United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-420) VVF
EPA/530/UST-89/010
June 1989
Petroleum Tank Releases
Under Control
A Compendium Of Current
Practices For
State UST Inspectors
                         Printed on Recycled Paper

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 Petroleum Tank Releases
       Under Control

A Compendium of Current Practices
     for State UST Inspectors
   U.S. Environmental Protection Agency
   Office of Underground Storage Tanks
            June 1989

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                            ACKNOWLEDGEMENTS
The Environmental Protection Agency's (EPA's) Office of Under-
ground Storage Tanks (OUST) would like to express its gratitude
to the following individuals for their review and comments: Roger
Chu and Sharon Gerolamo of the Massachusetts Department of
Environmental Quality Engineering; Shawn Abbott and Gordon
Dean of the Florida Department of Environmental Regulations;
Terry Brazell and the California State Water Resources Control
Board (for the inspiration in the design of the cleanup scenarios
from their "Leaking Underground Fuel Tank Field Manual"); Jack
Hwang of EPA Region III and Steve Spurlin of Region IV; and
Helga Butler, Iris Goodman, Mike Kalinoski, Pam McClellan,
Dave O'Brien, Joseph Retzer, Peg Rogers, Tom Schruben, L.M.
Williams, and Tom Young of OUST.

Also, special thanks to Claudia Brand of IGF Inc. for working with
OUST to develop and to write this document and to the rest of the
project team for all of their efforts.  The team included David
Brown, Allison Cogley, Vernon Dunning, William Finan, Linda
Hart, Jody Holtzman, Ed Meyer, Arch Richardson, Gardner Shaw,
and Jean Smith. Additional thanks to Paul Yaniga, Gary Gen-
teman, and Todd Schwendeman of Groundwater Technology Inc.
for their technical review and support and to Michael Boone of the
Washington Information Center for his production assistance.
                              Dana S. Tulis
                              Project Manager
                              June 1989

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                                             TABLE OF CONTENTS
  I.  PURPOSE, CONTENT, AND ORGANIZATION
                  Purpose                                           1
                  Content                                           1
                  Organization                     .                  3

 II.  INITIAL RESPONSE	_____

                  Site information                                    6
                  Fire and safety hazards                              6
                  Source and cause of release                          10
                  Stopping free product flow                           14
                  Vapor migration                                   16
                  Potentially affected community                       16
                  Alternative drinking water supplies                   17
                  Containment of free product                         18
                  Security of site                                    19
                  Reporting requirements                             19
                  Site Evaluation Checklist                           21

III.  LIMITED SITE INVESTIGATION	

     Scenario A. Minimal Soil Contamination

                  Locations of contamination                          28
                  Soil screening                                     28
                  Minor soil contamination management                 30
                  Reporting requirements                             31
                  Site Evaluation Checklist                           33

     Scenario B.  Extensive Soil  Contamination

                  Potential sources, suspected areas of contamination,
                   and site conditions                                36
                  Field preparation                                   36
                  Initial screening                                   36
                  Subsurface soil sampling                            38
                  Evaluation of the extent of contamination              44
                  Source control and soil management                  46
                  Reporting requirements                             48
                  Site Evaluation Checklist                           49
                                                                        111

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                                              TABLE OF CONTENTS
 III.  LIMITED SITE INVESTIGATION (CONTINUED)
      Scenario C. Groundwater Contamination
                  Monitoring well locations
                  Monitoring well installation
                  Groundwater flow characteristics
                  Groundwater sampling
                  Assessment of groundwater contamination
                  Free product removal from ground water
                  Determination of groundwater uses
                  Alternative water supplies
                  Reporting requirements
                  Site Evaluation Checklist
52
52
55
56
61
61
65
65
66
67
APPENDICES
         A. Vapor Control and Treatment Options
         B. Transport of Contaminants
         C. Tank Removal, Closure, and Repair Activities
71
79
83
 WORKSHEETS
         1.  Site History and Tank Information
         2.  Preliminary Review of Impacts of Release
         3.  Evaluation of Anticipated Site Conditions
         4.  Preparation for Field Operations
REFERENCES
 INDEX

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                                              TABLE OF EXHIBITS
  1.   Common Occurences and Avenues of Hydrocarbon
       Migration Following a Leak                                    8
  2.   Hydrocarbon Vapor Detection Meters                            9
  3.   Information to Help Identify the Source of the Release            11
  4.   Sample Tank Inventory Record                                12
  5.   Types of Facilities with Petroleum USTs                         14
  6.   Identifying Possible Sources of Contamination                   15
  7.   Selecting a Scenario                                          24
  8.   General Considerations Determining Magnitude
       of Potential Impacts                                          25
  9.   Laboratory Analysis of Samples                                39
 10.   Analytical Options                                           40
 11.   Well Drilling Methods                                        42
 12.   Split-Spoon Sampler                                         43
 13.   Typical Boring Log                                           45
 14.   Soil Management Options                                     47
 15.   Typical Monitoring Well                                       53
 16.   Method to Determine Water Table Elevation and
       Product Thickness                                            58
 17.   Purging Equipment                                          59
 18.   Free Product Recovery                                        62
 19.   Trenches and Recovery Wells                                  63
 20.   Barrier Installations                                         64

A-l    Passive Vapor Control System                                 72
A-2    Active Vapor Control Systems                                  74
A-3    General Considerations for Active Vapor Control Systems         75
A-4    Catalytic Converter                                          77
B-l    Typical Seepage Patterns                                      80
B-2    Hydraulic Conductivity of Selected Rocks                        82
                                                                        Vll

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                     I.  PURPOSE, CONTENT, AND ORGANIZATION
Purpose
          Tank Releases Under Control is intended to help States
train inspectors of underground storage tanks (USTs); it also
provides new and experienced inspectors with ways to evaluate
options for controlling releases from leaking USTs. The document
is flexible enough to be used by States regardless of their specific
requirements, conditions, and practices.

.The document is a compendium of general knowledge based on
standard engineering practices; and, as such, it covers a wide
range of activities. Remediating dissolved contamination in
ground water is not addressed, however, because of the
complexity of this topic and because of the ongoing work in this
area.

As stated above, this document is a baseline of general knowledge.
As developments and improvements evolve in the field, and as the
Office of Underground Storage Tanks (OUST) continues to focus on
specific project areas, this document will be updated.
Content
Chapter II contains descriptions of the first actions to take at a
site with an UST that is leaking petroleum.  In this document, we
employ the commonly used phrase "initial response" to describe
these activities. During this stage of the cleanup, State UST
inspectors may need to gather information about the site to help
determine the cause of the leak or release. In addition, UST
inspectors might oversee the activities necessary to stop the flow of
free product, to ensure that fire and safety hazards have been
mitigated, and to determine whether other response actions (such
as vapor migration control) are needed. Inspectors may also
oversee the responsible party's investigation to determine whether
an alternative drinking water supply is needed.

Chapter III provides a list of the actions to take once the initial
response is completed. We call this a "limited site investigation."
It begins with selection of a scenario based on review of available
information and anticipated contaminant migration. The three
scenarios are: Scenario A, Minimal Soil Contamination; Scenario B,
Extensive Soil Contamination; and, Scenario C, Groundwater Con-
tamination. Depending on site-specific conditions, the activities in
one or more of the scenarios may be applicable. For example, if
groundwater contamination is discovered at the outset, Scenarios A
and B serve as the basis for investigating the release before con-
tinuing on to Scenario C.

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Organization
Because it is a training tool, Petrole/wr"
                          Reeases Under
                      Control is designed primarily for office use; however, certain pages
                      (e.g., checklists and worksheets) can be photocopied and used in
                      the field during inspections.

                      A step-by-step approach is used to present information.  Not
                      every step is necessary for every situation and the sequence of
                      steps may vary depending on site conditions. We encourage
                      State inspectors to use their discretion in determining which
                      steps to take at each site.

                      In addition, we've used symbols (small icons) to help readers locate
                      information quickly, to highlight added details, and to identify
                      specific field and evaluation tools.  The following icons identify
                      Chapters II and III respectively and are placed at the bottom of
                      the corresponding chapter page.
                      Fire Truck   Initial Response; Chapter II
                      Detective     Limited Site Investigation; Chapter III
                      The remaining icons highlight added detail or identify specific field
                      and evaluation tools. These symbols and their meanings are:
                      Stop Signs
             =/     Checklists
Detailed information for you to know when
implementing a step.
Reminders and progress tracking sheets you can
use for supplementing other documentation.
                      Worksheets   Tools to help you evaluate individual release
                                    incidents.
                      In addition to this document, OUST has developed other source
                      materials for corrective action and tank closure.  Ordering infor-
                      mation for these materials can be found in the References.

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                            II.  INITIAL RESPONSE
The descriptions of initial response steps included in this chapter
will help inspectors evaluate the selection and implementation of
measures, taken by the owners/operators or contractors, to clean
up leaking petroleum underground storage tanks (USTs). These
steps address the suggested approaches on how to:

•  Gather basic information about the site;

•  Identify, monitor, and mitigate fire and safety hazards;

•  Identify the source and cause of the release;

•  Stop the flow of free product;

•  Initiate vapor control, collection, and treatment by using either
   passive or active control systems;

•  Determine if public and private water supplies have been con-
   taminated;

•  Provide alternative drinking water supplies, if necessary;

•  Initiate the collection of free product in basements/sewers and
   surface waters;

•  Secure the site in order to discourage unauthorized entrance or
   vandalism; and

•  Report all required information on site activities to the imple-
   menting agency.
   The need for some, or all, of these steps is contingent
   upon the site-specific situation.

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       Site Information
       Step 1    Has information on site history, tank usage, and impacts of the
                 release been compiled by an inspector or contractor?

                            In order for inspectors to begin evaluating a release situation, it is
                            important to gather basic information about the site.  Inspectors
                            should try to answer the following types of questions concerning
                            initial response to a release: Where is the release located? Who
                            reported it? What appears to have taken place at the site? (Work-
                            sheets 1 and 2, in the Worksheet section, have been provided to
                            assist with the gathering of this information.)

                            This initial information provides the foundation of an inspector's
                            understanding and assumptions about a site. Therefore, it will be
                            important to check these early assumptions (e.g., regarding poten-
                            tial sources and direction of groundwater flow) as additional infor-
                            mation is gathered throughout the project.
       Fire and Safety Hazards
       Step 2    Have fire and safety hazards been identified, monitored and
                 mitigated?

                            If vapors or liquids are detected or suspected in a confined area, a
                            quick assessment is necessary to determine the presence of fire
                            and explosion hazards. This type of assessment is based on vola-
                            tility of the spilled substances, approximate  amount released, and
                            amount of time elapsed since the release. If a fire and safety
                            hazard exists, it is important to ensure that  proper health and
                            safety measures have been performed. Step 5 and Appendix A
                            provide more details on vapor control.

                            During initial response, inspectors may need to verify that the
                            following steps have been taken (some of these measures may need
                            to be repeated or maintained over a period of time, depending on
                            specific site conditions).

                            2.1    Has the local fire department and/or State been
                                  alerted?

                            2.2    Has an operator trained in the use of a combustible
                                  gas indicator and an oxygen indicator (e.g., from the
                                  State and/or local fire department) determined if
                                  vapors are present at the site outdoors and/or in-
                                  doors? And if present, at what concentrations?
ilii, i ,.f •m

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            2.3   Have all persons been evacuated from the areas
                  where unsafe hydrocarbon levels have been found or
                  suspected (except for properly trained and equipped
                  persons)?

            2.4   If flammable vapors or liquids have been detected at
                  levels dangerous to human health or property (e.g.,
                  near the lower explosivity limit), have the following
                  steps been performed?

                  •   Notification of appropriate State and local authorities
                      and the facility owner/operator;

                  •   Enforcement of security measures such as posting of
                      notices to warn the public of potential danger;

                  •   Elimination of ignition sources that may be present in
                      vapor contaminated spaces (e.g., vapor-fired heaters,
                      light switches, non-explosion-proof motors, and electri-
                      cal items); and

                  •   Ventilation of confined areas by opening windows and
                      doors and by using an explosion-proof exhaust fan to
                      dilute concentrations (this may need to be done prior to
                      entering the area).
The following additional factors are important to consider when evaluating
safety hazards:

•  All gasoline vapors are heavier than air, therefore it is necessary to monitor
   air near the ground or foundation as well as in the breathing zone.

•  Elevator shafts, telephone lines, electrical cables, subways, and sewers are
   common migration routes and collection points. (Exhibit 1 shows common
   migration pathways of a tank release.)

•  In explosive situations, ignition sources may not always be obvious.
   Precautionary measures may need to be taken to prevent sparks and static,
   e.g., when starting cars or using metal objects.

•  The selection and use of detection meters for hydrocarbon vapors should be
   based on their applicability to site-specific conditions. (See Exhibit 2 for
   descriptions of hydrocarbon vapor detection meters.) For example,
   explosimeters should be calibrated for the volatile compound of concern and
   are generally most effective when used with an oxygen indicator for
   determining high concentrations of contaminants and explosive conditions in
   confined spaces. A photoionization detector, on the other hand, is more
   suitable for identifying lower concentrations that are a concern because of the
   risk of long-term exposures.

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00
                                                       EXHIBIT 1

                                         Common Occurrences and Avenues of
                                       Hydrocarbon Migration Following a Leak
                                                             VAPORS LOST TO
                                                             ATMOSHPERE
                                           UNDERGROUND
                                               UTILITIES
                                           STORAGE
                                           TANK
                      SOIL CONTAMINATED BY
                 ADSORBED RESIDUAL HYDROCARBONS
                     BOUND TO SOIL PARTICLES
                                                                                    VAPOR MIGRATION ALONG
                                                                                         SEWER LINE
                                                                                ACCUMULATED MOBILE
                                                                                HYDROCARBONS
WATER TABLE
                                                          HYDROCARBON/WATER
                                                          INTERFACE
                                                    DISSOLVED HYDROCARBONS IN WATER
                                                    MIGRATING DOWN WATER TABLE GRADIENT
                                              Source: Groundwater Technology Inc.

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                                                            Hydrocarbon Vapor Detection Meters
Air
Monitoring
Meters (1)
Combustible
Gas Indicator
(CGI or
Explosivity
Meter) (3)
Oxygen
Indicator (3)
Flame
lonization
Detector
(FID) (4)
Photoionization
Detector (PID)
(4)
Infrared
Colormetric
Tube
Portable Gaa
Chromatograph
(can be equipped
with PID or FID)
Danger of Volatilization
Examples of Ranges Vapors in Fires and of Chemicals
of Detection (2) Soil Explosions to Air
0-100% LEL XX
(Response is
relative to the
calibration gas)
Indicates X
Oxygen Content
0-30% (variable)
0.6-10,000 ppm X X
approximate
(Response is
relative to the
calibration gas)
0-2,000 ppm X X
approximate
(Response is
relative to the
calibration gas)
Sppm-100* X X
Variable (e.g., XX X
0.001-10,000 ppm,
0.1-10% by volume)
0.6-10,000 ppm (FID) X X
0.01-1,000 ppm (PID)
Vapors in Vapors in
Vapors in Sewer Ambient Approximate
Buildings Pipes Air Cost Limitations
X X $600-16,000 • Accuracy of reading depends on difference between
calibration and ambient sampling temperatures, humidity,
and atmospheric pressure
• Calibration to methane and pentane may alter accuracy
of readings of other substances
• Certain chemicals (e.g., leaded gasoline) may damage the
filament on 'hot wire" models, reducing the sensitivity
• Response is qualitative
X X (Often • Does not detect fuel hydrocarbons
built into • Accuracy affected by altitude and temperature. Instrument
CGI) must be calibrated under condition of use
XXX $6,000-$7,600 • Does not detect inorganic gases or vapors
• Requires identification of chemical before it can report its
concentration
• Can be affected by humidity and moisture
• • Qualitative data only
XXX $4,000-16,000 • Does not detect methane
• Presence of high concentrations of methane or humidity may
alter reading drastically
• Interference from power lines, water vapor, transformers,
high voltage equipment, and radio wave transmissions may
alter readings
• Qualitative data only
XXX $1,750-$9,000 • False positives may occur due to interference of other gases.
XXX $2-6Vtube • Accuracy of readings subject to human error
• Responses of different models of tubes may vary
• Responses affected by humidity, temperature, other
contaminants present, and age of tube
XXX $7,000-160,000 • Accuracy of results affected by ambient conditions when using
some models
• Reading is not direct
• Portable units tend to be less accurate than lab-based GC '
• Lower detection limits can be obtained depending on
manufacturer and detector

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Source and Cause of Release
Step 3   Have the source and cause of the release been satisfactorily
          identified?

                      A recent review of case studies from several States indicates that
                      misidentification of the source of the release is a common problem
                      leading to delays and costly cleanups.  To avoid this error, an
                      inspector should be aware that the nearest facility, tank, or line is
                      not always the source. Therefore, it is important to review avail-
                      able information about the site and surrounding areas. The
                      inspector may also want to visit the site as soon as possible to
                      confirm initial assumptions.

                      3.1    Has information from the suspected facility, local
                             and/or State officials, and from surrounding facili-
                             ties been reviewed by the inspector or contractor
                             (see Exhibit 3)?

                             Although a review of inventory records can be time-
                             consuming, a quick review may be especially helpful in
                             discovering large leaks or in determining which of several
                             tanks is the most likely one to be leaking.  See Exhibit 4 for
                             an example of a tank inventory record. When reviewing
                             inventory records and interpreting discrepancies, the
                             following guidelines are helpful:

                             •   If a facility owner/operator's daily stock readings, sales
                                records, and/or delivery receipts are incomplete or
                                missing, other investigative steps should be pursued.

                             •   Daily records should be reconciled on a monthly basis.
                                Looking at less than 30 days of information at a time
                                can be highly misleading.

                             •   Discrepancies in inventory data can be caused by sev-
                                eral factors other than a leak. The most important of
                                these are:  1) errors in delivery receipts, 2) temperature
                                changes which cause the fuel to expand when heated or
                                contract when cooled, creating the appearance of a leak,
                                3) errors in pump meter calibration, 4) product loss due
                                to evaporation, and 5) theft.  Each of these errors is
                                more significant for larger tanks and larger sales vol-
                                umes (throughput).

                             •   Generally, a leak is suspected when monthly discrepan-
                                cies exceed  1% of throughput plus 130 gallons. If a

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                   large discrepancy is found, the reconciliation should be
                   reviewed for math errors and the calibration of pump
                   meters should be checked. If these items are not found
                   to be the source of the error, additional investigation of
                   the tank with the discrepancy may be required.
                           EXHIBITS
   Information to Help Identify the Source of the Release
The following items are examples of information that may be useful:
•  Map or sketch of the area identifying operating and abandoned facilities
   with petroleum product storage
•  Locations of active/inactive tanks in the area
•  Records of past leaks on site
•  Precision testing results
•  Inventory and repair records
•  Records of any water pump-outs from the tank(s)
•  Observations by fire department and other local officials
•  Information on past ownership and site uses (refer to old maps and
   atlases)
•  Equipment installation and maintenance data
•  Data from leak detection systems installed on suspicious tanks
•  Well logs from on-site or nearby monitoring wells or water supply wells
•  Boring logs from engineering studies
•  Interviews with employees and neighbors
          3.2    Has a site inspection been conducted to observe site
                conditions?
                A site inspection may reveal information regarding:
                •  Evidence of leaks, spills or overfills (e.g., stained soils
                   and irregular vegetation patterns);
                •  Tank locations upgradient and upstream of sewer or
                   conduit flow;

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                                            EXHIBIT 4
                               Sample Tank Inventory Record
                                                                                       *'/
                                                                        Tank ID ^/Capacity
                                                                        Product    Unleaded.

                                                                        Month/Yr    IO
                                                                        Operator

Cotunm 1
0*y
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31

2
Opening
Dipstick
Inventory
(galore)
3001
37SV
3/63
763/
7/V3
&636
&Z.67
791?
*?V27
V6V7
^936
3977
3V26
7
Closing
Dlpsdok
Inventory
(Inches)
33 '/2
2S'/z
2V
75
73
67 Vi
6/
77 Vz
70'/z
V7
V/
3^
3V '/2
6>fr
(p/
76 Vz
77
Vg'/z.
W
vo
3V '/i
80
7V
70
6fo'/z
6/'/z
7*/
72
^7V2
^2Vz
39
8
Closing
Dipstick
Inventory
(galons)'
2^92-
/99Y
Iftoto
69S/
&7V6
toO 27
7376
VSC7
V276
3903
3268
Z97V
Z5V2
f879
7376
*/9/^
V3Z9
V0&V
37»V
3/fi>3
Z793
7/V3
6>6>36>
6Z67
79 2g
7V2?
V6V7
W36
3977
3V26
30*58
9
QoneFrom
Tank
(column 6)
minus
(column 8)
7/V
H9S
V28
773
V37
72/
&V9
77/
729
37J
637
3/V
V/Z
^76
7£>3

3V
VV
2-73
307
8
5/
/07

         Charts converting dipstick readings (in inches) to gallons are specific for each type and size of tank. Consult
         the manufacturer for the appropriate chart if it is not already provided.


                                           Source: ICFInc.
12

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                   •  Evidence of other possible sources of contamination at
                      surrounding facilities (see Exhibits 5 and 6);

                   •  Recent excavation or signs that a tank or piping system
                      has been repaired;

                   •  Water in the underground tank; and

                   •  Evidence of free product or dissolved constituents in
                      samples from drinking water wells, observation wells (if
                      available), collection sumps, or surface water.
Vapors and liquids from petroleum releases may not always be detectable in
subsurface structures or in wells depending on the site-specific geology,
hydrogeology, and recent weather conditions. For example, a gasoline spill in
low permeability soil, such as clay, where depth to ground water exceeds 10 feet,
may not appear for over a month. Rain can also sometimes mask the presence of
contamination. As a result, it may be prudent to resample suspected locations
on more than one occasion, i.e., after the aquifer system is expected to have
returned to equilibrium. In general, the more permeable the soil, the more
quickly it will return to relative equilibrium and yield representative data
following precipitation.
             3.3    If review of available information has failed to con-
                   firm the source, has a tightness test been performed
                   on tanks and underground lines?

                   Due to the numerous types of tank tests available, it is
                   necessary to evaluate a proposed test method based on its
                   performance claim. It should be noted, however, that the
                   accuracy of tank tests is variable and may be influenced by
                   factors such as temperature, the elevation of the water
                   table, tank shell deformation, product evaporation, tank
                   and piping layout, wind vibration and noise, and operator
                   error.

                   Product levels, for example, can fluctuate in a tank due to
                   temperature disturbances that occur from opening the fill
                   hole, the addition of product, and tank deformation. There-
                   fore, it is important that there is an adequate waiting
                   period to allow stabilization prior to starting a tank test.
                   As a result of the variability, tank test results often cannot
                   be considered to be conclusive and are best used in conjunc-
                   tion with the other available evidence such as historical
                   records and available field data.
                                                                 13


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                                               EXHIBITS
                               Types of Facilities with Petroleum USTs

                    The following facilities often store petroleum products on site:
                    •  Service stations (existing, abandoned, or converted)
                    •  Automobile dealerships and auto repair garages
                    •  Municipal garages
                    •  Fleet operators such as taxicab companies, bakeries, dairies, contractors,
                       bus companies
                    •  Industries, including refineries, terminals, and bulk plants
                    •  Commercial operations (e.g., convenience stores, cleaning
                       establishments), airports, schools, hospitals
                    •  Abandoned oil and gas well sites
                    •  Subsurface disposal systems (including drywells and deep injection wells)
                    •  Machine shops
                    •  Salvage yards
        Stopping Free Product Flow
        Step 4    Has the flow of free product into the environment been stopped?
                             Stopping the flow of product often requires the following steps:
                             •  Shutting off product dispensing equipment (pumps and valves)
                                during repair or replacement;
                             •  Removing product from the tank and the lines;
                             •  Monitoring and recording the amount and flow of product
                                during suspension of use; and
                             •  Shutting off power sources as necessary.
•BKBHffi H

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                                                          EXHWT6

                                  Identifying Possible Sources of Contamination
1
1 / \
•^T*» Vacant Lot /V^ }
A f *<* (
( (possible )
Airport Potential Source 	 » spBI location) /
(less Ikely potential '~"A. -^^
source due to location)
1 Property Line
. 1 	
Gas Station O £3*5-.
01 • (Potent'al source) Q
Tank " '" |
m- m- m- h — , ' >
Pump Islands 1 - - - ^r
m- m- m- — •• jf

/
Assu
Direct
Grounc
Fh
Potential Sources
Salvage T^^%. O ^
Yard ^^E/Q ^f?
Automobiles ^^^ ^u ^nma
S ._.
' GaS Station O Concrete Pad
(potential source) Q Cover lor USTs
mod '
Wrtor : W- ii- » r - - '
3W Pump island
                                                 (possible conduit for product transport)
                                                                                           MAIN STREET
   Residence
    (no vapors In
     basement)
(shallow)
Drinking water
 wells. Slight
odor detected In
 shallow wed.
                         Residence
                           (vapors in
                           basement)
 Heating
  Oil
 Tank
entlal source)
Residence
 (no vapors in
  basement)
                                    Contaminated Site
                                        Jackson Creek
                              (Potential lor surface water contamination from surface
                               run-off a discharge of contaminated ground water)
                                             Shallow Well

                                          (no odors detectable)
                                                        Source:  ICFInc.

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Vapor Migration
Step 5   Has a determination been made as to the need for vapor
          migration control, collection, and treatment?

                      Hydrocarbon vapors and released petroleum products often enter
                      confined structures such as buildings, sewers, telephone vaults,
                      other utility lines, and tunnels.  If vapors and/or liquids have been
                      detected, a recovery system may be needed near the point of entry
                      to intercept the product or vapors before they enter the confined
                      structure.

                      Either passive or active vapor control systems may be selected
                      depending on site-specific conditions (see Appendix A). Vapor
                      control can extend over a substantial period of time, however, it is
                      often necessary to determine the need for it, and begin the process
                      during the initial response stage.
         Structures and human health must be adequately protected during implemen-
         tation of vapor control. Precautionary measures may entail isolating the area of
         concern, ventilating with equipment having explosion-proof motors and gears,
         and eliminating and/or controlling ignition sources.
Potentially Affected Community
Step 6   Has the potentially affected community (e.g., nearby well owners)
          been identified?

                      Before deciding if provision of alternative drinking water supplies
                      is necessary, inspectors may need to complete or review an assess-
                      ment of groundwater use.

                      6.1    Has information on the number, location and depth
                            of public and private wells, and the number of
                            people connected to these supplies been evaluated?

                            This step may involve the following:

                            •  Reviewing available zoning or property plans for the
                               nearby area to determine the location of residences,
                               businesses, and municipal wells;
   16
   ***

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                            •  Reviewing local Public Works and/or Water Department
                              records to identify other potential well users;

                            •  Conducting a field survey in the vicinity of the site (i.e.,
                              drive around neighborhood) to identify any other poten-
                              tial users;

                            •  Reviewing available well logs to determine the depth
                              and rate of pumping for the identified wells;

                            •  Reviewing Health Department records for complaints
                              registered for petroleum odor or taste in the area's
                              water; and

                            •  Surveying possible owners of wells and sampling their
                              wells for evidence of contamination.

                     6.2    Based on the extent of contamination, has a determi-
                            nation been made as to whether or not water sup-
                            plies need to be replaced or treated?

                            The following measures may need to be conducted in order
                            to make this determination:

                            •  Collecting water samples from the well or tap for analy-
                              sis (i.e., testing for volatile organic compounds and/or
                              petroleum hydrocarbons depending on the type of prod-
                              uct — see Chapter III, Scenario B, Step 4); and

                            •  Evaluating the analytical data using available State
                              and Federal drinking water criteria.
Alternative Drinking Water Supplies
Step 7    Have alternative drinking water supplies been provided?

                     Depending on the extent of contamination and the feasibility of
                     aquifer restoration, a temporary and/or emergency water supply
                     may be needed until a permanent alternative is found or until the
                     existing supply is restored.

                     7.1    Has a plan been initiated to determine how to inform
                            residents of potential problems with their water
                            supplies?

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                      7.2    Have measures been taken to provide a temporary
                             alternative water supply (if applicable)?

                             This may include using one of the following techniques:

                             •  Providing bottled or bulk water;

                             •  Providing point-of-entry home treatment units (e.g.,
                                carbon adsorption systems); and

                             •  Installing rainwater collection systems.
          In general, if aquifer restoration can be accomplished within a few years,
          provision of temporary point-of-entry home treatment units may be practicable.
          As an initial response, point-of-entry systems or bottled sources will probably be
          required for a limited period of time before implementation of a permanent water
          supply. If aquifer restoration is not feasible in a reasonable timeframe, then a
          permanent alternative water supply should be developed as a long-term measure
          during remediation of ground water (see Chapter HI, Scenario C, Step 8).
Containment of Free Product
Step 8   Has the containment of free product been initiated?

                      During the initial response to a release, free product may be
                      encountered in sumps, tank pits, sewers, basements, elevator
                      shafts, subway tunnels, telephone manholes, or seeping to surface
                      waters. In such cases, containment of free product can be initiated
                      as an interim measure until the limited site investigation can be
                      completed.

                      Where seepage discharge to small streams occurs, the use of
                      berms, dikes, booms, and/or sorbent materials may be used to
                      contain the product. If free product has contaminated a river or
                      large stream, the spill should be monitored to predict if and where
                      it will reach the shore. Once this occurs,  the floating spill can be
                      contained with a boom. Encircling booms are useful when floating
                      free product has contaminated a slow-moving body of water (e.g.,
                      lake, lagoon, pond, or large river). Recovery of free product is most
                      often achieved by one of several pumping methods. See Chapter
                      in, Scenario C, Step 6 for a discussion of longer-term free product
                      removal from ground water.

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Security of Site
Step 9   Has the site been sufficiently secured?
                      Sites often need to be secured to prevent unauthorized entrance
                      and vandalism, particularly on abandoned sites and those with
                      open excavations. Security measures may include the following:
                      tightly closed and properly stored drums of recovered product and/
                      or absorbent materials; plastic covers over any excavated soils;
                      gates, buildings, and equipment locked; fencing or brightly colored
                      tape around excavations and at entrances; and notices posted as
                      warnings for the public.
Reporting Requirements
Step 10  Have all site activities been reported in accordance with State
          and Federal requirements?

                      Inspectors should ensure that owners/operators comply with State
                      and Federal reporting requirements concerning initial response to
                      petroleum UST releases. The requirements usually include provi-
                      sions for reporting all suspected and confirmed releases, completed
                      and planned initial response activities, and any resulting informa-
                      tion and data.

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                                                  SITE EVALUATION CHECKLIST
                                                              INITIAL RESPONSE
SITE NAME/ID*:

SITE COORDINATOR:
Step 1:   Has information on site history, tank usage, and impacts of
         the release been compiled by an inspector or contractor?
         (Use Worksheets 1 and 2.)

Step 2:   Have fire and safety hazards been identified, monitored,
         and mitigated?

Step 3:   Have the source and cause of the release been satisfactorily
         identified?

Step 4:   Has the flow of free product into the environment been
         stopped?

Step 5:   Has a determination been made as to the need for vapor
         migration control, collection, and treatment?

Step 6:   Has the potentially affected community (e.g., nearby well
         owners) been identified?

Step 7:   Have alternative drinking water supplies been provided?

Step 8:   Has the containment of free product been initiated?

Step 9:   Has the site been sufficiently secured?

Step 10:  Have all site activities been reported in accordance with
         State and Federal requirements?
                                                                  Date Completed/
                                                                     By Whom
        Note:  Not every task may be applicable in all situations, and the sequence of
              steps will vary somewhat from site to site.
                                                                         21

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              III. LIMITED SITE INVESTIGATION
This chapter presents three scenarios that correspond to the
severity of contamination which may be found at various sites.
Scenarios may also evolve sequentially at one site (that is, results
of one scenario may lead the investigation into the next scenario).
The three scenarios discussed in this chapter are:

•  Scenario A:   Minimal Soil Contamination

•  Scenario B:   Extensive Soil Contamination

•  Scenario C:   Groundwater Contamination

The decision as to what constitutes minimal soil contamination as
compared to extensive soil contamination rests with the imple-
menting agency.  To select the appropriate scenario, it is impor-
tant to review the available information from the Worksheets, the
results of the initial response tasks, field observations, site history,
hydrogeology, soil characteristics, and other site-specific data. See
Exhibit 7 for descriptions of the type of site that may fall under
each scenario. For determining the magnitude of potential
impacts to soil and/or ground water, see Exhibit 8 which illustrates
the general interrelationship between soil permeability and
adsorptive capacity. (Additional information on one method to
determine transport of contaminants is presented in Appendix B.)

The key to the limited site investigation process involves ongoing
questioning and reevaluation of assumptions about site conditions.
Typical questions to ask during the process include:

•  Have all of the potential sources of contamination been
   identified?

•  What additional information could be obtained and reviewed?

•  Based on the new information received, are the owner/opera-
   tor's or contractor's assumptions true?
                                                   23 Y_l

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                                                                   IIBIT7
                                                         Selecting a Scenario
  Scenario A — Minimal Soil Contamination
Scenario B — Extensive Soil Contamination
  Scenario C — Groundwater Contamination
Leaks or spills suspected to have occurred
recently

Only small quantity release suspected

Presence of low permeable soils is expected to
have minimized migration

Field screening indicates low concentrations
present in soils

Visual observations of discoloration at surface
or during excavation. Failure of tank or piping
tightness test
Failure of tank or piping tightness test

Discrepancy in inventory

Leak suspected due to age of tank or evidence of
a previous underground storage tank leak

Field screening indicates positive reading above
designated background levels*. Groundwater
contamination observed during excavation of
leaking tank or piping
Groundwater contamination observed during
excavation of leaking tank or piping

Observations and records indicate significant
loss of product

Odors detected in drinking water near source

High permeability of natural soils and/or high
water table*
* NOTE: High readings in soils with low permeabilities (e.g., >100-1,000 ppm in clays) may indicate only localized contamination, whereas lower readings in
high permeability soils (e.g., 10-50 ppm in sand and gravel) could indicate that contamination has rapidly migrated to greater depths.
                                                              Source: ICF Inc.

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                             EXHIBITS

               General Considerations Determining
                  Magnitude of Potential Impacts
General Curve for Adsorptive Capacity versus Permeability
             HIGH
     RELATIVE
   ADSORPTIVE
     CAPACITY
             LOW
                      HIGH
                    (GRAVEL)
                                 PERMEABILITY
 LOW
(CLAY)
General Curve for Impact to Ground Water
             HIGH
    IMPACT TO
      GROUND
       WATER
             LOW
                      LOW
                    (GRAVEL)
 HIGH
(CLAY)
                          RELATIVE ADSORPTIVE CAPACITY
                    Source: Groundwater Technology Inc.
                                                                        25

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          SCENARIO A.  MINIMAL SOIL CONTAMINATION
Sites addressed under this scenario are locations where evidence
gathered during initial response and a review of the site history
indicate that minimal contamination to the soil has occurred. For
example, minimal soil contamination may be expected in those
cases where a release is recent and consists of a small quantity of
product. In this scenario, inspectors may need to ensure that the
following activities are conducted:

•  Identification of locations of minimal soil contamination;

•  Soil screening for hydrocarbon vapors to confirm the presence
   of minimal contamination or the need to continue to
   Scenario B;

•  Management of contaminated soil (if necessary); and

•  Submission by owner/operator of all information relating to the
   cause of the release and the status of the site to the State.
The need for some, or all of these steps is contingent upon
the site-specific situation.
                                                  27

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Locations of Contamination
Step 1   Have all of the locations of minimal soil contamination been
          identified?

                      The identification of these areas may be based on visual observa-
                      tions of discolored or saturated soils, detectable odors, and/or
                      knowledge of historical activities (e.g., soils near a gas pump).
                      Such evidence may be gathered during the initial response phase
                      of a cleanup, and during the excavation and removal of a tank and
                      lines. Tanks are often removed as a provision of a real estate
                      transaction and are frequently the reason minimal contamination
                      is discovered. (For more information on tank removal, closure or
                      repair activities, see Appendix C.)
Soil Screening
Step 2   Have the soils been screened for hydrocarbons to confirm the
          presence of minimal contamination or the need to continue to
          Scenario B?

                      Field screening for hydrocarbons in soils can provide valuable
                      information to help verify that only minimal contamination is
                      present. Soil screening is typically accomplished by conducting a
                      soil gas survey or by collecting shallow soil samples and testing
                      them in the field. Soil gas surveys involve making a small
                      diameter hole and either inserting a detection meter probe into the
                      hole or extracting a vapor sample for screening. Shallow soil
                      samples can be collected using a trowel, bucket auger, or shovel.

                      The following four factors can affect the accuracy of soil screening:

                      •  Selection and operation of the detection meter;

                      •  Consistency of screening procedures;

                      •  Number and location of soil samples; and

                      •  Interpretation of the results.

                      Details on these four factors are discussed in Substeps 2.1 to 2.4.
   28

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             2.1    Has the appropriate type of instrument been
                   selected based on anticipated concentrations?

                   See Exhibit 2 on page 9 for a list of types of meters. To
                   some extent, meter selection will be dictated by State
                   preferences, sensitivity requirements, and general equip-
                   ment availability.
The quality of the data is extremely variable depending on equipment
maintenance, calibration, its operator, and climatic conditions. To obtain good
quality data, the equipment manufacturer's instructions for maintenance and
calibration should be carefully followed.
             2.2    Have sampling procedures been consistent at the
                   site?

                   The soil gas survey method is most frequently used for
                   larger areas where more significant contamination is sus-
                   pected. Hence, more detailed discussion of this method is
                   presented in Scenario B, Substep 3.1.

                   Shallow soil samples can be collected in a number of ways.
                   More important than the type of equipment used, however,
                   is the  consistency of the procedures across the site. (This
                   ensures that the data can be compared.)
One example of a soil sampling method is as follows:

Soil is placed in a precleaned, airtight, glass jar and filled to approximately two-
thirds of capacity. Screening procedures are as follows:

•  Close the jar tightly;

•  Place it in an area of controlled temperature;

•  Shake the jar vigorously after it reaches room temperature (approximately
   15 minutes); and

•  Place the indicator probe in the jar to measure the concentration of organic
   vapors.

Other methods for screening samples include:

•  Puncturing a hole in the jar lid to extract a known volume of sample with a
   needle (then injecting the needle into the detection meter); or

•  Immediately after sampling, covering the jar with foil and then capping it.
   When it is time to screen the sample, the cap is removed and the probe is
   inserted through the foil.

Precautions  need to be taken to prevent the volatilization of contaminants from
the sample.  In those cases where soil samples are allowed to aerate or are
placed in warm locations, screening results will not be an accurate reflection of
the actual level of contamination.
                                                                29

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                      2.3   Have the number and the locations of soil samples
                            been sufficient for the specific site conditions?

                            In general, samples are collected directly from the identified
                            contaminated area and from one or more background
                            locations around the perimeter of the release. By comparing
                            the results from each of the locations, an evaluation can be
                            made as to the relative amount of contamination.  (State
                            agencies may have specific policies on this matter.)

                            Samples obtained from tank removal excavations are
                            usually collected where soils are discolored and where the
                            backfill and the native soil meet. Additionally, soil may be
                            sampled at the following locations within the excavation
                            pit: the bottom center where stick testing may have worn
                            through the tank, near the soil surface, and at the area
                            previously adjacent to the fill end of the tank.

                      2.4   Have hydrocarbon vapor test results been correctly
                            interpreted?

                            If test results show minimal contamination — based on
                            State guidelines and/or the presence of such small amounts
                            so as not to be a threat to human health and the environ-
                            ment — soils may need to be managed as described in
                            Step 3. Following soil management, a repeat of soil screen-
                            ing may need to be conducted to confirm that cleanup was
                            adequate.

                            If test results show significant soil contamination, as deter-
                            mined by the implementing agency, the investigation
                            should proceed to Scenario B.
Minor Soil Contamination Management
Step 3   Has minor soil contamination been managed?
                      If soil contamination is minor and the release will be controlled
                      upon completion of this scenario, contaminated soils may be left in
                      place or excavated for disposal or treatment on or off site. Follow-
                      ing removal or treatment, another soil screening test is usually
                      conducted to verify that minor contamination is no longer present
                      on site.

                      Managing soils in this scenario generally involves small scale
                      removal and treatment operations as described in Scenario B, Step
                      6 and in Exhibit 14 on page 47. Those methods most applicable to
   30

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                      this scenario include: leaving small quantities of soils with low con-
                      centrations on site to degrade naturally; excavating and removing
                      small quantities of soils with relatively high concentrations for off-
                      site disposal (e.g., at landfills or asphalt batching facilities); and
                      using enhanced volatilization and soil venting for large quantities
                      of soils with lower concentrations of total volatiles.
Reporting Requirements
Step 4    Have owners/operators submitted all information relating to the
          cause of the release and the status of the site to the State?

                      Owners/operators should comply with existing State and Federal
                      reporting requirements concerning petroleum UST releases. At
                      this stage of the process, owners/operators will likely be required
                      to report all information on the cause of release, the estimated
                      quantity of product released, the surrounding population, subsur-
                      face soil conditions, and locations of drinking water wells.
                                                                        31

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                                                 SITE EVALUATION CHECKLIST
                                SCENARIO A. MINIMAL SOIL CONTAMINATION
SITE NAME/ID#:

SITE COORDINATOR:
Step 1:   Have all of the locations of minimal soil contamination been
         identified?

Step 2:   Have the soils been screened for hydrocarbons to confirm the
         presence of minor contamination or the need to continue to
         Scenario B?

Step 3:   Has minor soil contamination been managed?

Step 4:   Have owners/operators submitted all information relating to
         the cause of the release and the status of the site to the State?
                                                                Date Completed/
                                                                   By Whom
       Note: Not every task may be applicable in all situations, and the sequence
             of steps will vary somewhat from site to site.
                                                                       33

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        SCENARIO B.  EXTENSIVE SOIL CONTAMINATION
An example of a Scenario B site is a location where a significant
quantity of product was released relatively recently in permeable
soils, and the contaminants have migrated through the subsurface
with the percolation of rainwater.  Alternatively, a release of
product over time in less permeable soils (i.e., silts and clays) may
also result in extensive soil contamination, since contaminants
tend to adsorb to the material and migration to ground water may
be limited. When information from the initial response and/or
Scenario A activities reveals evidence of extensive contamination
to soils, the inspector may consider the following:

•  Identification of potential release sources, suspected areas of
   contamination, and site conditions;

•  Preparation for field operations;

•  Preliminary screening to confirm the presence of vapors and to
   identify areas of highest contaminant concentrations;

•  Collection of subsurface soil samples to determine the vertical
   extent of contamination;

•  Evaluation of soil data to determine the extent of soil
   contamination and the need to continue to Scenario C;

•  Source control (if applicable) and soil management; and

•  Submission of information concerning the cause of the release
   and the status of the site to the State.
The need for some, or all, of these steps is contingent upon
the site-specific situation.
                                                   35

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Potential Sources, Suspected Areas of Contamination, and Site Conditions
Step 1    Prior to initiating field work, have all potential sources,
          suspected areas of contamination, and site conditions been
          identified?

                     In order to evaluate a field program, inspectors need to understand
                     a site's hydrogeologic conditions to help determine release sources
                     and suspected areas of contamination. Worksheet 3 provides an
                     outline of the type of information that could be reviewed in the
                     beginning of this scenario. This is also a good time to review
                     information gathered during Initial Response activities (see Chap-
                     ter II, Step 3) and information gathered during the activities
                     undertaken in Scenario A.
Field Preparation
Step 2    Have adequate field preparation measures been taken by
          contractors and oversight personnel?

                     Failure to adequately anticipate site conditions and prepare for
                     field operations may result in costly delays or errors. For example,
                     sampling locations should be sited to avoid underground utilities.
                     See Worksheet 4 for information on field preparation. Delays can
                     often be prevented if the involved parties are aware of the impor-
                     tance of careful planning before initiating field work.
         It is important that all of the involved parties maintain complete field notes.
         (See the Site Inspection and Telephone Logs accompanying Worksheet 1.) These
         notes provide the foundation for numerous project management activities such
         as budget tracking and report writing and can sometimes provide important
         materials in legal disputes.
Initial Screening
Step 3    Has initial screening been conducted to confirm the presence of
          vapors in soils and to identify areas of highest contaminant
          concentrations?

                     Initial soil screening methods may be used to further narrow the
                     set of potential sources of a release and to help locate subsequent
                     soil sampling points. The basic screening methods are the same as
                     those described in Scenario A, Step 2 on page 28, and include soil
                     gas surveys and shallow soil sampling.
   36

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                Soil gas surveys measure the hydrocarbon vapors in the unsatu-
                rated (vadose) zone and are useful at this stage of an investigation
                to characterize a large area. As noted in Scenario A, the survey
                involves making a small diameter hole and either inserting a
                detection meter probe into the hole, or extracting a sample and
                analyzing it on or off site (using an FID, PID, explosimeter, or
                Draeger tubes).

                Shallow soil samples can be collected to confirm the presence of
                contaminants in locations identified during the soil gas survey.
                Typically, these shallow samples are collected below the vegetative
                mat from depths ranging between 0 and 4 feet.


                3.1    Has the soil gas survey been designed for
                      site-specific conditions?

                      Design considerations may include the following:

                      •  Spacing of sampling grid — close spacing is better in
                         dense, clayey materials;

                      •  Depth of holes — deeper holes (e.g., over 4 feet) may be
                         necessary depending on thickness of soils; and

                      •  Testing methods — on-site analyses can provide imme-
                         diate results (or "real-time" results) which can be useful
                         during the layout of the grid.
   Soil gas surveys have several limitations that may need to be considered. For
   example, they are not as effective when the samples are taken at a distance from
   the source. They are also most reliable in permeable soils and have limited
   effectiveness in clayey soils. Furthermore, soil gas surveys can have limited
   results detecting older plumes whose more volatile compounds may have either
   evaporated, dissolved, or degraded.
V	..
                3.2   Have shallow soil samples been obtained from
                      strategic locations using an appropriate sampling
                      technique?

                      To ensure that accurate, representative data is gathered,
                      an inspector may want to check that the following occur:

                      •  Using techniques described in Scenario A, Step 2;

                      •  Selecting sampling locations so as not to miss areas of
                         potential contamination (e.g., near tank Lines and fill
                         pipes);

                                                                   37

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                             •   Recording odors and/or other observations in the field
                                log; and

                             •   Avoiding cleaners (e.g., solvents or gasoline) that could
                                contaminate samples when cleaning the sampler or
                                equipment.
Subsurface Soil Sampling
Step 4   Have subsurface soil samples been collected to determine the
          vertical extent of contamination?

                      Subsurface soil sampling is important because it provides informa-
                      tion on soil characteristics necessary to estimate contaminant
                      migration pathways, the depth to the water table, and the poten-
                      tial impact to ground water. Additionally, the data can be used to
                      estimate the volume of contaminated soil which is useful when
                      selecting clean-up alternatives.

                      Typically, field screening methods are used during soil sampling,
                      although in some cases,  laboratory analyses may be desired. See
                      Exhibit 9 for more information on laboratory analyses and Exhibit
                      10 for examples of analytical options available for collected
                      samples.

                      Some of the devices available for subsurface soil sampling include
                      backhoes and clamshells for excavating test pits, and bucket
                      augers, hollow stem augers, and other drilling methods for soil
                      borings. (See Exhibit 11 for a summary of drilling methods.)

                      4.1   Have the following general sampling procedures
                            been used for collecting subsurface soils from test pit
                            excavations?

                            •  Obtaining samples by using a clamshell or a backhoe
                               (since entering an open excavation is hazardous);

                            •  Collecting soil sample(s) from designated depths and
                               locations of changes in strata;

                            •  Using the general procedures described in Substep 3.2
                               of this scenario and in Scenario A, Step 2;

                            •  Using a field screening meter to measure hydrocarbon
                               vapors in the  headspace of soil jars; and

                            •  Completing test pit field notes, including information on
                               location,  orientation, and dimensions of excavation, as
                               well as soil stratigraphy and screening results.

   38

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                                     EXHIBITS
                         Laboratory Analysis of Samples
Field screening for hydrocarbon vapors provides enough information to determine the presence
of contamination and the relative concentration.  In many cases, screening information may be
sufficient for decision-making purposes, for example, when there is no uncertainty about the
type of contaminant (i.e., the source is from a known spill or identified leaking tank). There
are instances, however, when laboratory analyses may be desired during an investigation. For
example, analytical data from a laboratory may be used for the following reasons:

    •  To determine if a potable water supply has been affected and the need for an
      alternative water source;

    •  To identify contaminants that cannot be detected (or differentiated) by field screening
      techniques; and

    •  To meet State and local requirements (e.g., for verification of a cleanup).

Given the cost and time associated with laboratory  analyses, it is important that certain meas-
ures are taken to ensure accurate results.  In order to avoid resampling (which results in
unnecessary delays and expenses), inspectors should be aware of the following common mis-
takes and possible solutions:
                  Mistakes
            Solutions
      Selection of inappropriate type of
      analysis
Consult with the laboratory and exist-
ing guidelines for recommended analy-
ses. See Exhibit 10 for a summary of
some common analytical options
      Use of improper container and pre-
      servative
Consult with laboratory and use con-
tainers that they have approved and/or
provided
      Samples unusable due to breakage or
      cross-contamination
Collect duplicates or triplicates; place
field blank in storage container with
samples
      Samples unusable due to improper
      storage and excessive holding time
Arrange with laboratory ahead of time
for analysis to be run as soon as pos-
sible after delivery; store samples in
ice-filled cooler immediately following
collection
      Analytical results indicate improper
      labellin  or samle misidentincation
Label samples very carefully in the
field and; carefully fill out chain of
custody forms prior to delivery to the
laboratory
                                    Source:  ICF Inc.
                                                                                    39

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                                                                                           QlMriO
                                                                               Analytical Options
          ANALYTICAL METHODS
                                                          GENERAL DESCRIPTION
                                                                                                              APPLICABILITY
                                                                                                                                                                LIMITATIONS
TOTAL PETROLEUM HYDROCARBONS
(TPH, PHC, or TRPH — for recoverable
hydrocarbons)
 1 Uses GC/FID analysis to measure concentration
  of total petroleum hydrocarbons extracted from
  sample using a solvent

 ' Must specifically request "fingerprint" analysis
  for identification of types of petroleum
  hydrocarbons
• Can be used to analyze water and soil samples

• Most applicable for determining presence of oils
  (i.e., fuel oil, waste oil)

• Can provide information on "weathered" product

• Should specify if analysis of dissolved fraction of
  ground water is desired
• Need to specify to laboratory the type of data
 desired

• Possible to use to identify presence of gasoline
 product but loss of gasoline can occur during
 extraction

• Identification of product types can be approxi-
 mate unless samples of pure product (i.e., from
 the suspected source) are analyzed
INFRARED
(IR—EPA Method 418.1)
 1 Measures concentration of total petroleum
  hydrocarbons extracted from sample using freon
• Can be used to analyze water and soil samples

• Most applicable for determining presence of oils

• Can be used to measure lighter oils
• Does not provide identification of types of hydro-
  carbons

• Subject to interference since analysis also
  measures non-petroleum hydrocarbons
  (e.g., organic acids)

• Possible for gasoline sites, however, up to 1/2 of
  total gasoline concentration of the sample can be
  lost during extraction
OIL AND GREASE (Standard Method 603)
• Measures weight of oil and grease extracted
  from sample using freon
• Can be used to analyze soil and water samples

• Better for heavy oils
• Inappropriate for gasoline or oils with volatile
  fraction (e.g. waste oils with solvent contamina-
  tion) due to loss of volatiles during extraction
GAS CHROMATOGRAPHY (GC)
(EPA Method 602-water; EPA Method 6020-soil)
• Measures purgeable aromatics (volatile fraction)
  using purge and trap method

• Provides data on benzene, toluene, ethyl
  benzene, and total xylenes (BTEX). (May need
  to request xylene data specifically.)

• Compound I.D. is not definitive, i.e., compared to
  mass spectrometry (MS) results which are
  verifiable
• Good for gasoline

• Can detect some solvents in waste oils
 1 Not optimum for fuel oils, particularly heavier
  oils, since those compounds lack significant
  volatile fractions
GC
(EPA Method 601-water, EPA Method 8010-soil)
1 Measures purgeable halocarbons using purge
 and trap method

1 As with Method 602, compound I.D. cannot be
 confirmed
' Best for detecting presence of solvents in waste
 oils
• Not applicable for petroleum hydrocarbons

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                                                                                 EXH
                                                  10
                                                                            Analytical Options
                                                                                   (continued)
         ANALYTICAL METHODS
         GENERAL DESCRIPTION
                                                                                                          APPLICABILITY
                                                                                                                                                         LIMITATIONS
GC/MASS SPECTROMETRY (MS)
(EPA Method 824-water, EPA Method 8240-soil)
• Measures purgeable halocarbons and aromatic*

• Provides positive identification of BTEX
 constituents
' Most applicable for gasoline
1 Not optimum Tor fuel oils (particularly heavier
 oils) since those compounds lack significant
 volatile fraction
GC/MS (EPA Method 625-water;
EPA Method 8270-eoil)
• Measures acid extractable semi-volatile organic      • Applicable for sites with diesel oil contamination     •  In general, limited applicability at petroleum
 compounds                                                                                   UST sites
LEAD (EPA Method 239.2 or
Standard Method 304)
• Measures concentration of metal extracted using
 a slightly acidic distilled water solution
• Can be used for water and soil samples

• Generally used for gasoline

• Also applicable for waste oils
1 Data on lead concentration in background
 samples useful to assist with interpretation
     NOTES:
                  however, they are typically only used for analyzing soils.
                                                                                                                    For UST sites,
                  There is currently no one standard method available for quantitative identification of petroleum products in soil and water samples, therefore, it is important to work closely with a
                  laboratory when selecting analytical methods for a specific site.
                                                                          Source: Adapted by ICF Inc.

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                                                                                      [EBIT 11
                                                                        Well Drilling Methods
DRILL TYPE       NORMAL DIAM.    MAX. DEPTH
                  HOLE
                                    AVERAGE TIME   NORMAL EXPENSE
                                    PER HOLE
                                 ADVANTAGES
                                                      DISADVANTAGES
1. Rotary
4--20"
                                    Unlimited
                                    Fast
Expensive
1. Good for deep hotel
2. Can be vised in soils and relatively soft rock
3. Wide availability
4. Controls caving
1. Need to use drilling fluid
2. Potential bore hole damage with drilling fluid
3. Requires drilling water supply
2. Stem Auger      4"-8"
                                    30-50 a.
                                    Fast under suitable   Inexpensive to
                                    soil conditions       moderate
                      1. Widely available
                      2. Very mobile
                      3. Can obtain dry soil samples while drilling
                                         1. Difficult to set casing in unsuitable soils (caving)
                                         2. Cannot penetrate large stones, boulders, or bed rock
                                         3. Normally cannot be used to install recovery wells
3. Hollow Stem      4"-8"
  Auger
                                    30-50 ft
                                    Fast under suitable   Inexpensive to
                                    •oil conditions       moderate
                      1. Good for sandy soil
                      2. Can set casing through hollow stem
                      3. Very mobile
                      4. Can obtain dry soil samples and split-spoon
                        samples
                      5. Controls caving
                                         1. Casing diameter normally limited to 2"-3* outside
                                           diameter
                                         2. Cannot penetrate large rock, boulders, or bed rock
                                         3. Limited availability
                                         4. Normally cannot be used for recovery wells
4. Kelley Auger     8'-48"
0. Dug Wells       Unlimited
                                    90ft
                                                      Fast
                                                     Moderate to expensive
                      1. Can install large diameter recovery wells
                      2. Drills holes with minimum soil wall
                        disturbance or contamination
                      3. Can obtain good soil samples
                                         1. Large equipment
                                         2. Seldom available in rural areas
                                         3. May require casing while drilling
5. Bncker Anger 12"- 72"
6. Cable Tools 4'- Iff
7. Air Hammer 4M2"
8. Casing Driving 2"-24"
(well point)
90 ft Fast Moderate to expensive
Unlimited Slow Inexpensive to
moderate
Unlimited Fast Expensive
60 ft Slow to moderate Inexpensive
1. Can obtain good soil samples
2. Can install large diameter recovery wells
1. Widely available
2. Can be used in soil or rock
1. Fast penetration in consolidated rock
1. Very portable
2. Readily available
1. Hard to control caving
2. At times must use drilling fluid
3. Normally very large operating area required
1. Slower than other methods
2. Hole often crooked
3. May require casing while drilling
1. Inefficient in nnconsolidated soil
2. Very noisy
3. Control of dust/air release
4. Excessive water inflow will limit use
1. Limited to nnconsolidated soil - cannot penetrate
large rocks, boulders, bedrock
2. Difficult to obtain soil samples
3. Generally inefficient method to install recovery well
                  10-20 ft
                                                      Fast
Inexpensive
1. Readily available
2. Very large diameter hole easily obtained
1. Caving can be severe problem
2. Limited depth
3. Greater explosive hazard during excavation into
  hydrocarbons
    Source: Reprinted courtesy of the American Petroleum Institute, "Underground Spill Cleanup Manual" Publication #1628, First Edition, June 1980.

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STOP
It may be necessary to consider the following before using test pits at a site:

•  Test pits can disrupt normal site operations, and if left open, pose a safety
   hazard to persons and vehicles. Therefore, they are probably most applicable
   at large, undeveloped sites.

•  Test pits are of limited value where contamination is expected to extend
   below the reach of the equipment (i.e., generally 15 to 20 feet).

•  Volatilization of contaminants from open excavations can result in an
   increased short-term exposure pathway (e.g., to equipment operations).
     EXHIBIT 12
Split-Spoon Sampler
             4.2    When collecting samples from soil borings, have soil
                   sampling procedures been consistent?

                   A split-spoon sampler is one of the most common devices
                   used for collecting a soil sample from a soil boring or test
                   hole.  As depicted in Exhibit 12, the split-spoon is a steel
                   tube that can be opened to observe and collect an undis-
                   turbed soil sample. An inspector should be aware that
                   subsurface sampling involves the following general proce-
                   dures:

                   •  Collecting samples from designated intervals depending
                      on the desired information (e.g., every 5 or 10 feet,
                      continuously, or at strata changes);

                   •  Recording the number of hammer blows while the split-
                      spoon sampler is being driven to determine the density
                      or hardness of the soils;

                   •  Noting any loss of soil during sampling (that is, the
                      sampler may have penetrated 2 feet but only 1 foot of
                      soils may have been recovered);

                   •  Using a sharp edge to scrape across the length of the
                      sample, and noting any changes in strata;

                   •  Placing the samples in the proper containers immedi-
                      ately, capping them, and ensuring that they are air-
                      tight;

                   •  Placing all containers in an ice-packed cooler after sam-
                      pling until it is time to screen soils or send them to a
                      laboratory for analyses;
    PLASTIC BASKET
    (INSERTED IN NOSE
    OF SPOON TO PREVENT
    LOSS OF SAMPLE)
    Source:  ICFInc.
                                                                            43

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                               Classifying the soil type according to the designated
                               system, and noting any moisture, discoloration, odor, as
                               well as field screening results; and

                               Completing soil boring logs in accordance with standard
                               engineering practices associated with the particular
                               technique (see Exhibit 13). Include depth to ground
                               water if encountered during drilling.
Evaluation of the Extent of Contamination
Step 5   Have soil data been accurately evaluated in order to determine
          the extent of contamination and the need to continue to
          Scenario C?

                      The information on soil characteristics and contaminant concen-
                      trations (gathered during Steps 3 and 4 of this scenario) needs to
                      be compiled and evaluated in order to determine the lateral extent
                      of contamination. Information on the vertical extent of contamina-
                      tion and the depth to the water table can be used to determine the
                      likelihood of impact to ground water.

                      5.1    Did an evaluation of the soil data include the follow-
                            ing, if applicable?

                            •  If additional contaminants are found, determining
                         v     whether or not they represent an isolated occurrence  or
                               relate to a separate problem which may require addi-
                               tional investigation;

                            •  Comparing the screening and analytical results with
                               background samples from areas that are not suspected
                               of contamination;

                            •  Plotting the screening and analytical data on a site plan
                               to delineate the lateral extent of soil contamination; and

                            •  Determining if additional sampling is necessary based
                               on existing data gaps.

                      5.2    Did a determination of the potential impact to
                            ground water include the following, if applicable?

                            •  Determining depth to the water table from ground
                               surface based on observations from test pits or borings,
                               or estimates from local/regional hydrogeologic data;
   44

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    PlVHlKIT 13
Typical Boring Log
PROJECT/LOCATION
PAGE / OF 	 £_
CONTRACT CODE LOGGED BY
DRILLER DATE (START) H/2-8/«q (FINISH) 1 1/28/OT
BORING NUMBER M\V-/ BORING DIAMETER 3 3/s"
EQUIPMENT TYPE DRILLING FLUID USED IVON/E.
CASING , SAMPLER (joOn GROUND WATER
SIZE (H.TA) 33/S TYPESfl/ifSooon (2M') DATE Cf>mal?1,r,n TIME IkOO DEPTH /7.£>'
HAMMER Ib. HAMMER MO Ib. DATE / 2. /*7 7 5?9 TIME f /UA»/-^5DEPTH /? ?•
FALL
DEPTH
(FT.)
0-2
V-7
/0-/Z
/T-/7
20-22
27-27
30-32
FALL 3O~ GROUND "ELEVATION/DATUM
SMPL
S-l
5-2
5-3
5-V
5-6
5-7
REC.
2V
12"
2i'
BLOWS/6"
1*4 - ID
/ " O
/T 1^7
10-20
ZO-/8
10- 28
50-ZO
I-Z
3-6
DESCRIPTION
Med»uiTt c/finge, c)F&y i medium \
"to coarse. GRAVE. L
Loose. , qr*y. SILT and CLAY
Ifttk -fine. sand.
Medium dense, qray,5/l_T
doct CLAY, trace GRAVEL
Dense , white, medium to
Coarse. 5A/VD «9nc( GfZhrfeL,
UWe C/ayey Si/t
Vfry denSC , or&nCjC brovvn,
medium "to coarsfi S A/VO <9ic(
G^A V£TL , //tt/e ClayzySiH'
Soft , or&y , C^-AVe»no(
S/LT
Medium dense. qray CLAYandSlLT
BoTTom at 32 '

EQUIPMENT /J}
INSTALLED W
P


— ^
'.•'•'•'•
1
•X
O-IO'
0-lf
2-PVC
Riser
\0-I2'
Seal
p'i ftef
Pact

SCREENING RESULTS
/REMARKS /5)
(/>p *H J >**^
20
3
-f
0
0
0
SIGNATURE CHECKED BY

NOTES: 1. Wells were constructed innediately following drilling using a 2" diameter, schedule 40 PVC,
with .01" slotted screen, bentonite pellets, cement, and clean sand. All wells were
finished with a locking well cap and protective cover.
2. Field screening results represent total organic vapor levels measured with an HNu Model PI
101 phot oionizat ion detector, in the headspace of soil gas.
3. Grounduater encountered at 20' during drilling.
   Source: IGF Inc.
                                        45

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                            •  Developing a vertical profile showing soil stratigraphy
                               and contaminant concentrations from samples;

                            •  Considering other factors such as the solubility of the
                               contaminant, porosity and adsorptive capacity of the
                               soils, precipitation, and approximate amount of con-
                               taminant released (if known); and

                            •  Proceeding to Scenario C if impact to ground water is
                               likely to occur or may have already occurred.
Source Control and Soil Management
Step 6   Have effective clean-up measures been taken to control the
          source (if applicable) and to manage contaminated soils?
                      Source control most often involves removal of product from the
                      leaking tank system, tank removal, tank closure, or tank repair.
                      See Appendix C for more information on these activities. Once the
                      source of the release has been adequately controlled, soil manage-
                      ment usually begins.  Inspectors may need to ensure that the
                      following three basic steps have occurred in the soil management
                      process.

                      6.1   Has a determination been made as to what extent
                           soils need to be managed based on State require-
                           ments and criteria?

                           Examples of criteria used to determine cleanup include soils
                           that are saturated (as measured by a paint filter test) and
                           soils that exceed an established concentration level.

                      6.2   Have treatment or disposal methods been carefully
                           selected and implemented?

                           These options include excavation and disposal, enhanced
                           volatilization, soil venting, incineration, and biodegrada-
                           tion.  (See Exhibit 14 for general descriptions of these
                           technologies.)

                      6.3   Has the cleanup been confirmed to ensure that the
                           goals or criteria have been met?

                           This may involve verification sampling to determine if
                           treatment has met target clean-up levels as determined by
                           the State. Such levels  may be set based on background
                           conditions, established concentrations, or groundwater
                           criteria.
   46

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                                                                         Soil Management Options
        TECHNIQUE
             GENERAL DESCRIPTION
                                                                       ADVANTAGES
                                                                                                                         DISADVANTAGES
EXCAVATION AND DISPOSAL
• Conventional construction equipment (e.g., backhoe) is
 used to excavate and remove soils.

• Often done in conjunction with tank removals.

• Disposal options include approved landfills, asphalt
 batching plants, landfarming or other treatment facilities.
• Relatively quick and common.

• Allows pollution problem to be removed from the
  site.
• Disrupts the site (excavating adjacent to buildings is
 not recommended).

• Increases short-term exposure pathway to volatile
 hydrocarbons.

• Disposal options may be limited by facility acceptance
 criteria and space availability.

• Depth of excavation limited by equipment and presence
 of ground water.
ENHANCED VOLATILIZATION/
LANDFARMING
• Contaminated materials are excavated and spread over
 the ground surface.

• Volatilization and degradation mechanisms are enhanced
 (e.g., by tilling or scarifying the soil and/or adding
 sorbents).
• Feasible when open land is available (usually UST
  site owner's land).

• Organic soils and temperate climate conditions
  facilitate treatment.
• Can require air and soil monitoring.

• Land availability limits use.
VENTING (IN SITU)
• Fane or vacuums are used to create a pressure gradient
 that forces air through the soils.

1 Vapors are directed to a vent and released with or without
 treatment
1  Feasible at moat sites where trenches or wells can
  be installed.

1  Design can account for less permeable soil
  conditions (e.g., by vent spacing).
• Can take time (e.g., several weeks or more) to install
 and complete.

• Air monitoring and treatment permits may be required.
INCINERATION
                                  • Thermal destruction of contaminants in excavated soils
                                   can be achieved by a variety of types of available
                                   incinerators (e.g., rotary kiln, liquid injection, or circular
                                   bed).
                                                        > May be particularly beneficial at sites where petro-
                                                         leum products are mixed with other types of
                                                         contaminants.

                                                        ' Mobile unite are available and can be set up on site
                                                         for long-term projects.
                                                  • Liability perceived by some when soils mixed with
                                                    other waste types in the incinerator. (This can be con-
                                                    trolled by segregating materials).

                                                  • Can require significant permitting (Subtitle C facilities
                                                    would meet the permit requirements.)

                                                  • Still in the developmental stage.
BIOLOGICAL DEGRADATION
1 Natural microorganisms degrade the contaminants in
 soils and can be used during cleanup by monitoring
 natural occurrences or by optimizing oxygen and nutrient
 conditions.
• Works well in conjunction with groundwater
 remediation.

• Best suited for in-situ treatment

• Appropriate as a polishing technique for sites
 where other clean-up measures have also occurred.
• Effectiveness limited by microbial population, availabil-
 ity of nutrients, temperature, and type of hydro-  •
 carbons.

• Controlling these factors can be difficult, costly, and
 time-consuming.
                  NOTE: Extensive discussion on these and other technologies has been developed in the existing literature. Please refer to the References for "Remediation* for more information.

                                                                                    Source: IGF Inc.

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Reporting Requirements
Step 7   Have owners/operators submitted all information relating to the
          cause of the release and the status of the site to the State?

                      Owners/operators should comply with existing State and Federal
                      reporting requirements concerning petroleum UST releases. At
                      this stage of the process, owners/operators will likely be required
                      to report all data and information that characterizes the site and
                      the cause of the release (if they have not already done so,  see
                      Scenario A, Step 4 on page 31). Additionally, owners/operators
                      may be asked by the State to develop a Corrective Action Plan
                      (e.g., for long-term soil management efforts).
   48

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                                                  SITE EVALUATION CHECKLIST
                               SCENARIO B. EXTENSIVE SOIL CONTAMINATION
SITE NAME/ID#:

SITE COORDINATOR:
                                                                  Date Completed/
                                                                     By Whom
Step 1:   Prior to initiating field work, have all potential sources,
         suspected areas of contamination, and site conditions
         been identified?

Step 2:   Have adequate field preparation measures been taken by
         contractors and oversight personnel?

Step 3:   Has initial screening been conducted to confirm the presence
         of vapors in soils and to identify areas of highest
         contaminant concentrations?

Step 4:   Have subsurface soil samples been collected to determine the
         vertical extent of contamination?

Step 5:   Have soil data been accurately evaluated in order to determine
         the extent of contamination and the need to continue to
         Scenario C?

Step 6:   Have effective clean-up measures been taken to control the
         source (if applicable) and to manage contaminated soils?

Step 7:   Have owners/operators submitted all information relating to the
         cause of the release and the status of the site to the State?
        Note:  Not every task may be applicable in all situations, and the sequence
               of steps will vary somewhat from site to site.
                                                                         49

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          SCENARIO C. GROUNDWATER CONTAMINATION
This scenario addresses those sites where groundwater contamina-
tion is likely or has already been identified (e.g., based on visible
product on the surface of the water or analytical results of samples
from drinking water wells). At these sites, a State inspector may
need to evaluate the following:

•  Locations of monitoring wells;

•  Installation of monitoring wells;

•  Characterization of groundwater flow;

•  Groundwater sampling procedures;

•  Assessment of groundwater contamination;

•  Initiation of removal of floating free product from ground
   water;

•  Determination of the existing and future uses of ground water;

•  Provision of additional alternative water supplies if necessary
   (temporary alternative water supplies typically would have
   been addressed during the initial response phase of the
   cleanup); and

•  Information relating to the groundwater investigation and
   cleanup (in the form of reports and plans) submitted by the
   owner/operator to the State.

The purpose of conducting these activities is to determine the type
of contamination (i.e., dissolved or floating product), the extent of
contamination, and the need (if any) to protect additional ground-
water users in an area. Information gathered under this scenario
can help provide the basis for further remediation, as necessary.
The need for some, or all, of these steps is contingent upon
the site-specific situation.
                                                   51

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Monitoring Well Locations
Step 1   Have monitoring wells been sited in strategic locations so as
          to allow sampling upgradient and downgradient of the
          contamination source?

                      The location of wells should take into consideration the expected
                      direction and rate of contaminant migration based on permeability
                      and gradient (see transport discussion in Appendix B). Prior to
                      siting well locations, it is also beneficial to evaluate the types of
                      information outlined in the Worksheets as well as data gathered
                      during soil sampling in Scenarios A or B.

                      Typically, the  direction of groundwater flow in a water table
                      aquifer will replicate the surface topography. (This is not neces-
                      sarily true in confined aquifers.) In general, at least one well is
                      placed in the assumed upgradient direction of the contamination
                      source, two to  three wells are located around the suspected source,
                      and one or more is installed downgradient to determine the extent
                      of contamination.

                      An investigation may also require at least one well to be installed
                      at depth, below the shallow aquifer, to determine the vertical
                      extent of migration into a deeper aquifer.  The need for a deep well
                      depends on the site geology, the age of the release, and the type of
                      contaminants  (e.g., "sinker" constituents such as No. 6 fuel oils can
                      have densities greater than water).
Monitoring Well Installation
Step 2   Have monitoring wells been installed correctly?

                      Monitoring wells are generally installed in soil borings, upon
                      completion of drilling, when evidence (e.g., from soil screening)
                      indicates a release of petroleum product has affected ground water.
                      (See Scenario B, Substep 4.2 and Exhibit 11 on page 42 for soil
                      sampling and drilling information.)  For well installation purposes,
                      dry drilling methods are preferable to those using water or mud,
                      because drilling fluids can influence the quality of the groundwater
                      sample.
                      2.1
Have the monitoring wells been designed to meet the
following general criteria, as applicable? (See
Exhibit 15.)

•  Well screens have been placed at the depth appropriate
   for the information desired. For example:
   52

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                        EXHIBIT 15
                 Typical Monitoring Well
PROTECTIVE CASING
LOCK
GROUT/BENTONITE
BACKFILL
PVC RISER
W/THREADED JOINTS
BENTONITE
SEAL
PVC SCREEN
W/THREADED JOINTS
CLEAN SAND/
GRAVEL FILTER
PACK
BOREHOLE

ANNULAR SPACE
                       Source: ICFInc.
                                                                          53

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                             .  the screen intersects the water table when investi-
                                gating a floating layer;

                             -  the well screen extends sufficiently above and below
                                the water table in order to account for anticipated
                                seasonal fluctuations in the groundwater elevation;
                                and

                             •  the well screen is placed at the depth of primary mi-
                                gration when investigating dissolved constituents or
                                "sinkers."

                          •  The well diameter is wide enough to accommodate the
                             intended sampling equipment. In some cases, however,
                             small diameter wells will be used to minimize the
                             volume of fluid that will need to be handled and dis-
                             posed of during sampling.

                          •  All well materials and sampling equipment are clean or
                             decontaminated prior to use.

                          •  The well has a bottom cap.

                          •  A filter pack of clean, inert sand or gravel is  placed in
                             the annular space (between the sides of the boring and
                             the outside of the well). Generally, a sand pack will
                             extend two to five feet above the top of the well screen.

                          •  Bentonite and/or grout seals are placed at appropriate
                             depths (i.e., one to two feet above the sand and between
                             significant strata) to prevent cross contamination
                             between aquifiers and/or infiltration of sheet runoff
                             from the ground surface.

                          •  The well was developed upon completion to ensure
                             proper operation. This is usually accomplished by pump-
                             ing the well until the water is clear and until the rate of
                             recovery between pumping is relatively constant.  If
                             gasoline is suspected or known to be present, develop-
                             ment water must be drummed and handled as hazard-
                             ous material (until laboratory results are available to
                             indicate otherwise for suspected ground water).

                          •  The well is equipped with a protective casing or road
                             box and a locking cap to prevent vandalism.

                   2.2    Has all pertinent information been recorded on the
                          boring log as shown in Exhibit 13 on page 45 (or in
                          the field notebook), if applicable?
54

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                     2.3   Have well locations and ID numbers been clearly
                           marked so as to be sufficiently visible in all seasons
                           (e.g., with colored flags staked into the ground or
                           with spray paint)? Have well locations been
                           sketched on a plan, using measured distances from
                           stationary site features, to allow easy location in the
                           future by surveyors and field personnel?
         Other factors to remember about well installations include the following:

         •  Delays during installation can occur when the sand filter pack is put in place
            too quickly and forms a block or bridge between the well and the interior of
            the auger or casing. This is particularly apt to occur when the annular space
            is small (e.g., a 2-inch diameter well is placed in a 3.75-inch diameter auger
            or casing).

         •  Bentonite and grout can influence water quality if improperly placed.
            Bentonite should be wetted following placement and allowed to set, and grout
            should be well-mixed before placement. Interference from poor seals may be
            identified (i.e., by elevated conductivity readings from bentonite or by high
            pH readings in groundwater samples).

         •  Piezometers, i.e., monitoring wells whose primary purpose is to obtain water
            level data (typically used in clay materials), should be of small diameters
            such that head changes can be detected quickly.

         •  For more information, see the References for "Soil and Groundwater
            Investigations."
Groundwater Flow Characteristics
Step 3    Have groundwater flow charactericstics been determined?

                     In order to verify that wells are properly located both upgradient
                     and downgradient of the suspected source, the direction of ground-
                     water flow must be confirmed. To determine if sufficient data are
                     available on groundwater flow, inspectors may evaluate the
                     following.

                     3.1   Have experienced surveyors measured the elevation
                           of the tops of wells or piezometers?

                     3.2   Based on the survey, have groundwater elevations
                           been calculated?  (For this calculation, it is best to
                           use water table measurements that were all collected
                           on the same day.)
                                                                       55

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                      3.3    Have elevations been plotted on a groundwater
                            contour plan to determine:

                            •  Direction of flow (perpendicular to the groundwater con-
                               tour lines); and

                            •  Hydraulic gradient (the distance between contour lines
                               divided by the change in groundwater elevation)?

                            Elevation data from shallow and deep aquifers should be
                            examined separately. This is important since the direction
                            of flow in a deep aquifer may differ from, and can actually
                            be the opposite of, the flow in a shallow aquifer.

                      3.4    Were data available on hydraulic conductivity and
                            porosity of the soil (to estimate groundwater velocity
                            or the rate of flow)? (See Appendix B for one method
                            to calculate flow rate.)

                            Information on hydrogeologic characteristics of a site can be
                            obtained from review of available literature or direct aqui-
                            fer testing such as pump tests and slug tests (i.e., rising
                            head and falling head tests). This information is important
                            for estimating how quickly downgradient drinking wells
                            may be affected as well as for future selection of treatment
                            options.
Groundwater Sampling
Step 4   Have groundwater sampling procedures been correctly
          implemented?

                      Inspectors may want to review sample collection procedures to
                      ensure that representative groundwater samples have been col-
                      lected and no cross contamination occurred at the site.

                      4.1    If samples are to be sent to a laboratory, have the
                            appropriate types of analyses been identified prior
                            to sample collection? (See Exhibit 9 on page 39 for
                            more discussion of laboratory analyses.)

                            The chosen laboratory analyses should provide data on the
                            indicator parameters for the released product. For
                            example, benzene, toluene, and xylene are major constitu-
                            ents of gasoline, and lead is an indicator parameter for
                            regular, leaded gasoline.  The type of analysis will  influence
   56

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                   how a groundwater sample is collected.  Different analyses
                   require different volumes of water and types of containers.
                   (See Exhibit 10 on page 40 for additional information on
                   analytical options.)

            4.2    Were the necessary measurements obtained prior to
                   purging the well to remove stagnant well water?

                   This may include the following:

                   •   Using a weighted tape or electric water level reader to
                      determine the depth to the water table from the top of
                      the casing and/or ground surface (see Exhibit 16); and

                   •   Determining the presence of floating free product on the
                      water table. This determination may be made using a
                      weighted tape with hydrocarbon detection pastes, an oil/
                      water interface probe, a clear bailer, or obtaining a
                      sample from the water table with a standard bailer.
The inspector should recognize that the thickness of floating product observed in
a well is often greater than the actual thickness in the rock formation due to the
influence of the well diameter and the capillary fringe. Product thickness in a
well may also fluctuate seasonally and may even decrease to zero when the
water table is high.

When a floating product layer is present, measurements of depth to the water
table need to be corrected to account for the density difference of the product
relative to water. For example, gasoline has a density approximately 75 percent
that of water. Therefore, if a one-foot floating layer was present, 0.75 feet should
be added to the elevation of the water/gasoline interface to obtain the true water
table elevation.
            4.3    Has the appropriate purging equipment been
                   selected based on the depth to the water table,
                   amount of water, well diameter, and the volume of
                   water to be removed (usually three to five times the
                   water standing in the well)? (See Exhibit 17 for more
                   information on purging equipment).

            4.4    Were well water purging techniques satisfactory?

                   This may entail the following:

                   •  Operating pumping equipment in accordance with
                      manufacturer's instructions, or bailing the well a desig-
                      nated number of times using clean tubing and/or
                      bailers; and
                                                               57

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                                       EXHIBIT 16
                    Method to Determine Water Table Elevation
                                and Product Thickness
       (B) MARKER DEPTH =
           READING ON TAPE LEVEL WITH
           EDGE OF CASING. USE AN
           EVEN FOOT FOR CONVENIENCE.
                                                            (A) CASING ELEVATION =
                                                               ELEVATION ON TOP OF
                                                               CASING DETERMINED FROM
                                                               SURVEY.
                                                    GASOLINE FINDING PASTE
                                                  /(C) FLUID CUT =
                                                        FOOTAGE READING OF
                                                        FLUID MARK ON TAPE.
       j?V»£;~sJL*L*U^»w.*,'
       * V^WATER^N^NG PASTE
    	  ...
               I	 I	 !..!,
^DJWTERCirH .„,%" * v/
 •^ V    -^ fjf'™ *•• siv ••. ^f"   "• *"" -.S
 -  f   ^ '{&•>'**''   '   t
 ..  *     i " ',, <» s "f  ' ^ - "?
   ''*'*"/,''%   *•?"   --' - -V
   ,/  -   ,;   ',;/ ->4
        ' ,",   ' * ' "f, •.  ,is ^
   f ^"  4*'   \f- s'tf,"***"' •&'"i"
   .•^   $ f       I *•• \  •$  t
   ^    *? *y   ^   P %\  f t  vx ff
    f    fp f  '_,/••   S f * •'^ «" * / A,
 *  /    s  <  ^ -^   ' *f  .  •=•   ' ^
  s. X    *" •*'•* •*s"\ f ff f ff f f ff f f f f ffff f
 <"•!£ £.•   '5'-!' X" f %" ffffff f f$ f fff ff f tyf   f
 &,&,  **•$£*«•£ ,',\'A, ,\st," '»-
*"-' ,^  -^''{\,'''\,f/^  "' '-'"'
  \t <*••• sv&vv v. s 's   ^ "*%  '*•. •*•. •"•  *• ^ '
—WEIGHT '- s-  >,   --'-„ s,' ^ /V;
 ,*Ttc~.r    i   ^;,   y  ,f/
    *    V  '  J    ," - --   'tf
   f     ,    A   ' ''  ' ••
    fz "•*   *  •. * " s     ^    '
    J* «> , - .-V 's  *'   <  *  t > •. i

    ^^'-'^S^^i^^L
 '* PRODUCTION ELEVATION = A = (B
I WATER ELEVATION = A = (B - D)
i '5
                                                                              - C) ^
58
   Source:   Reprinted courtesy of the American Petroleum Institute, "Underground Spill Cleanup
             Manual," Publication #1628, First Edition, June 1980.

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                                                                      EXHE81T17

                                                                 Purging Equipment
        Diameter Casing
Bailer
Peristaltic Pump    Vacuum Pump     Airlift
                                                          Diaphragm        Submersible       Submersible      Submersible Electric
                                                          Trash* Pump      Diaphragm Pump   Electric Pump     Pump with Packer
        1.25 Inch
        Water level <25 ft

        Water level >25 ft.
        2-inch
        Water level <26 ft.

        Water level >25 ft.
        4 inch
        Water level <26 ft

        Water level >26 ft.
        flinch
        Water level <2B ft.

        Water level >25 ft
        Binch
        Water level <25 ft.

        Water level >25 ft.
              Source:  Barcelona, M.J., J.P. Gibb and R.A. Miller.  A Guide to the Selection of Materials for Monitoring Well Construction and
                       Groundwater Sampling.  ISWS Contract Report 327, Illinois State Water Survey, Champaign, IL. 1983.
en

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                   4.5
 • Disposing contaminated discharge water and free
   product appropriately. Options include treating
   discharge water on site (using an air stripper and/or
   carbon adsorption system), discharging to the sewer if
   allowed (a permit may be required), or collecting and
   hauling off site. Refer to the appropriate State regula-
   tory standards for guidance.

Purging and sampling may be complicated if free product is
present. Common options include the following: choosing
not to sample; bailing, followed by use of sorbent material
to swab the floating product off the surface of the well
water; and installing dedicated wells/samplers below the
free product (e.g., a cluster well or a gas-driven sampler
which can be isolated to collect from a specific depth).

Have samples been obtained using the appropriate
equipment and collection method?

Following the recharge of the well, samples should be
collected using a pre-cleaned bailer (e.g., stainless steel,
TeflonfR], or polyvinyl chloride — PVC) attached to a clean
cable. (Samples obtained from a pump can compromise the
quality of results since volatilization can occur prior to
sampling.)
      The quality of groundwater samples can be affected by the following:

      •   Excessive turbulence during sampling;

      •   Inadequate cleaning of sampling equipment (bailers) between wells;

      •   Incorrect selection, use, and labelling of sample containers; and

      •   Insufficient temperature and quality control during sample handling
          (e.g., samples should be transported and stored in ice-packed cooler).
                   4.6    Has all pertinent information been recorded in a
                          field notebook and on the labels?

                          Typically this includes well number, date, time, sampler,
                          project name/ID#, and for laboratory analyses the type of
                          preservative and analytical method should be identified.
60

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Assessment of Groundwater Contamination
Step 5   Has an accurate assessment of groundwater contamination been
          made?

                     Based on the analytical results, a determination can be made
                     about the presence and extent of groundwater contamination.
                     This assessment is necessary to help determine the need for addi-
                     tional sampling, protection of additional groundwater users, and/or
                     cleanup.

                     Consult with State drinking water offices to determine if contami-
                     nation levels exceed their criteria. Additionally, sample results
                     can be compared to background data (representative of conditions
                     around the site). The site data may then be plotted on a site plan
                     to delineate the limits of the contaminant plume.
         If a nearby downgradient stream or river exists, it may be a good idea to collect a
         surface water sample. The results can provide valuable information on the
         downgradient extent of a plume assuming the ground water and surface water
         are interconnected (i.e., the ground water discharges to the stream).
Free Product Removal from Ground Water
Step 6    Has an effective means of removing free product from ground
          water been initiated?

                      To prevent free product from acting as an ongoing source of
                      groundwater contamination (or flammable vapors which could lead
                      to a health and safety hazard), free product removal can be
                      implemented.

                      Generally, the preferred free product recovery technologies are the
                      trench method and the recovery well method. Barriers may also
                      be used in conjunction with recovery systems to enhance their
                      effectiveness. For more information, see Exhibits 18,19, and 20
                      and the References for "Remediation."
                                                                       61

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                                     EXHIBIT 18

                               Free Product Recovery
 Option A: Trenches or drains
 Trenches function as relatively simple passive systems for the collection of free product (see
 Exhibit 19). They are particularly effective at sites with shallow ground water (at depths less
 than 10 to 15 feet), in open areas, and in soils with low permeability (e.g., 10"7 cm/sec). To
 determine if a trench has been properly located and installed, it is necessary to review the
 following: the depth to ground water; the direction of flow; observations of product ponding in
 the trench; the effect of any pumping of water from beneath the product; the length of the
 trench; and the soil conditions. (Crushed stone or gravel may need to be added for support in
 long-term trenches.)

 Option B: Recovery wells
 Recovery wells can also be used as retrieval systems and are best suited for confined spaces,
 where ground water is at depths greater than 20 feet, and where soils have moderate to high
 permeabilities.
 When a single pump system is used, the drawdown created during pumping needs to be suffi-
 cient to control contaminant migration. Storage, treatment, and disposal of the removed fluids
 (which are a mix of product and water) must be addressed in accordance with State and Fed-
 eral requirements. Special permits may be necessary for managing removed fluids
 (see Exhibit 19).

 Dual pump systems employ separate pumps for water and for product and therefore reduce the
 amount of contaminated water which must be handled. As a result, these systems are advan-
 tageous for large volume spills (see Exhibit 19).

 Option C: Barriers
 As part of the retrieval system, barriers may be necessary to minimize withdrawals of large
 volumes of water (see Exhibit 20). Barriers may include:

    •   Sheet Piles - Due  to substantial costs involved and unpredictable wall integrity, sheet
        piles are generally used for temporary dewatering during other construction efforts or
        as erosion protection where some other barrier, such as a slurry wall, intersects flowing
        surface water.

    •   Grouting - Generally used to seal voids in rocks.

    •   Hydraulic barriers - Can be used at sites directly over moderate or highly productive
        aquifers, as well as those with low permeability soils, as part of a manifolded system
        with automated controls.

    •   Slurry walls - Installation can be less expensive than alternatives. Most applicable at
        sites where the wall depth will be less than 80 feet; also, presence of bedrock or imper-
        meable layer is beneficial for "keying" or connecting the bottom of the wall.

 For more information see References for "Remediation".
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
                                    Source: IGF Inc.

 62

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                                      HXHIHIT 19
                            Trenches and Recovery Wells

              Cross Section of Interceptor Trench 1
              Single Pump System 2
                                        OIL-WATER SEPARATOR
                                                  OIL
                                                                 WATER
                                                 WATER LEVEL
                                                WHEN PUMPING
CONCENTRATED
FREE PRODUCT
                                               GASOLINE-WATER
                                                   PUMP
              Dual Pump System 2
                    CONCENTRATED
                    FREE PRODUCT
                    WATER TABLE
                  COMPRESSION PUMP
                                                PRODUCT RECOVERY PUMP
Sources:  1. Reprinted courtesy of the American Petroleum Institute,"Underground Spill Cleanup
            Manual," Publication #1628, First Edition, June 1980.
         2. Cleanup of Releases from Petroleum USTs:  Selected Technologies. U.S.
            Environmental Protection Agency, April 1988.
                                                                                        63

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                                       EXHIBIT 20
                                  Barrier Installations
               Plan View of Barrier with Recovery Well1
                                                                   DITCH
                                                                   IMPERMEABLE
                                                                   BARRIER
                                                                   RECOVERY
                                                                   WELL
               One-Sided Subsurface Drain with Clay or Plastic Barrier2
                        UNDERGROUND
                            TANK
SUBSURFACE DRAIN
  WITH CLAY OR
 PLASTIC BARRIER
                                                     ORIGINAL WATER
                                                         TABLE
                                                               CLEAN WATER
                                                               RECHARGING
                                                               FROM STREAM
                        LOW PERMEABILITY
64
  Sources:  1. Reprinted courtesy of the American Petroleum Institute.'TJnderground Spill Cleanup
              Manual," Publication #1628, First Edition, June 1980.
           2. Underground Storage Tank Corrective Action Technologies. U.S. Environmental
              Protection Agency, reprinted from JRB Associates, January 1987.

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Determination of Groundwater Uses
Step 7    Have both the existing and future uses of ground water been
          determined to further identify the potentially affected
          community?

                     Before deciding if additional alternative water supplies are
                     necessary, inspectors may need to complete or review an
                     assessment of ground water use.

                     7.1   Have the designated or planned uses of the ground
                           water been determined?

                           This may involve the following:

                           •  Checking the State classification system;

                           •  Reviewing regional and/or local classification systems
                              and planning documents; and

                           •  Identifying special restrictions pertaining to the
                              designation.

                     7.2   Has existing groundwater use been evaluated by
                           checking new information against that gathered in
                           Chapter n, Initial Response, Step 6 on page 16?
Alternative Water Supplies
Step 8    Have additional alternative water supplies been provided, if
          necessary?

                     Depending on the extent of contamination and the feasibility of
                     aquifer restoration, a temporary and/or emergency water supply
                     may be needed until a permanent alternative water supply is
                     found, or until the existing supply is restored. (See Chapter II,
                     Initial Response, Step 7 on page 17 for more information on
                     temporary alternative water supplies.)

                     If the situation is such that the existing water supply is irrevoca-
                     bly damaged, permanent alternative water supplies may be pro-
                     vided by one of the following techniques:

                     •  Blending the existing municipal water supply with an alterna-
                        tive supply;

                                                                      65

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                      •  Purchasing a new municipal water supply from a neighboring
                         unit;

                      •  Providing a new central municipal system using a surface
                         water supply;

                      •  Developing a new groundwater well for municipal or private
                       •  supply systems; and

                      •  Determining the feasibility of extending municipal water
                         supply lines or developing new wells or surface water sources
                         as alternatives for private wells.
Reporting Requirements
Step 9   Have owners/operators submitted all information relating to the
          groundwater investigation and cleanup to the State?

                      Owners/operators should comply with existing State and Federal
                      reporting requirements concerning the investigation and subse-
                      quent remedial activities associated with groundwater contamina-
                      tion. Owners/operators should report the steps taken to delineate
                      the extent of contamination, the estimated quantity, type, and
                      thickness of free product observed and measured, the type of
                      recovery system, and the extent of free product removal. Addition-
                      ally, owners/operators may be required to develop a Corrective
                      Action Plan for responding to contaminated ground water.
   66

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                                                 SITE EVALUATION CHECKLIST
                                SCENARIO C.  GROUNDWATER CONTAMINATION
SITE NAME/ID#:

SITE COORDINATOR:
 Step 1:   Have monitoring wells been sited in strategic locations so as
         to allow sampling upgradient and downgradient of the
         contamination source?

Step 2:   Have monitoring wells been installed correctly?

Step 3:   Have groundwater flow characteristics been determined?

Step 4:   Have groundwater sampling procedures been correctly
         implemented?

Step 5:   Has an accurate assessment of groundwater contamination
         been made?

Step 6:   Has an effective means of removing free product from
         ground water been initiated?

Step 7:   Have both the existing and future uses of ground water
         been determined to further identify the potentially
         affected community?

Step 8:   Have additional alternative water supplies been provided,
         if necessary?

Step 9:   Have owners/operators submitted all information relating to
         the groundwater investigation and cleanup to the State?
                                                                 Date Completed/
                                                                    By Whom
       Note:  Not every task may be applicable in all situations, and the sequence
              of steps will vary somewhat from site to site.
                                                                        67

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                                             APPENDICES
A. VAPOR CONTROL AND TREATMENT OPTIONS
B. TRANSPORT OF CONTAMINANTS
C. TANK REMOVAL, CLOSURE, AND REPAIR ACTIVITIES
                                                     69

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APPENDIX A -- VAPOR CONTROL AND TREATMENT OPTIONS
                     Passive and active vapor control systems can reduce the hazards
                     associated with hydrocarbon vapor migration.  These systems are
                     designed to enhance or create a pressure gradient which causes
                     the vapors to flow to a desired collection area (trench or well).
                     From the collection point, vapors are then either released or
                     treated (e.g., by adsorption or catalytic conversion).

                     It is important to remember that the first steps in any vapor
                     control effort involve the following precautionary measures:

                     •  Using explosion-proof equipment;

                     •  Eliminating ignition sources; and

                     •  Posting warning notices for security.

                     With both types of systems, inspectors need to be aware of the
                     following:

                     •  Worker health and safety controls are a consideration during
                        installation;

                     •  Preliminary testing may be necessary prior to design; and

                     •  Periodic monitoring of subsurface vapors (and pressure for
                        active systems) may be needed to ensure effectiveness.
   Passive Vapor Control Systems
                     Passive vapor control systems typically involve the installation of
                     trenches or wells just outside the area of contamination. The
                     trenches may be open or filled with permeable crushed stone.
                     Perforated pipes and vent stacks may also be installed. (See
                     Exhibit A-l.) Passive systems are most suitable for sites where
                     small volume losses have occurred, soils have high permeabilities,
                     and a perched water table is not present. Situations where the
                     temperature of the ambient air is cooler than the soil temperatures
                     are also suitable for passive systems.

                     The advantages of passive systems are that they are relatively
                     quick and easy to install and that they do not require ongoing
                     operation and maintenance. These systems may be limited,
                                                                       71

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                                     EXHIBIT A-l
                           Passive Vapor Control System
                                                     Vent
'   \
    J*

 ..)    Perforated Collection Pipe
                                                                               Monitoring Well
                                                                                 w/Probe
Note:  Vent pipe placement varies with the situation.  State Fire Marshalls or local fire departments
       should be consulted for minimum vent pipe heights.
                                     Source:  IGF Inc.
      72

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                      however, by climatic conditions such as heavy rainfall or prolonged
                      freezing, and by low permeability rock formations. The trench
                      method also has limited applicability at sites where the depth to
                      contamination exceeds the capabilities of the equipment
                      (i.e., approximately 20 feet).
Active Vapor Control Systems
                      Active vapor control systems force the vapors to collection points
                      (usually located within the contamination area) through the use of
                      pumps (positive pressure) or vacuums (negative pressure).  The
                      system includes a series of vapor extraction wells, a gas collection
                      unit, control valves, a vacuum or blower, and vents (see Exhibit
                      A-2).  Active systems may be used for most site conditions.

                      The advantages of active systems include: accelerated vapor
                      removal; relatively quick and easy installation; reliability in heavy
                      rainfall or prolonged freezing conditions; ability to isolate areas to
                      be protected; and effectiveness in most geologic conditions (see
                      Exhibit A-3). Negative pressure systems are also excellent for sub-
                      slab venting where gravel fill exists. The disadvantages of active
                      systems include ongoing operation and maintenance requirements,
                      the potential need for treatment of contaminated air, and the
                      potential to direct vapors to previously uncontaminated areas
                      (using positive pressure).
Vapor Treatment Options
                      Depending on the specific site and State requirements, vapor
                      treatment technologies may need to be included in the design of an
                      active control system to further control the emissions of hydrocar-
                      bon vapors.  Two of the more common technologies, adsorption and
                      catalytic conversion, are described here.

                      Adsorption

                             Adsorption systems can be very effective at UST sites if
                             they are properly designed and maintained. The selection
                             of a type of adsorption media, i.e., carbon or synthetic
                             resins, will vary depending on the contaminant. Factors to
                             consider when designing an adsorption system include
                             anticipated effectiveness, rate of breakthrough, and dis-
                             posal/regeneration of the sorption media, as well as the
                             volume of vapor. The actual adsorption capacity of con-
                             taminants varies with the material.
                                                                          73

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                                       EXHIBIT A-2
                               Active Vapor Control Systems


                                                                                Inclined Perforated Pipe S&
                                                                                  to Collect Vapors   §|
^^^^^^^^m


                      •ft
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                           EXHIBIT A-3
     General Considerations for Active Vapor Control Systems
General Curve for Vacuum versus Soil Permeability
          HIGH
   VACUUM
           LOW
                    HIGH
                               PERMEABILITY
LOW
General Scheme for Well-Point Spacing
          WIDE
   SPACING
          CLOSE
                    HIGH
                               PERMEABILITY
LOW
                   Source: Groundwater Technology Inc.
                                                                  75

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                   The use of vapor phase carbon as an emergency response
                   mechanism is generally on a finite short-lived basis.
                   Normally, for longer duration use, a catalytic converter or
                   natural diffusion to a soil vent system is more feasible and
                   cost effective. Some of the general rules for carbon adsorp-
                   tion include:

                   •   Vapor phase carbon adsorbs approximately 10 percent
                       by volume of the organics to be collected. Multiple bed
                       systems can be used to increase contact time.

                   •   A small volume 55-gallon drum portable adsorber has
                       approximately 5-6 gallons or 30 to 40 pounds maximum
                       adsorption capacity.

                   •   Under normal vapor input conditions, with 20-50 ppm
                       voL/vol. and a 200 ftVminute flow, a typical unit might
                       last 7-10 days before breakthrough.

                   •   Alarms and/or shutdown controls may be necessary for
                       complex systems, sensitive locations, or populated
                       areas.

             Catalytic Conversion

                   The catalytic conversion option is an approach for vapor
                   control at sites with low to high level vapor concentrations.
                   Typically, a catalytic converter unit consists of three basic
                   elements — a high efficiency air-to-air heat exchanger, an
                   air heater (electric), and a precious metal catalyst (see
                   Exhibit A-4). During operation, the vapor to be treated is
                   preheated in the heat exchanger and is passed over the
                   catalyst where combustion takes place. During the design
                   phase, safety features and monitoring controls are of pri-
                   mary importance to consider and pilot studies may be
                   necessary. (Flaring — the process of exposing vapors to an
                   open flame with no special features to control temperatures
                   or time of combustion — is another alternative for vapor
                   control. Design and operating conditions for flaring are not
                   readily available, however, and it is not a desirable method
                   for many situations e.g., gas stations or densely populated
                   areas.)
76

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                               EXHIBIT A-4
                       Catalytic Converter System
RECIRCULATED
CLEAN HEATED
AIR TO HEAT  -^
EXCHANGER
1
1
s

1
f

1
<
4


\
w.
                              . ELECTRIC
                              HEATER
                      w





ATALYST
VENT TO
TMOSPHERE
f^ji
" M— 1





1

1









*•






jtfM

\
V
_ 
-------
                  APPENDIX B « TRANSPORT OF CONTAMINANTS
Unsaturated Soils
                      The rate and pattern of seepage of petroleum products through
                      unsaturated soils is primarily influenced by the geologic material,
                      the volume, type of contaminant released, and the amount and
                      type of precipitation. (Exhibit B-l presents the seepage pattern for
                      three hydrocarbon plumes.) To estimate the maximum depth of
                      penetration, the following formula can be applied:

                                               D = RvV
                                                    A

                      where: D = maximum depth of penetration, m; V = volume of
                      infiltrating product, m3; A = area of spill, m* and Rv = constant for
                      retention capacity and product viscosity based on the chart below.
                                       TYPICAL VALUES FOR Rv*
                               Soil

                       Coarse Gravel
                       Gravel to Coarse Sand
                       Coarse to Medium Sand
                       Medium to Fine Sand
                       Fine Sand to Silt
Gasoline

  400
  250
  130
   80
   50
                                                                Rv
                                                                  **
Kerosene

  200
  125
   66
   40
   25
 Light
Fuel Oil

  100
   62
   33
   20
   12
                       *  Source: Shepherd, W.D., "Practical Geohydrological Aspects of Groundwater
                         Contamination."
                       ** A constant value representing capacity of soil and viscosity of product.
                    V	J
Saturated Flow
                      The migration of a plume of dissolved contaminants in the satu-
                      rated zone is primarily controlled by the characteristics of ground-
                      water flow.  As expressed in Darcy's Law, the quantity of flow (Q)
                      is a function of the hydraulic conductivity of the soil material (K),
                      the gradient dh/dl (or I), and the cross-sectional area (A) expressed
                      as:
                                               Q = KIA
                                                                         79

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                                         EXHIBIT B-l
                                 Typical Seepage Patterns
      Product Seepage
                     , LAND SURFACE
        SLOW SEEPAGE
            INTO
         PERMEABLE
            SOIL
HIGH VOLUME
SEEPAGE WTO
 PERMEABLE
    SOIL
 SEEPAGE INTO
STRATIFIED SOIL
 WITH VARYING
 PERMEABILITY
                  Behavior of Product after Spill Has Stabilized
                                                          GROUND SURFACE
                                                      SOIL CONTAMINATED
                                                      BY RESIDUAL PRODUCT
                                                      PRODUCT MIGRATING DOWNWARD
                                                      AND ACCUMULATING ON WATER TABLE
                                                                  CAPILLARY ZONE
                             Typical Behavior in Porous Soil Following a Sudden, High Volume Spill
                                                                   SOIL CONTAMINATED
                                                                   BY RESIDUAL PRODUCT
80
     Source:   Reprinted courtesy of the American Petroleum Institute, "Underground Spill Cleanup
               Manual," Publication #1628, First Edition, June 1980.

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(See Exhibit B-2 for hydraulic conductivities of geologic materials.)
Using Daley's Law as the basis for further calculations, the rate or
velocity of flow (v) can be calculated as:
where n = porosity.

While Dairy's Law is commonly used to determine ground water
flow characteristics, other factors such as biological degradation,
oxidation, and sorption must also be taken into account when
determining contaminant transport or dispersion. Because these
factors can vary significantly from site to site, dispersion must be
calculated on a site-specific basis.

There are no established dispersion rate values, however, there
are several methods currently used to estimate transport rates on
a site by site basis. The two primary dispersion factors that need
to be considered are the rate of longitudinal dispersion and the
transverse to longitudinal ratio.

•   In general, the rate of dispersion increases as the hydraulic
    conductivity of the aquifer increases. For example, in medium
    grained sands the dispersion rate is greater than in fine
    grained silty sands. (This premise may not be valid if a pre-
    ferred migration pathway develops, e.g., through cracks in a
    clay formation or along subsurface manmade lines.)

•   The ratio of dispersion in the longitudinal direction vs.  the
    transverse direction decreases as the silt and clay content
    increases in soils. For example, depending on groundwater
    flow velocity, in a medium grained sand the ratio ranges from
    approximately 6:1 to 10:1, while silty and clay sands may have
    a ratio of about 2:1 to  3:1.  (These ratios combine the affects of
    biodegradation and chemical degradation.)
For more information see the References for "Soil and Ground-
water Investigations."
                                                     81

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                                     EXHIBIT B-2
                  Hydraulic Conductivity of Selected Rocks
                Igneous and Metamorphic Rocks
   Unfractured                                       Fractured
                                     Basalt
   Unfractured                 '          Fractured                          Lava Flow
                                   Sandstone
                        Fractured            Semteonsolidated
              Shale
 Unfractured               Fractured
                                                Carbonate Rocks
                               Fractured                                    Cavernous
                   Clay	  	Silt, Loess	

                                                   Silty Sand
                                                          Clean Sand
                                                      Fine          Coarse
                           Glacial Till                                     Gravel
                                                             I	I
10'"    10"   10'10   10"9    10*   107    10*    10*   10*    10*    10*   10'1     1      10
                                          cms -1
   I       I       I      I      I      I      I       I      I      I      I      I       I
   10*    10"7    10*    10"s   10"*    10"3    10"2    10"'    1      10     10*    103    104
                                           md-1
       I       I       I      I      I       I      I      I       I      I      I       I      I
       107   10*    10*    10*    10*    102    10'    1      10     102    103   10*     10s
                                          ftd-1
I      I	I	I	I	I	I	I	I	I	I	I	I	I
10"7    10*   10*    10*    10*   10*    10'1    1      10     10*   10s    10*     105    10s
                                       gald-'tf2
                      Source:  United States Geological Survey, 1983
  82

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 APPENDIX C — TANK REMOVAL, CLOSURE, AND REPAIR ACTIVITIES
Tank Removal
                      The permanent removal or in-place closure of tank systems may be
                      conducted for a number of reasons, including compliance with
                      regulations, and as a condition of a real estate transaction. The
                      determination of whether to excavate and remove a tank perma-
                      nently, to close it in place, or to repair it depends on a number of
                      factors, such as the location of the tank, State and local regula-
                      tions, availability of equipment, labor, materials, and associated
                      costs.  State and local Fire Marshalls should be consulted to obtain
                      information on specific requirements.
                      An understanding of tank removal procedures is important, since
                      site observations made during these removals can often provide
                      the first direct evidence of leaks and the extent of soil contamina-
                      tion.  The following steps may be followed during a tank removal:

                      •  Drain the product from the piping into the tank;

                      •  Pump the product from the tank;

                      •  Clean residual sludge from the tank;

                      •  Remove the fill (drop) tube; disconnect the product lines and
                         the fill gauge, and cap or plug all open ends of lines (except
                         vent lines);

                      •  Eliminate explosive conditions in the tank, e.g.., by placing dry
                         ice inside (1.5 Ibs. per 100 gallons of tank capacity) or by venti-
                         lating the tank with air by use of a small gas exhauster;

                      •  Remove the tank and place it in a secure location (i.e., to
                         prevent movement or obstruction);

                      •  Check tank for explosive conditions;

                      •  Remove soil accretion on the outside of the tank as much as
                         possible;
                                                                        83

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Tank Closure
                       •  Check certain parts of the tank for evidence of leakage, i.e., the
                          seams, the tank bottom (particularly the area beneath the fill
                          pipe where stick tests frequently hit the tank), and the parts of
                          the tank which are located near patches of stained soils;

                       •  Plug or cap all openings, except the vent, after vapor removal;
                          and

                       •  Check for explosive conditions and secure the tank on a truck
                          for transportation to the disposal site.

                       Note that, if possible, arrangements for a disposal site should be
                       made prior to excavation. With the ongoing capacity shortages at
                       landfills and recent regulations restricting land disposal, it may
                       take time to finalize an agreement with a disposal site.  In those
                       cases, an open excavation or stockpiled soils could pose unneces-
                       sary risks during the negotiation period. Similarly, arrangements
                       should be made for a supply of clean fill or security fencing for a
                       site before beginning operations.

                       Managing soils during removal is another aspect of the project
                       that should be planned.  Some States prohibit any contaminated
                       soils from being placed back in an excavation during a tank
                       removal, even if more extensive soil removal will need to be
                       conducted in the  near future. In some situations, however, it is
                       possible to place plastic sheeting between unexcavated contami-
                       nated soils and new clean fill. This helps facilitate partial separa-
                       tion of the soils so they can be placed in separate stockpiles when
                       the comprehensive excavation is conducted.
                       Tank closure (in place) is often a viable option when a tank
                       removal would be extremely difficult (i.e., a tank is located directly
                       underneath a building, and/or removal would severely disrupt a
                       facility's operations).  As with tank removals, in-place closures
                       involve emptying the tank of all liquids and dangerous vapors and
                       cleaning out the accumulated sludge. Additionally, a tank closed
                       in place should be filled with a harmless, chemically inactive solid,
                       such as sand, concrete or urethane foam.

                       In order to ensure that a tank being closed in place is not respon-
                       sible for any contamination, a site assessment must be conducted
                       prior to the completion of closure activities. If any contaminated
                       soil and/or ground water or any free product is discovered during
                       this assessment, the owner/operator will need to report the release
                       and conduct appropriate clean-up measures.
   84

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Tank Repair
                       Tank repair is an alternative to tank removal or in-place closure.
                       It is important that the person repairing the tank follow standard
                       industry codes that explain the correct procedures for repairing
                       tanks and demonstrating that the tank repair was successful.
                       This demonstration is usually made by inspecting the tank inter-
                       nally with an electrical detector.  Other methods include conduct-
                       ing a tightness test or conducting another leak detection test that
                       is approved by the State regulatory authority.  It is also required
                       that USTs with cathodic protection be tested (within six months)
                       to determine if the cathodic protection is continuing to work prop-
                       erly following the construction activities.

                       For more information on tank removal, closure, or repair activities,
                       see the References for "Remediation.''
                                                                        85

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                                             WORKSHEETS
1. SITE HISTORY AND TANK INFORMATION
2. PRELIMINARY REVIEW OF IMPACTS OF RELEASE
3. EVALUATION OF ANTICIPATED SITE CONDITIONS
4.  PREPARATION FOR FIELD OPERATIONS

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       WORKSHEET 1 — SITE HISTORY AND TANK INFORMATION
SITE NAME/TO*:
SITE COORDINATOR:
DATE/TIME:
SITE LOCATION/ADDRESS:
COUNTY/CITY:.
SITE CONTACT:
TELEPHONE:
NAME AND ADDRESS OF OWNER/OPERATOR(S):
NOTIFICATION (name and date of incident report):
DESCRIPTION OF LOSS:
LOCATION OF TANKS (attach site plan or sketch):

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        WORKSHEET 1 — SITE HISTORY AND TANK INFORMATION
                                 (Continued)
TANK DESCRIPTION:
   Volume
   (gallons)         Fuel Type
  Construction Material
Age
CAUSE OF RELEASE (Circle One):
                             A
                             B
                             C
                             D
                             E
Catastrophic
Long-Term Leakage
Overfilling
Unknown
Other — Describe
LOCATION OF FAILURE(S) (sketch on plan):

                             A    Tank
                             B    Lines
                             C    Connections
                             D    Other
                             E    Undetermined

TANK TEST RESULTS (recorded leakage rate, attach results):
INVENTORY LOSS (period of records, percent loss, and volume accounted for):
HISTORY OF TANK USAGE (on site and in the area around the site, e.g., could a removed or
abandoned tank or an off-site tank have contributed to the problem?):

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        WORKSHEET 1 — SITE HISTORY AND TANK INFORMATION
                                (Continued)

LOCAL CONTACTS (list individuals to contact):

   Department/Affiliation                  Name               Telephone N,\mifof r

   FIRE                       	    	
   HEALTH
   EMERGENCY RESPONSE/
   HAZARDOUS MATERIALS
   ENGINEERING
   PUBLIC WORKS/WATER
   AND SEWER
   ASSESSORS
   U.S.G.S. AND SOIL SURVEY
   SITE EMPLOYEES
   NEIGHBORS
Note: Use the attached telephone and/or site inspection logs to record information on: past site
use; availability of maps, soil borings, or well logs; proximity to drinking water supplies; waste
oil disposal practices; and location of underground lines.

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                           TELEPHONE LOG
   SITE NAME/TO*:
   SITE COORDINATOR:
   DATE/TIME:

   CONTACT:      	
   DEPARTMENT/
   AGENCY:
   TELEPHONE NUMBER:

   SUMMARY:      	
i»

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                       SITE INSPECTION LOG
SITE NAME/ID#:
SITE COORDINATOR:
DATE/TIME:

PURPOSE OF VISIT:
SUMMARY OF SITE ACTIVITY:
                                            SIGNATURE

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                WORKSHEET 2 — PRELIMINARY REVIEW OF
                                IMPACTS OF RELEASE
    SITE NAME/TO*:

    SITE COORDINATOR:

    DATE/TIME:

    CURRENT SITUATION:
    AFFECTED AREA (Residential, Commercial, or Industrial?):
    NUMBER OF PERSONS AND/OR HOUSEHOLDS WITH AFFECTED DRINKING WATER:
    SOURCE OF WATER SUPPLY:
    ALTERNATE WATER SUPPLY AVAILABLE (If yes, what type?):
i
    NUMBER OF PERSONS WITH POTENTIALLY AFFECTED WATER:
    NUMBER OF PERSONS KNOWN AND/OR POTENTIALLY AFFECTED BY VAPORS:
    VAPOR TREATMENT (provide detail, if any):
    DEPTH TO GROUND WATER/METHOD TO DETERMINE:
    SOIL PERMEABILITY (circle one):   Low     Medium     High

    SOIL CHARACTERISTICS:	


    DEPTH TO BEDROCK:   	

    SITE CONDITIONS WHICH COULD AFFECT PLUME MIGRATION:
    PRELIMINARY RECOMMENDATIONS FOR INVESTIGATIVE/REMEDIAL APPROACH:

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   WORKSHEET 3 — EVALUATION OF ANTICIPATED SITE CONDITIONS

To determine if a proposed scope of work satisfactorily addresses specific site conditions, an
inspector may want to answer the following questions. Some questions addressed during the
early stages of a cleanup may need to be reexamined later.

INITIAL RESPONSE

   1. What are the anticipated soil conditions? Is a sand and gravel layer present; if so how
      thick?
   2. What is the estimated Tpm'nim^T^ depth from ground surface to the water table? What
      are the seasonal low elevations and possible tidal influences?
   3. Do any man-made features exist which could act as conduits for contaminant
      migration?
   4. What are the unique site features (e.g., on-site or nearby streams) which might influ-
      ence site conditions?
LIMITED SITE INVESTIGATION

   5. Is any contaminated soil found in past borings? Where? How far from the water table?
      What contaminants were identified?
   6. Are any bedrock outcroppings located on or near the site?

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WORKSHEET 3 — EVALUATION OF ANTICIPATED SITE CONDITIONS
                               (Continued)

7.  Do any borings show indications of encountering bedrock? If so, are any fractures or
   joints identified which may provide conduits for contamination?
8.  What is the hydraulic conductivity of the soils? (See Appendix B.) What is the antici-
   pated time it will take for contaminants to reach the ground water?
9.  Has a confining layer been identified? If so, is contamination expected to be present
   below?  Were past deep borings adequately sealed between strata?
10. What is the anticipated direction of groundwater flow?
11. What are the locations and depths of nearby and downgradient drinking water wells?

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         WORKSHEET 4 — PREPARATION FOR FIELD OPERATIONS
Prior to initiating field work for a subsurface investigation, the following measures may be
taken by the owner/operator/contractor:
   1. Obtain permission from property owners, preferably in writing.           	
   2. Notify the appropriate utility companies or central notification
      organization. (Record date and contact person).

   3. Locate and mark the following lines:                 gas

                                                        telephone

                                                        sewer

                                                        power

                                                        water

                                                        oil

   4. Check available site plans to identify the additional utility lines not
      marked by the utility companies (e.g. connecting service lines
      branching off from the main lines).

   5. Review available information on site conditions (such as type of soil,
      anticipated depth to ground water, and proximity to nearby surface
      water bodies) as well as information on history of site and adjoining
      properties as identified in Worksheets 1 & 2.

   6. Sketch boring/excavation location plan. Select general locations and
      depths for test pits or (at least three) test borings and/or observation
      wells based on the available information. Check locations to verify
      that overhead and underground obstructions are avoided. Typically,
      at least one boring/well should be located upgradient.

   7. Choose the appropriate sampling/excavation technique based on the
      anticipated conditions at the selected locations. (See Exhibit 11 on
      page 42 for Well Drilling Methods.) Test pits or trenches may be used
      when visual observation of a continuous area is desired. However, test
      pits have limited depth; for example, they typically can only extend a
      few feet below the water table.

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      WORKSHEET 4 — PREPARATION FOR FIELD OPERATIONS
                                 (Continued)

8. Address the following miscellaneous issues:

   a. Confirm the following with contractors: site location and
      directions, meeting time, and necessary equipment (drilling
      equipment request should include estimated quantities of rods,
      augers, casing, well screen, grout, and lock boxes).
   b. If decontamination is required, make provisions for steam-cleaning
      equipment and collection and disposal of rinse water. Check with
      the appropriate implementing authority on rinsewater disposal.

   c. Confirm availability of drilling water if rotary drilling is to be used.

   d. Develop health and safety information (including the locations of
      the nearest hospitals) and maintain on the site.

9.  Gather all the equipment and materials necessary for field inspection
   identified on the attached Equipment Lost.

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                                 EQUIPMENT LIST


In order to minimize errors and delays, prepared field personnel will typically be equipped with
the following items:

   Field Notebook

   Weighted tape (may also need chalk, paste, interface probe, and/or electric water level
   reader)

   Protective gloves

   Clean sample containers

   Labels

   Waterproof markers

   Cooler (with ice or dry ice)

   Spray paint/stakes/flagging

   Log sheets

   Decontamination fluid

   Paper towels

   Camera and film

   Bailers and cable and/or pump with tubing                             '

   Plastic bags (e.g. for duplicate samples and contaminated equipment)

   Key to protective casing or road box over well

   Jackknife, large screwdriver, hammer, channel lock pliers

   Directions to site, site plan, emergency telephone numbers

   Hard hat and steel-toe boots

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                                                              REFERENCES
 SOIL AND GROUNDWATER INVESTIGATIONS
                        Barcelona, M.J., J.P. Gibb and R.A. Miller. A Guide to the Selec-
                        tion of Materials for Monitoring Well Construction and Groundwa-
                        ter ffflmplinpr. ISWS Contract Report 327, Illinois State Water
                        Survey, Champaign, IL. 1983.

                        Driscoll, Fletcher G.  Groundwater and Wells. Second Edition.
                        Johnson Division.  1986.

                        Everett, Lome G. Groundwater Monitoring. General Electric
                        Company, Technology Marketing Operation. 1980.

                        Freeze, R. Allan, and John A. Cherry. Groundwater. Prentice-
                        Hall, Inc. 1979.

                        Khanbilbardi, Reza M., and John Fillos. Groundwater Hydrology.
                        CPTlt91T>ination. and Remediation. 1986.

                        Shepard, W.D., "Practical Geohydrological Aspects of Groundwater
                        Contamination."

                        U.S. Environmental Protection Agency, Environmental Monitoring
                        Systems Laboratory. Monitoring in the Vadose Zone:  A Review of
                        Technical Elements and Methods. Interagency Energy-Environ-
                        ment Research and Development Program Report. EPA-600/7-80-
                        134. June 1980.

                        U.S. Geological Survey, Heath, Ralph C.  Basic Ground-water
                        Hydrology.  Water-Supply Paper 2220, United States Government
                        Printing Office.  1983.
REMEDIATION
                        American Petroleum Institute. Cleaning Petroleytn
                        Tanks. API Bulletin 2015. 3rd Edition, September 1985.

                        American Petroleum Institute. Management of Underground
                        Petrolfiym fiforage Systems at Marketing and Distribution
                        Facilities. API Recommended Practice 1635.   3rd Edition,
                        November 1987.

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                                                               REFERENCES
REMEDIATION (CONTINUED)
                         American Petroleum Institute. Removal and Disposal of Used
                         Underground Petmlenm Storage Tanks. API Bulletin 1604.  Rec-
                         ommended Practice, 2nd Edition, 1987.

                         American Petroleum Institute. Underground S/p?ll ClfianuP
                         Manual. API Bulletin 1628.1st Edition, June 1980.

                         Roy F. Weston, Inc., and the University of Massachusetts. Pre-
                         pared for Electric Power Research Institute and Utility Solid
                         Waste Activities Group. Remedial Technologies for Leaking Under-
                         ground Storage Tanks. July 1987.

                         U.S. Environmental Protection Agency, Hazardous Waste Engi-
                         neering Research Laboratory, Office of Solid Waste and Emer-
                         gency Response. Underground Storage Tank Corrective Action
                         Technologies. EPA/625/6-87-015. January 1987.

                         U.S. Environmental Protection Agency, Office of Underground
                         Storage Tanks. Cleanup of Releases from Petroleum USTft:
                         Selected Technologies. EPA/530/UST-88/001. April 1988. Avail-
                         able from Superintendent of Documents, Government Printing
                         Office, Washington, B.C., 20402, Stock No. 055-000-00272-0,
                         (202)783-3238.

                         U.S. Environmental Protection Agency, Office of Underground
                         Storage Tanks. "Tank Closure Without Tears: An Inspector's
                         Safety Guide." 1988. (Video)  See "Video Ordering Information"
                         at end of the References.
LEAK DETECTION
                         American Petroleum Institute. Cathodic Protection of Under-
                         ground Petroleum ^tnrage Tanks and Piping Systems. API
                         Bulletin 1632. 2nd Edition, 1987.

                         American Petroleum Institute. Observation Wells as Release
                         Monitoring Techniques. July 1986.

                         Geonomics, Inc. Soil Vapor Monitoring for Fuel Leak Detection.

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                                                             REFERENCES
LEAK DETECTION (CONTINUED)
                        Maresca, Joseph W. Jr., and Monique Seibel, Vista Research Inc.
                        Volumetric Tank Testing. Prepared for Carol L. Grove, Center for
                        Environmental Research Information, Office of Research and
                        Development, U.S. Environmental Protection Agency. November
                        14,1988.

                        Niaki, 8., and John A. Broscious, IT Corporation. Prepared for
                        John S. Farlow, Releases Control Branch, Hazardous Waste
                        Engineering Research Laboratory, Office of Research and Develop-
                        ment, U.S. Environmental Protection Agency. Draft. Under-
                        ground Tank Leak Detection Methods: A State-of-the-Art Review.

                        U.S. Environmental Protection Agency Environmental Monitoring
                        Systems Laboratory, Office of Research and Development, Survey
                        of Vendors of External PetroHgyrn Leak Monitoring Devices for Use
                        With Underground Storage Tanks. EPA/600/4-87/016. 1987.

STATE MANUALS	

                        New York State Department of Environmental Conservation,
                        Division of Water, Bureau of Water Resources. Recommended
                        Practices for Underground Storage of Ppfrroleym   May 1984.

                        State of California Leaking Underground Fuel Tank Task Force.
                        Leaking1 Underground Fuel Tank Field Manual: Guidelines for Site
                        Assessment. Cleanup, and Underground Storage Tank Closure.
                        December 1987.

VIDEO ORDERING INFORMATION	

                        "Tank Closure Without Tears: An Inspector's Safety Guide"
                        -  Focuses on the problems of explosive vapors, safe tank removal
                           and closure (30 minutes).

                        Purchase:    Video and companion booklet: $25.00 prepaid
                                    Booklet only: $5.00 prepaid
                                    Order from:  New England Interstate Water
                                                Pollution Control Commission
                                                Attn: VIDEOS
                                                85 Merrimac Street
                                                Boston, MA 02114

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                                                      REFERENCES
VIDEO ORDERING INFORMATION (CONTINUED)
                      Loan:
Video and companion booklet: $5.00 prepaid
Order from:  New England Regional
           Wastewater Institute
           2 Fort Road
           South Portland, ME 04106

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                                                                         INDEX
Active vapor control  16,73-77
Adsorptive capacity 23,25,35, 73, 76
Alternative water supplies  17,18, 65, 66
Aquifer (see ground water)
  characteristics 23, 55, 56
  restoration  17,18
  shallow,deep  52
Analytical procedures  39-41
Asphalt batching (see soil
  remediation)
Barriers 61,62,64
Bentonite seals 53-55
Benzene analysis  40,41
Biodegradation 30,31
Boring log  44,45

Cleanup criteria (see
  regulatory requirements)
Combustible gas indicator (CGI) 6,9
Community water supplies  16-18, 65, 66
Confined spaces  6, 7,16
Contaminant migration  7, 8,13,15, 23, 25,
  44, 61, 79-82

Darcy's Law  79, 81
Detection meters  6, 7,9
Draeger tubes  9
Drains  62,63
Drinking water supplies
  (see community and private)
Elevation survey  55, 56
Enhanced volatilization  30, 31,46,47
Explosimeters (see CGIs)
Excavations  30, 83, 84
Filter pack 52-54
Fire and safety hazards  6, 7,9
Flame ionization detector (FID)
9
              Floating (free) product
                containment/recovery
                (from surface waters and
                subsurface collection points)  14,18
                measurement  13, 57, 58
                recovery from ground water  61, 62

              Ground water
                direction of flow 52
                elevation  55, 56, 57
                gradient  52, 79
                sampling  56-60
                use 16,17, 65
                velocity  56,81
              Grout
                as barriers  62
                in boreholes  53-55
              Hydrocarbon vapors  6, 7, 9,16, 28, 36-41
              Incineration 46, 47
              Inventory records 10-12
              Laboratory analyses
                general use 39
                quality control  39, 60
                types of analyses  40, 41
              Lead analysis  41
Man-made structures  7,11
Monitoring well
  design  52-54
  development 54
  floating product in 57, 58
  installation 52-54
  location  52,54, 55
  materials  52-54
  purging  57, 59, 60
  survey  55

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Oxygen indicator 6,9
Unsaturated flow  35, 79
Passive vapor control  16, 71-73
Permeability 23-25, 35, 75, 82
Photoionization detector (PID)  7, 9
Piezometers  55
Porosity  35,55,56
Private water supply wells  16-18
Purging
  disposal of water 60
  pumps  57-59
Vapor control 6,16, 71-77
Ventilation  7,16
Volatile organic compounds (see hydrocarbon
  vapors)
Well drilling methods 38,42
Recovery wells  61-63
Regulatory requirements
  drinking water  17, 61
  reporting  19,31,48,66
  soil remediation  46, 47
  tank removal, repair, closure  28,83-85
Remediation (see
  soil remediation)
Sampling (see ground water, soil
  sampling)
Sheet piles 62
Sinker constituents  52
Slurry walls 62
Soil boring 38,42
Soil gas survey  28,29,36,37
Soil remediation
  asphalt batching 30,31,46,47
  biodegradation  30, 31,46,47
  enhanced volatilization  30, 31,46,47
  excavation/removal 30, 31,46,47
  incineration  46,47
Soil sampling  28,29, 36, 38,43,44
Soil screening  28,29,36,37,38
Split-spoon sampler  43, 44
Surface water  15,18, 61
Tank
  closure 28,83-85
  repair  85
  tightness testing  13, 85
Test pits 38,43
Total petroleum hydrocarbon analysis  17,40
Transport pathway  79-82
Trenches 61-63

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PURPOSE, CONTENT, AND
    ORGANIZATION

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INITIAL RESPONSE

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LIMITED SITE INVESTIGATION

-------
SCENARIO A

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SCENARIO B

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SCENARIO C

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APPENDICES

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WORKSHEETS

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REFERENCES

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INDEX

-------