vvEPA
United States
Environmental Protection
Agency
Dynamic Field Activity Case Study:
Initial Site Screening, Callaway Drum Recycling Site

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Office of Solid Waste and
Emergency Response (5201G)
EPA 540/R-03/14
OSWER No. 9200.1-49
January 2004
              Dynamic Field Activity Case Study:
                     Initial Site Screening,
                 Callaway Drum Recycling Site

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                                      Notice

This document has been funded by the United States Environmental Protection Agency (EPA)
under Contract 68-W-02-033. The document was subjected to the Agency's administrative and
expert review and was approved for publication as an EPA document. Mention of trade names
or commercial products does not constitute endorsement or recommendation for use.

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                             Acknowledgments

The Office of Emergency and Remedial Response would like to acknowledge and thank the
individuals who reviewed and provided comments on the draft documents. Reviewers include
EPA headquarters, EPA Region 4, Florida Department of Environmental Protection, and the site
contractor, Ecology and Environment, Inc.

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                                  Contents
Exhibits	iv

Abbreviations  	 v

Abstract  	 1

Background  	 1

Project Goal and Objectives	 3

Field Activities	 4
      Soil Screening 	 4
      Surface and Subsurface Soil Sampling  	 6
      Groundwater Screening	 6
      Monitoring Well Installation 	 6
      Groundwater Sampling  	 7

Site Investigation Results	 7

Benefits of Dynamic Field Activity	 8

Lessons Learned  	 9

References	 10
                                      in

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                                 Exhibits
Exhibit                                                                 Page

1     Map of Callaway Drum Recycling Site  	 2
2     Sampling Locations at Callaway Drum Recycling Site	 5
                                     IV

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                                  Abbreviations
bgs          below ground surface
CDR         Callaway Drum Recycling
CERCLA    Comprehensive Environmental Response, Compensation, and Liability Act
DP          direct-push
EPA         U.S. Environmental Protection Agency
FDEP        Florida Department of Environmental Protection
FIRS         Hazard Ranking System
IRA         interim remedial action
L            liter
|ig/L         microgram per liter
mg/L         milligram per liter
mL          milliliter
NPL         National Priorities List
NTU         nephelometric turbidity units
PA/SI        preliminary assessment/site inspection
QA/QC      quality assurance/quality control
SARA       Superfund Amendments and Reauthorization Act
SCTL        soil cleanup target level
SOWS       secondary drinking water standards
SVOC       semivolatile organic compound
TAL         target analyte list
TCL         target compound list
TVA         total organic vapor analyzer
VOA         volatile organic analysis
VOC         volatile organic compound

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                      Dynamic Field Activity Case Study:
                              Initial Site Screening,
                         Callaway Drum Recycling Site
Abstract

       The Florida Department of Environmental Protection (FDEP) used a dynamic field
activity to conduct an initial site screening on the Callaway Drum Recycling (CDR) site in Polk
County, Florida, during 2001.  The dynamic field activity combined on-site data generation with
on-site decision making.  Colorimetric analysis provided the in-field data that were used to
identify and quantitate potential contaminants in shorter time frames and at less cost than those
needed for sample analysis by offsite fixed laboratories.  The resulting report saved the FDEP
significant amounts of time and money by providing them with the data they needed to negotiate
a Consent Order with the property owner.  As a result, the FDEP minimized the resources they
needed to invest in the site and remediation activities began much sooner than would have
otherwise occurred.
Background

       The CDR site consists of 10.66 acres of vacant property located in a rural residential and
agricultural area north of Auburndale, Florida. Adams Packing Association, Inc. has owned the
property since 1947. Although little historical information was available to the initial site
screening team, municipal records indicated that CDR conducted drum recycling operations at
the site prior to 1971 until about 1979. Aerial photographs suggested that excavations began in
approximately 1958, but did not reveal any drum recycling operations until 1971.  No permanent
structures currently exist on the property, the majority of which is densely vegetated.

       Former recycling operations may account for several manmade features and areas of
debris at the site (Exhibit 1). A large excavated area that encompasses a series of ditches and
berms running north-south is located in the northwest section of the site.  The remains of many
drums were observed in this area during the field investigation. A similarly excavated area
containing both drum remains and crushed aluminum cans was observed in the site's southwest
section. Interviews with former employees indicated that drums were unloaded from vehicles on
the western portion of the property, where any remaining contents were poured on the ground.
Two large east-west running trenches are located in the southeastern section of the site.

       The main drum reconditioning operations may have taken place in the eastern half of the
site, where many drums, reconditioning equipment, a large pile of pallets, and 100-gallon-plus
open-top containers were observed. A former employee described a drum reconditioning
process whereby the drums were emptied onto the ground, taken to the reconditioning areas for
rinsing

                                           1

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                                                           Exhibit 1
                                        Map of Callaway Drum Recycling Site
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 6W Groundwater Sample
 SS  Surface Soil Sample
 SB  Subsurface Soil Sample
 TW Temporary Monitoring
 BW           Monitoring Well

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and cleaning, placed on racks to dry, and straightened and repainted for sale.  The former
employee noted that some drums were labeled as caustic and corrosive, but the source and
contents of the drums were unknown.

       The City of Auburndale operates six wells within a 4-mile radius of the site. This well
system collectively serves a population of nearly 32,000 people.  In addition, 49 community and
non-community well systems exist within 4 miles of the site, collectively serving nearly 7,000
people.  Three private wells are known to exist within 0.25 miles of the site, and additional
private wells may exist within the 4-mile radius  of the site. In 2001, a total of 24,909 people
resided within the 4-mile radius.

       The aquifer system at the site consists of a 50- to 60-foot thick surficial aquifer of quartz
sands and clays overlying a 100-foot thick intermediate system of discontinuous sand, limestone,
and dolomite beds.  Semi-confining clay layers separate the intermediate aquifer from the
surficial aquifer and the underlying regional aquifer (Floridan).  The Floridan is the local source
of public water supplies. The  surficial aquifer is used for irrigation and livestock in the area but
not for potable water. Depth to water at the site is 3 to 10  feet below ground  surface (bgs).
Project Goal and  Objectives

       The FDEP conducted the initial site screening with funding from the U.S. EPA
Superfund program. As such, the screening was called a preliminary assessment/site inspection
(PA/SI) and was designed to determine whether further action at the site was warranted in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA). One of the major aspects of this process was to obtain information necessary for
preparing a Hazard Ranking System (HRS) evaluation. The objectives of the PA/SI were to:

•      Identify previous investigations and other background information;
•      Further define the site characteristics and contaminant sources, including waste type and
       volume;
•      Determine the human population, sensitive environments, and fisheries that are
       threatened or potentially threatened by releases of hazardous materials from the site;
•      Identify contaminant migration pathways and HRS data gaps;
•      Confirm preliminary HRS data and identify the number of samples and sampling
       locations required to fill HRS data gaps;
•      Define the nature of the contamination; and
•      Provide FDEP and EPA with the necessary information to make decisions on other
       actions that may be needed at the site.

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Field Activities

       During the PA/SI, colorimetric analysis of soil and groundwater samples in the field
allowed the project team to tentatively identify and quantitate the chlorinated ethene contaminant
class within a short time.  The availability of analytical results during the initial field screening
gave project managers a field-based decision-making capability to target locations for
subsequent sampling of surface soil, subsurface soil, and groundwater. These samples were to be
analyzed at an offsite laboratory.

       Project managers from FDEP and the contractor selected soil and groundwater screening
locations based on field observations and the site history. Field screening activities included:

•      Sampling continuously seventeen 8- to 12-foot boreholes using direct-push (DP)
       technology (Exhibit 2);
•      Collecting surface and subsurface soil samples from each boring for contaminant
       screening; and
•      Collecting and analyzing groundwater grab samples from each boring.
Soil Screening

       Soil screening was conducted by collecting continuous 4-foot soil cores from the ground
surface to the water table (ranging from 4 to 9 feet below the ground surface) at the 17 sampling
locations. Each of the 4-foot core samples were cut into two 2-foot sections. A soil sample was
collected from each of the two sections for field screening a colorimetric screening method
(Color Tec) for total chlorinated ethenes and a total organic vapor analyzer (TVA).  Visual and
olfactory observations also were noted. A total of 106 soil samples were screened by the Color
Tec method for chlorinated ethenes as well as with the TVA.

       Although, the Color Tec method produces a moderate degree of quantitative information
(i.e., approximate concentrations), the primary intent was to provide fast, low-level, low cost,
decision-quality data that could maximize sampling frequency and sample coverage to identify
hot spots. Once these areas of concern are identified, more expensive definitive analytical
methods, such as GC/MS, can be more effectively focused on target areas to confirm the results
and accurately quantify the levels of contaminants present.

       A description of the Color Tec method used at CDR is available on an EPA website
(EPA, 2003a). The method combines the use of colorimetric gas detector tubes with sample
purging to detect very low (ppb-range) concentrations of chlorinated compounds in groundwater
and soil samples. Groundwater (or a soil and water mixture) is placed in a  standard 40 mL
volatile organic analysis (VOA) vial, leaving approximately 30% of headspace, and capped.
After heating the sample to 40ฐ C, a manual vacuum pump, two hollow needles, and Tygonฎ
tubing are used to purge the contaminant vapors from the sample and send the vapor through the
colorimetric gas detector tube.  The tips of the needles are positioned so that one is in the

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                         Exhibit 2
Sampling Locations at Callaway Drum Recycling Site
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       Face of Power Pole
       Elevation = 147.96
KEY:
IW
MW
SB
TW
Irrigation We!
Monitoring Well          |
Subsurface Soil Sample    |
Temporary Monitoring Well
                    /SB
                    C6
                         Lot 107 •
                                                                (Estimated Location;
                                                                Not Surveyed)
                            1/2 Lot 108
                                  /CSV
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         Site Benchmark #2
         Set Nail & Disk |
         "SSMC TRAV PT"
         in SW Corner of a 2'x2'
         Concrete     Aroynd
         MWA2 —-—1
         Elevation = 149,58

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headspace and the other is submerged at the bottom of the vial.  As air passes from the headspace
through one needle, ambient air is drawn into the bottom of the vial through the other needle.

       Each colorimetric tube typically contains a catalyst that decomposes chlorinated ethenes,
releasing hydrogen chloride and discoloring the (4-phenylazodiphenylamine) reagent in the tube.
Any color change within the detector tube indicates the presence of chlorinated compounds.
This method is capable of detecting chlorinated ethenes near or below regulatory levels.

       At the CDR site, approximately 10 grams of soil were collected at each core depth and
mixed with approximately 10 mL of analyte-free water in a 40-mL VOA vial.  Field personnel
could quickly quantitate the total chlorinated ethenes present in the soil by observing color
changes in the tube. This capability avoided the additional time and dollars required for
laboratory analysis of soil samples collected from each of the 17 boreholes.
Surface and Subsurface Soil Sampling

       Based on the field screening results obtained through Color Tec analysis and TVA, six
surface soil and six subsurface soil samples were collected at points on or near the CDR site that
were suspected of containing contaminant hot spots. Control samples were collected at two
offsite locations. Using a stainless steel bucket auger, surface soil samples were collected 0 to 2
feet bgs.  Subsurface samples were collected from the 2-foot interval above the water table at
each borehole, at depth ranges of 2 to 4 feet bgs to 6 to 8 feet bgs. Each sample was submitted to
the FDEP central laboratory in Tallahassee, Florida, for analysis of target compound list (TCL)
analytes, target analyte list metals, and cyanide.  For quality assurance/quality control (QA/QC)
purposes, two duplicate, one equipment rinsate, and three trip blank samples were collected and
analyzed in conjunction with surface and subsurface soil sampling.
Groundwater Screening

       Groundwater grab samples were collected at a depth approximately 5 feet below the
water table at each of the 17 DP boreholes.  To collect the samples, a well screen with a
retractable steel casing was advanced to a desired depth where the casing was retracted to expose
the screened section, thus allowing water to enter.  A peristaltic pump equipped with Teflon
tubing was used to sample the groundwater.  These grab samples were field screened using the
Color Tec method and the TVA. Again, by observing the tube color changes, total chlorinated
ethenes in the 17 samples could be tentatively identified and quantitated without offsite
laboratory analysis.
Monitoring Well Installation

       Although the PA/SI work plan proposed five on-site monitoring wells, field screening
results from the DP boreholes and colorimetric analysis indicated that only four on-site locations

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exhibited significant contamination. In October 2001, four permanent monitoring wells were
installed in the surficial aquifer to depths of 10 to 14.5 feet bgs using DP methods. The earlier
results of groundwater and soil field screening were used directly in the field to determine the
location of each of the four monitoring wells in areas of suspected hot spots. An additional well
for background monitoring was installed on an adjacent property south of the CDR site, and
another more temporary background well was installed downgradient on the adjacent property to
the north.  Installing four, rather than five, permanent monitoring wells reduced project costs
significantly both in terms of installation and future sampling and analysis costs.
Groundwater Sampling

       Groundwater samples were collected from each of the permanent and temporary
monitoring wells (Exhibit 1) using low-flow sampling methodologies. Prior to sampling, at least
three well volumes were purged from each monitoring well.  The pH, specific conductance,
turbidity, and temperature were recorded after each well volume was removed. If these
parameters did not stabilize after the removal of three well volumes, purging continued.
Turbidity levels for all groundwater samples were below 10 nephelometric turbidity units
(NTU).

       Each sample was shipped to the FDEP central laboratory for analysis of TCL analytes,
target analyte list (TAL) metals, and cyanide.  For QA/QC purposes, one duplicate groundwater
sample, one groundwater sampling equipment rinsate blank sample, and two trip blanks were
collected during groundwater sampling and shipped for FDEP laboratory analysis.  In addition,
the Polk County Department of Health collected four groundwater samples from private supply
wells in the site vicinity and submitted them (with two trip blanks) for analysis to the Florida
Department of Health's laboratory in Jacksonville, Florida.
Site Investigation Results

       Surface soil analytical results indicated the presence of 14 metals at concentrations
greater than the minimum quantitation limit.  Calcium, iron, lead, manganese, and zinc were
detected in surface soil samples at concentrations significantly exceeding the background
concentrations, but none exceeded their respective soil cleanup target level (SCTL).  Although
pesticides and PCBs also were detected in the samples, their concentrations did not exceed
SCTLs. Chlorinated herbicides, organonitrogen/phosphorus pesticides, and volatile organic
compounds (VOCs) were not detected in any of the surface soil samples. While semivolatile
organic compounds (SVOC), such as bis (2-ethylhexyl) phthalate and butyl benzyl phthalate,
were detected at concentrations below SCTLs, isophorone exceeded the SCTL for teachability
based on groundwater criteria.  Similar results were reported with subsurface soil samples,
however, none of the concentrations exceeded their SCTL.

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       Groundwater analytical results of samples taken from the CDR site monitoring wells
found 19 metals. Aluminum concentrations (ranging from 2,040 |ig/L to 7,570 |ig/L) exceeded
the federal and state secondary drinking water standards (SDWS) of 50-200 |ig/L and 200 |ig/L,
respectively. In addition, the highest concentration of iron (7,360 |ig/L) and manganese (194
|ig/L) exceeded the respective federal and state SDWS of 300 jig/L and 50 |ig/L. Other metals
exceeding background concentrations included boron (717 |ig/L), chromium (7.9 |ig/L),
magnesium (5.5 mg/L), potassium (40 mg/L), sodium (150 mg/L), vanadium (33.3  |ig/L), and
zinc (66 |ig/L).

       Groundwater analytical results of ethylbenzene, PCE, and toluene exceeded the federal
and state primary drinking water standards. The highest concentrations of ethylbenzene, PCE,
and toluene were 1,300 |ig/L, 7,300 |ig/L, and 3,300 |ig/L, respectively.

       The PA/SI report (completed in March 2002), concluded that drum recycling operations
at the CDR site resulted in contamination of groundwater, surface soil, and subsurface soil on the
CDR site and potentially groundwater northwest of the site.  The results of the HRS evaluation
indicated that the potential for contaminant release to the Floridan aquifer is sufficient to place
the site on the National Priorities List (NPL),  primarily  due to the high number of potential
drinking water targets within 4 miles of the site.
Benefits of Dynamic Field Activity

       The dynamic field activity allowed the FDEP to rapidly evaluate the CDR site, begin the
remediation process, and minimize the overall program cost.  Within 6 months of the field work,
a PA/SI report was provided to FDEP and within one year of receiving the report, they had
negotiated a Consent Order with the potential responsible party (PRP).  The conditions of the
Consent Order required the PRP to:

•      Implement corrective action according to FDEP guidelines;
•      Prepare and submit an Interim Remedial Action (IRA)/Source Removal Plan, including
       plans to remove contaminated groundwater from Area A within 45 days of the order;
•      Implement the IRA/Source Removal Plan within 45 days of FDEP approval;
•      Submit an IRA/Source Removal Report that includes plans for additional assessment of
       contaminated groundwater;
•      Implement an approved Contamination Assessment Plan and submit a Contamination
       Assessment Report;
•      Reimburse FDEP $3,500 for a portion of expenses incurred in conducting the PA/SI; and
•      Notify the public  about the Consent Order in a widely distributed publication.

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       The total cost for the field work of the PA/SI was $9,443. This figure includes:

•      Labor: 2.5 days for 3 people  	$5,375
       DP rig: 2.5 days @ $l,500/day  ....  $3,750
•      Color Tec analysis: 106 samples ...   $318
This figure does not include the cost of fixed laboratory analysis for 12 soil, 6 water, and several
associated QA/QC samples which were performed by FDEP at their own facility.

       If FDEP and their contractor had used a more traditional rigid work plan in which sample
locations were selected without on-site analysis, the likelihood of discovering the severity of
contamination and its potential risk to drinking water wells would have been much less. Without
the amount and quality of data generated during the dynamic PA/SI, negotiations with the PRP
would have been delayed while another sampling event was  planned and implemented.
Consequently, the dynamic field activity with its rapid data generation and on-site decision
making saved time and money while also helping to prevent further degradation of drinking
water aquifers.
Lessons Learned

•      Dynamic field activities employing colorimetric analysis can effectively lower analytical
       expenses and overall costs for site investigations.

•      Field-based decision making can successfully reduce project duration by eliminating
       unnecessary field and fixed laboratory activities.

•      The Color Tec procedure needs to be performed by experienced field operators to
       minimize the possibility of missing very subtle color changes or misinterpreting water-
       induced false positives in test results compiled in the field.

•      The Color Tec procedure is best used to identify the presence of a class of contaminants
       and "hot spots."

•      The overwhelming data provided by dynamic field activities can facilitate negotiations
       with PRPs.

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                                    References
Ecology and Environment, Inc. 2002. Hazard Ranking System Evaluation for the Callaway
Drum Recycling Site, Auburndale, Polk County, Florida.  Florida Department of Environmental
Protection, Tallahassee, Florida.

Ecology and Environment, Inc. 2002. Preliminary Assessment/Site Inspection Report for the
Callaway Drum Recycling Site, Auburndale, Polk County, Florida.  Florida Department of
Environmental Protection, Tallahassee, Florida.

U.S. EPA. 2003 a. Standard Operating Procedures for Analysis of Total Chlorinated Ethenes in
Soil and Groundwater Using the Color Tec Screening Method.
http://www.epa.gov/superfund/programs/dfa/download/colortec_sop.pdf

U. S. EPA. 2003b. Using Dynamic Field Activities for On-Site Decision Making: A Guide for
Project Managers. EPA/540/R-03/002, OSWER Directive No. 9200.1-40. Office of Solid
Waste and Emergency Response, Washington, D.C.
http://www.epa.gov/superfund/programs/dfa/guidoc.htm
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