating
                practices

-------
                               -2-
                a hazardous substance is naturally occurring

                all hazardous waste exist in quantities/
                concentrations that are diminimous.
3.2 PENDING
         Many sites will be referred for further action but not
    under CERCLA authorities.  These sites are ones which may
    pose a threat to human health and the environment but which
    due to statuatory or policy decision are not addressed under
    CERCLA.  EPA will categorize these sites as pending in the
    ERRIS/CERCLIS data base.  In most cases, States will follow
    up on these sites.

         The pending criteria are:

              0 sites precluded from listing for policy reasons:

                   - RCRA sites with a Part B permit
                     (received waste after January 23, 1983)

                   - FIFRA sites (?)

              0 sites covered by Uranium Mill Tailing Control
                Act (UMTRCA) and Atomic Energy Act (AEA)
                   -see page 6

              0 petroleum/natural gas facilities CERCLA
                   -other petroleum/natural gas wastes products
                    can be addressed under CERCLA

              0 sites below 28.5 cut-off or sites which would
                not qualify for NPL

              0 any other site preculded from listing.


3. 3 FA

         A decision for further action generally falls out after
    you have excluded NFA and pending sites.  Further action
    decisions can include consideration for NPL listing or a
    follow-up site inspection.  The State CA guidance specifies
    that State CA funds are to be used only to gather more data
    for HRS.  Sites needing additional work to confirm no further
    action should be referred to the EPA Regional office for
    follow-up.

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             SITE  INSPECTION SCENARIOS
Residents of a community near an industrial park,
spurred by highly publicized stories of other
communities discovering that their drinking water
supplies were highly contaminated by local industries,
had their drinking water supply analyzed.   The testing
results indicated the presence of low levels of phenol,

PA interviews and investigations indicated the
presence of several potential sources of the
contamination within the industrial park,  one of which
was an NPL site.   The industrial park is located in an
area which drains into the river that serves as the
community's drinking water source.

Samples were collected during the SI.  Testing results
indicated that the only industrial site that showed
traces of contaminants leaving the facility boundaries
that were similar to those detected downstream was the
NPL site.
                        -1-

-------
Two bird watching naturalists observed approximately
50 partially buried barrels while hiking down an old
railroad grade in a rural area of the Blue Ridge
Mountains.  The barrels appeared to have been in this
location for a long period of time; they were corroded
and the vegetation cover was thick in places.  Upon
further examination, the naturalists discovered that
more drums were present and that there were small
unvegetated areas where the soil had a blue crust.
One of the naturalists opened a drum to determine the
nature of its contents and immediately fainted.  He
recovered within twenty minutes and was treated at a
local hospital for burns to his nasal passages.

EPA undertook a PA and conducted telephone interviews
with local officials.  They learned that a large
county dump had operated in this area for 10 years,
but was closed around 1965.  It was an unsecured,
unlined dump which accepted wastes 24 hours a day.
EPA also learned that the dump was located between two
mountain ridges and above naturally occurring clay
soils.

The closest population using ground water was seven
miles away over several ridges.  Surface water users
were 15 miles downstream from the site.  It was
determined, during the PA, that the area was not a
Federally-designated sensitive environment.

Magnetometer surveying of the site, conducted during
the SI, indicated the potential presence of buried
drums in an area of about one quarter acre.  Reliable
interviewees indicated that the dump had been no more
than 10 feet deep.  Contaminant levels in sample
leachate from the drum disposal area were high in
heavy metals and PCBs.  Off-site stream samples taken
1.5 miles downstream from the site did not indicate
the presence of contaminants above the lower detection
limit.  EPA investigators found that the railroad
grade was frequented by bird watchers and young
motorcyclists.
                        -2-

-------
A resort developer in a rural area had a well drilled
to serve as the drinking water source for his resort
community.  He had routine drinking water analyses
performed on water from the well.   The testing results
indicated levels of chromium well  above the State's
water quality standards level.  A  competing developer,
whose drinking water was drawn from a different
watershed, heard of the analysis results and reported
the problem to the Regional EPA office.

PA activities revealed the presence of several logging
operations in the same watershed as the affected
aquifer.

SI inspectors collected ground water samples from the
affected aquifer.  Analysis of the samples showed
consistently high levels of chromium.  Geological
research  of the area indicated that the ridges in the
region are comprised of peridotites and serpentines.
Analyses  of heavy minerals collected from pan samples
taken throughout the watershed confirmed the presence
of high quantities of chromite.
                        -3-

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A State conducted a PA on a tank farm covering over 50
acres in a densely populated urban area.  The main
operation is adjacent to a navigable river.  In
addition, the facility is above a shallow aquifer
which is the municipal water supply for a city of
35,000 only one mile downgradient.  Nearby residents
frequently complain of odors from their tap water.
All of these residents use the municipal water supply;
however, about half of them have switched to bottled
water for drinking water.  During the PA, the State
determined that the facility is a small fuel
distribution center.

Ground water samples collected during the SI showed
over 10 ppm of hexane through dodecane.  There was
also an easily observed sheen discharging from the
bank of the river adjacent to the facility-  Analysis
of surface water samples indicated the presence of the
same contaminants found in the ground water.
                        -4-

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A chemical company synthesized organic chemicals,
paints and pigments on a 300 acre site from 1940 until
1980.  It is located in a small industrial area,
adjacent to a creek which discharges into a large
river.  Several other companies are located upcreek
from the site.

PA studies indicated that the chemical company
disposed of its mixed wastes in a series of lagoons
for about 25 years until 1970.  State monitoring of
on-site wells has indicated the presence of solvents
and PCBs.  Groundwater is not used as a drinking water
source anywhere within a 20 mile radius of the site.
Approximately 32,000 people get drinking water from a
reservoir located 3.5 miles downstream from the site.

A water sample was collected from the reservoir during
the SI.  Testing results indicated that the levels of
PCBs, TCE, and PCE in the reservoir exceed background
and also exceed the EPA Suggested No Adverse Response
Levels (SNARLs).  A small capacitor manufacturing
plant is located about one mile upstream from the
chemical company.  A sediment sample taken 0.5 miles
upstream from the chemical company indicated the
presence of low levels of PCBs (55 ppm).  A sediment
sample taken immediately next to the outfall to the
company contained 550 ppm PCBs.  One sample taken 0.6
miles downstream from the chemical company contained
150 ppm PCBs.
                        -5-

-------
Residents of a small community were complaining of an
unusual odor in their drinking water.  Analysis of
samples collected by the residents for routine water
quality parameters did not indicate the presence of
harmful substances.

Available information reviewed during a PA on the
source of the drinking water, a small reservoir, was
scarce; therefore, an SI was conducted.

Analysis of the reservoir water, from samples
collected during the SI, revealed that there were
unusally large amounts of planktonic algae in the
water.  EPA gathered further information on
observations of the odor in the water and learned that
they followed a seasonal pattern which correlated with
algae blooms in the reservoir.
                        -6-

-------
A commercial landfill located two miles from an
industrial park receives hazardous wastes from various
companies producing chemical waste by-products.  PA
investigations found that the landfill operation began
in 1973, and in 1980 it received RCRA Interim Status.
In December 1984, it received a RCRA part B permit.
The facility manager has a history of mishandling
hazardous wastes in other parts of the State.  Some of
the waste haulers reported during PA interviews that
they had noticed unmarked drums on-site, and off-site
contamination was suspected.

SI inspectors observed improper handling of liquid
hazardous wastes.  They also noted many unmarked
barrels leaking at the seams.  In addition, it was
apparent from land surface scars that there had been a
number of spills on-site.  The disorderly appearance
of the site was'noted.  Analyses of samples collected
from one on-site monitoring well indicated low levels
of organics and heavy metals.  Samples collected
downstream from the site, about one mile from a major
water supply, showed high levels of contaminated
sediments.

The inspectors also found that the landfill had
stopped receiving wastes for a two year period from
1978 to 1980.  Wastes received after 1980 were dumped
in a previously unused portion of the landfill.  The
RCRA part B permit covers only this new landfill area.
                        -7-

-------
A county-lead enforcement cleanup has recently been
completed at an urban hazardous waste dump which
operated from 1960 to 1979 in an area of high annual
precipitation.  The dump contains leaking drums and
bulk tanks, and overflowing lagoons.  The county
claims that the site's problems have been remedied.

A PA was completed and it was learned that the county
had instituted a comprehensive effort to clean up and
regrade the site.  This effort had, in fact,
eliminated discharges to surface waters.  The adjacent
surface water supplied drinking water to a city of
10,000.

Some citizens were concerned, however, about ground
water contamination.  These citizens notified the EPA
Regional office of the situation.  State
investigators, during an SI site visit, collected
ground water samples from a municipal well located two
miles from the waste dump and serving 4,000 people,
and from private wells located between the municipal
well and the dump site.  The wells draw water from 60
feet beneath the surface.  The State also collected
representative groundwater and surface water samples
to determine background levels of chemicals present in
the aquifer.  No contaminants were found above the
lower detection limit in any of the samples.  Geologic
analyses of the site's subsurface indicated it is
comprised of unconsolidated rock to a depth of 40 feet
and sandstone from 40 to 65 feet beneath the surface.

County officials assured the State that appropriate
measures had already been taken to remedy the
potentially hazardous situation and argued that State
actions would interfere with county efforts to force
an industrial company to clean up an old disposal area
two miles from the subject site.

-------
9.   A metal refinishing  plant specializing  in chrome
    plating was repotted to  EPA by a  former plant employee
    for  dumping waste  acid,  heavy  metal  solutions,  and
    solvents into  a  french drain.

    PA activities  indicated  that the  plant  is located in
    an area that relies  solely on  groundwater for drinking
    water  supplies for approximately  12,500 people  within
    three  miles of the plant.

    SI sampling of wells within a  three  mile radius of the
    site verified  the  presence of  trichloroethylene in the
    drinking water.  Concentrations south of the  site were
    greater for wells  located  closer  to  the metal
    refinishing plant.   Wells  northwest  and east  of the
    site showed no detectable  amounts  of trichloroethylene.
    Ground water  in  all  utilized aquifers flows from north
    to south in this area.
                           -9-

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                                   -3-
                0  ground water/surface water/air  releases  have
                  been observed/documented

                0  non-dimininous quantities  of hazardous waste
                  exist on  site and  or may be released into the
                  environment

                0  investigation (sampling) does not  reveal
                  presence  of hazardous waste or  releases  but
                  geology  suggests  that there should be or  will
                  be a release eventually.

                0  does not  reveal presence of hazardous wastes
                  or releases but past practices  are unclear or
                  not reliable.

                0  further  investigation is necessary to insure
                  that the  documented remedy is functioning
                  properly

                0  enforcement action is currently  ongoing  but
                  no remedial action has  taken place

3. 4 EMERGENCY  ACTION

          In the  course of conducting a  site inspection,  State
    inspectors may become aware of situations that pose  a more
    immediate  threat to  human health or  the environment  or releases
    that can be  readily  cleaned up.  EPA's "removal" program  is
    designed to  address  these problems.   "Removal" actions are
    not  limited  to sites  on the NPL.

           The  NCP (47 FR  31214, July 16,  1982)  states:
                      f MOM  PhM« III—bnmwttatt removal.
                       (a) In determining the appropriate
                      extent of action to be taken at a given
                      release, the lead agency (hall fint
                      review the preliminary assessment to
                      determine if Immediate removal action
                      It appropriate, immediate removal
                      action (hail be deemed appropriate in
                      those case* In which the lead agency
                      determines that the initiation of
                      Immediate removal action will prevent
                      or mitigate immediate and significant
                      risk of harm to human life or health or to
                      the environment from such situation* as:
                       (1) Human, animal, or food chain
                      exposure to acutely toxic substance*;
                       (2) Contamination of a drinking water
                      supply;
                       (3) Fire and/or explosion; or
                       (4) Similarly acute situation*.

-------
                                           -4-
      EPA  proposed  changes  to  the NCP  (50 FR  5862,  February  12,
1985)  to  lower  the threshold to qualify for  "removal"  action.
If  these  proposed  criteria are  adopted, then in general,  releases
at,  near,  or  above ground  that  can be  addressed without compromising
the  cost-effectiveness  of  the solution, can  be  undertaken.
     The  proposed  NCP  States:
                            (2) Th« fuilowuig factors »hall be
                          considered in determining the
                          apropriateness of a removal action
                          pursuant to this subjection:
                            (ij Actual or potential exposure to
                          hazardous substances or pollutants or
                          contaminants by nearby population*.
                          animals or food chain:
                            (ii) Actual or potential contamination
                          of drinking water supplies or sensitive
                          ecosystems:
                            (iii) Hazardous substances or
                          pollutant or contaminants in drums.
                          barrels, tanks, a* other bulk storage
                          containers, that may poee a threat of
                          release:
                            (iv) High levels of hazardous
                          substances or pollutants or
                          contaminants in soils largely at or near
                          the surface, thut may migrate.
                            (v) Weather conditions  that may
                          cause hazardous substances or
                          pollutants oc contaminants to migrate or
                          be released;
                            (vi) Threat of fire or explosion;
                            (vii) The availability of  other
                          appropriate Federal or State response
                          and enforcement mechanisms to
                          respond to the release';
                            (viii) Other situations or factors which
                          may pose gjnular threats to public
                          health, welfar« or the environment.

     The  only  limitation  to   "removal" action  are:
                            (3) Removal actions, other than those
                          authorised under section 104tb) of
                          CKRCLA, shall be terminated after $1
                          million hue been obligated for the action
                          or 6 months have elapsed from the date
                          of initial response unless the lead
                          agency delermiaes that: (i) there is an
                          immediate risk to public health, welfare
                          or the environment, (ii) continued
                          response actions are immediately
                          required to prevent, limit, or mitigate an
                          emergency, and (iii) such assistance will
                          not otherwise b* provided on a timely
                          basis.

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                              -5-
3.5  SUBSTANCES COVERED BY CERCLA
         CERCLA Section  104  authorized  EPA to  "act",  consistent
    with the NCP,  when  there is  a  release  or threat  of  a release
    a hazardous substances or  a  pollutant  or contaminant.

         Section  101(4)  of  CERCLA defines what  substances  qualify
    as a hazardous substance for CERCLA purposes.  They are any
    substances  designated under:

              0 FWPCA  311 (b)(2)(A)  CERCLA 102,  FWPCA 311(b)(4) -
                reportable quantities

              0 CERCLA  102,  FWPCA  311  (b)(4) - reportable quantities

              0 RCRA 3001 -  listed hazardous waste or hazardous
                waste  having certain charateristics

              0 FWPCA  307(a)  - toxic pollutant

              0 CAA 112  - hazardous air pollutant

              0 TSCA 7  -  imminently hazardous  chemical

         CERCLA 104 (a)(2) defines a pollutant or  contaminant as
    that which  presents  an  imminent and substantial  danger  to the
    public health  or welfare.   This can include  mining  waste
    materials.

         Hazardous Substance,  pollutant or contaminant  does not
    include petroleum,  including crude  oil and any  fraction or
    natural gas, liquified  natural gas, or synthetic gas of
    pipeline quality or  mixtures of natural gas  and  such synthetic
    gas.

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                                          Attachment  1.

                                                 -6-

     Federal  Register / Vol 48. No.  175 / Thursday, September 8, 1983  /  Rules and Regulations    10661
Releases of Radioactive Materials

  Section 101(22) of CERCLA excludes
several types of releases of radioactive
materials from the statutory definition of
"release." These releases are therefore
not eligible for CERCLA response
actions or inclusion on the NPL. The
exclusions apply to 1) releases of
source, by-product or special nuclear
material  from a nuclear incident if these
releases are subject to financial
protection requirements under section
170 of the Atomic Energy Act, and 2)
any release of source, by-product or
special nuclear material from any
processing site designated under the
Uranium Mill Tailings Radiation Control
Act of 1978. Accordingly, such
radioactive releases have not been
considered eligible for inclusion on the
NPL. As  a policy matter, EPA has also
chosen not to list releases of source, by-
product,  or special nuclear material from
any facility with a  current license issued
by  the Nuclear Regulatory Commission
(NRC), on the grounds that the NRC has
full authority to require cleanup of
releases  from such facilities. (Formerly
licensed  facilities whose licenses no
longer are in effect will, however, be
considered for listing.) Comments
generally supported the position.
  Some commenters said that EPA
should also not list facilities that hold a
current license issued by a State
pursuant to a delegation of authority
from the NRC pursuant to section 274 of
the Atomic Energy Act (42 U.S.C. :!021|.
EPA ha» decided, however, that its
policy of excluding licensed facilities
from the list should extend only to those
facilities over which the Federal agency,
the NRC, has direct control. When a
facility is licensed by a Slate pursuant to
an NRC delegation, the NRC has no
authority, short of withdrawing the
delegation itself, to enforce conditions of
the license or determine that new
conditions are necessary. EPA
recognizes that the licensing State may
be able to ensure cleanup of any release
through the license, but has decided to
list such sites on the NPL to provide
potential Federal authorities if
necessary. Since listing on the NPL in no
way determines whether actual cleanup
actions will  be taken, EPA will be able
to defer to the licensing Slate whenever
the Agency determines that Stale efforts
are adequate to address  the problem.
  Some commenters staled that no sites
of radioactive releases should be
included on the NPL. for several
reasons. One point made was that other
Federal authorities, such as the Uranium
Mill Tailings Radiation Control Act of
1!178 (UMTRCA). provide adequate
authority to control releases from such
sites. With  the exception of certain
specified sites (which EPA has not
considered for listing on the NPL),
however, UMTRCA addresses the
problem only by inclusion of conditions
in facility licenses and does not
authorize any direct response actions.
While UMTRCA may prove adequate in
some cases. EPA believe* that CERCLA
provides sufficiently  broader authorities
lo warrant listing in anticipation of the
possibility that action under CERCLA
may prove necessary or appropriate H!
some of these sites.
   Another point made was that the MRS
does not accurately reflect the real
hazard presented by  radioactive sites
because the HRS scores releases of
radioactive  material  even when those
releases are within radiation limits
established  by the  Nuclear Regulatory
Commission and by EPA pursuant to the
Atomic Energy Act. As explained above
in discussing the HRS approach to
scoring observed releases, this factor is
designed to  reflect the likelihood thai
substances can migrate from the site.
.10! that the particular release observed
is itself a hazard. In addition. EPA's
experience h.is been that some
radioactive  releases do exceed these
standards, confirming the premise of the
HRS thnl y rurrcn! observed release in
low conciMilrHiions may be followed b>
greater releases leading lo higher
concentrations.

-------

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                  The Hazard Ranking Systems (HRS)
Purpose:  To teach persons who are performing site inspections the
          information requirements of the HRS.

Note:     A 2-day teaching and problem session on the HRS is offered
          for those persons who develop HRS scores and documentation
          packages.
                           Today's Agenda
1.  Overview of the Structure of the HRS

2.  A Factor-by-Factor Examination of the Informational Requirements
    of the HRS

    •  Groundwater
    •  Surface Water
    •  Air

3.  Fire and Explosion and Direct Contact

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                                                         OVERVIEW
                   An Overview of the HRS
•  How hazardous are the materials on-site?

   Toxicity
   Persistence
   Quantity

•  What is the probability these materials will migrate off-site?

   Observed release = 100%
   Otherwise containment x route characteristics for ground
   water and surface water

•  If the materials migrate, what are the targets that may be
   impacted?

   Population vs. distance
   Land and water use
   Sensitive environments

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                                                             OVERVIEW


                  Documentation Issues for the HRS


    •  Extensive investigation and documentation not required

    •  Specific HRS items must be documented

    •  "Preponderance of the Evidence"

    •  Establish rationale for HRS score

    •  Document the facts for public review

    •  A legally defensible record

    •  Demonstrate fairness

    •  Evaluation applied on a nationally uniform basis


               Documentation Issue  for  Field  Personnel


If the information vital to an HRS factor is gained in a
conversation—

    •  Telephone log, signed and dated

    •  Memo to file,  signed and dated

    •  If particularly sensitive, send a letter to the person
       summarizing the conversation asking for written confirmation
       of accuracy.

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                                                             OVERVIEW
A Site is defined by where the contamination is rather than by
property lines.

    •  Where originally deposited

    •  Where it has migrated to

      ,     A	                        .....
       Contaminated Stream
Contaminated Wells
Action Items;

    •  Search literature for where contamination attributable to the
       site has been observed.

    •  Check surface migration  paths  for  evidence  of  contamination.

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                                                             OVERVIEW
A site is evaluated on its condition before remedial actions.

    •  Before dredging, removal, capping, etc.

    •  Before the fish were killed and the stream closed to
       recreation

    •  Before municipal water was provided to users of contaminated
       wells

Timely waste management actions are not considered to be remedial
actions.

    •  Regularly scheduled covering of landfill and proper capping
       upon closure of a cell


Action Items:

    •  Search literature for information on past conditions

    •  Plot out on time scale conditions, management actions and
       remedial actions

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                                                             FACTORS






Factor-by-Factor  Analysis  of  the  Information Requirements of the HRS




1.   Three factors that appear in all 3 routes are discussed  first




    •  The observed release




    •  Toxicity/persistence or toxicity (air route only)




    •  Quantity




2.   The three routes are examined next




    •  Ground water




    •  Surface water




    •  Air

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                                                     OBSERVED RELEASE


An observed release is:

    •  Valued at 45 points

    •  Indicates the probability of migration is 100%


The alternative to an observed release is
    Route Characteristics x Containment

    •  Evaluated if there is no observed release

    •  Value may range from 0 to 45

    •  Containment indicates the likelihood that materials will
       leave the place where deposited

    •  Route characteristics indicate the likelihood that
       uncontained materials will move along the ground water or
       surface water pathways.
For the air route if there is no observed release, the route score
is zero.

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                                                     OBSERVED RELEASE


             Analytical Evidence of an Observed Release
                     "Significantly Higher Level
                     than  the Background Level"
    •  When a release is observed in any quantity, so long as it is
       above background, it can  be  considered a release.  This
       factor is not intended  to reflect level of hazard but is an
       indication  that substances can migrate from the site and that
       more may do so in the future.  48 FR 40665

    •  Negative results during one  or more sampling intervals cannot
       refute a positive finding, when based on valid sampling and
       analysis, that an observed release occurred.  49 FR 37078
    Examples of Situations in Which a Background Was Not Required


    •  Uncontained hazardous waste deposited in the water table

    •  Leachate from  site  observed flowing into creek

          leachate sample  must show  contamination close  to point of
          entry into  creek

       -  direct observation plus photograph

    •  Photograph of  dust  cloud  from tailings pile and of field
       personnel gathering dust  sample

          upwind/downwind  airbourne  particulate samples  would have
          been greatly perferred


Action Items:

    •  Search literature for releases already documented

    •  Determine what hazardous  materials are most likely to be
       found, and where

    •  Plan sampling  strategy to assure an adequate background

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                                                     OBSERVED RELEASE


Needed:  A rationale for attributing the contamination to the site

    •  A good sketch or map showing sampling points

    •  The hazardous materials were used/stored/released on site

    •  No alternative source


Sample analytical data for a site;

Above
Below

(ppb)
(ppb)
As
2
6
Cd(l)
5
8
Cr
10
20
Pb(5)
5
112
Cu
15
35
Zn
750
1090
Sample HRS documentation for an observed release

Contaminants detected in surface water at the facility or downhill
from it (5 maximum):

    Lead; Ref. 10 - attached data sheet

    Note that As, Cd, Cr, Cu and Zn were also somewhat elevated in
    the downstream sample versus the upstream background.

Rationale for attributing the contaminants to the facility:

    Pb at 112 ppb in creek just below the tailings pile vs. 5 ppb
    just upstream.  Ref. 10, Ref. 14.  The contaminants noted above
    were found in the tailings (Ref. 7).

    HRS Value = 45

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                                                             QUANTITY


                      Hazardous Waste Quantity


Hazardous waste quantity is defined as deposited.

    •  Contaminated rinse water to lagoon

    •  PCB-containing oil poured on ground

    •  Truckloads containing a hazardous component

The issue is not how much would have to be removed to effect a
clean-up.

    •  Sludge from lagoon

    •  Contaminated soil at site


Action Items;

On-site meaurements may include:

    number of drums
    dimensions and contents of tanks
    dimensions of evaporation and percolation lagoons
    size of piles

Record search includes:

    trucking manifests
    process engineering vs. production per year (be carefull)
    CERCLA 103C notification

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                                                 TOXICITY/PERSISTENCE


                        Toxicity/Persistence
    •  HRS values are read from a 4 x 4 matrix with 4 levels of
       toxicity and 4 levels of persistence.  The HRS matrix values
       range from 0 to 18

    •  For the air route, toxicity alone is evaluated

    •  Choose the compound that gives the highest HRS value.  This
       compound must have a non-zero containment score and be able
       to migrate by the route under consideration
Action Items:

    •  What hazardous substances would you look for?

          reprocessing of waste oils
       -  solvent recovery
          metal finishing operation
       -  wood preservative company

    •  Evidence of the presence of the compound:

          analytical
          trucking manifests (specific reference, not generic)
          plant process that universally involves the particular
          waste
                                 11

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                                                         GROUND WATER
                       The Ground Water Route
Often 2 or more aquifers are used in  the area.
          #11:

           Thou shalt not confound aquifers
The aquifer that yields the highest HRS score will be used in the
HRS documentation as the aquifer of concern.

Common Situation:

    •  Surficial aquifer:  observed release and a number of private
       wells

    •  deeper aquifer:  no observed release and some communal wells

Data on both aquifers will need to be separately evaluated to
determine which aquifer yields the highest HRS score.
Action Items;

Task 1:  Find out about the hydrogeology within 3 mile radius of
site:

    •  thickness, depth and names of various water-bearing strata

    •  description of confining layers

    •  barriers to horizontal migration

    •  evidence that aquifers function as a single hydrological unit

What sources of information will be useful?
                                 12

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                                                         GROUND WATER
                          Observed Release
The release and the background well must be in the same aquifer.

Knowledge of flow gradients help in determining where to look for
background versus contamination...but beware of local or seasonal
variation.

Background well(s) must discriminate out any alternative sources of
the contamination.
Action Items:

    •  Are there existing nearby wells?

    •  At what depth are they screened?

    •  Can existing wells provide an adequate background?

    •  Are any drinking water wells contaminated?
                                13

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                                                     GROUND WATER


               Depth of  the Aquifer of  Concern


•  Deepest level at which contamination Is documented

»  If depth of deposit is unknown, 6 feet may be assumed

•  Highest seasoned level of the saturated zone of the aquifer


                      Net Precipitation


•  Use figures 4 and 5, or the original sources

•  In some areas, may get higher HRS value by using seasonal
   (one or more consecutive months) data.

   -  same months for precipitation as for lake evaporation

      data must be averaged over at least 10-20 years


            Permeability of the Unsaturated Zone


        Actual tests

        Well logs and Table 2

        SCS is not usually helpful

        Evaluate the least permeable continuous layer


                       Physical State


                   At  the time  of  disposal

-------
                                                         GROUND WATER
                             Containment
Note that containment for groundwater ±s not described by the same
factors as containment for surface water.
The issue is leachate-generation
                 Surface encourages                  Surface water
                      ponding -v            ^^^T      run-on
                                             Quality of Liner, if any

             Leachate collection system, if any

Describe containment in terms of Table 3.

Describe containment before any remedial actions.

Evaluate containment carefully.  It has a major impact on the site
score.
                                 Use
Describe use for each aquifer separately.

Describe use before any remedial actions attributable to the site.

Describe before any effects of pollution attributable to the site.


Action Items:

For HRS value of 3:

    •  Identify at least one user who does not have alternative
       water from an unthreatened source readily available

    •  If a municipal system is threatened, show that the loss of
       wells within the 3 mile radius would require the development
       of alternative sources to meet the system demand
                               15

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                                                     GROUND WATER
                Distance to the Nearest Well
•  Specify nearest well for each aquifer separately and give
   depth of well to verify aquifer

•  The well must be currently used for drinking or irrigation
   (not monitoring, not industrial) or have ceased to be used
   because of contamination specifically attributable to the
   site (documentation needed)

•  Give location of well and show it on map

•  Measure distance from well to nearest point of documented
   contamination

•  If well is contaminated and contamination is attributable to
   the site, the distance is zero
                             16

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                                                         GROUND WATER


                          Population  Served


Evaluate separately for each aquifer

For each residential connection or house, count 3.8 persons

Public Supplies

    •  EPA data base on public supplies (15 connections, 25 people)

    •  Phone calls to communities for geographical extent of
       service, number of connections,  location of wells

    •  State summaries on water supplies

    •  Is water from the contaminated well potentially deliverable
       to any customer served by the system?

Private Wells

    •  House-count within 3 mile radius from the contamination

    •  Show clearly on house-count map those areas not counted
       because they are served by communal or municipal sources
       drawing from a different aquifer

    •  If more than one aquifer, need some rationale for the
       population that is to be attributed to each aquifer
                                17

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                                                         GROUND WATER
                             An Exercise
Develop an MRS ground water score from the following information:

    Observed Release:  Monitoring well #1, screened from 12 to 16
    feet in surficial aquifer, shows chlordane.  Not detected in
    monitoring wells, 2, 3 and 4.

    Hydrogeology:  Surficial aquifer at 12 to 30 feet depth in
    vicinity of site.  Confining layer of silty clay from 30 to 45
    feet deep.  Clarkson aquifer from 45 to 85 feet.  Well logs show
    no discontinuity in the clay layer within the 3 mile radius.

    Net precipitation is +6".

    Site investigation shows contaminated process water was
    discharged to an evaporation lagoon.  The once-filled operating
    capacity of the lagoon is 333 cubic yards (30* by 100' by 3').
    The lagoon has no liner or leachate collection systems.

    Village of Southland has a radial supply system with 3 wells, 2
    of which lie within 3 miles of the site.  The closest is 2500
    feet from contaminated monitoring well #1.  The village engineer
    reports that all 3 wells are in the Clarkson with depths ranging
    from 58 to 87 feet.  The village clerk reports that the system
    has 695 residential hook-ups.

    The nearest residential well in current use is the Jones
    residence, located 1200 feet from the contamined monitoring well
    and drilled to 28 feet depth.

    A house count within the 3 mile radius of the site (USGS topo,
    photo-revised to 1975) and not counting the area served by the
    Southland system showed 128 residences.  A survey of the state
    well logs for this area showed that 65 percent of the wells are
    completed in the surficial aquifer.
                                18

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Rating Factor
UJ Observed Release
Ground Water Route Work Sheet
Assigned Value Multl-
(Circle One) pller
0 45 1
Score

Max. Ref.
Score (Section)
45 3.1
If observed release Is given a score of 45, proceed to line [4].
If observed release is given a score of 0, proceed to line \2\.
H] Route Characteristics
Depth to Aquifer of
Concern
Net Precipitation
Permeability of the
Unsaturated Zone
Physical State
3.2
0123 2 6
0123 1 3
0123 1 3
0123 1 3
Total Route Characteristics Score
Lil Containment
H Waste Characteristics
Toxldty / Persistence
Hazardous Waste
Quantity
0123 1


15
3 3.3
3.4
0 3 6 9 12 15 18 1 18
0123456781 3
Total Waste Characteristics Score
LLI Targets
Ground Water Use
Distance to Nearest
Well / Population
Served

26
3.5
0123 3 9
\ 0 4 6 3 10 1 40
12 16 18 20
I 24 X 32 35 40
Total Targets Score
H If line [TJ is 45, multiply
If line [T] la 0, multiply
H3 Divide line [a] by 57,330
T| x [3] « H x [U


49
57,330
and multiply by 100 Sgw-
           FIGURE 2
GROUND WATER ROUTE WORK SHEET
             19

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                                                        SURFACE WATER
                       The Surface Water Route
The first step is to identify  the  surface water migration path.

    Trace out on a map  the  path(s)  that  surface run off will take
    from the site to the probable  point  of entry to surface water.

    From this probable  point of entry  follow the surface water flow
    in stream miles for three  miles  (but limited to only one mile of
    static water).

All targets (uses, sensitive environments, water intakes) must lie
on or contiguous to this surface water migration path.

The definition of surface water for  HRS  purposes includes:

    •  All perennial streams and rivers  from their point of origin
       to the sea

    •  Intermittent streams only in  areas with less than 20 inches
       of normal annual precipitation

    •  Man-made ditches only insofar as  they are perennially flowing
       into other surface water

    •  Isolated but perennial  ponds  or lakes

The HRS cannot handle those surface  water situations where
contaminated ground water is alleged to  discharge to surface water
unless contamination of surface water  at the point of discharge is
actually measured.

If tidal reversals take place  within the migration path, the extent
of these reversals needs documentation.
Action Items:

    •  When on-site, describe and map out the surface migration path
       from each wast area to the nearest surface water

    •  Determine where on the migration path the most down gradient
       samples should be taken that will define the site boundary
                                 20

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                                                        SURFACE WATER


                        The Observed Release
    •  Upstream/downstream samples are normally required, and taken
       at such points as to distinguish the site from alternative
       potential sources of contamination

    •  The exception is when contaminated leachate or contaminated
       ground water (e.g., a spring) is observed to flow into
       surface water

    •  The most downgradient or downstream point of documented
       contamination marks the beginning of the surface water
       migration path
               Facility Slope and Intervening Terrain
       If the site is actually in surface water but without evidence
       of release to surface water,  note in report

       Facility slope is measured from the highest point of
       hazardous waste deposit to the most downgradient point of the
       storage area or of where contamination is detected

       The slope of intervening terrain is measured from the most
       down gradient point of documented contamination to the
       probable point of entry to surface water
Action Item:

When on-site, measure or estimate the slopes of the waste storage
areas and of the intervening terrain.
                  Distance  to  Nearest  Surface  Water
       Measured from the most down gradient point of documented
       contamination to the probable point of entry to surface water
                                21

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                                                        SURFACE WATER


                      One Year 24-Hour Rainfall


The value is read from Figure 8.


                           Physical State


Same procedure as for ground water.


                             Containment


Do not confuse surface water containment with ground water
containment.

The issue is not leachate generation, but surface run-off.

Describe containment in the terms used in Table 9.

    •  Adequate free board

    •  Adequate diking or run-off diversion structure

    •  Quality of cover

Containment is always evaluated before remedial actions (as
contrasted with timely waste management practices).


                  Toxicity/Persistence and  Quantity


    •  These factors are usually the same as for ground water

    •  Occasionally, however, there is a compound or quantity that
       has a zero containment value for one route and not the other

    •  Count only those substances and quantities that can
       potentially migrate via the route under consideration
                                22

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                                                        SURFACE WATER
                               Targets
Uses and Sensitive Environments must lie within 3 migration path
miles (limit of 1 mile in static water) from the hazardous
substances.

Population served must be served by surface water withdrawn within 3
migration path miles (limit of 1 mile in static water) from the
probable point of entry of contaminants into surface water.

Critical Habitat does not include the entire range of the species
but only the areas in which the species are normally found nesting
or breeding.

Consideration is limited to federally endangered species.

An open irrigation ditch counts as a part of the migration path and
the 3 mile limit.  A pipe does not.
Action Items;

    •  Examine USGS topo map for any intakes or wetlands

    •  Contact water authorities to verify whether there are surface
       water intakes.  Are they used?  Population served?

    •  Contact agricultural authorities for irrigation intakes,
       acreage under irrigation

    •  Contact environmental experts for critical habitats of
       Federally endangered species

    •  If use is recreational, verify with memo on file
                                23

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                                                        SURFACE WATER
                             An Exercise
Develop an HRS surface water score from the following information:

Approximately 450 drums, many on the ground behind the abandoned
transfer center.  Sampling indicates spent solvents such as methyl
ethyl ketone, acetone and toluene and wood perserving compounds such
as pentachlorophenol, chromated copper arsenic  (CCA) and creosote.
The storage area is essentially flat with drainage to the west north
west to an unnamed tributary of deer creek.  The ground is stained
at the storage area and down along the drainage path to the
streambed.  Vegetation has been killed or appears stressed.  One
year 24-hour rain in the vicinity is 1.5 inches and normal annual
precipitation is 16 inches.  The map of the surface migration path
is attached and shows the location of potential targets.
                                                      ,l&
                               24

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Surface Water Route Work Sheet
Rating Factor
Qj Observed Release
Assigned Value
(Circle One)
0 45
Multi-
plier
1
Score

Max.
Score
45
Ref.
(Section)
4.1
If observed release Is given a value of 45, proceed to line f7j.
If observed release Is given a value of 0, proceed to line [jT.
LU Route Characteristics
Facility Slope and Intervening 0123
Terrain
1-yr. 24-hr. Rainfall 0123
Distance to Nearest Surface 0123
Water
Physical State
\2\ Containment

0123
4.2
1 3
1 3
2 6
1 3
Total Route-Characteristics Score

0123
H Waste Characteristics
Toxiclty / Persistence
Hazardous Waste
Quantity
LU Targets

0 3 6 9 12 15 18
012345678

1


15
3

4.3
4.4
1 18
1 8

Total Waste Characteristics Score

Surface Water Use
Distance to a Sensitive
Environment
Population Serve
to Water Intake
Downstream
2J If line QJ Is 45,

0123
0123
id/Distance 10 4 8 8 10
I 12 16 18 20
| 24 30 32 35 40

26

4.5
3 9
2 6
1 40
Total Targets Score
multiply
If line Q] Is 0, multiply
CZ3 Divide line 0 by 94,350
Q3 x 0 x H
2] x [3] x [7j x [sj
and multiply by 100





55

84,350



»«.-
           FIGURE 7
SURFACE WATER ROUTE WORK SHEET
             25

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                                                            AIR ROUTE


                            The Air Route


If there is no observed release, the pathway score is zero.



Air measurements must be  taken at  reasonable distances from sources
such as stocks, drum openings, well heads, leachate pool
contaminated soils, etc.

No disturbance of the site is allowable.

Samples should be taken in the breathing zone.

The human nose is not considered an analytical instrument.

OVA in survey mode is not acceptable because it picks up methane.
Show that a volatizing substance is uncontained on site and show
airbourne transport by upwind/downwind sampling.
Dust sample must be taken from locations unaffected by the
activities of residents or workers.  Upwind and downwind dust
samples are preferred.
Show sampling locations with respect to the volatilizing or
particulate source and. indicate wind direction during sampling.
Report sampling procedure in detail.

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                                                            AIR ROUTE
                              Quantity
Count only those quantities that can migrate by the air route, if
released.
                         Population/Pistance
Draw concentric rings of 1/4, 1/2, 1 and 4 miles around the
volatizing source, or source of particulate and document population
within each ring.
Note:  No provision is made for wind direction in the evaluation of
air route targets.
                                27

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                                                            AIR ROUTE
                             An Exercise
Develop an HRS air score from the following information:

An anonymous tip led to the investigation of this site, a warehouse
and parking lot stacked with an estimated 50 to 60 thousand drums.
Many drums are battered, some leaking and the drums stored outdoors
are corroded.  The drums are piled 3 and 4 high.

Spot checks sampling revealed a wide variety of chemicals including
benzene, methyl ethyl ketone, toluene, pciric acid, caustic sludges
and spent acids.

Air sampling was also done because of the smell of chemicals both
inside the warehouse and in the adjoining parking lot.  All HNu
readings inside the building were high.  An adequate upwind/downwind
sample pair was however, obtained at the northeast corner of the
parking lot (upwind) and the southwest corner of the property line
about 75 feet downwind from the outside drum storage area.

The nearest commercial building is immediately adjacent to the
warehouse.  The nearest residential area is almost one half mile to
the north.  The historic part of the harbor is less than one half
mile to the east.

The city planning board estimated that over 100,000 persons live
within 4 miles of the site.  At least 5000 people work in the
industrial area that surrounds the site, approximately a one half
mile radius.  The technical college with 1200 students is located 3
blocks to the north of the site.
                                28

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                                    Air Rout* Work Sheet
    Rating Factor
  Assigned Value
   (Orel* One)
Multi-
plier
                                                                    Score
Max.
Score
  Re«.
(Section)
    Observed Rnleane
                                                45
                                                                             45
                                                    5.1
    Date and Location:
    Sampling Protocol:
    If line  0  Is 0, the Sm • 0. Enter on line \5j .
    If line  R]  la 45, then proceed to line  \2\.
    Waste Characteristics
     Reactivity and
      Incompatibility
     Toxtelty
     Hazardous Waste
      Quantity
 0123

 0123
 012345678
                                                    5.2
                             Total Waste Characteristics Score
                                                                             20
    Targets
     Population Within
      4-Mlle Radius
     Distance to Sensitive
      Environment
     Land Use
 0  9 12 15 18
21 24 27 30
 0123

 0123
                                                    5.3
               30


                8


                3
                                   Total Targets Score
                                           39
    Multiply MJ «  [2]  x
                                         35,100
LU  Divide line  Q  by 35,100 and multiply by 100
                                        FIGURE 9
                             AIR ROUTE WORK SHEET
                                           29

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      APPENDIX A
SOURCES OF INFORMATION

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                               TABLE 1

            SOURCES OF INFORMATION FOR CHARACTERIZATION OF
                         HAZARDOUS SUBSTANCES
1.   Review management records
     a.  Waste inventories
     b.  Storage inventories
     c.  Shipment manifests
     d.  Permits
2.   Search for Waste Generator Records
3.   Interview
     a.  Site Personnel
     b.  Neighbors
     c.  Government Inspectors
4.   Review Official Agency Files
     a.  Permit Application
     b.  Site Inspection Reports
     c.  Sampling or Monitoring data
5.   Consult Toxicology and Hazardous Substances References
     a.  Chemical Hazard Response Information System
     b.  Hamilton and Hardy, Industrial Toxicology
    *c.  Sax, Dangerous Properties of Industrial Materials
     d.  Patty, Industrial Hygiene and Toxicology
     e.  ACGIH, Threshold Limit Values for Chemical Substances and
         Physical Agents in the Workroom Equipment
     f.  Miedl, Hazardous Materials Handbook
     g.  Hauley, Condensed Chemical Dictionary
     h.  The Merck Index
     i.  CRC Handbook of Chemistry and Physics
    *j.  NFPA Hazardous Materials Manual
    *k.  JRB Associates, Methodology  for Rating the Hazard Potential
         of Waste Disposal Sites
    *These are the only reference documents  recognized  as having
    accepted toxicity values.
6.   Consult Industrial Processes References

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                               TABLE 2

             SOURCES OF INFORMATION FOR IDENTIFICATION OF
                     POLLUTANT DISPOSAL PATHWAYS
1.  Geological Data
     a.  USGS Topographic Maps (Identifies surface drainage features)
     b.  Other USGA Publications (Geological and water resources)
     c.  State Geological Survey Offices
     d.  USDA Soil Conservation
2.  Hydrology
     a.  USGS Water Resources Reports
     b.  State Water Resource Division
     c.  Flood Insurance Rate Maps  from US Dept of Housing and Urban
         Development (or local insurance agency)
3.  Aerial Imagery
     a.  EPA Sources
         1.  Environmental Photographic Interpretation Center (EPIC)
             in East
         2.  Environmental Monitoring Systems Laboratory (EMSL) in
             West
     b.  National Cartographic Information Center (NCIC) photos
         collected from NASA, USOA, USGS, NDAA and National Archives
     c.  Local Planning Agencies
4.  National Weather Service publications (rainfall, etc.)
5.  EPA Site Reports
                                  A3

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                               TABLE 3
         SOURCES OF INFORMATION FOR RECEPTOR CHARACTERIZATION
1.   Maps and Aerial Photographs
     a.  USGS
     b.  State Department of Transportation
     c.  Local Planning Groups
     d.  Utility Companies (right-of-way maps)
     e.  County Road Commissions
2.   Local Water Departments
3.   US Public Health Service files and publications
4.   County Agricultural Extension Offices
5.   Federal and State Fish and Wildlife Departments
6.   Local Universities
7.   Local Naturalists
8.   Medical Reports
9.   Local Newspapers
10.  Local well drillers
                                  A4

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APPENDIX B

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                             SAMPLE PLAN
I.  INTRODUCTION

     A brief paragraph citing  authorities  and  reasons for developing
this plan.

II.  OBJECTIVES

     Delineate, by item, the proposed  objectives  of the SI.   Be  sure
to address each phase of  the  SI and its  reason  including air,  soil,
surface and ground water sampling as appropriate.

III.  SITE DESCRIPTION

     Describe the size  and  location of the  site.   Provide the  legal
description of  the  site by  Section,  Range  and  Township  as  well  as
latitude  and  longitude.   Also  provide  a  summary  of  the geology  and
hydrology of the  area.   This  section should also  include any use  of
the aquifer, any environmental  sensitive areas, etc.

LV.  FIELD PROCEDURES

     Describe  the field  operations planned  including:    Concept  of
Operations,  Sampling   Locations,   Coordinating    instructions,   Site
Safety plan, Project  schedule, Personnel  requirments  and duties  and
Control of Contaminated  materials.   A  table should be  included  show-
ing samples, locations and rationale for that  sample.

V.  LOGISTICS

     Discuss how  the personnel  and  equipment will  get  to and  from the
site.  A  description  of  how samples will be  delivered to the  lab  as
well as what laboratory will be used should  also be included.

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VI.  QUALITY CONTROL

     The plan  should  provide a discussion  of  quality control  proce-
dures  to be  implemented  in  the  following  areas:   Sample Methods;
Sample  Preservation,  and  Containers;  Equipment  Decontamination  and
Chain of Custody.

VII.  SAMPLING REPORT

     Describe  what  the  final  report  will contain,  who  will  receive
copies  of it, where copies may be  obtained  and  procedures  required  to
obtain  copies.   Include  the  date  the  report  will  be  available.

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                       SAMPLE PLAN DEVELOPMENT
I.  INTRODUCTION

     The purpose  of  this section  is  to acquaint  the  reader with  the
procedures  necessary  to  develop  a  detailed  sampling  plan  for  Site
Inspection (Si).

II.  PURPOSE AND OBJECTIVES OF THE SITE INSPECTION

A.  PURPOSE

     The purpose of the  SI  is  to characterize the problems  present  at
a potential or identified hazardous waste site.  The primary  objective
of  an  SI  is  to  generate  a sufficient  data  base  to  compute  a  site
score,  under  the Hazard  Ranking  System (HRS).  Site-specific  informa-
tion collected  during  the SI will update  or confirm information  that
was  presented in  the Preliminary Assessment.    The  site  visit  may
include  the  collection  of sufficient  samples  to  verify  that a  hazar-
dous waste control problem exists.

B.  OBJECTIVES

     The objectives of  a site inspection  include one or  more  of  the
fol lowing:

     o   to  confirm  preliminary   assessment   data  that   is   otherwise
         poorly substantiated;
     o   to  obtain data  that was  unavailable during  the  preliminary
         assessment;
     o   to  update  site   conditions,   if  there  are  indications  that
         changes may have  occurred  at  the site; and/or
     o   to obtain  data  necessary  to  conduct  an  HRS ranking  or  plan a
         field investigation.

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     It  is  important  to  provide  analytical  evidence  that  a significant
hazardous substance control  problem exists  at  a  specific  site,  so  that
HRS  ranking  and/or  more  detailed  SI  follow-up can  be  developed  to
fully  characterize  such  pollution sources.   To  accomplish  this  objec-
tive,  the site  inspection includes biased  sampling  of  limited  on-site
locations  to demonstrate that  hazardous  materials  are  present,   and
biased  sampling  of  off-site locations to demonstrate  the  migration  of
such wastes.

III.   SCOPE  OF WORK

     The  site inspection  is not  an intensive,  complete  environmental
assessment.   Rather,  it  is a  limited,  quickly  implemented  effort.
Site Inspection  activities are  restricted  to:

     o   field measurement of ambient  conditions  (background);
     o   documentation of observations  regarding  conditions at  the  site
         or  at sample  collection  locations;  and
     o   collection  of  environmental  grab   samples  and  samples  from
        waste spillage,  open containers,  waste pits,  and  lagoons.

     Specifically   excluded  from   site   inspection  activities   are
enforcement-related   studies  (but  enforcement  procedures  should  be
followed),  geophysical  testing  (with the exception  of metal  detectors
or proton magnetometer  surveys), ground water monitoring  well  instal-
lation  (unless  the  state  has  a drill rig),  and all  other  activities
that  require detailed  background  investigation  or  specialized  tech-
niques.  Finally,  studies aimed at identifying  the  extent  of  contami-
nation,  rather   than  its  existence,  are  beyond  the  scope  of  a  site
inspection.

IV.  HRS SAMPLING STRATEGY

     To  insure  that  necessary  HRS  ranking  data  is   collected,   a
sampling plan must  be developed  for  each  site  to  be  inspected.   The
sampling plan should  be  developed  to  insure  that:

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     o  off-site  sample  locations  target  the maximum route  population
        and/or sensitive environments exposed  to  the  site
     o  appropriate  background  samples,  both  in  type  and number,  are
        collected to confirm a release
     o  if  no documentation  exists regarding  waste characteristics,
        discrete  samples positively identifying pollutant sources  are
        collected
     o  on-site  sampling  (medium and  high  hazard)  is  minimized with
        priority being given to:
        - liquids, gases and sludges;
        - powders or fine materials;
        - unconsolidated or unstabilized solids
     o  verify,  document  and  sample,  if  possible,  the  least  secure
        pathway to surface and/or ground water
     o  water samples are prioritized as follows:
        - drinking water;
        - irrigation,  fisheries,   food  preparation,  and/or   recrea-
          tional; and
        - commercial or industrial.

V.  PRELIMINARY SI ACTIVITIES
A.  ASSIGN PROJECT MANAGER

     Each  site  should be assigned  to a  particular  individual.   This
person will serve as  the project manager  throughout  the  entire  SI.

B.  BACKGROUND COLLECTION

     Planning  for  a  site  inspection begins  with the  collection  and
review of pertinent available data regarding  the  site.   The  background
data review of  such  information serves  to establish the  specific  site
inspection needs and  to  identify missing elements to be  determined at
the site.

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C.  PROBLEM  DEFINITION

     At  this  stage,  a preliminary  HRS  score  should be  done  to  see
what  impact  the site  has  and to get  an  idea of how  sampling  will  be
effective.   This preliminary ranking  will  allow Sis  to  be prioritized
based  on  apparent  hazards.   The site inspection is  usually  the first
phase   of   site   characterization   that    involves   site   contact.
Consequently,  it generates a need for consideration of site safety for
investigative  personnel.    After reviewing the  background information
available  for  the site,  the project manager must  determine  the types
of   equipment    that   will   be   needed  to   provide   adequate  dermal
protection,  repiratory  protection,   and  protection  from  mechanical
injury for  the  team.  This information will be  incorporated  into the
sampling  plan  when it  is  written.

     If  potential  hazardous  substances  at  the  site have  been identi-
fied,  the project  manager  can  assemble information on  the substance,
determine  the  physical   state   of   the  substance  likely  to  be  be
encountered,  and then choose  the appropriate protective  clothing and
respiratory  protection.   Sites  that  require  no  more  than  Level D pro-
tection may  be inspected  by as  few as two persons.   Any  site requiring
the wearing  of respiratory protection  (Level C,  B,  and  A) will neces-
sitate at  least  three  team members:  two inspectors  "downrange" utiliz-
ing the buddy  system,  and  at least  one inspector upwind  in the support
area as a safety observer.  If  only  three  inspectors  are  present on a
Level  C,  B,  or A site, the safety observer should not enter the exclu-
sion  area (go downrange)  to effect  a rescue  of the two inspectors.
They must extract  themselves.

     A preliminary  hazard evaluation  is necessary  to  determine  the
equipment and  manpower needs for the site inspection.

     Often  there  is   not  enough background  information  available  to
make a decision  regarding  the  level of personal protection  that will
be necessary.  In  such instances, the team must  be  prepared to use the
highest  level  of  respiratory   protection  for  at   least   the  initial

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entry  during  site inspections.   This usually means  a  self-contained
breathing  apparatus  (SCBA)  with  appropriate dermal  protection.    If,
after  arriving  at  the  site,  the  project  manager  and  site  safety
coordinator can  determine  that  the  site does not  pose the  potential
dangers originally assumed,  the  level of protection may be  downgraded
to a lower level.

VI.  SAMPLING RATIONAL

A.  INTRODUCTION

     The  preliminary  activities  should  have  provided  the  following
site-specific information:

     o  types of  hazardous materials expected  to be at  the  site,  such
        as organic solvents, pesticides,  heavy metals,  etc.,
     o  probable  locations  of these materials   (soil,  surface water,
        ground water,  or air),
     o  potential off-site migration  routes, and
     o  potential sampling locations.

     The  project  manager must  now  begin  to formulate  the types  and
number  of  samples necessary  to  fulfill  the SI  and HRS requirements.
The project manager must also determine  the  appropriate  parameters  for
the samples collected.   Information  developed during  this  phase  will
be  incorporated  into  the  sampling  plan.    Sources  of   information  to
assist  these decisions are provided  in Appendix  A,  Table 1.

B.  ENVIRONMENTAL PATHWAYS

     Hazardous wastes will segregate into one, two  or  all  three  avail-
able environmental pathways  (air,  water  or soil)  based  on  the physical
and  chemical   characteristics  of  the  materials.    Examples  of  this
segregation include:

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      o  Organic solvents  are  volatile, water  soluble  to  some degree
         and  may bind  to  soils.   Consequently,  they  would  be expected
         in all environmental pathways.
      o  Heavy metals may be water  soluble  and  may be spread by eolian
         forces.  They  would be  routinely  expected  in  soil  and water
         pathways;  however,  breezy  conditions   can  induce  short  term
         severe impacts.
      o  Pesticides  tend to  bind  to  soils  and would exhibit short term
         air  impacts during  application  and/or  windy  conditions.  Many
         of these materials  photo degrade  at the  soil  surface but may
         persist at  depths of 6 inches or more.

      To  provide  sufficient data  for HRS  ranking,  it  is  critical  to
have  background samples.   These are  from areas expected to be unaffec-
ted by the waste site.   Background samples must be collected  from each
environmental  pathway  for  which contaminant  samples  are  collected.
Table 2  in Appendix  A  provides  a  list  which aids  in  selecting loca-
tions for  sample collections for background and off-site sampling.

      Off-site sampling locations, selected to show off-site migration,
should be selected  to emphasize the  threat  to  local  populations  or
sensitive  environments.  Table  3 in Appendix A provides  some aids  to
assist in  selecting  such  sampling locations.

      The  project manager  needs  to  relay  information  concerning  the
final  decisions  on  type,   number  and  parameters of  samples  to  the
laboratory coordinator.   The  lab  coordinator  will  then  provide  this
information  and anticipated dates  for  sampling  and  shipping  to  the
analytical  laboratories or the Sample Management Office.

      Such  planning  of sample numbers  and  locations  allows  the project
manager  to assess the  equipment  needs to conduct the SI.

     Once  the level  of protection  has been  determined  and  the number
and types  of  samples  and  field  measurements have been  decided upon,
the project manager  should make  sure  that  there will  be enough equip-
ment  to complete the  scope  of  work  in a safe and timely manner.

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     Manpower  needs  will  depend  on all  of  the  following  considera-
tions:  the necessary level of protection;  sampling  and  field  measure-
ment  requirements,  and  the amount  of  equipment  that  must  be  carried
on-site.   Even at  a Level D site,  a two-person  team  will  find  it
difficult  to  carry  all  the equipment  that wil be  needed to  complete
the work.   Sometimes, it  is necessary to  increase  the number of  per-
sonnel at  a site  just  to  carry all  the  instruments  that  are  required
and to perform the necessary monitoring tasks.

VII.  SAMPLING PLAN

     Site  inspections require a work plan  which describes  the  scope  of
work  and  details  the  methodologies   and  safety   procedures  to  be
followed.  A  work plan  can be adjusted to  suit  the  activities  of  the
specific  investigation,  but  it  should  always contain  the  following
eleraents:

     o  A  summary of  background  information  on the  site and  a  refer-
        ence  to legal authority to perform  Site Inspections.
     o  A  statement  of  objectives  and  goals  of  the  investigation.
        Typical investigation goals  include hazardous  substance  inven-
        tory  and documentation of pollutant migration.
     o  Investigation methods required to  characterize the  site.   This
        includes a sampling plan that  indicates sample types,  sampling
        locations, sampling procedures, and field quality  control.
     o  Personnel requirements.
     o  Equipment needs.
     o  A  safety plan.
     o  Any nonstandard  equipment  or  contract services  which may  be
        needed to complete  the investigation.
     o  Methods  used  to   control  contaminated   materials,   including
        decontamination procedures,  solutions to  be  used,  and  storage
        or  disposal  requirements  including RCRA manifest  number  for
        removal if designated hazardous.
     o  Special training requirements.
     o  Organization of special teams.

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     As  this  list indicates,  the  work plan  allows  the  investigation
team  to  efficiently  schedule  such resources  as  manpower,  equipment,
and  laboratory  services  (in-house   or  contract)  in  advance  of  an
investigation.  The work plan  is thus an essential tool  in  the  inves-
tigation  of  hazardous substance sites.   A descriptive outline  of  the
sampling  plan elements  is  provided in Appendix  B.

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                                SECTION 1

                      SAMPLE COLLECTION TECHNIQUES

1.1  INTRODUCTION
     Currently, there are few publications providing guidance specifical-
ly directed to sampling at  hazardous  substance  sites.   The sampling pro-
cedures  outlined  in  this  manual  are  adaptations  of  methods  which  are
described in a variety  of  publications.   The publications most directly
applicable to  sampling  at  hazardous substance sites include  the follow-
ing:

     (1)  Enforcement Considerations for  Evaluations of Uncontrolled Haz-
          ardous  Waste Sites by Contractors  (NEIC, 1980)

     (2)  Samplers and  Sampling  Procedures  for  Hazardous  Waste  Streams
          (MERL,  1980)

     (3)  Procedure  Manual  for  Groundwater  Monitoring  at  Solid  Waste
          Disposal Facilities  (EPA, 1977)

     (4)  Field  Monitoring  and  Analysis  of Hazardous  Materials  (E RT,
          1980)

     The objective of sampling  is  to acquire data  which  will  assist in-
vestigative personnel in determining:

     (1)  The  identification  of  the  hazardous   substances present  at  a
          site and

     (2)  The occurrence and extent of hazardous substance migration.

     Also, the data  generated  from analysis of  samples  often provides a
crucial  portion  of  the  evidence used in subsequent  litigation  and may
further be used  in  the  development of appropriate remedial action  alter-
natives.   Therefore, the  design of  the  sampling  operation  must  ensure
                                   1-1

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 that  the  samples  obtained  will  meet  the  goals  of  the  investigation.
 Careful selection of sampling locations and methods also helps reduce the
 costs of labor and analytical support.

 1.2  SAMPLING STRATEGY
      Hazardous substance  sites  normally are sampled  to  provide  data for
 HRS,  support  enforcement, or  characterize the  site   for  remedial  work.
 These tasks entail different sampling goals and strategies.
      For enforcement  alone it  is  not necessary  to  identify  all  of the
 site's hazardous  substances  or  areas  of  migration.   The general  strategy
 is   to  sample  those  areas  or  containers  most likely  to give  positive
 evidence of the most hazardous  contamination or chemical suspected to be
 present.   Likewise, to  demonstrate  off-site migration, those areas where
 off-site migration is most probable  are  sampled first.  Thus, containers
 to  be  sampled  for evidence of hazardous  chemical  presence are generally
 selected on  the  basis  of  drum  markings or  other  information indicating
 hazardous  contents.   Stream  sediments are  sampled  in  locations  of heavy
 stream deposition,  and  stream  water  samples  are  collected  nearest  the
 point  of  suspected  contaminant  entry.    Therefore,   a biased  sampling
 approach  is used  for  legal support.  This approach  is  contrary  to  most
 established  sampling procedures which stress  the  importance  of selecting
 sampling points without  bias.
      For  site investigations in support  of remedial  design,  thoroughness
 in  total site characterization is  desirable.  In such cases,  statistical-
 ly  acceptable  random  sampling  techniques  should  be  used  if  possible  to
 minimize  sample  numbers.     Portions  of  this  discussion  will  describe
 applicable  random sample selection procedures  and  the  references  provide
 further guidance.

 1.3   TYPES OF  SAMPLES  FOR  FIELD INVESTIGATIONS
 1.3.1   Environmental  Samples
      Environmental samples  are  normally dilute  and  do  not   require  the
 special  shipping  procedures  used  with concentrated samples  (Section  6).
 If  there  is  reason to believe  that particular  environmental  samples  are
concentrated  or  particularly  hazardous for  any  other  reason,  they  should
be shipped as  hazardous  samples.
                                    1-2

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1.3.2  Hazardous Samples, Excluding Those Taken From Closed Containers
     These  include  on-site  samples  obtained  from  surface   impoundments
(lagoons), pits, waste  piles and containers,  including  drums,  tanks and
tank cars.  Based  upon  the best professional  judgement  of field person-
nel, these  types  of samples  may be sub-categorized  as  either  high- or
medium-concentration samples.
     High-concentration hazardous  samples  include all  samples  that  have
no obvious and  significant  dilution  with water,  soil,  or any other  non-
toxic component.   Generally these samples  are from containers  or  fresh
spills.   Obtaining  these  samples poses the  greatest risk of  exposure to
personnel.  In addition, U.S.  Department of Transportation (DOT) regula-
tions require that  the  samples  be  shipped  under "worst case" conditions.
The samples should be conveyed to a regulated substances  laboratory  where
they may be safely prepared for  further analysis.   (See Section 6.)
     Medium concentration hazardous  samples  are environmental  samples
suspected  of  being  heavily contaminated  because  they  are  discolored,
turbid,  odorous, or  from a location suspected  to be  highly  concentrated
(spill location).   These  samples are  shipped in  the same manner as  high
concentration  samples,  but  should be  analyzed  only in  an environmental
laboratory equipped with an OSHA-approved carcinogen glove box (Policy of
EPA for contract laboratories).

1.3.3  Hazardous Samples Taken From Closed Containers
     These samples must  be  shipped to a  regulated  substances laboratory
for preparation prior  to analysis.  EPA maintains such  a laboratory at
the  National   Enforcement   Investigations  Center   (NEIC)   in  Denver,
Colorado, which may be  consulted for  guidance.   Currently, shipment  must
be according to DOT regulations  for  "Poison A" substances, unless  avail-
able information  clearly excludes the  possibility  of   the  presence  of  a
"Poison A" substance.

1.4  GENERAL SAMPLING TECHNIQUES
     Two  types  of  sampling  techniques are  generally   recognized:    grab
sampling and composite  sampling (See  Sections  2, 3,  and 5   for  specific
applications).    A  grab  sample  is taken  over a short  period  of  time,
                                   1-3

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generally  less  than 15 minutes.   Grab sampling  is  used  to  characterize  a
waste  or  waste stream  at  a  given time.   Grab  sampling  is  frequently
employed  for  hazardous substance site  investigations.
     A composite  sample is  a  combination of individual  samples taken over
a prolonged period  of  time  at the same  sampling  point.   This  technique  is
not  frequently  used in hazardous site investigations; however,  a  modifi-
cation  of composite  sampling may  be  used  in  certain  instances.    This
modification  involves  combining  samples  taken at  different  locations
(pond, lagoon,  etc.)  into one sample.    This provides a  sample composited
by  location  rather  than time and may  provide  useful data  on  the  average
concentration of contaminants  or  the  presence  or  absence of  hazardous
substances in the area.

1.5  THE  SAMPLING PLAN
     As  part  of  the work plan  for a  field  investigation  that  involves
sampling,  a sampling plan should be developed  that  includes the types- and
number of samples  to  be taken  and the  potential  locations   of  sampling
points.   It   is  recommended that a brief rationale be  written for  each
selected  type of sample  and  sampling  point  chosen.   This process  will
help focus the  sample  selection  on the  objective of the  field investiga-
tion and will help  investigators select those points likely to  be  repre-
sentative  of  hazardous  conditions.  The  importance of  using all  back-
ground information  available  to assist  in the development  of the  plan
cannot be  stressed  enough.
     The sampling plan  should address, but  not necessarily  be  limited to,
the following elements:

     (1)   Team organization.

     (2)    Degree  of protective  clothing  and  equipment  required.   Deter-
          mined  by  the  potential  for exposure  and the hazardous  nature of
          the suspected contaminants.

     (3)   Number of samples  to be taken.   In  general,  a small number of
          samples  is   required   to   establish  contaminant  concentration
          ranges.   Other factors  affecting  the number of  samples required
          include the  area  of the  site  and  sampling  goals.    Table 1-1
                                   1-4

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          provides  some  guidelines  for  onsite  sample numbers.   Average
          concentrations are sufficient for enforcement cases, while con-
          centration ranges are necessary for remedial work.

     (4)  Selection  of  background sampling points.   Sampling points be-
          yond the limits of site contamination, e.g., upwind ambient air
          samples or  upstream  surface water  samples, should  be identi-
          fied.  This is essential in enforcement cases in order to docu-
          ment environmental quality  in  the  immediate vicinity  that  has
          not been affected by contaminants on the site.

     (5)  Sampling containers,   preservation techniques,  sample obtain-
          ing equipment  and  field measurement devices.   See  Sections  2,
          3, and 5.

     (6)  Sample documentation.  The sample tags, chain-of-custody  forms,
          field logbooks and photographic equipment necessary to document
          the  sampling  process  should  be prepared.   Also,  preparation
          should be made to  split samples  with  site/facility representa-
          tives if required.

     (7)  Analytical  support.   The  analyses  which will  be requested for
          the samples, based on background information, should be identi-
          fied, and the laboratory facilities which will  receive the sam-
          ples should be notified.

     (8)  Quality control.   The  sampling  points  where duplicate samples
          will be  taken for  quality  control  should  be   identified,  and
          field blanks should be prepared.

     (9)  Sample packaging and shipping.   See Section 6.

1.6  DATA ANALYSIS
     The evaluation of analytical data generated from  sampling operations
during field investigations requires the integration of a  variety of fac-
tors which may influence the validity or value of the  data.
                                   1-5

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                                      TABLE  1-1

                  NUMBER OF  SAMPLES  TO  BE COLLECTED (MERL,  1980)
Case
 No.
Information
  Desired
 Waste
 Type
Container
  Type
Number of Samples
 To Be Collected
  9


 10
         Average
         Concentration
         Average
         Concentration
         Average
         Concentrat ion
         Average
         Concentration
         Average
         Concentration
         Concentration
         Range
         Concentration
         Range
         Concentration
         Range
Concentration
Range

Concentrat ion
Range
                  Liquid
                  Liquid
                  Solid
                  (powder or
                  granular)

                  Waste
                  pile

                  Soil
                  Liquid
                  Liquid
 Solid
(powder or
 granular)

 Waste
 pile

 Soil
                Drum,  vacuum truck
                and similar con-
                tainers

                Pond,  pit,  lagoon
                  1 combined sample
                  of several samples
                  collected at dif-
                  ferent sampling
                  points or levels
                Bag,  drum,  bin,  sack   Same as Case
                                                                  Same as Case #2
                  1 combined sample
                  of several samples
                  collected at dif-
                  erent sampling
                  areas

                  3 to 10 separate
                  samples, each fron
                  a different depth
                  of the  liquid

                  3 to 20 separate
                  samples from
                  different sampling
                  points and depths

                  3 to 5 samples
                  from different
                  sampling points

                  Same as Case #8
                Drum, vacuum,
                truck, storage
                tank
                Ponds,  pit, lagoon
                                  Bag,  drum,  bin
                  3 to 20 separate
                  samples from dif-
                  ferent sampling
 11      Average Con-       All
         centration  for     Types
         legal evidence
 12      Average           Liquid
         Concentration

 13      Average           Liquid
         Concentration
                                 All  containers
                                  Storage  tank


                                  Storage  tank
                                       3 identical
                                       samples or 1
                                       combined sample
                                       divided into 3
                                       identical samples
                                       if homogeneous

                                       Same as Case #6
                                       Same as Case #6
                                         1-6

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     The internal quality  control  standards utilized by  laboratories in
monitoring  their  analyses  are  beyond  the  scope  of  field  investigation
personnel function and is  therefore  not  addressed  here.   However, assum-
ing that the data is sound  from an analytical point of view, field inves-
tigation personnel  are  tasked to  assimilate this  data  with all  of the
other information available about a site in order to determine the status
of a  site.   Suggested  factors to  be  considered in data  analysis should
include, but not be limited to, the following:

     (1)  The date of analysis  should  be compared with the  date  of  sam-
          pling.  Degradation of  chemical  contaminants   in  samples   over
          time has been documented.

     (2)  Duplicate/blank sample results should be examined to help  iden-
          tify contamination  problems with  sampling  technique  and equip-
          ment including  sample containers.

     (3)  If samples have been  split and  analyzed  by  two  different  labs,
          the resulting  data should be  compared.

     (4)  Background data  taken  from  upwind,  upstream,  or  upgradient
          should be examined  carefully to  establish  identity  and  concen-
          trations of contaminants  in the  environment  prior  to  contact
          with the site.

     (5)  Comparison of  on-site  concentrations to  downwind,  downstream,
          and down-gradient  off-site  concentrations should  be  used  with
          available  topographical,  geohydrological  and  meteorological
          data to link  on-site substances to off-site contamination.

     (6)  Evaluate  sample  handling  procedures  for proper  preservation
          techniques, e.g., acidification of samples for metal analysis.

     (7)  Evaluate climatic  factors  at  sampling time.   A wide variety of
          factors such  as temperature,  rainfall, wind direction and  velo-
          city  affect the  concentrations of contaminants.   Variation  in
          these conditions  can produce variation in actual concentrations
          found.
                                   1-7

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(8)   If trace quantities of  contaminants  are  found  in a sample, the
     sampling point should be evaluated in terms of the physical and
     chemical properties  of that  contaminant.   For  example,  if  a
     surface sample from a lagoon shows trace heavy metal concentra-
     tions, the conclusion would be that higher concentrations might
     be found if  a greater  depth  is  chosen  for the  sampling point
     because of low water solubility of heavy metals.

(9)   Careful examination of  field  data  measurements  relative  to the
     sampling points and analytical results can provide key informa-
     tion about contaminant  plume migration.

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                         REFERENCES - SECTION 1
Environmental  Response  Team,  1980.    Field  Monitoring  and Analysis  of
Hazardous Materials.   EPA  Training Manual,  Course #165.4,  Cincinnati,
Ohio.
Environmental Protection  Agency,  1973.   Handbook for  Monitoring Indus-
trial Wastewater.  U.S.  EPA Technology Transfer.


Environmental Protection Agency, 1974.  Methods  for  Chemical  Analysis of
Water and Wastewater.  U.S. EPA Technology Transfer.


Environmental Protection  Agency.   Handbook  for Analytical Quality  Con-
trol in Water and Wastewater Laboratories.  U.S. EPA-600/4-79-019.
Environmental Protection  Agency,  1977.   Procedures  Manual  for  Ground-
water Monitoring at Solid Waste Disposal Facilities.   EPA/530/SW-611.
Huibregtse, K.  R. ,  and Moser, J.  H. ,  1976.   Handbook for  Sampling  and
Sample Preservation of Water and Wastewater.  U.S.  EPA-600/4-76-049.


Municipal  Environmental  Research  Laboratory,  1980.   Samplers  and  Sam-
pling Procedures  for  Hazardous  Waste  Streams.   Environmental  Protection
Agency, Cincinnati, Ohio.   EPA-600/280-018.


National Enforcement Investigations Center,  1980.  Enforcement Considera-
tions for  Evaluations  of  Uncontrolled  Hazardous Waste  Sites  by Contrac-
tors .  EPA Office of Enforcement, Denver, Colorado.


Olson,  D.  M. ,  Berg,   E.  L. ,   Christensen,  R. ,  Otto,  H. ,   Ciancia,  J.,
Bryant, G., Lair, M.D., Birch, M., Keffer,  W.,  Dahl ,  T.,  and Wehner,  T. ,
1977.  Compliance Sampling Manual.  Enforcement Division,  Office of Water
Enforcement,  Compliance Branch.
Weber, C. I., 1973.   Biological  Field  and  Laboratory Methods for Measur-
ing the Quality of Surface Waters and Effluents.  U.S. EPA-670/4-73-001.
                                   1-9

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                         REFERENCES - SECTION 3
Municipal Environmental  Research Laboratory,
pling Procedures for  Hazardous  Waste  Streams.
Agency, Cincinnati, Ohio.  EPA-600/280-018.
1980.    Samplers and  Sam-
  Environmental  Protection
National Enforcement  Investigations  Center,  1980.   Enforcement  Consi-
derations for Evaluations of  Uncontrolled Hazardous  Waste  Sites by Con-
tractors .  EPA Office of Enforcement,  Denver,  Colorado.
                                   3-9

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                                SECTION 2

             WATER SAMPLING METHODS FOR FIELD INVESTIGATIONS

2.1  GENERAL
     The sampling and analysis of surface water and groundwater are major
focal points for a large number of field investigations of hazardous sub-
stance sites.  In some cases, the analysis of a sample taken off-site may
be the initial indicator that  the  site  is a pollution  source.   Once the
substances associated with the site have been characterized in a prelimi-
nary  assessment  or  from analysis  of  samples taken  on-site  (See Section
5), surface water and groundwater samples may be necessary to help estab-
lish the existence and extent  of  contaminant  migration.   Such data helps
investigators  identify populations  at  risk  and  determine  appropriate
remedial actions.
     Surface water and  groundwater samples are  usually  considered  envi-
ronmental samples, as  defined  in  Section  1.   There  are  instances,  how-
ever, when surface water and groundwater  samples  may be more highly con-
centrated, even to the degree  that  they  may be considered hazardous sam-
ples.  The site entry team leader or project manager must decide how such
samples should be handled.   Visual  indicators  of high concentrations in-
clude coloration,  turbidity,  odor, multiphasic  layering  and spontaneous
formation of  precipitates.   Field instruments  should  also be  used for
this evaluation.

2.2  CONTAINERS,  CLEANING OF CONTAINERS AND SAMPLE PRESERVATION
     For surface water and groundwater samples, the same  containers, con-
tainer cleaning and preservation methods are employed.  The chemical con-
stituent  for  which  the  samples  will be  analyzed determines  the method
used.  Ideally,  background  information  will limit analytical requests  to
a  few chemicals or chemical groups.
     In  the  absence  of  such  information,  the  most  commonly  requested
analyses are  for  the  substances  on the  Environmental Protection  Agency's
Priority  Pollutant  list.    This   list  includes 129  substances  which are
                                   2-1

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used  in a wide  range  of  industrial  applications  and  whose  presence  in the
environment  has been linked  to  health-related  effects and overall  water
quality deterioration.   Of the  total,  30  are classified  as  purgeable  or
volatile organic  compounds, which  are  removed from a water sample by bub-
bling  an  inert  gas   through  the sample;  83  are  classified  as  extract-
able  organic  compounds,  which are  removed  from a water  sample  by the use
of  an organic  solvent   (this  includes 47 base/neutral  extractables,  11
acid  extractables,  and  26  pesticides/PCB1s);  13  are metallic  elements;
and two are  "miscellaneous" —total  cyanides  and  asbestos. A list  of the
priority pollutants  and  the EPA approved  analytical  methods  are  found  in
the Federal  Register, Vol.  44,  No.   233, Monday,  Dec.  3,  1979.    Other
analyses may  be requested  as  site-specific information becomes  available.
The priority  pollutants  typically  are  also analyzed  for  in soil,  sediment
and hazardous  samples.
      Table  2-1  specifies  the recommended  type  and  size  of  containers,
number of containers, sample  volumes,  container  cleaning,  and sample pre-
servation  and  holding time  for  the analytical  needs for most  hazardous
substance site  investigations.  The  specifications listed  are recommended
by  the EPA  National Enforcement   Investigations  Center  (NEIC,   1980).
Where  no  specific container  cleaning   instructions  are  listed, the  con-
tainers  should  at  a minimum  be washed with detergent  and  rinsed  with
copious amounts of distilled  water.
      It  is  important to  determine  the  limitations of  the  analytical
laboratory to  which  samples  are  being  shipped.  The  laboratory  should  be
aware  of the  bottle  preparation  procedures,   preservatives used, and  data
on  how the  sample  was   collected.    (The analytical  laboratory  chosen
should also be  able  to provide further guidance  on container  cleaning.)
     The types  of analyses  listed  in  Table  2-1  include  those which  are
most  likely  to  be  requested   during an investigation of  an  uncontrolled
hazardous substance  site.   If background information indicates  that other
analyses may  be needed,  the nearest regulatory agency  laboratory of con-
cern  should be  consulted.  Also, the holding  times are merely guidelines.
The samples  should  be conveyed  to  the  analytical  laboratory as soon  as
possible,   especially if they are   necessary  evidence  to support   legal
action on the site.
                                    2-2

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                                                                       2-1



                                                        RECOMMENDED SAMPLE  HANDLING
TYPE OE
ANALYSIS
Purge able
(Volatile)
Ortjanics
Extract able
Organics, PCB,
Pesticides
Metals
Cyanides
Total Organic
Carbon
Ammonia
Fluoride
Sulfide
TYPE AND SIZE
OF CONTAINER
40 ml glass
vial, Teflon-
backed septum
One-half gallon
bottles with
Teflon-lined caps
1 liter poly-
ethylene bottle
with polyethylene-
lined cape
1 liter poly-
ethylene bottle
with polyethylene-
lined caps
500 ml polyethylene
bottle
500 ml polyethylene
bottle
500 ml polyethylene
bottle
1 liter poly-
ethylene bottle
NUMBER OF CONTAINERS
AND SAMPLE VOLUME
(PER SAMPLE)
Two; vials filled
completely, no air
space
Two; total volume
approx. 1 gallon;
Fill bottles 5/6
full
One; bottle is
filled 7/8 full
One; bottle is
filled 7/8 full
One; bottle is
filled 7/8 full
One; bottle is
filled 7/8 full
One; bottle is
filled 7/8 full
One; bottle is
filled 7/8 full
CONTAINER CLEANING
Bottles and septa
washed with deter-
gent, rinsed with
organic-free water
and dried an hour
at 1050 c
Bottles and cap
liners rinsed with
methylene chloride
and dried by vacuum
or other aafe means
until no solvent
remains
Bottles are rinsed
with dilute nitric
acid and washed well
with distilled or
deionized water
»
*
*
*
*
PRESERVATION
Cool to 40 c
(ice in cooler)
Cool to 4° c
(ice in cooler)
Nitric acid to
below pH of 2
(approx. 1 .5 ml
Con HN03
per liter)
Sodium hydroxide
to pH 12 and
cool to 4° Q
(ice in cooler)
Sulfuric acid to
pH below 2 and
cool to 40p
(ice in cooler)
Sulfuric acid to
pH below 2 and
cool to 4o c
(ice in cooler)
Cool to 4o c
(ice in cooler)
0.04S zinc
acetate
MAXIMUM HOLDING
TIME
14 Days
Must be extracted
within 7 days
6 Months
24 Hours
7 Days
Unstable
7 Days
7 Days
•No specific instructions.  At a minimum,  wash  containers with detergent and rinse with distilled water.

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2.3  SURFACE WATER SAMPLING
2.3.1  Sampling Locations
     Surface water  sampling  locations  are selected on  the  basis of  the
probability they will  show contaminants migrating from a site.   Prior  to
sampling, the surface  water  drainage  in and  around  a site  should  be  char-
acterized  using all  available  background  information,  including  topo-
graphic maps and river basin studies.  Air photos may be used  to develop
drainage maps which  can then be  confirmed  by initial  survey of  the  sur-
face water adjacent  to or  on a  site.   An initial  survey  of  potential  sam-
pling  points  is essential  to the development of  a  sampling plan.   Fur-
ther,  it  is possible   to  anticipate  any  special  equipment or  personnel
safety  requirements  which  might be necessitated by  terrain  or  other  fac-
tors.   The  initial  survey  also allows field personnel  to  identify  land-
marks  which  locate  sampling  points—a crucial  step in  maintaining  docu-
mentation of activities for legal actions.
     In  general,  sampling  locations  would include  rivers,  brooks  or
streams running through or adjacent  to  a  site,  including  those  bodies  of
water  which may receive surface runoff  or  leachate  from a  site.   Discre-
tion is  advised in  sampling  leachate  breakouts, which may  have  high  con-
centrations of  contaminants.
     Leachate  is  formed by the mixing of rain water with wastes buried in
the  ground.  The  leachate  may then enter groundwater,  where it may remain
below  the ground's  surface.   In  areas where  the  ground  surface slopes
steeply  away  from  the  buried  wastes,  the   leachate may  "break  out"  or
emerge on  the  ground surface.  This is referred to as a leachate breakout
and  is typically encountered at landfills.  Samples  taken  from  leachate
streams  may have to  be treated  as  medium or high  concentration samples
depending  upon  a  field evaluation.
     Other  surface  water  sampling locations would include  any  adjacent
standing  bodies of  water  such as ponds,  lakes  or  swamps which  might  be
receiving  contaminants.  (Again, care must be taken in judging the nature
of samples  taken  from on-site surface  impoundments  if high concentrations
are  indicated. )
     It  is  also essential  to establish the  quality  of  water prior to  its
contact  with  the  site.   Surface drainage  patterns should  be  carefully
studied  to determine   background  sampling  locations.   A minimum of  one
                                    2-4

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upstream  sample  is required  for streams,  although a  background  sample
should be  taken  from  each upstream  surface water  source.   For  standing
bodies of water,  a background sample may be obtained from a similar water
body away from the suspected point-source discharge.
     The number of  sampling  locations  is dependent  on  a variety of  fac-
tors, including the size  of  a site, the  availability  of analytical  sup-
port, and  the objectives of  the investigation.   A recommended  absolute
minimum  would be   two   locations,   including   one   background   location.
Ideally,  additional   locations  should  be   sampled,  with  some   locations
selected  for  taking a duplicate sample, which  improves  the quality  con-
trol of the analytical data.

2.3.2  Field Measurements and Observations
     While  sampling points  are  being  located,  several  quick  field  mea-
surements  and  observations  should  be  made  to  help in  interpreting  the
analytical  data.   The following  are suggested  field  measurements which
should be noted in the sampler's field logbook:

     (1)  Water temperature at point and time of sampling.

     (2)  pH of water  sampled.  This measurement is  made using  a  pH meter
          or indicator paper in a separate  sample collected for  this  pur-
          pose.  Do not  risk contaminating  a  sample or losing  volatiles
          by immersing the pH electrode into a  sample which is  to be  sent
          out for analysis.

     (3)  Dissolved oxygen content of water sampled.  Use a portable  dis-
          solved oxygen meter.

     (4)  Depth of  stream or  pond  (average).   This  may  be  limited  to
          estimates,  especially  if access is restricted  to  the  shoreline.
          If using a  sounding   device,  such as a graduated pole, perform
          this after  the  samples have been  obtained.

     (5)  Velocity of stream.  This  can be  approximated  by  estimating the
          velocity of a  floating object.   Perform  this  measurement  after
          samples are obtained.
                                    2-5

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      (6)   Flow rate of stream.   Estimate  cross-sectional area from depth
           and  width of stream.   The cross-sectional area may be estimated
           by  assuming  that  it  is  a  triangle  and  using  the formula A  =
           (1/2)  BC, where:

           A =  cross-sectional  area
           B =  width of stream
           C =  depth of stream  at deepest point

           Multiply this  area  by  velocity  for a  rough  approximation  of
           flow rate.

      Some  suggested observations to record before and during the sampling
operation  include  the following:

      (1)   Overall  weather conditions  at the  time  of sampling.   Include
           air  temperature,   sky  condition,  any  recent  heavy rainfall  or
           drought   conditions  which might  affect  contaminant  migration,
           flow rates, etc.

      (2)   Observable  physical  characteristics such  as  odor,   color,  and
           turbidity.

      (3)   Stream characteristics  such  as stagnation or  mixing  which might
           affect the  distribution or volatilization  of contaminants  in
           the  water.

      (4)   Evidence  of dead vegetation  or animals.

2.3.3  Sampling  Equipment
     For  hazardous substance  site investigations,  the  equipment  needed
for  surface water  sampling  is  minimal.    In  most  instances,   the  sample
container  serves as the  sampling  device.   The  use  of  highly  sophisticated
or automatic sampling devices  is  normally  not  required  for hazardous  site
investigations.
     Table  2-2  is   a  suggested  list of  surface  water  sampling  equipment
and accessories.   Field personnel  are encouraged  to  draw upon  their  own
                                   2-6

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           TABLE 2-2





SURFACE WATER SAMPLING EQUIPMENT
EQUIPMENT
Sample containers
Sample preservatives
Coolers with ice
Field blanks
Telescoping aluminum pole with
clamp & Teflon beaker
Thermometer
Portable pH meter
Portable dissolved oxygen meter
Field logbook
Camera/film
Sample tags
Chain-of-custody records
Receipt for sample forms
Ink pen (waterproof)
USE
Appropriate to analysis desired (See
Table 2-1).
See Table 2-1.
Used for preserving, shipping samples.
One is recommended for each group of ten
samples. These are prepared for the
desired analysis in the same type of con-
tainer as the sample, and preserved and
handled in the same manner in the field.
For organics analysis, use organic-free
water. For inorganics analysis, use de-
ionized or distilled water.
Used to extend reach and depth so that wa-
ter samples can be safely taken from the
shore of a stream or pond. Rinse thorough-
ly between use to avoid contamination of
samples.
Measure water and air temperature.
Measure pH of water at time of sampling.
Measure dissolved oxygen.
Record field observations.
Document sampling activity.
Sample documentation.
              2-7

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experience and creativity  to  supplement this list.  As  a  general  precau-
tion, any newly  obtained  container or  sampling device must  be  thoroughly
cleaned prior to use  and between  sample locations  to  avoid contamination.
It is also recommended  that devices  or  containers  for  samples  for  organic
compound analysis  be fabricated  from glass,  Teflon,  or stainless  steel.
These materials  may also  be  present in  sampling  devices  used  to  obtain
samples for metals  analysis.

2.3.4  Surface Water  Sampling  Techniques
     Most samples  taken during site investigations are  grab samples  (See
Section  1).   Typically,   surface  water sampling  involves immersing  the
sample container in the body  of water;  however,  the  following  suggestions
are made to  help ensure that  the samples obtained are  representative  of
site conditions:

     (1)  The  most  representative  samples  in  a  well-mixed  stream  are
          obtained  from mid-channel  at  0.6  stream  depth.

     (2)  Stagnated  areas  or  pools  in  a stream  or  river might  contain
          zones  of  varying pollutant concentrations,  depending upon  the
          physical/chemical properties  of the contaminants and  the  posi-
          tion of these stagnated areas relative  to  the  site.

     (3)  Even though  the  containers used to obtain the samples are  pre-
          viously  laboratory  cleaned,  it  is  suggested that  the  sample
          container  be  rinsed  at  least  once with  the water  to  be  sampled
          before the  sample is  taken.

     (4)  For  sampling  running  water,  the  farthest  downstream   sample
          should  be  obtained  first,  and  subsequent  samples  should  be
          taken as  one  works upstream.   This  avoids  contaminating  samples
          by raising  the  stream  turbidity  levels.   Work  from  zones  sus-
          pected of  low contamination to  zones of  high  contamination.

     (5)  To sample  a  pond or other standing  body of water, the  surface
          area may  be divided  into grids.  A  series  of'samples  taken  from
          each grid is combined  into  one  sample, or  several  grids  are
          selected  at random.
                                   2-8

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     (6)  Care should be  taken  to  avoid  excessive agitation of  the water
          since this results in the loss of volatile constituents.

     (7)  When obtaining  samples  in 40 ml  septum vials  for volatile  or-
          ganics analysis,  it  is  important  to exclude  any  air space  in
          the  top  of the  bottle  and  to  be  sure that  the  Teflon liner
          faces in after the bottle is filled  and capped.  The  bottle  can
          be turned upside down to check for  air  bubbles.

     (8)  Do not sample at  the  surface,  unless sampling specifically  for
          a  known  constituent  which  is  immiscible  and  on  top  of   the
          water.   Instead,  the  sample  container should be inverted, low-
          ered to  the  approximate depth,  and held at  about  a  45-degree
          angle with the mouth of the bottle  facing upstream.

2.4  GROUNDWATER SAMPLING
2.4.1  Sampling Locations
     Groundwater  sampling  locations  are  determined  by  the  location   of
existing wells.  It  is  important  that the  installation  of any  new wells
be under the direction of an experienced hydrogeologist.
     The  obvious  groundwater  sampling  locations  are  those   monitoring
wells,  residential  wells,  and  industrial  wells which are  adjacent to  a
site.  Many  landfills typically have  monitoring wells in place, and most
residences in rural areas lacking municipal water supplies have their  own
wells.   In  urban  areas,  many  industries  whose  processes  require large
amounts of water have their own production wells, and  many municipalities
rely  upon  large  production wells.   Additionally,  monitoring   wells have
been  installed in  areas  where  routine  tests  showed  contamination   of
municipal  or  industrial  production wells,  or where an aquifer  was being
evaluated  for  future water  supply  development.  Once  again, the need  for
an exhaustive  background  information  search  is stressed.  The  background
search helps identify wells near a site and can provide  information about
the depth, diameter and use of  the wells.
     Existing  monitoring wells  should  be sampled and  analyzed  first.
This will establish the nature  of  any  contaminants  in  the  groundwater  and
assist  in determining the need  for additional well  sampling.   If analyti-
                                    2-9

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cal data  for  the  monitoring wells  already  exists,  this should be  evalu-
ated with  the other site-specific  information  to determine the  need  for
sampling  private  wells  farther  away from  the  site.   Existing  data  may
also enable  the investigative team  to  key  on a  particular type  of  con-
taminant,  and  thus  the  amount   of  analytical  support required can  be
reduced.
     Before monitoring wells at  a hazardous  substance site are  sampled,
the placement  of  each  well  should  be  carefully  evaluated   for  its  poten-
tial of  producing  a highly  concentrated  sample.   Such  samples  require
attention to  personnel  protection and may require the  use  of  respirators.
Also,  it  may  be necessary  to ship  concentrated  samples  to a  laboratory
capable of handling  hazardous  samples.
     It  is  important to  locate  a well  or wells  to provide a  background
(upgradient)  groundwater sample.    This  may  be   accomplished by  studying
available hydrological  data about the direction  of  groundwater flow  near
a site, but may require  the use  of  geophysical techniques  and  the instal-
lation of additional monitoring  wells.

2.4.2  Field Measurements and  Observations
     The  following  field measurements  and  observations may prove  useful
in preparing  to  sample and  in interpreting  the  data  from  the  subsequent
analyses.

     (1)  It  should  be  noted  if monitoring wells  are locked.    Arrange-
          ments must be  made to   secure keys or  to remove   locks  by  other
          means and  re-secure  the wells.

     (2)  The  diameter of  the wells should  be   noted to   ensure that  a
          bailer of  the  proper size will be  available.  The diameter  is
          also necessary  for  calculating  the wells'  static  water  volume.

     (3)   The  type of  casing material  should  be   noted, i.e., PVC,  steel,
          etc .

     (4)   For municipal or  industrial production  wells, information  would
          be  obtained  about the  pumping  rates,   static  level,  and  total
          well  depth.    Such  information is  usually  available   from  the
          facility management.
                                  2-10

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(5)  For drilled or dug residential wells,  little  or  no information
     may be available, but an attempt  should  be  made  to obtain what
     information there is.

(6)  The overall weather  conditions  at the time of  sampling should
     be  noted,   including  air  temperature,  sky condition,  recent
     heavy rainfall or  drought  conditions  which might  affect  con-
     taminant migration,  etc.

(7)  Note any observable  physical  characteristics of the groundwater
     as it is being sampled,  e.g., color,  odor, turbidity.

(8)  The  elevation  of the  well  casing  should  be  determined  from
     background  information or  by field personnel.   If there  is a
     sufficient amount of  well data,  it may be possible to construct
     a groundwater contour map.   If the construction/use of the well
     permits, the static  water level  of each well should be measured
     prior to sampling.    This  is  best accomplished with  the use of
     an  electronic  water  level  indicator.    Similarly,   the  total
     depth of  the  well   should  be  determined  prior   to  sampling.
     These measurements  should be  obtained  whether  or  not  well logs
     are available since  the measurements  are required  in calculat-
     ing the  static water  volume of the well.

(9)  Any observations about well-casing  integrity  (e.g., difficulty
     lowering bailer because of bent  casing)  or  disparities between
     existing  well  logs   and  current  field measurements  should be
     noted in a  field logbook.

(10) The  temperature  of the  water should be  measured  and  recorded,
     both at  the time of  initial purging of the well and at  the time
     of sampling.  Groundwater  temperatures are  an indicator of  the
     degree of contamination.   In addition, the  pH and  specific con-
     ductivity of  the groundwater  being  sampled  should be measured.
     (Because  of possible contamination  problems,  measurements  of
     temperature, pH and  specific conductivity should be carried  out
     on a portion  of  groundwater  which is  not in a sample  container
     to be sent  out for analysis.)
                             2-11

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     (11) If  the  monitoring wells or production wells being  sampled  have
          been  shown  to  be  part  of  the  same  aquifer  which  is  being  pumped
          by  other production  wells,   this  fact  should be  noted  at  the
          time  of  sampling.

     (12) Any  surface water bodies  which  have been  shown  to be,  or  are
          suspected  to be,  hydraulically  connected  with the wells  being
          sampled  should be sampled  at  the same  time.

2.4.3  Groundwater Sampling Equipment
     Table 2-3  is  a  list of groundwater sampling equipment which  is  sug-
gested  for  sampling  operations.   The  use of more  sophisticated  methods
and/or  sampling equipment is beyond the scope of  typical  site  investiga-
tions and is  not  addressed  here.   It is recommended  that the  equipment be
kept to a minimum, since the access  to  many  wells  may be difficult.

2.4.4  Groundwater Sampling Techniques
     Because  most  site  investigations  involve sampling groundwater  from
monitoring wells,  the following is  an  outline of  suggested procedures to
be  used for  monitoring  well  sampling.  Suggested  procedures  for  other
types of wells  follow this  section.
     For purposes  of  reference,  the sampling of a monitoring well  may be
divided into  three parts: (1) measurement  of well  volume and  water  level,
(2) evacuation  of  static water,  and  (3) obtaining  the sample.

Measurement of  Well Volume  and Water Level

     (1)  Measure  or  otherwise  determine well-casing diameter.

     (2)  Determine  static  water  level.   (Express  as  feet  below  ground
          surface  or  below casing  elevation, depending  on  information
          available.)  The water  level  indicator must  be  cleaned  before
          use in the  next well.

     (3)  Determine depth of  the  well.
                                  2-12

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               TABLE 2-3




SUGGESTED GROUNDWATER SAMPLING EQUIPMENT
EQUIPMENT
Sample Containers
Sample Preservatives
Field Blanks
Keys
Pipe wrenches
Propane torch
Hammer and cold chisel
Tape measure
Electronic water level indicator/
graduated depth sounder
Pocket calculator
Pump
Wei 1 bailer
USE
Appropriate to analyses desired (See
Table 2-1).
See Table 2-1.
See Table 2-2.
For locked monitoring wells.
May be necessary to remove steel security
caps on wells which have not been recently
opened and sampled.
Use to measure diameter of well casing
above ground level.
Used to determine static water level and
total depth of well.
Use for static water volume calculations.
Use to purge or evacuate well prior to
obtaining sample; it is not a recommended
means to obtain a sample. (Section 2.4.4
further qualifies the use of a pump in
groundwater sampling.)
A bailer is a device which is lowered into
a well to obtain water samples. Bailers
are typically 1 to 2 feet long and 0.75 to
2 inches in diameter. Several lengths and
diameters should be available to accommo-
date a variety of well diameters. Use to
obtain groundwater samples. Recommended
material for construction includes stain-
less steel with Teflon ball valve or all-
Teflon construction. Other materials such
as PVC or copper are not recommended be-
cause they may be difficult to decontamin-
ate thoroughly and can cause sample con-
tamination.
                  2-13

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TABLE 2-3 (cont'd)
EQUIPMENT
Monofilament line
Decontamination solutions/water
Plastic pails, graduated
Thermometer
Portable pH meter
Portable specific conductivity
meter
Field logbook
Camera/film
Sample tags
Chain-of-custody records
Receipt for sample forms
Waterproof ink pen
USE
Use for lowering bailer into well; should
be of sufficient strength to hold full
bailer and overcome any resistance between
well casing and bailer. The use of any
other type of line is not recommended.
Steel wire might be an appropriate substi-
tute but can cause handling problems for
personnel wearing gloves.
Use for decontaminating bailer and water
level indicator between wells.
Use for measuring volume of water taken
from well prior to sampling.
Use to measure temperature of groundwater.
Use to measure pH of groundwater.
Used to measure specific conductivity of
groundwater.
Used to record field observations.
Use to document sampling procedure.
   2-14

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     (4)  Calculate the number of linear feet of  static water  (difference
          between static water level and total depth  of well).

     (5)  Calculate the static volume  (or use a previously  prepared  table
          or  graph).   An easily  remembered formula  for  calculating  the
          static volume is:
                            V = Tr2(0.163)
          Where:  V = Static volume of well in gallons.
                  T = Thickness of water table in  the well measured  in
                      feet, i.e., linear feet of static water.
                  r = Inside radius of well casing  in inches.
              0.163 = A  constant  conversion factor which compensates  for
                      the  conversion  of  the casing radius from  inches  to
                      feet, the conversion  of  cubic feet to gallons,  and
                      pi.

Evacuation of Static Water (Purging)
     Before  a  groundwater sample is  obtained,  the  static  water must  be
evacuated  (purged).   This process  ensures  that  the sample subsequently
obtained is representative of the groundwater quality.  There  are  several
schools  of  thought  about  the  amount  of  water to  be  purged  and  how  to
gauge this.  An  absolute minimum of  five  times  the well's  static  volume
is  recommended  for  legal  cases  (EPA, 1977).   Another  suggestion  is  to
measure  the specific conductivity of  the  water  as  it is  being  purged  and
to  take  the sample when  two successive readings are the  same.
     The method  used  to purge  the  well  is dependent  upon  the  equipment
available and the accessibility  of  the well.   A  variety  of pumps  may be
used, including  hand-operated  or  motor-driven  suction pumps,  peristaltic
pumps, or compressed-gas-driven  pumps.   If the  pump being  used does  not
have a  flow  meter,  a  graduated  plastic pail is  a convenient way  to mea-
sure the total  volume  discharged.   Regardless of  the  type  of  pump used,
the  sample should not  be obtained from the pump  used  to purge  the well,
and  any hose coming in contact with  the well water must  be  decontaminated
before use in the next well to avoid  the  possibility of  sample contamina-
t ion.
                                   2-15

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     In many  cases,  the method  used  to purge  the  well is hand  bailing.
This may be necessitated by  accessibility,  depth  to water,  well  diameter,
etc.  In addition, for wells  which  are  slow to  recharge,  it may  be  neces-
sary to  return several  hours or  even  a  day  later  to discharge  a  suf-
ficient volume and to obtain a sample.
     The water  removed from  a  hazardous  substance site monitoring  well
during the purging process could contain  hazardous  materials  in  relative-
ly high concentrations.   As  a result,  the water should be containerized
and not discharged  on the ground.   Once a  sample  has been  removed  from
the well, the water can be  carefully poured back into  the  well  if  it  has
not been contaminated by purging.

Obtaining the Sample
     (1)  If  a pump has  been used  to purge  the well,  the  hose  should  be
          removed and a bailer used to  obtain  the sample.

     (2)  If  a bailer has  been  used to  purge the well,  it  is recommended
          that a  previously cleaned second  bailer  be used to obtain  the
          sample.

     (3)  When transferring  the  water  from the bailer  to  the sample  con-
          tainers, care should be  used  to  avoid  agitation,  which  promotes
          the loss of volatile constituents.

     (4)  Bailers  should  be cleaned  between  wells  by  rinsing  with  a
          water-miscible  organic  solvent,  such  as  methanol  or  acetone,
          followed by  copious distilled  water.   Care must  be   taken  to
          remove all possible traces of  the  organic solvent to avoid  con-
          tamination and interference problems.

     (5)  The monofilament  line  or steel  wire used  to  lower  bailers  into
          the well should  be discarded,  and  a new length  used   for  each
          well.

     (6)  If the water is being  drawn for  evidentiary purposes,  the final
          decontamination  rinse  water  should be  sampled  and  analyzed  if
          any chance  of cross-contamination  is  suspected.
                                  2-16

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2.4.5  Sampling Techniques for Other Wells
     Where  it  becomes necessary  to  sample a  well other  than a  typical
monitoring well, the  following recommendations  are made:

     (1)  For a domestic  well,  the cold water  should  be run  for  several
          minutes prior to obtaining the  sample.   The  use of  any  type  of
          water conditioning  equipment  should be  noted.   Such equipment
          would necessitate sampling at a point before the well water has
          passed through the conditioning equipment.

     (2)  For production  wells,  it should be  established  whether or not
          the well has  been  in operation prior  to  the sampling  time and
          whether any  filtration  equipment is  installed  before  the  sam-
          pling point.

     (3)  At some hazardous substance sites, special multi-level  monitor-
          ing wells have been installed which  require  the use  of  specific
          kinds of equipment.  In  this instance, the firm which installed
          the wells should be consulted prior  to the sampling  operation.
                                  2-17

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                          REFERENCES -  SECTION  2
Environmental  Response  Team,  1980.   Field  Monitoring  and  Analysis  of
Hazardous  Materials.   EPA  Training  Manual,  Course  #165.4,  Cincinnati,
Ohio.


Environmental  Protection Agency,  1973.   Handbook  for  Monitoring Indus-
trial Wastewater.   U.S.  EPA  Technology  Transfer.


Environmental  Protection Agency,  1974.   Methods for Chemical Analysis of
Water and Wastewater.   U.S.  EPA  Technology  Transfer.


Environmental  Protection Agency.   Handbook  for Analytical  Quality  Con-
trol in Water  and Wastewater  Laboratories.   U.S. EPA-600/4-79-019.
Environmental  Protection  Agency,  1977.   Procedures  Manual  for  Ground
Water Monitoring  at  Solid  Waste  Disposal Facilities.  EPA/530/SW-611.


Huibregtse,  K.  R.,   and  Moser,  J.  H. ,  1976.   Handbook  for  Sampling  and
Sample Preservation  of Water  and Wastewater.  U.S.  EPA-600/4-76-049.
Municipal  Environmental  Research  Laboratory,  1980.    Samplers  and Sam-
pling Procedures  for Hazardous Waste  Streams.   Environmental Protection
Agency, Cincinnati,  Ohio.   EPA-600/280-018.


National  Enforcement  Investigations  Center,  1980.    Enforcement   Consi-
derations  for Evaluations  of	Uncontrolled  Hazardous Waste  Sites  by
Contractors.  EPA Office  of Enforcement, Denver, Colorado.
Olson,  D.   M. ,  Berg,  E.   L. ,  Christensen,  R. ,  Otto,  H. ,   Ciancia,  J.,
Bryant, G., Lair, M.D.,  Birch,  M.,  Keffer, W.,  Dahl, T.,  and Wehner, T.,
1977.  Compliance Sampling Manual.  Enforcement Division, Office of Water
Enforcement, Compliance Branch.


Weber, C.  I.,  1973.   Biological Field and Laboratory Methods for Measur-
ing the Quality of Surface Waters and Effluents.  U.S.  EPA-670/4-73-001.
                                  2-18

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\A Halliburton Company
   Superfund
    Division
                                     OPOUZXNQ
                                     OTIDCLIKES
                                       NMfDAL
GROOND-WATER WELL SAMPLING
                                                              4.7
                                                                           5 of  15
                                                              Draft 2
                                                              All Division Activity
                                                              Ration II fit
                                                                    Paul Goldstein
                                                              Zone Project Manager
   1.0  OBJECTIVE

   Ths objective of these guidelines La to provida ganaral  reference  information
   on tha sampling of ground-watar vails.

   This guideline ia primarily eoneamad with tha eollaetion of watar samplaa
   fro* tha aaturatad zona of tha sub-aurfaca.  Evary affort must  be  aada  to
   aaaura that tha aaapla la representative of tha particular  zona of watar
   bain? samplad.

   2.0  LIMITATIONS                                                      "'  -  -••>-:

   Thaaa guidalinaa ara for information only and ara not  to tales precedence ovar
   tha requirements of projact-apacifle plans for ground-water wall sampling.

   Tha limitations of analyses of samples collected  from  walls include changes
   to tha sample from the materials that tha water contacts, praasura changes, *'
   and temperature changea.  Tha sample will only ba representative of a small
   volume of tha aquifer that is being sampled.
                                                                                 -i'
   3.0  DEFINITIONS

   None.

   4.0  GUIDELINES

   4.1  GENERAL

   The primary consideration is to obtain a representative  sample  of the ground-
   water body by guarding against mixing tha sample  with  stagnant  (standing)
   water in the well casing.  In a nonpumping well, -thera will be  little or no .
   vertical mixing of tha water, and stratification  will  occur.  Tha well water
   in the screened section will mix with the ground  water due  to  normal flow    ;
   pattame, but the well water above  the screened  section  will  remain isolated *
   and become stagnant.  Persona sampling should  realize  that  stagnant water aay
   contain foreign material inadvertently or deliberately Introduced from the
   surface, resulting in unrepresentative data and  misleading  interpretation of
   the same.                                                             "'"**•   •>•";;,
                                                                        '; '"'-  r'1'--
   To safeguard against collecting nonrepresentativ« stagnant  water in a sample,
   the  following guidelines and techniques  should be adhered to  during sample   •"'
   withdrawal:

        1 .  Aa a general rule, all monitoring 'wells should be  puap«d:' or^-ballad
            prior to withdrawing a sample.  Evacuation  of a ainimun of one

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                 voluM of wa««r la thei wall caaing and preferably tore* to  five
                 voluaea) la reeoaaended Cor a repraaentative  saapla.   In a high-
                 yielding ground-water formation and whara  thara  la no atagnant water
                 in the wall above tha aeraanad aaetlon, evacuation prior to sample
                 withdrawal la not aa critical.  However,  in  all  caaaa whara tha  mon-
                 itoring data la to ba uaad Cor enforceaent aetiona,  evacuation ia
                 recoaaanded.

             2.   For walla that can ba puapad or ballad  to drynaaa with tha  aaapling
                 equipment balng uaad, tha wall ahould ba  •vacuatad and allowad to
                 racovar prior to aaapla withdrawal.  It  tha  racovary cata ia fairly
                 rapid and tiaa allova, avaeuation of aore than ona voluaa of watar
                 ia prafarrad.

             3.   For hlgh-yialding aonitoring walla  that  cannot ba avacuatad to dry-
                 naaa, bailing without prapuaplng  tha wall la not racoaaandad;  thara
                 la no abaoluta aafaguard againat  contaminating tha aaapla with stag-
                 nant watar.  Tha following procaduraa  ahould ba  uaad:

                 a.  Tha inlat Una of tha aaapling  puap  ahould ba placad juat balow
                     tha aurfaca of tha wall watar and  thraa  to fiva. voluaaa of watar
                     puapad at a rata equal  to  tha wall1a  racovary rata.  Thia pro-
                     vidaa raaaonabla aaauranca  that all  atagnant watar haa baan
                     avacuatad and that tha  aaapla will  ba rapraaantativa of tha
                     ground-watar body at  that  tiaa.  Tha  aaapla  can than ba col-
                     lactad diractly  froa  tha puap dlacharga  Una.

                 b.  Tha inlat Una of tha saapling  puap  (or  tha  aubaarsibla puap
                     itaalf) ahould ba placad naar tha  bottom of tha screen aaction,
                     approxiaataly ona wall  voluaa of watar ahould ba puapad at tha
                     wall1a racovary  rata  and  tha  aaapla  collactad diractly froa  tha
                     dlacharga Una.

                 A nonrapraaantativa  aaapla  can  alao raault froa axcaasiva pro-
                 pumping of tha aonitoring wall.   Stratification of tha loach*t«
                 concantrationa in tha ground-watar formation nay occur or haaviar-
                 than-watar coapounda aay  alnJc  to  tha  lowar portions of tha aquifer.
                 Excaaaiva puaping can diluta or  incraaaa  tha contaminant concan-
                 trationa froa what ia rapraaantativa  of tha  aaapling point of
                 intaraat.

        4.2   3A«PLlMGr MONITORING, AND EVACUATION  EQUIPMENT

        Saapla  containers ahould conform  to  EPA  regulationa for tha appropriate
        contaainanta, with Boat containers being  conatructed of polyethylene.

        Tha  following equipaant ahould ba  on  hand  whan  saapling ground-watar wells:

             1.   Coolers for saapla shipping  and  cooling,  chemical preservatives, and
                 appropriate packing  cartons and  filler.
NUS44I* II

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GROoiro-wtfza WELL SAMPLING
4.7
nmtt*H
0
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IffeMwOOT
Draft 2
          2.   Th«noMt«r;  pS paper/meter;  dissolved oxygea meter;  earner* end,
              film;  tags;  appropriate keys)  (for locked wells);  tap* *•«•<&»;  pip*
              wrenches,  torch.  hammer, and  chiMl;  wster-level Indicators; flow
              meter;  specific-conductivity  meter;  and depth sounder (only where
              applicable).

          3.   Pumpe

              a.   Shallow-well  pumps—Centrifugal,  pitcher, •action, or peristal-
                  tic pumps with droplinee, air-lift apparatus (compressor and
                  tubing)  where applicable.

              b.   Deep-well pumps—Submersible pump and electrical power generat-
                  ing unit  on air-lift apparatus where applicable.

          4.   Bailers and  monofilament line with tripod-pulley assembly (if  neces-
              sary) .   Bailers shall be used to obtain samples from shallow and
              deep ground-water wells.

          S.   Pails—Plastic, graduated.

          6.   Decontamination solutions—Distilled water, alconox, metHanoi.

     Sample withdrawal methods require the  use of pumps, compressed air,  bailers,
     and  samplers.  Ideally, sample withdrawal equipment should be completely
     inert; economical to  manufacture; easily cleaned, sterilized, and reused;
     able to  operate  at remote  sites in the absence of power-resources; and  capa-
     ble  of delivering variable rates for well flushing and sample collection.
     The  sample  withdrawal equipment (evacuation devices) aost commonly used is
     discussed in  Section  4.4.1 below.

     4.3   CALCULATIONS OF  WELL VOLUME

     Calculations  are to be done according to the following steps:

          1.   Obtain  all available information on well construction (casing,
              screens, etc.).

          2.   Determine well or casing diameter.

          3.   Determine static water  level (feet below ground  level).

          4.   Determine depth of well.

          5.   Calculate number of  linear feet of  static  water  (total  depth minus
              the  static water level).

          6.   Calculate static volume  In gallons  (V  • Tr2  (0.163)),  where T  is
              the  linear feet  of static water and  r is the inside  radius of  tha
              well of casing in inches.

          7.   Determine the  minimum  amount to be  evacuated before  sampling.
nus tttm is aiti

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  GROOHO-MATSR WELL SAMPLING
                                                       4.7
                                                                             8 of   15
                                                                             Draft 2
      4.4   EVACDASZOH OF STATIC WAIER (Purging)

      The  amount of flushing a well receives prior  to  sample  collection  depends  on
      tlM  intent of the Monitoring program a« well  as  the hydrogeologic  condl-
      tione.   Prograaie where overall quality determinations of  water  reaervee  are
      involved may require long pumping periods  to  obtain a sample  that  la  repre-
      sentative of a large volume of that aquifer.  The pumped  volume can be
      determined prior to sampling so that the sample  la a composite  of  a known
      volume  of the aquifer, or the well can be  pumped until  the stabilization of
      parameters such as temperature, electrical conductance, and pH  has occurred.

      However,  monitoring for defining a contaminant plume requires a representa-
      tive sample of a small volume of the aquifer.  These circumstances require
      that the well be pumped enough to remove the  stagnant water but not enough to
      induce  flow from other areas.  Generally four to six well volumes  are con-
      sidered effective, or calculations can be  made to determine,  on the basis  of
      the  aquifer parameters and well dimensions,  the  appropriate volume to remove
      prior to sampling.
     4.4.1   Evacuation Devteee

     The  devices described In this section  are  the  onee  commonly used.
     that have  been aide on a limited  scale have  been  omitted.
Others
     Table  4.7-1  provides guidance on  the  proper  evacuation device to use for
     given  sampling situations.

     Bailers

     Bailers  are  the simplest evacuation devices  used  and  have many advantages.
     They generally consist of a length of pipe,  usually with a ball check-valve
     at  the bottom.  A line is. used to lower  the  bailer and retrieve the sample.

          Advantagee
          e   only practical limitations on size and  materials
          e   no power source needed
          e   portable
          e   Inexpensive, eo It can be dedicated  and hung  In a well reducing the
              chancee of cross contamination
          e   minimal outgasslng of volatile organics while sample Is in bailor
          e   readily available

          Limitations
          e   time consuming to flush well  of  stagnant  water
          e   transfer of sample nay cause  aeration

     .Suction  Pumps

     There are many different types of suction pumps such  as centrifugal, peri-
     staltic, diaphragm,  and pitcher pumps.   Diaphragm pumps can be used for well
     evacuation at a fast pumping rate and sampling  at a low pumping rate.   The
     peristaltic  pump is  a low volume pump that uses rollers to squeeze flexible
NUS ««*• aa am

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  GROUND-HATER MELZ. SAMPLING
                                                      4.7
9 o*  15
     tubin? craatino; •nation.  TM« tubing can ba dedicated  to  a wall to prevant
     croaa contamination.  Periataltic puapa, however,  requira  a power source.
     Th« pitchar pu»p la a coaaon far* hand-puap.

          Advantage•
          •  portable,  inexpenaiva, readily availabla

          Liaitationa
          •  reatrictad to areaa with watar lavela within  20 to 25 ft of tha
             ground surface
          •  vacuua can cauaa loaa ot diaaolvad gaaaaa  and volatila organica

     Gaa-Litt Saaplara

     Thia group of saaplara Includaa thoaa that uaa  a gaa  praaaur* In tha annulua
     of tha wall to Corca tha watar out a sampling tuba and  othars which uaa tha
     gaa In a vanturi to forca tha aaapla up a tuba.

          Advantagaa
          a  portabla,  inaxpanaiva, raadily availabla
          a  good for w«ll davalopmant

          Olaadvantagaa
          a  if air la uaad, oxidation of tha aaapla may occur
          a  loaa of COj changes tha pH and oatala concantratlona will ba
             lowarad
          a  loaa of volatila compounda aay occur

     Subaaraibla Pumpa

     Thara «ra now many typaa of pumpa which can ba  conaidarad aubmaraibla;  that
     is, thay talca in watar and puah tha  aaapla  to  tha  aurfaca.  Tha powar  sourcaa
     for thaaa aaaplara may ba coapraaaad gaa or alactricity.  tha oparation prin-
     ciplaa vary.  Tha dlaplacamant of tha aaapla  can ba by  an inflatabla bladdar,
     sliding piston, gaa bubbla, or tapallar.  Induatry ia now concentrating on
     tha manufacture of davlcaa to obtain aaaplaa  in 2-In. diameter walla with
     water lavala balow 20 to 23 ft.

          Advantagea
          a  portabla and raadily availabla
          a  construction oatariala to natch parameters of Interest
          a  availabla for 2-in. diaaater wells

          Limitations
          a  may have low delivery rataa
          a  expanaiva
          a  coapreaaad gaa or electric powar  naadad
          a  sediment in water may cauaa  problaaa  with some  of  thaaa  sampler types
NUS <«•• II •<«>

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   <3«OCHD-WATM TOLL SAMPLING
                                                       4.7
10
                                                                             Draft 2
      4.5  SAMPLING

      4.5.1   Stapling Plan

      Prior to sampling, a sampling plan and a safety plan  should  ba developed  In
      consultation with tha intereatad parties and submitted  for approval.  Tha
      contents of a sampling plan conaiat of tha  following:

            1 .  Background and objectiva of sampling

            2.  Briaf araa and waata characterization

            3.  Salection of sampling location, with nap or sketch

            4.  Sampling equipment to ba uaad

            5.  Intandad numbar, volumaa, and typaa of  samples

            S.  Working achadula

            7.  Liat of taaa aembers

            3.  Liat of observers

            9.  List of contacts

           10.  Othar Information, such aa tha nacaaaity for  a  warrant,  or  permis-
                sion of antry and for split aamplaa

      4.5.2  Ganaral Sampling Rulaa

      If  tha aamplaa nuat ba filtarad, tha appropriata  ehamical preaervatives  ara
      to  ba  addad aa soon aa poaaibla.

      Racommandad aampla containera should ba uaad.

      Samplaa  of organic analysis should ba leapt  rafrigaratad or on  ica  during
      transport  to tha laboratory.

      Racomnandad holding times should ba adharad to in order to ensure  Chat con-
      stituent alteration Is olninizad.

      All  samplea will require tha usa of a bailar to maintain  tha Integrity of the
      aampla.  Sample handling, labeling, and shipping  methods  are described In
      other  guidelines of this manual.

      4.5.3  Sampling Procedure

      tha  procedure for sampling la made up of tha following  steps:

            1 .   Opan wall cap and usa dataction equipment on  tha escaping gases at
                tha wall head to determine tha need for respiratory  protection.
NUS ««•• it «i*a

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               Oalao; cleaa equipment, monad well far total depth and water level;
               then calculate tha fluid volume- In thai casing.

           2.   Determine depth to midpoint of screen or well ••etion open to
               aquifer tram casing top.  Any dry walla encountered mat be noted
               during tha field investigation.

           3.   Select appropriate purging equipment (aaa Tabla 4.7-1).  if an
               electric submersible pump with packer ia chosen, go to  step 10.

           4.   Lower purging equipment or intake into tha wall to a short distance
               below tha water level and begin water removal.  Collect or dispose
               of purged water in an acceptable manner.  Lower purging device,  aa
               required, to maintain submergence.

           5.   If pumping,  measure water level with an electric sounder in uniform
               drawdown increments of 19- to 30-second intervals.  If  balling,
               measure water levels aa needed for a good record.*

           6.   Measure rate of discharge frequently.  A bucket and stopwatch  are
               aoat commonly used; other techniques include  uaing pipe  trajectory
               methods or constructing weir boxes.

           7.   Observe peristaltic or vacuum pump intake Cor degaaaing "bubblaa."
               If bubblee are abundant and the intake ia fully submerged,  these
               devlcea may not be suitable for collecting samplea  for  volatile
               organica.

           3.   Purge a minimum of three to five casing volumaa before  sampling.
               In low permeability strata, one volume will  suffice.

           9.   While pumping, lower  intake to midacrean or  mldopen  section  depth
               and collect sample.   If bailing, lower device to sampling  level
               before filling (thia  requires other  than a "bucket-type" bailer).
               Purged water should be collected in  a designated container or  dis-
               posed in an acceptable manner.

          10.   (For pump and packer  assembly only.)  Lower  assembly  into  well ao
               that packer ia positioned  Just above  the screen or  open section and
               inflate.  Purge a volume equal to at  leaat twice  the  screen  or open
               section volume below  the packer  (whichever ia greater)  before  sam-
               pling.  Packers should alweya be tested in a  casing  section  above
               ground to determine proper  Inflation  pressures for  good sealing.

          11.   Allow the well recharge  to  tha static water  level  and then sample.
     •These data may be used to compute  aquifer transmissivity and other
      hydraulic characteristics.
NU> <«•• 11 (Id

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GROUND-MAXKR WELL SAMPLING
                                                     4.7
                                                                         12  of 15
                                                                           Draft 2
        12.  After  sampling,  monitor water level recovery (may not be appro-
             priate with a  packer/pump assembly) and decontaminate all equip-
             ment.  Make aura well is securely capped.

   The data required  from  the sampling program will determine the quantity and
   preservation needed  for  each group of constituents.  Sample preservation is
   not completed and  aay not  be possible for some parameters.  This may require
   field analysis for pH, Eh, electrical addition, refrigeration, and freezing.
   The use of preservatives retards both biological activity and the hydrolysis
   of some constituents and also reduces volatility.  A list of preservatives
   and their effects  is presented in Table 4.7-2.

   Some parameters  require  special preservation, such as eyanidee and phenols.
   Table 4.7-3 illustrates  the quantities and preservation methods for the 129
   priority pollutants  Identified by the EPA.

   The EPA has recommended  volumes of samples to be collected, container type,
   preservation methods, and  holding times for specific parameters.  Generally,
   however, the volumea  for individual constituents can be grouped and collectad
   together where the handling is the same.  These groups include the volatile
   organics (purgable organics), metals, extractabla organics, and some general
   chemistry constituents.

   4.6  DECONTAMINATION

   Decontamination  solutions  may vary according to type of contamination.  To
   decontaminate pumps  used in sampling or evacuation, two' separate  solutions
   should be prepared:  one  containing alconox and water and  the other containing
   water and oethanol.  The alconox solution should be run through the pump  and
   tubing first, and  the methanol solution should be used as a rinse.  Then  the
   pump should be rinsed with distilled water.

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   CMlng
 «JS  It
W*l«r l«
 >2i  (t

2-lnch
 <2i It
y«t«r l
 >Ji It

4-lnch
Water level
 «2b It
Hater level
 >2S It

6-Inch

Hater level
 <2S It
Hater level
 >2S It

0-lnch
Hater
 <2S It
Hater level
 >2S It
                                  T«bl« 4.7-1 .  Purging
                                                                   S«l«ctloa
               B«ll«r
F«rl«taltlc
   tump
V«cuua
 tump
                                               Airlift
Ol«pbr«ga   Suta«r«lt>l*
 •Ir*»h'     01«pki«g>
  tump         tump
(l«ctrlc
  tump
 
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    GROUND-WATER KKLZ. 3AMPL1WJ
                                                        4.7
                                                      of   15
                                                                              Draft 2
       Preservative
       Acid (HNO3)



       Acid (H2SO4)
       Alkali (NaOH)
       Refrigeration
                         Table 4.7-2.  Sample Preservation Method*
                                     Action
                                                                AppUcablility
                           3«ct«rial inhibitor
Metal* solvent,
  prevent* precipitation

Bacterial inhibitor
Salt formation with
  organic base*

Salt formation with
  volatile compounds

Bacterial inhibitor
Nitrogen fora*,  phosphorous
  form*

Metal*
Organic sample* (COO, oil
  and grease, organic
  carbon)

Aaaonla, aaine*
Cyanide*, organic acids
Acidity-alkalinity, organic
  materials, 300,  color,
  odor, organic P. organic
  N, carbon, etc.;
  biological organisms
  (coliform, etc.)
NUI««1> IS «!•»

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aaOOMD-HAXEX WLL 3AHPLUW
4.7
n^WIBA Q
'*** 15 o« 15
IftaMMl
>•» Draft 2
Tabl* 4.7-3. Sample Itoqalrementa for the 129 Priority Pollutant*
       A.   Extractabl* Organic*

           1.   Fill 1-9*1 bottl*.

           2.   Cool and aalntaln sample at 4°C.

       B.   Metal*

           1.   Pill 1-qt bottla.

           2.   Adju*t to pH of 2 with 10103.

           3.   Cool and aalntaln sample at 4°C.

       C.   Volatile Organic Analyst* (VOA or purgabl* organic*)

           1.   Pill tvo new and cleaned 40-«1 vial*.

           2.   S«al with cleaned septum and cap;  invert; tap; if air bubble*  app«ar,
               refill.

           3.   If wa*t* stream contain* residual chlorin*, collact  Civ*  vial*.
               Pr«**rv« two with either sodium biaulfata or  sodium  thioculfat*.
               Th*** vial* will b* specially narked, and the preservative  will  then
               have been added in the lab.

           4.   Wrap in waterproof packing; cool and maintain at 4°C.

       0.   All Cyanide*

           1.   Fill a 1-qt cubitainer (polyethylene bottle).

           2.   teat for chlorin* with potassium Iodide  (KI)  starch  paper.

           3.   If paper color la unchanged, go to step  5.

           4.   If paper turn* blue, add ascorbic acid until  paper  no  longer turns
               blue.

           5.   Add an additional 0.6 g ascorbic acid  (preaeaaured  In  a vial).
MUC44IB It •!•»

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                                SECTION 3

                   SOIL AND SEDIMENT SAMPLING METHODS

3.1  GENERAL
     The analysis of  soils  and  sediments  for the contaminants  present  at
a  hazardous  substance  site  can provide  valuable  information  about  the
existence  and  extent  of  contaminant  migration.    Vertical  contaminant
movement may occur  through  soil  strata into the groundwater  resulting  in
the  lateral  transport of pollutants.   Surface  water  can transport  con-
taminants directly or as bound complexes with soil  or  other solids.
     It is important that field personnel determine  whether soil  or  sedi-
ment samples require  handling as  hazardous  (concentrated) or environmen-
tal samples.   Factors such as weathering  and  dilution of soil  by  sun  and
rain,  turbulence  of  surface  water, and permeability of soil  will affect
the  concentration  of  contaminants  in  a  given sample.   This  section
focuses on those samples which would be considered  environmental  samples.
(See  Section 5  for  guidance  on  obtaining  and   handling   concentrated
[hazardous] soil and sediment samples.)
     Many of the soil and  sediment samples  taken during  the  field  inves-
tigation of a hazardous  substance  site are  grab samples.  (See  Section 1
for a definition of types of samples.)  However, it is possible  to  use a
modification of composite sampling to  obtain useful  data  about  contamina-
tion over a wide area and still control analytical  costs.

3.2  SOIL SAMPLING
     Soil and subsurface samples may  be  used not only  to identify  conta-
minants, but also to  evaluate  the role of  soil  types  in influencing  the
migration of contaminants.

3.2.1  Sample Containers
     An  appropriate  soil  sample   container  is  an  8-  to 10-ounce  wide-
mouth jar with a Teflon-lined screw  cap.   For samples  for organic  analy-
sis, the containers are  cleaned  by washing  in detergent  and  rinsing with
                                    3-1

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organic-free water.   De-ionized or distilled water  rinses  should  be  used
for containers  to  hold  samples  for inorganic  analyses.   Typically,  a  full
8-ounce wide-mouth jar  of soil  which has been  sieved during  the  sampling
process will provide  a  sufficient quantity for  priority  pollutant  analy-
sis (Federal Register,  Vol.  44,  No.  233,  Dec.  3, 1979).

3.2.2  Surface  Soil Samples
     Surface soil  samples may be  obtained  from  areas where spills  and/or
leaks  of  contaminants  may  have  occurred.    Investigators  can  determine
these  areas  from  site records or  photographs or on  direct  observation  of
stained soils or  areas  lacking  vegetation.   (If soil is  receiving  a  con-
stant  discharge of material,  samples taken  should  be  treated as  hazar-
dous/concentrated  samples.)

Approach For Surface  Samples
     Depending  on  the area to be sampled,  the  information desired  and the
analytical  support available, investigators may  take several  approaches.

     (1)  The total area  of  study may be   divided into  a grid  pattern  to
          identify samples with a specific  location.

     (2)  If the  area of  study  is large,  and  if complete characterization
          is required,  a  random  sampling  approach  may  be  used  to  reduce
          sample  numbers.   In this instance,  the area is gridded  and  sam-
          ple locations determined randomly.

     (3)  A  large  study area can also be  divided into grids and soil  com-
          bined  from  several randomly chosen locations within  that  grid.
          This  soil then  constitutes  one  sample.

     Any combination  of  the  above approaches  may by employed  to  charac-
terize contamination  over a  large  area.   The number of  samples  required
to produce statistically  valid  data is  impossible to determine  beforehand
since  it depends  on the variability  in  the analytical  results.   In  cer-
tain instances  a  small-scale sampling program  may be required  to  estimate
data variability.
                                    3-2

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     As in any  sampling  program,  it  is  advisable  to obtain an  off-site,
theoretically uncontaminated  surface  soil  sample to establish background
levels of analyzed chemicals.

Sampling Techniques and Equipment for Surface Samples

     (1)  All pertinent weather  factors  such as  temperature,  wind  velo-
          city  and  precipitation  should be  noted  and  recorded  in  the
          field logbook.

     (2)  A  sketch of  the  area of  study  should be  made  in the  logbook,
          indicating the sampling approach,  sample  locations and  depths,
          and site conditions.

     (3)  A  stainless  steel  scoop  or hand  trowel  is recommended  for  ob-
          taining surface samples.

     (4)  Shallow,  high-density  polyethylene  pans  lined  with   aluminum
          foil may be used for mixing soil  for compositing.

     (5)  A  stainless  steel  sieve  may be  used   for  screening  rocky  soil
          before placing it  in the  sample  container.  Sieving may be  re-
          quired by the analytical  laboratory.

     (6)  Equipment such as  stainless steel scoops must be  decontaminated
          between sampling  locations  to  avoid contamination of   the  next
          sample.   The equipment  should  be  detergent-washed  and  rinsed
          with distilled water.  If  organic contaminants are involved,  a
          methanol  or  acetone  wash  followed by  an  organic-free  water
          rinse is suggested.

3.2.3  Subsurface Soil Samples
     Subsurface soil samples  indicate the  extent of contaminant  penetra-
tion into  the soil and  also provide a  means to evaluate  the   effect  of
soil type distribution on contaminant migration.  Either  hand-operated or
power equipment   can be  used, depending on  the  extent of  the  investiga-
tions .
                                   3-3

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     The most  important  safety  factor  involved  is  the  avoidance  of  buried
containers or  pockets  of highly concentrated material.  A  thorough  back-
ground information  search  should  be  completed  before  obtaining  subsurface
samples, especially on or  near  the site.   At a minimum, a  metal  detector
survey should  be performed before obtaining  subsurface samples  by  hand.
If  funds  are  available,  a  survey using ground-penetrating radar is  sug-
gested before  boring with  power equipment.

Sampling Approach for Subsurface  Soil  Samples
     Locations  for  subsurface  soil samples can be chosen on  the  basis  of
such  background information  as  areas  of  past waste  storage,   the  waste
handling practices  which gave  rise  to contaminated  soil,   and  geological
survey information.   Visual inspection of  the  study area  may  also  help.
If a  large study area  is involved, a  random sampling  approach  similar  to
the types  outlined  earlier (Section 3.2.2)  may be employed.    Any  avail-
able  hydrological  data   on  seasonal   water  table  levels  and  regional
groundwater flow patterns  should  also  be  obtained.

Subsurface Sampling Techniques  and Equipment
     The  selection  and  use of  various types of hand-operated  subsurface
sampling equipment  will  be determined  by the type of  soil  and  subsurface
material  encountered.   The following  is  a  list  of  useful equipment  and
techniques:

      (1)  A  shovel  may  be used  to  dig  down   several  inches or  several
          feet,  depending  on  soil types.   A  stainless  steel   scoop  can
          then be used to  take  soil  from  the  depth reached  by digging.

     (2)  A slotted  sampling  trier allows for  core  sampling  but  is  limi-
          ted  to a  depth of about 2.5  to 3  feet  and  may  be  of  no  use  at
          all  in soils difficult  to penetrate  due to  compaction  or  stone
          and  gravel content.   The use of  the  trier allows  a  visual  ob-
          servation of a  soil  core before the  soil is  placed  in  the sam-
          ple  jar.
                                    3-4

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     (3)  A  hand  auger  may  be  used  to collect  subsurface  samples  at
          depths up  to 4  or  5  feet;  however,  it  mixes soils  and  thus
          destroys the cohesive structure and  stratigraphic character.

     (4)  A hollow-stem hand  auger  provides  the  opportunity to collect  a
          small core  sample at depths  up  to  3  or  4  feet,  although  the
          success of this is greatly dependent upon soil type.

     (5)  A hand-driven  split-spoon sampler  provides  a means  to  obtain
          somewhat undisturbed  core samples.   The  depth  will  again  be
          limited by  the  soil type and  also the number of  sampling  rod
          sections available  for  the  split   spoon.  When the  split  spoon
          is opened,  the core  should  be visually  inspected  for  strata
          changes.   When  different  strata are present, samples should  be
          obtained from each,  using a stainless-steel  scoop.

     (6)  A hand-driven hollow-stem sampler  of the  type used  in  agricul-
          ture may  be  used to  retrieve core  samples  from depths  of  16
          feet or so.   Again, this method  is limited  by soil  type.   As
          with the  split-spoon  sampler, the  core should be  visually  in-
          spected and samples taken accordingly.

     It is  important  that all equipment coming  in  contact  with  the  soil
be decontaminated between sampling locations.   The equipment  should  be
detergent-washed and  rinsed  with  distilled  water.    If the  presence  of
organic compounds  is  suspected,  a solvent  such as methanol  or  acetone
should be used followed by rinsing with  organic-free water.

3.3  SEDIMENT SAMPLES
     Sediment  samples  are valuable for  locating  pollutants  of low  water
solubility  and  high  soil binding  affinity.    Where  surface waters  might
show  trace  quantities  of  contaminants, thus  leading  investigators  to
believe  that  an  off-site contaminant  migration  problem   is  minor,  the
analysis of sediments  might show otherwise.   Heavy metals and  high mole-
cular weight halogenated  hydrocarbons  are  examples of  contaminant  groups
which might be found in greater concentrations in sediments.
                                    3-5

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     It  is  important  to  note  that  the  sediments  obtained from  surface
impoundments,  such  as lagoons, which  are suspected to be  highly  concen-
trated are to be handled  and  treated  as  hazardous  (concentrated)  samples.
This section  addresses sampling  those  locations  which will produce  sam-
ples which can be treated  and  handled  as environmental  samples.

3.3.1  Approach for Sediment  Sampling
     The  review of  background  information  gives  an  indication  of  the
types of substances which  may  be  present in  sediments.

     (1)  One would look  for  chemicals  known to  bind  with  the  soil.

     (2)  Of  additional  importance   is   any  hydrogeological  information
          which can help  establish a  relationship  between  the  contaminant
          source  and  the  contaminants  in sediments.    (For example,  are
          contaminants  entering   the   sediments   via  surface  water  or
          groundwater?)

     (3)  The pH of the surface water  over  the  sediments  should  be deter-
          mined to  identify  any unusual  pH conditions  which would influ-
          ence contaminant precipitation into  the  sediments.

     (4)  Several sediment samples should be  obtained  from the area  near-
          est the suspected contaminant  point  source.

     (5)  A background  sediment  sample should be obtained  from  sediments
          upstream  from the  suspected  point source for running water and
          from sediments  away  from  the suspected point source  for stand-
          ing  surface water.   In cases  of high  contamination of  small
          bodies of standing  water,  it may  be impossible  to find  a  back-
          ground sample.   The analysis  of  background  sediments  attempts
          to establish the contribution  of  the source  to pollution levels
          in the area. This is especially important if  contamination  with
          heavy metals is  suspected because  they occur  naturally.

     (6)   Field instruments can be used  to screen  the  samples  as  they are
          taken.
                                   3-6

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3.3.2  Sediment Sampling Techniques
     Very  simple  techniques can  usually be  employed  for  sediment  sam-
pling.   Most  samples will  be  grab samples,  although sometimes  sediment
taken from various  locations  may  be  combined into  one  sample to  reduce
the amount of  analytical  support  required.   Suggested techniques  include
the following:

     (1)  In  small,  low-flowing  streams or near  the shore  of a pond  or
          lake,  the  sample  container  (typically  an  8-ounce  wide-mouth
          glass jar) may be used to scrape up the sediments.

     (2)  To  obtain  sediments  from  larger  streams  or  farther from  the
          shore of  a  pond  or lake, a  Teflon  beaker  attached  to a  tele-
          scoping aluminum pole by means of a clamp  may  be used  to  dredge
          sediments.

     (3)  To obtain sediments from rivers or  in deeper  lakes  and  ponds,  a
          spring-loaded sediment  dredge or benthic  core  sampler may  be
          used by  lowering  the sampler  to  the appropriate  depth with  a
          rope.   The sediments  thus  obtained  are   then  placed into  the
          sample container.

     (4)  In each of the last two above cases, the sampling  device  should
          be decontaminated between locations.

     Below is a list of suggested equipment to be used  for sampling  soils
and sediments.

     (1)  Sample containers (8-oz. wide-mouth glass  jar  with Teflon-lined
          screw cap)

     (2)  Stainless steel scoops

     (3)  Stainless steel sieves (assorted mesh sizes)

     (4)  Field logbook
                                    3-7

-------
(5)   High-density polyethylene pans

(6)   Shovel

(7)   Slotted sampling trier

(8)   Hand auger, hollow stem

(9)   Hand-driven split-spoon sampler

(10) Hand-driven agricultural sampler (hollow tube)

(11) Teflon  beaker,  attached  to   telescoping  aluminum  pole  with
     clamp.

(12) Sediment dredge/benthic core  sampler
                              3-8

-------
SAMPLING PRIORITIES FOR ENVIRONMENTAL POLLUTANTS
PAGE FOUR
Environmental Compartment
Compound Water

PHTHALATE ESTERS
Dimethyl phthalate
Diethyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
POLYCYCLJC AROMATICS
Acenaphthene
Acenaphthylene
Anthracene
Benzo (a) anthracene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
Benzo (ghi) perylene
Benzo (a) pyrene
Chrysene
Oibenzo (a,h) anthracene
Fluoranthene
Fluorene
Indeno (1,2,3-cd) pyrene
Naphthalene
Phenanthrene
Pyrene
NITROSAMINES AND MISCELLANEOUS COMPOUNDS
Dimethyl nitrosamine X
Diphenyl nitrosamine
Di-n-propyl nitrosamine X
Benzidine
3,3'-Dichlorobenzidine
1,2-Diphenylhydrazine (hydrazobenzene)
Acrylonitrile X
Adapted from Chapman, P.. G. P. Romberg and G Vigors 1982

Sediment


X
X
X
X
X
X

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


X
X
X
X
X
X
"Design of Mo
Studies for Priority Pollutants." Journal Water Pollution Control Federation
Biota


X
X
X
X
X
X

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


X
X

X
X

nitorin
Vol. 5
Number 3.

-------
SAMPLING PRIORITIES FOR ENVIRONMENTAL POLLUTANTS
PAGE THREE
             Compound
   Environmental Compartment
Water      Sediment       Biota
ETHERS (Continued)

Bis(2-chloroisopropvOether
2-Chloroethyl vinyl ether
4-Chlorophenvl phenyl ether
4-Bromophenyl phenyl ether
Bis(2-chloroethoxy) methane

MONOCYCLIC AROMATICS

Benzene
Chlorobenzene
1,2-Dichlorobenzene (o-dichlorobenzene)
1,3-Dichlorobenzene (m-dichlorobenzene)
1,4-Dichlorobenzene (p-dichlorobenzene)
1,2,4-Trichlorobenzene
Hexachlorobenzene
Ethylbenzene
Nitrobenzene
Toluene
2,4-Dinitrotoluene
2,6-Dinitrotoluene

PHENOLS AND CRESOLS

Phenol
2-Chlorophenol
2.4-Dichlorophenol
2,4,6-Trichlorophenol
Pentachlorophenol
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
2,4-Dimethylphenol
p-Chloro-m-cresol
4,6-Dinitro-p-cresol
  X
  X
  X
  X
  X
  X
X
X
X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
               X
                            X
                            X
             X
             X
             X
             X
             X
             X
  These compounds  have been removed from the EPA priority pollutant list.

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SAMPLING PRIORITIES FOR ENVIRONMENTAL POLLUTANTS
PAGE TWO
                                                   Environmental Compartment
             Compound	             Water       Sediment       Biota
PCBs AND RELATED COMPOUNDS

Polychlorinated biphenyls (6 PCB arochlors)                        X            X
2-Chloronaphthalene                                            X            X

HALOGENATED ALIPHATICS

Chloromethane (methyl chloride)                    X
Dichioromethane (methylene chloride)                X
Trichloromethane (chloroform)                       X
Tetrachloromethane (carbon tetrachloride)            X
Chloroethane (ethyl chloride)                        X
1,1-Dichloroethane (ethylidine chloride)               X
1,2-Dichloroethane (ethylene dichloride)              X
1,1,1-Trichloroethane (methyl chloroform)            X
1,1,2-Trichloroethane                               X
1,1,2,2-Tetrachloroethane                           X
Hexachloroethane                                  X
Chloroethene (vinyl chloride)                         X
1,1-Dichloroethene (vinylidine  chloride)               X
1,2-Trans-dichloroethene                           X
Trichloroethene                                    X
Tetrachloroethene (perchloroethylene)                X
1,2-Dichloropropane                                X
1,3-Dichloropropene                                X
Hexachlorobutadiene                                            X            X
Hexachlorocyclopentadiene                                       X            X
Bromomethane (methyl bromide)                    X
Bromodichloromethane                             X            X
Dibromochloromethane                             X            X
Tribromomethane (bromoform)                      X            X
     Dichlorodifluoromethane*                      X            X
     Trichlorofluoromethane*                       X            X

ETHERS

     Bis(chloromethyl) ether*                       X
Bis(2-chloroethyl) ether                            X
   These compounds have been removed from the EPA priority pollutant list.

-------
                                  EXHIBIT 1
              SAMPLING PRIORITIES FOR ENVIRONMENTAL POLLUTANTS
Compounds are  characterized  on the  basis of persistence,  accumulative capacity and
volatility.    "X"  indicates  the  appropriate  environmental  compartment(s)  for  initial
sampling.
                                                  Environmental  Compartment
             Compound
Water
Sediment
Biota
METALS AND INORGANICS

Antimony
Arsenic
Asbestos
Beryllium
Cadmium
Chromium
Copper
Cyanides
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc

PESTICIDES

Acrolein
Aldrin
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan and endosulfan sulfate
Endrin and endrin aldehyde
Heptachlor
Heptachlor epoxide
Hexachlorocyclohexane (a,B,5 isomers)
y-Hexachlorocyclohexane (lindane)
Isophorone
TCDD
Toxaphene
  X

  X
  X
  X
  X
  X
               X
               X
               X
               X

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

   X
   X
                X
                X
                X
                X

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

                            X
                            X
                            X
                            X
                            X

-------
                                          CONSTITUENTS  IN  INDUSTRIAL
                                              SIGNIFICANT  POTENTIAL
                                               MUNICIPAL WAS1EWATER HAVING
                                               SOUNOWATER CONTAMINATION
                    MINING (SIC  10.  11.  and  12)

        Metal  and Coal  Mining  Industry  (SIC  10,  11.  and  12)
 pH                       Zinc
 Sulfate                  Tin
 Nitrate                  Vanadium
 Chloride                 Radium
 Total  Dissolved Solids    Phenol
 Phosphate                Selenium
 Copper                   Iron
 Nickel                   Chromium
 Lead                     Cadmium
                          Uranium

              PAPER  AND  ALLIED  PRODUCTS  (SIC 26)

           Pulp and  Paper  Industry (SIC  261 and 262)
 COD/BOO
 TOC
 PH
 Heavy metals
 Phenols
 Sulfite
 Color
 Biocides
            CHEMICALS AND  ALLIED PRODUCTS  (SIC 26)

             Organic Chemicals  Industry (SIC 286)
 COO/BOO
 pH
 Total Dissolved Solids
 Heavy metals
Alkalinity
TOC
Total phosphorus
                              Magnesium
                              Silver
                              Manganese
                              Calcium
                              Potassium
                              Sodium
                              Aluminum
                              Gold
                              Fluoride
                              Cyanide
 Nitrogen
 Phosphorus
 Total  Oiss.
   Solids
Phenols
Cyanide
Total nitrogen
     Inorganic Chemicals. Alkalies, and Chlorine Industry (SIC 281)
Acidity/alkalinity
Total dissolved solids
Chloride
Sulfate
COO/BOD
TOC
Mercury
Chlorinated benzenoids        Chromium
 and polynuclear aromatic*    Lead
Phenols                       Titanium
Fluoride                      Iron
Total phosphorus              Aluminum
Cyanide                       Boron
Arsenic
                  CHEMICALS AND ALLIED PRODUCTS
       Plastic Materials and Synthetics Industry (SIC 282)
COD/BOD
prt
Phenols
Total dissolved solids
Sulfate
Phosphorus
Nitrate
Organic nitrogen
Chlorinated benzenoids and
  polynuclear aromatics
           nitrogen Fertilizer Industry (SIC 2873)

Ammonia                  Sulfate
Chloride                 Organic nitrogen
                           compounds
Ammonia
Cyanide
Zinc
Mercaptans
                              COO
                              Iron,  total
                                                                   Nitrogen Fertilizer Industry (SIC 2873) (Conl.)
                          Chromium                 Zinc
                          Total dissolved solids   Calcium
                          Nitrate                  Sodium
                                                       pH
                                                       Phosphate
                                        Phosphate Fertilizer Industry (SIC 2874)
                         Calcium
                         Dissolved solids
                         Fluoride
                         pH
                         Phosphorus
                         Ac i d i ty
                         A1umi num
                         Arsenic
                         Iron
                         Cadmium
                PETROLEUM AND COAL PRODUCTS (SIC 29)

                Petroleum Refining Industry (SIC 291)

Ammonia                  Chloride
Chromium                 Color
COD/BOD                  Copper
pH                       Cyanide
Phenols                  Iron
Sulfide                  Lead
Total dissolved solids   Mercaptans

                     PRIMARY METALS (SIC 33)

                     Steel Industry (SIC 331)

                         Cyanide
                         Phenols
                         Iron
                         Nickel
                         PH
                         Chloride
                         Sulfate
                         Ammonia
Mercury
Nitrogen
Sulfate
Uranium
Vanadium
Radium
Nitrogen
Odor
Total phosphc
Sulfate
TOC
Turbidity
Zinc
Tin
Chromium
Zinc
                                    ELECTRIC. CAS. AND SANITARY SERVICES (SIC 49)

                                         Power Generation Industry (SIC 491)
                                                       COO/BOO
                                                       Polychlorinated
                                                         biphenyls
                                                       Total dissolved solids
                                                       Oil and grease
                                                  Copper
                                                  Zinc

                                                  Chromium
                                                  Other corrosion
                                                    inhibitors
                 Municipal  Sewage Treatment QIC 49S)
                         pH                       Nitrate
                         COO/BOO                  Ammonia
                         Alkalinity               Chloride
                         Detergents               Sodium
                         Total dissolved solids   Potassium
                                                       Phosphorus
                                                       Organic bioci

                                                       Sulfur dioiid
                                                       Heat
                                                       Sulfate
                                                       Copper
                                                       Tin
                                                       Zinc
                                                       Various  Organ

-------
                             ORGANIC SAMPLE COLLECTION REQUIREMENTS
    MATER  SAMPLES
 EXTRACTABLE ANALYSIS
      (LOW LEVEL)
 EXTRACTABLE ANALYSIS
    (MEDIUM LEVEL*)
REQUIRED
VOLUME
1 GALLON
fb
fl


fh
r i
1 GALLON


                                            CONTAINER TYPE
                                          2 X 1/2-GAL. AMBER
                                             GLASS BOTTLES

                                                  OR

                                           4 X 1-LITER AMBER
                                             GLASS BOTTLES
                   4 X 32-OZ.  WIDE-MOUTH
                        GLASS JARS
  VOLATILE ANALYSIS
(LOW OR MEDIUM LEVEL*)
 80 ML
fl   0
                                          2 X40-ML GLASS VIALS
    •ALL MEDIUM LEVEL SAMPLES TO BE SEALED  IN METAL PAINT CAN FOR SHIPMENT

-------
                           ORGANIC SAMPLE COLLECTION REQUIREMENTS
SOIL/SEDIMENT SAMPLES

 EXTRACTABLE ANALYSIS
(LOW OR MEDIUM LEVEL*)
REQUIRED
 VOLUME

  6 OZ.
                                               on
                   CONTAINER TYPE

                I X 8-OZ. WIDE-MOUTH
                     GLASS  JAR

                        OR

                2 X 4-OZ. WIDE-MOUTH
                     GLASS JARS
  VOLATILE ANALYSIS
(LOW OR MEDIUM LEVEL*)
  210 ML
oo
2 X12D-ML WIDE-MOUTH
     GLASS VIALS
    •ALL MEDIUM LEVEL SAMPLES TO BE SEALED
        IN METAL PAINT CAN FOR SHIPMENT

-------
                        INORGANIC SAMPLE COLLECTION REQUIREMENTS
     HATER SAMPLES
    METALS ANALYSIS
       (LOW LEVEL)
    METALS ANALYSIS
    (MEDIUM LEVEL*)
 CYANIDE  (CN~)  ANALYSIS
      (LOW LEVEL)
 CYANIDE  (CN~)  ANALYSIS
    (MEDIUM LEVEL*)
REQUIRED
 VOLUME
 1 LITER
 16 OZ.
 1 LITER
 16 OZ.
•ALL MEDIUM LEVEL SAMPLES TO BE SEALED
    IN METAL PAINT  CAN FOR  SHIPMENT
                9
               x
     CONTAINER TYPE
1 X 1-LITER POLYETHYLENE
         BOTTLE
  1 X  16-OZ. HIDE-MOUTH
       GLASS JAR
1 X 1-LITER POLYETHYLENE
         BOTTLE
 1 X 16-OZ. WIDE-MOUTH
       GLASS JAR

-------
                        INORGANIC SAMPLE COLLECTION REQUIREMENTS
 SOIL/SEDIMENT SAMPLES
REQUIRED
 VOLUME
   CONTAINER TYPE
METALS AND CYANIDE (CN~)
        ANALYSIS
 (LOW OR MEDIUM LEVEL*)
  6  OZ.
1 X 8-OZ.  HIDE-MOUTH
     aASS JAR
                                                                             OR
 'ALL MEDIUM LEVEL SAMPLES TO BE  SEALED
     IN METAL PAINT CAN FOR SHIPMENT
                                            X
                                                                     2  X  4-OZ. WIDE-MOUTH
                                                                          GLASS JARS

-------
                          DIOXIN SAMPLE COLLECTION REQUIREMENTS
     SOIL/SEDIMENT
        SAMPLES
REQUIRED
 VOLUME
   CONTAINER TYPE
      2,3,7,8-TCDD
   (DIOXIN) ANALYSIS
 4 OZ.
1 X 4-OZ. HIDE-MOUTH
     GLASS JAR

         OR

1 X 8-OZ, WIDE-MOUTH
     GLASS JAR
•ALL MEDIUM LEVEL SAMPLES TO BE SEALED
    IN METAL PAINT CAN FOR SHIPMENT
                      X

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                          HIGH HAZARD SAMPLE COLLECTION REQUIREMENTS
LIQUID SAMPLES

    ORGANIC AND INORGANIC
           ANALYSIS

 SOLID SAMPLES

    ORGANIC AND INORGANIC
           ANALYSIS
                                REQUIRED
                                 VOLUME
6 OZ.
6 OZ.
                                        CONTAINER TYPE
1 X 8-OZ.  HIDE-MOUTH
     GLASS JAR
1 X 8-OZ.  WIDE-MOUTH
     GLASS JAR
   •ALL MEDIUM LEVEL SAMPLES TO BE SEALED
       IN METAL PAINT CAN FOR SHIPMENT
                                                       X

-------
RECOMMENDED  SAMPLING AND PRESERVATION  PROCEDURES FOR WATER AND WASTEWATER
Parameter
Acidity
Alkalinity
Asbestos
Bacteria

Bicarbonate
BOD
Bromide
Carbonate
Chloride
Chlorine Demand
Chromium VI
COD
Color
Conductance
Cyanide
Fluoride
Hardness
Hydrazine
Collection
technique
Grab or composite
Grab or composite
Grab or composite
Grab only

Grab only
Grab only
Grab or composite
Grab only
Grab or composite
Grab only
Crab or composite
Grab only
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Container9
P.G
P.C
F
Pro, G

P.G
P,G
P.G
P.G
P,G
P,G
P,G
P.G
P.G
P.G
P.G
P
P.G
P.G
Preservation
Cool, 4°C
Cool, 4°C
Cool, 4°CC
Cool, 4°C, 10*
Na2S203. EDTA
Determine onsite
Cool, 4°C
None required
Determine onsite
None required
Determine onsite
Cool, 4°C
H2S04 to pH <2; Cool, 4°C
Cool, 40C
Cool, 4°C
NaOH to pH >12, 0.6g
Ascorbic acidd
None required
HN03 to pH <2
If not analyzed immediately,
Holding timeb
14 days
14 days
48 hours
6 hours

No holding
48 hours
28 days
No holding
28 days
No holding
24 hours
28 days
48 hours
28 days
14 days
28 days
6 months
7 days
                                collect under acid.  Add
                                90 ml of sample to  10 ml
                                (1 + 9) HC1

-------
                                                           (continued)
Parameter
Iodide
Iodine
Metals (Except Cr VI)
Dissolved
Suspended
Total
Nitrogen
Ammonia
Kjeldahl (total)
Nitrate plus Nitrite
Nitrate
Nitrite
Oil & Crease
Collection
technique
Grab or composite
Grab only
Grab or composite
Grab or composite
Grab or composite

Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab only
Container3 Preservation
P,G Cool 4°C
P,G Determine onsite
P,G Filter onsite, HN03 to
pH < 2
P,G Filter onsite
P,G HN03 to PH < 2

P,G Cool, 4°C, H2S04 to
pH < 2
P,G Cool, 4°C, H2S04 to
pH < 2
P.G Cool, A°C, H2S04 to
pH < 2
P,C Cool, 4°C, H2S04 to
pH < 2
P.G Cool, 4°C
G Cool 4°C, H2S04 to
Holding time''
24 hours
No holding
6 months, except
Hg— 28 days
6 months, except
Hg— 28 days
6 months, except
Hg— 28 days

28 days
28 days
28 days
48 hours
48 hours
28 days
Organics

  Extractables (base/
    neutrals and acids)
                                                             pH < 2
Grab or composite     G,  Teflon-   Cool, 4°C
                     lined cap
7 days until
extraction,  30 days
after extraction

-------
(continued)
Parameter
Organics (cont.)
Purgeables (halocarbons-
a roma tics)
Purgeables (acrolein and
acrylonitrile)
Pesticides and PCbs
PH
Phenol
Phosphorus
Ortho phosphate
Phosphorus, Total
Radioactivity
Silica
Dissolved
Total
Solids
Dissolved
Volatile Dissolved
Suspended
Collection
technique Container3 Preservation

Grab only C, Teflon- Cool, 4°C
lined cap
Grab only G, Teflon- Cool, 4°C
lined cap
Grab or composite G, -Teflon- Cool, 4°C
lined cap
Grab only P,G Determine onsite
Grab or composite G Cool, 4°C, H2^°it co PH <2

Grab or composite P,G Filter onsite, cool, 4°C
Grab or composite P,G Cool, 4°C, ^SO,?, to
pH <2
Grab or composite P,G HN03 to pH <2
Grab or composite P Cool, 4°C
Crab or composite F Cool, 4°C
Grab or composite P,G Cool, 4°C
Grab or composite P,G Cool, 4°C
Grab or composite P,G Cool, 4°C
Holding timeb

14 days
14 days
7 days until
extraction, 30 days
after extraction
2 hours
24 hours

48 hours
28 days
6 months
28 days
28 days
7 days
7 days
7 days

-------
                                                            (continued)
Parameter
Solids (cont.)
Volatile Suspended
Total
Volatile Total
Settleable
Sulfate
Sulfide
Sulf ite
Surfactants
TOC
TOX

Turbidity
aP « Polyethylene, G =
bThe holding times are
EPA -600/4-8 2-055 and
Collection
technique
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite
Grab or composite

Grab or composite
Glass, Pro = Polypropylene
those listed in Technical
Container3
P.C
P.G
P.C
P.G
P.G
P.G
P.G
P.G
G, Teflon-
lined cap
G, Amber,
Teflon-lined
cap
P.G

Additions to
Methods for Organic Chemical Analysis of
Preservation
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C, 2 ml zinc acetate
plus NaOH to ph > 9
Determine onsite
Cool, 4°C
Cool, 4"C, HC1 to pH <2
Cool, 4°C, add 1 ml 0.1 M
sodium sulfite

Cool, 4°C

Methods for Chemical Analysis
Holding timeb
7 days
7 days
7 days
48 hours
28 days
7 days
No holding
48 hours
28 days
7 days

48 hours

of Water and Wastes,
Municipal and Industrial Uastewater, EPA-600/4-82-057.
clf samples cannot be filtered  within  48 hours, add  1 ml of a 2.712 solution of mercuric  chloride  to inhibit bacterial
 growth.

dShould only be used in the  presence of residual chlorine.

-------
                                     USES OF GENERAL PURPOSE OECON SOLUTIONS
TYPE OF HAZARD
PREFERRED DECON SOLUTION
DIRECTIONS FOR PREPARATION
1. Inorganic acids, metal processing wastes
2. Heavy metals - mercury, lead, cadmium, etc.
3. Pesticides, fungicides, chlorinated
phenols, dloxlns, PCPs
4. Cyanides, ammonia and other non-acidic
Inorganic wastes
5. Solvents and organic compounds such as
trlchloroethylene, chloroform and toluene
6. PBB's and PCB's
7. Oily, greasy unspecified wastes
8. Inorganic bases, alkali and caustic waste
A
A
B
B
C (or A)
C (or A)
C
D
To 10 gallons of water, add 4
pounds of sodium carbonate
(soda lime) and 4 pounds of
trl sodium phosphate. Stir
until evenly mixed.
Same as 11 above
To 10 gallons of water, add
8 pounds of calcium hypochlorlte.
Stir with wooden or plastic
stlrrer until evenly mixed.
Same as 13 above
To 10 gallons of water, add
4 pounds of trl sodium phosphate.
Stir until evenly mixed.
Same as 15 above
Same as 15 above
To 10 gallons of water, add
1 pint of concentrated
hydrochloric acid. Stir with
a wooden or plastic stlrrer.

-------