RCRA CORRECTIVE ACTION CONFERENCE
         March 26-28,1996
 U.S. Environmental Protection Agency
             Region IX

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                       1996 RCRA CORRECTIVE ACTION CONFERENCE
                               U.S. Environmental Protection Agency
                                            Region IX

                                            AGENDA
Tuesday. March 26

8:00 -  9:00  Registration
9:00 -  9:05  Logistics/Conference Structure
9:05 -  9:20  Opening Remarks (Laura Yoshii, EPA Region 9)
9:20 - 10:15  National Perspective-Subpart S, HWIR  (Guy Tomassoni, EPA Headquarters)
10:15-10:30  Region 9 Corrective Action Universe (Larry Bowerman, EPA Region 9)
10:30-10:45  Break
10:45-11:15  State Perspectives (Calif: Watson Gin, Cal-EPA/DTSC)
11:15-11:45  Community Involvement (Denny Larson, Communities for a Better Environment)
11:45- 1:00  LUNCH
1:00 - 1:30   Ecological Toxicity Overview (Clarence Callahan, EPA Region 9)
1:30 - 1:45   Human Health Toxicity Overview (Patrick Wilson EPA Region 9)
1:45 - 2:10   Preliminary Remediation Goals (Dan Stralka, EPA Region 9)
2:10 - 2:30   Cal/TOX and PRGs in California (Jeffrey Wong.Cal-EPA/DTSC)
2:30 - 2:45   Permit Writers Perspective on Cal/TOX (Sarah Picker, Cal-EPA/DTSC)
2:45 - 3:15   Risk/Exposure Assessment Case Study (Ravi Arulanantham, Cal-EPA/RWQCB)
3:15 - 3:30   Break
3:30 - 4:30   RCRA Containment Methods (Jeffrey Dunn and Harold Tuchfeld, Geosyntec Consultants)
4:30 - 5:00   Corrective Action Case Study: Metals Contamination at Square D Company
             (Mohinder Sandhu,  Karen Baker, Cal-EPA/DTSC; Gladys Thomas, Square D)
5:00 - 5:30   Open Discussion with EPA HQ (Guy Tomassoni, EPA  Headquarters)

Wednesday. March 27

8:30 - 10:00  Vadose Zone Contaminant Transport (Ron Sims, Utah State  University)
10:00-10:30  Waste Burial in  Arid Regions (Brian Andraski, US Geological Survey)
10:30-10:45  Break
10:45-11:15  Accelerated Site Characterization (Richard McJunkin, Cal-EPA/DTSC)
11:15-11:45  Water Isotopes as Tracers (Brian Smith, Lawrence Berkeley Laboratory )
11:45-12:15  Soil VOC Methanol Preservation (Kurt Zeppetello, AZ  Dept. of Env. Quality)
12:15- 1:30   LUNCH
1:30 - 2:00   Bacterial Dechlorination of TCE & PCE  (Ned Black. EPA Region 9)
2:00 - 2:45   Leaking Underground Fuel Tank (LUFT) Remediation  (David Rice, LLNL)
2:45 - 3:00   Break
3:00 - 3:30   Technical Impracticability w/Case St. (Matt Hagemann, EPA Region 9)
3:30 - 4:00   Containment Zones (Steve Morse, Cal-EPA/RWQCB)
4:00 - 4:30   IT-Vine Hill Case Study  (Valerie Heusinkveld.Cal-EPA/DTSC; Jane Zevely, IT Vine Hill)
4:30 - 4:45   Closing Remarks (Michael Feeley, EPA  Region 9)
4:45-5:15   Open Mike

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Thursday. March 28 (Regulators Only)

8:30 - 9:00   Importance of Field Oversight (Brian Lewis, Cal-EPA/DTSC)
9:00 -10:00   Laboratory Data Interpretion (Kathy Baylor, Ray Saracino, EPA Region 9)
10:00-10:15   Break
10:15 -12:00  State-Specific Issues (Paula Bisson, EPA Region 9)
12:00        Conference Ends

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                                        Dl   NINC       OUT
                                   D-ClK-flT-CSS-CN
                                     ITflUflH
1 BRASS  ELEPHANT
  GROSVENOR HOTEL
  38O SOUTH AIRPORT BLVD.
  873-32OO
  L: S5.0O-S8.OO
  D: SIO.oo-SI 5.OO


2 BURGER KING
  972 EL CAMINO REAL
  583-7O92
  L,D: S2.OO-S5.OO


3 CAFE ON THE PARK
  RAMADA INN
  245 SOUTH AIRPORT BLVD.
  589-7200
  L: S5.OO-S7.OO
  D: S1O.OO-S1 8.0O


4 CITY CAFE
  HOLIDAY INN
  275 SOUTH AIRPORT BLVD.
  873-3550
  L: S5.OO-S7.OO
  D: S8.0O-S1 2.OO


5 HUNGRY HUNTER
  180 SOUTH AIRPORT BLVD.
  873-5131
  L:  S5.00-S8.00
  D: S 1 2.OO-S1 6.OO


6 JO ANN'S CAFE
  1131  EL CAMINO  REAL
  872-2810
  L:  S6.0O-S9.OO


7 LYON'S RESTAURANT
  10 AIRPORT BLVD.
  871-5885
  L:  S6.OO-S8.OO
  D: S8.00-S1 2.00


g ST. MAMES BAR &  GRILL
  CROWN STERLING
  250 GATEWAY BLVD.
  589-34OO
  L: S8.OO-S1 2.OO
  D: $13.00-518.00
 9  D & M LIQUOR & DELI
    21 1  SPRUCE AVE.
    583-4121
    L,D: S3.OO-S6.OO


10  DARBY DANS
    GOURMET SANDWICH
    733 AIRPORT BLVD.
    876-0122
    L,D: S4.00-S7.00


 11  LA TAPATIA
    41 1  GRAND AVE.
    589-5881
    L,D: S4.0O-S8.OO
 12 LIBERTY DELI-MART
    812 LINDEN AVE.
    583-7892
    L,D: S3.OO-S6.OO
13
    LITTLE LUCCA DELI
    724 EL CAMINO REAL
    589-8916
    L,D: S4.OO-7.OO
14
16  BERTOLUCCI'S RESTAURANT
    421 CYPRESS AVE.
    588-1625
    L: S8.00-S 12.00
    D: S15.OO-S2O.OO


17  BUON GUSTO RESTAURANT
    224 GRAND AVE.
    742-9777
    L: S8.OO-S 12.OO
    D: S12.OO-S18.OO


18  CAPRI RESTAURANT
    1129  EL CAMINO REAL
    588-6078
    D: S8.OO-S 12.0O


19  Dl NAPOLI PIZZA/PASTA
    608 LINDEN AVE.
    873-5252
    L: S5.OO-S9.OO
    D: S8.00-S 12.00


20  PASTA MOON  EAST,  INC.
    425 MARINA BLVD.
    876-7O90
    L: S8.OO-S1 2.OO
    D: S12.OO-S18.OO
    BASQUE CULTURAL CENTER
    599 RAILROAD AVE.
    583-8O91
    L: S8.OO-S 12.00
    D: S12.OO-S18.OO
     m-EXK-flN
 15  EL CHARRO
     257 GRAND  AVE.
     873-1 993
     L,D: S4.OO-S8.OO

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                                                                 San Bruno Mountain
                                                                    County Park
NOTE:Restaurant locations
     are approximate
                                                                                                          San Francisco Bay

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RCRA CORRECTIVE ACTION CONFERENCE
         March 26 - 28,1996

          South San Francisco, CA
 U.S. Environmental Protection Agency
                iron IX

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                            TABLE OF CONTENTS

                                                                         Section
INTRODUCTION                                                           »
SPEAKER'S NOTES

   Day 1 Topic/Speaker
      EPA Headquarters Issues, Guy Tomassoni                                  1
      Reg. 9 Corrective Action Universe, Larry Bowerman                        2
      Fundamentals of Ecological Risk Assessment,  Clarence Callahan            3
      Preliminary Remediation Goals (PRGs), Dan Stralka                        4
      Cal/TOX and PRGs, Jeff Wong                                           5
      Risk-Based Soil Cleanup Goals, Ravi Arulanantham                         6
      RCRA Containment Methods, Jeffrey Dunn and Harold Tuchfeld            7
      Corrective Action Case Study, M. Sandhu, K. Baker, G. Thomas              8

   Day 2 Topic/Speaker
      Vadose Zone Contaminant Transport, Ronald Sims                          9
      Waste Burial in Arid Regions, Brian Andraski                               10
      Accelerated Site Characterization, Richard McJunkm                         1 1
      Use of Stable Isotopes in Groundwater Monitoring, Brian Smith               12
      Soil VOC Methanol Preservation, Kurt Zeppetello                            \ 3
      Bacterial Degradation of Chlorinated Solvents,  Ned Black                     14
      Leaking Underground Fuel Tank (LUFT) Remediation, David Rice             15
      Technical Impracticability, Man Hagemann                                 16
      Containment Zones, Steve Morse                                          17

   Day 3 Topic/Speaker
      Importance of Field Oversight for Groundwater Sampling, Brian Lewis         18

APPENDICES
      A.  Speaker Biographies
      B.  Attendee List

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 INTRODUCTION

   Welcome to the EPA Region 9 1996 RCRA Corrective Action Conference.  We believe
 the conference is an excellent forum for people working on corrective action from all over the
 region to meet each other and share their ideas and experiences.  Thank you for attending.

   Corrective action is a very large and important program throughout EPA Region 9.  In
 general, corrective action is the process of investigating and cleaning-up chemical releases
 from hazardous waste management facilities. The Resource Conservation and Recovery Act
 (RCRA), as amended, provides EPA with the legal authority to require corrective action at
 hazardous waste management facilities. The corrective action process involves many
 disciplines, including, hydrogeology, toxicology, ecology,  treatment processes and many
 others.  The speakers at the conference will  discuss many of these interesting areas along  with
 a number of case studies.

   The primary purpose of this document is to provide participants at the conference with  a
 compilation of speakers notes.  Not all of the speakers have provided material for inclusion
 into this compilation.  For easier reference, the notes are listed in the same sequence as the
 presentations on the conference agenda.

 DISCLAIMER

   The presenters' notes or outlines in this document have been supplied by the speakers and
 have not been peer reviewed by EPA.  Views expressed either in the notes or in the
 presentations are strictly those of the individual speakers and do not necessarily represent
 Federal, State or local policy.  EPA is  not responsible for any errors in the notes or
 presentations.  Moreover, mention of trade names, commercial products, or publications does
 not constitute endorsement or recommendation for use.
ACKNOWLEDGMENTS

This conference was planned and organized by the following individuals from U.S. EPA
Region 9-
     Planning Committee

Kathenne Baylor (Co-Chair)
Ron Leach (Co-Chair)
Mary Blevins
Susan Chiu
Tom Kelly
Steve Lmder
Elaine Ngo
Carmen Santos
Ray Saracino
Vicky Semones*
Carl Warren
Nahid Zoueshtiagh
 Management

Laura Yoshii
Michael Feeley
Larry Bowerman
Paula Bisson
                                                Contractor **

                                                Suzanne Kraft
                                                Neil Munro
 *  Office of Community Relations
**  PRC Environmental Management, Inc.

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1

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   EPA HEADQUARTERS ISSUES

            presented at

           REGION IX
CORRECTIVE ACTION CONFERENCE
               by

           Guy Tomassoni
       USEPA, Office of Solid Waste
            703/308-8622

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        EPA ISSUES
to
              Subpart S Initiative
              HWIR-Contaminated Media Rule
              Post-Closure Rule
Legislative Activities
              Miscellaneous
              Summary

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        Subpart S Initiative
u
Five primary objectives

1 .  Create a consistent, holistic approach to cleanup at
   RCRA facilities

2.  Establish protective, practical cleanup expectations

3.  Shift more of the responsibilities for achieving
   cleanup goals to the regulated community

4.  Focus on opportunities to streamline and reduce
   costs
               5.  Increase opportunities for meaningful public   / **  \
                  involvement throughout corrective action

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Subpart S Initiative (cont.)
      Issue Advance Notice of Proposed Rulemaking
      (ANPR), developed through EPA/State Workgroup

      ANPR has three purposes:

      -   Open a dialogue on program development and
         improvement (i.e., introduces strategy for initiative
         and seeks broad-based comments to help identify
         and develop program improvements)

      -   To provide context for comments, includes a
         general status report on program and how it has
         evolved since 1990 proposal

         Emphasizes areas of current flexibility


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Subpart S Initiative (cont.)
      Some of the key messages conveyed in ANPR

      -   No one approach to cleanup is appropriate for all
          corrective action facilities

          Focus on results rather than a prescribed
          mechanistic cleanup process

      -   Focus resources first on controlling unacceptable
          exposures and stabilizing continuing releases

      -   Corrective action obligations should be addressed
          using the most appropriate tool for any given
          facility, including RCRA orders or permits,       *
          state cleanup orders, and voluntary programs \

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Subpart S Initiative (cont.)
       Summarizes key elements of 1990 proposal, recent
       policy developments, and areas of flexibility, including:

       Principle of parity between RCRA and Superfund
       Role of voluntary cleanup
       Cleanup of non-SWMU releases
       Use of data quality objective (DQO) concept
       Use of innovative site characterization techniques
       Role of human health and ecologic risk assessment
       Formal corrective measures study not always needed
       Role of action levels
       Natural attenuation
       Technical impracticability
       Media cleanup standards and points of compliance
       Recognizing non-residential land use assumptions
       Stabilization initiative and relat. to interim measures
       Use of presumptive, remedies
       Phasing corrective action

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Subpart S  Initiative (cont.)
        AN PR requests comment on:

        General implementation of CA program
        Scope and form of final corrective action regulations
        Elements of 1990 proposal needing additional notice/comment
        Self-implementing corrective action, including third-party oversight
        Land use assumptions and institutional controls
        Point of compliance issues
        Measuring and enforcing performance standards
        Focusing less on SWMU
        State authorization and role of EPA in authorized states
        Life of corrective action permits
        Affect of property transfer on CA requirements (selling of SWMU)
        Financial assurance
        Expanding opportunities for public involvement
        Voluntary cleanup
        Applicability of ASTM RBCA approach                       /       \
        Life of corrective action permits

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         Subpart S Initiative (cont.)
CO
                Next Steps
Publish ANPR in federal register and place on Internet;
90 day comment period

Assess comments and develop strategy for developing
guidance and re-proposing/finalizing corrective action
regulations

-  Target, strategy by fall 1996

~  Target, re-proposal/final rule by fall 1997
                HQ contact Guy Tomassoni 703/308-8622 or
                Hugh Davis 703/308-8633


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        HWIR-Contaminated Media Rule
to
Official title "Requirements for the Management of
Hazardous Contaminated Media" - commonly referred to as
the  "Hazardous Waste Identification Rule for Contaminated
Media or (HWIR-media)"

Rule would establish a "bright line"

    Contaminated media above bright line would remain
    subject to Subtitle C

    Below bright line, EPA and authorized states would have
    authority to exempt media from Subtitle C

Rule will modify RCRA requirements (e.g., LDRs,
MTRs, and permitting) for contaminated media

                                                              •*i

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HWIR-Contaminated Media Rule (cont.)

•      HWIR-media does not set cleanup standards

          Rule addresses contaminated media generated by cleanup;
          Subpart S addresses when, how and to what extent
          cleanup should be conducted.

•      Would withdraw Corrective Action Management Unit
       (CAMU) regulations

          CAMUs approved prior to final HWIR-media rule (which
          would officially withdraw CAMU - expected June 1997)
          would be "grandfathered"

•      Proposal expected March/April 1996; HQcontact:
       Carolyn Hoskinson 703/308-8626^

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Post-Closure Rule
       Proposed November 1994

       1.  Remove the Post-Closure (PC) Permit Requirement

              Would remove requirement to obtain permit for post-
              closure period and allow EPA/authorized State to use
              other authorities to address PC provisions

       2.  Remove closure requirements at regulated units for
          facilities that require corrective action

              Would allow EPA discretion to address those units
              through the corrective action process
       HQ contact: Barbara Foster 703/308-7057


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Legislative Reform
       Reform negotiations for both RCRA and Superfund continue

       RCRA "Rifleshots" may clarify requirements for managing
       contaminated media

       Superfund Re-authorization

          EPA has committed to substantive consistency between
          RCRA and Superfund cleanups

          Superfund legislative  reforms may affect RCRA
          requirements for remedy selection, how clean is clean
                                                      ^  **

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Miscellaneous Issues (cont.)
      RCRA/CERCLA Integration Guidance; plan to issue memo in
      April '96 addressing:

      1 .   coordination among EPA RCRA, EPA CERCLA and
          state cleanup programs;

      2.   concept of parity between RCRA corrective action and
          CERCLA and state programs; and

      3.   coordination of closure of regulated units with other
          cleanup activities.
          HQ contact: Hugh Davis 703/308-8622
                                                          \

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Miscellaneous Issues  (cont.)
      Use of Area of Contamination (AOC) concept during RCRA
      cleanups; plan to issue guidance memorandum in very near
      future.

          Memo conveys that under certain conditions, hazardous
          wastes may be moved within broad areas of
          contamination without triggering RCRA LDRs and MTRs

          Memo also describes distinctions between final CAMU
          regulations and the AOC approach

          Not the same issue as area of concern under RCRA CA
          HQ contact: Hugh Davis


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Miscellaneous  Issues (cont.)
       "Environmental Indicators" as a new approach for measuring
       results rather than process

       Currently, two indicators: Human Exposures Controlled and
       Ground Water Releases Controlled

       Guidance on these indicators is available in the RCRIS Data
       Element Dictionary under codes CA725 and CA750

       Interested in feedback on successes/problems

       Goal of FY '97 for evaluating all facilities currently being
       addressed by corrective action

       HQ contact: Sue Parker 703/308-8653
Ul

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         Summary
0>
EPA and States have made considerable progress

Improvements are still necessary

Goal is to improve speed, efficiency, protectiveness and
responsiveness, and to focus program more clearly on
environmental results

Communication of our experiences is paramount

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2

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   The Corrective Action
   Universe for EPA
   Region 9
   By Larry Bowerman, Chief
   Corrective Action Section
   (415)744-2051
RCRA Corrective Action
Program Goals

• Focus resources at high priority facilities.
• Complete assessments at all TSDFs by the end
 ofFY96.
• Emphasize the stabilization initiative.
• Enhance State capabilities through effective
 work-sharing arrangements.
• Tailor oversight of corrective action activities
 based on facility specific conditions.
Corrective Action Topics
to be Covered

• Program goals and authorities.
• Universes (facilities subject to corrective action).
• Environmental Priorities Initiative (EPI).
• Stabilization Initiative.
• Corrective Action Pipeline.
 RCRA Corrective Action
 Authorities

 • 3004(u) - Continuing releases at permitted
  facilities (including Solid Waste Management
  Units, or SWMUs)
 • 3004(v) - Corrective Action Beyond Facility
  Boundary
 • 3008(h) - Interim Status Corrective Action Orders
 • 7003- Imminent  Hazard

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Corrective Action
Workload Universe (Tier 1)
' 376 facilities in Region 9.
> Active and closing TSDFs.
 TSDFs closed with waste in place.
 Facilities referred to Superfund.
< Abandonned facilities.
' Delay of closure facilities.
Environmental Priorities
Initiative  (EPI) Goals

• Assess and rank all TSDFs by end of FY1996.
• Address the worst release problems first.
• Ensure all high priority facilities are being
 addressed.
                                                         Other Facilities Subject to
                                                         Corrective Action (Tier 2)

                                                         • About 300 additional facilities in Region 9.
                                                         • Clean closed facilities.
                                                         • 90 day converters.
                                                         • Illegal Units.
                                                         • Permit by Rule.
                                                         EPI Activities in Region 9


                                                         • 96% of TSDFs have been assessed and ranked
                                                          as of 9/30/95; the remaining 13 facilities will be
                                                          assessed in FY1996.
                                                         • About two thirds of the 'Tier 2" facilities have also
                                                          been ranked; we are exploring whether we have
                                                          the resources to rank the remaining 100 facilities.
                                                         • In general all known high and medium priority
                                                          facilities are being addressed by EPA and/or
                                                          states.
                                                         • We  are currently reviewing high priority sites to
                                                          ensure appropriate follow-up is occurring.
                                                         • vye  are continuing our efforts to ensure that this
                                                          information is accurately reflected in RCRIS.

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 RCRA Corrective Action
 NCAPS ASSESSMENT
 California Workload Universe = 310
 September 30,1995
                         High 31 o%
              	(96)
             ^m^^^m
    Medium 2.10*
     (Tfl
                              Unassessed 32%
                                (10]
Stabilization Initiative
Goals

• Control or abate threats to human health and/or
 the environment from releases at RCRA facilities.
• Prevent or minimize the further spread of
 contamination while long-term remedies are
 pursued.
• Work with authorized states to ensure
 implementation of the Stabilization Initiative.
• Develop an accurate tracking system for
 stabilization activities.
RCRA Corrective Action
NCAPS ASSESSMENT
HANG Universe = 66
September 30,1995
        Medium 288%

         (19)
                                                                                         Unassessed «s%

                                                                                           (3)
Stabilization Activities in

Region  9

• 96% of TSDFs have been evaluated as of
 9/30/95; the  remaining 15 facilities will be
 evaluated in  FY1996.
• Where further investigation is needed, we will
 ensure that the investigation is conducted by the
 facility, state and/or EPA.
• Where stabilization is found to be necessary and
 appropriate,  we will ensure that stabilization is
 actually implemented by the facility, state and/or
 EPA.
• We are continuing our efforts lo ensure that this
 information is accurately reflected in RCRIS.

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Stabilization Initiative -

Lessons  Learned

• We should devote more time and effort to the
 Stabilization Initiative.
• Of 62 facilities requiring stabilization:
  - 58 (93%) have stabilization imposed
  - 46 (74%) have implemented measures
• Need to follow-up on the 60 facilities where
 further investigation is needed.
• Consider evaluating the approx. 300 Tier 2
 facilities; many may not require an evaluation.
 RCRA Corrective Action
 STABILIZATION EVALUATIONS
 September 30,1995
            7

         Arizona

      Workload Univ. - 35
                      Guam
                   Workload Univ -4
      4

   Hawaii
Workload Unrv - 13
                            Nevada
                         Workload Univ • 12
        • Not evaluated • Stab required  D Stab not req
        O Not feasible D Inveslig needed • None needed
                                                     RCRA Corrective Action
                                                     Stabilization Evaluations
                                                     September 30,1995
                                                      Slab not required 109
                                                               Inveslig needed
                                                                             Stab required
                                                                                Not evaluated 12
                                                                                Not Feasible 2
                                                                             None needed M
                                                                           lo«f Prior Of CERCLA l«ad
                                                                            California
                                                                         Workload Univ. = 310
Corrective Action  Pipeline

Status and Issues

• The pipeline graphics are based on RCRIS data.
• The pipeline consists of activities from the RCRA
 Facility Assessment (RFA) to Corrective
 Measures Implementation (CMI).
• Are all high priority facilities being adequately
 addressed?
    -Yes, in fact, with only a few exceptions, all
    known high and medium priority facilities are
    being addressed by EPA, DTSC, RWQCBs or
    local agencies.
    -The Analogous Project provides a way for
    EPA and DTSC to become familiar with
  other agency's clean-up activities at TSDFs
  and to record them in RCRIS.

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RCRA Analogous Project
' Goal: recognize work at sites deferred to
 non-RCRA agencies.
 Accomplishments:
 Better understanding and management of RCRA
 universe; we reviewed a total of 86 SMP and
 RWQCB sites.
 RCRIS data greatly expanded.
 Tangible measure of SMP and RWQCB
 contributions.
 Duplication of effort minimized.
 Facility deferral effective.
   California High Priority Sites
     C A100 CA190  CAJOO CA25O  C*300 CA35O  C A«00  CASOO CASW
             I Pipeline Status as of FY 95
 Corrective Action Pipeline

 Status and Issues (cont.)
 The universe is not static; rankings can change
 based on new information, clean-ups or
 stabilization actions.
 Are we appropriately disinvesting in low/medium
 priority and/or stabilized facilities to focus more
 attention on unstabilized and other high priority
 faciltities?
 Are facilities moving through the "pipeline" fast
 enough? Can combine RFI/CMS Workplans and
 Reports to  increase efficiency.
' Are states adequately implementing corrective
 action?
' Is EPA adequately guiding, assisting and training
 states to implement the corrective action
 program?
  California Medium Priority Sites

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        HANG States High Priority Sites
                                       P
           CA100 C*1W  C«00  C«» CAMO  CA3» CA*»  C«5OJ  CA550
                   • Pipotrw SI« M 01 n -95
        Sourca RCPIS CAtFOtA Rtfxyt
rp
CD
HANG States Medium Priority
Sites
                                                                      CAJOD CA2W CJOOO CA39O CA400 CA9OO  CASIO

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3

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                                          DRAFT

U.S. Environmental Protection  Agency  Region 9
       Ecological Risk Assessment Guidance
                     for Superfund  Sites
            Clarence A. Callahan and B. Douglas Steele (H-9-3)
                  U.S. Environmental Protection Agency
                               Region 9
                          75 Hawthorne Street
                        San Francisco, CA 94105
 ABSTRACT
      Ecological Risk Assessment at Superfund sites is an iterative process with
 phases that builds a database with the integration of information at each step.
 This document provides guidance that is integral to the Remedial Investigation/
 Feasibility Study activities as part of the overall Superfund process. The
 guidance includes checkpoints for deciding the adequacy and interpretation of
 data gathered for interpreting potential ecological exposure, ecological impact
 and risk characterization.  All available data are summarized in the site Scoping
 Phase (Phase 1) for use in a Preliminary Impact Assessment (Phase 2); relevant
 site-specific data are gathered, integrated and interpreted in the Confirmatory
 Phase (Phase 3) and the Risk Characterization Phase (Phase 4); and finally,
 focused and comprehensive data are collected in the Remedial Guidance Phase
 (Phase 5) to direct the remedial action. This guidance material is adapted from
 Agency material from the Superfund program and publications in the open
 literature.  Issues include the description of assessment and measurement
 endpoints, background or reference data, identification of chemicals of concern,
 site receptors, site conceptual models, detection limits, and approaches for the
 impact assessment of contaminants. This guidance material stresses the
 interaction of all participants throughout the process of ecological risk
 assessment at Superfund sites.
Key Words:  Superfund, Ecological, Risk, Assessment, Remediation
                               DRAFT
                                  3-1

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          FUNDAMENTALS OF
    ECOLOGICAL RISK ASSESSMENT
u
rb
            Clarence A. Callahan, PhD
              BTAG Coordinator
               USEPA Region 9
          San Francisco, California 94105
              Phone 415/744-2314
              FAX 415/744-1916
   CA Callahan USEPA. Region 9

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    - Preliminary Assessment
    - Site Inspection
    - NPL Listing
Ecological Assessment in the RI/FS Process
                      Site
                 Characterization
                      (RI)
         PROBLEM
       FORMULATION

    Review ecological data
  collected from site inspection
       and other studies

    Review sampling data
       collection plans

    Formulate preliminary
      remediation goals

    Determine level of effort
     for baseline ecological
        risk assessment
     Establishment of
     Remedial Action
        Objectives
          '(FS)
Development &    Detailed
 Screening of    Analysis of
 Alternatives    Alternatives
     (FS)          (FS)
           Refine remedial goals
                 based on
              risk assessment
               and ARARs
- Remedy Selection
- Record of Decision
- Remedial Design
- Remedial Action
            Conduct Risk
            Evaluation of
              remedial
             alternatives
                                             f
    Ecological
   Monitoring
  CONDUCT BASELINE ECOLOGICAL
    ASSESSMENT
       - Exposure Assessment
       - Ecological Effects Assessment
       - Field Verification/Remedial Guidance
       - Risk Characterization
                                   T
CA Cllllhin USEPA Rein*. 9

-------
                           PHASED APPROACH FOR ECOLOGICAL ASSESSMENT
w
                            PHASE I, SCOPING
                       I. Data Quality Objectives
                         •Develop assessment goals
                         -Set confidence limits
                         -Establish data acceptiblility criteria

                       2. Data Identification and Collection
                         -PA/SI Informatioin
                         -Site Reconnaissance Survey
                         -Others
                       3. Conceptual Site Ecological Model
                         -ID potential stressors of concern
                         -ID potential ecological receptors
                         -ID potential exposure pathways
    PHASE  II ACTIVITIES
 1. Phase II Workplan
 2. Toxicity data bases searched
 3. Literature searched
 4. Preliminary Assessment e.g.,
 Gradient analysis or Screening I.e., H.Q.
i.e., H.Q.
i

DECISION*
POINT
    PHASE HI ACTIVITIES
Phase HI Workplan for Confirmation of
     Preliminary Assessment
•Scope of Work for Phase III
-Data Quality Objectives
-Seasonal Site Observations
                                                                                            HAVE DQOs
                                                                                            BEEN MET
     PHASE HI
      REPORT
DECISION
 POINT*
                             SCOPING REPORT
                         1. Identification of potential risks
                         2. Identification of data gaps
                         3. Establish Endpoints
                           -Assessment Endpoings
                           -Measurement Endpoints
                         4. Site Conceptual Model Defined
                                           'Regulatory/Resource
                                            Agency Involvement
                                            In this decision.
         PHASE V ACTIVITIES
         I. Work Plan Developed
          •Scope of Work Defined
          •Level of Effort
          -Recommended Approaches
         2. Results and Conclusions
         3. Post ROD Monitoring
            Recommendations
                           PHASE IV
                    RISK CHARACTERIZATION;
                    ARE THERE SIGNIFICANT
                     ECOLOGICAL IMPACTS?*
                                                                                               YES
                                      Mitigation and/or
                                         Remediation
                   CJtCilUI»IISEM.I«*_*

-------
             Ecological Risk Assessment
                    Fundamentals
                                 Potential
                                 Receptors
Chemicals of
  Concern
                   lexicological, Biological
                       or Ecological
                         Impact
       CA Callahan USEPA, Rcjtion 9
@
             3-5

-------
     Ecological Risk Assessment
             Fundamentals
       Chemicals of
         Concern
Potential
Receptors
            lexicological, Biological
                or Ecological
                   Impact
Concentrations
 high enough, but
potential receptors
   are lacking
C.A Callahan USEPA. Union V
                     3-6

-------
      Ecological Risk Assessment
              Fundamentals
 Chemicals of Concern and receptors are
 present, but concentrations are not high
 enough for biological or ecological impact
                            Potential
                           Receptors
Chemicals of
  Concern
             lexicological, Biological
                 or Ecological
                   Impact
CA Callohjn USEPA, Rerun V
                       3-7

-------
     Ecological Risk Assessment
             Fundamentals
                           Potential
                          Receptors
Chemicals of
  Concern
            Toxicological, Biological
                or Ecological
                   Impact  ^  Potential
                          receptors impacted by
                          something other than
                           chemicals of concern
                              e.g., habitat
C.A Callahan USEPA. Region 9
                      3-8

-------
     Ecological Risk Assessment
             Fundamentals
                          Potential
                          Receptors
Chemicals of
  Concern
           All conditions met,
         toxicological, biological
             or ecological
            impact observed
CA Callahon USEPA. Region V
                     3-9

-------
      Ecological Risk Assessment
              Fundamentals
 Chemicals of Concern and receptors are
 present, but concentrations are not high
 enough for biological or ecological impact
                             Potential
                            Receptors
Chemicals
  Concern
Concentrations are
 high enough, but
potential receptors
   are lacking
     lexicological, Biological
          or Ecological
            Imriact    /  Potential
                    receptors impacted by
                     something other than
                     chemicals of concern
                         e.g., habitat
C.A Callahan USCPA. Rcfion »
            All conditions met,
           toxicological, biological
               or ecological
              impact observed
                       3-10

-------
    PHASED  APPROACH FOR ECOLOGICAL ASSESSMENT
    PHASE I, SCOPING
1. Data Quality Objectives
  -Develop assessment goals
  -Set confidence limits
  -Establish data acccplihlility criteria

2. Data Identification and Collection
  -PA/SI Informal iitin
  -Site Reconnaissance Survey
  -Others
3. Conceptual Site Ecological Model
  -ID potential stressors of concern
  -ID potential ecological receptors
  -ID potential exposure pathways
                PHASE II ACTIVITIES
             I. Phase II Workplan
             2. Toxicily data bases searched
             3. Literature searched
             4. Preliminary Assessment e.g.,
             Gradient analysis or Screening i.e., H.Q.
i.e., H.Q.
i

DECISION*
POINT
«
                 PHASE III ACTIVITIES
             Phase III Workplan for Confirmation of
                  Preliminary Assessment
             •Scope of Work for Phase III
             -Data Quality Objectivies
             -Seasonal Site Observations
                                                                    HAVE DQOs
                                                                    BEEN MET
                 PHASE III
                  REPORT
DECISION
 POINT*
      SCOPING REPORT
  1. Identification of potential risks
  2. Identification of data gaps
  3. Establish Endpoinls
   -Assessment Endpoings
   •Measurement Endpoinls
  4. Site Conceptual Model Denned
                    * Regulatory /Resource
                    Agency Involvement
                     in this decision.
         PHASE V ACTIVITIES
         1. Work Plan Developed
          -Scope of Work Defined
          -Level of Effort
          -Recommended Approaches
         2. Results and Conclusions
         3. Post ROD Monitoring
           Recommendations
                                       PHASE IV
                                RISK CHARACTERIZATION;
                                ARE THERE SIGNIFICANT
                                 ECOLOGICAL IMPACTS?*
                                                                       YES
                                                  Mitigation and/or
                                                     Remediation

-------
      TOXICITY  QUOTIENT

                   METHOD'
          TQ    =
                          c
                          v-' end-point
Where:
TQ     = Toxicity Quotient

EPCs  = Exposure Point Concentration

Qd*-.   = Concentration associated with a

     particular biological effect based on the

     Effects Assessment for indigenous or closely

     related species.

Requirements:
     -EPCs are the measured concentrations on the site;
     "Qaid-pon* is based on the potential receptors for the site being assessed. It is not advisible to
      substitue species nor to extrapolate to other species or genera without exposure response
      relationships for the surrogate and the particular chemical of concern.
Interpretation:
     -Interpretation of the TQ is the goal of this assessment and comparisons of the potential
     effects are compared to the TQ for concentrations obtained in the reference area(s).

	Menrie and Cura, 1991
                           3-12

-------
   BIOASSAY STRATEGY FOR MEASUREING
  TOXICOLOGICAL OR BIOLOGICAL EFFECTS
                               Greatest Response at
                               Highest Concentration
                 Reference Site Response
 Observable
 Effects
CA billion USEFA.Rqaf
Reference  Low    Medium   High
 CONTAMINANT CONCENTRA-

-------
                                Cochato River
                                        122        .  /-/

                                        .   N  -/fir
                                           /  > • /  *^*tM
 Toxicity Ranking
 7 Day Test Data
  4 Most Toxic
o 3 Moderately Toxic  o
  2 Least Toxic
  1 Nontoxic
D  Damaged

-------
                           IX  vm C°cnato River
                                                                      fClay Cap J
TOXICITY RANKING
7 DAY TEST DATA
Overland
Runoff
                                              No-Name
                                              Brook

-------
        ECOLOGICAL RISK ASSESSMENT
         GUIDANCE FOR SUPERFUND:

  PROCESS FOR DESIGNING AND CONDUCTING
       ECOLOGICAL RISK ASSESSMENTS
                    DRAFT
         U.S. Environmental Protection Agency
            Environmental Response Team
                  Edison, NJ
ry?AFT
  "            September 26, 1994
                 Review Draft
                   3-16

-------
             California
75 HAWTHORNE ST.. H-93
SAN FRANCISCO. CA 941O5
   (415)744-2314

 FAX (415) 744-1916
 Department of loxic Substances Control

   GUIDANCE FOR ECOLOGICAL RISK
ASSESSMENT AT HAZARDOUS WASTE SITES
        AND PERMITTED FACILITIES

     PART B: SCOPING ASSESSMENT
                State of California
         California Environmental Protection Agency


           Department of Toxic Substances Control
              Office of Scientific Affairs
            Human and Ecological Risk Section


                 SEPTEMBER, 1994
       THIS GUIDANCE IS FOR REVIEW AND COMMENT ONLY
                      3-17

-------
     Development of Ecological Exit
     Criteria for the Hazardous Waste
            Identification Project

                   Review Draft

                     April 1994
Prepared for
U.S. Environmental Protection Agency
Office of Solid Waste
Contract No. 68-D2-0065
                          3-18
Prepared by
/RT»
Research Triangle Institute
Project 5810-43

-------
   xvEPA
                                United States
                                Environmental Protection
                                Agency
                                                     Off ice of
                                                     Solid Waste and
                                                     Emergency Response
Publication 9345.0-051   '
December 1991       '
                             ECO   Update
   Office of Emergency and Remedial Response
   Hazardous Site Evaluation Division (OS-230)
                                                                         Intermittent Bulletin
                                                                         Volume 1. Number 2
   Ecological Assessment of Superfund Sites:
                                 An  Overview
    This document is the second issue of the ECO Update
series of Intermittent Bulletins, published by the Toxics
Integration Branch, Hazardous Site Evaluation Division.
Office of Emergency and Remedial Response. Practical
experience with the process of ecological assessment at
Superfund sites has pointed to the need for information and
guidance concerning both the scientific and management
aspects of ecological assessment. The ECO Update series is
intended to fill this need.
    Ecological Assessment cfSuperfundSites:An Overview
is an updated framework for ecological assessment in the
Superfund program. As such, it offers a description  of
ecological assessment components and a discussion of how
they fit  into the Remedial Investigation and Feasibility
Study (RI/FS) process. Ecological assessment in the re-
moval process will be xMrp-wf-d in a future ECO Update.
The ECO Update Series

    ECO Updates are a series of Intermittent Bulletins intended
to facilitate ecological assessment of Superfund sites. Each Bulle-
tin focuses on one aspect of ecological studies or ecological
assessment in the remedial process. Individual Bulletins may
discuss either technical methods or the management of ecological
assessments.
                                                     Limiting eachBuQetintoaspecific topic allows flexibility for
                                                  the user to select only those Bulletins that are applicable to the site
                                                  in question or the user's needs. For example, some sites do not
                                                  require toxirity tests, so investigators would not need to consult
                                                  Bulletins specific to testing. A user who needs only general
                                                  information on Natural Resource Trustees can refer to a specific
                                                  Bulletin on that topic  and not have to  look through a larger
                                                  document containing other, less relevant information.
                                                     The Bulletin series is written for both general and technical
                                                  audiences, which includes EPA site managers and staff, contrac-
                                                  tors. State personnel, and anyone else involved in the performance,
                                                  supervision, or evaluation of ecological assessments in Superfund.
                                                     Ecological assessment involves considerable professional
                                                  judgment. The ECO Updates assume that readers will confer
                                                  with qualified scientists for site-specific advice. These Bulletins
                                                  are not step-by-step guides on how to accomplish an assessment.
                                                  The series supplements the advisory process involving Regional
                                                  Biological Technical Assistance Croups (BTAGs). EPA staff
                                                  should consult their BTAG coordinator for more detailed infor-
                                                  mation on ecological assessment in their  Region.
                                                           IN  THIS  BULLETIN

                                               Background	2
                                               What is an Ecological Assessment?	_..2
                                               Ecological Assessment In the Rl/FS Process		6
  ECO Update u a Bulletin series on ecological assessment of Superfund sites. These Bulletins serve as supplements to Risk Assessment Guidance
  trSuferfiuut.Volume II: Environmental Evaluation Manual (EPA/540-1-89/001). The mformation presented is intended as guidance to EPA tnd
   her government employees. It does not constitute nilemaking by die Agency, and may not be relied on to create a substantive or procedural right
  Alorceaole by any outer person. The Government may take action that is at variance with these Bulletins.
                                                 3-19
                                                                        Printed on Recycled Paper

-------
  &EPA
                            United States
                            Environmental Protection
                            Agency
                     Office of
                     SoDd Waste and
                     Emergency Response
Publication 9345.0-051
May 1992
ECO  Update
  Office of Emergency and Remedial Response
  Hazardous Site Evaluation Division (OS-230)
                                       Intermittent Bulletin
                                       Volume 1. Number 4
           Developing  A Work Scope  For
                 Ecological  Assessments
       This Bulletin is intended for Remedial Project
  Managers (RPMs), to help them plan and manage
  ecological assessments of sites as part of the Remedial
  Investigation and Feasibility Study (RI/FS) process.1
  As used here, the generic term work scope describes
  the process of specifying the work to be done for the
  ecological assessment, as part of the overall RI Work
  Plan. The term encompasses project scoping, devel-
  opment and approval of the Work Plan, and prepara-
  tion of the Statement of Work (SOW) for contractors
  (at Fund-lead sites).
       The outcome of a successfully executed work
  scope should be an ecological assessment that in-
  cludes four essential components: problem formula-
  tion, exposure assessment, ecological effects assess-
  ment, and riskcharacterization.' A work scope should
  also provide for close oversight of individual tasks.
  This will ensure that the assessment accomplishes its
  objectives within reasonable budget and schedule
  limitations.
Need for  Clarity, Specificity,  and
Completeness

      SOWs and Work Flans should clearly state the
studies needed at each phase of the assessment In addi-
tion, they should include other parameters concerning an
assessment, such as sample collection, data analysis, and
reports. Specifically, SOWs and Work Plans should de-
scribe:
                   • Which studies should be conducted;

                   • Why they should be conducted;

                   • When and where they should be conducted;

                   • What data should be collected;

                   • How samples should be collected, handled, and ana
                     lyzed;

                   • How data should be evaluated; and '

                   • What reports should be produced.


                            IN THIS BULLETIN
                 The Role Of The Biological Technical Assistance
                  Group	2
                 Points To Consider In Developing A Work Scope	_2
                 Elements Of An Ecological Assessment Work Scope ....4
                 Ensuring Contractor Capability To Do Work	7
                 Review Of Interim And Final Products	8
                 Sample Work Scope		—9
                 Conctu sion..~.............—......'.—»~	...................9
                 Appendix			11
                  1 Although the primary focus of this document is on the RI/FS
                  process. On-Scene Coordinators may find much of the informa-
                  tion useful in evaluating rites during the removal process.
                                             VoL l,No. 2).
 ECO Update is a Bulletin series on ecological assessment of Superhand sites. These Bulletins serve as supplements to Risk Assess-
 ment Guidance for Superfund, Volume H: Environmental Evaluation Manual (EPA/540-1-89/001). The information presented is
 intended as guidance to EPA and other government employees. It does not constitute rulemaVing by the Agency, and may not be
 relied on to create a substantive or procedural right enforceable by any other person. The Government may take action that is at
 variance with these Bulletins.

-------
4

-------
                    The Use of US EPA Region 9
         Preliminary Remediation Goals  in Site Evaluation

                        Daniel  Stralka.PhD
                      Regional Toxicologist

   The Use of Preliminary Remediation Goals for Site Evaluation

A.  What are  PRGs?

      a. Generic chemical-specific concentrations of concern.
      b. Human health endpoints.
      c. Select pathways.
      d. Combined pathways for each media.

B.  The Site  Conceptual Model

      a. How have you defined the site?
      b. What  is the extent of your data?
      c. Have  you characterized the site?
      d. Is your data consistent with your model?

C.  Evaluate  the use of Generic vs. Site-specific  PRGs

      a. Are there other pathways not evaluated
        in the generic PRGs?
      b. Are the assumptions used in the generic PRGs
        relevant for the site?
      c. How refined a risk assessment is required?

D.  Exposure  Point Concentration Term

      a. Does  the data characterize the site?
      b. How was the data collected, composite or individual?
      c. Maximum hit screening vs. statistical methods,
        point of compliance?

E.  Examples

F.  Advantages and Disadvantages

      a. Standardize equations and default assumptions.
      b. Most  common human exposure pathways.
      c. Flexible framework.
      d. Must  have a conceptual site model.
      e. Not walk away numbers.

G.  How do you access the table?

     California Regional Water Board's BBS 510-286-0404
      file name- PRG2ND.ZIP

     via internet "gofer.epe.gov" menu selection
      "EPA Offices and Regions:  Region 9; Superfund Program"

                                   4-1

-------
Highlight 1:  Key Attributes of the
          PRG Framework

  • Standardized equations and default
   concentrations (PRGs) are presented to
   address most common human exposure
   pathways.
 ro
   Conceptual site model for each site is
   used to determine the applicability of
   generic PRGs and identify data gaps.

   Framework is flexible and allows both
   generic and site-specific inputs into the
   s andardized equatio 5.

-------
    Pathways Addressed by
         Region IX PRGs

1. Ingestion of Soil
2. Dermal Contact with Soil
3. Inhalation of Volatiles and Fugitive
  Dust
4. Migration of Contaminants to an
  Underlying Potable Aquifer
  Soil PRG (mg/kg) = Target "Safe" Dose
             Add Exposures 1+2 + 3

-------
Pathways Addressed by Preliminary Remediation Goals (PRGs)
      Direct
   Ingestlon of
   Groundwater
     and Soil
  Dermal
Absorption
.Inhalation
                                                Blowing Dustt
                                              and Vblatilizatlo
          Groundwater
                       Not Addressed:
                       • Ecological effects
                       • Indoor exposure to volatiles
                        from soil and water
                       • Consumption of fish,
                        beef, or dairy
                       • Land uses other than
                        residential/industrial
                                                                     PRQS.EP8
                                               4/JM

-------
 Decisions to Move from Generic
to Site-Specific  PRGs Consider:

  » Do pathways at the site match up with
   pathways used to derive generic PRGs?

  • Are the assumptions used in the PRGs
t   appropriate, relative to site conditions?

  • Are site-specific goals established from
   collecting additional data likely to be
   less costly to achieve?

-------
PRELIMINARY RISK GOALS MAV
 CHANGE WHEN CONSIDERING
      ADDITIONAL FACTORS
 Exposure Factors
 - cumulative effect of
  multiple chemicals
 - exposures from
  additional pathways
 - potential impacts on
  environmental
  receptors
 - cross-media
  impacts of remedial
  alternatives

 Uncertainty
 Factors
 - reliability of
  alternatives
 - weight of scientific
  evidence concerning
  exposures and
  health effects
Technical Factors
- detection/quantification
 limits
- ability, to monitor and
 control movement of
 contaminants
-background levels of
 contaminants
                    4-6

-------
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-------
5

-------
    Jeffrey JA
    wong, ph.d.
    DTSC/CalEPA
    916-327-2500
      PROBLEM SET: MANAGEMENT
      OF HAZARDOUS WASTE?
Ul
1. Has there beeh'h9rm?<1sih
-------
Jeffrey J.I
wong, ph.d.
DTSC/CalEPA
916-327-2500
Risk Assessment:
Simple Conceptual Components
   Source Assessment
                                          Risk
                                        Characterization
                                        Gaieulate
                                   Movement
                                            Exposure
    Hazard D

-------
 Jeffrey j.(
 wong, ph.d,
 DTSC/CalEPA
 916-327-2500
01
What does risk assessment
do for me?

-------
 Jeffrey j. I
 wong, ph.d.
 DTSC/CalEPA
 916-327-2500
RISK-BASED
 SOLUTIONS
            Risk

    Unacceptable
       FORWARD RISK
       CALCULATION
Limit
                                      CCEPJTABO

        Exposure
        Pathways
         AIR SOILWATER FOOD
                                   AIR SOIL WATER FOOD
AIR SOIL WATER FOOD
                                              Managed
                                             mitigated exposure
         Above the Limit II
                 smaller source
                           Below theJJmit
                               **^= jlip^ • «

-------
cn
I
cn
  Jeffrey j.(
  wong, ph.d.
  DTSC/CalEPA
  916-327-2500
A Simple World
    To Ground Water
                     Sediment
                                                           5

-------
 Jeffrey J.I
 wong, ph.d.
 DTSC/C«1EPA
 916-327-2500
cn
en
MATHEMATICS:
Basic Exposure Model
              f?'
           ce term)

-------
 Jeffrey j.l
 wong, ph.d.
 DTSC/CalEPA
 916-327-2500
Biological/ Toxicological
          Uncertainty
     RISK
en
^ 1 x 106
       PROJECIllEPDejSE
                Toxicity Assessment
                  • Toxicity data
                    • Animal extrapolation -
                     Do rats = man?
                  • Dose-response
                    • Extrapolation model -
                     Right model?
                       *^ -  '-.•',•:..'''.• f
                    • Conservative assumptions -
                     Right assumptions?
                          DOSE
              At risk   Not at risk
                                                       7
                                                       •

-------
  Jeffrey j. I
  wong, ph.d,
  DTSC/CalEPA
  916-327-2500
 Parameter  Uncertainty
DOSE =
^V* *'•*•
-------
   Jeffrey j. (
   wong, ph.d.
   DTSC/CalEPA
   916-327-2500
Simple Exposure Scenario
           Inhalation
           Direct Soil Contact and Ingestion
           Ingestion of Water
tn
I

-------
Jeffrey J.I
wong, ph.d.
DTSC/CalEPA
916-327-2500
REAL WORLD COMPLEXITY


  fr-:-..r,..:^.
  KA /h O D Lil C ID' I /aS\/M
)•)',! rr^•sali5J-i-i.il


                                            BREAST MILK

-------
Jeffrey j. I
wong, ph.d.
DTSC/CalEPA
916-327-2500
Which Fate & Transport Model?
                       MODEL #2
            MODEL #1    I        MODEL #3
MEDIA
CONCENTRATION
(mg / mA3 air)
                 DISTANCE (meters from source)
                                                 11

-------
  Jeffrey j. (
  wong, ph.d.
  DTSC/CalEPA
  916-327-2500
 Exposure Data:
 Breathing Rate
Monte  Carlo Analysis
           Parameter X1
 Environmental
 Data: Rainfall
          Parameter X2
Sampling Data:
Soil Concentration!
           Parameter X3
                                 Fate&
                               Transport
                                ModeM
                             Y1=f1(X1,X2,X3)
                        PROBABILITY
                              RISK
                           Output  Y1
                                                               12

-------
 Jeffrey jA
 wong, ph.d.
 DTSC/CalEPA
 916-327-2500
RISK-BASED
SOLUTIONS
           Risk

    Unacceptable-*

      FORWARD RISK
      CALCULATION
en

                 *'•" /'$ V" v
               *<,,-. •M-.Vi-.-f"iiSs', siJ. .^rf
              Acceptabe,^
               u-  r * *   J Bl?
       Exposure
                       • + {T*Wt*vm.m
         Above the Limit
                        Below the Limit
 Limit

-------
This Page Intentionally Blank

-------
6

-------
 RISK-BASED APPROACH TO DERIVE SOIL CLEANUP GOALS PROTECTIVE OF
                  HEALTH AND WATER QUALITY -  A Case Study

     by Ravi Arulanantham, Ph.D.', Kenneth E. Eichstaedt, P.E.b, and Eddy P. So, P.E.C
Abstract

       Soil and groundwater pollution often pose a threat, to varying extent, to either human
health or water quality or both.  Cleanup of this pollution is a lengthy process and requires
significant economic resources,  and the elimination of all risks at an impacted site is not often
possible. Considerable time, effort, and resources spent for cleanup may not always be justified
technically and economically in light of the  uncertainty  and  inconsistency encountered by the
responsible parties during their cleanup process.  This paper provides a methodology to derive
site-specific cleanup goals which are protective of public health and water quality. The suggested
approach also provides (i)  predictability to the  overall decision-making  process; (ii)  the
opportunity for responsible  parties to participate in the decision-making process during the
establishment  of  soil cleanup  goals; and (iii)  consistency while ensuring  flexibility in  the
remediation and management of pollution problems.

       The methodology consists of: (1) completion of site characterization; (2) initial risk-based
screening of contaminants; (3) derivation of health and/or ecological risk-based cleanup goals;
(4) derivation of groundwater  quality-based cleanup goals;  (5) site  cleanup goals  and site
remediation; and (6) risk management decisions.  The approach was recently used at a site in
Newark. California. The pollutants of concern in soil were petroleum hydrocarbons as weathered
diesel, oil and grease, lead, and copper. The lead agency for this site was the San Francisco Bay
Regional Water Quality control  Board with assistance on human health issues provided by the
Alameda County Health Agency.  The approach is technically defensible and  can be a valuable
tool to provide cost-effective solutions in the complex decision making process of site cleanup.
a Staff lexicologist, San Francisco Bay Regional Water Quality Control Board
b Project Engineer, URS Consultants, Inc., San Francisco
c Associate Water Resources Control Engineer, San Francisco Bay Regional Water Quality
  Control Board
                                            6-1

-------
This Page Intentionally Blank

-------
   Risk/Exposure Assessment Case Study
                  March 26,1996
  1996 RCRA Corrective Action Conference
Ravi Arulanantham, Ph.D.  Ken Elchstaedt, P.E.       Eddy So, P.E.
   California Regional     URS Consultants, Inc.      California Regional
Water Quality Control Board   San Francisco, CA    Water Quality Control Board
 San Francisco Bay Region                    San Francisco Bay Region
RISK EXPOSURE/ASSESSMENT CASE STUDY
   ISSUES

   Soil and groundwater contamination can cause varying degrees
   of threat to either human health/environment and/or water
   quality.

   Soil and groundwater cleanup can be a very lengthly process
   requiring significant economic resources.

   Eliminating all risks at a contaminated site is often not
   possible, even after cleanup.

   Different agencies with different responsibilities are
   involved during the overall reclamation process.

CalltenUt ftWOCB
URS Consultants, toe.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
     OBJECTIVES

     1. To derive cleanup or remediation goals that are
     protective of both land use issues and water quality
     issues based on site-specific conditions and risk.

     2. To ensure that the cost of overall remediation efforts
     is truly'relevant to the protection of human health and
     safety and other natural resources.
California RWQCB
URS Consultants, toe.
RISK EXPOSURE/ASSESSMENT CASE STUDY


  SITE SETTING

  Former foundry on 10 acres of a 37-acre parcel

  Located in East Bay (San Francisco Bay) / Alameda County

  Consisted of 2.5-acre (106,450 sq. ft.) building with
  associated furnaces, extrusion form press, pickling baths,
  and bag house

  Manufactured brass and bronze metal products from
  1957 to 1986
California RWQCB
URS Conaultnot, toe.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY	


  SITE HISTORY

  Premanufacturing (pre-1957): Cultivation of hay

  Manufacturing (1957 • 1986):  Processed raw brass and bronze
  ingots into housing fixtures (plumbing, hardware, etc.). Facility
  consisted of extrusion form press, furnaces, bag house, coil
  pickling vats, acid storage tanks, caustic storage tanks, solvent
  (TCE), and dlesel fuel.

  Postmanufacturing (post-1986): Land fallow. RWQCB/Alameda
  County and owner agree to Site Cleanup Order in 1991.
  Rl completed in 1992.  Soil remediation completed In 1993.
  Groundwater remediation began in 1994.

Catlfemlt PWQCB
RISK EXPOSURE/ASSESSMENT CASE STUDY
   LAND USE

   Adjacent land use:   South • City Park
                     East - Residential Housing
                     North - Industrial Facility
                     West - Railway line and
                           San Francisco Bay
                           (approximately 1 mile away)

   Zoned In municipal master plan as commercial/Industrial

   Current residential use and city park within 500 feet of site
Calltomit ffWOCB
URS Consultant*, Inc.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
                     INDUSTRIAL SITE
         PROPERTY LINE
                                           FORMER

                                           FOUNDRY

                                         ^-PROPERTY
                               FORMER

                               FOUNDRY

                               | BUILOINO

UJ
o
55
UJ
cc
                         CITY PARK
                                            100  200
                                         SCALE IN FEET
RISK EXPOSURE/ASSESSMENT CASE STUDY
                                      HAYWARD

                                       HILLS
CMtomlt PWQCB
URS Consultant* Inc.
                   QROUNDWATER

                     MOVEMENT
                            SCALE

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
                 REGIONAL GEOLOGIC CROSS SECTION
                                      ;.a. ••••<••• ••qi.t-g. t.-a <-aoo It.
                             II

                             IIIII II Illll        »»ir.«. itltl .1 lilHir.U.
                                       l«pt. •( Will? itiHM». lilltlli 14-!
California RWQCB
URS Consultants, me.
RISK EXPOSURE/ASSESSMENT CASE STUDY	




 SENSITIVE WATER BODIES

 San Francisco Bay (» 1 mile away)

 Mowry Slough (» 1/2 mile away)

 Shallow Aquifer (10 to 30 feet bgs)

 Newark Aquifer (potential drinking water aquifer);
       - 50-feet below ground surface
       • Municipal drinking water well within 1/2-mile east of site
California HWQCB
           Inc.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
DISTRIBUTION OF CONTAMINANTS

SOIL
      Metals:
           Lead
           Copper

      Hydrocarbons:
           TPH/diesel
           Oil & Grease


0 to 2ft
0 to 2ft
Maximum*
Concentration
2,950
11,000
Average*
Concentration
900
1,500
                         OtolOftbgs  6,200
                         OtoSftbgs  22,000
  GROUNDWATER (Shallow aquifer < 10 ft bgs)
        Total VOCS (Primarily TCE, TCA, DCE, and DCAs) 7
        TPH/dlesel                       6
                                               1,000
                                               1,700


                                               <2
                                               <0.5
California RWOCB
URS CoMuttana, toe.
                                              * (ppm)
RISK EXPOSURE/ASSESSMENT CASE STUDY


[
L
Soil-
Excavation
ffl


n

S[_c-
•
•
•
••
I W-<™




- 1 1 IT*»I
s!
•••!••••


FORMER '"
POUNDRY •—

"••..BUILDING i
• i
• i
• i
i
..-•*


~\
_i




                       Groundwater
                       Plume
California HWOCB
UHS Corauiuntt, lite.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
  PUBLIC HEALTH RISKS

  Dominant Exposure scenario:

        Future on-site      - Residential use
        Current off-site     • Nearby park provides potential
                             child exposure

  Exposure routes: ingestion, dermal, and inhalation

  The risk associated with drinking shallow G.W. was not evaluated
California HWOCB
UBS Consultants, Inc.
RISK EXPOSURE/ASSESSMENT CASE STUDY
  ENVIRONMENTAL RISKS

  Environmental risk posed by potential leaching of soil
  contaminants to groundwater

  Environmental risk evaluated by modified TCLP test to
  assess teachability

  Comparison of leaching extract to the following criteria:
    Suggested No Adverse Response Levels (Secondary MCLs)
    LUFT Field Manual
    State of Washington Model Toxics Control Act Cleanup Regulations
    RWQCB's Water Quality Control Plan (Basin Plan), Toxic
        Pollutant Accumulation guidelines

California RWOCB
1/ftS Consultants, Inc.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
 HYPOTHETICAL CLEANUP STRATEGY

 >•<• ND/Background/Order
1 ' —
£
~




A
m
2.5ppm
f
C T2

V
— i
s

• •
•
25ppm
~ T2T
^
~
• -
250ppm
~ sn+
"%. «*
-^L (*'*KyCrttl
                  Site Concentration
                      5000 ppm
RISK EXPOSURE/ASSESSMENT CASE STUDY
     Corrective Action Strategies
Ctlltomlf HWQCB
UftS Consultant*, Inc.
                                     Universal Standards
                                     RBCA

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
  PUBLIC HEALTH PROTECTIVE CLEANUP GOALS


  0  Followed U.S. EPA 1990 UBK model for lead.
  0  Followed U.S. EPA RAGS for Cu and TPH-D.
  0  Standard dose equations using deterministic exposure
        parameters for on-site/off-slte exposure.
  0  Reverse calculations of allowable soil concentrations for Cu
         and TPH-D using the following exposure parameters:

  Ingestion rate 200 mg/day                Adherence of soil to skin - 1 45 mg/cm
  Fraction Ingested from contaminated soil - 1     Fraction of Cu adsorbed through the
  Exposure frequency - 265 days/year               skin - 0.05
  Exposure duration - 6 years               Paniculate emissions factor -
  Body weight - 15 kg                          4 63x 10fl cu. meters/kg
  Skin surface area available for soil           Inhalation rate - 15 cu. meters/day
        contact • 9.500 sq. cm
  Target risk level was a HI . 1

Clf/femM RWQCB
UHS Consu/CMitt, toe.
RISK EXPOSURE/ASSESSMENT CASE STUDY
   RESULTS

   Calculate health-risk-based soil cleanup goals protective of
         children:

   Pb:    225 mg/kg of soil

   Cu:    860 mg/kg of soil

   TPH                General      Children
         Ing.          2190 mg/kg   625 mg/kg

         Derm.        180 mg/kg    80 mg/kg


California RWQCB

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY

  ENVIRONMENTAL CLEANUP GOALS
  Contaminants leaching from soil to groundwater
  Used modified TCLP test to assess leachability
  Comparison of leacnate to the following criteria:
        MCLs for copper and lead
        Secondary MCLs for TPH-Dlesel and TOG
California ftWOCB
URS Consultants, toe.
RISK EXPOSURE/ASSESSMENT CASE STUDY

       RESULTS
            Lead               100 mg/kg
            Copper           >1600 mg/kg
            TPHasdlesel      > 130 mg/kg
            TOG             > 100 mg/kg
California HWQCB
UPS Consultants, me.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
 SITE WIDE RISK BASED CLEANUP GOALS
COG


SOIL

Lead
Copper
TPHasDtoart
TOO
OROUNOWATER

TCE
TCA
OCE
OCA
Maximum Sit*



(mg/kg)
2.950
11.000
0.200
22.000

(mg/L)
a.8
0.5
1.3
0.8
Calculated
mg/kg of Soil



258
860
80
100


•
.
.
•
Leachablllty-
Quality Goal
mo/kg of Soil


100
>860
>80
»100


•
'
.
•
Cleanup Goal
o—i-— .— j
mg/kg of Soil



100
860
80
100

AttSfnpttnQ MCLs*

Futuro vnflytoo
risk-based
cleanup criteria.
Catltomtt HWOCB
MS Consvlt*na, toe.
RISK EXPOSURE/ASSESSMENT CASE STUDY


   CORRECTIVE ACTION IMPLEMENTATION

   Soil
         Lead   \
         Copper '
         TPH/TOC
 700 cy
7.900 cy
        TOTAL
8,600 cy
   Groundwater
        5-well extraction/treatment system operating
        Tentative MCL/health-risk-based cleanup goals
California PWOCB
UPS Consu/tantt, /he.

-------
RISK EXPOSURE/ASSESSMENT CASE STUDY
  RISK MANAGEMENT ISSUES

  0 Agency letter confirming all health risks are mitigated for
         residential soil
  0 Site cleanup order for G.W. remediation
  0 Deed notification for G.W. treatment system
        access/operations
  0 Contingency plan for future plume migration
  0 All records placed In the local city archives available for
        easy public access
  0 At time of building houses, an additional RA for G.W.
        volatilization to Indoor air
California HWQCB
UPS Consultants, toe.
RISK EXPOSURE/ASSESSMENT CASE STUDY	


                  'Working Smart Vs. Working Hard*

 Risk-Based Cleanup Approach    $860,000    Time: 3 months

 Cleanup to Background          $1,600,000   Time: 12 months
California HWQCB
URS Conaultutta. Inc.

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   RISK-BASED MANAGEMENT APPROACH TO CLEANUP OF CONTAMINATED SOIL
Authors:       Mr. Ravi Arulanantham, Ph.D.
              Staff Toxicologist

                     "Mr. Arulanantham is the Staff Toxicologist for the Alameda County. Currently,
                     he is serving as the Staff Toxicologist for the Regional Water Quality Control
                     Board on an Inter Agency assignment. He is also an ASTM sanctioned National
                     Trainer for the ASTM RBCA standard."

                     California Environmental Protection Agency
                     Regional Water Quality Control Board
                     San Francisco Bay Region
                     2101 Webster Street, Ste. 500
                     Oakland, CA  94612

                     DL:    510/286-1331                 Fax:    510/286-0928

              Mr. Kenneth E. Eichstaedt, P.E.
              Project Civil Engineer

                     "Mr. Eichstaedt has worked extensively  in the hazardous/toxic materials field
                     over the  past 12 years performing remedial  investigations, feasibility studies,
                     remedial action plans, and construction management of hazardous waste cleanup
                     projects.   He is currently the Site Manager for two Superfund projects and a
                     private site in which he has successfully used the cleanup strategy presented in
                     this abstract for the cleanup of petroleum hydrocarbon contamination."

                     URS Consultants, Inc.
                     100 California St., Ste. 500
                     San Francisco, CA   94111

                     DL:    415/774-2767                 Fax:    415/398-1904
              Mr. Eddy P. So, M.Sc., P.E.
              Associate Water Resources Control Engineer

                     "Mr.  So has over  15 years of experience in sanitary engineering  and the
                     hazardous/toxic waste  field.   He is  a P.E.  in  both civil and  mechanical
                     engineering. Currently, he is the Area Engineer overseeing soil and groundwater
                     investigation and cleanup for the southern Alameda County."

                     California Environmental Protection Agency
                     Regional Water Quality Control Board
                     San Francisco Bay Region
                     2101 Webster Street, Ste. 500
                     Oakland, CA  94612

                     DL:    510/286-4366                Fax:   510/286-1380

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7

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              DESIGN OF ON-SITE WASTE CONTAINMENT SYSTEMS
                          FOR RCRA CORRECTIVE ACTION

                                           by

                          R. Jeffrey Dunn and Harold A. Tuchfeld

                                   GeoSyntec Consultants
                               1600 Riviera Avenue, Suite 420
                               Walnut Creek, California 945%
                         Phone (510)943-3034 Fax: (510)943-2366

        On-site waste containment systems have attracted increased interest among regulators and
 the private sector for potential management of on-site contaminant sources at sites regulated
 under RCRA, CERCLA, and state regulations This interest has been heightened by the potential
 of on-site containment systems to be both environmentally protective and cost effective at certain
 sites, and by greater use of risk-based decisions for corrective action (especially for areas where
 there will be future industrial or open space use)

        This presentation focuses on the design and construction of on-site systems for buried or
 excavated waste for use in RCRA interim stabilization measures and RCRA final corrective
 measures Methods discussed include 1) in-situ containment of buried waste, such as capping and
 subsurface barriers (including slurry walls), and 2) development of new on-site containment  cells
 for excavated solid and hazardous  waste or impacted soil   The goal  of the presentation is to
 provide  private  sector environmental  managers  and  regulatory  oversight  managers   with
 information that can be useful for deciding  on the  appropriateness of such  on-site containment
 strategies for particular situations, and for the logistical planning, scheduling,  cost estimating, and
 implementation of on-site containment methods

        An overview is provided of the various  stages of a typical on-site containment project,
 including the  regulatory approval process,  design, procurement,  construction, operation,  and
 closure Information  is provided on the design of single-liner and double-liner systems, leachate
 collection systems, leak detection systems, final cover systems, and subsurface barriers  Leachate
 management is also discussed  In addition, the use of innovative materials and designs that have
 the potential for increased performance and  cost  savings  are described   The  reliability  and
 longevity of modern engineered hazardous waste containment systems are also briefly discussed
j VmarketVepa doc
                                            7-1

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                          OVERVIEW OF GEOSYNTEC CONSULTANTS

 GeoSyntec Consultants (GeoSyntec) is a geoenviromnental consulting and engineering design firm with 250
 personnel in seven offices in the United States (including Walnut Creek and Huntington Beach California offices
 within EPA Region 9) and one office  in France.  GeoSyntec's technical staff includes engineers and scientists
 with specialties in a broad array of technical disciplines. The firm has an active process in the areas of RCRA
 corrective actions; RCRA TSD facility and closure design; CERCLA remedial investigations, feasibility studies.
 remedial design, and removal orders; landfill design and closure; subsurface fate and transport modeling for nsk
 assessment and remedial design; investigation  and  remediation at agricultural chemical and manufacturing
 facilities,  seismic design  and  evaluation  of earth  structures,  geotechnical  engineering,  and  construction
 management and construction quality assurance (CQA).

 The firm is recognized nationally as the technological leader in the design, construction, and closure of hazardous and
 solid waste landfills, including application of subsurface barriers.  GeoSyntec has completed over 500 landfill-related
 projects for private and public sector clients GeoSyntec has also provided assistance to the EPA and state agencies
 throughout the country (including the California Integrated Waste Management Board and California Regional Water
 Quality Control Boards) in research, technical guidance  document preparation, and training regarding landfill design
 and closure

 GeoSyntec has worked with the EPA in the evaluation of the performance of liner systems used at hazardous waste land
 disposal facilities, and on the development of technical regulator}1 guidelines for the design and construction of double
 liners and leak detection systems at these facilities  GeoSyntec recently performed research for the U S Navj on the use
of subsurface barriers for containment source control at unlined Naw landfills
                                                    7-2

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                Outline of Presentation
              •  Functions of Systems
              •  Regulatory Drivers
              •  Factors Favoring Systems
              •  Components of Typical Systems
              •  Detailed Design
              •  Construction Quality Control/Assurance
              •  Contractor Procurement
              •  Typical Costs
              •  Opportunities/Cost Savings
              •  Case Studies
          Functions of On-Site Disposal
        and In-Situ Containment Systems

•  Provide for safe, environmentally protective on-site disposal and in-
   situ containment of wastes

•  On-Sitc Disposal - Landfills
    - Industrial wastes (ash, sludge, manufacturing waste)
    - Hazardous wastes
    - Contaminated soils and sludges
    - Contaminated building debris
    - Construction/demolition debris

•  In-Situ Containment - Source Control
    - Former disposal pits
    - Subgrade building debris
    - Contaminated soils and sludges
    - Marsh Sediment
           Functions of On-Site Disposal
   and  In-Situ Containment Systems (cont.)

•  Disposal and containment systems are intended to protect the quality
   of human health and the environment by preventing contaminant
   migration across all major pathways, including
    - Ground water
    - Surface water
    - Air

•  This goal is achieved through the use of engineered s> stems
    - Liquid and gas barrier layers
    - Liquid and gas collection systems
       Factors Favoring On-Site Disposal

              and  In-Situ  Containment

• Source area contains wastes not amenable to treatment
    -  Mercury containing plastic clay soils
    -  PCBs containing co-contaminants (dioxins or lead)
    -  Contaminated sludges containing MSW and C/D debris

• Source area contains RCRA hazardous waste
    -  Remediation wastes become hazardous once removed from a CERCLA
       Operable Unit or RCRA CAMU
    -  Off-site treatment and disposal cost for RCRA hazardous waste will
       tv pically be very  high
Nnlc Off-site Ireilmcnt and disposal coili for RCR A hazardous waste coiuiiling of toil, mixed iludge.
   and debris mil depend on whether an LDR trealabilil) variance can be obtained under 40 CFR 5
   268 44(i) USr.l'A is often predisposed lo provide variances for these materials 39 CFR 47986
   stales, "It has been the Agenct'» experience thai contaminated soils are significantly different in their
   liealahililv characteristics from the wastes that have hecn evaluated in establishing the BOA I"
   standards, and thus, uill generally qiialifv for a Irealahililv variance under 40 l.TK 268 44(a)"    .

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        Factors Favoring  On-Site Disposal
          and In-Situ Containment (cont.)

   Source area contains nonhazardous waste requiring significant
   prctreatment prior to off-site disposal
    -  Dewatering/filler press/drying beds
    -  Ex-situ solidification
    -  Unique material handling issues (debris, Ihixotropic material, tarry waste)

   Source area has waste identified by USEPA as being amenable to in-
   situ containment or not treatable with current technology
    -  SACM Presumptive Remedies - m-situ containment for waste containing
       MSW and CDW
    -  USEPA Technical Guidance - limitations on treatment technologies
       Factors  Favoring On-Site Disposal
         and In-Situ Containment (cont.)

•  Source area contains waste that is difficult or dangerous to excavate
    - Source extends to significant depth
    - Source is in a high water table zone with loose, permeable soil
    - Source consists or sludges, muds, debris, etc , that are difficult to excavate
    - Source contains volatile components that create health and safety or air
      quality concerns if excavated
    - Source contains dangerous waste such as air-reactive material
      (phosphorus)
    - Short-term risks associated with excavation and transport exceed long-
      term management risk (requires nsk assessment and demonstration)

Note On-Site disposal and in-situ containment do not result in a reduction in
     loxicitv or volume of waste
        Factors Favoring On-Site Disposal
          and In-Situ Containment (cont.)

 •  An analysis of the proposed remedy /corrective action demonstrates
    acceptable nsk to human health and environment
    -  Source performance modeling (ground water, surface water, air)
    -  Risk assessment (human health, ecology)
    -  Assessment of remedy reliability and permanence

Note  Achievable performance levels are as follows
      (I1  On-site disposal facilities can obtain leachate collection efficiencies
          of
          — 95 to 99 9% (RCRA Subtitle D landfill)
          — 99 to 99 99% (RCRA Subtitle C landfilM
      (2)  In-silu containment svstems can Ivpicallv achieve reductions in
          source migration rates of 90 to 99%
        Factors Favoring On-Site Disposal
          and In-Situ Containment (cont.)
                     (ROM Construction Cost)
     Institutional Controls
     On-Site Disposal
     In-Situ Containment
     Off-Site Disposal (Nonhazardous)
     -  Without pretreatment
     -  With pretreatment
     Off-Site Disposal (Subtitle C or TSCA)
     -  Pretreatment and disposal
     -  BDA1  treatment and disposal
$lto$5/yd'
$20 to $40/yd3
$10 to $250 /yd'

$15 to $50/yd'
$25 to $100/yd5

$150 to $200/yd3
$250 to $1,000/yd'
  Note  On-site disposal or in-situ containment options may have significant
       O&M cost and long-term risk management implications Passive in-situ
       containment options will tvpicallv be less costlv than on-sile disposal
       options

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             On-Site Disposal (Landfill)
                System  Components
   Liner System
*  Final Cover System
*  Liquid/Gas Removal System
                 DISPOSAL FACILITY LEACHATE GENERATION
                                                                    40OO
£ 3000

  2500
Uf

£ 2000

0 '500

g inoo

a  50)
                                                                     0
                                                                     JUL 88
                                                                          JA
                                                                                                  PENNSYLVANIA LANDFILL
                                                                              inn,.i.i.—.......
                                                                               JUl B9
                                                                             89
                                                                                   <\N
                                                                                       JUL-90
                                                                                                JUL-91
                                                                                                         JUl 92
                                                                                   JAN-90
                                                                                                                  JUl 93
                                                                                            JAN-91     JAN-92     JAN-93     JAN-94

                                                                                              DATE
                                                                                                                           10
    On-Site Disposal System Components:
                     Liner System

*  Combination of one or more drainage layers and low-pernieabilitv
   barrier layers (i.e., liners)

•  Liners impede migration of liquid and gas out of the landfill

*  Drainage layers control the build-up of hydraulic head on underlying
   liners and convey liquids to sumps
                       LINER SYSTEM
                     (RCRA SUBTITLE D)
                      * A 3 1 E
  h <03m i
                                                                      u.o rn

                                             IEACHATE
                                             COUECIION SYSTEM
                                                                                                              COMPOSITE
                                                          11
                                                                                                                            12

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                   LINER SYSTEM
                  (RCRA SUBTITLE C)
h < 0.3 m,
h <03 m ,
  09m
      I  -i
                                 , IEACHAIE
                                 | COUECIION SYSTEM

                                 GEOMEMBRANE
                                 ! TOP LINER

                                 LEAKAGE DETECTIVE
                                 SYSTEM
                                         COMPOSIIE
                                         BOTTOM LINER
                                                        13
    On-Site Disposal System Components:
                 Final  Cover System

•  Combination or one or more drainage layers and low-permeability
   barrier layers (i.e., caps)

*  Caps prevent water infiltration into, and gas migration from, on-site
   disposal area

•  Drainage layer above cap controls hydraulic head on cap and
   minimizes downslope seepage forces in the cover soil

•  Grass and topsoil layer is usually the topmost layer; function is to limit
   erosion and promote surface-water runofT
                                                                                                                         14
                  FINAL COVER SYSTEM
                   (RCRA SUBTITLE D)
                                                                                   FINAL COVER SYSTEM
                                                                                    (RCRA SUBTITLE C|
 0 15m /
 0.45m
W***^lti??***^
i^*waiffl
                                          I EROSION LAYER
                                           COMPOSITE CAP
                                                                      06m
                                                                      0.3m
                                                                       0.6m
                                                                                                       VEGETATION/
                                                                                                       SOILTOf LAYf»
                   WASTE
                                                                                                                         16

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    On-Site Disposal System  Components:
           Liquid/Gas Removal Systems

*  Liquid removal systems are used to remove collected Icachatc from
   landfills: leachate is discharged to a storage tank (Tor subsequent
   transport to an off-site treatment facility', near-site sewer line hookup,
   or on-site treatment facility')

*  Gas extraction systems are used to remove gas from landfills; gas is
   either vented to atmosphere (usually with prctrcatment), flared, or
   incinerated
                                                             17
                             LIQUID REMOVAL SYSTEM
                                                                                                                          assar
                                                                  18
     On-Site Disposal/ln-Situ Containment
            Liquid Management Options

    Hard pipe to existing sanitary' sewer line
     - Only occasionally acceptable to local sewer authority
       Not an option for CERCLA/RCRA facilities

    Hard pipe to existing on-site wastewater treatment plant
       Requires existing facility
     - Often requires facility upgrades
     - Often capacity constrained

    Construct new on-site leachate treatment plant
     - Cost range $500,000 to $2,000,000

    Truck to industrial wastewater treatment plant
     - Costs vary widely
     - Regional industrial facility - $0.05 to $0 25/gallon
     - RCRATSDF-$I 00/pallon
                                                                                         GAS RECOVERY SYSTEM
19
                                  HDPEPI
                                     b

COVf* FOUNDATION LAY»

lOHIADtl


CLAY IAOFIU


uNioNnt PIUG

Hon ixntAcnoH rm



COAUM AGGKCATE
                                                 souo
                                 20

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      In-Situ Containment System Components
        •  Final Cover Systems
           Vertical Barriers
           Ground-Water Interceptor Trenches or Extraction Wells
           In-Situ Solidification/Stabilization
                                                             21
                                                                                IN-SITU CONTAINMENT SYSTEM COMPONENTS
                                                                        GHOUNO VtfUtR
                                                                         t RIHAt IKW
                                                                                                        COVfHSVSltM

                                              SKHf ATE VWttR
                                              CUNIHUt WICM
                                                                                                                              22
CO
     In-Situ  Containment System Components:
                    Final Cover System

   •  Combinalion of one or more drainage layers and low-permeability
      barrier layers (i.e., caps)

   •  Cap prevents u atcr infiltration into surface or subsurface contaminant
      source area

   *  Drainage layer above cap controls hydraulic head on cap and
      minimizes downslope seepage forces in the cover soil

   •  Grass and (opsoil layer is usually the topmost layer: function is to limit
      erosion and promote surface-water runoff
In-Situ Containment System Components:
                 Vertical Barrier


 Low-permeability physical structure installed vertically into the
 ground to provide a barrier to:
    Upgradient flow of ground water toward a subsurface source area or
    contaminant plane
  -  Downgradient migration of contaminated ground water from a surface or
    subsurface source urea

 Vertical barriers may be constructed of natural or synthetic materials
 and used alone or in combination with other in-situ containment
 components
                                                             23
                                                        24

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In-Situ Containment System Components:
              Vertical Barrier (cont.)

 Vertical barriers limit transport of ground water and/or specific
 chemical contaminants beyond a designated boundary due to:
  - Hydraulic gradient (advection)
  - Chemical gradient (diffusion)
  - Density gradient (density-driven migration)
 Barriers may be designed to provide:
  - Upgradient control
  - Downgradient control
  - Complete containment
 Barriers may be designed to be:
  - Fully penetrating
  - Partially penetrating
                                                              25
FULLY-PENETRATING
 VERTICAL BARRIER
PARTAULY-PENETRATINO
  VERTICAL BARRIER
                        I  I
                                                        26
    UPGRADIENT VERTICAL BARRIER
                                  DOWNGRADIENT VERTICAL BARRIER
                                                                       Summary of Key Vertical  Barrier Attributes
                                                                      *  Soil-Bentonite Cutoff Wall
                                                                            Least expensive, reliable, versatile
                                                                            Provides low to moderate permeability barrier
                                                                          •  Potential issues related to air emissions and contaminated soil disposal
                                                                            Requires horizontal ground and significant ROW
                                                                            Potential negative ground stability impacts

                                                                      *  Polymeric Membrane Wall
                                                                            Moderate cost
                                                                          •  Essentially impermeable
                                                                          -  Same limitations of soil-bentonite wall
                                                               27
                                                                                                                                     28

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  Summary  of Key Vertical  Barrier Attributes
                                   (cont.)

•  Vibrating Beam Wall
     -  Low to moderate cost and permeability
     -  Cannot penetrate stiff soils and bedrock
     -  Produces thin wall with potential for defects
     -  Does not require soil excavation, little ROW needed

•  Sheetpile Wall
     -  Moderate to high cost
     -  Very low permeability with special seals
     -  Can withstand hard driving
     -  Does not require soil excavation, little ROW needed
     -  Can improve foundation shear strength
Note: Older barrier rypei include cemenl-benlonile ilurry  wills, deep soil mixing, jel grouting, >nd
     "enhanced" barrier lyilemi.                                                       29
                Summary  of Soil-Bentonite
          Slurry Cutoff  Wall  Characteristics
       CrNarto

Effecllvcaett
Reliability
n.r.blllty
                                           Rtkml CkMvctarMki
                     Low hyoraalic oond.cbvuy (typically ID4la 10 'cm/.)  Mo
                     inherent aooaeictunie capacity "nil AicUw aarUy oontrotlod Aii.pri*g conlractinii to
                      hindk ncnild m.tmil uU mil b«ckfill Opoil tmck toi^lk In lin.™ drp* fM«n4
                           io* •qwpntMl mdily •vmiUM*
F»»lroamml.t iMp.clf
                pied
 EicOTted material may be contaminated Soil djatarkaaca may rattan VOCl.

| Worker, mmt kandle potentially cottantiittled eicanled meleriaj Vary me.iy comtraclion .it.
i Reduced tenth rabihty pnoi to backfill Imported bicUII Mil may be nepirad
                      SS Mlllf* voitinl .
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Summary of Vibrating Beam
 Cutoff Wall Characteristics
CiMtrti
EfltcltomtM
R.IUfclllrr
D"W"*
Implement ability
CnvtrvH mental Impacti
C»nrtrwi1k>n RrUlrd Impart*
Cert
Kttrv ••! r ha r art r. IHItt
Low hydraulic conductivity (typically 10* to 10* em's) Use of specially designed backfill
materials possible Wall thickness not controllable Not recommended for penetration of
medium to stiff clays, glacial tills, or bedrock
Extensive experience and good results reported Tor tetpage cutoff, but applicability for hazardous
waste containment not conclusive Defects in wall and key to aqiddude not easy to detect
Construction quality assurance difficult
Could be very sensitive lo hydraulic fracturing Small wall thickness makes ibility to withstand
detrimental contaminant effects suspect NAPLsmiy quickly degrade thin wall section
Easy lo construct in loose granular toils Cannot bt constructed in firm «rtils or where cobbles or
boulders are prevalent Requires minimal space lo construct Applicable in restricted access
situations in areas with sloping terrain
Lowest environmental impact because no contaminated soil is removed
Low potential for worker exposure
t7 lot! 5 per vertical square Toot of wall
                                      33
           VIBRATING BEAM WALL

              t-

              f_
fl
                                                                   n
                                                                          DMtCTKW Of NStAlLAIKM
                                           VHPRC.F «!€•!»
                                                         SLURRY OMMMf
           VIBRATING BEAM WALL
                     DttECTONOF M3TM.LATWN
                   ..m...
                                                                                          34
 Summary of Geomembrane
 Cutoff Wall Characteristics
  Summary of Mixed Soil
Cutoff Wall Characteristics
Crtttrta
CffecilvcHtii
Rrllabllll)
DarahltNy
Implrnmlflbllliy
T.m\ Iran m e*ial l« pads
CoMilrucllaa-Rclaltd ImpBcIt
Rckvinl * 'h.r •( If r In!* i
Entirmely low hydraulic conductivity (iboot 10 '' cm')) \ rrv thin will ihicknm NcftligiMc
attenuatioa capacity a* complied to culotTwalli with *mlf Adaptable to only a limited range of
hydrogfolofic letting*
Newer technology with limited performance hulory Harner continuity ti obtained with jointa.
and key into underlying a^uicloda Conitruction quality aaturance of matenala 11 excellent
Construction quality umrance of inilallabon 11 difTicull
HDPE h«i tKcellenl durability charactcnXici Hue to thmnoi. durantlitx it a concern in Ihe
prM«ncrofNAPL« Componte (HOPE and ml henlnmle) »alli are p->pnMe
Haa been matalled in looat graimlar icila lo moderate depths uung pile dnvmg frame Can be
initdlcd ia •lurry trvnch lo gr«il«t depthi Applicable lo ilopiRg terrain Initalled ai conbnunui
• ktet Tor very ihatlow depth* ChemiCll compmihilrn l*»ting between iralanl and contaminant
required before nae
Dependent on mttallihon method
Dependent on installation method
    I $8 to J25 p« verlicaJ vquare fool of wall, not inchidmn off tile dupntal nf any contaminated coil
CriUria
Cffeclheattt
RellabNIly
l)-r.bfltly
iMplcmeaUblllly
f,m\ Iron mental Impacts
CaMilrvctleii-Relalfd Impact!
Coil
R.kvaat Cbaractariatfca
Moderate hydraalic eoadwrtivity (typically 10 ' to 10 ' ctn/i) Wall (hicknaap aomawhat
controllaMa AdaptaMa to meat hydrogcologic eatiina;* axe«pl bo«ld«t ion*
Baaed on familiw coRatnetiMi techniqav, almoagh r*q«ir«a apactal aogcra. Litda available
pnformaiic* data Defada in wall not awy to detect- CoMtrvctjoii quality aaemrvca difficvlt
Qvanbbe* of betilomtetM tUrry limited Durability dependent on alvny and aoil type
Relatively clean ptoceM Soil mixed in ntu Doea aot create open excavation Require* clear
overhead ipacc Applicable in rcttncted acceai •ihiBtaom and in wew with •loping terrain
Small volume of cuceet malarial may be contaminated
Low potential for worker expoanre
5" lo SI 5 per vertical iqaare Toot of wall To«i could eacaJatc if off vile diapotal of contaminated
•oil if required
                                      35
                                                                                          36

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                 Summary  of Sheet Pile
              Cutoff Wall Characteristics
•       £":!!!.*
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                  WilhKilRljanliindioodkeyMiqiicluk.nrylDwtnilkhrikiuIiccondiKlivilydlwil 10 lo
                  10* cart) Adipublc lo muiy hydiogeolofic leranp except tort md bouldeii      	

                  Hopeifommicehulory BuneiconlmulytuindwithKilcdjnnl•"<_!»££.!VJ£!•*	
                  Veiy h|h fa moil camunininli Joint mitenil mint be coraMkred in presence oTNAPLi

                  Very tunhtt contraction technology Applicable ID jlopinj lemm Chemicil cotnpmhiliiy
                  tnlmt between teilinl ind conumintnti icquied before me
                  UBte emiiuninentil icnptrt

                  Lowpotenbil Tot worker expowc

                  IJ5 to ISO pel vertrcil Hpiire fort
                                                                 37
           Enhanced Vertical Barriers

Organically-modified clays (organoclays) — bentonite cation
substitution by organic molecules that reduce the hydrophilic nature of
the bentonite and improve the ability of the benlonite to absorb
specific organic molecules
 - Quaternary amines
 - Tetramethylamonium
 - Surfactant cations

Activated carbon — granular activated carbon (2 percent by weight)
is added to the soil-bentonite mixture to enhance the potential to retard
specific organic molecules

Flyash — fly ash is added to the soil-bentonite mixture

Funnel and Gate — combination of vertical barrier and permeable
treatment wall                                                 39
   In-Situ Containment System  Components:
  Ground-Water Interceptor Trenches or Extraction Wells


 •  Subsurface interceptors (sand or gravel Tilled trenches or pumping
    wells) for the control and/or collection of.
     - Contaminated ground water migrating from a surface or subsurface source
       area
     - Upgrodient ground water flowing toward a subsurface source area or
       contaminant plume

 4  Extraction wells for the lowering of ground-water wells within an area
    cutoff from  surrounding ground water b\ a vertical barrier

 •  For in-situ containment applications, these components are typically
    used in conjunction with final cover systems and/or vertical barriers
                                                                           In-Situ Containment System Components:
                                                                                 In-Situ Solidification/Stabilization

                                                                            Mixing, blending, or injection of physical/chemical additives to:
                                                                             - Reduce contaminant mobility or solubility
                                                                             - Improve the handling, physical, and hydraulic characteristics of a waste
                                                                             - Decrease the exposed surface area across which transfer or loss of
                                                                               contaminants may occur

                                                                            Solidification refers to  the process in which materials are added to a
                                                                            waste to produce a solid

                                                                            Stabilization refers  to converting a waste to a more chemically stable
                                                                            form
                                                                                                                                         40

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        In-Situ Solidification/Stabilization
             Construction Techniques

   Backhoe with shovels (< 15 ft)
      Widely available equipment
    -  Solidifying agent (cement, flyash placed dry or in grout/slurry form) must
      be applied separately
    -  Typically used when only handling/strength improvements needed

   Backhoe with rotary tiller (< 15 ft)
    —  Specialty equipment
      Hydraulic system injects grout/slurry at tiller
    -  Better mixing/blending than with shovel
                                                            41
        In-Situ Solidification/Stabilization
        Construction Techniques (cont.)

*  Crane with single flight auger (< 20 ft)
      Widely available, conventional auger
    - Specialty auger has built-in hydraulic or pneumatic system
    - Auger can work under a removal hood
    - Large diameter auger (5 to 10 ft)

   Crane with multiple flight augers (< 50 ft)
    - Specialty equipment
    - Hydraulic or pneumatic system  injects grout/slurry
    - Smaller diameter augers (2 to 3  ft)
                                                            42
        In-Situ Solidification/Stabilization
         Construction Techniques (cont.)
   Jet grouting (>50 ft)
    •  Greater depths possible
      F:ffcctiveness dependent on soil type
    •  Good for solidifying isolated zones
    -  Verification difficult
Note:    All systems except backhoe and shovel require reagent delivery
        systems such as a grout plant or air compressor system.
                                      SSM MIXING PATTERN
                                                            43

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                    DEEP SOIL MIXING (DSM)
                   Jrd

              A   B  C  D
    riltl

A  B  C   D
                            2nd
                               DSM
                               AUGERS
l   I   l   I
                                                   IN-SITU
                                        SOLIDIFICATION / STABILIZATION
                                                                        45
                                                          IN SITU
                                              SOLIDIFICATION / STABILIZATION
                                                                                                             IN-SITU
                                                                                                  SOLIDIFICATION / STABILIZATION

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8

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Q A SUCCESSFUL REMEDIATION OF METALS
   CONTAMINATED SOIL:
   A CASE STUDY
    Theodore R. Johnson, III
    Karen T. Baker
    Mohinder S. Sandhu
    Facility Permitting Branch
    Department of Toxic Substances Control

Q SUCCESSFUL REMEDIATION PROJECT OVERVIEW
    • Effective Coordination Among Remediation Team
    • Established Fee for Service Agreement between DTSC and
     Square D Company
    • Streamlined the Corrective Action Process
    • Reduced Costs
    • Protect Human Health and the Environment

Q BACKGROUND
    • Site Location: Square D Company Beaumont, California
    • Description of Site
    • Geology
    • Land Use
  PROJECT OBJECTIVES
    • Remediate Square D Company Site in order to:
    • Protect Human Health and the Environment
    • Return Land Quickly to Beneficial Use
    • Reduce Costs to Save Time and Money

  REMEDIATION TEAM
    • Members Consist of Square D Company, DTSC and the Public
    • Coordinate Work Schedule
    • Agree Upon Site Cleanup Goals
    • Provide Real Time Oversight
    • Streamline Report Approval Process
                            8-1

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 6
10
   PROJECT SCHEDULE
      4/94: Fee for Service Agreement
      5-7/94: RFI Phase I Completed
      8-9/94: RFI Phase I I/CMS Approval
      9/94-1/95:lnitial Risk Assessment
      9/94-3/96: Public Participation
      1/95-3/96: CMI Completed
      3/96: Corrective Action Terminated
   Q CONSTITUENTS OF CONCERN
      • Antimony
      • Arsenic
      • Barium
      • Beryllium
      • Cadmium
      • Total Chromium
   Q CONSTITUENTS OF CONCERN
      • Hexavalent Chromium
      • Copper
      • Lead
      • Mercury
      • Zinc
Q HEALTH RISK-BASED CLEANUP LEVELS
D RCRA FACILITY ASSESSMENT
    • 39 Solid Waste Management Units:
     • 1 Area of Concern (Main Plant Building)
    • 9 Regulated Units in Post Closure Permit:
     • Surface Impoundments
                              8-2

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11
12
13
14
15
Q RCRA FACILITY INVESTIGATIONS (RFI)
    B RFIs Performed in 1990,1992,1993,1994 and 1995
    • Identified 16 Areas of Concern
      • Parcels 1 and 2
    • Collected Baseline Data to Set Health Risk Based Cleanup
      Goals
    • Established Areas Require Corrective Measures
Q CORRECTIVE MEASURES STUDY
    • Established Efficient Remedial Method
    • Reduced Costs and Labor
    • Streamlined Process
    • Combined RFI Phase II with Corrective Measures Study
Q CORRECTIVE MEASURES STUDY
    • Record Deed Restriction
      • Parcel 1 only
    • Prepare Fact Sheet on Remediation
3 PUBLIC PARTICD7ATION ACTIVITIES
    • Prepared CEQA Initial Study and Negative Declaration
    • Sent Out Public Notice for Corrective Measures Study
    • Prepared Response to Public Comments

D CORRECTIVE MEASURES IMPLEMENTATION
    • Remedial Design Implemented 1/95
    • Used XRF to Screen Soil Samples
    • Verify Attainment of Cleanup Goals by Conventional Sampling
      and Analysis
    • Stored Remediation Wastes on Parcel 1
    • Stabilized Soil On-Site, If Necessary
    • Land Disposal of Wastes
    • Backfill and Cap Excavations
                               8-3

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16
17
Q CONCLUSIONS
    • SQUARE D COMPANY SITE WAS SUCCESSFULLY
      REMEDIATED TO CLEANUP CONTAMINATED SOIL
    • Effective Team Coordination
    • Streamlined Corrective Action Process and Resport Approval
    • Established Site Cleanup Goals Early
    • Reduced Costs and Labor
   RECOMMENDATIONS FOR FUTURE
   PROJECTS
    • Established Site Cleanup Goals Early
    • Use Appropriate Method for Onsite Screening
    • Establish Team for More Efficient Coordination
    • Combine Remediation Steps, If Feasible
                                8-4

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                       RCRA CORRECTIVE ACTION:
                               A CASE STUDY
A SUCCESSFUL REMEDIATION OF METALS CONTAMINATED SOIL AT
           SQUARE D COMPANY, BEAUMONT, CALIFORNIA

        By Theodore R Johnson m, Karen Baker and Mohinder Sandhu
                    Department of Toxic Substances Control

   Presented at the U. S. EPA Region 9 RCRA Collective Action Conference
                              March 26-28, 1996
                              Executive Summary

            The Square D Company ceased manufacturing operations at their Beaumont,
      California facility in 1989.  Several phases of site characterization were undertaken to
      delineate the horizontal and vertical extent of heavy metals contamination at the
      facility. The facility elected to enter into  the Fee For Service (FFS) program offered
      by the Department of Toxic Substances Control (DTSC) as a means of expediting
      remediation of the facility.  Collaborative  efforts were utilized  to address issues
      dealing with scheduling, cleanup goals, regulatory requirements, field oversight, and
      site characterization. The success of this corrective action project hinged on the
      facility and DTSC acting as a team, working to achieve a mutual goal of returning the
      Square D Company's property to beneficial use in a timely  and cost effective manner
      while protecting human health and the environment.  This team approach accelerated
      the environmental cleanup process and resulted in an economically feasible and
      environmentally responsible remediation.
                   1.0 Corrective Action Program Objectives
            One of the key objectives of California's corrective action program is to
      accelerate environmental restoration by utilizing a streamlined and proactive team
      approach. The intent of the program is to identify releases or potential releases of
      hazardous waste or constituents requiring investigation.  Once the release has been
      identified, the corrective action program  provides guidance to evaluate the nature and
      extent of releases and identify, develop, and implement appropriate corrective
      measures to remediate the identified releases.

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                                   2.0  Introduction

2.1    Site Background

             Square D Company, formerly Yates Industries, Inc., is located approximately
       70 miles east of the City of  Los Angeles, in Beaumont, California  (Figure 1). The
       site consists of three contiguous parcels (designated as Parcels 1, 2 and 3) collectively
       comprising 42.6 acres.  The facility is underlain by alluvial deposits composed of
       interbedded sands, clayey sands, silts, clayey .silts and clays. The uppermost aquifer
       below the  facility is at depths ranging from 160 to 223 feet below ground surface.

             The facility operations involved manufactured copper foil sheets for the printed
       circuit board industry. The facility began operations in 1970 and ceased  copper foil
       production in 1989 due to economic infeasibility.

             Before entering into the FFS program, Square D Company conducted four site
       investigations on Parcels 1 and 2 between 1990 and  1994.  The facility entered into
       the FFS program in April  1994.  Corrective measures implementation began in January
       1995 and concluded in March 1996.

2.2    Parcel 1

             Parcel 1  occupies nine acres and includes the former manufacturing and
       operational areas of the facility (Figure 2). The manufacturing process involved
       dissolving recycled and scrap copper metal in sulfuric acid and depositing the copper
       in  thin sheets on drums in electroplating baths. The resulting copper sheets were used
       by the electronics industry for printed circuit board production.

             Wastes generated by this process included spent solvents and plating solutions,
       waste machine oil, contaminated rinse waters, filters, and sludges containing heavy
       metals (antimony, arsenic, banum, cadmium, chromium, hexavalent chromium, copper,
       lead, mercury, nickel, and zinc).  Various waste treatment operations were utilized
       including reverse osmosis, filtration, chemical precipitation, and evaporation process
       (surface impoundments) to concentrate liquid waste sludge and reclaim rinse water and
       metals.  Early operations  at the facility included  on-site direct land application of
       process wastes.

             Currently, there is one regulated unit on Parcel  1, designated as the North Post
       Closure  Area (NPCA) (Figure 2). The NPCA was previously the site of the
       evaporation ponds (surface impoundments) and an area used for direct land disposal of
       wastes.  The NPCA was certified as closed with waste in place in May 1988. The
       facility completed the Post Closure Permit Application in June 1995. DTSC is
       currently drafting the post closure permit.

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23    Parcel 2
             Parcel 2 is an undeveloped 6.67-acre parcel east of Pennsylvania Avenue
       (Figure 2).  No manufacturing activities occurred on Parcel 2, however the area was
       used for the storage of scrap copper and equipment.  Surface impoundment sludges
       were found on Parcel 2 during site investigations conducted between 1992 and 1995.
       Additionally, during the period 1937 to 1947, disposal  of refuse occurred in the
       Beaumont Channel, a dry wash bisecting the southern border of Parcel 2.

2.4    Parcel 3

             Parcel 3 is an undeveloped 27-acre open area adjacent to the facility located
       south of East 3rd Street (Figure 2).  No known industrial activities have occurred on
       Parcel 3. This area was not a part of the proposed corrective measures; however, the
       site was utilized as a borrow site for the export of fill soil for Parcels 1 and 2 and is
       one of the areas where the background soil samples were collected.

                          3.0  Corrective Action Process

3.1    Historical Site Investigation

             The U.S. EPA conducted a RCRA Facility Assessment (RFA) of Parcel 1 in
       1987  The RFA identified 39 Solid Waste Management Units (SWMUs) and one Area
       of Concern (AOC).  Subsequent site investigations conducted by the facility identified
       releases of wastes (generated by the facility)  on Parcels 1  and 2.  DTSC's review of
       the soil analytical data  collected in the early investigations (1990 to 1994) indicated
       that lateral and vertical extent of contamination was not well delineated and several
       constituents of concern (COC), that are key health risk drivers, were not included in
       the investigations.

             Based on the RFA results and subsequent site investigations, the 39 SWMUs
       and one AOC were screened down to  16 AOCs (15 on Parcel 1 and all of Parcel 2).
       A RCRA Facility Investigation (RFI) Phase I was conducted in order to determine the
       extent  of soils contamination at Parcel 1 and  Parcel 2.  Based on the findings of the
       RFI Phase I, an additional soil investigation (RFI Phase II) and a health risk
       assessment were conducted to delineate the extent of the contamination present and
       assess  the potential threat to human health and the environment. Site investigations
       revealed that the AOCs were contaminated with arsenic, antimony, copper, chromium,
       hexavalent chromium, lead, and zinc above background levels.  On Parcel 2 and in the
       Beaumont Channel, site investigations conducted from  1992 to 1995 identified metals,
       including arsenic, cadmium, copper, chromium, lead and zinc at concentrations above
       background levels.
                                        Page 3

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              The Phase I and Phase El RFIs resulted in implementation of corrective
       measures for 15 AOCs on and adjacent to Parcel  1 and portions of Parcel 2.

3.2    Cleanup Goals

              The facility initially proposed to clean up the site to background levels for
       metals.  Upon further study, the cost of cleanup to background levels was found to be
       excessive. Therefore, the facility subsequently proposed health risk-based cleanup
       goals derived from the California Preliminary Endangerment Assessment (PEA)
       guidance document.  The PEA makes conservative assumptions for calculating the
       health risk-based cleanup levels.  During the implementation of the health risk-based
       cleanup levels, it was determined that achieving these cleanup goals was also
       infeasible in that certain soil background concentrations (arsenic, beryllium, thallium
       and vanadium) were higher than the health risk-based cleanup goals. Thus, a
       combination of the two approaches of health risk-based and background levels was
       used to establish the cleanup goals for soil  remediation.

              In the last  six months of the remediation, a site specific/constituent specific
       health based risk assessment was conducted to provide alternate cleanup goals for
       certain constituents (antimony, arsenic and  hexavalent chromium) because the initial
       cleanup goals for  these constituents were too conservative and, therefore, economically
       infeasible. The site specific/constituent specific cleanup levels provided the facility a
       means of completing the remediation in a cost effective and environmentally
       responsible manner.

              Cleanup levels for  Parcel 1 were established in consideration of the future land
       use to be industrial.  A risk management goal of 1  X  10"6 for a typical industrial
       exposure scenario was used to set the cleanup levels for this parcel.  However, for
       Parcel 2,  an  unrestricted land  use scenario was used, thus  assuming a residential use
       and a risk management goal of 1 X  10"6 was used to set the cleanup levels.

3.3    Proposed Corrective Measures

             The corrective measure selected for Parcel 1 and Parcel 2 was excavation and
       off-site disposal of impacted soil.  Impacted soil was defined as soil  with contaminant
       concentrations in excess of the health risk-based cleanup levels or contaminant levels
       that exceed naturally  occurring background concentrations. Excavated soil from the
       remediation was stockpiled on Parcel 1, profiled for RCRA metals, stabilized on-site
       as  required to meet Land Disposal Restrictions, and transported by rail to a permitted
       non-RCRA landfill in Utah. The cost savings for disposal to the Utah landfill versus
       disposal at the closest landfill  in California was over $7 million.
                                        Page 4

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3.4    Public Participation Activities

             Interviews were held with community group leaders, legislative officials and
       local regulatory agencies to gather the community's concerns for the proposed project.
       In December 1994 and January 199S, DTSC issued public notices of the California
       Environmental Quality Act (CEQA) documents, the Corrective Measures Study  and
       associated remedy selection.  Comments received during the public  comment period
       resulted  in three additional off-site AOCs.  After reviewing the soil  sample analyses,
       one of the three additional AOCs required excavation.

             Ten residential well owners responded during the public comment period with
       concerns regarding the effects of the facility's past practices on the groundwater
       pumped  from their wells.  DTSC met with the residential well owners and discussed
       the area  hydrogeology.  The residential wells are located hydraulically upgradient in
       relation to the facility and the water levels  measured in  the residential wells are
       approximately ISO feet vertically higher than the water levels measured at the facility.
       However, the facility, in a gesture of goodwill towards the community, tested all the
       residential wells. The results of the groundwater sampling analyses showed that the
       constituents present in the groundwater were at or below the levels  which are
       considered background for the facility.

3.5    Corrective Measures Implementation

             Remediation work  began at the facility in January 1995.  Soil samples were
       collected for on-site metals screening by a portable X-Ray Fluorescence (XRF)
       instrument when excavated areas reached proposed depths.  If the XRF analysis
       indicated residual soil contamination, additional excavation  was performed   If the
       XRF analysis indicated that the soil concentrations of the COC were equal to or less
       than the  cleanup goals, conventional confirmatory soil samples were collected.  If
       confirmation sample analyses indicated residual soil contamination above the cleanup
       goals, the contaminated area was excavated until the cleanup goals were attained
       Approximately 10 percent of the samples collected were duplicated  for quality
       assurance/quality control (QA/QC)  purposes   All  confirmation and QA/QC samples
       were sent to an off-site laboratory certified by the  Environmental Laboratory
       Accreditation Program.
                                        Page 5

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           4.0  General Issues Related to the Conective Action Process

4.1    Chronology of the site investigations:

       4.1.1  Prior to DTSC oversight

             1987         U.S. EPA conducted a RCRA Facility Assessment
             1990         Facility conducted Site Characterization on Parcel 1
             1992         Facility conducted Site Characterization on Parcel 2
             1993         Facility conducted Additional Site Characterization and
                          Pilot Study on Parcel 2
             1993 to 1994  DTSC reviewed previous site characterizations
             1994         Facility conducted RFI Phase I (Parcels 1 and 2)
             1994         DTSC compiled an additional list of AOCs and COC list

       4.1.2  Under DTSC oversight

             1994         Facility entered into FFS program, giving the corrective action
                          project a priority  status.
             1994 to 199S  RFI Phase I Report (Parcels  1 and 2) and RFI Phase II (Parcels
                          1  and 2)

                    In April 1994, the facility proceeded with the RFI Phase I.  However,
             the RFI Phase I Report on Parcel  1 did not include the additional AOCs and a
             complete list of COCs because the facility's investigation was completed prior
             to the compilation of DTSC's lists. The COC list was of particular concern to
             DTSC because the soil analyses to date excluded COC which were the mam
             risk drivers for the health risk assessment, such as arsenic and hexavalent
             chromium. To investigate the additional AOCs and collect soil samples with
             the complete COC list, a RFI Phase n  was  initiated.

4.2    Combining corrective action steps

                    In lieu of requiring the facility to complete a separate RFI Phase II for
             Parcels 1 and 2,  DTSC suggested that the facility  combine the RFI Phase  II
             workplan with the Corrective Measures Study submittal and initiate the
             additional characterization  concurrently with the corrective measures
             implementation.  In effect, any additional areas requiring removal of soil could
             be combined with the existing areas scheduled for soil removal, thus
             eliminating duplication of cost for equipment and mobilization.
             Consolidation of these tasks reduced preparation and review time of workplans
             and reports resulting  in a savings of over eight months of overall schedule
             time.
                                       Page 6

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 43    Additional characterization versus excavation

                     To avoid additional costs during the investigative stage of corrective
              action, the facility and DTSC concurred that characterization in the known
              contaminated areas was sufficient to initiate excavation, with the understanding
              that additional characterization, outside planned excavation areas on Parcel 1
              and Parcel 2, would be undertaken  concurrently.

                     Approximately ten (10) times the amount of soil was removed from
              Parcels 1 and 2 than originally estimated.

 4.4    Project coordination and oversight

                    The facility and DTSC engaged in a series  of meetings to discuss the
              protocol, processes, procedures and scheduling  for the project.  The agreement
              reached between DTSC and the facility ensured that workplans and reports
              were submitted and reviewed in a timely manner and that the concerns of all
              panics involved were addressed.  This resulted  in a savings of over six (6)
              months of overall schedule time.

                    The  FFS process required scheduling and budgeting for the various
              phases of corrective action.  The facility requested ihe corrective action process
              be accelerated to accommodate a schedule regarding a real estate transaction
              involving Parcel  1.  DTSC assigned a project manager as the point of contact
              through whom all correspondence and transactions would be processed.  The
              project manager was also responsible for the day-to-day oversight of field
              operations and accountable for project costs.  This  ensured efficient
              communication between the  facility and DTSC; it also  expedited decisions
              regarding excavations, stockpile management, regulatory requirements, and soil
              screening and confirmation sampling strategies.

                    Additionally, the presence of the DTSC  project  manager on-site
              facilitated rapid response to the community's concerns and created open
              communications between the community, DTSC and the facility.

4.5    Regulatory issues

       4.5.1   Land Disposal Restrictions (LDRs)

                    The Corrective Action Implementation Workplans for Parcels 1  and 2
              stated that the stockpiles would be placed on visqueen sheeting to prevent
              contamination of the underlying subgrade. The use of visqueen was not
              practicable because it was easily damaged by extensive heavy equipment  traffic
              during stockpiling; and, therefore, was not used.

                                        Page 7

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             Heavy equipment used for stockpiling operations breached the asphalt/base
             layer adjacent to and below .the stockpiles.

                    The loading of soil onto rail cars could not be accomplished from Parcel
             2 as approved by DTSC in the CMI Workplan due to railroad regulation
             restrictions.  Excavated soil from Parcel 2 was transported to Parcel 1 and
             placed in stockpiles in the parking area adjacent to and behind the Main Plant
             Building (Figure 2).

                    The placement of contaminated soil from Parcel 2 to Parcel  1 resulted
             in violation of the LDR regulations. To  mitigate the spread of contamination
             from Parcel 2 to Parcel 1, in the areas where stockpiles were placed, DTSC
             requested that the asphalt, base material and underlying soil be excavated after
             removal of stockpiles and  confirmation soil samples collected. DTSC
             determined that to stop the transfer of soil from Parcel 2 to Parcel 1 would
             result in costly delays in the  remediation as well as create an impracticable
             situation for the disposal of soil off-site by train.  DTSC requested the facility
             to remove the soil as soon as possible and to adhere to mitigating measures
             (visqueen-covered stockpiles and a covered route from Parcel 2 to Parcel 1) to
             prevent a release of contaminated soil excavated from Parcel 2.

       4.5.2  Deed Restriction

                    Since the facility used industrial  health risk-based cleanup levels for
             Parcel 1, a deed restriction was required to limit the future site use  to
             industrial. In addition to a deed restriction, federal and state laws and
             regulations require future site owners and occupants to manage any hazardous
             materials that may be generated during excavations for modification of the
             buildings or the areas surrounding the buildings.

                    It was acknowledged  by both DTSC and the facility during the early
             stages of the project that a deed restriction would be required. DTSC presented
             the standard deed restriction  language (pursuant to DTSC Management Memo
             87-14), to which the facility  had several objections.  The negotiation process
             took approximately three (3) months.

5.0    Observations and Recommendations

             Open and frequent communication between the facility and DTSC was
       paramount in the success of this corrective action project. Creating project schedules
       and goals prior to corrective action implementation established clear direction for the
       corrective action process.  A combination of project management decisions enabled the
       facility and DTSC to complete this corrective action in an economically feasible, time
       effective and environmentally responsible manner.

                                        Page 8

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 Some of these project management decisions were:

        1.     Combining corrective action steps such as RFI Phase II during
              excavation.  This resulted in a savings of approximately eight months in
              overall schedule time.

        2.     Utilizing meetings, including teleconference calls, to establish a mutual
              understanding of concepts, processes and problems.

        3.     Streamlining report submittal and revision process.  Draft reports were
              submitted and deficiencies were addressed through meetings and/or
              teleconference calls.  Final reports incorporated the agreed upon  changes
              resulting in reduced approval time for submitted reports.

        4.     Providing frequent real time oversight in the field.

        Some lessons that were learned during this project which may provide
 additional economic and time savings on future projects are as follows:

        1.     Establish site specific cleanup goals early in the project.  As soon as
              chemical compounds have been speciated,  a Health Risk Assessment
              (HRA) should be completed.  Also,  a theoretical model of the various
              disposal scenarios should be developed.  The modeling process coupled
              with the HRA can lead to the selection of the most feasible and
              economic alternative  while detailed site characterization is in progress.

       2.     If deed restrictions are anticipated, DTSC and the facility should start
              negotiating the documents mechanism and language early during the
              corrective action process.

       3      Acceptable on-site screening of soil  can  be cost effective and expedite
              site restoration.

       4      During the initial planning stages, the facility and the applicable
              regulating agencies should agree on  the corrective measures
              implementation designs to mitigate  any possible  regulatory violations

       The ultimate success of this project hinged on the regulated community  (Square
D Company) and the regulating agency (DTSC)  working together to  return the
facility's property to a useful status while protecting human health and the
environment

       The duration of the  corrective action project was two years (April 1994  to
March 1996)  The property will be ready for reuse, in March 1996.

                                  Page 9

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                           FACILITY 	

^i:£^VJ

                     1/2
     N
                               Scale in miles
FACILITY LOCATION MAP
      SQUARE D COMPANY
      1060 EAST 3RD STREET
     BEAUMONT, CALIFORNIA
       For Square 0 Company
REFERENCE: USGS 7.5 Minute Series Topographic Map, •Beaumont. Calif."
        Quadrangle, Photorevised 1988.
                                                      DRAFT
                                     Dames & Moore
                                     FIGURE 1

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                                                    TW BUILDING
j
1
1
1
1
1
1
1
1
i
•
i
i
""-•• L
•
OfM^^XJ I
CLOSURE 1
AREA j , —
|T_i__j__
Transtofn

i
1
i
i
1
NORTH 1
BrtOT—T'l <~»OI IDC '
rUbl— GLUoUrlt i
AREA J
1 	 '
i
j

/ — Power
/ Building
L_J
-,J |
-J ' J BUILDING
1 ~~\ --•..,
~~ ^ — Tank Farm
1

MAIN
PLANT
BUILDIN'3





	 i


\
K 'n
i 1





                                                East 3rd  Street
                              'azardous
                               Waste
                              Building
  Explanation:
          Post Closure Area
PARCEL 3
(27 Acres)

                                                                                           PARCEL 1
                                                                                           (9 Acres)
                                                                                                                  A
                                                                                                                            PARCEL 2
                                                                                                                            (6.7 Acres)
SITE  FACILITY  MAP

    SQUARE D COMPANY
   1060 EAST 3RD STREET
   BEAUMONT. CALIFORNIA
    For Square 0 Company

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This Page Intentionally Blank

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9

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        VADOSE ZONE
   CONTAMINANT TRANSPORT

        Ronald C. Sims
Environmental  Engineering Division
       Utah State University
    Logan, Utah 84322-4110
        (801)  797-2926
      sims@lab.cee.usu.edu
 MISUNDERSTOOD WORLD OF
 UNSATURATED FLOW

 STORAGE IN THE VADOSE ZONE

 LIQUID FLOW IN THE VADOSE ZONE

 CHEMICAL MOBILITY IN THE
 VADOSE ZONE
               9-1

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             METHODOLOGY FOR INTEGRATING SITE
          CHARACTERIZATION WITH SUBSURFACE REMEDIATION
Characterization
Site
i
Soil
1

1
Uaste 1
1
1
uisirioution
Reaction
Migration/Escape
Exposure
/
\
\
/
\ reaimeni
Technique
Evaluation &
Selection
N
/
Treatment
Measurement


   Problem Definition
Treatment (train')
Monitoring
                                 9-2

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           VADOSE ZONE

      Vadosus   =     shallow
      Vadere    =     walk or wade

Therefore:
   slow movement at  a shallow depth
"When water moves into  relatively
dry,  unsaturated sediment, it is only
slightly  affected  by gravitation."
          co rujuct it   in the
unsaturated zone depends  upon the
amount  of water residing at  any one
time in  that  material.
                  9-3

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 The  Misunderstood World  of Unsaturated Flow
 by Jay H. Lehr
    For decades, farmers made critical errors in the estab-
 lishment of drainage systems to maintain proper soil*
 moisture levels in the root-zones of their crops. These
 errors were the result of misunderstanding flow in the
 unsaturated zone, by confusing it with saturated flow.
 Results were as radically out of phase as those expe-
 rienced when people favorably compared the nature of
 surface water flow with ground water flow. In spite of
 widespread beliefs, we have fev underground  streams
 bubbling turbulently along as they do on the surface, and
 contrary to accepted physical precepts, highly permeable
 conduits will not normally conduct  moisture rapidly
 through the unsaturated zone.
    Perhaps for ground water scientists following in the
 erroneous paths of misguided soil physicists and agricul-
 tural engineers, the problem has been exacerbated by the
 ill-chosen  but popular appelation, "vadose zone." True
 enough, the Latin roots "Vadosus" meaning shallow and
 "vadere- meaning to walk or wade infer slow movement
 at a shallow depth. Bui as Latin has fallen out of our
 common,  intellectual framework, obvious terms '•un-
 saturated zone" or even "zone of aeration" would create
 less confusion.
    We all recognize that ground water flow—when gov-
 erned by Darcy's century-old, physical law—allows pre-
 cise description. Here, potential energy is efficiently util-
 ized in overcoming frictional resistance and creating the
 kinetic energy of movement. Surface water flow, on the
 other hand, defies accurate prediction because of random
 energy loss produced by turbulence. Many of us still do
 not clearly understand the equally distinct variations that
 make Darcian flow dramatically different from  unsatu-
 rated flow.
   The variations occurring between surface and ground
 water flow result from dramatic velocity variations, while
 the differences between unsaturated and saturated flow
 result from very different variables that conirol permea-
 bility. Many of the articles in this issue,  and countless
 others thai have preceded them, offer ground water
 scientists and engineers insight into how we can monitor
flow in the unsaturated or?vadose"zone.aswell as a hint
 of what that data may mean in terms of the movement of

 4         Spring 1988 CW.MR
    contaminants in and through that zone and ultimately to I
    the water table below. But as I convene with colleagues I
    across this country and abroad, I am amazed at how few
    truly understand the basic physics that make this inter-
iatg Tone of fluiq
                                    r801C8l]Vfli|jejCIll
    from thg familiar arena of saturated flow. If you arc not
    among my misinformed, uninformed or apathetic friends
    in our rapidly expanding scientific community, you may
    find this editorial sophomoric, simplistic or even insult-
    ing. If you suspect that your intellectual acuity on this
    subject needs no additional stimulus, by all means skip
    ahead to the far more sophisticated contributions th»f
    follow. But if I have piqued your curiosity, follow me {
    we shrink ourselves to the size of water drops and imagi;
    our way through the misunderstood world of unsaturated
    flow.
       Let us first define our boundaries in accordance with
    the oft-forgotten father of ground water hydrology,
    Oscar  E.  Meinzer whose classic  1923  USGS Water
   Supply Papers 489 and 404. divided the vadose zone into*
   three belts. The uppermost belt "consists of soil and other
   materials that lie near enough to the surface 10 discharge;
   water into the atmosphere in perceptible Quantities by
   the action of plants or bv soil evaporation and convee-
   tion." The lowest belt, which we know as the capillary
  _£nnaL.is "the belt immediately above the water table that
   contains water drawn up from the zone of saturation by
   capillary action." Meinzer then defined the primary target
   of this monologue as the intermediate belt, which simp[v
   "lies between the belt  nf 
-------
/to
ues
ew
er-
cm
101
ids
lay
jli-
his
dp
ut
as
me
         media, may not be necessary for many of our engineering
         purposes.
          '  Movement in the unsaturated zone  is primarily a
         function of negative forces built up by conditions found
         not to be in equilibrium. The negative or suction forces
                      called capillary f°""" *nA
  hesion—the attraction of unlike molecules (i.e.. water to
  rock panicles) and cohesion—which is the attraction of
  like molecules such as water to water.
     The strength ol both cohesion and adhesion in water
  i% due chiefly to hydrogen bonding as a result of the
  hydrogen and oxygen attachment unsymmetrically sur-
  rounded by electrons, so that there is a separation of
  k%harj.'e or polar character. If other molecules with non-
  hind..%•  electrons are present, there is a tendency for
  hydr-jjen to increase the symmetry of its surroundings
  by approaching a pair of electrons in line with its chemical
  bond to oxygen.
     When water-moves into relatively dry. unsaturated
  rock or sediment, it is only slightly affected by gravitation
  «nd will move horizontally as well as downward. Adhe-
  sive and cohesive forces are responsible for this movement
  against the force of gravity. The pressure in the water is
  Uc* than the pressure of the atmosphere, and the water is
  si\d to be under tension. As the sediment becomes wetter
  and  wetter, however, gravity does play a stronger role
                                                        pores exists under tension, as is usually the case, such
                                                        materials stop or materially retard water flow. Thus.
                                                        efforts  bv farmer* to drain unsaturated sedim^n.c fry
                                                        construction of coarse media drains have had the rgv
 .and the volume of potential flow-paths increase thereby
 Increasing hsdraulic conducti vity.
     Water is held in small pores by large adhesive and
   .ihesivc forces as a result  of greater surface area of
   .•diment per cubic inch of earth material These small
   ores are like those in blotting paper used to soak up ink
   r paper towels used to soak up whatever liquid you
   pilled. Larger pores cannot hold water at tensions that
. exist in smaller pores, so water does not move readily
 from fine to coarse material.
     As finer material becomes very wet. water will even-
 tually move from it to coarser material in contact with it
 much as coffee will leak from a soaked paper towel.
 Coarse material, layered below fine material in an unsat-
 urated  zone, will act like a check-valve, holding water
 back until the finer material above it becomes very wet,
 then allowing the excess flow to pass through.
    The unsaturated zone may include ponions that are.
 in fact, totally saturated as a result of being perched
 above an impermeable segment of rock orclay-like mate-
 rial which, in turn, mav overlie an exceptionally drv area
 sheltered by the perching matenal.
    Although fine sediment hinders downward movement
 of water, it does absorb water readily. Perched water
jables are  built up over fine materials not because of
 water's inability to enter them, but as a result of slow
^transmission through them. The extent to which down-
 ward flow  is restricted and  water  storage is altered
 depends on the fineness of the pores and the thickness of
 the restricting layer.
    Porous materials with very large pores in the unsatu-
   ted 7one aid in water movement only under conditions
   icre there is  contact with free water or water under
 .•ositive or atmospheric pressure. Where water in these
 effect: in fact, creating barriers to flow. Similarly, ground
 water scientists who can correctly predict the movement
 of contaminant plumes into  more highly permeable
 members of underlying formations below the water table
 are rudely awakened when they attempt to interpolate
 similar scenarios in the unsaturated zones. Thus, we see
 the topsy-turvy world of this zone of aeration — this zone
 where, it seems, that night is day and small pores attract
 while large pores repel.
       "When water moves into
     relatively dry,  unsaturated
     sediment, it  is only slightly
       affected by gravitation."
    Let us not gloss over too quickly the possibility of
 larger pores being in contact with free water or atmo-
 spheric pressure. It does happen as a result of almost
 microscopic root-borings and fractures that  produce,
 what we  call "finger-flow" instead  of the predictable7
 wetting from in homogenous, dry sediment. Many con-
 taminants introduced at or near ground surface will flow
 through fine to narrow vertical paths as a result of their
 initial ability to maintain atmospheric  pressure in these
 relatively  open micro-pore channels.  Continued flow
 along these paths is maintained by cohesive forces that
 draw water along the previously wetted channels much
 like water flows in rivulets over a pane of glass, never
 evenly wetting the entire pane. This phenomenon further
 exacerbates the unpredictable passage  of contaminants
 through the unsaturated zone.
    Trapped air can also  play a significant role in the
 unsaturaied zone. Initially an advancing front of leachate
 will be irregular and air will be expelled at various points.
 The energy required to force air out  of the unsaturaied
 zone will  slow the rate of infiltration.  As a saturating
 front  advances, pockets of dry sediment  will be left to
 form barriers to water movement. Continued movement
 of leachate. nevertheless, will dissolve some of the air. In
 this manner, effects of trapped  air may reverse  the
 response expected when fine sediment is encountered.
    Eventually, as all good scientists do, we must try to
quantify movement in the saturated zone which leads us
to attempt the use of equations distantly related to Dar-
cy V In fact, many attempt this exercise by using Darcy's
law recognizing that hydraulic conductivity is a far more
elusive number than it is  in the saturated zone. While
conductivity is a virtual constant in the saturated zone
 where it is entirely dependent on the fnctional resistance
 rendered by a formation's collective surface area and that
 same  formation's cross-sectional  area of void  space
 through which flow may occur, conductivity is a moving
 target in the unsaturated zone where the slightest change
                                                              9-5
                                                                             Spring 19X8 GW.MR

-------
      in moisture content alters both the restrictive adhesive
      and cohesive fnrrg* nT1f1th" "»'"""» "f nathwnw nncn far
      transport.
         Hvdraulic conduciivitv in the unsaturated 7one is a
      function of both grain si?e and sorting of paniculate
      materials just as it is in the saturated rone: additionally, it
      depends on ihe amount of water residing aianv one time
      in that material. Water in the pores under negative pres-
      sure cannot move from small pores to large pores, thus
      contaminant movement takes  place only through the
      continuous films of water that surround the rock pani-
      cles. A* the volume of water declines, there is less area left
xp   through which water can flow Thus, as water ormflisjujg.
      foment declines, so does the hydraulic conductivity in
      the umamrated zone.
         Theoretically, if one can properly characterize the
      physical nature of the structure of the unsaturated zone
      and maintain continuous readings of soil moisture (or
      soil tension) in a depth profile from neutron logs, porous'
      blocks, or suction-lysimeiers. one can use a Darcy equa-
      tion to calculate flow. But. obviously, we are dealing with
      a dynamic system that changes continuously over time in
      a non-linear manner. At the lower end of the moisture
      scale, transport  is overwhelmed  by the capillary  force
      capabilities to retard flow. In the mid-range of moisture
      content, a degree of linear improvement in conductive
      properties occur. A< saturation approaches 70 percent of
      available pore space, flow begins to be Darcian in nature
      and hydraulic conductivity asymptotically approaches
      that which we recognize in the saturated zone.
   Fora number of reasons. I have avoided delving into
the capillary zone which is the next stop on the way to the
water table. First, it is normally a thin zone, a few inches
over coarse material and a few meters over fine material
Second, it acts both like the unsaturated zone by exhibit'
ing tension and the saturated zone by allowing, movement
in the direction of the local ground water flow gradient, li
is probably a subject for another editorial but. regardless.
its ultimate impact on the timing and direction of con-
taminant transport into our ground water systems is of
considerably less impact than that offered by the inter-
mediate zone of aeration lying above it.
   If I have piqued your interest, overwhelmed or con-
fused you. and you are determined to get to the bottom of
this misunderstood subterranean strata, you may be able
to alleviate the misery by viewing an old but excellent
film titled Waitr Movement In So;'/ made in I960 by Dr.
Walter Gardner and the Agronomy and Soils Depart-
ment of Washington State University in Pullman. Wash-
ington. Gardner* film is a classic in educational simplic-
ity, if not mathematical elegance. If you cant find it in
your local  university film library,  you can find it in
NWWA*.
   Let me conclude this monologue with a riddle that
has served me well these past four decades in ground
water science. If the answer un\ obvious, ask  any teen-
ager to fill in the blanks.
    Flow in the unsaturated
                                                           9-6

-------

      MODELING
Land Surface
 Belt of Soil Water
     •Distribution
                 'WATER
      Reaction
  Intermediate Beit
2	,
o
n
e

of

A
e
r
a
t
i
o
n_
Z"
o
n
e

of

S
a
t
u
r
a
t
i
o
n
             9-7

-------
CHEMICAL MASS BALANCE APPROACH FOR CONTAMINATED SOIL
                                   texture
                                     sand
                                    silt
                                    clay
gas
 carbon dioxide
 oxygen
                                                                   a 3
 Solid Phase contains solid components of soil/waste mixture
 (1) organic matter
 (2) texture, i.e., sand, silt, and clay components

 Fluid Phase contains components that can flow
 (1) NAPL - Non-Aqueous Phase Liquid (e.g., oil)
 (2) gases, generally including carbon dioxide and oxygen
 (3) water or leachate
                                    9-8

-------
  SOIL MOISTURE EXAMPLE

GIVEN:
  60 cc MOIST SOIL
  WEIGHT = 1 00 GRAMS (MOIST)
  WEIGHT -  85 GRAMS (AIR-DRY)
  WEIGHT =  80 GRAMS (OVEN-DRY)

FIND:
    m
    v
  BULK DENSITY (pb)
SOLUTION:
  0m= [100  gm-80gm]/80gm= 25%

  ©v = [100  gm-80gm]/60cc  = 33%

  pb = 80 gm/60 cc  = 1.33 gm/cc
                 9-9

-------
CO
Field Capacity:
     Amount of water held by soil against
gravitational force. (0.3 atm for fine-textured soils,
0.1 atm for coarse-textured soils).

Wilting Point:
     Soil moisture at which the ease of release of
                                        «
water to plant roots is just barely too small to
balance the transpiration losses. (15 atm).


Available Water:
     Difference in soil water content at field
capacity and wilting point.
    pt-| • Soil/Vadose Zone Fundamentals

-------
                              POROSITY

         POROSITY = [1 - BULK DENSITY/PARTICLE DENSITY] X 100

SILT 1

[ GRAVEL 1

1 SAND J

1 C! AY

  10         20         30         40         50        60         70

                               POROSITY %

   (REFERENCE: DRAGUN, 1988)
Discussion:

*     Clay is more porous than sand, silt, & gravel, therefore can store more
water;

*     Clay is more porous than sand, silt, & gravel, therefore can store more
water soluble contaminants;

*     Clay represents smallest particle size, therefore offers greatest resistance to
flow of fluids including water, air, NAPL.

*     Clay texture has slowest diffusion and greatest sorption of chemicals,
therefore old sites (>50 years) may have high contamination and new sites (< 1
year) may  have low contamination in clay.
                                    3-11

-------
      20
Feet
      15
above
      10
water
table
               hi
                      SILT
              rl
r2
                          h2
                                SAND
r3
                                     h3
                   SILTY
                   GRAVEL
r4
                          h4
SANDY
GRAVEL   COAR
         GRAVL^
       _j rb n6
          Fine  <-
         TEXTURE-
                   ~>
                    Coarse
                 RELATIONSHIP BETWEEN PORE SIZE (r) AND
                 CAPILLARY RISE (h) IN UNSATURATED SOIL
                                9-12

-------
                                      DNAPL AS
                                    " RESIDUAL SATURATION
  DNAPL CONTAMINATED UNSATURATED ZONE WITH FOUR PHASES:
  AIR, SOLID, WATER, AND NAPL RESIDUAL SATURATION IS NAPL
  RETAINED BY CAPILLARY FORCES IN THE MEDIA. SOLUBILIZATION OF
  RESIDUAL SATURATION CAN OCCUR BY WATER PERCOLATION.

  (Reference: Huling and Weaver, 1991)

               NON-AQUEOUS  PHASE LIQUIDS  (NAPLS)

      Light Non-Aqueous Phase Liquids (LNAPLS)

      Oil
      Pentachlorophenol in oil
o    Dense Non-Aqueous Phase Liquids (DNAPLS^

     Creosote
     Methylene Chloride

Discussion:

o    Can have free phase flow

o    Can have residual saturation

o    Chemicals within the NAPL can contaminate air, water, and soil
     through distribution among compartments in the subsurface
                                 9-13

-------
            Photograph  of  Residual  Saturation  in  the Subsurface

o     Another source of contamination

o     Chemicals originate from "residual saturation" and distribute in air,
      water, and soil phases in unsaturated zone

o     Chemicals distribute in water and soil phase in saturated zone

o     Chemicals can be transported from "residual saturation" in the
      unsaturated zone into the saturated zone by percolating water
Discussion:

o     Distribution among phases depends upon "tendency" or "preference"
      of each chemical to be in a particular phase(es)

o     Knowing something about the "tendency" of each chemical to be
      associated with one or more phases provides information that can be
      used to formulate the "problem" at the site

o     Challenges to  bioremediation  of residual saturation include toxicity
      and "bioavailability" of chemicals within the "resdiual saturation"
POP  and PAH  concentrations  in water  fractions from non-poisoned soil in
Time  (days)      0     30    60    oO   l30  lo  200   285

PCP             7.53  2.63  2.67  2.28  1.38  1.35  0.50  1.13

Naphthalene      6.90  5.17  5.02  4.98  4.59  3.24  2.93  2.82

Acenaphthylene   5.70  5.21  4.90  4.44  4.91  4.68  4.00  4.19

Acenaphthene     2.86  2.34  2.17  2.00  2.05  2.06  1.33  1.42

Fluorene         0.39  0.22  0.20  0.16  0.09  0.02  0.04  0.04
                                      9-14

-------
       u
              30
              20
              10
                                                     B
                                     B


                                      fl   A   ft—fr
               -SO      0      SO     100     ISO     200     250      300
                                Time of Incubation in Soil (Days)

                                  O Non-poisoned soil
                                  A Poisoned soil
                                  • ry»niaminat
-------
             FLUX
EXAMPLE:
Velocity
                  AR
EA
   Flux =     Volume   =  aal
           Time -  Area   day-ft2
             z
   j    =  -Jo  
-------
EXAMPLE:
     \J -
          VELOCITY
          V  =

          V  =   0.125 cm/hr
                  0.23

          V  = 0.54  cm/hr
                  9-17

-------
 MOBILITY OF CHEMICALS IN SOIL
        R = VW/VP
        R = 1 + pb Kd/0
R  = Water  velocity  relative  to
   pollutant  velocity  (Retardation)
Vw= Velocity  of  water
Vp  =  Velocity  of pollutant
pb = Soil bulk  density
Kd = Soil parition  coefficient
   = Cone,  in soil/cone,  in water
   = C>>(ug/gm)   =  m I
     Cw(ug/ml)      gm
0  = Soil moisture  content

R  = 1 + ram/cc]   rml/gm]
          £cc/cc]
   = 1 + [ml/cc]and since ml=cc
       £cc/cc]
   = 1 + rcc/cc]
       [cc/cc]
R  = UNITLESS
                 9-18

-------
Discussion:
      Useful for characterizing the behavior of a chemical at a site (takes
      into  account site characteristics (p, 6)  and chemical-site
      interaction  (Kd)

      Useful for formulating the  problem  at a  site with regard to
      transport

      Useful for devising treatment approaches - may  be possible to
      "manage" the magnitude of R by controlling 6 or Kd

      Useful for designing monitoring strategies for specific chemicals -
      rank chemicals in terms of tendency to be immobilized at a site
Assume:
           Pb
           ©v
           Kd

Then:   using
           R

Results   in:
           R
           R
           R
                     RETARDATION  EXAMPLE
1.4  gm/cc
0.2  cc/cc
2      ml/gm
1 + pb
1  + [1.4]  [2]/[0.2]
1  + [2.8]/[0.2]
1 + 14  = 15
Interpretation:  The  pollutant  will   move  15  times   more   slowly
than  the  water  through  the  soil.
                                   9-19

-------
                  BIOREMEDIATION
                      Illustration  of  "Pac-Bug1
      Biodegradation
Discussion:

o    Often  mis-interpreted  for  volatilization,  leaching,  sorption

o    Implies many things to many people: a) mineralization to carbon
     dioxide and water; b)  destruction of toxicity; c) transformation to a
     chemical that is not the parent compound

o    Can result in the  production  of "metabolites" or chemicals that
     represent "what left" of the parent chemical - these can be more or
     less toxic than  the parent compound (e.g., trichloroethylene [TCE] to
     vinyl  chloride  [VC])
                                    9-20

-------
                 Degradation  of  Contaminant  in  Soil
o     dC/dt  =  -

o     ti/2  = 0.693/k  [a  first order equation]

o     ti/2  = half-life of the chemical

o     0.693 =  a constant (natural  logarithm of 2)

o     k  =  slope of  first order  plot of In Concentration versus time



Discussion:

o     The  first  order  equation  for half-life is commonly  used by  scientists
      and  engineers to quantify biodegradation  in soil and ground-water

o     Many  half-life values  are in the  literature

o     Ask  what mechanisms the  half-life  value  includes  for a chemical,
      i.e.,  does  it include  volatilization,  leaching, abiotic degradation?
                                     9-21

-------
     c
     o

     CO
     re

     c

     S

     Q.
     O
     D.
     I
     O
     •c
                                    60
80
                        Time (days)
Mineralization  of  14C-PCP  In  non-poisoned  soil
microcosms  as  a function  of  oxygen  concentration.
Error  bars  represent  the  least  significant  difference
4.27.    Values plotted  are the  means for  triplicate
reactors.


Average distribution of  14C in non-poisoned microcosms
spiked  with  14C-PCP  ± standard  deviation.
               of
Oxygen
Concen
tration
0%
2%
5%
10%
21%
Mineralized

0.51
63. 5±
55.81
54.11
48.41

0.64
0.51
0.15
3.17
0.60
Volatilized

0.111
0.011
0.031
0.051
0.021

0.15
0.01
0.02
0.04
0.01
Soil Soil Bound
Extractable

85.81
15.01
15.31
12.01
17.91

2.82
1.18
2.69
4.76
1.01

3.81
14.51
14.31
16.41
15.31

0.45
0.91
1.43
0.79
0.52
i«C
Recovered

90
93
85
82
81

.21
.01
.31
.61
.61

2.93
1.57
3.05
5.77
1.29
                             9-22

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           SOIL-BASED CHARACTERIZATION
Chemical
Properties
Chemical
Class
Chemical
Reactivity
Soil Degradation
Parameters
Specific Gravity
Water  Solubility
Molecular Weight
Melting Point
Acid
Base
Polar Neutral
Nonpolar Neutral
Inorganic
Oxidation
Reduction
Hydrolysis
Polymerization
Precipitation
Photodegradation
Half-life,  (ti/2)
Rate Constant
Loss of Parent Compound
Mineralization
Intermediates
Biotic/Abiotic
          SOIL-BASED  CHARACTERIZATION
Volatilization
Parameters
     Soil  Sorption
     Parameters
          Soil  Contamination
          Parameters
AirWater (Kh)
Vapor Pressure
     SoihWater (Kd)
     Soil Organic Carbon (Koc)
     Octanol:Water (Kow)
          Concentration in Soil
          Soil Horizonation
          Depth of Contamination
          Physcial Phases  (oil.water.air)
                                  9-23

-------
                             References

Aprill, W. and R.C. Sims. Evaluation of the Use of Prairie Grasses for
Stimulating Poly cyclic Aromatic Hydrocarbon  Treatment in Soil.
Chemosphere, 20(1-2):  253-265,  1990.

Ferro, A., R.C. Sims, and B. Bugbee. Hycrest Crested Wheatgrass
Accelerates the Degradation of Pentachlorophenol in  Soil.  Journal  of
Environmental Quality, 23(2):  272-279,  1994.

Sims, R.C. and J.L. Sims. Chemical Mass Balance  Approach  to Field
Evaluation of Bioremediation.  Environmental Progress, 14(1):F2-F3, 1995.

Symons, B.D., R.C. Sims, and W.J.  Grenney. Fate and Transport of Organics in
Soil: Model Predictions  and Experimental Results. Journal Water  Pollution
Control  Federation, 60(9):  1684-1693,  1988.

U.S. EPA. RCRA Corrective Actions - Speaker Slide Copies. Center for
Environmental Research Information (CERI). CERI-91-99, NRMRL,
Cincinnati, OH. Nov.,  1991.

U.S. EPA. Sensitive Parameter  Evaluation for a Vadose Zone Fate  and
Transport Model. EPA/600/2-89/039. NNRMRL, Ada, OK, 1989.

U.S. EPA. Site Characterization for Subsurface  Remediation.
EPA/625/4-91/026,  NRMRL, Ada, OK. Nov., 1991.
                                    9-24

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10

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                          WASTE BURIAL IN ARID ENVIRONMENTS-
   APPLICATION OF INFORMATION FROM A FIELD LABORATORY IN THE MOJAVE DESERT
                                          B.J. Andraski
                                      U.S. Geological Survey
                                  333 West Nye Lane, Room 203
                                      Carson City, NV 89706
                                    email: andraski@usgs.gov
                            Phone: (702)887-7636; FAX (702)887-7629
                                          ABSTRACT
As and sites in the western United States are increasingly sought for disposal of the Nation's hazardous
wastes and as volumes of locally generated municipal and industrial wastes continue to increase, concern
about the potential effect of contaminants on environmental quality in the region is being raised. A
prevalent assumption is that percolation will be negligible at an arid site  However, few data have been
available to test assumptions about the natural soil-water flow systems at arid sites, and even less is
known about how the natural processes are altered by construction of a waste facility.

In 1976. the U S  Geological Survey began a senes of studies at a site in the Mojave Desert, near Beatty,
Ne\ , to evaluate  mechanisms that can affect waste isolation. Precipitation at the site averages 108 mm/yr
and depth to ground water is 110 m.  Chloride concentrations in the unsaturated zone beneath an
undisturbed, vegetated area indicate that deep percolation of water was limited to the upper 10 m during
the past 16,000 to 30,000 years. Long-term field monitoring confirms the effectiveness of the natural
soil-plant system  in limiting the potential for deep percolation:  stratified soils impede deep percolation
and accumulated water is rapidly depleted by vegetation.  Under waste-burial conditions, however,
infiltrated uater accumulates and continues to move downward in liquid and vapor form  Rates of trench-
cover subsidence  are positively correlated with the long-term accumulation of infiltrated water and
erosion rates are inversely related to near-surface rock-fragment content

Continued long-term monitoring at the Mojave Desert site is critical to documenting how mechanisms
controlling waste  isolation may change with tune. Because of the complexity of liquid- and vapor-flow
processes, we also need to take the next step and combine existing laboratory and field data with
numerical simulations to quantitatively evaluate the importance of these potential contaminant-release
pathways
                                                 10-1

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This Page Intentionally Blank

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                                               BIBLIOGRAPHY
                  U.S. Geological Studies at a Waste Site in the Mojave Desert near Beatty, Nevada
                                                February 1996

                                                  REPORTS

 Andraski, B J.. 1990. Water movement and trench stability at a tJimiiataH arid burial site for low-level radioactive
        waste near Beatty, Nevada: La Grange Park, HI., American Nuclear Society, Nuclear Waste Isolation in the
        Unsaturated Zone, Las Vegas, Nev., September 1989. Proceedings, p. 166-173.

 Andraski, B.J., 1991, Balloon and core sampling for determining bulk density of alluvial desert soil: Soil Science
        Society of America Journal, v. 55. p. 1188-1190.

 Andraski, B.J., 1991, Soil-water regime at a low-level radioactive waste site, Amargosa Desert, Nevada:
        Characterization of Transport Phenomena in the Vadose Zone, A Workshop Sponsored by Soil Science Society
        of America and American Geophysical Union, Tucson, University of Arizona, April 1991, Proceedings, p. 2-3.

 Andraski. B J., 1992, Water movement through soil at a low-level radioactive-waste site in the Amargosa Desert: U.S.
        Geological Survey Yearbook Fiscal Year 1991. p. 73-75.

 Andraski, B.J., in press. Simulated trench studies near Beatty, Nevada-Initial results and implications, in Stevens.
        P.R.. and Nicholson, T., eds.. Conference on Disposal of Low-Level Radioactive Waste, Reston, Va., May
        1993: U.S. Geological Survey Water-Resources Investigations Report 95-4015.

 Andraski, B.J., 1996, Properties and variability of soil and trench fill at an arid waste-burial site: Soil Science Society
       of America Journal, v. 60, p. 54-66.

 Andraski. B.J.. Fischer, J.M., and Prudic, D.E.. 1991, Beatty, Nevada, in Trask. NJ.. and Stevens, P.R., U.S.
       Geological Survey Research in radioactive waste disposal-fiscal years 1986-1990:  U.S. Geological Survey
       Water-Resources Investigations Report 91-4084, p. 34-40.

 Andraski  B J.. and Prudic, D.E., in press. Soil, plant, and structural consideration for surface barriers in arid
      environments-application of results from studies in the Mojave Desert near Beatty, Nevada: Washington, B.C..
      National Academy Press, Barriers for Long-Term Isolation, Denver, Colo., August 1995. Proceedings.

 Andraski. B.J.. Prudic, D.E., and Nichols, WJD., 1995, Waste burial in arid environments-Application of information
      from a field laboratory in the Mojave Desert, southern Nevada: U.S. Geological Survey Fact Sheet FS-179-95,
      4p
 Bedinger, M S  , 1990, Geohydrologic aspects for siting and design of low-level radioactive-waste disposal: U.S.
       Geological Survey Circular 1034,36 p.

 Brown.  R G, and Nichols. W.D., 1990. Selected meteorological data for an arid climate over bare soil near Beatty,
       Nye County, Nevada, November 1977 through May 1980: U.S. Geological Survey Open-File Report 90-195,
      48 p

Clebsch, Alfred. Jr., 1968, Geology and hydrology of a proposed site for burial of solid radioactive waste southeast of
      Beatty,  Nye County, Nevada, in Morton. RJ., Land burial of solid radioactive wastes-Study of commercial
      operations and facilities: Atomic Energy Commission. National Technical Information Service, Report
      WASH-1143, p. 70-100. Available only from National Technical Information Service, U.S. Department  of
      Commerce, Springfield, VA 22161.

Fischer. J M., and Nichols. W.D.. 1986, Beatty, Nevada, in Dinwidde, G.A., and Trask, NJ., eds.. U.S. Geological
      Survey research in radioactive waste disposal-Fiscal years  1983.1984, and 1985: U.S. Geological Survey
      Water-Resources Investigations Report 87-4009, p. 87-88.
                                                   10-2

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 Fischer, JJM., 1990, Geohydrology of the near-surface onsaturated zone adjacent to the disposal site for low-level
        radioactive waste near Beany, Nevada, in Bedinger. MS- and Stevens, P.R., eds.. Safe disposal of
        radionudides in low-level radioactive waste repository sites—Low-level radioactive-waste disposal workshop,
        U.S. Geological Survey, July  11-16,1987, Big Bear Lake, Calif., Proceedings: U.S. Geological Survey
        Circular 1036. p. 57-61.

 Fischer, JJM., 1992, Sediment properties and water movement through shallow unsaturatf1 alluvium at an arid site for
        disposal of low-level radioactive waste near Beatty. Nye County, Nevada: U.S. Geological Survey Water-
        Resources Investigations Report 92-4032,48 p.

 Fouty. Suzanne, 1989, Chloride ma«.fraiaiiM as a method for determining long-term ground-water recharge rates and
        geomoxphic surface stability in arid and semi-arid regions-Whiskey Flat and Beany, Nevada: Tucson.
        University of Arizona, unpublished M.S. thesis. 130 p.

 Gee, B.W.. Wierenga, PJ.. Andraski, B J., Young, MJi.. Payer, MJ., and Rockbold. MI.- 1994, Variations in water
        balance and recharge potential at three western desert sites: Soil Science Society of America Journal, v. 58. p.
        63-72.

 Morgan. D.S.. and Fischer. JJM.. 1984, Unsaturated-zone instrumentation in coarse alluvial deposits of the Amargosa
        Desert near Beatty. Nevada in Proceedings of Sixth Annual Participants' Information Meeting-
        U.SDepanment of Energy Low-Level Waste Management Program: Available from National Technical
        Information Service, U.S. Department of Commerce. Springfield, VA 22161, CONF-8409115, p. 617-630.

 Nichols, W.D.. 1982. U.S. Geological Survey research in radioactive waste disposal-Fiscal year 1979. in Schneider.
        Robert. Roseboom, E.H.. Jr.. Robertson. J.S., and Stevens. PJL, eds, U.S. Geological Survey Circular 847, p.
        62-63.

 Nichols, WD..1987, Geohydrology of the unsaturated zone at the burial site for low-level radioactive waste near
         Beatty, Nye County, Nevada: U.S. Geological Survey Water-Supply Paper 2312,57p.

 Prudic, DE., 1994, Estimates of percolation rates and ages of water in unsaturated sediments at two Mpjave Desert
       sites, California-Nevada: U.S.  Geological Survey Water-Resources Investigations Report 944160.19 p.

 Prudic, D.E.. in press. Water-vapor movement through unsaturated alluvium in Amargosa Desert near Beatty, Nevada-
       -Current understanding and continuing studies in Conference on Disposal of Low-Level Radioactive Waste,
       Reston. Va.. May 1993: U.S. Geological Survey Water-Resources Investigations Report 95-4015.

 Prudic. DJE., and Dennehy. K.F., 1990, Induced changes in hydrology at low-level and radioactive waste repository
       sites, m Bedinger, M.S., and Stevens, P.R., eds., Safe disposal of radionudides in low-level radioactive waste
       repository sites-low-level radioactive-waste disposal workshop, US. Geological Survey. July 11-16.1987.
       Big Bear Lake, Calif., Proceedings: U.S. Geological Survey Circular 1036. p. 2-4.

 Prudic, D.E., and Striegl, R.G., 1995, Tritium and radioactive carbon (I4C) analyses of gas collected from unsaturated
        sediments next to a low-level radioactive-waste burial site south of Beatty. Nevada. April 1994 and July 1995:
        U.S. Geological Survey Open-File Report 95-471,7 p.

 Stnegl. R.G.. Prudic, DJE.. Duval, J.S., Healy, R.W., Landa. E.R., Pollock, D.W., Thorstenson. D.C. and Weeks. E.P..
        1996, Factors affecting tritium and 14carbon distributions in the unsaturated zone near the low-level
        radioactive-waste burial site south of Bealty, Nevada: U.S. Geological Survey Open-File Report 96-110,16
        P-

Wood. J.L.. and Fischer. J.M., 1991, Selected meteorological data for an arid site near Beatty, Nye County. Nevada.
       calendar year 1986: U.S. Geological Survey Open-File Report 91-189,27 p.

Wood. J.L., and Fischer, J.M.. 1992, Selected meteorological data for an arid site near Beatty. Nye County. Nevada,
       calendar year 1987: U.S. Geological Survey Open-File Report 92-59.27 p.

Wood, J.L., Hill. K J., and Andraski, B.J.. 1992, Selected meteorological data for an arid site near Beany, Nye County,
       Nevada, calendar year 1988: U.S. Geological Survey Open-File Report 92-61, 27 p.
                                                   10-3

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 Wood, JI... and Andraski. B J.. 199Z Selected meteorological data for an arid site near Beany. Nye County. Nevada.
       calendar year 1989: U.S. Geological Survey Open-File Report 92-484,27 p.

 Wood. JJL, and Andraski. B J., 1995, Selected meteorological data for an arid site near Beany, Nye County. Nevada.
      ' calendar years 1990 and 1991: U.S. Geological Survey Open-File Report 94-489.

                                                ABSTRACTS

 Andraski. B J.. 1989. Physical properties of trench backfill at a simulated burial site for low-level radioactive waste
       near Beatty, NV (abs.): 80th Annual Meeting. American Society of Agronomy. Anaheim, Calif.. December
       1988, Agronomy Abstracts, v. 80. p. 178.

 Andraski, B J.. 1990, Soil-water movement at a simulated burial site for low-level radioactive waste near Beatty.
       Nevada-first year results (abs.). in Nevada decision point-Which water course to the future?: Annual
       Conference. Nevada Water Resources Association. Las Vegas, Nev., February 1990. Program Information and
       Abstracts, unpaginated.

 Andraski. B.J.. 1990. Rubber-balloon and drive-core sampling for determining bulk density of an alluvial desert soil
       (abs.): Agronomy Abstracts. American Society of Agronomy, 1990 Annual  Meetings. San Antonio, Texas.
       October 1990. p. 208.

 Andraski. B J.. 1991. Vegetation and land-disturbance effects on recharge potential.  Amargosa Desert. Nevada (abs.):
       Agronomy Abstracts. American Society of Agronomy, 1991 Annual Meetings, Denver. Colo.. October 1991.
       p. 212.

 Andraski. B.J.. 1994. Disturbance effects on soil properties and water balance at a low-level radioactive waste site.
       Amargosa Desert Nevada [abs. soil properties and water balance at a low-level radioactive waste site,
       Amargosa Desert, Nevada [abs.]: 86th Annual Meeting. American Society of Agronomy. Seattle, November
       1994,  Agronomy Abstracts, v. 86, p. 227.

 Beutner.  M.L.. and Andraski. BJ.. 1989. Comparison of standard and simplified hydrometer methods for textural
       analysis of a desen soil near Beatty, Nevada (abs.): 81st Annual Meeting. American Society of Agronomy, Las
       Vegas, Nev., October 1989. Program of Agronomy Abstracts, v. 81. p. 184.

 Fischer, J.M., 1985, Preliminary evaluation of a method for installing thermocouple psychrometers and determination
       of psychrometer calibration changes near Beatty. Nevada: Morgan, D.S.,and Fischer, J.M.. 1984, Unsaturated
       zone instrumentation in coarse alluvial deposits of the Amargosa Desen near Beany, Nevada (abs): Second
       National Symposium and Exposition on Ground-Water Instrumentation, Las Vegas. Nev.. April 1984,
       Conference  Program.

 Morgan. D.C.. and Fischer. J.M., 1984. Unsaturated zone instrumentation in coarse alluvial deposits of the Amargosa
       Desen near Beatty, Nevada (abs.): Second National Symposium and Exposition on Ground-Water
       Instrumentation, Las Vegas. Nev., April 1984, Conference Program.

 Prudic, D.E.. 1994, Effects of temperature at the arid disposal site for low-level radioactive wastes near Beatty, Nevada
       [abs.]:  Geological Society of America, Abstracts with Programs, v. 26. no. 7. p. 143.

 Prudic, D.E.. and Striegl, R.G., 1994. Water and carbon-dioxide movement through unsaturated alluvium near an and
      disposal site for low-level radioactive waste, Beatty, Nevada [abs.]: Eos, American Geophysical Union
      Transactions, v. 75, no.  16. p. 161.

Trask, NJ.. Prudic,  D.E., and Stevens, P.R.. 1994, Hydrologic research programs of the U.S. Geological Survey
      relevant to low-level radioactive waste disposal [abs.]: Eos. America Geophysical Union Transactions, v. 75,
      no 16.  p. 160.
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Waste Burial in Arid  Environments—
     plication of Information  From a Field
    joratory in the Mojave Desert, Southern Nevada
                                                                   u
                                                                   G
                                                                 U.S. Department of the Interior—U.S. Geological Survey
  Accumulation and management of waste is a pressing
problem facing the United States today. Improper disposal of
hazardous wastes poses a threat to public health and environ-
mental quality. As arid sites increasingly are being sought for
disposal of the Nation's radioactive and other hazardous wastes,
concern about the potential effect of contaminants on water re-
sources in the arid western  United States is being raised. In
addition, volumes of locally generated municipal and industrial
wastes are increasing because of rapid population growth and
industrialization of the region.

  The suitability of a waste-burial site or landfill is a function
of the hydrologic processes that control the near-surface water
balance. Precipitation that infiltrates into the surface of a burial
trench and does not return to the atmosphere by evapotrans-
piration from the soil and plants can percolate downward and
come in contact with buried waste. Water that contacts the
waste can enhance the  release of contaminants for subsequent
transport by  liquid water, water vapor, or other gases.

     prevalent assumption is that little or no precipitation will
^.wi'colate to buried wastes at an arid site. Thick unsaturated
zones, which are  common to arid regions, also are thought to
slow water movement  and minimize the risk of waste migration
to the underlying water table. On the basis of these assump-
tions, reliance is commonly placed on the natural system to
isolate contaminants at waste-burial sites in the arid West.

  Few data have been  available to test the validity of assump-
tions about the natural  soil-water flow systems at arid sites, and
even less is known about how the construction of a waste-burial
facility alters the  natural environment of the site. The lack of
data is the result of (1) technical complexity of hydraulic char-
acterization of the dry, stony soils and (2) insufficient field
                   DEATH
                   VALLEY
NEVADA

WASTE
BURIAL
Vs SITE
NsLv r
i^C

I
UTAH



"J

MOJAVE
DESERT
                                    ARIZONA
          Figure 1. Location of waste-burial site. Death
          Valley, and Mojave Desert of southwestern United
          States.
                                                              Figure 2. Undisturbed, vegetated area near waste-burial site,
                                                              October 1991 (A); low-level radioactive waste burial trench (8); and
                                                              nonvegetated surface of backfilled waste-burial trench with identifying
                                                              monument, June 1988 (C).
                         studies that account for the extreme temporal and spatial
                         variations in precipitation, vegetation, and soils in arid regions.
                         In 1976, the U.S. Geological Survey (USGS) began a long-
                         term study at a waste-burial site in the Mojave Desert near
                         Beatty, Nov., to collect the necessary data and evaluate un-
                         tested  assumptions. This fact sheet summarizes the findings of
                         investigations at the site and discusses how this information is
                         important to issues of waste burial in an arid environment.

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Mojave Desert Waste-Burial Site

  The waste-burial  silc. 30 miles east of Death Valley National
Park, is in one of the most arid parts of the United Stales
(fig. I). Precipitation in the area averages about 4 inches per
year. The water table is about 360 feet below land surface.
Vegetation in the area is sparse (fig. 2/4). Burial trenches at the
site have been used  for disposal of low-level radioactive waste
(1962-92) and hazardous-chemical waste (1970-present).
Burial-trench construction includes excavation of native soil,
emplacement of waste, and backfilling with previously stock-
piled soil (fig. 2,6). The surfaces of completed burial trenches
and perimeter areas are kept free of vegetation (fig. 1C).
Regulations governing burial of low-level radioactive waste do
not require that trenches be lined with impervious materials.
Prior to 1988, linings were not required for chemical-waste
trenches. As a result, only the most recent chemical-waste
trench at the site is lined.

Field Laboratory Established

  Recognizing the need for long-term data collection, the
USGS established a study area adjacent to the waste-burial site
through agreements with the Bureau of Land Management and
the State of Nevada. This 40-acre  area serves as a field labora-
tory for long-term data collection  and the study of hydrologic
processes under natural-site and waste-burial conditions.

Lessons  Learned to Date

  Early (1962) evaluation of the general hydrologic conditions
at and near the waste-burial  site suggested that low average
annual precipitation and high average annual evapotranspira-
tion would prevent  water from percolating downward more
than 1  or 2 feel below land surface. This assumption, however,
did not consider the extreme annual and  seasonal variations in
a desert climate. During 1985-92, annual precipitation mea-
sured at the USGS study site ranged from 0.55 to 6.51 inches
and monthly  precipitation ranged  from 0 to 2.34 inches.
Monthly average temperature ranged from 38 to 92 degrees
Fahrenheit.  Most of the precipitation falls during the cool
              TOTAL ANNUAL PRECIPITATION, IN INCHES
             297   5.37    4,11   0.55   1.28   4.08
       1985
             1986
                         1988   1989
                           YEAH
                                    1990
                                                1 '¥>','
winter months when evaporative demands are low (fig. 3).
Initial water-balance modeling by the USGS demonstrated (
that, under particular climate and soil-moisture conditions, tV
potential for deep percolation does exist, in  spite of high
annual e\apor;tlive demands (Nichols, 19X7).

  l-ielcl  investigations to define the rates and directions of
water movement through the deep unsaturated zone beneath an
undisturbed, vegetated area began in the early 1980's and con-
tinue today. A study of chloride concentrations in the unsatur-
ated zone indicates that deep percolation of water was limited
to the upper 30 feet during the past 16,000 to 33,000 years
(Prudic, 1994a). To monitor present-day flow processes, an
instrument shaft was installed that allows access for operation
of electronic devices to a depth of 45 feet (fig. 4; Fischer,
1992). Additional instrumentation has been installed to study
flow processes throughout the unsaturated zone (Prudic, in
press). Meteorological data are collected by an automated
weather station (Wood and Andraski, 1995).

  Water movement in the unsaturated zone  is complex.
Several variables—water content, water potential, humidity,
and temperature—must be monitored to define rates and
Figure 3. Annual and monthly total precipitation and monthly average
temperature measured at U.S. Geological Survey field laboratory
during 1985-92.
      Figure 4.  Installation of vertical shaft used for soil-moisture
      monitoring in upper 45 feet of unsaturated zone beneath
      undisturbed, vegetated area. Photograph by David S.
      Morgan. U.S. Geological Survey, August 1983.

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dircclions of water movement. Winer content indicates how
    h water is held in the soil. Water potential indicates how
    iy the water is held by the soil matrix. Water moves
unough soil in liquid and vapor form, and the Iwo forms can
move simultaneously as a consequence of water-potential,
humidity, and temperature gradients in  the soil.

  Ongoing investigations at the undisturbed, vegetated site
indicate that the natural soil-plant-water system effectively
limits the potential for deep percolation.  During more than
5 years of monitoring, downward percolation was  limited
to the upper 3 feet of soil (Fischer, 1992; Andraski, 1994).
Between the depths of 40 and 160 feel, water movement, as
liquid and as vapor, is consistently upward.  Preliminary evi-
dence indicates that upward flow of water vapor through the
thick unsaturated zone may potentially  serve as a contaminant-
release pathway (Prudic, 1994b; Prudic and Striegl, 1994).

  Little is known about how, or to what degree, features of
the  natural system may be altered  by  installation of a disposal
facility. Investigations to determine the effects of disturbance
on soil properties and the long-term soil-water balance began
in 1987.  Two nonvegetated test trenches  and an area of bare
soil are monitored (fig. 5; Andraski, 1990).  The effects of
disturbance are evaluated in terms of observed differences
between data collected at the undisturbed, vegetated site and
data collected at the disturbed sites.
                              show that this lower limit is not adequate for nonirrigated,
                              desert soils and plants, nor is it appropriate for the extremely
                              dry backfill material produced by trench construction. Thus.
                              characterization of hydraulic properties at the site has been
                              extended u> include data measured over a soil-moisture range
                              that is representative of seldom-studied arid conditions
                              (Andraski. in press).

                                 Backfilling with very dry material will, at least initially,
                              increase the importance of vapor flow as a potential transport
                              mechanism in the trench fill (Andraski, in press). These initial
                              dry conditions can change substantially, however, in response
                              to subsequent precipitation and a lack of vegetation. On an
                              annual basis, no water accumulates in the vegetated soil
                              because water is removed by the plants (fig. 6). In contrast,
                              even  under conditions of extreme aridity, water accumulates in
                              the nonvegetated soil and test trenches. Water that has accumu-
                              lated at the three disturbed sites is continuing to percolate
                              downward (Andraski, 1994).  Thus, the construction of waste-
                              burial trenches and removal of native vegetation markedly alters
                              the natural site environment and may increase the potential for
                              release of contaminants.(Gee and others,  1994).  Surprisingly.
                              such  changes typically are not considered  in the evaluation of a
                              proposed waste site and may not be considered in management
                              of existing sites.

                              Well-informed Decisions Needed
     ^curate characterization of hydraulic properties is critical
    .Iculations of water movement through soil. Characteriza-
tion data normally are measured to a minimum water-potential
value referred to as the permanent wilting point for crops.
Below this value, water is held so tightly by the soil matrix that
a crop plant cannot extract the water and will wilt and die. Data
collected by the USGS at the Mojave Desert site, however,
                                 Regulations governing the licensing of solid-waste landfills
                               and hazardous-waste sites require an assessment of the potential
                               for deep percolation of water through buried waste before
                               disposal operations can begin.  Numerical models commonly
                               are relied on for this assessment. For a proposed low-level
                               radioactive waste site, 1 year of preoperational monitoring of
                               site conditions also is required. Thus, data used in numerical
            UNDISTURBED SOIL;
           VEGETATION REMOVED
   NONVEGETATED
   TEST TRENCH 2
(drums randomly placed)
                                    15 FEET
                        EXPLANATION
      (JJJ)  Drum filled with soil
            (simulated waste)

           Subsidence plate and rod

       X   Surface subsidence/
            erosion pin
 Neutron access tube lor
  monitoring soil-water
  content

 Thermocouple psychrometer
  lor monitoring soil-water
  potential and temperature
60
                                                                 -  40
                                                                 O  30
                                                                 <  20
                                                                 3
                                                                 z
                                                                 uj
                                                                 O  10
                                                                 H)  0
                                                                                HM  Undisturbed, vegetated soil
                                                                                ••  Undisturbed soil, vegetation removed
                                                                                HH  Nonvegetated tesl trench 1
                                                                                I   I  Nonvegetated tesl trench 2
  Nov 21, 1988  Sept 21, 1989  Sepl. 18, 1990  Dec. 18, 1991   Sept 24, 1992
  _ jre 5. Schematic diagram of instrumentation used to determine
effects of vegetation removal and trench construction on water
movement through unsaturated zone. Subsidence and erosion are
monitored to determine changes in structural integrity of test trenches.
In second test trench (not shown), soil-filled drums are stacked in
orderly fashion.
                               Figure 6.  Cumulative changes in quantity of water being held in
                               uppermost 4 feet at four monitoring sites:  undisturbed, vegetated soil:
                               undisturbed soil where native vegetation was removed; and two
                               nonvegetated test trenches. Values are based on measurements
                               during first 5 years following vegetation removal and trench
                               construction at disturbed study site in October 1987.

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analysis ol a proposed wastc-bunal MIC may he based solely on
hydraulic mlormation available in the litcialuic. or the data may
include some sitc-.spccillc inlbrm.ilion. which typically is limn-
ed lo naliual conditions and a shoii period ol time This ap-
proach is of pailicu'iai concern for waste sites in arid regions
because, compared with the amount of infoimadon available
for more humid sites, (he amount ol hydrauhc-pioperty data
and long-term Held data for arid sites is negligible. In addition,
although significant advances have been made in the develop-
ment of soil-water flow models, the lack of long-term field data
has resulted in these models remaining largely untested as to
how well they lepresent flow systems at and sites.

Long-Term Benchmark Information

  Ongoing work by the USGS at the Mojave Desert field
laboratory continues to provide long-term, quantitative "bench-
mark" information about the hydraulic characteristics, water
movement, and the potential for release of contaminants
through the unsaturated zone in an and environment. Monitor-
ing methods developed and tested at the Mojave Desert site
have helped others in their study and evaluation of waste-
isolation processes at the Nevada Test Site, and at proposed
waste sites in Texas and California The U S. Nuclear Regula-
tory Commission and Pacific Northwest Laboratory have cho-
sen the  Mojave Desert waste site for use m numerical modeling
of infiltration because it is representative of burial operations in
an arid environment. Data collected at the  USGS field labora-
tory are being provided for this effort The National Academy of
Sciences also has used information from the site in the evalua-
tion of issues related to waste disposal m an and environment.

  Because of the potentially harmful effect of improper waste
disposal on water resources in the and West, comprehensive
laboratory and field studies are critical to identifying likely
contaminant-release pathways and the potential for waste
migration at arid sites However, the quandary for those charged
with assessment of the suitability of potential disposal sites is
that site characterization and evaluation must be accomplished
in a relatively short period of time—only I to 2 years.

  Data  collection at the Mojave Desert field laboratory
provides the needed long-term benchmark against which short-
term data from proposed arid sites can be compared. The data
base and monitoring facilities developed at the field laboratory
also provide an excellent foundation upon  which to build col-
laborative effoits with universities and local, State, and other
Federal agencies to further the study and understanding of
hydrologic processes in an arid environment.

—BJ Andraski. David E Piudic, and William D. Nichols

References Cited

Andiaski, B J . 1990, Water movement and trench stability at a
  simulated arid burial site for low-level radioactive waste near
  Beatty, Nevada LaGrangc Paik. Ill . American Nuclear
  Society, Nuclear Waste Isolation in the Unsaturated Zone,
  Las Vegas. Ncv . September 1989. Proceedings, p  166-173
	1994. Disturbance cllccts on soil properties and water
  balance at a low-level uidioaclivc waste site. Amargosa
  Descit, Nevada |abs |  American Society of Agronomy,
  Agionomy Abstiacls, v 86. p 227

	in picss. Propcitics and variability of soil and liench fill ill
  an and waste-bin i.il site' Soil Science Society of Amenta
  Journal

Fischei, J.M . 1992, Sediment properties and water movement
  through shallow unsaturated alluvium at an and site for
  disposal of low-level radioactive waste near Bealty, Nyc
  County, Nevada U.S Geological Survey Water-Resources
  Investigations Report 92-4032, 48 p

Gee, G W, Wiercnga, Pi , Andraski., B.J., Young, M H . Payer.
  M J., and Rockhold, M.L , 1994, Variations in water balance
  and recharge potential at three western desert sites  Soil
  Science Society of America Journal, v. 58, no  1, p  63-72

Nichols, W D , 1987, Geohydrology of the unsaturated zone at
  Ihe burial site for low-level radioactive waste near Beatty,
  Nye County, Nevada U S Geological Survey Water-Supply
  Paper 2312, 57 p.

Prudic, D.E , 1994a, Estimates of percolation rates and ages of
  water in unsaturated sediments at two Mojave Deseil sites,
  California-Nevada U S  Geological Survey Water-Resources
  Investigations Report 94-4160, 19 p.

	1994b, Effects of temperature on water movement at the
  arid disposal site for low-level radioactive wastes near Beatty
  Nevada [abs.]:  Geological Society of America, Abstracts with
  Programs, v. 26, no. 7, p. 391

     m press, Water-vapor movement through unsaturated
  alluvium m Amargosa Desert near Beatty, Nevada—Cunent
  understanding and continuing studies, in Stevens, P.R , and
  Nicholson, T., eds., Conference on Disposal of Low-Level
  Radioactive Waste, Reston, Va., May 1993: U.S. Geological
  Survey Water-Resources Investigations Report 95-4015

Prudic, D E , and Stnegl, R.G , 1994, Water and carbon dioxide
  movement through unsaturated alluvium near an arid disposal
  site for low-level radioactive waste, Beatty, Nevada [abs ]
  Eos, American Geophysical Union Transactions, v 75.
  no 16, p 161.

Wood, J.L., and Andraski. B J.,  1995, Selected meteorological
  data for an arid site near Beatty, Nye County, Nevada.
  calendar years 1990 and 1991  US. Geological Survey Open-
  File Report 94-489, 49 p

For more information about the Mojave Desert
studies, contact:

Brian J  Andiaski
U S. Geological Survey
333 W Nye Lane
Cai son City, NV 89706
(702)887-7600,ext 7636
andraski@usgs.gov
                                                              August 1995
                                                                                                        Fact Sheet FS-179-95

-------
11

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ACCELERATED SITE CHARACTERIZATION

               (A CASE STUDY)

                        by

             Richard McJunkin, CEG, Chief
      Geologic Services Unit, Site Mitigation Program
         Department of Toxic Substances Control
             10151 Croydon Way - Suite 1
             Sacramento, CA 95827-2106
                    916-255-3672
                 FAX: 916-255-3697
                       and


          RCRA Corrective Action Conference
          U.S. Environmental Protection Agency

                 March 26-28, 1996
                          11-1

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This Page Intentionally Blank

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                               ABSTRACT


The "iterative" process being used to characterize volatile contaminants at many
hazardous waste release sites is taking years to complete and is very costly for both
industry and government A change from using this commonly applied process is
needed.  Investigations should address the entire extent of contamination using
"rapid field characterization" and the least number of phases as possible; usually,
no more than two or three phases of field investigation should be necessary. This
approach should utilize an on-site laboratory to collect real-time data from soil gas,
soil, or ground water samples. Rapid field characterization provides for collecting
accurate and  precise  contaminant data that define pathways.  If collected early
during  projects, these data should reduce the overall site cleanup time by  ninety
percent and overall site cleanup costs by one-half.  Rapid field characterization
techniques should be  used by both RCRA Corrective Action and Site Mitigation
CERCLA investigations.
                                      11-2

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12

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       IMENTAL TECHlJBlOGY FACT SHEET
                                  Ernest Orlando Lawrence Berkeley National Laboratory
                                                      I Cyclotron Rd. • Berkeley. CA 94720
stable Isotope  Methods
_.j  Hydrogeologic Modeling  and
Monitoring  of  Contaminated  Sites
              A method for assessing the sources and  movement of
              waters and pollution by measuring stable isotopic data
 A methodology for
   ^developing rational
   nitoring and
remediation strategies
Statement of Problem
  Analysis of the oxygen isotope(,l8O/16O) and
hydrogen isotope (D/H) ratios of waters is a popular
tool in hydrogeologic assessment. Applications of the
technique, however, have been limited to studies of
uncontaminated watersheds at much larger scales than
are required for meaningful environmental character-
ization. Moreover, because environmental site
characterization activities typically incorporate only
those analytical methods required under environmen-
tal law, characterization efforts at contaminated sites
               normally lack stable isotopic
••^^^••^•••M  data.
                 Stable isotopic techniques
               enable a comprehensive
               understanding of the
               hydrogeology at scales appropri-
               ate for the rational development
               of monitoring and remediation
strategies. Isotopic data provide a baseline for the
assessment of water and pollutant sources and move-
ments, and for the implementation of strategies for
environmental protection, determination of ecological
impacts, and assessments of environmental risk.

Laboratory Capabilities
  Our work has focused on determining the spatial
and temporal isotopic variations of water at Berkeley
Lab and other DOE sites. For example, we are analyz-
                                                   Fault
ing the components (biotic and abiotic) of the water
cycle within Berkeley Lab's Strawberry Canyon area to
establish flow rates and directions. The isotopic
contrasts between rainfall, groundwater, and municipal
water at Berkeley Lab have been used to develop mass
balance equations to calculate stream flow, and to
demonstrate that groundwater is a major component
of runoff and stream flow—even in the rainy season.
  Groundwater isotopic data also have helped
identify areas of contrasting infiltration velocities (and
thus differing risks for contamination) and areas where
municipal water leaks have occurred. Vadose zone
isotopic data highlight the importance of fog water
inputs, processes such as plant water uptake and
transpiration, and organic matter decomposition in
determining water budgets and water isotopic charac-
teristics in the unsaturated zone.
  We also use isotopic ratios in plant biomass and
plant fluids to investigate variations in plant water
sources in space and time. This information will help
in planning vegetation cover for regulating water
infiltration and transpiration rates, for immobilizing
pollutants, and for minimizing exposures to humans
and organisms in the food chain.
                                                                Precipitation
                                                                              Stream
                                                                              inflow
               Contact
                 Leticia B. Menchaca
                 E-mail: iDmenchaca»lbl.gov
                 Telephone: 510/486-5923
                 Fax: 510/486-4 7 76
                 Mail Stop: 758-101
                                                Water
                                                table
                                                   Stream outflow

                                      Hydrogeologic modeling requires oxygen isotopes.
                                                12-1

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13

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                  SOIL VOC METHANOL PRESERVATION

                         Kurt Zeppetello
           Arizona Department of Environmental Quality
                        KJZ6EV.STATE.AZ.US
                          (602)-207-4410
                       (602)-207-4236  (fax)

                            Abstract

     This paper presents different field sampling techniques that
the Arizona Department of Environmental Quality  (ADEQ) recommends
emphasizing the methanol  preservation method.   This procedure is
used when  samples will not be  extracted at the mobile or fixed
laboratory within 2 hours.  Using  pre-weighed  vials (40 or 60 ml
vials) , add 15 gms of soil to the 40 ml vial or  25 gms of soil to
60 ml vial.   After  adding the sample to  the vial,  quickly add a
pre-measured amount of methanol to the  vial and close it.  Other
methods for adding methanol may  be  acceptable.  This method is the
most recorjnended method for when samples cannot  be extracted by a
laborator/ withir 2  hours.  Results from case studies performed in
Arizona indicate that VOC concentrations may be significantly under
reported using conventional sampling techniques.

                           Introduction

     Volatile organic  compounds VOCs, halogenated and aromatic, are
widely used throughout society  and as  such are commonly the most
prevalent contaminants at  remediation sites.  Since site assessment
decisions and remedial actions  are based on sampling results for
these compounds, it is essential that accurate data is collected.
Frequently, laboratory results show no detectable volatile organic
compounds  (VOCs)  in soil  samples collected from sites  that have
significant ground water contamination (Koroghlanian et al., 1995).
This indicates that there  may be a problem with the conventional
soil collection procedure  of containerizing the  sample in a Teflon
capped glass jar or  sealing it in a brass sleeve, refrigerating it
at 4° C, and then transporting it to a laboratory.

     Although there other  explanations  for not detecting VOCs in
soils where the ground water is  contaminated, such as collecting a
soil sample which composed of a non-sorbing material like sand or
not collecting the sample  in the correct zone, field research from
the last six  years  has suggested  that  the procedures associated
with conventional soil collection  may  lead to substantial errors
when sampling for VOCs.  Preliminary studies on  the problems with
conventional  soil sampling has been  conducted by  Siegrist and
Jensen  (1990), Jackson  et al.  (1991),  Lewis et  al.  (1991), King
(1993),  and Hewitt  (1993).   The  ADEQ has  been  involved with
alterative VOC sampling since discovering soil vapor results were
more indicative of VOC contamination than  soil results (Heywood et
al., 1992).
                                 13-1

-------
     Conventional methods for soil sampling are subject to errors
which  can under  report VOC  concentrations  by  as much  as 100%
(Koroghlanian   et   al.,  1995).     These  errors  result  from:
volatilization  of  VOCs during removal from the  soil profile and
transfer  of the  soil  from  the  sampling  device  to  the sample
container; volatilization of VOCs from the sample container during
pre-analytical  holding;  and volatization  of  VOCs  during  the
subsampling by  the laboratory prior to analysis (Siegrist, 1992).
Of these, sample transfer is the most crucial step in collection
process (Koroghlanian et al., 1995).

                       AOEQ Recommendations

     In August 1995,  the Draft ADEQ Quality Assurance Project Plan
(QAPP) was submitted to the Environmental Protection Agency  (EPA).
The  QAPP contains ADEQ's  recommended  methods  for VOC sample
collection,  handling, and storage.  The methods are modifications
of those  described EPA  document  by  Lewis et  al.  (1991), American
Society   for  Testing  and  Materials  (ASTM,  1991),  and  other
publications.
1.   Collect samples in brass, stainless Steel, Teflon or acetate
     sleeves:

     a.   Submit to  a  mobile lab or  a fixed  lab  for extraction
          within  2  hours.    Completely  filled  sleeves  should
          immediately sealed by:  1)  covering  ends with a Teflon
          patch;  2)  covering  the  Teflon  patch  with foil;  3)
          covering patches with  tight  fitting plastic  caps; and 4)
          sealing  the  caps  by wrapping  custody seals or  a non-
          contaminating tape  around the sleeve,  overlapping the
          lower edge of the cap.

     or immediately upon collection;

     b.   Use a sub-coring device to  obtain and transfer samples
          to a vial.  The sample can then be  processed  in four ways
          (in order of preference):  1) immerse  sample  in methanol;
          2) use a sub-coring sampler that can be demonstrated to
          prevent  loss of VOCs for  an adequate period of time to
          get  to  a  laboratory  (for  example  EnCore  samplers  or
          equivalent proven  to  hold VOCs for  48 hours) ;  3)  use
          specially designed  purge-and-trap  adaptor cap for direct
          connection to a  laboratory equipment;  or 4)  other proven
          methods approved by the appropriate AOEQ program.

2.   For  soils  collected  from  split-spoon  (or  similar  devices)
     used without liners,  or  any drilling method which produces a
     soil core,  samples should  be  obtained by either pushing a
     sleeve into the  core  immediately  after  the  core is brought to
                                 13-2

-------
     the surface, or sub-coring and processing the sample using one
     of the four methods listed above.

3.   Collect  soil  vapor  samples  when  the  cobble   and  gravel
     content of soils result in low, or no sample recovery by any
     of the above methods.

After sample collection the sample should be immediately labeled,
placed in a cooler  on ice.   "Blue ice" should not be used unless
required  for  shipping  purposes.    Field  measurements and the
lithologic description should be  conducted  with the remainder of
the recovered sample. Figure 1 shows a diagrammatic sketch of the
procedure.

                      Methanol Preservation

The methanol-immersion  procedure calls  for the  transfer  of the
sample into a  glass jar containing a  known volume of  laboratory
grade methanol  (ideally,  1:1, weight-to-volume ratio  of soil to
methanol).  Currently,  ADEQ uses the methanol-immersion procedure
described  in  the  1995  draft  Environmental  Laboratory Advisory
Committee (ELAC) technical guidance document.  The ELAC appointed
a technical sub-committee made up of representatives from Arizona
laboratories to develop  a  suggested  guidance document  for the
procedure.

Highlights from suggested soil sampling guidance for methanol  field
preservation is as follows;

•    Soil samples should be collected in either a 40 ml vial or a
     60 ml vial.  Ideally,  15 gms  of soil  are needed for the  40 ml
     vial and 25 gms of  soil are needed for the 60 ml vial.

•    If the amount soil  added to the vial is less than  10 or more
     than 20 gms for the 40 ml vial, or less than 20 or more than
     35  gms  for  the 60 ml  vial,  then the  samples  may  not be
     analyzed by the laboratory.

Weight Estimation in tbe Field

60 ml vial:
a.   Measure a  volume  of  soil  equivalent  to  15  - 20 mis with
     a soil syringe, non-coring  type  sampler,  or other sampling
     method that is appropriate.

b.   Add 15  -  20 mis of  liquid  (equivalent to soil)  in  a test
     vial and  put a mark on a  vial.   Fill the  sample vials to
     approximately the  same level.

40 ml vial:
a.   Same as for the 60  ml vial except measure between  7-11 mis
     of soil.
                                 13-3

-------
b.   Same as for the 60 ml vial except measure between 7-11 mis
     of liquid.

Both:
c.   Measure the soils at the site using  a  pocket scale to train
     the eye and estimate the amount of soil to add.

Addition of Methanol

a.   Using   pre-measured  vials   (20   mis)   provided  by   the
     laboratory, quickly open the soil vial and pour the methanol
     in the sample vial immediately and close it.

b.   Using a syringe, transfer methanol from a pre-measured septa
     vial provided by the laboratory to the sample vial.  To avoid
     cross contamination, a clean syringe will be needed for each
     new vial.

c.   Using  a  Teflon  re-pipetor  that  attaches  to  a bottle  of
     methanol and delivers 20 mis, quickly open the soil vial and
     depress the pump to deliver the methanol.

Methanol preservation must be performed within 2 hours of sample
collection.    Samples  should  be returned  to  an  iced  cooler
immediately after preservation .  A reference mark should be placed
on the vial  showing  the top of the methanol  to  indicate that no
methanol has leaked.  Sample labels should be placed  on ziploc bags
and not sample vials.

Loss of Methanol Due to Evaporation

     Concern has been expressed that the high temperatures common
to Arizona may  cause  significant  methanol  losses during the time
the jar is opened to  add the soil sample.   Significant losses of
methanol would tend to  over-estimate  the amount  of VOC  in the
sample.  In order  to explore  the magnitude of  the  loss,  ADEQ
performed an experiment using wide and narrow mouth jars containing
methanol at approximately 4°C and  room temperature.  The jars were
opened and placed in the shade and periodically weighed.  The air
temperature ranged  from 107 -  109°F  during the  experiment, the
humidity ranged from 23  - 25% and  a light wind was present most of
the time.

     The  results of  the  experiment  (figure  2)   indicate  that
methanol losses are not significant  during the  time reasonably
needed to add a soil sample to the jar  (Koroghlanian  et al., 1995).

Sample Preparation at tbe Laboratory

1.   The  sample  vials  must  be  pre-weighed  by the  laboratory
     (label vials before  weighing) .   A separate vial containing
                                 13-4

-------
     either 10 or 20 mis of methanol is included for each sample at
     least one extra for the methanol blank.

2.   After samples are received by  the laboratory, the vials are
     weighed to determine the weight of soil added.

3.   Add more  methanol  to the vials  in order to  maintain a 1:1
     ratio of grams of soil to milliliters of methanol.

4.   Laboratories  should   extract  the   VOCs  from   soils  by
     sonication  in a  bath,  vortex  mixing,  shaking,   or other
     approved method.

                          case Studies

1.   Table  1:     Field  methanol  preservation  vs.  conventional
     sampling methods.

2.   Table 2 and 3:  Field methanol preservation vs. sealed metal
     sampler.

                           Conclusions

     Several laboratory and field investigations have documenting
voc losses inherent with conventional soil sampling methods since
1990.  Alternative methods to conventional VOC sample collection
methods have been incorporated into the 1995 ADEQ QAPP.  The method
described in the QAPP  represents a combination of  EPA and ASTM
publications along with current articles from scientific journals.

     Preparation is necessary prior to sampling.   If samples are
not going to be extracted at a fixed or mobile laboratory within 2
hours,   then  conventional  field   VOC sampling  is  no  longer
recommended in Arizona.   The methanol preservation method
represents ADEQ's  most  recommended alternative  for VOC sampling
when a  mobile lab is not used.  Additional case studies are needed
in order  to add to the  validity of  this method  and  refine the
technique.
                                13-5

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                         FIGURES
  Soil Gas
       Methanol
  Mobile Ub
            Sleeves
            Split Spoons and Coring Devices
                   Sealed Subcoring      Purge and Trap
                      Samplers
             Fixed Lab
                                Adapter Cap
Figure 1: ADEQ's Recommended VOC Soil  Collection
and Handling Methods

(from Koroghlanian  et al.,  1995)
     6-
   •=•5-
   -24 H
     1-
JvTypt and
Pro-experiment Storag* Temperature
— wkj» mouth, room tampwzturv
+• narrow mouth, room t*mp«catura
j* narrow mouth. 4*C
 wtd« mouth. 4-c
       0 2 4 • • 101214iaH2D22a42eaa032943e4«515S«1«7iriM«1iaO
                         Time (minutes)
Figure 2: Methanol Weight Loss Over Time
(from Koroghlanian  et  al.,  1995)
                             13-6

-------
                          TABLES
Table 1
                 1,000
              200
             <50
                          <100
      B
<2,500
1,300
13,000
NC
<100
                  75
               48
              270
              <50
            <100
                <2.500
               23
             310
              <50
            <100
                  68
              0.21
             <50
              <50
            <100
 Field Blank
  NC
 NC
 <50
NC
 NC
NC = No sample collected
PCE Results for a Soil Investigation at a Dry Clear in Phoenix
(Modified from Koroghlanian et al., 1995}
            Table 2
            NC = No sample collected
            PCE Results for a Soil Investigation at a Dry Cleaner
            in Flagstaff (Modified from Koroghlanian etal., 1995)
            Table 3
            BH-10
             360
             60
            PCE Results for a Soil Investigation at an AFB in Phoenix
                                    13-7

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                           References

American  Society  of  Testing  and  Materials.    1991.    Standard
Practice for Sampling Waste and Soils for Volatile Organics  (ASTM
D 4547).   In 1992 Annual Book of ASTM  Standards, Volume 11.04: 108-
11.

Arizona Environmental Laboratory Advisory Committee.  1995.  Draft
Suggested soil sampling guidance for methanol field preservation.

Hewitt,   A.D.    1993.    Review  of  current  and  Potential  Future
Sampling  Practices  for Volatile Organic  Compounds in  Soil.   In
Proceedings,  National Symposium on Measuring and  Interpreting VOCs
in Soils: State of the Art and Research Needs.  Las Vegas, Nevada,
12-14 January.

Heywood J., Bellot M.,  Fulton M., and Koroghlanian G.  1992. Use of
Soil Gas in the CERCLA Site Assessment Program at  Selected Sites in
Arizona.  In  Arizona Water 2000  - Proceedings  of  the Commission on
the Environment and Arizona Hydrological Society.  Sedona, Arizona.
10-11 September.

Jackson J.,  Thomey  N.,  and  Dietlein L.F.  1991.   Degradation of
Hydrocarbons in Soil  Samples Analyzed  within Accepted Analytical
Holding  Times.   In Proceedings,  Fifth  National  Outdoor  Action
Conference on  Aquifer  Restoration,  Groundwater Monitoring,  and
Geophysical  Methods.  Ground Water Management, no. 5: 567-576.  Las
Vegas,  Nevada,  13-16  May.    Dublin, Ohio:  National Water  Well
Association.

King  P.H.    1993.     Evaluation  of Sample  Holding  Times  and
Preservation  Methods  for  Gasoline  in  Fine-Grained Sand.    In
Proceedings,  National Symposium on Measuring and  Interpreting VOCs
in Soils: State of the Art and Research Needs.  Las Vegas, Nevada,
12-14 January.

Koroghlanian G. , Fatherly N.D.,  Padilla M., and Ruddiman  W.  1995.
ADEQ's Recommended Methods to Determine Volatile Organic Compound
Content  of   Soils:   An  Update.    Proceedings  in  the  Arizona
Hydrological Society Eighth Annual Symposium.   Tucson, Arizona, 14-
15 September.

Lewis T.E.,  Crockett  A.B.,  Siegrist R.L., and Zarrabi  K.   1991.
Soil Sampling for Volatile Organic  Compounds.  EPA/590/4-91/001.
Washington,  D.C.: U.S.  EPA,  Office  of Solid  Waste and   Emergency
Response, Technology Innovation Office.

Siegrist  R.L.  and  Jennsen P.D.   1990.   Evaluation  of Sampling
Method  Effects  on   Volatile  Organic  Compound  Measurements  in
Contaminated Soils.   Environmental Science and Technology 24, no.
9: 1387-1392.
                                 13-8

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14

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Bacterial Degradation of  Chlorinated Solvents
Ned Black,  Ph.D.
United States Environmental  Protection Agency
Hazardous Waste Management Division
I.    Background information
     a.   PCE and TCE degradation products:  TCA,  the DCEs,  VC,
     ethene,  ethane,  organic acids
     b.   In situ vs  ex situ activity
     c.   Intrinsic vs amended remediation
                                                      oJ^r
II.   Microbiology
     a.    In general
     b.    Cometabolism
     c.    Aerobic vs  anaerobic  growth

III.  Aerobic bacterial  dechlorination  of  chlorinated solvents
     a.    Expected rates  and  degradation  products
     b.    Methods to  augment  intrinsic activity

IV.   Anaerobic bacterial  dechlorination of chlorinated solvents
     a.    Potential rates and degradation products
     b.    Methods to  augment  intrinsic activity
V.
     Conclusions
                                  14-1

-------
A summary of mechanisms of bacterial degradation of TCE and PCE.
 (With an emphasis on work done in the Dept. of Civil Engineering
at Stanford University.)

Natural attenuation of chlorinated solvents (e.g., PCE, TCE and
carbon tetrachloride) by microbial action can take place both
aerobically and anaerobically.  The bacteria which are capable of
dechlorination can be found in all habitats, including deep
aquifers.  However, the conditions necessary to allow the
bacteria to degrade chlorinated solvents at a particular site may
not exist.

Aerobic mechanisms

The aerobic (oxygen-utilizing) mechanisms involve single enzymes
 (and so single bacterial strains)  for the entire dechlorination.
TCE is completely dechlorinated via cometabolism by oxygenase
enzymes intended to act on such growth substrates as ammonia,
propane, isoprene, toluene,  phenol, and methane.  Due to the
specific enzymatic mechanism,  vinyl chloride does not accumulate
and is actively dechlorinated by these organisms.  Fully
chlorinated compounds, such as PCE and carbon tetrachloride are
NOT dechlorinated by these enzymes.  Thus, in a field situation,
PCE will not be biodegraded when oxygen is present.

Most of the early lab and field work concentrated on
methanotrophic transformation of TCE.  (Methanotrophs are
bacteria which eat methane.)   Unfortunately, methanotrophs
produce two different forms of methane oxygenase.  When copper is
present, asxis the case in almost all groundwater environments,
the methane'oxygenase with the lower capacity to transform TCE is
produced.  Groundwater field experiments conducted at the Moffett
Field Station by Stanford University showed only 20-30% TCE
removal.  In addition, methanotrophs require large amounts of
oxygen to grow or degrade chlorinated compounds.

Many researchers have also studied cometabolism by oxidase
enzymes for aromatic compounds (e.g., toluene and phenol) both in
the lab and at groundwater field sites.  Again, TCE and other
partially chlorinated solvents are transformed, but PCE is not.
Vinyl chloride does not accumulate.  The organisms are able to
grow and cometabolize TCE using less oxygen than methanotrophs,
so TCE removal is higher.  Stanford University researchers have
induced TCE transformation at  the Moffett Field Station by
injecting phenol into the groundwater.

For methanotrophs, trans-DCE is dechlorinated faster than cis-
DCE,  and 1,1'-DCE is toxic.   For the bacteria which consume
aromatics,  cis-DCE is dechlorinated more readily than trans-DCE.

Most of the aerobic mechanisms in groundwater require addition of
some substrates (nutrients) ,  so they should be described as in
situ bioremediation, not natural attenuation.
                                   14-2

-------
TCE,  PCE and carbon tetrachloride are dechlorinated by anaerobic
cometabolism (where no oxygen is present).   This is also referred
to as reductive dechlorination.   Largely because anaerobes are
harder to culture,  there is less detail known about the mechanism
for this activity.   It is likely that consortia (i.e., two or
more bacterial  strains working together)  are responsible for this
activity.  Vinyl chloride is produced and does accumulate in some
lab and field experiments.   However,  in many field situations,
transformation to ethene, ethane, and methane is complete.  This
activity occurs with no human intervention,  and so can be
described as natural attenuation or intrinsic remediation.  The
process can be promoted by addition of substrates such as
benzoate or sulfate.

In unamended groundwater, reductive dechlorination will only
occur where oxygen has been depleted and where there is
sufficient organic matter to support a microbial community.
Thus, aerobic aquifers with low organic carbon, typical of the
arid southwest, do not support natural attenuation by this
mechanism.  Reductive dechlorination is commonly observed in
aquifers with higher natural levels of organic carbon, such as
those in eastern North America,  and at sites in the West where
contaminant mixtures provide readily degradable organic matter to
support the microbial community and lead to oxygen depletion.
This is occurring in the groundwater at the Aerojet Propulsion
plant in Rancho Cordova, CA.

Reductive dechlorination of TCE and PCE is observed under
fermentative, sulfate-reducing and methanogenic conditions;
carbon tetrachloride reduction has been observed under
denitrifying conditions.

There is laboratory evidence that cis-DCE is toxic to some
anaerobes at concentrations above 10 mg/L.


Some useful references for the above and further information:

Hinchee, R.E.,  A. Leeson, L. Semprini, and S.K. Ong.  1994.
Bioremediation of Chlorinated and Polycyclic Aromatic Hydrocarbon
Compounds.  Lewis Publishers, Boca Raton,  FL.  525 pp.

Hopkins, G.D.,  L. Semprini, and P.L. McCarty.  1993.  Microcosm
and In Situ Field Studies of Trichloroethylene by Phenol-
Utilizing Microorganisms.  Applied and Environmental Microbiology
59:2277-2285.   (Also released as EPA600/J-93/295 . )

Weaver, J.W., J.T. Wilson,  D.H.  Kampbell,  and M.E. Randolph.
1995.  Natural bioattenuation of trichloroethene at the St.
Joseph, Michigan, Superfund site.  US EPA.   EPA/600/SV-95/001.
                                  14-3

-------
t)Cf:
                           II,
            This Page Intentionally Blank

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15

-------
                                          in in AH mil.'
 l..i\vicii(.r I ivciiniiir N.ilinii.il l.:iliin.iliii \p
 llmtri sil) iif (..ilidimi.i
 l.ivri mine.Cnlifiiinn 94SSI
UC LUFT Team
 Recommendations To Improve the
   Cleanup Process for California's
 Leaking Underground Fuel Tanks
                   (LUFTs)
                     Authon

                  David W. Rice
                  Drendon P. Dnnher*
                  Stephen J. Cullcn"
                  LorneC. Everell"
                  William E. Kaslenberg*"
                  Randolph D. Grose""
                  Miguel A. Marino""
        Principal Investigator/Contract Manager
            David W. Rice, LLNL
        Risk Analysis/Decision-Makina Approaches:
            William Kastenberg, Ph.D., UC Berkeley
            Brendan Dooher, UC Los Angeles

        Vadose Transport:
            Lome Everett, Ph.D., UC Santa Barbara
            Stephen Cullen, Ph.D., UC Santa Barbara

        Saturated Transport:
            Miguel Marino, Ph.D., UC Davis
            Randolph Grose, UC Davis
Submitted to Ihc California Stale Water Resources Control Hoard and the
 Senate Dill 1764 Leaking Underground Fuel Tank Advisory Committee
                October 16,1995
              •••Univcrulr "f talifdrma. lln krli >
             ••••Uni«tr
-------
Background
 California Underground Storage Tanks (USTs) are regulated through a
 framework of laws, regulations, and state, regional, and local policies
 The California Water Code is the law from which regulations and
 policies are derived
 State Water Resources Control Board (SWRCB) resolutions are
 policies used to implement the Water Code
 SWRCB resolutions are prepared through a public hearing process
 and consideration of the current state of knowledge and experience
         Hypothetical Cost vs Cleanup Curves
         Base Case
         • Total pumping time:
          50 years          uncertainty
         • Stop pumping      reduction
          at 5 ppb
                        Q.
Engineered
proceises
                        u
                        8
                                . \ . .           • • -jX^- V cumulal
                                       Years from start o< project
         Alternative Approach
         •Total pumping time:
          17 years          Uncertainty  Engineered
                           reduction   processes
         • Stop pumping      ,—•—v	—•	
          at 200 ppb
         Natural
        processes
                               — ConumlMnt
                                uncertainty
                                                     Cumulative com
                                                 Annual ens) (•1001
                                        Years from st.vl ol |iro|ci:t
                                                                   o
                                                                   O
                                 15-2

-------
01
     CtMf •cwrliiHon phut   EnglMic td prac«u» phiu
     1B
                4     «     a
                 V«v • tram dirt el proltcl
CtiwicttrliMtofl pht**^ Englnftrtd preMiMt ptaw
     —*	*^      Natwri procNMiphMt
      1b
                      4     »     •
                       Vitrtlromitiilalpro|Kl
                                           12
     ngui* i. Hypolhrte* eon vtfwi etoinup CUT.M lor ITP»C- tUFT cnt
     • p««e«i« PumpiiidluWttmtaillon-llhiloiilclttnopllimoHSytar
     ippb
                 Ovtr •ic*MHdn el trnnt wd ttl>Mihmnl ol plum*
                 Montag Wrtntle MortiMdlillofi l» dim gioond .ittt le ippb
Revised LUFT Decision-Making Approach
Broad, consistent decision-making approach that
can be adopted at State level, but still retain
element of local control
   • Overcome inconsistencies of old LUFT implementation
   • Facilitates water management planning
     - local beneficial use determination
   • Streamlines the clean-up process
   • Considers cost/risk benefit as a component in the
    decision-making process
   • Addresses  issue of highest beneficial uses (Water quality
    standards goals) versus risk-based prioritization

-------
    Revised LUFT Decision-Making Approach
     Relies on continuous access and utilization of data
     for decision-making

       • Provides increased regional/area hydrogeologic
        representativeness

         - Regional/area specific target screening levels established

       • Decision-making approach is evergreen

         - Action levels periodically re-evaluated
         - Knowledge of one site transferred to another
Conclusions
    Drinking water impacts from leaking underground fuel tank (LUFT)
    fue1 hydrocarbons (FHCs) have been low in California
    The cost of cleaning up LUFT FHCs is often inappropriate when
    compared to the magnitude of the impact on California's groundwater
    resources
    LUFT groundwater cleanup requirements are derived from policies
    that are inconsistent with the current state of knowledge and
    experience
    Current understanding of passive bioremediation processes in the
    subsurface environment is not reflected in the present LUFT cleanup
    process
                              15-4

-------
 Conclusions
 • A risk-based corrective action (RBCA) framework would provide a
  common decision-making process to systematically address LUFT
  cleanup
 • Modifications would be necessary for the American Society for
  Testing and Materials (ASTM) RBCA framework to be used in
  California
 • After removal of a FHC source, there are few LUFT cleanup situations
  where pump and treat should be attempted
LUFT Recommendations
 Once the fuel leak (tank and contaminated soil) source is removed:


 • Utilize passive bioremediation as a remediation alternative whenever
  possible
   - Minimize actively engineered LUFT remediation processes
   - Once passive bioremediation is demonstrated and unless there is
     a compelling reason otherwise, close cases after source removal
     to the point of residual FHC saturation
   - In general, do not use the UST Cleanup Fund to implement pump
     and treat remediation unless its effectiveness can be
     demonstrated
   - Support passive bioremediation with a monitoring program
                              15-5

-------
 Recommendations -— Risk Management Process       [@
  Immediately modify and implement the ASTM RBCA framework to
  allow streamlined closure criteria that:
   - Encompass a majority of LUFT cases;
   - Facilitate and encourage the use of natural bioremediation;
   - Position low-risk LUFT sites for rapid closure if risk-based
     groundwater cleanup goals are allowed.
Recommendations — Process Validation
   Identity a series of LUFT demonstration sites to:
     - Test recommended sampling and monitoring procedures and
       technologies to use natural bioremediation
     - Confirm cost effectiveness of the ASTM RBCA process

     - Act as training grounds for the implementation of a modified
       ASTM RBCA process
     - Facilitate the implementation of a revised LUFT decision-making
       process
                              15-6

-------
16

-------
   Practicalities of the
         Technical
     Impracticability
         Guidance
      What is Tl? (cont.)

' establishment of "alternate remedial
 strategies"
 -exposure control
  • deed restrictions on supply well
   construction
 - source control
 - aqueous phase remediation
         What is Tl?

waiver of ARARs in a specific area
because of
-DNAPL
- hydrogeologic complexity
-cost
- ineffectiveness of selected remedy
    How is Tl determined?
' the Tl Guidance
 -finalized in Sept. 1993
 - clarifies how, when, and where to waive
  ARARs for reasons of Tl
 -establishes alternate remedial objectives

-------
       Who determines Tl?


  • Tl team makes recommendation to DD
   - RPM, HQ, ORC, hydro(s) make up ad-hoc
    team
   - state involvement encouraged
    • Rich Freitas is point of contact in
     Superfund (744-2315)
    • Steve Linder is point of contact in RCRA
     (744-2036)
    • Peter Feldman is point of contact in HQ
     (703) 603-8768
Requirements for a Tl evaluation

  • identification of ARARs to be waived
  • identification of zone (area and depth) in
   which ARARs are to be waived
  • thorough site characterization
  • conceptual model
  • evaluation of restoration potential
   - analysis of why efforts have not achieved
    ARARs
   -timeframes
   - applicability of other technologies
   -cost
 When can EPA consider Tl?

• petitions may be submitted for review
 - at the time of the ROD
 - post-ROD
     Recent impetus for Tl

' July 31,1995 memo from AA Laws
 - "OSWER expects Tl waivers will be
  generally appropriate for DNAPL sites"
i October 1995 Superfund Administrative
 Reforms
 - suggests update of remedies at sites where
  we now know DNAPL to exist
  • "current policy is to isolate and contain
    DNAPL, removing the source only to the
    degree practicable"

-------
                  The rush for Tl


         • What rush?
          - one petition submitted so far under 9/93
           guidance
o>
u

-------
This Page Intentionally Blank

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17

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         Groundwater Containment Zones - "A Regulatory Policy and Process in Development..
                for US EPA 9's 1996 Corrective Action Conference - March 27,1996
   Containment Zones
       "A Regulatory Policy and
     Process in Development..."
                Pnttntatton to
              US EPA Region 9's
    1996 Corrective Action Conference
                   by
                 Stava Mont
       San Francisco Bay Ragional Wittr Quality Control Board
                March 27,1996
              Introduction
           Topics to be covered
    • Background
    • CZ rationale
    • Comparison with US EPA's Policies
    • SWRCB's new proposed requirements
    • Experiences implementing
      *Case Studies
      * Possible uses
    • Challenges and Opportunities
     What is a Containment Zone (CZ)?
                           Containment
                           Monitoring Well(s)
Stephen Morse
2/29(96
/o
                                       17-1

-------
             Groundwater Containment Zones - "A Regulatory Policy md Process in Development..
                       tor US EPA 9's 1996 Corrective Action Conference - March 27,1996
              Why Containment Zones?

    • 20,000 LUFT sites in California for cleanup
      6,000 LUFT in San Francisco Bay Area for cleanup
      1,000 solvent site cleanups in San Francisco Bay Area
    • "Lessons Learned" from fifteen years experience cleanup of
      ground water contamination:
      Solvents:
      cleanup to background or even MCLs Is often technically
      Impracticable or economically Infeaslble
      Fuels:
      fuel hydrocarbon leaks have had limited Impacts and risk to
      human health, the environment, or groundwater resources
      and can be regulated less stringently
    • National - "Alternatives for Ground Water Cleanup", NRC (June
      1994) and EPA studies
    • Some sites inherently pose limited risk to health, environment,
      and water quality (present and future)
    • Reality check
Why Containment Zones (cont .)?
Rela
asaF
••»<»»<«»*ipjr
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     Why  Containment Zones (cont.)?
  concentration
Stephen Mone
179/96
                        *cthra«em»d»ttDo«tes
                    \
                      ground water cleanup goal
                                                        17-2

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            Groundwater Containment Zones - "A Regulatory Policy and Process in Development...
                      for US EPA 9's 1996 Corrective Action Conference - March 27,1996
         Why Containment Zones (cont.)?

      "Lessons Learned" - Fuel Leaks
      & Lawrence Livermore recommendations
       •> Different characteristics than VOC, especially
         chlorinated
         - Light NAPL (LNAPL - fuels) vs.
           Dense NAPL (VOC chlorinated)
         - Can biodegrade readily and easily
         - Limited plume length
       » Remediation Costs vs. Value Gained
       » Limited historical impacts
         Why Containment Zones (cont.)?

    • Regulatory Reform — Desired Changes and Purpose
       *• A regulatory strategy for the reasonable protection of
        beneficial uses
          •Would
            - Provide stronger consideration of costs
            - Recognize technical limits
            - Recognize probable nsks
          • Would Not
            - Let water be further contaminated
            - Let those responsible escape
       » State and Regional Water Boards
          •Non-Attainment Area (now Containment Zone)
            - Higher risk sites - solvents, metals, etc
          •Low-risk fuel leak sites - bioremedistion
            - State law & regulations will change
        Comparison with US EPA's Policies

       US EPA's "Technical Impracticability" Policy
        »• Similarities:
          • Recognizes difficulties of ground water cleanups
          • Must be protective of human hearth and
            environment
          - Data requirements similar — site characterization
        *• Differences:
          - Covers all ground water pollution
          - Allows establishment of CZ prior to full
            implementation of remedy
          - Use of "mitigation''
          - Management of nsk following establishment
       EPA recommending implementation of nsk-based
       cleanups for LUFTs
       EPA considering intrinsic bioremediation for cleanup
Stephen Mone
209/96
                                                        17-3

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              Groundwater Containment Zones - "A Regulatory Policy and Process In Development.... *
                         for US EPA 9's 1996 Corrective Action Conference - March 27,1996
         Highlights of Proposed Containment Zone
             Amendments to SWRCB Res 92-49
            (from SWRCB'* September 14.1995. prepOMd amendments)

      • Renamed Non-Atttirmerrt Zone to Conttinmerrt Zone (CZ)
      • Draft Program Environmental Functional Equivalent Document
      • Recognized non-attainment as remediation strategy. If...
        » Determined that objectives cannot "reasonably be achieved*
        » Considering what is technologically or economically feasible.
          accounting for
           - reasonable period
           - environmental characteristics of the hydrogeologic unit
           - degree of residual risk
        » Technological feasibility
           - Assesmg available technologies effective in similar
             hydrogeologic conditions
        » Economic feasibility
           - Objective balancing of the incremental benefit of attaining
             further reductions in concentrations and mass vs
             incremental costs
                                                            10
         Highlights of Proposed Containment Zone
        Amendments to SWRCB Res 92-49 (cont.)
                  inm SMCVl 1IHIMH u IMS f*«M •MMUHI)

     • Source removed (containment/storage vessels, floating free
      product etc)
     • Plan submitted
      a  Agree to do work
      b  Residual risk management plan
          • Includes land use controls
      c  Mitigation Plan -- must provide reasonable mitigation measures
         for any significant adverse environmental impacts in the CZ.
         eg
          » Alternative water supplies and/or costs
          » Regional groundwater monitoring programs
          > Contributing groundwater basin cleanup or management
            programs
             - Off-site, another person. SEP. SWRCB's CAA
             - Financing off-site adequate with improvement to water
              quality
                                                            11
         Highlights of Proposed Containment Zone
        Amendments to SWRCB Res 92-49 (cont.)
           (from SWRCB s September 14 1995 proposed amendments)

       a Defined three types of Containment Zones
          » Sites with an approved cleanup program
            - fully implemented, groundwater asymptotic
            - generally VOC solvents, etc
          »"Low risk sites"
            - stable plume
            - classes of sites possible
            - generally fuels, areas
          » Difficult sites
            - strong sorpton, DNAPLs, complex geology
       » Must be limited in extent
       » Not cause a substantial decline in overall yield of basin
       • "No further acton" when implemented
Stephen Mone
2/29/96
                                                            17-4

-------
          Groundwater Containment Zones - 'A Regulatory Policy and Process in Development..
                   for US EPA 9's 1996 Corrective Action Conference - March 27,1996
      Highlights of Proposed Containment Zone
     Amendments to SWRCB Res 92-49 (cont.)
        (from SWRCB's September 14.1995. proposed amendments)

   > Water quality objectives are attained and
    maintained at and beyond the containment
    monitoring points
   »Containment Zone's Containment Points
     » Close as possible
     » CZ no larger than necessary
   • Must not adversely affect human or other biological
    receptors
                                                13
      Highlights of Proposed Containment Zone
     Amendments to SWRCB Res 92-49 (cont.)
        (from SWRCB's September 14. 1995. proposed amendments)

    > Comply with local ground water management
     plan (AB 3030)
    i CZ not permitted in some areas
      > Critical recharge areas
    > Local agencies may implement
      »• Petroleum products only
    i Utilize a TAC before designation
                                                 14
       Highlights of Proposed Containment Zone
      Amendments to SWRCB Res 92-49 (cont.)
         (from SWRCB's September 14 1995 proposed amendments)

    • SWRCB/RWQCB Review Committee
      ••will review for consistency first 2 years and
       prepare specific guidance as necessary
    • Must be designated by Cleanup Abatement Order
     (i.e. SCR)
      *• RWQCB — not Executive Officer
      » CEQA and public participation issues to be
       addressed
        - SWRCB's Program environmental document
        - Minimum requires RWQCB agenda notice
        - LUFT program (RWQCB coordination?)
                                                 15
Stephen Morse
2/29/96
                                                   17-5

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              Groundwater Containment Zone* - 'A Regulatory Policy mnd Process in Development.
                         for US EPA 9'« 1996 Corrective Action Conference - March 27, 1996
         Case Study #1 - Higher Risk Site

    • Site is 30 acres; formerly used lor manufacture of computer disk
      drives: pollution in soils and ground waters on-srte
    • Predominant VOCs in shallow ground water are TCE. Freon-113,
      1,2-DCE. and vinyl chloride; some pollutton in deeper ground
      waters
    • Classified as 'potantiar drinking water by SWRCB Res B8-63
    • Ground water extraction and treatment system installed in August
      1986; operated continuously to early 1994:
       » 84 million gallons water; 152 pounds VOCs; asymptotic
    e SF Bay RWQCB adopted CZ December 1993
       » Ground water extraction no longer efficient; could be improved,
         but not cost-effective and still would not meet MCLs on-sita
       > Ground water above MCL must be contained en-site
       » Residual risk management and contingency plan to be
         implemented
      Case Study #1 - Cumulative Pounds of VOCs Removed
             160-

             140-

             120-

    Cumulativeioo-
       VOCs
      removed 80-

             60-

             40-

             20-
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                                                         8«4
      Case Study #1 - Contaminant Isocontours of TCE and 1,2-DCE
             Shallow ground w«w concentrators - lite 1803
                                                O
                                            background well
Stephen Morse
2/29/96
                                                             11
                17-6

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           Groundwater Containment Zones - 'A Regulatory Policy »nd Process in Development..
                    for US EPA 9's 1996 Corrective Action Conference - March 27,1996
Case Study #2 - "Low
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   Appl i cation of CZ to Larger, Complex Sites
  MW = Monitoring Well RMZ = Remediation Management Zone 20
   Application of CZ to Commingled Plumes
  MW = Monitonng Well
STephen
2/29/86
                                                 17-7

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             Groundwater Containment Zones - 'A Regulatory Policy and Process in Development..
                        tor US EPA 9's 1996 Corrective Action Conference - March 27,1996
                     "Ideal" CZ Sites
        Residual risks are acceptable and low
        Contaminant concentration at asymptote levels and/or
        dose to State water quality objectives
        Fine-grained soils
        Benign biodegradaton taking place
        Pollutant plume contained on-srte
        Non-potable water uses under the site
        "Instrtutonals" remain stable and constant
        » Few owners/operators involved
        » Continuity of operator, regulator, contact poison, lab
        » "Standard" deed restrictions
        Industrial and/or commercial land uses on-srte and
        adjacent
                 Disadvantages of CZ?
      1   "Closure" mechanism is not yet formulated for CZ
      2   Establishment of a CZ will require some nsk
         assessment
      3   Lack of technical training for nsk evaluation at
         RWQCBs and LOPs may create reluctance of
         approval
      4   It may create cumbersome management
         requirements at "clean" sites where CZ should not
         even be deemed necessary
      s   Potential for misapplication in situations where
         water quality does not warrant consideration
                                                          21
    6.
                Advantages of CZ?
De-emphasizes 'closure' at sites where closure is impractical
Allows long-term monitoring only vs aggressive technological
application
Allows long-term, predictable cost-planning for approved site
management plan
Could be ideal for operational facilities where plumes are stable
and source cannot be removed
Would be recognized remedial alternative within SWRCB
Resolution 92-49 and therefore is not subject to further
enforcement action
Use of nsk assessment process provides increased insight and
understanding of the problem and optimizes protection of health.
environment, and water quality
Assumes that the beneficial use as potable water is not immediate
and therefore allows time to remediate the pollution
                                                          M
Stephen Morte
2/28/96
                                                  17-8

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             Groundwater Containment Zones - "A Regulatory Policy and Process in Development..,
                       for US EPA 9's 1996 Corrective Action Conference - March 27, 1996
      Opportunities to Improve Implementation of CZ

       1.  Simplify and streamline all procedures for low-nsk
          sites to match threat
       2.  Consider cleanups on the basis of "risk-management"
          alone, eg low-nsk fuel sites
       3.  CZ leading to "closure" must be developed
       4.  Integration into upcoming SB1764 process /
         'regulations
       5.  "Reasonable", etc to be defined through examples
          and case studies and education
       6.  Real estate and financial institutions must be satisfied
       7.  UST Cleanup Fund decision-making should be
          integrated into CZ
       6.  Partial CZ. e g  off-site vs on-stte CZ
       9.  Commingled plumes using an "area" approach
      10.  Guidance for project mitigation requirements
                                                      26
                       Summary
        Containment Zones could provide for:
         » Recognition of the technical and financial
           infeasibility to reasonably achieve ground
           water quality objectives;
         » Rational management of site cleanups;
         »• Protection and conservation of significant
           amounts of ground water
         »• Protection of public health and the
           environment;
         * Potentially the most "cost-effective" to the
           public and private sector.
                                                      26
       SF Bay RWQCB Comments & Recommendations on
    SWRCB's Proposed 92-49 Amendments (Containment Zone)

    • Compliments pursuing Containment Zone amendments and
     Program Functional Equivalent Document (FED)
    • Requested SWRCB consider following changes
      » Amend finding to commit to change to reflect fuel leak
        cleanups as special category (ref LLNL report)
         - Consider use of nsk management for fuel cleanups
      » Revise to not unnecessary restnct RWQCBs
         - CAOs by RWQCBs only
         - "One size fits all" administrative requirements
      » Clarify intent and use of certain sections (and  FED)
         - Which local agency to implement
         - tank removal practicality
         - Use of FED
           - Significant adverse impacts
           • Mitigation
    e Adopt and move on                                 27
Stephen Moree
2/29/96
                                                        17-9

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              Groundwater Containment Zones - "A Regulatory Policy and Process In Development..,
                        for US EPA 9's 1996 Corrective Action Conference - March 27,1996
      Summary of SWRCB Bublic Heanng Novembers. 1995 on
     SWRCB's Proposed 52-49 Amendments (Containment Zone)

       • Over 4 hours testimony, 20* parlies testified
          » Most supported concept of Containment Zone (-IB)
           Primarily industrial but included SCWVD. San Jose. Emeryville
             - Typically wanted even more (earlier daemons, closure, etc)
             - Supportive but concerns ebeut
               •fuel cleanups (admin, timing. LLNL report, etc)
               •mitigation requirements (especially off-site)
               •administrative requirements (especially fuel)
               •'•stigma' upon reel estate
          • Opposition to Containment Zones
             - Planning and Conservation League. MetvVater. TAG. UC Davis
              Law Clinic. Save Santa Monica Bay
               •Aquifer Abandonment Policy
               •Loss of finite resources
               •Inadequate CEOA documentation
       e SWRCB seemed supportive
          » Record Open to December 1.1995
          • Written comments impacts unknown
       • Future of Policy Uncertain   but Fuels????'
Amendment of SWRCB Res 92-49 to Include CZ
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                   CZ -Conclusions
      • CZ could break the logjam on some site
        cleanups and management decisions
         »CZ can only  be considered now by
          RWQCBs one-by-one as appropriate
      • Further consideration at SWRCB being
        given through Res 92-49 amendments
      • "Still in development...."
Stephen Morse
2/29/86
                                                        10
                                                        17-10

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            Groundwater Containment Zones - "A Regulatory Policy and Process in Development...."
                     for US EPA 9's 1996 Corrective Action Conference - March 27.1996
   BBS / Internet
Supnen Moise
2/29/96
                                                    17-11

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This Page Intentionally Blank

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18

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  THE IMPORTANCE OF FIELD OVERSIGHT FOR GROUNDWATER SAMPLING

                            Brian Lewis (HQ-24)
                   Department of Toxic Substances Control
                              P.O. Box 806
                       Sacramento, CA  95812-0806
                              (916) 323-3632
                            (916) 323-3700 Fax
                   E-Mail: BLEWIS@HW1.CAHWNET.GOV
ABSTRACT:

Groundwater sampling, including collection, handling, preservation, and
transportation, is carried out by a wide variety of personnel. Some samplers have
little training, whereas other samplers may have had extensive training. A few
Owner/Operators and environmental companies offer internal training to ensure
competency as well as consistency. This presentation provides an overview of
some of the common errors observed in the field. DTSC has found th^t with
oversight and coaching of the sampling done for Owner/Operators, sampling
collection methods have improved over time. However, more work (e.g., training,
detailed sampling and analysis plans, etc.) is needed to insure that representative
samples are obtained. Additionally, DTSC encourages Owner/Operators,
consultants, and regulators to  routinely audit samplers.
                                     18-0

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This Page Intentionally Blank

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                Guidelines for the Preparation of Water Quality
                    Sampling and Analysis Plans (WQSAPs)

      The Department of Toxic Substances Control's (Department's) Permitting and
Enforcement Geological Services Unit (PEGSU)  has developed guidelines for use in
the review of WQSAPs by Department staff. As the Department implements Senate
Bill 1082 (Calderon), these guidelines may change to incorporate comments from the
State Water Resources Control Board and/or the Regional  Water Quality Control
Boards. PEGSU  may also  revise  these guidelines  to incorporate concepts and
guidelines from the Department's Regulatory Structure Update (RSU).

      The WQSAP is the document  that completely describes the water quality
monitoring program for a regulated unit at a RCRA facility. It identifies the regulated
unit, describe pertinent details about the construction of the unit and  the historical
use of the  property, and  describe waste management activities at the unit.  The
WQSAP describes  the hydrogeology of the area and contain specifications for the
water quality monitoring systems (ground water, surface water and unsaturated zone)
in use at the facility.  The WQSAP  describes any  contamination that has  been
identified and state whether the regulated unit  will be in detection, evaluation or
corrective action monitoring.

      The WQSAP should also include the following

•     the  constituents of  concern  (CoCs)  and   monitoring  parameters  and
      documentation to support the lists,

•     the sampling frequency  and the number and kinds of samples to be collected
      during each sampling event,

•     documentation (hydrographs) indicating the seasonal maximum and minimum
      water levels expected (by month),

•     a discussion of the need  to monitor for wellhead gases and immiscible layers,

•     the rationale for deciding if  samples  for metals will  be filtered or not.  The
      decision must include  a consideration of the  purpose of sampling  (i.e.,
     detection  monitoring, evaluation of a release or risk assessment),

•     information  used  to  establish  background  values  for all  CoCs and all
      monitoring parameters,  and  provides a detailed description  of  the statistical
      methods to be used to evaluate  analytical data,
                                     18-1

-------
 •     the Quality Assurance Project Program (QAPP) or reference to the QAPP. The
      QAPP describes the data quality  objectives  (in terms of accuracy and
      precision), acceptance criteria for analytical data, and the format for reporting
      the results of the Quality Assurance /Quality Control (QA/QC) program. (Note:
      Proposed detection limits must be low enough to fulfill the data needs of the
      monitoring program),

 •     the statement that actual laboratory  values between the detection limit (DL)
      and the practical quantitation  limit (PQL) will be reported (and maintained in
      the data  base) with the numerical value determined by the laboratory and a
      flag to indicate that these values are  below the PQL. In such cases the value
      of the PQL  must also  be reported  and maintained in the data  base.  The
      practice of artificially censoring data that is reported below the calculated PQL
      can lead to  the use of less powerful statistical  methods.  It  is important to
      preserve the actual uncensored values for all concentrations above the DL for
      possible  use in  future statistical analysis, and

 •     a detailed description of the content and submittal dates  for periodic reports
      (including the submittal  of quarterly  determinations of groundwater flow rate
      and direction).  The name, address,  and telephone number of the person at
      DTSC  to whom reports and  notifications of significant  findings are to be
      addressed and  the name,  address  and telephone  number of the  facility
      representative to contact for questions regarding  the report  should also be
      included.
      The following items may also be needed in WQSAPs.

•     For a detection monitoring program, a specification of the maximum amount
      of time needed after each monitoring episode to perform statistical analysis and
      make  a determination of whether of  not there is  statistically  significant
      evidence of a release from the regulated units.

•     A description of well redevelopment and routine well maintenance.   For
      permitted facilities, it is wise to include a section on well decommissioning
      and replacement so that those  procedures can be implemented without a
      permit modification.

•     To evaluate the accuracy of the analytical data,  provisions for initially and
      periodically characterizing the major cations and anions and testing the results
      by determining the charge balances.  This could probably  be most easily
                                      18-2

-------
      performed during the initial sampling to establish background values for CoCs
      and during the periodic testing of CoCs in downgradient wells.

      For a detection monitoring program, a statement that DISC will be notified by
      certified mail within 7 days of determining statistically significant evidence of
      a release for any monitoring parameter or CoC at any monitoring point (Section
      66264.98(j)). The WQSAPshould describe the exact procedures for performing
      verification sampling, specify the maximum amount of time before the results
      of the verification sampling  are reported to DISC and  state that, if  the
      significant evidence of a release is confirmed, the facility will comply with the
      requirements of Section 66264.98(k) Title 22 California Code  of Regulations
      (CCR) for responding to significant evidence of a release (e.g., immediately
      collect samples for Appendix IX constituents and  for all CoCs, etc.).
      Finally,  the WQSAP  should contain detailed  information describing  the
physical process of sampling. This portion of the WQSAP is generally written as a
stand-alone document that is appropriate for use by field personnel and is usually
referred to as the sampling and analysis plan (SAP).  Attached is a checklist of items
to be included in a SAP.  Also included are  two checklists indicating what  the
Department  reviewers look for in quarterly monitoring reports and annual reports
generated after the sampling takes place.
                                       18-3

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                     Sampling and Analysis Plan Checklist

      This sampling and analysis plan (SAP) checklist was developed to address
the physical process of obtaining  field information, measurements, and water
quality samples.  The SAP should be written as an enforceable document.
Deviations from the procedures described in the current SAP for a facility are
subject to enforcement by the Department.  It should be written to unambiguously
describe exactly what steps will be taken to ensure that representative samples are
collected. The SAP must contain sufficient detail for a sampler with limited
experience to understand and follow and to ensure that sampling will  be
conducted in the same manner by different  samplers. The following items should
be included in the SAP.

      1)     A copy of the document each member of the field team signs stating
            that he/she has read and understands the current version of the SAP.
            A signed copy of this document should  be submitted to the
            Department with the report of analytical results.

      2)     A description of the equipment to be used and procedures to  be
            followed for the measurement of the depth to water. The SAP should
            specifically state that water levels will be measured in all  wells and
            piezometers at least quarterly for the calculation of ground water flow
            rate and direction, that all water levels will be measured in the
            shortest possible time, and that water levels in all wells will be
            measured before any well is purged.

      3)     A statement that water  levels for the calculation of ground water flow
            rate and direction will be measured during times of expected  seasonal
            maximum and minimum water levels.

      4)     A statement that the depth to water will be measured with reference
            to a marked point that has been surveyed by a licensed surveyor.
            The water level probe should be capable of obtaining reliable
            measurements to +/- 0.01 foot.  The SAP should specify the method
            for decontamination of the water level probe between use at each
            well.

      5)     The order in which wells will be visited for water level monitoring,
            sampling, and  maintenance.  The rationale for the order in terms of
            minimizing the possibility of cross-contaminating  the wells and/or
            samples should be presented.
                                     18-4

-------
6)    Calibration procedures, frequency, and recordkeeping for water level
      probes.

7)    Procedures, frequency, and recordkeeping for measuring the depth of
      the well casing.

8)    Calibration procedures, frequency, and recordkeeping for the well
      depth sounding instrument.

9)    Copies of sample field data sheets.

10)   A statement that well-head conditions (condition of well casing, well
      lock, markings,  standing water at surface) and any suggested
      maintenance will be recorded in the field notes. The SAP should
      describe procedures for performing necessary well maintenance in a
      timely manner.

11)   Equipment"and  procedures for testing wellhead  gases and for testing
      the water surface for immiscible layers (if required per the WQSAP).

12)   Procedure for calculation of well casing volumes. Where references
      are made to total well depth, it should be clear  that the total well
      depth is the well depth as measured from the permanent mark on  the
      well casing.  (Total well depth is also commonly recorded as depth
      below ground surface.)

13)   The maximum purge rate for  each  well.  Whenever possible, purge
      rates should not exceed recharge rates. (Note: For wells completed at
      the water table,  maximum purge rates may be a function of the water
      level in the well. The objective is  to avoid purging a well to dryness
      whenever possible.)

14)   A statement that, unless wells are purged to dryness, a minimum of
      three casing volumes will  be  removed during well purging.

15)   A statement that, unless wells are purged to dryness, wells will be
      purged until field parameters  stabilize. DTSC currently believes that
      stability of field  parameters is the best indication that the water being
      sampled is representative of the ground water in the aquifer. All
      measurements of field parameters are to be recorded in the field log.
                                 18-5

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      The final, stable value for each field parameter must be recorded and
      graphed through time for each well.

16)   For wells purged to dryness, procedures for removing as much water
      as possible from the well, monitoring recharge, collecting samples as
      soon as the well has recharged sufficiently, and documenting the
      sampling events. For wells that are bailed, the SAP must state that a
      well will only be considered to have been purged until "dry" if less
      than  10% of the original volume of water remains in the well  after
      purging.  (Note: The objective is to minimize the amount of water
      that remains in the well after the well has been purged "dry",  because
      that water is expected to mix with  the recharging water so that the
      sample will be a combination of "stagnant" and "fresh" groundwater.
      It is important to optimize the  percentage of "fresh" water.)  The SAP
      must specify the frequency for measuring recharge and the criteria for
      initiating sampling. Sampling must proceed as soon as possible after
      the recharge criteria have been satisfied.  Samples for volatile
      organics must be collected no  more than two hours after purging.

17)   For wells not purged to dryness, a  statement that  sampling will be
      conducted as soon as possible after purging is completed. The SAP
      should specify, based on measured recharge rates, the approximate
      time period after purging that sampling will occur; or,  the SAP
      should describe the procedures for measuring and recording water
      levels after purging and before sampling and specify the criteria for
      recharge.

18)   A description of equipment and procedures for measuring field
      indicator parameters during purging.  The SAP should  specify  the
      criteria for determining that field parameters  have stabilized before
      sampling (e.g.,  pH +/- .1 pH unit,  temperature +/- 1 degree Celsius,
      conductivity +/- 10%, turbidity +/- 10%) and must state the
      minimum purge volume between tests to determine if  field
      parameters have stabilized (e.g.,  one-half casing volume). The SAP
      should specifically state that turbidity will be measured with a
      turbidity meter. Visual estimates are not sufficient.

19)   Calibration procedures,  frequency and recordkeeping for all meters
      used  during sampling.  The SAP should  state that the expiration dates
      of standard solutions used for calibration will be  recorded in the field
      log. Any deviations noted during the day (e.g. meter drift) should
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      also be recorded.  If meter drift requires an adjustment to any final
      values for field parameters, the results should be flagged in the data-
      base.

20)   Procedures for recording flow  rates and volumes of water purged and
      for disposing of purged water.  Field notes should include the
      appearance of the purged water including  its color and odor.

21)   A description  of the equipment and procedures for collecting
      samples.  Sampling equipment should be constructed of inert
      materials.  Dedicated equipment should be used whenever possible.
      If equipment must be used at more than one well, the SAP should
      describe in detail the procedures to decontaminate the equipment
      and procedures for the collection of equipment blanks.

22)   A statement that clean, powderless, surgical gloves (or another
      approved type of glove) shall be worn by sampling personnel and
      shall be changed often.

23)   A description  of the sample containers (size and materials) for each
      type of analysis.

24)   A description  of the labeling of the sample containers.

25)   A description  of the preservation techniques necessary for each type
      of sample.

26)   Procedures for determining the amount of preservative necessary to
      achieve the required chemical  stability (e.g., amount of  acid
      necessary to ensure pH<2 for metals analysis).

27)   Procedures for checking and documenting  the results of preservation
      (e.g., checking whether metals samples have been acidified to a pH
      of less than 2  and that temperatures are maintained at 4 degrees
      Celsius during shipping and  storage).  The  SAP must state that
      problems will be reported to the Department. (We have had some
      trouble with laboratories  documenting problems but not reporting
      them.)

28)   A description  of the equipment and procedures for taking each  type
      of sample. Sampling procedures should be designed to minimize
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      disturbance of the sample that could result in changes in water
      chemistry.

29)   If filtering is required, a description of the equipment (including filter
      size) and procedures for filtering samples.  The use of in-line filters is
      preferred. If in-line filtration is not possible, filtering should be done
      as quickly as possible (immediately) using positive pressure filtering
      equipment. The SAP should specify the discard volume (the volume
      of groundwater to be used to flush the filter before sampling) for the
      type of filter to be used. If manufacturer's guidelines are not
      available, the SAP should specify that two times the capacity of the
      filtering device will  be passed through the filter and discarded  before
      samples are collected.

30)   A statement that  bottles that have been prepared with preservatives
      will not be overfilled.

31)   A description of the equipment and procedures for storing samples for
      transport.

32)   Forms and procedures for sample transport and chain of custody
      control.  The SAP should specify the procedures to be followed to
      assure that strict custody of samples is maintained  during sample
      collection, storage and transport (i.e., samples are  not left unattended
      or samples are secured in storage areas with limited access). Sample
      copies  of chain-of-custody and sample analysis request forms should
      be included.

33)   A description of equipment, procedures,  and recordkeeping for
      decontamination of all sampling equipment and protective  gear.
      Equipment shall not be used if visual signs, such as discoloration
      indicate that decontamination was insufficient.

34)   The analytical method to be performed for each sample.

35)   A copy of a document each member of the field team signs following
      each sampling event, detailing any deviations from the SAP that were
      necessitated by field conditions (e.g, equipment failure, wells that
      could not be sampled, etc.) and stating that, with the exceptions
      noted above, all  field measurements and samples  were collected in
      accordance with the procedures described in the SAP. A signed  copy
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of this document must be submitted with the report of analytical
results.
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                  Checklist for Quarterly Monitoring Reports

      Within 60 (or 90) days following each quarterly sampling event, the facility
is required to submit a quarterly monitoring report to the Department.  The
following items apply to each quarterly monitoring report:

 •    The report should be presented in  a professional report format with a table
      of contents and numbered pages.

 •    Since the quarterly monitoring report must contain interpretations of
      hydrogeologic and geochemical  data, each  report should be signed by a
      Geologist, registered in the state of California who takes responsibility for
      the technical content of the report.  This is  required by California state law -
      Business and Professions Code, Geologists and Geophysicists Act.  Reports
      should indicate the license number of the geologist.

 •    Each report should reference the current sampling and analysis plan (SAP)
      and state that, with only the exceptions listed in the report, all sampling and
      analysis was conducted in accordance with the current plan.

 •    Each report should contain a detailed description of any deviations from the
      current SAP, an explanation of the conditions that necessitated those
      deviations and a description of any corrective measures being taken to
      avoid future deviations from the  SAP.

 •    When appropriate, each report should describe recent changes to the
      monitoring program that are allowed by the conditions of the current SAP.
      (For example, minor changes in sampling or analytical equipment or
      protocol,  addition of new or replacement wells to the monitoring system,
      and the use of updated concentration limits.)

 •    Each report should contain a summary of the sampling event that identifies
      the type of monitoring program for each regulated  unit (detection,
      evaluation, and/or corrective action) and describe significant findings.

 •    Each report should contain a narrative report summarizing and interpreting
      the results of the monitoring event, including, but not limited to:
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  *    Analysis of water level data and potentiometric maps, including a
      determination of groundwater flow rate and direction in each
      hydrologic zone monitored at the facility;

  *    A report on the results of quality assurance / quality control (QA/QQ
      sampling and analysis. The report must state whether or not data
      quality objectives of accuracy, precision and completeness have been
      met.  If objectives were not met (e.g., target detection limits were
      exceeded), this section must discuss corrective measures (e.g.,
      resampling) that are being taken by the facility and/or the laboratory.

  *    Summary of the results of statistical analyses on water chemistry data;

  *    Interpretation of soil moisture data; and

  *    Summary of the results of facility maintenance inspections of the
      monitored units and their monitoring systems.

Each report should contain a current set of potentiometric maps for the
facility.

Each report should include summary tables of current water level data,
analytical  data, and the  results of the statistical analysis.

Each report should contain supporting documentation related to the
sampling event, including, but not limited to: copies of field logs and
activity sheets; depth to water data; well head data; immiscible layer data;
field parameter results; purge volume data; on-scene observations; chain-of
custody forms; and  laboratory data sheets (analytical reports).  Internal
laboratory calibration and QA/QC data need not be submitted to the
Department, but should be available at the facility or laboratory if needed.

Each report should contain an evaluation of the effectiveness of the leachate
monitoring and control facilities and  of the run-off/run-on control facilities.

For active units, each report  should describe the quantity and  types of waste
discharged and the  locations in the facility where waste has been placed
since the submittal of the last such report.

Each report should include a section that tracks outstanding issues and/or
follow-up  work that needs to be performed (e.g., verification sampling of
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      apparently significant evidence of a release, repair or replacement of wells
      or equipment). Any item included in this section must be addressed in
      every subsequent quarterly report until  the outstanding issue is resolved.

Note:  The documentation requirements for quarterly monitoring reports are not a
substitute for the notification requirements in  section 66264.98 (j)(1) and
66264.98(1).  As required  by those sections, anytime the facility determines that
there is statistically significant evidence of a release  from the regulated unit, the
facility must notify the Department by certified mail  within seven days of making
that determination.
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                   Checklist for Annual Monitoring Reports

      By March 1 of each year (unless the facility permit states otherwise), the
facility must submit an annual report that covers the activities of the previous year.
The annual report may be combined with the quarterly report for the fourth
quarter provided it is submitted within 90 days of the fourth quarter sampling
event and all items required for each report are included in the annual report.

The following items apply to each annual monitoring report:

 •    The report should be presented in a professional report format including a
      table of contents and numbered pages.

 •    Since the annual monitoring report must contain interpretations of
      hydrogeologic and geochemical data, each report should be signed by a
      Geologist, registered in the state of California who takes responsibility for
      the technical content of the report. This is required  by California state law -
      Business and  Professions Code, Geologists and Geophysicists  Act.  Reports
      should indicate the license number of the geologist.

 •    Each report should contain an executive summary of previous year's
      sampling events that identifies the type of monitoring program for each
      regulated unit (detection, evaluation, and/or corrective action) and describe
      significant findings.

 •    Each report should contain a narrative report summarizing and interpreting
      the results of the water quality monitoring program to date, including, but
      not limited to:

       *    An analysis of water level data and potentiometric maps. Water level
            data, including hydrographs and  potentiometric maps, must be
            evaluated to determine if the water quality monitoring system is in
            compliance with the requirements of Section 66264.97(b)(1)  (i.e.,  the
            system satisfies the data needs for the current  monitoring program:
            detection, evaluation or corrective action.)   If  the system is not
            adequate, the report must specify the steps that will be taken by the
            facility to achieve compliance with those requirements.

       *    Interpretation of the results  of statistical analysis on water chemistry
            data; and
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  *    Interpretation of soil moisture data.

Unless otherwise stated in the permit or sampling and analysis plan, each
report should contain comprehensive summary tables of all historical
analytical data related to water quality monitoring (groundwater, surface
water, and soil-pore liquid) at each regulated unit.

Each report should contain time series plots of water level, laboratory
analytical data, and the final, stable value of field parameters.  Unless
otherwise stated  in the permit or WQSAP, graphs should be presented in
the following format:

  *    Every monitoring parameter or CoC should be shown on a separate
      graph with the data from as many wells as can  be legibly displayed.
      As much historic data as possible should be included on each graph
      so that long-term and/or recurring trends can  be distinguished.

  *    When a concentration is reported  as below the detection limit (DL),  it
      should be displayed on the graph in  such a way that the reviewer
      can clearly tell that the  analyte was not detected.  The value of the
      DL must be evident.  If the DL has remained  constant, it is sufficient
      to simply state what that limit is and to  plot the data at a constant
      value (i.e., the value of the DL).  If the DL has varied through time
      the facility should devise a way to depict that information on the
      graph.

  *    When a concentration is reported  below the  reporting limit  (or
      practical quantitation limit [PQL]), but above  the DL (such data is
      frequently  referred to as "censored" or "trace" data) it should be
      displayed on the graph  at the estimated concentration reported by the
      laboratory,  but in such a way that the reviewer can clearly tell that
      the concentration was estimated to be below the reporting limit (or
      PQL). The values of the reporting limit (or PQL) and the DL should
      be evident. Methods in use by other  facilities include: substituting
      the letters TR (trace) for the well symbol on the graph, altering the
      well symbol in some standard way (e.g  circling the well  symbol,
      using alternate colors), and plotting detection limits on overlays.

  *    The spread of the y axis should be selected to best display the
      variability of the data and must be no more than three times the
      range of the data.
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When plotting concentration data for multiple wells, it is expected
that much of the data will overplot for values near the mean of the
data set.  This still provides useful  information and should not be a
problem as long as the graphs are  submitted at an appropriate scale
and well symbols are clearly legible  in areas where the concentration
deviates from normal.

If more than one graph is needed for each parameter then:

a)     to facilitate comparison between upgradient and downgradient
      data, each graph shall show data from the background
      monitoring points  (Note: This can also be accomplished by
      printing graphs on transparencies and overlaying the graphs.);

b)     downgradient wells shall be grouped by location or by other
      significant characteristics; and

c)     all graphs for a parameter shall be  at the same scale.
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  SPEAKER

BIOGRAPHIES
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                          SPEAKER BIOGRAPHIES
      1996 EPA REGION 9 CORRECTIVE ACTION CONFERENCE
                               BRIAN J. ANDRASKI
                               U.S. Geological Survey

Brian Andraski, Research Hydrologist, U.S. Geological Survey, has 10 years of experience
in the study of soil physical and hydrological problems related to waste disposal in arid
environments.  His present work emphasizes the evaluation of soil-plant-water interactions
and the testing and evaluation of methods for characterizing and monitoring water movement
in desert soils. Previous work, done as a Senior Research Specialist at the University of
Wisconsin Soil Sciences Department, included studies to characterize water movement in  a
coal fly-ash landfill.
                                KAREN T. BAKER
               California EPA Department of Toxic Substances Control

Karen T. Baker has been with the California Department of Toxic  Substances Control
(DTSC) for eight years.  She received a M.S. in Geological Sciences from the University of
California, Riverside in 1985. She is a California Registered Geologist, Certified
Hydrogeologist and Certified Engineering Geologist.  She is currently the supervisor of the
Geological Support Unit.  The unit provides geological consultation  to both the RCRA and
CERCLA Programs within DTSC.
                                   NED BLACK
                   U.S. Environmental Protection Agency, Region 9

Ned Black, Ph.D., has been with the United States Environmental Protection Agency as a
Superfund Project Manager and Ecologist for two years.  Prior to that, he worked as a post-
doctoral fellow and acting assistant professor in the Department of Civil Engineering at
Stanford University, where he studied bacterial degradation of PAH's and chlorinated
solvents.  Dr. Black has a doctorate in Engineering Sciences from Harvard University.  His
doctoral research dealt with aquatic microbiaJ ecology and metal geochemistry.

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                                 R. JEFFREY DUNN
                                GeoSyntec Consultants

R. Jeffrey Dunn, Ph.D., P.E., G.E., Manager of GeoSyntec's Walnut Creek Office, has more
than 19 years experience in the permitting, design, construction, operations, and closure of
municipal, industrial, and hazardous waste landfills.  Dr. Dunn is a licensed Geotechnical
Engineer and has a wide variety of experience in many different projects and is nationally
recognized for his expertise in design and construction of geosynthetic and clay liners and
covers. He has worked  on projects for both;private and public sector clients.  Specific
projects Dr. Dunn has managed include the closure design for the City of Fresno CERCLA
Landfill, 1SRT NPL remediation in Woburn, Massachusetts, as well as the expansion designs
and construction quality  assurance for the Sonoma. Vasco Road, and Keller Canyon sanitary
landfills.  He has worked with a number of clients and regulatory agencies in the development
stages of state and local  regulations and guidelines for closure and post-closure landuse at
landfills.  Recently he managed a two year state-of-the-art study of "Performance Criteria for
Landfill Covers" for the  California Integrated Waste Management Board (CIWMB).
                              MATTHEW HAGEMANN
                    U.S. Environmental Protection Agency, Region 9

Matthew Hagemann has been with the U.S. EPA for seven years.  He has worked as a
hydrogeologist in the RCRA, Safe Drinking Water and Superfund Programs.  Matthew earned
a B.A. in geology from Humboldt State and an M.S. from Cal State L.A.  In the twelve years
he has practiced geology, Matthew has worked for a consulting firm, the U.S. Forest Service,
and has taught at the secondary, community college and university levels.  Currently, he
teaches part-time at San Francisco State University.
                             VALERIE HEUSINKVELD
               California EPA Department of Toxic Substances Control

Valerie Heusinkveld has been with the California Department of Toxic Substances Control,
Berkeley Regional Office, for seven years. She has a Bachelor's degree in chemistry from
UC San Diego and a Master of Public Policy degree from UC Berkeley.  Before coming to
DTSC, she worked as a research chemist in industry.

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                             THEODORE R. JOHNSON
               California EPA Department of Toxic Substances Control

Theodore R. Johnson HI has over fifteen years experience as a geologist.  He received a
B.S. in Geological Sciences from the University of Southern California in 1981. He is a
California Registered Geologist.  He has been working for the last three years for the
Department of Toxic Substances Control in the Hazardous Waste Management Program.  His
current projects include soil and  groundwater characterization and remediation of
contaminated sites.  He specializes in environmental and engineering geology and project
management, exploration and high resolution geophysics.


                                DENNY A. LARSON
                       Communities for a Better Environment

Denny Larson has over 15 years experience with community organizing and outreach
activities.  He has a Bachelor of Science in Communications from the University of Texas at
Austin.

Mr. Larson has worked closely with communities located near oil refinery and chemical
plants to address concerns regarding  chemical spills and air pollution  problems. In the Bay
Area, he helped found the West County Toxics Coalition in Richmond, California, and helped
negotiate Good Neighbor Agreements with Shell, Chevron,  Tosco, Pacific and Unocal
refineries in  Contra Costa County. The Good Neighbor Agreements reduced millions of
pounds of toxic pollution, improved air monitoring, and gave  neighbors inspection and
oversight rights.

In 1994, Mr. Larson began a national effort to link oil refinery neighbors, workers and
shareholders together to achieve  "cleaner and safer refining."  In recognition of Larson's
work, U.S. EPA Administrator Carol  Browner named Larson to a Federal panel charged with
reinventing regulator) approaches to the oil industry.
                                   BRIAN LEWIS
               California EPA Department of Toxic Substances Control

Brian Lewis, CEG, CHG, Chief of Permitting and Enforcement Geological  Services Unit,
California Department of Toxic Substances Control, has more than 16 years experience in the
groundwater field, including 11 years with hazardous waste. For two years, he was on loan
to the U.S. Environmental Protection Agency, Headquarters, as a member of the National
Groundwater Task Force.  This task force evaluated compliance with the Resource
Conservation Recovery Act, Subpart F requirements at sixty facilities nationwide.  Within
California, he established a state task force based on the federal model. Currently he is a
member of the Regulatory Structure Update (RSU) team that is focused on implementing the
corrective action program in California.

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                                RICHARD McJUNKIN
                California EPA Department of Toxic Substances Control

Richard Mcjunkin, RG, CEG, supervises the Geologic Services Unit in the Site Mitigation
Program of the Department of Toxic Substances Control.  He has a B.S. and M.S. in geology
and is a Registered Geologist and Certified Engineering Geologist with over 10 years
experience in characterizing and remediating hazardous waste release sites.  He also teaches
ground water classes as a part-time faculty member for the Environmental Hazard
Management Program of U.C. Davis Extension.
                                  SARAH PICKER
                California EPA Department of Toxic Substances Control

Sarah Picker, P.E., senior hazardous substances engineer with the California Department of
Toxic Substances Control has more than 10 years of technical expertise in hazardous waste
management. She has a Bachelor of Science degree from California State University, Chico.
She has worked extensively in the area of sanitary and landfill design, landfill closure and
post-closure plan regulatory review and approval, implementation of the California
Environmental Quality Act and hazardous waste incineration.
                                DAVID W. RICE, JR.
                       Lawrence Livermore National Laboratory

David Rice is an expert on the fate and transport of contaminants in subsurface soils, ground
water, and the marine environment. He is presently the lead scientist and Project Director in
a team of University  of California collaborators assisting the State of California in re-evalu-
ating the leaking underground fuel tank cleanup decision-making process.

Mr. Rice is an expert in the fate and transport of energy-related contaminants in marine and
terrestrial ecosystems. He has participated in the management of the Lawrence Livermore
National Laboratory (LLNL) Superfund sites.  His current research focus is on the
technologies and information management systems to support time-critical environmental
restoration decisions involving cost/benefit analysis and multiple stakeholders.

Mr. Rice has authored/co-authored over 50 publications.

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                              MOfflNDER S. SANDHU
               California EPA Department of Toxic Substances Control

Mohinder S. Sandhu, P.E., has over sixteen years experience in the hazardous waste
management field.  He received his M.S. in Civil Engineering form the University of
California, Berkeley in 1977. He is a registered Professional Civil Engineer.  He is currently
Chief of the Facility Permitting Branch of the California Department of Toxic Substances
Control Region 4 Office in Long Beach, California. His responsibilities include a wide
spectrum of technical  and managerial assignments in the permitting, surveillance and
enforcement and site mitigation programs.


                                 RONALD C. SIMS
                               Utah State University

Ronald C. Sims, Ph.D., Professor and Head  of the Division of Environmental Engineering at
Utah State University, has more than 20 years of technical experience in vadose zone
characterization, treatment,  and monitoring.  Dr. Sims has a Ph.D/in Biological and
Agricultural Engineering  from North Carolina State University.  He has worked for the
University of North Carolina at Chapel Hill, Mobay Chemical Corporation, SC, and Research
Triangle Institute, NC, and  was a visiting engineer at the U.S. EPA NRMRL, Robert  S. Ken-
Laboratory, Ada, Oklahoma, 1989-1990.
                                 BRIAN M. SMITH
                           Lawrence Berkeley Laboratory

Brian M. Smith, Ph.D., has been using stable isotopes to understand natural processes for
nearly 20 years, first as an exploration research geochemist for Unocal Corporation and more
recently as a Staff Scientist and Environment, Health and Safety Specialist at the Lawrence
Berkeley Laboratory.  Dr. Smith has a Ph.D. in geology from Brown University, where he
studied the geochemical consequences of interactions between waters and rocks in high
temperature geothermal systems. Dr. Smith's current interests are to stimulate the use of
stable isotopes in low temperature hydrogeologic systems, where they can be particularly
useful in site characterization and monitoring programs and environmental management
efforts.

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                                 DANIEL STRALKA
                    UJS. Environmental Protection Agency, Region 9

 Dan received his Ph.D. in biochemistry at the University of Texas at Houston in 1984 and
 then served on active duty with the Army Medical Research and Development Command for
 6 years.  He has been with the Superfund Technical Support Section in Region 9 since 1991
 as a Regional lexicologist. He has worked on review and oversight of Federal facilities and
 closing bases throughout the region.
                              HAROLD A. TUCHFELD
                                GeoSyntec Consultants

 Harold A. Tuchfeld, R.E.A., is a project manager, geochemist, and health risk assessor with
 over 18 years environmental consulting experience. His project management and regulatory
 experience spans a wide range of projects, including site contamination evaluations and
 remediation, risk assessment, hazardous waste management facility permitting, operational
 hazardous waste regulation compliance studies at industrial plants, facility
 closure, litigation support, and agency negotiation and liaison. Mr. Tuchfeld has an extensive
 working knowledge of RCRA, particularly in the area of Part B permitting, compliance.
 closure, and in the  application of corrective action  to RCRA facilities. He holds an M.S. in
 Environmental Health Sciences from University of Michigan at Ann Arbor and B.S. in Earth
 and Space Sciences from the State University of New York at Stoney
 Brook.
                                PATRICK WILSON
                   U.S. Environmental Protection Agency, Region 9

Patrick Wilson, Ph.D., M.P.H., is a Regional Toxicologist assigned to the Corrective Action
Section of the Hazardous Waste Management Division at the United States Environmental
Protection Agency, Region DC office in San Francisco. California. Dr. Wilson has a Ph.D. in
Environmental Toxicology with a minor in Pathology from the UCLA School of Medicine.
His Ph.D. research was conducted in the laboratory of Dr. John Froines, and focused on the
molecular pharmacokinetics and biblogical monitoring of chemical carcinogens (aromatic nitro
and amine compounds and toluene diisocyanate) found in the industrial and occupational
environment.

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                                 JEFFREY J. WONG
                California EPA Department of Toxic Substances Control

Jeffrey J. Wong, Ph.D., is currently responsible for the development of the scientific basis
and rationale for risk assessment, risk management and risk reduction strategies within the
California Environmental Protection Agency's Department of Toxic Substances Control.  He
has more than 14 years of experience in (1) the  assessment of public health and
environmental effects associated with chemical exposures, (2) the development and
formulation of risk management and reduction strategies and (3) analysis of policy
implications of risk control options.  Dr. Wong has a Ph.D. in Pharmacology and Toxicology
and a Masters of Science degree in Food Science and Technology from the University of
California, Davis.

Upon nomination by the US National Academy  of Sciences, President William J. Clinton
appointed Dr. Wong to the United States Nuclear Waste Technical Review Board.  The US
NWTRB is an independent establishment within the executive branch, which evaluates the
scientific and technical validity of US Department of Energy activities in the spent fuel and
high-level  waste management program and reports it findings, conclusions, and
recommendations to the Congress and the Secretary of Energy.
                                KURT ZEPPETELLO
                    Arizona Department of Environmental Quality

Kurt Zeppetello, R.G., hydrologist for the Hazardous Waste Section of the Arizona
Department of Environmental Quality, has over four years of experience collecting soil and
ground water samples. Kurt holds a M.S. degree in geology from Arizona State University
and a B.S. degree in geochemistry from the State University of New York at Oswego. He
worked in the private sector as a staff geologist for two years before joining the state.
                                   JANE ZEVELY
                                   IT Corporation

Jane Zevely is the Manager of Permitting for IT Corporation's Vine Hill Complex.  A
Certified Hazardous Materials Manager and Registered Environmental Assessor with more
than 12 years experience, Ms. Zevely's professional background is in community and
regulatory agencies relations; permitting, operating, remediating, and closing commercial
hazardous waste treatment, storage and disposal facilities; spill response; hazardous waste
transportation; and reduction in use of polychlorinated biphenyls in electrical utility systems.
Ms. Zevely has a bachelors degree in chemistry and a masters degree in environmental
engineering both from California Polytechnic State University, San Luis Obispo.

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 CONFERENCE

REGISTRATION

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                                       1996 EPA Region 9
                               RCRA Corrective Action Conference
                                       March 26-28, 1996
                                                       Page 1
Gerard Abrams
Cal EPA / DTSC Region 1
10151 Croydon Way, Suite 3
Sacramento    CA   95827
Ph.(916)255-3600
Fax (916)255-3595
Waqar Ahmad
Cai EPA / DTSC Region 2
700 Heinz Ave
Berkeley       CA   94710
Ph.(510)540-3932
Fax. (510)540-3937
ahmad@lanminds com
Sheila Alfonso
Cal EPA / DTSC Region 2
700 Heinz Ave.
Berkeley        CA   94710
Ph (510)540-3968
Fax (510)540-3937
Nancy Alvarez
University of Nevada. Reno
1481 Clovis Ct.
Reno           NV   89523
Ph  (702)746-9450
Fax
Fernando Amador
Cal EPA / OTSC Region 4
245 W Broadway Ste 425
Long Beach     CA   90802
Ph. (310) 590-4894
Fax:(310)590-4870
Glenn Anderson
Texaco
10 Universal Cily Plaza
Universal City    CA    91608
Ph  (818)505-2680
Fax. (818) 505-4600
Brian Andraski
USGS
333 W NyeLn  #203
Carson City      NV   89706
Ph  (702)887-7636
Fax (702) 887-7629
andrasKi@usgs gov
Ravi Arulanantfiam
Cat EPA / RWOCB Region 2
2101 Webster St. Ste. 500
Oakland        CA   94612
Ph (510)286-1331
Fax:(510)286-1380
Waller Bahm
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph (510) 540-3957
Fax (510) 540-3939
Karen Baker
Cal EPA / DTSC Region 4
245 W Broadway Ste 425
Long Beach    CA   90802
Ph (310)590-4944
Fax (310)590-5511
Samuel Bandrapalli
Cal EPA / RWQCB Region 2
2101 Webster SI Ste. 500
Oakland        CA    94612
Ph (510)286-1035
Fax:(510)286-1380
Douglas Bauhsta
Cal EPA / DTSC Region 4
245 W Broadway Ste 425
Long Beach     CA    90802
Ph.(310)590-4893
Fax (310) 590-4870
Kalhy Baylor
US EPA Region 9
75 Hawthorne Street fH-3-1)
San Francisco   CA    94105
Ph (415) 744-2028
Fax (415)744-1044
baylor katherme@epamail epa gov
Sallv Bilodeau
EMCON
3300 N San Fernando Blvd
Burbank        CA    91504
Ph (818)841-1160
Fax (818) 846-9280
sbilodeau@emconmc com
 Shernl! Beard
 Cal EPA / DTSC Region 4
 245 W Broadway. Sle 425
 Long Beach     CA    90802
 Ph (310)590-5528
 Fax. (310)590-5511
 Paula Bisson
 US EPA Region 9
 75 Hawthorne St H-3-2
 San Francisco   CA    94105
 Ph.(415)744-2064
 Fax (415)744-1044
 Martene Bennett
 BMP Melbourne Laboratory
 Box 264 Clayton Sth
 Victoria               3169
 AUSTRALIA
 Ph 61395454757
 Fax 61 3 9561 6709
 Bennett.lvlarleneML@bhp.aa com

 Ned Black
 US EPA Region 9
 75 Hawthorne Street, (H-6-4)
 San Francisco   CA   94105
 Ph (415)744-2253
 Fax (415) 744-1797
John Blasco
Harding Lawson Associates
PO Box 6107
Novato         CA    94948-
Ph (415)884-3125
Fax (415) 884-3300
|blasco@harding com
 Mary Blevins
 US EPA Region 9
 75 Hawthorne Street (H-3-2)
 San Francisco   CA   94105
 Ph  (415)744-2069
 Fax (415)744-1044
 blevms mary@epamail epa gov
 Phil Blum
 Cal EPA / DTSC Region 2
 700 Heinz Ave
 Berkeley        CA    94710
 Ph  (510) 540-3965
 Fax (510) 540-3937

-------
                                        1996 EPA Region 9
                               RCRA Corrective Action Conference
                                        March 26-28, 1996
                                                       Page 2
Marilyn Blume
Harding Lawson Associates
105 Digital Drive
NovatO         CA    94949
Ph: (415) 884-3124
Fax (415)864-3300
Timothy Bodkin
Radian International
PO Box 962
Montara        CA   94037
Ph  (415)728-1345
Fax
               Max Boone
               Tosco Refining Company
               Avon Refinery
               Martinez       CA   94553
               Ph -.(510)370-3361
               Fax:(510)372-3179
Larry Bowerman
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA   94105
Ph-(415) 744-2051
Fax. (415) 744-1044
Glenn Brown
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph-(510)540-3961
Fax (510)540-3937
Justin Bradley
United Defense LP
1125ColemanAve.
San Jose       CA  "95103
Ph (408)389-0874
Fax (408) 289-0877
Justin_bradley@fmc.com

Pratap Bulsara
Cal EPA / DTSC Region 4
245 W. Broadway Ste. 425
Long Beach     CA   90802
Ph (310)590-4952
Fax-(310)590-4870
               James Breitlow
               Envt. Management & Compliance Services
               607 Ventura St
               Richmond      CA    94805
               Ph: (510)232-5828
               Fax:(510)232-5828
               Richard Burzinski
               Rust Environment & Infrastructure
               695 River Oaks Pkwy
               San Jose      CA    95124
               Ph : (408) 232-2800
               Fax:(408)232-2801
Clarence Callahan
US EPA Region 9
75 Hawthorne Street (H-9-3)
San Francisco   CA   94105
Ph  (415)744-2314
Fax (415)744-1797
Peter Chen
Cal EPA / DTSC Region 3
1011 N GrandviewAve
Glendale       CA   91202
Ph (818)551-2906
Fax (818)551-2901
               Rebecca Chou
               Cal EPA / RWQCB
               101 Centre Plaza Dr
               Monterey Park   CA
               Ph: (213) 266-7607
               Fax (213) 266-7600
                     91754
Henry Chiu
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph  (510)540-3960
Fax (510)540-3937
Susan Chiu
US EPA Region 9
75 Hawthorne St H-3
San Francisco   CA   94105
Ph (415)744-2060
Fax. (415) 744-1044
               Wei Wei Chiu
               Cal EPA / DTSC Region 2
               700 Heinz Ave
               Berkeley        CA    94710
               Ph.(510)540-3975
               Fax (510) 540-3937
Sal Cinello
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph  (510)540-3972
Fax (510)540-3937
Gary Colbert
Allwaste. Inc
12475 Llagas Ave
San Martin      CA
Ph  (408)268-1196
Fax (408) 683-0485
95046
Susan Corbaley
SAIC
20 California Street #400
San Francisco   CA   94111
Ph-(415) 399-0140
Fax. (415) 399-0299
Rose Coughlm
Texaco Refining and Marketing, Inc
10 Universal City Plaza
Universal City   CA   91608
Ph  (818)505-2719
Fax (818)505-3820
coughra@texaco com

Peter Day
Phillips Petroleum Co
6551 S Revere Pkwy 0155
Engtewood      CO   80111
Ph  (303)784-3909
Fax (303) 784-3940
pcday@bvemx ppco com
Mike Cruz
Guam EPA
P 0 Box 22439-GMF
Barngada       GU    96921
Ph  (671)472-8863
Fax (671)472-9402
 Frank Dellechaie
 Cal EPA / Haz Waste Mngmt Program
 PO Box 806
 Sacramento     CA    95812
 Ph (916)324-9931
 Fax (916) 322-1005
               William Cutler
               FMC Corporation
               1735 Market Street
               Philadelphia    PA
               Ph.(215)299-6206
               Fax'(215) 299-6947
                      19103
               Jeff Denison
               Nevada Depl of Environmental Protection
               333 W Nye Ln
               Carson City     NV    89710
               Ph (702)687-4670
               Fax (702) 885-0868

-------
                                        1996 EPA Region 9
                               RCRA Corrective Action Conference
                                        March 26-28, 1996
                                                        PageS
Arnil Dharmapal
Roy F Weston. Inc
14724 Ventura Blvd. Ste 1000
Sherman Oaks   CA    91403
Ph: (818) 971-4912
Fax. (818) 971-4901
 Martina Diaz
 Cal EPA / DTSC Region 4
 245 W. Broadway Ste. 425
 Long Beach     CA   90802
 Ph  (310)590-5559
 Fax (310) 590-4870
                 Enc Dielhelm
                 IT Corporation
                 4585 Pacheco Blvd
                 Martinez       CA
                 Ph-(510) 372-9100
                 Fax (510)372-5220
                     94553
RlCO Duazo
Cal EPA / RWOCB Region 2
2101 Webster St. Ste 500
Oakland        CA    94612
Ph: (510)286-0837
Fax:(510)286-3981
 Michael Dunbavan
 BMP Hawaii Inc
 P.O. Box 3379
 Honolulu       HI
 Ph (808)547-3341
 Fax. (808) 547-3807
-96842
Jeff Dunn
GeoSyntec Consultants
1600 Riviera Ave. Suite 420
Walnut Creek    CA    94596
Ph : (510) 943-3034
Fax (510)943-2366
Ken Eichstaedt
URS Consultants
100 California St. Ste 500
San Francisco    CA    94111 -4529
Ph: (415) 774-2767
Fax:(415)398-1904
 Joe Eidelberg
 US EPA Region 9
 75 Hawthorne St (P-3-2)
 San Francisco   CA   94105
 Ph: (415) 744-1536
 Fax.
                 Keith Elliot
                 Cal EPA / RWQCB
                 101 Centre Plaza Dr
                 Monterey Park   CA    91754
                 Ph- (213) 266-7614
                 Fax. (213) 266-6787
Nancy Emerson
Unocal
376 S Valencia Ave
Brea           CA    92621
Ph  (714)577-2952
Fax (714) 577-2960
certnle@uoccent unocal com

Mary Esper
Dames & Moore
221 Mam Street. Ste. 600
San Francisco   CA    94105
Ph.(415)243-3852
Fax (415)882-9261
 Kenneth J Enckson P.E.
 US EPA Region 9
 75 Hawthorne Street (H-9-3)
 San Francisco  sCA   94105
 Ph: (415) 744-2324
 Fax-(415) 744-1797
 Brad Esslmger
 Woodward-Clyde Consultants
 500 12th Street, Ste 100
 Oakland       CA    94607-4014
 Ph : (510) 874-3284
 Fax:(510)874-3268
                 Elena Espada
                 Rust Environment & Infrastructure
                 695 River Oaks Pkwy
                 San Jose      CA    95134
                 Ph (408)232-2828
                 Fax (408) 232-2801
                 Maria Fabella
                 Cal EPA / DTSC Region 3
                 1011 N GrandviewAve
                 Glendale        CA    91201
                 Ph-(818) 551-2918
                 Fax. (818) 551-2901
Ade Fagorala
Cal EPA / RWQCB Region 2
2101 Webster St Ste 500
Oakland        CA    94612
Ph  (510)286-0602
Fax (510) 286-1380
- Michael Feeley
 US EPA Region 9
 75 Hawthorne Street (H-3)
 San Francisco   CA    94105
 Ph: (415) 744-2138
 Fax (415)744-1044
                 Naomi Feger
                 SAIC
                 20 California Street #400
                 San Francisco   CA    94111
                 Ph  (415)399-0140
                 Fax (415)399-0299
Craig Fletcher
PG&E
245 Market St # 1219
San Francisco   CA    94105
Ph  (415)972-5894
Fax (415)973-7668
Jamshid Ghazansh
Cal EPA / DTSC Region 3
1011 N Grandview Ave
Glendale        CA    91201
Ph  (818)551-2871
Fax (818)551-2901
 Stephen Fok
 PG&E
 245 Market St # 1217
 San Francisco    CA    94105
 Ph (415)973-4735
 Fax (415)973-7668
 Mike Gill
 US EPA Region 9. H-9-2
 75 Hawthorne Street. H-9-2
 San Francisco    CA    94105
 Ph  (415)744-2385
 Fax (415)744-1916
                 Richard Gailley
                 PACNAV-Facihties Engineering
                 Bldg 258 Makalapa
                 Pearl Harbor    HI    96860
                 Ph-(808) 471-0507
                 Fax (808)474-4519
                 rgaitley@eldpac navfac navy mil

                 Watson Gin
                 Cal EPA / DTSC Headquarters
                 PO Box 806
                 Sacramento     CA   95812-0806
                 Ph
                 Fax- (916) 322-1005

-------
                                         1996 EPA Region 9
                                RCRA Corrective Action Conference
                                         March 26-28. 1996
                                                       Page 4
 Susan Glao'sione
 Cal EPA / RWQCB Region 2
 2101 Webster SI. Ste 500
 Oakland       CA   94612
 Ph • (510) 2B6-0840
 Fax:(510)286-3986
 Ricardo Gonzalez
 Cal EPA / DTSC Region 4
 245 W Broadway Ste. 425
 Long Beach     CA   90802
 Ph (310)590-4877
 Fax (310) 590-4870
Karen Goldberg
US EPA Region 9
75 Hawthorne Street. RC-3
San Francisco   CA   94105
Ph-(415) 744-1382
Fax-(415) 744-1041
goldberg.karen@epamail epa.gov

Matt Hagemann
US EPA Region 9
75 Hawthorne Street (H-9-3)
San Francisco   CA  -94105
Ph-(415) 744-2325
Fax (415) 744-1797
Frank Gonzales
Cal EPA / DTSC Region 4
245 W  Broadway Ste  425
Long Beach     CA    90802
Ph  (310)590-4950
Fax (310)590-5511
Dixie Hambnck
Ogden Environmental
630 N FlorenceSt
BurbanK        CA    91505
Ph  (818)842-0373
Fax. (818) 842-4345
 Mark Haney
 Environmental Science and Engineering 5
 Five Overlook Drive
 Amherst        NH   03031
 Ph (603)672-2511
 Fax. (603) 673-1620
James Hanson
US EPA Region 9
75 Hawthorne Street (H-9-1)
San Francisco   CA   94105
Ph-(415) 744-2237
Fax (415)744-1797
Peggy Harns
Cal EPA / DTSC
400 P Street
Sacramento     CA
Ph  (916)324-7663
Fax-(916) 322-1005
96812-0806
Tony Hashemian
Cal EPA / DTSC Region 1
10151 Croydon Way, Suite 3
Sacramento     CA   95827
Ph (916)255-3587
Fax (916)255-3595
UlyHerskovits
US EPA Region 9
75 Hawthorne Street. H-3-2
San Francisco   CA   94105
Ph.(415)744-2062
Fax. (415) 744-1044
Valerie Heusinkveld
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph  (510)540-3941
Fax (510)540-3937
Helen Hillman
NOAA Hazmat
75 Hawthorne Street. H-9-3
San Francisco   CA   94105
Ph  (415)744-2273
Fax (415)744-3126
helen_hillman@hazmat noaa.gov

Anthony Hoover
U S Naval Activities. N534
PSC 455. Box 152
FPOAP              96540-1000
Ph  (671)339-7052
Fax (671)339-4363
Dave Hodges
US EPA Region 9
75 Hawthorne Street. H-9-2
San Francisco   CA   94105
Ph.(415)744-2391
Fax (415)744-1917
M David Hung
Cal EPA / RWOCB
101 Centre Plaza Dr.
Monterey Park   CA   91754
Ph-(213) 266-7611
Fax (213) 266-6787
Sean Hogan
US EPA Region 9
75 Hawthorne Street. H-6-4
San Francisco   CA    94105
Ph  (415)744-2334
Fax (415) 744-1916
hogan sean@epamail epa gov

Maied Ibrahim
Cal EPA / DTSC Region 4
245 W  Broadway Ste  425
Long Beach     CA    90802
Pn  (310) 590-4926
Fax (310) 590-4932
J Mark Inglis
SECOR International
1 Solano Way
Martinez        CA    94553
Ph  (510)370-3240
Fax (510) 372-3179
Jeff Inglis
US EPA Region 9
75 Hawthorne Street, H-8-i
San Francisco   CA   94105
Ph-(415) 744-2348
Fax (415)744-1917
Michel Iskarous
Cal EPA / DTSC Region 3
1011 N Grandview Ave
Glendale       CA    91201
Ph  (818)551-2857
Fax (818)551-2841
Elizabeth Jacobson
Desert Research Institute
PO Box 60220
Reno           NV    89506
Ph  (702)673-7373
Fax (702) 673-7397
britt@maxey dn edu
Iraj Javandel
Lawrence Berkeley National Laboratory
B50E. 1 Cyclotron Rd
Berkeley       CA   94720
Ph  (510)486-6106
Fax. (510)486-5686
Theodore Johnson III
Cal EPA / DTSC Region 4
245 W  Broadway Sle 425
Long Beach     CA   90802
Ph  (310)590-4967
Fax (310) 590-4870

-------
                                         1996 EPA Region 9
                                RCRA Corrective Action Conference
                                         March 26-28, 1996
                                                        Page 5
 Jay Jones
 Ogden Environmental
 5510 Morehouse Drive
 San Diegp      CA   92121
 Pr»-(619) 458-9044
 Fax- (619) 458-0943
 JJoneslV@aol com

 Lester Kaufman
 Cal EPA / DTSC Region 2
 700 Heinz Ave
 Berkeley'      CA   94710
 Ph (510) 540-3974
 Fax (510) 540-3937
 Mark Klaiman
 US EPA Region 9
 75 Hawthorne St, RC-3-1
 San Francisco   CA   94105
 Ph  (415)744-1374
 Fax (415) 744-1040
 klaiman mark@epamail epa.gov

 Jose Kou
 Cal EPA / DTSC Region 3
 1011 N GrandviewAve
 Glendale        CA   91201
 Ph  (818)881-2816
 Fax  (818) 551-2901
 Vicky Lang
 US EPA Region 9
 75 Hawthorne Street (RC-3-2)
 San Francisco   CA    94105
 Ph  (415)744-1331
 Fax (415)744-1040
 Paul Kalaiwaa
 Hawaii Dept of Health
 9l9AlaMoana8lvb «212
 Honolulu        HI     96714-
 Ph  (80S) 586-4237
 Fax-(808) 586-7509
 Tom Kelly
 US EPA Region 9
 75 Hawthorne St  (H-3-1)
 San Francisco   CA   -94105
 Ph: (415) 744-2070
 Fax:(415)744-1044
 kelly.thomas 9 epamail.epa.gov

 William Knight
 Rust Environmental & Infrastructure
 695 River Oaks Pkwy
 San Jose       CA   95134
 Ph . (408) 232-2822
 Fax (408) 232-2801
 Steve Krival
 Cal EPA / DTSC Region Z
 700 Heinz Ave
 Berkeley        VCA   94710
 Ph-(510)540-3959
 Fax (510) 540-3937
 sknval@aol.com

 Denny Larson
 Communities for a Better Environment
 500 Howard St. Ste 506
 San Francisco   CA   94105
 Ph (415)243-8373
 Fax (415)243-8960
 Mitch Kaplan
 US EPA Region 9
 75 Hawthorne Street. H-3-2
 San Francisco   CA   94105
 Ph-(415) 744-2063
 Fax-(415) 744-1044
 Mike Kenning
 Cal EPA / DTSC Region 2
 700 Heinz Ave
 Berkeley       CA   94710
 Ph-(510)540-3759
 Fax. (510) 540-3819
Calden Koehn
Cal EPA /DTSC
1515 Tollhouse Rd
Clovis          CA   93611
Ph: (209) 297-3937
Fax:(209)297-3904
ckoehn@hwl cahwnet.gov

Iryna Kwasny
Heller. Ehrman
333 Bush St
San Francisco   CA   94104
Ph.(415)772-6726
Fax. (415) 772-62 66
Ed Leach
Kleinfelder, Inc.
7133 Koll Center Pkwy. Suite 100
Pleasant Hill     CA   94566
Ph.(510)687-4863
Fax (510)687-3065
Ron Leach
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA    94105
Ph  (415)744-2031
Fax (415)744-1044
Kathenne Leibel
Cal EPA / OTSC Region 4
245 W  Broadway. Ste 425
Long Beach     CA   90802
Ph (310)590-4895
Fax (310) 590-4870
Gary Locke
IT Corporation
4585 Pacheco Blvd
Martinez        CA   94553-2233
Ph  (510)372-9100
Fax (510) 372-5220
C Chow Lee
C Chow Lee & Associates
5100-1B Clayton Rd. Box 285
Concord        CA    94521
Ph (510)827-4958
Fax (510) 689-6249
lrek)ees@aol com

Brian Lewis
Cal EPA / DTSC HQ
PO Box 806
Sacramento     CA    95812-0806
Ph- (916) 323-3632
Fax (916) 327-2509
btewis@hwl cahwnet gov

Helen Lucas
Rust Environment & Infrastructure
695 River Oaks Pkwy
San Jose        CA    95134
Ph («8) 232-2814
Fax (408) 232-2801
helen_lucas@ccmail rustei com
Daisy Lee
Cal EPA / DTSC Region 2
700 Heinz Ave.
Berkeley       CA   94710
Ph.(510)540-3933
Fax. (510) 540-3937
Steve Under
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA   94105
Ph  (415)744-2036
Fax- (415) 744-1044
Mike Mahoney
US EPA Region 9
75 Hawthorne Street (P-3-2)
San Francisco   CA   94105
Ph  (415)744-1495
Fax

-------
                                        1996 EPA Region 9
                                RCRA Corrective Action Conference
                                        March 26-28, 1996
                                                                      Page 6
Michelle Mason
Rust Environment & Infrastructure
695 River Oaks Pkwy
San Jose       CA    95112
Ph: (408) 232-2800
Fax:(408)232-2801
michelle_mason@ccmail.rustei com

Julie Menack
Groundwater Technology
5319 Miles Ave
Oakland        CA    94618
Ph (510)547-2520
Fax:
Tony Morales
Cal EPA / DTSC Region 2
700 Heinz Ave
Berkeley        CA    94710
Ph (510)540-3958
Fax:(510)540-3937
               Richard McJunkin
               Cal EPA / DTSC Region 1
               10151 Croydon Way, Suite 3
               Sacramento     CA   95827
               Ph (916)255-3672
               Fax (916) 255-3697
               Martha Mernam
               Cal EPA / DTSC
               P.O Box 806
               Sacramento     CA   45812-0806
               Ph 1(916)323-3636
               Fax (916) 323-3700
               mmemam® hw1 .cahwnet.gov

               Steve Morse
               Cal EPA / RWQCB Region 2
               2101 Webster St.  Ste. 500
               Oakland        CA    94612
               Ph  (510)286-0304
               Fax:(510)286-1380
                                   Pablo McLoud
                                   Levine-Fncke. Inc
                                   220 S King SI. #1290
                                   Honolulu        HI    96813
                                   Ph  (808)522-0321
                                   Fax-(808) 522-0366
                                   Mana Morales
                                   U.C Berkeley
                                   300 A&F Building
                                   Berkeley        CA   94720
                                   Ph.(510)642-0557
                                   Fax-(510) 642-9442
                                   Moujan Mostaghimi
                                   Cal EPA / OTSC Region 2
                                   700 Heinz Ave
                                   Berkeley       CA   94710
                                   Ph . (510) 540-3942
                                   Fax (510)540-3937
Nicole Moutoux
US EPA Region 9
75 Hawthorne Street, H-3-2
San Francisco   CA   94105
Ph : (415) 744-2034
Fax:(415)744-1044
moutoux nicole@epamail epa gov

Shn Nandan
ESE Inc
4090 Nelson Ave
Concord        CA   94520
Ph  (510)685-4053
Fax-(510) 685-5323
               Roshy Mozafar
               Cal EPA / RWQCB Region 2
               2101 Webster St Ste. 500
               Oakland        CA    94612
               Ph (510)286-1041
               Fax (510) 286-1380
                                   Gary Murchison
                                   Cal EPA / DTSC
                                   400 P Street
                                   Sacramento     CA
                                   Ph  (916)322-0807
                                   Fax (916)324-3107
                                   murch@ix netcom.com
                     95814
               Devender Narala                      Julio Narvaez
               Nevada Dept of Environmental Protection Cal EPA / DTSC Region 3
               555 E Washington Ave, # 4300          1011 N. Grandview Ave
               Las Vegas      NV    89101          Glendale        CA    91201
               Ph (702)486-2872                    Ph (818)551-2923
               Fax- (702) 486-2863                    Fax. (818) 551-2901
Kati Neidig
Turner / Maclane
3511 La Mesa Drive
Hayward        CA
Ph-(510) 881-8811
Fax (510)881-8802
94542
Craig O'Rourke
Geraghty & Miller, Inc
1 Technology Drive, Suite F-213
In/me           CA    92718
Ph  (714)753-0444
Fax (714)753-0945
Elaine Ngo
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA   94105
Ph'(415) 744-2044
Fax (415)744-1044
ngo eiaine@epamail epa gov

Emmanuel Okereke
Cal EPA / RWQCB Region 2
2101 Webster St  Ste. 500
Oakland        CA   94612
Ph  (510)286-3975
Fax (510)286-1380
Mehdi Noban
Cal EPA / DTSC Region 3
1011 N Grandview Ave
Glendale        CA    91201
Ph  (818)551-2924
Fax (818)551-2901
                                                  Ronald Okuda
                                                  Cal EPA / DTSC Region 4
                                                  245 W Broadway Sie  425
                                                  Long Beach     CA    90802
                                                  Ph  (310)590-4885
                                                  Fax (310)590-4901
Kola Olatunbosun
Cal EPA / RWOCB Region 7
73-720 Fred Waring Or
Palm Desert     CA    92260
Ph  (619)776-8930
Fax (619)341-6820
               Don Osterhold
               United Technologies
               P O Box 49028
               San Jose       CA    95161
               Ph (408) 776-5930
               Fax (408) 776-4895
                                   Nancy Oslron
                                   Cal EPA / DTSC
                                   PO Box 806
                                   Sacramento     CA
                                   Ph (916)322-3385
                                   Fax (916)322-1005
                     95812-0806

-------
                                        1996 EPA Region 9
                                RCRA Corrective Action Conference
                                         March 26-28, 1996
                                                        Page?
 Cherry Padilla
 Cal EPA / DISC Region 2
 700 Heinz Ave
 Berkeley       CA   94710
 Ph: (510) 540-3967
 Fax (510)540-3937
 hwl cpadilla@hwl cahwnetgov

 Susan Peterson
 Rust Environment & Infrastructure
 695 River Oaks Pkwy
 San Jose-      CA   95134
 Ph (408)232-2800
 Fax (408) 232-2801
 susan_pelerson@ccmail.rustei.com

 Wayne Praskins
 US EPA Region 9
 75 Hawthorne St. H-6-5
 San Francisco   CA    94105
 Ph (415)744-2256
 Fax (415)744-1797
 praskins wayne@epamail.epa gov

 Ram Ramanujam
 Cal EPA / DISC
 301 Capitol Mall
 Sacramento     CA    95814
 Ph (916)323-3637
 Fax (916)323-3647
 Pat Payne
 Cal EPA / OTSC Region 2
 700 Heinz Ave.
 Berkeley       CA   94710
 Ph: (510) 540-3872
 Fax:(510)540-3891
 Michael Pfister
 CalEPA/DTSC
 1515 Tollhouse Rd.
 Clovis          CA  -93611
 Ph • (209) 297-3934
 Fax-(209) 297-3904
 Bill Pratt
 United Technologies Corp
 P.O. Box 49028
 San Jose       CA   95161
 Ph: (408) 776-4951
 Fax:(408)776-4895
 Michelle Rembaum
 Cal EPA / DTSC Region 2
 700 Heinz Ave
 Berkeley        CA    94710
 Ph: (510) 540-3760
 Fax:(510)540-3819
 Mark Peterson
 US EPA Region 9 (P-3-2)
 75 Hawthorne Street
 San Francisco   CA    94105
 Ph.(415)744-1499
 Fax
 Sarah Picker
 Cal EPA / OTSC Region 2
 700 Heinz Ave
 Berkeley        CA   94710
 Ph: (510) 540-3973
 Fax. (510) 540-3937
 hwl .spicker@hw! .cahwnet gov

 Susan Prentice
 Morrison and Foerster
 345 California Street
 San Francisco   CA   94104
 Ph: (415) 677-6101
 Fax (415)677-7522
David Rice
Lawrence Livermore National Laboratory
PO  Box 808. L-627
Uivermore       CA    94551
Ph  (510)423-5059
Fax
Tony Roberson
U S Navy Public Works Center
PSC 455. Box 195
FPO AP              96540-2937
Ph  (671)339-4100
Fax (671)333-2035
John Robertson
Cal EPA / RWQCB Region 2
2101 Webster St  Ste. 500
Oakland        CA    94612
Ph-(510) 286-0851
Fax. (510)286-3986
Dante Rodriguez
US EPA Region 9
75 Hawthorne St. H-7-1
San Francisco   CA    94105
Ph  (415)744-2239
Fax (415)744-1797
Robert Romero
Cal EPA / DTSC Region 4
245 W Broadway. Ste 425
Long Beach     CA   90802
Ph  (310)590-4890
Fax (310)590-4870
Kalhy San Miguel
Cal EPA / DTSC Region 4
245 W  Broadway. Ste 425
Long Beach     CA   90802
Ph  (310)590-4900
Fax (310) 590-4870
William Rowe
Cal EPA / DTSC
400 P Street. P.O Box 806
Sacramento     CA    95812-0806
Ph-(916) 323-3624
Fax (916)323-3700
wrowe@hwl.cahwnet gov

Yvonne Sanchez
Cal EPA / DTSC Region 3
1011 N  GrandviewAve
Glendale        CA    91201
Ph  (818)551-2870
Fax (818) 551-2901
Roseanne Sakamoto
US EPA Region 9
75 Hawthorne Street (P-3-2)
San Francisco   CA    94105
Ph  (415)744-1535
Fax (415) 744-1604
Mohmder Sandhu
Cal EPA / DTSC Region 4
245 W  Broadway Ste  425
Long Beach     CA    90802
Ph  (310)590-4852
Fax (310)590-4870
Carmen Santos-Prior
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA   94105
Ph  (415)744-2037
Fax (415)744-1044
Ray Saracmo
US EPA Region 9
75 Hawthorne Street (H-3-1)
San Francisco   CA   94105
Ph.(415)744-2040
Fax (415)744-1044
saracino ray@epamail epa gov
Vicky Semones
US EPA Region 9
75 Hawthorne Street (H-1-1)
San Francisco   CA    94105
Ph  (415)744-2184
Fax (415)744-1797

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                                         1996 EPA Region 9
                                 RCRA Corrective Action Conference
                                         March 26-28, 1996
                                                        Page 8
 Robert Senga
 Cal EPA / DTSC Region 4
 245 W Broadway Ste. 425
 Long Beach     CA    90802
 Ph- (310) 590-4882
 Fax. (310) 590-4870
 Wendi Snafu-
 US EPA Region 9
 75 Hawthorne Street (H-3-2)
 San Francisco    CA    94105
 Ph  (415)744-2059
 Fax (415)744-1044
 shafir.wendi@epamail.epa.gov

 Don Shaulis
 Cal EPA / DTSC Region 1
 10151 Croydon Way. Suite 3
 Sacramento     CA    95827
 Ph  (916)255-3592
 Fax. (916) 255-3595
 Julie Small
 Rust Environment & Infrastructure
 695 River Oaks Pkwy
 San Jose       CA   95134
 Ph (408)232-2856
 Fax (408) 232-2801
 Whit Smith
 Rust Environment & Infrastructure
 695 River Oaks Pkwy
 San Jose       CA    95134
 Ph (408) 232-2824
 Fax (408) 232-2801
 Kathy Sedan
 US EPA Region 9
 75 Hawthorne Street H-7-2
 San Francisco   CA   94105
 Ph (415)744-2254
 Fax:(415)744-1797
 Chao Shan
 Lawrence Berkeley National Laboratory
 ESO. Lawrence Berkeley Lab
 Berkeley        CA   -94720
 Ph.(510)486-5718
 Fax  (510) 486-5686
 c.shan 9 lbl.gov

 Zuyi Shen
 Dames & Moore
 1050 Queen St, Ste 204
 Honolulu        HI     96814
 Ph (808)593-1116
 Fax (808) 593-1198
 hon@dames.com

 Barbara Smith
 US EPA Region 9
 75 Hawthorne Street (H-9-2)
 San Francisco  CA    94105
 Ph (415)744-2366
 Fax (415) 744-1917
Brian M. Smith
Lawrence Berkeley National Laboratory
1 Cyclotron Rd (26-109)
Berkeley        CA   94720
Ph  (510)486-6508
Fax (510) 486-4193
 Kevin Shaddy
 Cal EPA / DTSC
 1515 Tollhouse Rd
 Clows          CA   93611
 Ph: (209) 297-3929
 Fax:(209)297-3904
 kshaddy@hwl cahwnet gov

 Tony Shan
 BHP Hawaii Inc
 91-325KomohanaSt.
 Kapolei        HI    96707
 Ph : (808) 547-3804
 Fax: (808) 547-3068
 Ron Sims
 Utah State University
 Civil & Engineering Dept
 Logan         UT   84322-4110
 Ph: (801) 797-2926
 Fax:(801)752-7513
Cindy Smith
Phillips Petroleum Co
5th and Keeler
Bartlesville      OK   74004
Ph (918)661-0185
Fax (918)661-5664
clsmith@bvemx ppco com

Stan Smucker
US EPA Region 9
75 Hawthorne Street (H-9-3)
San Francisco   CA   94105
Ph (415)744-2311
Fax. (415) 744-1797
Charles Snyder
Cal EPA / DTSC Region 1
10151 Croydon Way. Suite 3
Sacramento     CA   95827
Ph (916)255-3581
Fax (916)255-3595
Dan Stralka
US EPA Region 9
75 Hawthorne Street (H-9-3)
San Francisco   CA    94105
Ph  (415)744-2310
Fax (415)744-1797
Conchita Taitano
Guam EPA
PO Box22439-GMF
Barngada       GU   96921
Ph  (671)472-8863
Fax (671)472-9402
Susan Solarz
Cal EPA / DTSC HO.
PO Box 806
Sacramento    CA   95812-0806
Ph  (916)324-1799
Fax (916)327-4495
James Strandberg
Woodward-Clyde Consultants
500 12th Street, Ste. 100
Oakland       CA   94607-4014
Ph  (510)874-3041
Fax (510)874-3268
|fstranO@wcc com

Harry Takach
James Stettler
Cal EPA / DTSC FPB
700 Heinz Ave
Berkeley       CA   94710
Ph : (510) 540-3936
Fax:(510)540-3937
jstettler@hw1 cahwnet gov

Greg Sweel
Cal EPA / DTSC Region 4
245 W. Broadway Ste 425
Long Beach     CA   90802
Ph  (310) 590-5504
Fax (310)590-5511
John Tang
Environmental Science and Engineering 1 United Defense LP
5440 N Cumberland Ave #111
Chicago        IL    60656
Ph  (312)693-6030
Fax (312) 693-6039
ll25Coleman Ave
San Jose       CA
Ph  (408)289-2903
Fax (408) 289-0877
|ohn_lang@lmc com
95103

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                                         1996 EPA Region 9
                                RCRA Corrective Action Conference
                                         March 26-28. 1996
                                                        Page 9
 David Tao
 Cal EPA / DISC Region 2
 700 Heinz Ave
 Berkeley       CA   94710
 Ph (510)540-3934
 Fax (510)540-3937
 Guy Tomassom
 US EPA Headquarters
 401 M Street SW/5303W
 Washington     DC   20460-
 Ph (703)308-8622
 Fax
 Hal Tuchfeld
 Geosyntec Consultants
 1600 Riviera Ave Ste. 420
 Walnut Creek   CA   94596
 Ph.(510)943-3034
 Fax  (510)943-2366
 Randy Ueshiro
 Rockwell International
 6633 Canoga Ave  MS 5514
 Canoga Park   CA   91303
 Ph  (818)586-6015
 Fax. (818) 586-5889
 Farshad Vakili
 Cal EPA / DTSC Region 1
 10151 Croydon Way. Suite 3
 Sacramento     CA  -95827
 Ph.(916)255-3612
 Fax  (916)255-3595
 Eduardo Vallesteros
 Cal EPA / DTSC Region 4
 245 W Broadway. Ste 350
 Long Beach     CA   90806
 Ph (310)590-4876
 Fax (310)590-4870
 Sue Vedantham
 Laidlaw Environmental Services
 1040 Commercial St. Suite 109
 San Jose       CA   95112
 Ph  (408)451-5012
 Fax. (408) 453-6045
 Patricia Wagner
 Chevron USA
 575 Market St. Room 2778
 San Francisco   CA   94105-3901
 Ph (415)894-0929
 Fax (415)894-3037
 Ed Vigil
 Phibro-Tech, Inc.
 8851 Dice Road
 Santa Fe       CA   90670
 Springs
 Ph-(310)698-8036
 Fax. (310) 698-1921

 Douglas Waltermire
 IT Corporation
 4585 Pacheco Blvd
 Martinez        CA   94553
 Ph (510)372-9100
 Fax (510)372-5239
Brian Waggle
Hargis & Associates
1400 E Southern Ave. Ste 600
Tempe         AZ    85282
Ph  (602)345-0888
Fax (602) 780-0508
Peter wan
United Defense LP
1125 Coleman Ave
San Jose       CA    T5103
Ph • (408) 289-4285
Fax (408) 289-0877
 Anthony Ward
 Geraghty & Miller, Inc
 100 N Barranca Ave  Ste 500
 WestCovma    CA    91791
 Ph (818)332-8010
 Fax (818)331-1224
Carl Warren
US EPA Region 9
75 Hawthorne Street (H-3-2)
San Francisco   CA   94105
Ph  (415)744-2067
Fax (415)744-1044
Adela Weinstem
Cal EPA / DTSC Region 4
245 W Broadway. Ste 425
Long Beach     CA    90B02
Ph  (310)590-5556
Fax (310)590-4870
Phil Whitmore
Arizona Dept ot Environmental Quality
3033 N Central Ave
Phoenix        AZ    85012
Ph  (602)207-4423
Fax (602) 207-4236
Allen Wmans
Cal EPA / DTSC Headquarters
PO Box 806
Sacramento     CA   95812-0806
Ph  (916)323-3646
Fax (916)323-3700
Jeff Wong
Cal EPA / DTSC OSA
10151 Croydon Way
Sacramento     CA   94827
Ph
Fax
Rick Wilson
Camp Dresser & McKee
18881 Von Kofman, Ste 650
Irvine           CA    92715
Ph-(714) 752-5452
Fax (714)752-1307
wilsonrg@cdm com

Charlie Wittman
Rust Environment & Infrastructure
695 River Oaks Pkwy
San Jose       CA    95134
Ph  (408)232-2800
Fax (408) 232-2801
charhe_wittman ©ccmail rustei com

David  Wright
Cal EPA / DTSC - OMF
10151  Croydon Way
Sacramento     CA    95827-2106
Ph  (916)255-3664
Fax (916) 255-3697
Patrick Wilson
US EPA Region 9
75 Hawthorne Street. H 3-1
San Francisco   CA    94105
Ph  (415)744-2038
Fax (415) 744-1044
Alfred Wong
Cal EPA / DTSC Region 2
700 Hemz Ave
Berkeley        CA    94710
Ph  (510)540-3946
Fax (510) 540-3937
Emad Yemut
Cal EPA / DTSC Region 4
245 W Broadway Ste  425
Long Beach     CA    90802
Ph  (310)590-4915
Fax (310)590-4932

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                                       1996 EPA Region 9
                               RCRA Corrective Action Conference
                                        March 26-28. 1996
                                                       Page 10
Chia Rtn Yen
Cal EPA / DTSC Region 4
245 W  Broadway Ste 425
Long Beach     CA   90802
Ph : (310) 590-5557
Fax (310) 590-4870
Damta Yocum
US EPA Region 9
75 Hawthorne Street (RC-3-2)
San Francisco   CA    94105
Ph-(415) 744-1347
Fax
     Yoshn
US EPA Region 9
75 Hawthorne Street (H-W-1)
San Francisco   CA    94105
Ph: (415) 744-1730
Fax. (415) 744-1797
Margie Youngs
Cal EPA / DTSC
4740 Robertson Ave
Carmichael      CA    95608
Ph  (916)323-3634
Fax (916)323-3647
Abdul Yusufzai
Cal EPA / RWQCB Region 2
2101 Webster St. Ste. 500
Oakland       CA  -94612
Ph-(510)286-0377
Fax. (510)286-1380
Zahra Zahiraleslamzadeh
United Defense LP
1125 Coleman Ave.
San Jose       CA    95103
Ph.(408)289-3141
Fax- (408) 289-0877
Michael Zamudio
Cal EPA / DTSC
P.O. Box 806
Sacramento     CA    95812
Ph • (916) 323-3634
Fax. (916) 323-3392
Jane Zevely
IT Corporation
4585 Pacheco Blvd
Martinez        CA    94553
Ph  (510)372-4427
Fax (510)372-5220
Alfredo Zanoria
Cal EPA/DTSC Region 4
245 W. Broadway Ste 425
Long Beach     CA   90802
Ph (310)590-5538
Fax. (310) 590-5511
Nahid Zouestiagh
US EPA Region 9
75 Hawthorne Street. H-3-2
San Francisco   CA   94105
Ph: (415) 744-2052
Fax. (415) 744-1044
Kurt Zeppetello
Arizona Dept. of Env Quality
3033 N. Central Avenue
Phoenix        AZ    85012
Ph: (602)207-4410
Fax: (602) 207-4236
kjz@ev.state.az.us

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                    1996 Corrective Action Conference
                             Speakers
         Name
       Organization
Brian Andraski
Ravi Arulanantham
Karen Baker
Kathy Baylor
Paula Bisson
Ned Black
Larry Bowerman
Clarence Callahan
Jeff Dunn
Michael Feeley
Watson Gin
Matt Hagemann
James Hanson
Valerie Heusinkveld
Theodore Johnson II
Denny Larson
Ron Leach
Brian Lewis
Richard McJunkin
Steve Morse
Sarah Picker
David Rice
Mohinder Sandhu
Ray Saracino
Ron Sims
Brian M. Smith
Stan Smucker
Dan Stralka
Guy Tomassoni
Hal Tuchfeld
Patrick Wilson
Jeff Wong
Laura Yoshu
Kurt Zeppetello
Jane Zevely
USGS
Cal EPA / RWQCB Region 2
Cal EPA / DTSC Region 4
US EPA Region 9
US EPA Region 9
US EPA Region 9
US EPA Region 9
US EPA Region 9
GeoSyntec Consultants
US EPA Region 9
Cal EPA / DTSC Headquarters
US EPA Region 9
US EPA Region 9
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 4
Communities for a Better Environment
US EPA Region 9
Cal EPA/DTSC HQ
Cal EPA/DTSC Region 1
Cal EPA / RWQCB Region 2
Cal EPA / DTSC Region 2
Lawrence Livermore National Laboratory
Cal EPA / DTSC Region 4
US EPA Region 9
Utah State University
Lawrence Berkeley National Laboratory
US EPA Region 9
US EPA Region 9
US EPA Headquarters
Geosyntec Consultants
US EPA Region 9
Cal EPA/DTSC OSA
US EPA Region 9
Anzona Dept. of Env. Quality
IT Corporation     	

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1996 Corrective Action Conference
    Regulatory Attendees
Name
Phil Whitmore
Peggy Harris
Calden Koehn
Martha Merriam
Gary Murchison
Nancy Ostron
Michael Pfister
Ram Ramanujam
William Rowe
Kevin Shaddy
Margie Youngs
Michael Zamudio
David Wright
James Stettler
Susan Solarz
Allen Winans
Gerard Abrams
Tony Hashemian
Don Shaulis
Charles Snyder
Farshad Vakili
Waqar Ahmad
Sheila Alfonso
Walter Bahm
Phil Blum
Glenn Brown
Henry Chiu
Wei Wei Chiu
Sal Ciriello
Lester Kaufman
Mike Kenning
Steve Krival
Daisy Lee
Tony Morales
Moujan Mostaghimi
Cherry Padilla
Pat Payne
Michelle Rembaum
David Tao
Alfred Wong
Peter Chen
Maria Fabella
Jamshid Ghazansh
Michel Iskarous
Jose Kou
Julio Narvaez
Mehdi Noban
Yvonne Sanchez
Fernando Amador
Douglas Bautista
Shernll Beard
Pratap Bulsara
Martina Diaz
Frank Gonzales
Ricardo Gonzalez
Majed Ibrahim
Katherme Leibel
Ronald Okuda
Robert Romero
Organization
Arizona Dept. of Environmental Quality
Cal EPA / DTSC
Cat EPA / DTSC
Cal EPA / DTSC
Cal EPA / DTSC
Cal EPA / DTSC
Cal EPA / DTSC
Cal EPA / DTSC
Cal EPA /DTSC
Cal EPA / DTSC
Cal EPA /DTSC
Cal EPA / DTSC
Cal EPA/ DTSC - OMF
Cal EPA / DTSC FPB
Cal EPA/ DTSC HQ
Cal EPA / DTSC Headquarters
Cal EPA / DTSC Region 1
Cal EPA / DTSC Region 1
Cal EPA / DTSC Region 1
Cal EPA / DTSC Region 1
Cal EPA / DTSC Region 1
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 2
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 3
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4
Cal EPA / DTSC Region 4

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                    1996 Corrective Action Conference
                       Regulatory Attendees
              Name
             Organization
Kathy San Miguel
Robert Senga
Greg Sweel
Eduardo Vallesteros
Adela Weinstein
Emad Yemut
Chia Rm Yen
Alfredo Zanona
Frank Dellechaie
Rebecca Chou
Keith Elliot
M. David Hung
Samuel Bandrapalli
Rico Duazo
Ade Fagorala
Susan Gladstone
Roshy Mozafar
Emmanuel Okereke
John Robertson
Abdul Yusufzai
Kola Olatunbosun
Mike Cruz
Conchita Taitano
Paul Kalaiwaa
Helen Hillman
Jeff Denison
Devender Narala
Mary Blevins
Susan Chiu
Joe Eidelberg
Kenneth J. Erickson P.E.
Karen Goldberg
Lily Herskovits
Dave Hodges
Sean Hogan
Jeff Inglis
Mitch Kaplan
Tom Kelly
Mark Klaiman
Vicky Lang
Steve Lmder
Mike Mahoney
Micole Moutoux
Elaine Ngo
Wayne Praskms
Dante Rodriguez
Roseanne Sakamoto
Carmen Santos-Prior
Vicky Semones

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                     1996 Corrective Action Conference
                        Facility / Industry Attendees
               Name
              Organization
Gary Colbert
Michael Dunbavan
Tony Shan
Marlene Bennett
C. Chow Lee
Rick Wilson
Patricia Wagner
Mary Esper
Zuyi Shen
Elizabeth Jacobson
Sally Bilodeau
Shri Nandan
Harry Takach
Mark Haney
James Breitlow
William Cutler
Craig O'Rourke
Anthony Ward
Julie Menack
John Blasco
Marilyn Blume
Brian Waggle
Iryna Kwasny
Eric Diethelm
Gary Locke
Douglas Waltermire
Ed Leach
Sue Vedantham
I raj Javandel
Chao Shan
Pablo McLoud
Susan  Prentice
Dixie Hambnck
Jay Jones
Richard Gaitley
Craig Fletcher
Stephen Fok
Ed Vigil
Peter Day
Cindy Smith
Timothy Bodkin
Randy  Ueshiro
Amil Dharmapal
Richard Burzmski
Elena Espada
Helen Lucas
Michelle Mason
Susan  Peterson
Julie Small
Whit Smith
Charlie Wittman
William Knight
Susan Corbaley
Naomi  Feger
J Mark Inglis
Glenn Anderson
Allwaste. Inc.
BMP Hawaii Inc.
BHP Hawaii Inc.
BHP Melbourne Laboratory
C. Chow Lee & Associates
Camp Dresser & McKee
Chevron USA
Dames & Moore
Dames & Moore
Desert Research Institute
EMCON
ESE Inc.
Environmental Science and Engineering 1
Environmental Science and Engineering 5
Envt. Management & Compliance Services
FMC Corporation
Geraghty & Miller, Inc.
Geraghty & Miller, Inc.
Groundwater Technology
Harding Lawson Associates
Harding Lawson Associates
Hargis & Associates
Heller, Ehrman
IT Corporation
IT Corporation
IT Corporation
Klemfelder, Inc.
Laidlaw Environmental Services
Lawrence Berkeley National Laboratory
Lawrence Berkeley National Laboratory
Levme-Fncke, Inc.
Morrison and Foerster
Ogden Environmental
Ogden Environmental
PACNAV-Facihties Engineering
PG&E
PG&E
Phibro-Tech, Inc.
Phillips Petroleum Co.
Phillips Petroleum Co.
Radian International
Rockwell International
Roy F. Weston, Inc
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environment & Infrastructure
Rust Environmental & Infrastructure
SAIC
SAIC
SECOR International
Texaco

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                     1996 Corrective Action Conference
                        Facility / Industry Attendees
               Name
             Organization
Rose Coughlm
Max Boone
Kati Neidig
Mana Morales
Anthony Hoover
Tony Roberson
Ken Eichstaedt
Justin Bradley
John Tang
Peter Wan
Zahra Zahiraleslamzadeh
Don Osterhold
Bill Pratt
Nancy Emerson
Brad Esslinger
James Strandbera
Texaco Refining and Marketing, Inc.
Tosco Refining Company
Turner /Maclane
U.C. Berkeley
U.S. Naval Activities, N534
U.S. Navy Public Works Center
URS Consultants
United Defense LP
United Defense LP
United Defense LP
United Defense LP
United Technologies
United Technologies Corp.
Unocal
Woodward-Clyde Consultants
Woodward-Clyde Consultants	

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