OSWER DIRECTIVE 9502.00-6D
INTERIM FINAL
RCRA FACILITY INVESTIGATION (RFI) GUIDANCE
VOLUME I OF IV
DEVELOPMENT OF AN RFI WORK PLAN
AND GENERAL
CONSIDERATIONS FOR RCRA FACILITY
INVESTIGATIONS
EPA 530/SW-89-031
MAY 1989
WASTE MANAGEMENT DIVISION
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
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OSWER DIRECTIVE 9502.00-6D
INTERIM FINAL
RCRA FACILITY INVESTIGATION (RFI) GUIDANCE
VOLUME I OF IV
DEVELOPMENT OF AN RFI WORK PLAN
AND GENERAL
CONSIDERATIONS FOR RCRA FACILITY
INVESTIGATIONS
EPA 530/SW-89-031
MAY 1989
WASTE MANAGEMENT DIVISION
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
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ABSTRACT
On November 8, 1984, Congress enacted the Hazardous and Solid Waste
Amendments (HSWA) to RCRA. Among the most significant provisions of HSWA are
§3004(u), which requires corrective action for releases of hazardous waste or
constituents from solid waste management units at hazardous waste treatment,
storage and disposal facilities seeking final RCRA permits; and § 3004(v), which
compels corrective action for releases that have migrated beyond the facility
property boundary. EPA will be promulgating rules to implement the corrective
action provisions of HSWA, including requirements for release investigations and
corrective measures.
This document, which is presented in four volumes, provides guidance to
regulatory agency personnel on overseeing owners or operators of hazardous waste
management facilities in the conduct of the second phase of the RCRA Corrective
Action Program, the RCRA Facility Investigation (RFI). Guidance is provided for the
development and performance of an investigation by the facility owner or operator
based on determinations made by the regulatory agency as expressed in the
schedule of a permit or in an enforcement order issued under §3008(h), §7003,
and/or §3013. The purpose of the RFI is to obtain information to fully characterize
the nature, extent and rate of migration of releases of hazardous waste or
constituents and to interpret this information to determine whether interim
corrective measures and/or a Corrective Measures Study may be necessary.
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DISCLAIMER
This document is intended to assist Regional and State personnel in exercising
the discretion conferred by regulation in developing requirements for the conduct
of RCRA Facility Investigations (RFIs) pursuant to 40 CFR 264. Conformance with this
guidance is expected to result in the development of RFIs that meet the regulatory
standard of adequately detecting and characterizing the nature and extent of
releases. However, EPA will not necessarily limit acceptable RFIs to those that
comport with the guidance set forth herein. This document is not a regulation (i.e.,
it does not establish a standard of conduct which has the force of law) and should
not be used as such. Regional and State personnel must exercise their discretion in
using this guidance document as well as other relevant information in determining
whether an RFI meets the regulatory standard.
Mention of company or product names in this document should not be
considered as an endorsement by the U.S. Environmental Protection Agency.
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ACKNOWLEDGEMENTS
This document was developed by the Waste Management Division of the
Office of Solid Waste (OSW). George Dixon was the EPA Work Assignment Manager
and Art Day was the Section Chief. Additional assistance was provided by Lauris
Davies and Paul Cassidy.
Guidance was also provided by the EPA RFI Work Group, including:
George Furst, Region I Janette Hansen, OSW
Andrew Bellina, Region II Lisa Feldt, OERR
William Smith, Region II Stephen Botts, OECM
Jack Potosnak, Region III Chris DeRosa, OHEA
Douglas McCurry, Region IV James Durham, OAQPS
Francine Norling, Region V Mark Gilbertson, OWPE
Lydia Boada Clista, Region VI Nancy Hutzel, OGC
Karen Flournoy, Region VII Steve Golian, C) ERR
Larry Wapensky, Region VIII Dave Eberly, OSW
Julia Bussey, Region IX Jackie Krieger, OSW
Melanie Field, Region IX Lisa Lefferts, OSW,
Jim Breitlow, Region IX Lisa Ratcliff, OSW
Paul Day, Region X Florence Richardson, (OSW
David Adler, OPPE Reva Rubenstein, OSW
Joanne Bahura, OSW Steve Sisk, NEIC
NUS Corporation and Alliance Technologies, Inc. assisted OSW in developing
this document, in partial fulfillment of Contract Nos. 68-01-7310 and 68-01-6871,
respectively. Tetra Tech, Inc. and La bat Anderson, Inc. also provided assistance.
Principal contributors included:
Todd Kimmell, NUS Tom Grieb, Tetra Tech
Kurt Sichelstiel, NUS Nick Pangaro, Alliance
William Murray, NUS Linda Marler, Alliance
Ron Stoner, NUS Andrea Mysliki, Labat Anderson
Dave Navecky, NUS
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RCRA FACILITY INVESTIGATION (RFI) GUIDANCE
VOLUME I
DEVELOPMENT OF AN RFI WORK PLAN AND GENERAL CONSIDERATIONS
FOR RCRA FACILITY INVESTIGATIONS
TABLE OF CONTENTS
PAGE
SECTION
ABSTRACT
DISCLAIMER
ACKNOWLEDGEMENTS
iv
TABLE OF CONTENTS
xiv
VOLUME II, III AND IV CONTENTS
xv
TABLES
xvi
FIGURES
xvii
LIST OF ACRONYMS
xix
SUMMARY
IV
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VOLUME I CONTENTS (Continued)
SECTION PAGE
1.0 OVERVIEW OF THE RCRA CORRECTIVE ACTION 1-1
PROGRAM
1.1 INTRODUCTION 1-1
1.2 OVERALL RCRA CORRECTIVE ACTION PROCESS 1-4
1.3 PURPOSE OF THE RCRA FACILITY INVESTIGATION i_n
(RFI) GUIDANCE
1.4 ORGANIZATION OF THIS DOCUMENT 1-12
1.5 REFERENCE INFORMATION 1-12
1.6 GUIDANCE CHANGES DESCRIPTION , 1_14
1.7 CORRECTIVE ACTION REGULATIONS 1-18
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VOLUME I CONTENTS (Continued)
SECTION PAGE
2.0 THE RFI WORK PLAN 2-1
2.1 INTRODUCTION 2-1
2.2 PREPARATION OF AN RFI WORK PLAN 2-1
2.2.1 Description of Current Conditions 2-3
2.2.1.1 Facility Background 2-3
2.2.1.2 Nature and Extent of Contamination 2-5
2.2.1.3 Implementation of Interim Corrective 2-9
Measures
2.2.2 Schedule for Specific RFI Activities 2-9
2.2.3 Procedures for Characterizing the Contaminant 2-10
Source and the Environmental Setting
2.2.3.1 Contaminant Source Characterization 2-10
2.2.3.2 Environmental Setting Characterization 2-18
2.2.4 Monitoring and Data Collection Procedures 2-18
2.2.5 Assembling Existing Data to Characterize the 2-20
Contaminant Release
2.2.6 Quality Assurance/Quality Control (QA/QC) 2-21
Procedures
2.2.7 Data Management and Reporting Procedures 2-22
2.2.8 Identification of Potential Receptors 2-22
2.2.9 Health and Safety 'Procedures 2-25
2.3 IMPLEMENTATION OF THE RFI WORK PLAN 2-25
2.4 EVALUATION BY THE REGULATORY AGENCY 2-26
VI
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VOLUME I CONTENTS (Continued)
SECTION PAGE
3.0 GENERAL STRATGEGY FOR RELEASE INVESTIGATION 3-1
3.1 INTRODUCTION 3-1
3.2 PHASED STRATEGY FOR RELEASE INVESTIGATIONS 3-2
3.3 DATA QUALITY AND USE 3-3
3.4 PROCEDURES FOR CHARACTERIZING THE 3-4
CONTAMINANT SOURCE AND THE ENVIRONMENTAL
SETTING
3.4.1 Sources of Existing Information 3-4
3.4.2 Waste and Unit Characterization 3-6
3.4.3 Characterization of the Environmental Setting 3-7
3.4.4 Assembling Available Monitoring Data 3-9
3.5 USE OF MODELS 3-9
3.5.1 General Applications 3-9
3.5.2 Ground-Water Modeling 3-12
36 FORMULATING METHODS AND MONITORING 3-16
PROCEDURES
3.6.1 Monitoring Constituents and Indicator 3-16
Parameters
3.6.2 Use of EPA and Other Methods 3-24
3.6.3 Sampling Considerations 3-27
3.6.3.1 General Sampling Considerations 3-28
3.6.3.2 Sample Locations and Frequency 3-29
3.6.3.3 Judgmental Sampling 3-30
3.6.3.4 Systematic or Random Grid Sampling 3-30
3.6.3.5 Types of Samples 3-31
3.6.4 Analytical Methods and Use of Detection Limits 3-34
3.7 RFI DECISION POINTS 3-35
VII
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VOLUME I CONTENTS (Continued)
SECTION PAGE
4.0 QUALITY ASSURANCE/QUALITY CONTROL PROCEDURES 4-1
4.1 OVERVIEW 4-1
4.2 QA/QC PROGRAM DESIGN 4-2
4.3 IMPORTANT CONSIDERATIONS FOR A QA/QC 4-3
PROGRAM
4.3.1 Selection of Field Investigation Teams 4-3
4.3.2 Laboratory Selection 4-5
4.3.3 important Factors to Address 4-6
4.4 QA/QC OBJECTIVES AND PROCEDURES 4-9
4.4.1 Data Quality and Use 4-9
4.4.2 Sampling Procedures 4-14
4.4.3 Sample Custody 4-15
4.4.4 Calibration Procedures 4-16
4.4.5 Analytical Procedures 4-17
4.4.6 Data Reduction, Validation, and Reporting 4-18
4.4.7 Internal Quality Control Checks 4-18
4.4.8 Performance and Systems Audits 4-20
4.4.9 Preventive Maintenance 4-20
4.4.10 Corrective Action for QA/QC Problems 4-21
4.4.11 Quality Assurance Reports to Management 4-22
4.5 REFERENCES 4-22
VIM
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VOLUME I CONTENTS (Continued)
SECTION PAGE
5.0 DATA MANAGEMENT AND REPORTING 5-1
5.1 DATA MANAGEMENT 5-1
5.2 DATA PRESENTATION 5-1
5.2.1 Tables 5-2
5.2.1.1 Listed (Raw) Data 5-2
5.2.1.2 Sorted Summary Tables 5-7
5.2.2 Graphic Presentation of Data 5-9
5.2.2.1 Bar Graphs and Line Graphs 5-9
5.2.2.2 Area or Plan Views (Maps) 5-12
5.2.2.3 Isopach Maps 5-14
5.2.2.4 Vertical Profiles or Cross-Sections 5-14
5.2.2.5 Three-Dimensional Data Plots 5-22
5.3 DATA REDUCTION 5-22
5.3.1 Treatment of Replicates 5-22
5.3.2 Reporting of Outliers 5-22
5.3.3 Reporting of Values Below Detection Limits 5-25
5.4 REPORTING 5-25
IX
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VOLUME I CONTENTS (Continued)
SECTION PAGE
6.0 HEALTH AND SAFETY 6'1
6.1 OVERVIEW 6-1
6.2 APPLICABLE HEALTH AND SAFETY REGULATIONS 6'2
AND GUIDANCE
6.3 ELEMENTS OF A HEALTH AND SAFETY PLAN 6-19
6.4 USE OF WORK ZONES 6-2°
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VOLUME I CONTENTS (Continued)
SECTION PAGE
7.0 WASTE AND UNIT CHARACTERIZATION
7-1
7.1 OBJECTIVES AND PURPOSES OF WASTE AND UNIT 7-1
CHARACTERIZATION
7.2 WASTE CHARACTERIZATION 7-3
7.2.1 Identification of Relevant Information 7-3
7.2.1.1 EPA Waste Listing Background 7-4
Document Information
7.2.1.2 Facility Information 7-6
7.2.1.3 Information on Physical/Chemical 7-7
C haracteristics
7.2.1.4 Verification of Existing Information 7-9
7.2.2 Waste Sampling 7-9
7.2.3 Physical/Chemical Waste Characterization 7-10
7.3 UNIT CHARACTERIZATION 7-11
7.4 APPLICABLE WASTE SAMPLING METHODS 7-12
7.4. I Sampling Approach 7-12
7.4.2 Sampling Solids 7-12
7.4.3 Sampling Sludges 7-17
7.4.4 Sampling Liquids 7-19
XI
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VOLUME I CONTENT-S (Continued)
SECTION PAGE
8.0 HEALTH AND ENVIRONMENTAL ASSESSMENT 8-1
8.1 OVERVIEW 8-1
8.2 HEALTH AND ENVIRONMENTAL ASSESSMENT 8-2
PROCESS
8.3 DETERMINATION OF EXPOSURE ROUTES 8-4
8.4 HEALTH AND ENVIRONMENTAL CRITERIA 8-7
8.4.1 Derivation of Health and Environmental Criteria 8-7
8.4.2 Use of Criterion Values 8-13
8.5 EVALUATION OF CHEMICAL MIXTURES' 8-18
8.6 EVALUATING DEEP SOIL AND SEDIMENT 8-20
CONTAMINATION AND USE OF STATISTICAL
PROCEDURES FOR EVALUATING GROUND-WATER
CONTAMINATION
8.6.1 Deep and Surficial Soil Contamination 8-20
8.6.2 Sediment Contamination 8-23
8.6.3 Use of Statistical Procedures for Evaluating 8-24
Ground-Water Contamination
8.7 QUALITATIVE ASSESSMENT AND CRITERIA 8-26
8.8 INTERIM CORRECTIVE MEASURES 8-27
8.9 REFERENCES 8-32
8.10 CRITERIA TABLES AND WORKSHEETS 8-33
8.10.1 Criteria Tables 8-33
8.10.2 Worksheets 8-59
XII
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VOLUME I CONTENTS (Continued)
SECTION PAGE
APPENDICES
Appendix A: Aerial Photography, Mapping, and Surveying A-1
Appendix B: Monitoring Constituents and Indicator B-1
Parameters
List 1: Indicator Parameters Generally
Applicable to Specific Media
List 2: 40 CFR 264 Appendix IX Constituents
Commonly Found in Contaminated
Ground Water and Amenable to
Analysis by EPA Method 6010-
Inductively Coupled Plasma (ICP)
Spectroscopy (Metals) and by Method
8240 (Volatile Organics)
List 3: Monitoring Constituents Potentially
Applicable to Specific Media
List 4: industry-Specific Monitoring
Constituents
RFI GUIDANCE FEEDBACK FORM
XIII
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VOLUME II, III AND IV CONTENTS
VOLUME II: SOIL, GROUND WATER AND SUBSURFACE GAS RELEASES
Soil - Section 9
Ground Water - Section 10
Subsurface Gas - Section 11
Appendix C - Geophysical Techniques
Appendix D - Subsurface Gas Migration Model
Appendix E - Estimation of Basement Air Contaminant
Concentrations Due to Volatile Components in
Ground Water Seeped into the Basement
Appendix F Method 1312: Synthetic Precipitation Leach
Test for Soils
VOLUME III: AIR AND SURFACE WATER RELEASES
Air - Section 1 2
Surface Water - Section 13
Appendix G - Draft Air Release Screening Assessment
Methodology
Appendix H - Soil Loss Calculation
VOLUME IV: CASE STUDY EXAMPLES
Introduction - Section 1 4
Case Studies - Section 1 5
XIV
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TABLES (Volume I)
NUMBER PAGE
2-1 Containment System Evaluation 2-13
2-2 Physical, Chemical and Biological Processes Affecting 2-19
Contaminant Fate and Transport
2-3 Some Potential Inter-media Contaminant Transfer
Pathways 2-24
4-1 Essential Elements of a QA Project Plan 4-4
5-1 Uses of Tables and Graphics in a RFI 5-3
5-2 Useful Data Presentation Methods 5-5
5-3 Sorted Data (Concentration of Volatile Organic
Compounds in Monitoring Well #32) 5-8
5-4 Soil Analyses: Sampling Date 4/26/85 5-10
5-5 Calculation of Mean Values for Replicates 5-24
7-1 Uses and Limitations of EPA Listing Background Documents 7-5
7-2 Sampling Methods Summary for Waste Characterization 7-13
8-1 Some Potential Exposure Routes 8-6
8-2 Intake Assumptions for Selected Routes of Exposure 8-8
8-3 Chemicals and Chemical Groups Having EPA Health Effects 8-16
Assessment (HEA) Documents
8-4 Examples of Interim Corrective Measures 8-30
8-5 Maximum Contaminant Levels (MCLs) Promulgated Under 8-34
the Safe Drinking Water Act
8-6 Health-Based Criteria for Carcinogens 8-35
8-7 Health-Based Criteria for Systemic Toxicants 8-38
8-8 Water Quality Criteria Summary 8-42
8-9 Individual Listing of Constituents Contained Within 8-49
Chemical Groups Identified in Table 8-8
8-10 Drinking Water Standards and Health Advisories 8-51
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FIGURES (Volume 1)
NUMBER PAGE
1-1 RCRA Corrective Action Process 1-5
2-1 RCRA Facility Investigation (RFI) Process 2-2
2-2 Overlapping Plumes from Adjacent Sources that Contain 2-7
Different Wastes
2-3 Discrete Versus Continuous Contaminant Sources 2-16
3-1 Grid Sampling 3-32
3-2 RFI Decision Points 3-36
5-1 Topographic Map Showing Sampling Locations 5-4
5-2 Comparison of Line and Bar Graphs 5-11
5-3 Phenol Concentrations in Surface Soils (ppm = mg/kg) 5-13
5-4 Isopleth Map of Soil PCB Concentrations (ug/kg) 5-15
5-5 Isopleth Map of Diphenylamine Concentrations in the 5-16
Vicinity of a SWMU
5-6 Sand Isopach Map Showing Contours (Isopleths) 5-17
5-7 Cross Section A-A' - Site Subsurface Profile 5-18
5-8 Transect Showing Concentration Isopleths (ug/l) 5-19
5-9 Plan View of Figure 5-7 Showing Offsets in Cross Section 5-20
5-10 Fence Diagram of Stratigraphy and Lead (Pb) 5-21
Concentrations (pprn = mg/kg)
5-11 Three Dimensional Data Plot of Soil PCB Concentrations 5-23
8-1 Hypothetical Facility with individual Solid Waste 8-5
Management Units and a Contaminant Release
Originating From One of the Units
XVI
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LIST OF ACRONYMS
AA
Al
ASCS
ASTM
BCF
BOO
CAG
CPF
CBI
CEC
CERCLA
CFR
CIR
CM
CMI
CMS
COD
COLIWASA
DNPH
DO
DOT
ECD
EM
EP
EPA
FEMA
FID
Foe
FWS
GC
GC/MS
GPR
HEA
HEEP
HPLC
HSWA
HWM
ICP
ID
Kd
Koc
Kow
LEL
MCL
MM5
MS/MS
NFIP
Atomic Absorption
Soil Adsorption Isotherm Test
Agricultural Stabilization and Conservation Service
American Society for Testing and Materials
Bioconcentration Factor,
Biological Oxygen Demand
EPA Carcinogen Assessment Group
Carcinogen Potency Factor
Confidential Business Information
Cation Exchange Capacity
Comprehensive Environmental Response, Compensation, and
Lability Act
Code of Federal Regulations
Color Infrared
Corrective Measures
Corrective Measures Implementation.
Corrective Measures Study
Chemical Oxygen Demand
Composite Liquid Waste Sampler
Dinitrophenyl Hydrazine
Dissolved Oxygen
Department of Transpotiation
Electron Capture Detector
Electromagnetic
Extraction Procedure
Environmental Protection Agency
Federal Emergency Management Agency
Flame lonization Detector
Fraction organic carbon in soil
U.S. Fish and Wildlife Service
Gas Chromatography.
Gas Chromatography/Mass Spectroscopy
Ground Penetrating Radar
Health and Environmental Assessment
Health and Environmental Effects Profile
High Pressure Liquid Chromatography
Hazardous and Solid Waste Amendments (to RCRA)
Hazardous Waste Management
Inductively Coupled (Argon) Plasma
Infrared Detector
Soil/Water Partition Coefficient
Organic Carbon Absorption Coefficient
Octanol/Water Partition Coefficient
Lower Explosive Limit
Maximum Contaminant Level
Modified Method 5
Mass Spectroscopy/Mass Spectroscopy
National Flood Insurance Program
XVII
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LIST OF ACRONYMS (Continued)
NIOSH
NPDES
OSHA
OVA
PID"
pKa
ppb
ppm
PUF
PVC
QA/QC
RCRA
RFA
RfD
RFI
RMCL
RSD
SASS
SCBA
scs
SOP
SWMU
TCLP
TEGD
TOC
TOT
TOX
USGS
USLE
uv
VOST
VSP
WQC
National Institute for Occupational Safety and Health
National Pollutant Discharge Elimination System
Occupational Safety and Health Administration
Organic Vapor Analyzer
Photo lonization Detector
Acid Dissociation Constant
parts per billion
parts per million
polyurethane Foam
Polyvinyl Chloride
Quality Assurance/Quality Control
Resource Conservation and Recovery Act
RCRA Facility Assessment
Reference Dose
RCRA Facility Investigation
Recommended Maximum Contaminant Level
Risk Specific Dose
Source Assessment Sampling System
Self Contained Breathing Apparatus
Soil Conservation Service
Standard Operating Procedure
Solid Waste Management Unit
Toxicity Characteristic Leaching procedure
Technical Enforcement Guidance Document (EPA, 1986)
Total Organic Carbon
Time of travel
Total Organic Halogen
United States Geologic Survey
Universal Soil Loss Equation
Ultraviolet
Volatile Organic Sampling Train
Verticle Seismic Profiling
Water Quality Criteria
XVIII
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SUMMARY
The Hazardous and Solid Waste Amendments (HSWA) to the Resource
Conservation and Recovery Act (RCRA) were enacted into law on November 8, 1984.
One of the major provisions (Section 3004(u)) of these amendments requires
corrective action for releases of hazardous waste or constituents from solid waste
management units (SWMUs) at hazardous waste treatment, storage, or disposal
facilities. Under this provision, any facility applying for a RCRA hazardous waste
management facility permit will be subject to a RCRA Facility Assessment (RFA). The
RFA is conducted by the regulatory agency and is designed to identify SWMUs which
are, or are suspected to be, the source of a release to the environment. If any such
units are identified, the owner or operator of the facility will be directed to perform
a RCRA Facility Investigation (RFI) to obtain information on the nature and extent of
the release so that the need for interim corrective measures or a Corrective
Measures Study can be determined. Information collected during the RFI can also
be used by the owner or operator to aid in formulating and implementing
appropriate corrective measures. Such corrective measures may range from
stopping the release through the application of a source control technique to a full-
scale cleanup of the affected area. In cases where releases are sufficiently
characterized, the regulatory agency may require the owner or operator to collect
specific information needed to implement corrective measures during the RFI.
This document provides the owner or operator with guidance on conducting a
RCRA Facility Investigation. Based on release determinations made by the
regulatory agency (generally resulting from the RFA), the owner or operator of a
facility will be notified, through an enforcement order or permit conditions, of
those unit(s) and releases (known or suspected) which must be further investigated.
This guidance is divided into fifteen sections presented in four volumes.
Volume I presents recommended procedures to follow in developing a work plan
for conducting the investigation. It also describes the criteria that the Agency will
use to interpret the data collected during the RFI. This interpretation is an integral
part of the RFI and is discussed in Section 8, which describes the Health and
Environmental Assessment (HEA) that is conducted by the Agency. The primary
element of the HEA is a set of criteria (chemical concentrations), against which
concentrations of hazardous constituents identified during the release
XIX
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characterization are compared. The health and environmental assessment is used in
determining the need for a corrective Measures Study (CMS) or Interim Corrective
Measures (ICM), and is based primarily on EPA-established chronic-exposure limits.
Volumes II and III describe specific methods for characterizing the nature,
extent, and rate of contaminant release to soil, ground water, subsurface gas, air,
and surface water. Each medium-specific section contains an example strategy for
characterizing releases, which includes characterizing the source and environmental
setting of the release, and conducting a monitoring program that will characterize
the release. Also, each section provides a checklist of information that may be
needed for release characterization, formats for data presentation, and field
methods that may be used in the investigation. Highlights of the medium-specific
sections are provided below.
Section 9 (SOIL)
Gives specific emphasis to the potential for inter-media transfer of
releases from the soil medium to other media;
Explains the significance of surficial soil and deep soil contamination;
and
Highlights the role of leaching tests.
Section 10 (GROUND WATER)
References the RCRA Ground Water Monitoring Technical Enforcement
Guidance Document (TEGD) to characterize site hydrology;
Encourages the use of flow nets for interactive/verifiable site
characterization; and
Focuses on basement seepage as an important pathway for contaminant
migration and exposure.
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Section 11 (SUBSURACE GAS)
Focuses on methane gas from refuse landfills because of its explosive
properties, as well as volatiles from underground tanks;
Emphasizes the importance of subsurface gas as a pathway for inter-
media transport (e. g., transfer of contamination from subsurface gas to
soil and air); and
Presents a subsurface gas migration model, detailed in in Appendix D.
Section 12 (AIR)
Addresses monitoring and modeling of unit emissions and dispersion
modeling for off-site receptors at or beyond the facility property
boundary; and
Provides an air release screening assessment methodology that may be
used as a transition between the general quality determinations made in
the RCRA Facility Assessment (RFA), regarding air emissions that warrant
the actual performance of an RFI.
Section 13 (SURFACE WATER)
Emphasizes the importance of understanding the form and frequency of
releases to surface water and the role of biomonitoring; and
Explains when sampling bottom sediments is important.
Volume IV presents a number of case studies selected to illustrate various
concepts and procedures presented in Volume I, II and III. Most of the case studies
are based on actual sites. In some cases, existing data have been supplemented with
hypothetical data to illustrate a particular point.
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Prior to conducting the investigation, the owner or operator will in most cases
be directed, through a permit or enforcement order, to submit a written plan (the
RFI Work Plan) that should propose, in detail, the manner in which the investigation
will be conducted. Specific components of this plan are defined in Volume i of this
guidance.
In planning the investigation, the owner or operator should consider a logical
progression of tasks that will be followed in investigating the release. Generally,
these tasks will consist of:
Gathering information on the source of the release to the environment
(e.g., gathering information on the unit and the waste in the unit);
Gathering physical information on the environment surrounding the unit
that will affect the migration and fate of the release (e.g., ground-water
flow direction, average windspeeds, soil types); and
Using the above information along with any existing monitoring or
modeling information, to develop a conceptual model of the release,
which will be used to plan and conduct a monitoring program to define
the nature, rate and extent of the release.
The owner or operator should use existing sources of information when these
sources can supply data of the quality and type needed. Information on waste
constituents, for instance, may be available from operational records kept at the
facility in other instances, the owner or operator may propose a waste sampling
and analysis effort to characterize the waste in the unit of concern, thereby
producing new data on the waste. In either case, the owner or operator should
ensure that the data is of the quality necessary to adequately define the release
because such data will be used in determining the need for corrective measures.
Characterizing the release source and the environ-mental setting of the release
will allow the owner or operator to design a monitoring program which will lead to
adequate characterization of the release. This effort may be conducted in phases, if
necessary, with each monitoring phase building on the findings and conclusions of
the previous phase. For example, in those cases where the regulatory agency has
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identified a suspected release, the first phase of the monitoring program may be
directed toward release verification. The level of effort required in an initial
monitoring phase will thus be dictated by the level of knowledge on the release.
The hypothetical examples of this approach given below illustrate that RFIs can vary
widely in complexity and, thus, will not always involve elaborate studies.
A facility contains both active and inactive landfills. All active landfills at
the facility are regulated for ground-water releases under 40 CFR Part
264, Subpart F; however, an inactive unit was identified by the
regulatory agency as being the source of a release to ground water. The
waste in the unit was identified by the owner or operator as being
supplied solely by a single, well-characterized process.
Hydrogeologic information, such as identification of the uppermost
aquifer and ground-water flow direction and rate, were defined in the
RCRA Part B permit application for the active units required for
compliance with Subpart B of 40 CFR Part 270. Environmental
characterization data relevant to the inactive landfill, such as flow
direction and hydraulic gradient, was readily derived from monitoring
wells already installed to comply with the-monitoring requirements of 40
CFR Part 264, Subpart F.
In this case, the owner or operator was able to use existing information
to characterize both the environmental setting and the source of the
release and conduct a limited sampling program, starting with wells near
the inactive unit, to define the release. After installation and sampling
of these initial wells, the owner or operator determined the need for
further well installation and sampling, In this case, the level of effort
required to characterize the release, especially in characterizing the
contaminant source and environmental setting, was minimal due to the
detailed information already available.
In another case, the owner or operator of a commercial facility with an
inactive surface impoundment that had received waste from several
generators was directed to conduct an investigation of a suspected
release to a nearby stream, The suspicion of a release was based on
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several fishkills noted in the stream during periods of heavy rains and
reported observations of impoundment overflow during these periods.
The owner or operator's knowledge of the impoundment's contents was
limited due to the varying wastes managed, and a survey of drainage
patterns around the impoundment had not been performed. Also,
monitoring of the receiving stream itself had not been conducted at the
time of the notification.
In this case, a rather extensive level of effort was required to characterize
the release. Because the waste could not be readily characterized by
direct sampling due to its varying nature over time, the owner or
operator proposed to forego a direct waste characterization effort and
conduct monitoring of the receiving stream for the constituents of
concern. The owner or operator conducted a survey of drainage patterns
around the site, developed a conceptual model of the release, and
established a network of monitoring stations. Initial sampling was
conducted in drains and swales around the unit, with subsequent
monitoring taking place in drainage ditches and eventually the stream
itself, with the design of each sampling effort based on knowledge
gained from the previous effort. In addition, because contamination of
the surface water column coincided with periods of heavy rains,
sampling of the water column was conducted during such periods. The
owner or operator also determined, through analysis of samples
collected in the initial phases, that the waste constituents being released
were highly water soluble and not-l likely to adhere to bottom sediments.
In addition, the owner or operator determined that these constituents
had a low potential to bioaccumulate. Stream sampling, therefore, was
limited to water column samples; bottom sediment and biota sampling
were not performed.
During a visual site inspection conducted by the regulatory agency as
part of the RCRA Facility Assessment, evidence was found that ten drums,
placed in an unrestricted storage area, were releasing their contents to
soils surrounding the area. Evidence observed by the investigative team
included discolored soils and stressed vegetation. The regulatory agency
issued a compliance order requiring the owner or operator to
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immediately remove the drums (as an interim corrective measure) and to
conduct an investigation of the nature and extent of the contamination,
The owner or operator complied with the order for removal and
conducted sampling to characterize the waste in the drums: After
identifying the constituents of the waste, the owner or operator
proposed a work plan to characterize the release, starting with a
screening survey of the area using an organic vapor analyzer (OVA),
followed by the collection of samples in the immediate vicinity of the
drum storage area, then additional sampling at progressively further
distances from the area, if necessary. After collection of three rounds of
sampling, sufficient data had been gathered to adequately define the
extent of the release.
The above three examples illustrate general concepts that may vary on a site-
specific basis.
The owner or operator should understand that the regulatory agency has a
significant oversight responsibility to ensure the protection of human health and
the environment. Accordingly, the regulatory agency may often choose to be
present to observe RFI-related operations, especially field and sampling operations.
Regulatory agency oversight of RFI field work is very important for ensuring a
quality study. In planning and conducting the RFI, therefore, the owner or operator
is encouraged to interact closely with the regulatory agency to assure that the data
supplied during the investigation and, thus, the interpretation of the data, will be
acceptable. The compliance order or permit conditions requiring the investigation
will specify a schedule for conducting the investigation, including the reporting of
data. The owner or operator should keep the regulatory agency advised of the
progress of the investigation, including any delays, and changes to, or deletions of
specific investigation activities.
This document presents guidance specific to the RFI and the RFI process.
General subject areas which are common to many types of hazardous waste
management activities (e. g., quality, assurance and control, sampling, analytical
methods, health and safety procedures), which are also important to the RFI, are
addressed in a summary fashion. More detailed references on these subject areas
are provided.
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This RFI Guidance is tailored to the structure and goals of the RCRA Corrective
Action Program. The RFI process described in-this document parallels the technical
components of the Remedial Investigation (Rl) and removal guidance issued under
the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA). The RFI Guidance has been developed to address releases from operating
as well as inactive and closing units. When such releases have been adequately
characterized, the next step in the RCRA corrective action process can be Initiated
(i.e., determination of the need for corrective measures).
In order to assess the effectiveness of this Guidance Document an "RFI
Feedback Questionnaire, " is provided at the end of Volume I, This feedback will
also help EPA determine the need for additional guidance.
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SECTION 1
OVERVIEW OF THE RCRA CORRECTIVE ACTION PROGRAM
1.1 Introduction
The primary objective of the RCRA corrective action program is to clean up
releases of hazardous waste or hazardous constituents, at treatment, storage, or
disposal facilities subject to Subtitle C of RCRA. "Release" means any spilling,
leaking, pouring, emitting, emptying, discharging, injecting, pumping, escaping,
leaching, dumping, or disposing of hazardous wastes (including hazardous
constituents) into the environment (including the abandonment or discarding of
barrels, containers, and other closed receptacles containing hazardous wastes or
hazardous constituents).
The 1984 Hazardous and Solid Waste Amendments (HSWA) provided EPA with
broad and expanded authorities for ensuring corrective action at facilities subject to
RCRA. Authorities that may be used by EPA to ensure corrective action include:
Section 3004(u) - Corrective Action for Continuing Releases
Section 3004(u) of HSWA requires that permits issued after the date of
enactment of HSWA (November 8, 1984) require corrective action for
releases of hazardous waste or constituents from any solid waste
management unit (SWMU) at any hazardous waste treatment storage,
or disposal facility seeking a permit, regardless of the time at which
waste was placed in the unit.
-. Section 3008(h) - Interim Status Corrective Action Orders
Section 3008(h) of HSWA authorizes EPA to issue orders requiring
corrective action or to take other" appropriate response measures to
protect human health and the environment based on any information
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that there is or has been a release of hazardous waste into the
environment from a facility authorized to operate under Section 3005(e).
Section 3004(v) - Corrective Action Beyond the Facility Boundary
Section 3004(v) authorizes EPA to require that corrective action be taken
by the facility owner or operator beyond the facility property boundary
where necessary to protect human health and the environment, unless
the owner or operator demonstrates that he was unable to obtain
permission to undertake such action.
Section 3005(c)(3) of HSWA (commonly known as the "Omnibus" provision)
gives EPA authority to add to RCRA permits any conditions deemed necessary to
protect human health and the environment.
In addition, Section 3004(n) of HSWA directs EPA to set standards for the
control and monitoring of air emissions at hazardous waste treatment, storage, and
disposal facilities as necessary to protect Human health and the environment. These
standards are presently being developed and will form the overall basis for
regulating air emissions at these facilities. These standards may be used by EPA in
evaluating corrective" measures associated with air releases at solid waste
management units. However, until these standards are sufficiently developed, EPA
will use this RFI Guidance to address air releases that may require corrective
measures.
EPA may also apply RCRA authorities existing prior to the passage of HSWA to
implement the corrective action program. These authorities include RCRA Sections
3013 and 7003. Section 3013 may be used to order an owner or operator to conduct
monitoring, testing, analysis, and reporting at a facility which is or may be releasing
hazardous waste that may present a substantial hazard to human health or the
environment. Section 7003 can be applied where hazardous waste management
activities may present an imminent and substantial endangerment to health or the
environment. Under this provision, the EPA Administrator may bring suit against an
owner or operator to cease activities causing such endangerment or to take other
appropriate action as may be necessary.
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Section 3004(u) has been codified as 40 CFR §264.101. A companion to EPA's
July 15, 1985 (see 50 FR 28702), codification rule specifies additional, information
and data requirements for owners or operators of solid waste management units to
support the conduct of RCRA Facility Assessments by the regulatory agency (see 52
FR 45788 - December 1, 1987). These authorities broaden the scope of the RCRA
corrective action program from detecting and correcting releases to the uppermost
aquifer from regulated units, to cleaning up continuing releases to any media
resulting from other waste management units and practices at RCRA facilities. Prior
to passage of HSWA, EPA exercised its authority under Section 3004 to require
corrective action for releases of hazardous constituents to ground water from only
certain land-based waste management units; 40 CFR Part 264, Subpart F contains
requirements for corrective action at these "regulated units," Regulated units
include surface impoundments, landfills, waste piles, and land treatment units that
received hazardous waste on or after July 26, 1982. Also, EPA applied Sections 3013
and 7003, as appropriate, toward meeting corrective action program objectives.
HSWA expanded RCRA authority to correct releases of hazardous waste or
hazardous constituents to all media at RCRA facilities, and encourages the use of
other authorities, as needed or appropriate, to help achieve corrective action
objectives at these facilities.
Section 3004(u)- of the HSWA corrective action provisions focuses on
investigating releases from solid waste management units (SWMUs). A SWMU is
any discernible unit at which solid or hazardous wastes have been placed at any
time, irrespective of whether the unit was intended for the management of solid or
hazardous wastes. Such units include any area at a facility at which hazardous
wastes or hazardous constituents have been routinely and systematically released.
A SWMU does not include an accidental spill from production areas and units in
which wastes have not been managed (e.g., product storage areas).
This RFI Guidance addresses investigations of all releases from SWMUs
(hereafter also referred to as units) to all media, including soil, ground water,
subsurface gas, air, and surface water. Ground-water releases from regulated units
will continue to be regulated under 40 CFR Part 264, Subpart F.
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1.2 Overall RCRA Corrective Action Process
The RCRA Corrective Action Process consists primarily of the following four
steps: the RCRA Facility Assessment (RFA), the RCRA Facility Investigation (RFI), the
Corrective Measures Study (CMS), and Corrective Measures Implementation (CMI).
A summary of the overall Corrective Action Process for identifying, characterizing,
and correcting releases is presented in Figure 1-1. This process is discussed below.
RCRA facility Assessment (RFA)
Release determinations for all environmental media (i.e., soil, ground water,
subsurface gas, air, or surface water) will be made by the regulatory agency
primarily through the RFA process. The regulatory agency will perform the RFA for
each facility seeking a RCRA permit to determine if there are releases of concern.
The major objectives of the RFA are to:
Identify SWMUs and collect existing information on contaminant
releases; and
Identify releases or suspected releases needing further investigation.
The RFA begins with a preliminary but fairly comprehensive review of
pertinent existing information on the facility. If necessary, the review is followed by
a visual site inspection to verify information obtained in the preliminary review and
to gather information needed to develop a sampling plan. A sampling visit is
performed subsequently, if necessary, to obtain appropriate samples for making
release determinations.
The findings of the RFA will result in one or more of the following actions:
No further action under the RCRA corrective action program is required
at that time, because no evidence of release(s) or of suspected release(s)
was identified;
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REGULATORY AGENCY performs RCRA Facility Assessment (RFA) to:
Identify solid waste management units (SWMUs) and collect existing information
on contaminant releases.
Identify releases or suspected releases needing further investigation
i
REGULATORY AGENCY specifies permit conditions or issues enforcement order to facility
owner or operator to:
i Perform investigations on releases of concern; and/or
Implement interim corrective measures.
OWNER OR OPERATOR performs RCRA Facility Investigation (RFI) to verify the release(s), if
necessary, and to characterize the nature, extent and rate of migration for releases of
concern. Owner or operator reports results and contacts the regulatory agency
immediately if interim corrective measures seem warranted.
\
REGULATORY AGENCY conducts health and environmental assessment based on results
of RFI and determines the need for interim corrective measures, and/or a Corrective
Measures Study,
I
OWNER OR OPERATOR conducts Corrective Measures Study (CMS) as directed by
regulatory agency and proposes appropriate corrective measures when required by
regulatory agency.
REGULATORY AGENCY evaluates Corrective Measures Study and specifies appropriate
corrective measures.
I
OWNER OR OPERATOR peforms the Corrective Measures Implementation (CMI). This
includes designing, constructing, operating, maintaining and monitoring the corrective
measures.
Figure 1-1: RCRA Corrective Action Process. Note that although certain aspects of the
Corrective Action Process are the responsibility of either the regulatory agency or
the owner or operator, close coordination between the regulatory agency and the
owner or operator is essential throughout the process.
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An RFI by the facility owner or operator is required where the
information collected indicates a release(s) or suspected release(s) that
warrant(s) further investigation;
Interim corrective measures by the owner or operator are required where
the regulatory agency believes that expedited action should be taken to
protect human health or the environment; and
In cases where problems associated with permitted releases are found,
the regulatory agency will refer such releases to the appropriate
permitting authorities.
Guidance for conducting the RFA is presented in the following reference:
U.S. EPA. October 1986. RCRA Facility Assessment Guidance. NTIS PB 87-
107769. Office of Solid Waste. Washington; D.C. 20460.
RCRA Facility Investigation (RFh
If the regulatory agency determines that an RFI is necessary, this investigation
will be required of the owner or operator either under a permit schedule of
compliance or under an enforcement order. The regulatory agency will apply the
appropriate regulatory authority and develop specific conditions in permits or
enforcement orders. These conditions will generally be based on results of the RFA
and will identify specific units or releases needing further investigation. The RFI can
range widely from a small specific activity to a complex multi-media study. In any
case, through these conditions, the regulatory agency will direct the owner or
operator to investigate releases of concern. The investigation may initially involve
verification of suspected releases. If confirmed, further characterization of such
releases will be necessary. This characterization includes identification of the type
and concentration of hazardous waste or hazardous constituents released, the rate
and direction at which the releases are migrating, and the distance over which
releases have migrated. Inter-media transfer of releases (e.g., volatilization of
hazardous constituents from contaminated soils to the air medium) should also be
addressed during the RFI, as appropriate.
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The RFI also includes interpretation by the regulatory agency of release
characterization data to established health and environmental criteria, to determine
whether a CMS is necessary. This evaluation is crucial to the RCRA Corrective Action
Process. The regulatory agency will ensure that data and information collected
during the RFI adequately describe the release and can be used with a high degree
of confidence to make decisions regarding the need for a CMS.
Identifying and implementing interim corrective measures may also be
conducted during the RFI. If, in the process of conducting the investigation, a
condition is identified that indicates that adverse exposure to hazardous
constituents is presently occurring or is imminent, interim corrective measures may
be needed. Both the owner or operator and the regulatory agency have a
continuing responsibility to identify and respond to emergency situations and to
define priority situations that warrant interim corrective measures. The need for
consideration of interim corrective measures, if identified by the owner or operator,
should be communicated to the regulatory agency at the earliest possible time. As
indicated earlier, the need for interacting closely with the regulatory agency is very
important, not only for situations discussed above, but also to ensure the adequacy
of the data collected during the RFI and the appropriate interpretation of those
data.
Corrective Measures Study (CMS)
If the potential need for corrective measures is identified during the RFI
process, the owner or operator is then responsible for performing a CMS. During
this step of the Corrective Action Process, the owner or operator will identify, and
recommend as appropriate, specific measures to correct the release.
Information generated during the RFI will be used not only to determine the
potential need for corrective measures, but also to aid in the selection and
implementation of these measures. For releases that have been adequately
characterized, the owner or operator may be required to collect such information
(e.g., engineering data such as soil compaction properties or aquifer pumping tests)
during the RFI. Selection and implementation of corrective measures will be
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addressed in future regulations and in separate guidance to redeveloped by EPA.
In the interim, guidance for corrective measures selection and implementation is
provided in several references, including the following:
U.S. EPA. September, 1986. Data Requirements for Remedial Action
Technology Selection. Final Report. NTIS PB87-110813. Office of Emergency
and Remedial Response and Office of Research and Development.
Washington, D.C. 20460.
U.S. EPA. October, 1985. Handbook of Remedial Action at Waste Disposal
Sites. EPA/625-6-85-006. Office of Emergency and Remedial Response.
Washington, D.C. 20460.
U.S. EPA. June, 1985. Guidance on Feasibility Studies Under CERCLA. NTIS
PB85-238590. Office of Emergency and Remedial Response. Washington, D.C.
20460.
U.S. EPA. June, 1987. RCRA Corrective Action Interim Measures. Interim Final.
OSWER Directive No. 9902.4. Office of Waste Programs Enforcement.
Washington; D.C. 20460.
U.S. EPA. May, 1985. Guidance Document for Cleanup of Surface Tanks and
Drum Sites. OSWER Directive 9380.0-03. Office of Emergency and Remedial
Response. Washington, D.C. 20460.
U.S. EPA. June, 1986. Guidance Document for Cleanup of Surface
Impoundment Sites. OSWER Directive No. 9380-0.06. Office of Emergency and
Remedial Response. Washington, D.C. 20460.
U.S. EPA. November, 1986. EPA/540/2-85/004. OSWER Directive No. 9380.0-05.
U.S. EPA. December, 1988. Guidance on Remedial Actions for Contaminated
Ground Water at Superfund Sites. OSWER Directive No. 9283.1-2. Office of
Emergency and Remedial Response. Washington, D.C. 20460.
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EPA has developed a draft of a guide for assessing and remediating
contaminated sites that directs users toward technical support, potential data
requirements and technologies that are applicable to several EPA programs such as
RCRA and CERCLA. The reference for this guide and a general discussion of its
content are provided below.
U.S. EPA. 1989. Draft Practical Guide for Assessing and Remediating
Contaminated Sites. Office of Solid Waste and Emergency Response.
Washington, D.C. 20460.
This document is intended as a practical guide and reference source for EPA,
state and industry personnel that are involved with assessing and remediating
contaminated sites. Special emphasis is placed on technical support, potential data
requirements and technologies related to assessing and remediating point-source
contamination (e.g., problems associated with landfills, surface impoundments, and
underground storage tanks). The guide is designed to address, in a general manner,
releases to ground water, soil, surface water and air.
The principal objective of the guide is to facilitate technology transfer
regarding the assessment and remediation of contaminated sites. It is anticipated
that the guide will be available in two forms: (1) as a hard copy, i.e., in three-ring
binder form and (2) stored on computer files within the OSWER Electronic Bulletin
Board System (BBS). (Note: The OSWER Technology Transfer Bulletin Board Users
Guide is available from OSWER headquarters.) This dual format will provide
maximum flexibility to users and allow timely revision of existing text or the
inclusion of supplemental material as appropriate. The primary function of the
guide is to direct the user toward references and technical support for detailed
information on program requirements, technical methods, data requirements and
technologies.
The guide is divided into five sections: (I) Collection and Evaluation of Site
Information, (II) Remedial Technologies, (III) Technical Assistance Directory,
(IV) Annotated Bibliography, and (V) Compendium of Courses, Symposia,
Conferences, and Workshops.
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Section I is subdivided into Overview, Preliminary Site Assessment,
Characterization of Contaminant Sources(s) and Environmental Setting, Assessment
of Contaminant Fate and Transport, Selection, Design and Implementation of
Remedial Technologies, and Performance Evaluation of Remedial Technologies.
Brief discussions and tables are provided under these and other subdivisions to
clarify how each phase of assessment/remediation fits into the overall, iterative
process of collecting and evaluating site information. The tables, designed as
screening tools, relate site information with technologies or methods, or vice versa.
Guidance documents, references and other technical support are listed after the
preliminary discussions and tables.
Section II contains, descriptions of specific remedial technologies that are
grouped under four categories: (1) source control, (2) withdrawal injection and
flow, control, (3) water treatment, and (4) restoration of contaminated water
supplies and utility/sewer lines. Each technology description includes a general
description, application/availability, design and construction considerations, costs,
and references. In addition, an overview of general references precedes the four
categories of remedial technologies.
Section III is a technical assistance directory of EPA program, regional, and
research staff that may be contacted to answer specific questions regarding the
assessment and remediation of contaminated sites. The directory includes the
individual's name, organization within EPA, area of expertise, mailing address, and
phone number. The directory is intended to foster communication among scientists
and engineers within EPA, other Federal agencies, industry, and state and local
governments. Improved access to current scientific advances and data on the
application and performance of technologies will likely enhance the effectiveness
and efficiency of assessment and remediation programs.
Section IV is an annotated bibliography of guidance documents and references
listed under Sections I and II. Brief summaries of each document are provided to
assist the reader in selecting the appropriate technical guidance.
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Section V is a compendium of existing courses, symposia, conferences, and
workshops. Each course, symposium, conference or workshop description includes
the title, content, contact, and cost.
Corrective Measures implementation (CMI)
CMI includes designing, constructing, operating, maintaining, and monitoring
selected corrective measures. As indicated above, selection and implementation of
corrective measures will be addressed in future regulations and in separate
guidance to be developed by EPA.
1.3 Purpose of the RCRA Facility Investigation (RFI) Guidance
This document provides guidance to regulatory agency personnel for
overseeing facility owners or operators who are required to conduct a RFI to
characterize the nature, extent, and rate of migration of contaminant releases to
soils, ground water, subsurface gas, air, and surface water. It also provides guidance
on the interpretation of results by the regulatory agency to determine if interim
corrective measures and/or a CMS may be necessary.
This RFI Guidance is not intended to describe all activities that may be
undertaken during the RFI. For example, consideration of community relations and
development of a community relations plan are addressed in other EPA guidances.
This and other items that may be undertaken during the RFI are outlined in the
following document:
U.S. EPA. November 1986. RCRA Corrective Action Plan. Interim Final.
OSWER Directive No. 9902.4 Office of Solid Waste and Emergency Response.
Washington, D.C. 20460.
This document provides as much procedural specificity as possible to clearly
define the owner or operator's responsibilities in the RFI. Each situation, however,
is likely to be unique. Site-specific conditions, including the amount and quality of
information available at the start of the RFI process, the existence of or potential for
actual exposure, and the nature and extent of the release call for a flexible
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approach to the release investigation. This RFI Guidance is written in this context.
However, some situations may be so complicated and unique that further technical
guidance may be necessary. If this is the case, the owner or operator shoud contact
the responsible regulatory agency for assistance. If necessary, the responsible
regulatory agency will contact EPA Headquarters.
1.4 Organization of this Document
This guidance is organized into four volumes containing 15 sections and 8
appendices. Volume I contains eight sections: Section 2 provides direction for
preparation of the RFI Work Plan and procedures for submitting this Plan to the
regulatory agency for review. Section 3 provides guidance on the general strategy
to be employed in performing release investigations. Sections 4, 5, and 6 discuss
Quality Assurance/Quality Control (QA/QC), Data Management and Reporting, and
Health and Safety Procedures, respectively. Section 7 discusses how information
from source (waste and unit) characterization can be used in the RFI process.
section 8 presents guidance on the interpretation of data collected during the RFI
process, using health and environmental criteria. Guidance for situations that may
require the application of interim corrective measures is also provided in Section 8.
Volumes Mi and III provide detailed technical guidance on how to perform
media-specific, investigations. Volume II presents Sections 9, 10 and 11, which
discuss the soil, ground water, and subsurface gas media, respectively. Volume III
presents Sections 12 and 13, which discuss the air and surface-water media,
respectively. Representative case study illustrations of various investigative
approaches and techniques described in Volumes I through III are presented in
Sections 14 and 15 of Volume IV.
1.5 Reference Information
This document provides guidance on characterizing known releases and on
verification of suspected releases. Applicable field methods (e.g., sampling
techniques) and equipment are described or referenced, as appropriate. This
document uses, to the extent possible, existing guidances and information
developed in various EPA programs (e.g.; Office of Emergency and Remedial
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Response, office of Waste Programs Enforcement, Office of Air Quality Planning
and Standards, and Office of Water), as well as State material to assist in performing
release characterizations for the various environmental media. As such, many
references are provided which refer the owner or operator to more complete or
detailed information. Where available, identification or ordering numbers have
been supplied with these citations. The following describes these identification
numbers and provides information on how these documents may be obtained.
NTIS: NTIS stands for the National Technical Information Service. NTIS
documents may be obtained by calling (703) 487-4650 or by writing to
NTIS at the following address:
NTIS
U.S. Department of Commerce
Springfield, VA 22161
EPA: Environmental Protection Agency (EPA) Reports are available through
EPA's Headquarters or Regional libraries, or by writing to EPA at the
following address:
U.S. EPA
Public Information Center
401 M. Street, S.W.
Washington, D.C. 20460
Many EPA reports are also available through NTIS. NTIS should be
contacted for availability information. The indicated EPA office may also
be contacted for information by writing to the above address.
OSWER: OSWER stands for EPA's Office of Solid Waste and Emergency Response.
Availability information on documents identified by an OSWER Directive
Number can be obtained by calling EPA's RCRA/Superfund Hotline, at
(800) 424-9346 (toll-free) or (202) 382-3000.
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GPO: GPO stands for the U.S. Government Printing Office. Documents
available through GPO may be obtained by calling GPO at (202) 275-
3648.
1.6 Guidance Changes Description
The RFI Guidance has undergone a number of revisions since publication of the
initial October 1986 draft. Draft documents were released to the public in July
1987, December 1987 (updated Section 8- Health and Environmental Assessment
only), and of course the current version, May 1989. These revisions were
necessitated by both the need to remain consistent with evolving EPA policy with
respect to corrective action, and the desire to provide facility owners and operators
with sufficient information and guidance to ensure that investigations provide
adequate information for confident decisionmaking. Further revision of the RFI
Guidance is not anticipated. Following is a brief discussion of how the RFI Guidance
has changed since its original release.
October 1986 Draft - This was the first draft of the RFI Guidance. It contained
basic information on the conduct of RFIs, but did not go into great detail on media
specific investigations, particularly with respect to the air and surface water media.
In addition, this first draft contained little guidance pertaining to health and
environmental assessment. This draft was circulated mainly to the EPA Regions, in
an attempt to obtain comment before further development of the Guidance was
initiated. As a result of this activity, the need for major revision was identified.
July 1987 Draft - This version of the RFI Guidance represented the first major
revision made to the Guidance. Virtually all sections were restructured for
consistency and new sections were added as well. The major changes were as
follows:
Revision of much of the regulatory and procedural aspects of the
Guidance (contained in Volume I) to reflect the final RCRA Facility
Assessment (RFA) Guidance.
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Introduction of a new, more efficient means of selecting hazardous
constituents and parameters to monitor for, based on available
information on the unit(s) involved, the waste managed, the media
being investigated and any previous data collected.
Addition of guidance relating to the selection of methods for sampling
and analysis, and incorporation of references to available information
regarding acceptable methods already published by EPA's Superfund
Program.
Addition of new section on health and environmental assessment
(Section 8), including tables of action levels for specific constituents in
specific media.
Major editing of all medium specific sections for consistency in structure
and overall content.
Expansion of all medium specific sections to address the importance of
inter-media transport of contamination.
Expansion of the Soil Section (Section 9) to emphasize the importance of
recognizing soil as a key medium for inter-media transfer of
contamination, both as a source and as a recipient of contamination,
Expansion of the Ground Water Section (Section 10) to provide guidance
on the use of flow nets and flow cells in defining site hydrogeology and
contamination migration pathways.
Complete rewrite of the Air Section (Section 12) to reflect the special
considerations inherent in investigations of releases to air, and evolving
Agency policy regarding renewed emphasis on monitoring vs modeling.
Complete rewrite of Surface Water Section (Section 13) to reflect the
importance of understanding the release mechanism (i.e., past vs
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intermittent vs continual release), and the type of release (i.e., point
source vs area source).
Addition of new Volume IV- Case Studies.
December 1987 Draft - This revision of the RFI Guidance involved only Section 8 on
Health and Environmental Assessment. Hence, only Section 8 was reissued. The
major revisions made to Section 8 are summarized as follows:
Clarification of the hierarchy in which the health and environmental
criteria (i.e., action levels) are applied.
Revision of the criteria tables to reflect new exposure assumptions for
the soil medium.
Revision of the criteria tables to reflect the latest additions and revisions
made by EPA to health based exposure levels.
Addition of new guidance pertaining to evaluation of deep soil and
sediment contamination.
Update in accordance with new MCLs promulgated for volatile organic
constituents.
Mav 1989 Final Draft - The current final draft of the RFI Guidance, constitutes
significant revision over the previous drafts. Major changes from previous drafts
include the following:
Incorporation of improved graphics and tabular presentations
throughout all four volumes of the Guidance.
Incorporation of an RFI Guidance Feedback Form (at the end of Volume
1) to determine the utility of the Guidance as well as the need for further
guidance.
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General revision, where appropriate, to ensure consistency with the
forthcoming regulations dealing with RCRA corrective action.
Revision of the Section 8 criteria tables to reflect revised exposure
assumptions for the soil medium.
Revision of the Section 8 criteria tables to reflect the latest additions and
revisions made by EPA to health based exposure levels.
Incorporation of the concept of using leaching tests (Section 9 - Soil) to
predict when soil contamination may affect underlying ground water,
including a new appendix (Appendix F) presenting a draft EPA method
developed specifically for contaminated soil.
Addition of a new appendix (Appendix E) illustrating the calculation of
basement air contaminant concentrations due to basement seepage of
volatile organic contaminants.
Addition of a new section (Section 8.6.3) pertaining to newly
promulgated methods for evaluating ground-water contamination in a
statistical manner, and reference to additional guidances and other
documents available from EPA for conducting ground-water
remediation (Section 10.7).
Revision of the Air Section of the Guidance (Section 12) to reflect a new
phased approach, involving an initial screening assessment, and the
incorporation of a new appendix (Appendix G) containing draft
Guidance on the screening assessment.
Revision of the Air Section (Section 12) to reflect a balance between the
application of modeling and monitoring approaches, depending on site-
specific circumstances.
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Incorporation of the concept of using soil loss equations for determining
contaminated soil loading to surface waters (Section 13), including a new
appendix (Appendix H) illustrating the soil loss calculation.
Rearrangement of the Volume IV Case Studies to reflect the order in
which the specific points illustrated are presented in Volumes I through
incorporation of a new Volume IV case study illustrating the use of
leaching tests to predict the potential for contaminated soil to
contaminate underlying ground water.
1.7 Corrective Action Regulations
EPA is in the process of promulgating comprehensive corrective action
regulations pursuant to HSWA Section 3004 (u) and (v). These regulations, which
will appear primarily in Subpart S of 40 CFR Part 264, will establish requirements for
all aspects of RCRA corrective action. Because the RFI Guidance is being released
prior to the proposal and promulgation of Subpart S, the potential for differences is
significant. Therefore, users of this guidance are advised to review the final
Subpart S rule carefully when published. Potential differences are identified below:
Identification of health and environmental criteria or "action levels" -
The RFI Guidance includes tables of the most recent action levels in
Section 8, Health and Environmental Assessment. However, these levels
are continually being updated by EPA, and the levels presented in the
Subpart S rule may differ.
Development of health and environmental criteria -. The RFI Guidance
provides information on how action levels are developed (e.g., use of
exposure assumptions, risk levels for carcinogens). The Subpart S rule
may propose alternate methods for developing actions levels.
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Definition, of constituent - The RF. I Guidance refers to constituents as
those listed in 40 CFR Part 261, Appendix VIII. Use of the term
"constituent" in the Subpart S rule is being reviewed.
Action levels for surface water - The RFI Guidance identifies action levels
for surface water to include various Agency-developed criteria (such as
MCLs), but indicates that State-developed standards may also be
considered. The Subpart S rule may propose, a different scheme for
establishing action levels for surface water.
Action levels for soil - The RFI Guidance attempts to differentiate deep
from surficial soil contamination, and provide methods (e.g., leaching
tests) and action levels for determining the need for corrective action.
Surficial soil and deep soil contamination may be addressed differently in
the Subpart S rule.
Influence of detection/quantitation limits on action levels - The RFI
Guidance indicates that the detection limit will serve as the action level,
where action levels are lower than detection limits. The issue of
detection/quantitation limits is under Agency review, and may be
changed in the Subpart S rule.
Evaluation of chemical mixtures - The RFI Guidance provides the
rationale and equations for computing adjusted action levels, assuming
additive toxicity, when more than one constituent is present in a
contaminated medium. The issue of evaluation of chemical mixtures is
under Agency review and may be addressed differently in the Subpart S
rule.
Definition of Solid Waste Management Unit (SWMU) - The RFI Guidance
definition of SWMU is currently under Agency review and may be
changed in the Subpart S rule.
Notification and Reporting - The RFI Guidance identifies specific reports
that may be required throughout the performance of an RFI, and also
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identifies specific-situations in which the owner or operator is required to
submit notifications to the regulatory agency. Notification and
reporting requirements are being reviewed by EPA and may be changed
in the Subpart S rule.
Use of specific language - The specific language used in various sections
of the RFI Guidance, for example when referring to factors the
regulatory agency may consider in determining the need for interim
corrective measures, may be changed in the Subpart S rule.
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SECTION 2
THE RFI WORK PLAN
2.1 Introduction
If notified by the regulatory agency that an RFI must be conducted, the owner
or operator should initiate a series of activities aimed at supplying specific
information on the identified, suspected, or known releases of concern. Such
activities can include release verification and characterization. Conducting the RFI
should follow a logical sequence of actions involving the preparation and submittal
of an RFI Work Plan, including development of a monitoring approach,
performance of investigatory tasks, submission of results, and interactions with the
regulatory agency on courses of further action. The overall RFI process is shown in
Figure 2-1.
As indicated previously, each RFI situation is likely to be unique in various
respects, including the unit or units releasing, the media affected, the extent of the
release, the potential for inter-media impacts, the amount and quality of existing
information, and other factors. The amount of work that may be involved in the
RFI, and therefore the content of the RFI Work Plan, is also likely to vary. This
section provides guidance concerning the general content of the RFI Work Plan,
2.2 Preparation of an RFI Work Plan
The RF1 Work Plan is a detailed plan that the facility owner or operator should
develop and follow throughout the RFI that will lead to characterization of the
nature, extent, and rate of migration of a release of hazardous waste or hazardous
constituents. This plan consists of a number of components that may be developed
and submitted either concurrently or sequentially in accordance with the schedule
specified in the permit or compliance order. These components are shown in
the top box of Figure 2-1. Development and, therefore, submittal of specific
plan components (e.g., detailed monitoring procedures) may not be required
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Owner or Operator submits RFI Work plan to regulatory agency for review. Plan should
include:
Description of Current Conditions (see Section 2.2.1)
A schedule for Specific RFI Activities (see Section 2.22)
RFI Strategy:
I Procedures for Characterizing the Contaminant Source, the Environmental
Setting and Assembling Available Monitoring Data (see Sections 2.2.3 and 2.2.5)
I Monitoring and Data Collection Procedures (see Section 2.2.4)
- Quality Assurance/Quality Control Procedures (see Section 2.2.6)
Data Management and Reporting Procedures (see Section 2.2.7)
- Identification of Potential Receptors.(see Section 2.2.8)
Health and Safety Procedures (Optional) (see Section 2.2.9)
- Other Information if Specified by the Regulatory Agency
±
Owner or Operator implements RFI Work Plan by conducting appropriate activities and
reports release-specific results to regulatory agency for review. "
Regulatory Agency evaluates release-specific, results and makes the appropriate ]
[determinations.
^H ^U ^U ^V
No further
action
necessary'
Begin Corrective
Measures Study
(CMS)d
Implement
interim corrective
measures'
Further
information
necessary
a In some cases, existing Information may be adequate to characterize specific releases.
b The owner or operator also has a continuing responsibility to identify and respond to emergency situations and to
define priority situations that may warrant interim corrective measures.
c No further action will be necessary where a suspected release is shown to not be an actual release based on an
adequate amount of monitoring data or where release concentrations are shown to be below levels of concern for a
sufficient period of time.
d Implies release concentrations were observed to be equal to or above health and environmental assessment criteria,
or that there was a reasonable likelihood of this occurring.
e Interim corrective measures may also be implemented prior to or during the RFI, as necessary.
FIGURE 2-1. RCRA FACILITY INVESTIGATION (RFI) PROCESS.
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until adequate information on the contaminant source and environmental setting is
gathered and evaluated. Discussion on RFI reporting and schedules between the
owner or operator and regulatory agency is encouraged.
The owner or operator should be guided by the information contained in the
RFA Report and the conditions specified in the permit or compliance order in
developing the RFI Work Plan. These conditions will usually indicate which units
and releases are to be addressed in the RFI (based on the findings of the regulatory
agency during the RFA), as well as which media are of concern. In most cases, the
information contained in the RFA Report and the conditions specified in the order
or permit will enable the owner or operator to develop a sufficiently focused RFI
Work Plan. However, if additional guidance is needed by the owner or operator,
consultation with the regulatory agency is advised.
2.2.1 Description of Current Conditions
As part of the RFI Work Plan, the owner or operator should provide
background information pertinent to the facility, contamination, and interim
corrective measures as described below. Data gathered during any previous
investigations or inspections and other relevant data should be included. The
owner or operator should consult with the regulatory agency to determine if any of
these information items are irrelevant or have already been submitted in an
appropriate format for other purposes (e.g., contained in a RCRA permit
application).
2.2.1.1 Facility Background
The owner or operator-should summarize the regional location, pertinent
boundary features, general physiography, hydrogeology, and historical use of the
facility for the treatment, storage or disposal of solid and hazardous waste. This
information should include the following:
Map(s) depicting:
General geographic location;
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Property lines, with the owners of all adjacent property clearly
indicated;
Topography and surface drainage (with an appropriate contour
interval and a scale of 1 inch = 100 feet) depicting all waterways,
wetlands, floodplains, water features, drainage patterns, and
surface-water containment areas;
All tanks, buildings, utilities, paved areas, easements, rights-of-way,
and other features;
All solid or hazardous waste treatment, storage or disposal areas
active after November 19, 1980;
All known past solid or hazardous waste treatment, storage or
disposal areas regardless of whether they were active on November
19, 1980;
All known past and present product and waste underground tanks
or piping;
Surrounding land uses (residential, commercial, agricultural,
recreational);
The location of all production and ground-water monitoring wells.
These wells shall be clearly labeled and ground and top of casing
elevations and construction details included (these elevations and
details may be included as an attachment); and
Location of any injection wells onsite or near the facility.
All maps should be consistent with the requirements set forth in 40 CFR
§, 270.14 and be of sufficient detail and accuracy to locate and report all current and
future work peformed at the site including
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A history and description of ownership and operation, solid and
hazardous waste generation, and treatment, storage and disposal
activities at the facility;
Approximate dates or periods of past product and waste spills,
identification of the materials spilled, the amount spilled, the location
where spilled, and a description-of the response actions conducted (local,
state, or Federal response units or private parties), including any
inspection reports or technical reports generated as a result of the
response; and
A summary of past permits requested and/or received, any enforcement
actions and their subsequent responses, and a list of documents and
studies prepared for the facility.
2.2.1.2 Nature and Extent of Contamination
The owner or operator should describe any existing information on the nature
and extent of releases, including
A summary of all possible source areas of contamination. This, at a
minimum, should include all regulated units, solid waste management
units, spill areas, and other suspected source areas of contamination. For
each area, the owner or operator should identify the following:
Location of unit/area (which should be depicted on a facility map);
Quantities of solid and hazardous wastes;
Hazardous waste or constituents, to the extent known; and
Identification of areas where additional information is or may be
necessary.
A description of the degree and extent of contamination. This should
include
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Available monitoring data and qualitative information on locations
and levels of contamination at the facility;
All potential migration pathways including information on
geology, pedology, hydrogeology, physiography, hydrology, water
quality, meteorology, and air quality; and
The potential impact(s) on human health, and the environment,
including demography, ground-water and surface-water use, and
land use.
The surface configuration of contaminant sources both on and off the site may
impact assessment and remediation by contributing to the complexity of
contamination. Technical factors such as contaminant migration potential, the
ability to withdraw or treat contaminants, and the effectiveness of treatment trains
can be significantly altered by the interaction of releases from different
contaminant sources. Well-developed maps showing the number, spacing, and
relative positions of contaminant sources are essential to the planning and
implementation of assessment and remediation activities. In addition to map and
field inspections, remote sensing surface geophysical methods, and Geographic
Information Systems are useful site evaluation tools. Information obtained from
these site screening methods will help direct subsequent, more intensive activities
to the major areas of concern.
Assessment activities may be subtly affected by the surface configuration of
contaminant sources at the site. Figure 2-2 shows an example of overlapping
ground-water contamination plumes from adjacent sources that contain different
wastes. Organic solvents from Source A may facilitate the movement of otherwise
low-mobility constituents from Source B. Contaminants from Source B, that are
fairly insoluble in water, dissolve readily when in contact with solvents from Source
A. This process is described as co-solvation. Examples of other potential
complications in the ground water medium include heavy metal transport by
complexation, particle transport, biotransformation, clogging of media pores or
filtering devices by particulates, and changes in subsurface adsorptive properties.
These and other factors suggest that an approach that focuses only on individual
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SOURCE A
SOURCE B
LEACHATE WITH
LOW WATER
SOLUBILITY
GROUNDWATER
FLOW DIRECTION
LEACHATE CONTAINING
ORGANIC SOL VENTS
FIGURE 2-2. Overlapping Plumes From Adjacent Sources That Contain Different Wastes
-------
contaminant sources without considering potential interactions between sources
may lead to improper assessment and remediation. Additional information on this
subject is provided in the following reference:
Keely, J.F. January, 1987. The Use of Models In Managing Ground-Water
- Protection Programs. EPA/600/8-87/003. EPA Office of Research and
Development. Washington, D-C. 20460.
The extent of contamination at a site can be viewed in two ways. First the
extent can be examined from a spatial perspective, i.e., where is the contamination
located and what are its approximate dimensions? Second, the extent of
contamination can be viewed from a toxicity or concentration level perspective, i.e.,
to what degree is the medium (e.g., soil, aquifer) "damaged" or contaminated?
Chemical isopleth maps (discussed in Section 5) can be used to represent both
components of contamination over a given area. Each perspective should be
considered because both can influence ground-water remedy selection, and on a
larger scale, future land use.
Data on the extent of contamination are gathered through a variety of
analytical devices and methods, such as monitoring wells, soil gas monitoring,
ambient air monitoring, modeling and geophysical techniques. As in all cases, a
more extensive monitoring system allows for better delineation of the contaminant
release. Economic considerations force investigators to obtain a maximum amount
of information from assessment activities. With this in mind, areal photographs,
color infrared imagery and other more sophisitcated remote sensing imagery may
be useful in defining vegetation stress or other environmental indicators that aid in
delineating the extent of contamination.
The vertical extent of contamination should also be considered in defining a
release. For ground water, the vadose zone, uppermost aquifer, and if affected,
other proximal interconnected aquifers and surface-water bodies, should be
considered as an integral part of every ground-water decontamination process. The
importance of controlling and cleaning up contamination within the vadose zone is
well documented. Often, ground-water pollution abatement efforts are inhibited
by percolating waters that collect leachate or products in a contaminated vadose
zone and advance down to the water table. At this point, the initial ground-water
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clean up attempt must be repeated causing additional problems and costs. To
prevent continued loss of ground-water quality, vadose zone decontamination
should be initiated and regarded as an important component of the ground-water
remediation process
Cross media effects also play an important role in defining the extent of
contamination. Air, soil, surface-water, and ground-water quality are all potentially
threatened by any contaminant release within the environment. Contaminants
transported inconspicuously from a seemingly confined media to another may harm
ecosystems or humans simply because the migration was not anticipated. Both
natural pathways between media and those created by anthropogenic features
(e.g., improperly constructed monitoring wells) may increase the extent of
contamination. For these reasons the complex interactions between environmental
media should not be overlooked.
2.2.1.3 Implementation of Interim Corrective Measures
The owner or operator should document interim corrective measures that
were or are being undertaken at the facility. This should include
Objectives of the interim measures, including how the measure is
mitigating a potential threat to human health and the environment
and/or is consistent with and integrated into any long-term solution
at the facility;
Design, construction; operation, and maintenance requirements;
Schedules for design, construction and monitoring; and
Schedule for progress reports.
2.2.2 Schedule for Specific RFI Activities
In the RFI Work Plan, the owner or operator should propose a schedule for
completing the RFI within the time frame of the order or permit schedule of
compliance. The schedule should be as specific as possible and should indicate dates
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for submittal of the various components of the RFI Work Plan, dates for starting and
accomplishing specific tasks associated with the RFI, and dates for reporting
information from specific tasks to the regulatory agency.
2.2.3 Procedures for Characterizing the Contaminant Source and the
Environmental Setting
Prior to establishing monitoring procedures to provide data on the release,
certain information should be acquired to determine constituents of concern and
appropriate sampling locations. Two key areas should be addressed:
characterization of the source (i.e.,. waste and unit), and characterization of the
environmental setting. These areas are described in general terms below. They are
also described, in detail in each of the media-specific sections.
2.2.3.1 Contaminant Source Characterization
Characterization of the unit(s) and associated waste may be necessary to
identify applicable monitoring constituents or useful indicator parameters for the
release characterization. Design and operational information on the unit, such as
unit size and amount of waste managed therein, may be necessary to determine
release rates.
In some cases, adequate characterization of the waste in the unit can be made
by evaluating existing waste management records or data on the process
generating the waste. In other cases, a sampling and analysis effort may be
necessary. If so, the owner, or operator should define the sampling and analysis
effort in regard to:
Constituents, analytical methods, detection limits, and the rationale for
their selection;
Sampling methods, sampling locations, equipment, and schedule; and
Pertinent QA/QC procedures to ensure valid waste characterization.
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Identification of monitoring constituents and use of indicator parameters are
discussed further in Section 3 and supported by Appendix B. Waste and unit
characterization methods, including sampling, are described in Section 7. QA/QC
procedures are described in Section 4.
Unit characterization should include information such as construction proc-
edures and materials, and liner specifications, if applicable. Such information may
be important in evaluating the probable degree of contamination from the unit,
and consequently, the probable type and severity of the release.
Waste characterization will not always provide complete information for use
in identifying monitoring constituents. This may be especially true for old units,
where significant degradation of constituents may have occurred, and for those
units that have received many different types of waste, where it is difficult to be
sure that, all wastes in the. unit were sampled and analyzed. The owner or operator
should be aware of these possibilities. Further guidance on appropriate procedures
in these cases is provided in Sections 3 and 7.
Important data on individual sources also includes the condition of the. source,
the spatial distribution of the source, and waste management practices. The
condition of a source may significantly affect its capacity to contaminate the
surrounding environment. Evaluating and controlling contaminant sources early on
may significantly reduce the costs of assessment and remediation.
Waste treatment, storage and disposal units (e.g., landfills, surface
impoundments, and waste piles, etc.) that do not have containment systems are of
course, more susceptible to the release of contaminants. If there is no cover or liner
present, the release of constituents from a unit will largely depend on site
characteristics (e.g., infiltration, hydrogeology) and contaminant characteristics
(e.g., solubility, specific gravity), which are discussed in later sections. Source
control technologies such as cover installation, waste removal, in situ waste
treatment, or subsurface barrier construction may be appropriate when no
containment system is present.
When a containment, system is present, it is appropriate to evaluate the
condition of the system to determine if modifications could significantly reduce or
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prevent further releases. Table 2-1 presents an outline describing some of the
important characteristics of waste treatment, storage and disposal unit
containment systems that should be evaluated. The degree of modification to a
source will largely depend on contaminant migration potential, exposure potential,
and the feasibility of implementing remedial measures, which in turn are affected
by site hydrogeology, land use, waste characteristics, and other factors.
The three-dimensional distribution of each source should also be carefully
delineated to focus remedial activities on the site's "hot spots" (i.e., those regions
with the highest concentrations of contaminants). Cleaning up contaminated sites
without identifying, defining and characterizing these hot spots may lead to
ineffective, ineffecient remediation attempts, innovative technologies such as
specialized coring methods (see Section 9), geophysical methods (see Section 10 and
Appendix C), and soil gas sampling devices (see Section 11) may provide better
resolution of these hot spots than more conventional methods and devices (e.g.,
monitoring wells, and split-spoon samplers).
The manner in which wastes are managed may significantly affect the nature
and extent of contamination-by influencing the spatial and temporal variability of
contaminant releases. Important factors to consider when characterizing
contaminant sources include the total-quantity of wastes, the location and timing of
waste management, waste and constituent characteristics, and general waste
management practices.
As indicated previously, the total quantity of contaminants within a source is
an obvious yet important consideration when assessing or remediating
contamination. In general, the potential extent of contamination is proportional to
the volume of wastes managed in the source, taking into account other factors such
as hydrogeologic setting, exposure potential, and the condition of the source.
In addition, the location of waste treatment, storage, and disposal units may
affect the' type and degree of remedial measures. In addition to the surface
configuration of sources, the location of different quantities and types of waste
within a source may affect the potential for release. For instance, low pH liquid
waste plated near wastes containing heavy metals may promote the migration of
the metal cations by increasing their solubility.
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TABLE 2-1. CONTAINMENT SYSTEM EVALUATION
I. Cover1
A. Characteristics of the soil to be used in the cover
B. Cover and surrounding land topography
C. Climate characteristics
D. Composition of the cover
1. Component type
2. Component thickness
E. Cover design and construction practices
F. Cover configuration
G. Cover drainage characteristics
1. Material used-in drainage system
2. Thickness of drainage system
3. Slope of the drainage system
H. Vegetative cover
1. Post-closure maintenance
1. Cap system
a. Adequate vegetative cover
b. Erosion
c. Settlement/subsidence
2. Run-on and run-off control system
a. Adequate vegetative cover
b . E r o s i o n
c. Flow obstructions
II. Liner and Leachate Collection/Detection System
A. The number of liners
1 information in this section was in part obtained from EPA's
technical resource document, Evaluating Cover Systems for Solid
and Hazardous Waste. SW-867, 1982.
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TABLE 2-1. CONTAINMENT SYSTEM EVALUATION (Continued)
B. The type and thickness of the liners
1. The compatibility of the liners with the waste type
2. The structural strength of the liners
3. The liner foundation
C. The age and installation methods of the liners
D. Description of leachate collection system
1. Thickness of drainage layer
2. Material used in the drainage system
3. Slope of the collection system
4. Method of leachate collection
5. Method of leachate withdrawal
E. Description of leak detection system
1. Thickness of detection system
2. Material used in the system
3. Slope of the detection system
4. Method of leak detection
5. Ability to withdraw leachate from the system
Other Factors
A. Compatibility of bottom-most liner with the underlying
geology
B. Relationship of the ground-water table to the bottom liner
c. Water content (percent solids and free liquids content)
D. Compatibility of waste with containment system (or underlying
soil, if no containment system is present)
E. Waste load on the containment system
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Transportation of wastes on and off site is an equally important consideration.
For instance, a buried transmission line may rupture and release contaminants to
the subsurface. Vehicles conveying wastes to, from, or within a site may spill or leak
substances onto the ground and eventually cause subsurface contamination.
Carefully maintained records of waste transportation or field inspections may reveal
such potential leaks or spills.
The timing of waste management also is important in assessing and
remediating site contamination. Two aspects of timing are important to recognize
here: the age of the source and the history of waste management. Both aspects
may affect the timing, nature, and degree of assessment and remediation.
Due to the generally slow movement of some, types of contamination (e.g.,
ground water plumes), releases covering a large area are more likely to originate
from older sources (i.e., sources that have managed wastes for long periods or at
previous times). Older sources are generally harder to define and characterize due
the paucity of waste management-data and little, if any, containment features.
Newer units, on the other hand, are more likely to have accurate management
records and improved design features for containment. Remediation for an older
source contaminating the ground water, for example, may involve substantial
plume control, aquifer restoration, and capping of large areas of contaminated soil.
On the other hand, a recently detected leak from a new source may be abated by
minor containment system repair, with little or no aquifer restoration and plume
control required.
The history of waste management for a specific source affects assessment and
remediation by influencing the source's capacity to contaminate over time. In
addition to the spatial variability of wastes, the temporal variability of waste
management should be considered. Sources may form discrete or continuous
plumes, depending on the history of waste management. As shown in Figure 2-3,
the configuration of ground-water contamination may be profoundly affected by
the timing of releases. Assessment and remediation of contamination are
consequently aided by understanding the history of waste management for
individual sources.
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DISCRETE
SOURCE
GROUND - WATER FLOW
CONTINUOUS
SOURCE
FIGURE 2-3. Discrete versus Continuous Contaminant Sources.
-------
In some cases, altering the timing of waste management may be an effective
source control measure. For instance, placement of wastes in landfill cells without
covers may be limited to anticipated dry periods. By doing so, the amount of
moisture in contact with wastes may be significantly reduced, thus minimizing the
potential for contaminant migration.
Specific characteristics of waste and constituents affecting the assessment and
remediation of contamination in specific media are discussed in the media specific
sections of this guidance. These characteristics include the compatibility of wastes
with the unit, the containment system (if any), the underlying geology, and
interactions between different wastes and constituents. Assessing the
characteristics of wastes and constituents in conjunction with data on the condition
of the source and site hydrogeology may aid assessment and remediation by
identifying problems related to waste containment or complicated fate and
transport mechanisms. If waste/containment system compatibility problems ate
discovered during a site evaluation, source modification such as liner replacement
may be necessary to reduce or prevent further releases. In some cases, modifying
waste treatment, storage, and disposal practices (e.g., restricting certain wastes
from operating landfills) may be the most appropriate source control measure.
Interactions between wastes and constituents and underlying geology may
alter contaminant migration potential and complicate control, recovery and
treatment operations. For example, acidic leachate may cause or exacerbate
solution cavity development in areas underlain by karst geology, thus promoting
the migration of contaminants. In other instances, interactions between
contaminants and subsurface materials may reduce the effectiveness and efficiency
of remediation technologies; for example, by changing the chemistry of
contaminated ground water or by inhibiting fluid flow to and from heavily
contaminated areas.
Predicting the interactions between different wastes and constituents is
among the most difficult tasks performed during site investigations. Such
interactions may affect contaminant migration potential and complicate recovery
and treatment operations. One example is the clogging of pore spaces or well
screens by precipitates which form by chemical interactions between wastes or
constituents. Other examples include co-solvation, particle transport and mobile
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transformation products (see Table. 2-2). It should be noted that laboratory testing
of waste, or constituent interactions, may not accurately depict subsurface
processes. For this reason, ground-water chemistry and waste treatment, storage,
and disposal conditions at the site should be considered when predicting the
behavior of cetiain combinations of wastes or constituents. In seine instances, this
may mean additional sampling, monitoring, and fieldtesting.
Reviewing waste management records to assess the quality of waste
management practices may aid assessment and remediation activities by providing
insight into the release potential of a source, and consequently, facilitate remedy'
selection. For instance, factors such as waste packaging, handling and placement,
freeboard maintenance, and waste characterization may indicate how well a waste
management unit is operated and maintained. Improvements in such waste
management practices may reduce contaminant migration potential and therefore
should be considered viable source control measures.
2.2.3.2 Environmental Setting Characterization
Characterization of the environmental setting may be necessary to determine
monitoring locations (i.e., contaminant pathways) and to aid in defining the
boundaries of the contaminated area. Techniques for characterizing the environ-
mental setting are media-specific and are described in Volumes II and III of this
Guidance. Examples of environmental information that may be required are wind
speed-and direction, subsurface stratigraphy, and surface-water body volumes and
flow rates.
2.2.4 Monitoring and Data Collection Procedures
Specific monitoring procedures should be identified in the RFI Work Plan to
characterize each release of concern. These procedures should indicate the
proposed approach for conducting the investigation and should account for the
following:
Historical information and/or information gathered during the
characterization of the contaminant source and the environmental
setting;
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TABLE 2-2. PHYSICAL, CHEMICAL AND BIOLOGICAL PROCESSES
AFFECTING CONTAMINANT FATE AND TRANSPORT
(Keely, 1987)
PHYSICAL PROCESSES
Advection (porous media velocity)
Hydrodynamic Dispersion
Molecular Diffusion
Density Stratification
Immiscible Phase Flow
Fractured Media Flow
CHEMICAL PROCESSES
Oxidation-Reduction Reactions
Radionuclide Decay
Ion-Exchange
Complexation
Co-Soivation
Immiscible Phase Partitioning
Sorption
BIOLOGICAL PROCESSES
Microbial Population Dynamics
Substrate Utilization
Biotransformation
Adaptation
Co-metabolism
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An approach for implementation, including the type of information to
be collected;
Description of the monitoring network; and
Description of monitoring, activities (e.g., sampling, meteorological
monitoring).
Monitoring procedures may include a phased approach for release
characterization as described in the media-specific sections of this Guidance. The
initial phase may include a limited monitoring effort followed by subsequent
phases, if necessary. The design of subsequent monitoring phases maybe based on
information gathered during a prior phase; therefore, revisions to the monitoring
procedures may become necessary as the RFI progresses. A phased approach maybe
particularly useful in cases where a suspected release was identified by the
regulatory agency as a result of the RFA process. In this case, the first monitoring
phase may be designed to provide for release verification as well as the first step for
release characterization. If revisions to a proposed monitoring approach become
necessary, documentation should be submitted to the regulatory agency to support
such changes.
2.2.5 Assembling Existing Data to Characterize the Contaminant Release
The owner or operator should assemble and review existing analytical and
monitoring data pertinent to the release(s) and media of concern. This information
can be used to determine the need for and to plan the extent of additional
monitoring. Only data that have been collected using reliable methods and
documented QA/QC procedures should be used as the basis for planning additional
efforts. The amount and quality of existing data will determine the need for
additional monitoring information on the release. Sources of such data include
Information supplied, by the regulatory agency with the permit con-
ditions or compliance order;
The RFA report;
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Facility records;
The facility's RCRA permit application;
State and local government agency files, and
CERCLA site reports (e.g., Records of Decisions).
2.2.6 Quality Assurance/Quality Control (QA/QC) Procedures
The use of properly documented and implemented QA/QC procedures for
monitoring activities (including sampling and analysis) is an essential part of the RFI
Work Plan. It is important to ensure that data generated during the investigation
are valid (i.e., supported by documented procedures) such that they can be used
with confidence to support determinations regarding the need for and design of
subsequent monitoring, the need for interim corrective measures, and the need for
a Corrective Measures Study. These procedures are used to describe and document
data quality and include such activities as
Defining sampling and analytical techniques;
Confirming and documenting correct sample identity;
Establishing precision and accuracy of reported data;
Documenting all analytical steps in determining sample identity and
constituent concentrations;
Establishing detection limits for constituents of concern; and
Establishing any bias arising from field sampling or laboratory analytical
activities.
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Another important aspect of QA/QC is to ensure the use of qualified personnel
(e.g., licensed or certified) to conductor oversee various parts of the investigation.
QA/QC procedures are described in Section 4.
2.2.7 Data Management and Reporting Procedures
Data management procedures should be included as part Of the RFI Work Plan
for organizing and reporting investigation data and results. Satisfactory
presentation of investigation results to the regulatory agency is essential in
characterizing and interpreting contaminant releases. Guidance on these pro-
cedures is presented in Section 5.
2.2.8 Identification of Potential Receptors
As specified by the regulatory agency in the permit or order, the owner or
operator should provide in the RFI Work Plan information describing" the human
populations and environmental systems that may be susceptible 'to contaminant
releases from the facility. Such information may include
Existing and possible future use of ground water, including type of use
(e.g., municipal and/or residential drinking water, agricultural,
domestic/non-potable, and industrial);
Location of ground-water users, including wells and discharge areas;
Existing and possible future uses of surface waters draining the facility,
including domestic and municipal uses (e.g., potable and lawn/gardening
watering), recreational (e.g., fishing and swimming), agricultural, and
industrial and environmental (e.g., fish and wildlife populations) uses;
Human use of or access to the facility and adjacent lands, including
recreational, hunting, residential, commercial, zoning, and the relation-
ship between population locations and prevailing wind direction;
A description of the biota in surface-water bodies on, adjacent to, or
which can be potentially affected by the release;
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A description of the ecology on and adjacent to the facility;
A demographic profile of the human population who use or have access
to the facility and adjacent land, including age, sex, sensitive subgroups
(e.g, schools, nursing homes), and other factors as appropriate; and .,
A description of any endangered or threatened species near the facility.
This information can be used to determine whether any interim corrective
measures may be necessary at the facility, If populations are currently being
adversely exposed or such exposure seems imminent, interim corrective measures
may be necessary. Further information regarding interim corrective measures is
provided in Section 8 (Health and Environmental Assessment).
Receptors can be affected by the transfer of a release from one medium to
another. Apparent or suspected inter-media transfers of contamination, as
identified in the permit or order, should be addressed in the RFI Work Plan. Table
2-3 illustrates some potential inter-media contaminant transfers and pathways. In
examining the extent of a release, the owner or operator may be directed to collect
sufficient information to allow the identification of potential inter-media transfers.
Situations where inter-media contaminant transfer may be important may
arise through common usage of the contaminated medium. For example, drinking
of ground or surface waters contaminated with volatile constituents poses an
obvious hazard. Less obvious is the inhalation hazard posed by shawering with such
contaminated waters. Situations such as this should also be considered when
determining the need for interim corrective measures.
The guidance presented in the media-specific sections (Volumes II and III)
addresses potential areas for inter-media transfer. The guidance also identifies
situations in which contamination of more than one media can be characterized, to
some extent, using common procedures. For example, soil-gas analyses, such as
those conducted using an organic vapor analyzer (OVA), can be used to monitor for
subsurface gas (e.g., methane), as well as to indicate the overall extent of certain
types of contaminant releases to ground water,
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TABLE 2-3. SOME POTENTIAL INTER-MEDIA CONTAMINANT
TRANSFER PATHWAYS
Release Media
Air
Soil
Ground Water
Sufrace Water
Subsurface Gas
Potential
Receiving" Media
Soil
Surface Water
Ground Water
Subsurface Gas
Surface Water
Surface Water
Subsurface Gas
Ground water
Air
Soil
Air
Soil
Transfer Pathways
- Deposition of particles
- Atmospheric washout
- Migration through the
unsaturated zone
- Migration through the soil
- Overland runoff
- Ground-water discharge
- Volatilization
- Ground-water recharge
- Volatilization
- Deposition of floodplain
sediments
- Venting through soil
- Migration through soil
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2.2.9 Health and Safety Procedures
Health and safety procedures maybe included as part of the RFI Work Plan.
The owner or operator is advised to understand, use, and document health and
safety procedures describing efforts that will be taken to ensure the health and
safety of the investigative team and others (e.g., the general public) during the RFI.
The owner or operator should also be aware that on December 19, 1986, the
Occupation-al Safety and Health Administration (OSHA) issued an interim final rule
on hazardous waste site operations (29 CFR 1910.120) which specifically requires
cetiain minimum standards concerning health and safety for anyone performing
activities at CERCLA sites, RCRA sites, or emergency response operations. Further
discussion on this topic is provided in Section 6.
2.3 Implementation of the RFI Work Plan
After review of the RFI Work Plan by the regulatory agency, the owner or
aperator should implement the plan as directed. In some cases, adequate
information may exist to characterize specific releases, and an extensive monitoring
effort may not be necessary. The extent of monitoring will depend on the amount
and quality of existing information and the nature of the release. Results of
investigative activities should be submitted to the regulatory agency according to
the RFI Work Plan schedule. Further guidance on specific reports that may be
required is provided in Section 5.
The owner or operator has a continuing responsibility to identify and respond
to emergency situations and to define priority situations that may warrant interim
corrective measures. Interim corrective measures may be necessary if receptors are
currently being exposed to release constituents or if such exposure seems imminent.
These situations may become evident at any point in the RFI process. The owner or
operator should contact the regulatory agency immediately if any such situation
becomes apparent. Further information regarding the evaluation of the results of
release characterization is presented in Section 8.
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2.4 Evaluation by the Regulatory Agency
The regulatory agency will evaluate reports of release-specific results of the
RFI submitted by the owner or operator to make determinations for further action.
Such determinations may include
No further action is necessary at that time;
Further information on a release is necessary. The owner or operator will
be advised to initiate additional monitoring activities;
Interim corrective measures are necessary; or
Adequate information is available to conclude that a CMS is necessary.
The regulatory agency may elect to be present at the facility to observe any
phase of the release investigation. As indicated previously, close coordination
between the owner or operator and the regulatory agency is essential throughout
the RFI process. Also, as shown in Figure 2-1, interim corrective measures may be
implemented prior to or during the RFI, as necessary.
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SECTION 3
GENERAL STRATEGY FOR RELEASE INVESTIGATION
3.1 INTRODUCTION
An investigation, of releases from solid waste management units requires
various types of information. This information is specific to the waste managed,
unit type, design, and operation, the environment surrounding the unit or facility,
and the medium to which contamination is being released. Although each medium
will require specific data and methodologies to investigate a release, a general
strategy for this investigation, consisting of two elements, can be described:
Collection and review of data to be used in developing a conceptual
model of the release that can be used to plan and develop monitoring
procedures. These data may include existing information on the
facility/unit or related monitoring-data, data which can be gathered from
outside sources of information on parameters affecting the release, or
the gathering of new information through such mechanisms as aerial
photography or waste characterization.
Formulation and implementation of field investigations, sampling and
analysis, and/or monitoring procedures designed to verify suspected
releases (if necessary), and to evaluate the nature, extent, and rate of
migration of verified releases.
AS stated in Section 2, two components of the RFI Work Plan will address these
elements. These are
Procedures to characterize the contaminant source and the environ-
mental setting; and
Monitoring procedures.
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Sections 3.4 and 3.5 provide general guidance on these procedures. Section
3.2 outlines the general strategy suggested for all release investigations, and
Section 3.3 briefly discusses concepts concerning data quality that are designed to
ensure that data collected during the investigation will adequately support
decisions that will eventually be made regarding the need for corrective measures.
Section 3.6 provides guidance for formulating methods and monitoring procedures,
and addresses monitoring constituents and indicator parameters, use of EPA and
other methods, sampling considerations, and analytical methods and detection
limits.. Section 3.7 provides information concerning various decisions that may be
made based on monitoring data and other information collected during the RFI
process.
3.2 Phased Strategy for Release Investigations
At the start of the RFI process, varying amounts of information will exist on
specific-releases and units. In some instances, suspected releases may have been
identified based on strong evidence, that releases have occurred, but with little or
no direct data confirming their, presence. On the other end of the spectrum, there
may be enough existing data at the start of the RFI to begin considering whether
some form of corrective measure may be necessary.
This potentially broad spectrum of situations that may exist at the beginning
of the RFI may call for a flexible, phased approach for the release investigation,
beginning with an evaluation of existing data and collecting additional data, as
necessary to characterize the release source and the environmental setting. From
such data, a conceptual model of the release can reformulated in order to design a
monitoring program capable of release verification and/or characterization.
The release characterization may be conducted in phases, if appropriate, with
each monitoring phase building on the findings and conclusions of the previous
phase. The overall level of effort and the number of phases for any given
characterization effort depend on various factors including
The level of data and information available on the site;
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The complexity of 'the release (e.g., number of units, release pathways,
affected media); and
The overall extent of the release.
As many situations are likely to be unique with respect to the above factors,
the number and intensity of each of the phases of the RFI process leading-to
eventual characterization and to assessment against health and environmental
criteria are also likely to be unique. Even though some RFIs may have several
phases, it is important to make sure that the establishment of a phased approach
does not result in undue delay of the RFI process.
Case Study No. 18 in Volume IV (Case Study Examples) provides an illustration
of a phased characterization.
3.3 Data Quality and Use
Throughout the RFI process, it should be kept in mind that the data will be
used in making comparisons to health and environmental criteria to determine
whether a CMS or interim corrective measures may be necessary. Therefore, the
data collected during the investigation must be of sufficient quality to support
decisions as to the need for corrective measures. The data can also be used to help
establish the scope and types of corrective measures to be considered in the CMS.
Qualitative or quantitative statements that outline the decision-making
process and specify the quality and quantity of data required to support decisions
should be made early in the planning stages of the RFI. These "data quality
objectives are then used to design-sampling and analytical plans, and to determine
the appropriate level of quality assurance and control (QA/QC). As this subject is
normally considered a QA/QC function, it is presented in more detail in the QA/QC
Section (Section 4) of this document. It is briefly discussed here to stress the
importance of defining the objectives of the investigation, and of designing data-
gathering efforts to meet these objectives throughout the investigation.
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3.4 Procedures for Characterizing the Contaminant Source and the
Environmental Setting
Before monitoring procedures are established, information on the
contaminant source (i.e., waste and unit) and environmental setting may be
required. The owner or operator should identify, necessary data and formulate
procedures to gather these data.
Unit-specific data that may be required for release investigation include such
parameters as the physical size of the unit, the amount of waste in the unit,
operational schedules, age, operational lifetime, and release controls. Data
concerning the environmental setting that may be necessary are specific to the
medium affected, and may include such information as climate, hydrogeologic
setting, vegetation, and topography. These and other important elements are
described below, starting with a discussion of the importance of existing
information.
Case Study Numbers 8, 10, 12, 13, 14, and 30 in Volume IV (Case Study
Examples) provide examples of the techniques discussed below.
3.4.1 Sources of Existing Information
Useful existing data maybe found in the following sources:
The RCRA Facility Assessment report. This report should provide
information on the unit(s) known to be causing or suspected of causing a
release to the environment and the affected media. It may also include
data supporting the regulatory agency's release determinations. The
owner or operator may wish to obtain, the RFA report from the
regulatory agency for use in scoping the RFI.
Facility records and files. Other useful information may be available in
facility records and files. This information may include, data from
required ground-water monitoring activities, results of required waste
analyses, and other analytical results (e.g., tests run on wastes to
determine such parameters as liner compatibility or free liquid
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compositaion). The owner or operator may have information on the
characteristics of the waste in the units of concern from other in-house
sources, such as waste reduction and engineering studies on the
process(es) feeding the units, or from analyses performed in conjunction
with other regulatory programs, such as the National Pollutant Discharge
Elimination System (NPDES) permitting process or Clean Air Act
Standards. Design and construction information may also be contained
within facility files. For example, design and construction information
for advanced wastewater treatment systems may contain information on
inactive units.
RCRA Permit Application. Under current requirements, a RCRA permit
application should include a description of the waste being managed at
the facility (although not necessarily for all the units of concern),
descriptions of the units relevant to the permit, descriptions of the
general environment within and surrounding, the facility (including
descriptions of the subsurface stratigraphy), and design and operating
information such as runon/runoff controls. A companion rule
(promulgated December 1, 1987) to the July 15, 1985, codification rule
for Section. 3004(u) expands the information requirements under
§,270.14(d) for all solid waste management units to be located on the
facility topographic map, and to contain information on unit type,
dimensions and design, dates operated, and waste managed, to the
extent available.
State Construction Permit (e.g., industrial wastewater) files.
Environmental or other studies conducted in conjunction with ownership
changes.
Interviews with facility personnel (current or retired).
Environmental audit reports.
Investigations for environmental insurance policies.
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3.4.2 Waste and Unit Characterization
In addition to obtaining waste data-on general parameters such as pH, density,
and viscosity, which may be needed to characterize a release to specific media (and
which may also be useful in evaluating corrective-measure technologies), the owner
or operator should characterize the unit's waste to the compound-specific level.
This characterization may seine as a basis for identifying monitoring constituents
and indicator parameters for the media of concern. It should be noted that the
owner or operator may be required to characterize all potential constituents of
concern for a given medium, unless it can be shown that only certain constituents
could be released from the waste source. A detailed waste characterization,
through the use of facility records and/or additional waste sampling and analysis,
can be utilized to limit the number of constituents for which release monitoring
must be performed during the RFI. (See also Section 3.6.1.)
Waste and unit characterization procedures should address the following:
Existing sources of information on the unit and waste and their utility in
characterizing the waste source; and
Methods for gathering data on the waste and unit that are not presently
available.
In some cases the location of disposal areas (units) may not be obvious. Some
of these disposal areas or units may have been buried, overgrown by trees, or
covered by structures such as buildings or parking lots. In such cases, use of
geophysical techniques (e.g., ground-penetrating radar - see Appendix C) may be
useful in locating former disposal areas containing materials such as discarded
drums or buried tanks.
After evaluating existing data, the owner or operator may propose to collect
additional waste and unit characterization information. In such cases, the owner or
operator should propose procedures in the RFI Work Plan for
Sampling-This should include sampling locations, schedules, numbers of
samples to be taken, and methods for collecting and storing samples.
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Analysis-This should include a listing of analytical constituents or
parameters, and the rationale for their selection, analytical methods, and
identification of detection limits.
QA/QC-This should include specific steps to be taken to ensure the
viability and validity of data produced during a waste sampling effort.
Data management-The owner or operator should describe data
management procedures, including the format(s) by which data on the
contaminant source will be presented to the regulatory agency and the
various reports that will be submitted.
Further guidance on the types of information and methods to be used in
gathering waste and unit data is given in Section 7. Case Study Numbers 3,4,7,8,9,
and 10 in Volume IV (Case Study Examples) illustrate some of the activities discussed
above.
3.4.3 Characterization of the Environmental Setting
Data on the environmental setting will generally be necessary for
characterizing the release, and may also be helpful for evaluating various
corrective-measure technologies. The information necessary is specific to the site
and medium receiving the release and is described in the media-specific sections
(Sections 9 through 13). Some examples of the methods and techniques that may be
used are as follows:
Direct media measurements-Direct media measurements can provide
important information that can be used to determine the rate and extent
of contaminant release. For example, hydraulic conductivity
measurements are essential in determining ground-water flow rates.
Wind roses and patterns can be used in determining how far air
contamination, may migrate and are essential input for air dispersion
models. Specific measurements helpful for investigating the rate and
extent of releases are discussed in the media-specific sections (Sections 9
through 13) of this Guidance.
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Aerial photography -- Aerial photography can provide information that
can" be helpful in determining the extent of contamination at a site.
interpretation of aerial photographs can aid in describing past and
present contaminant sources, pathways, and effects. Information
obtained can include ecological impacts (e.g., decaying vegetation),
topography, drainage patterns, fracture traces, and other erosional
features. The usefulness of aerial photography is discussed further in
Appendix A.
Geophysical techniques-Geophysical techniques can aid in
characterizing subsurface conditions fairly rapidly with minimal
disturbance of the site. Such characterization can provide information
on physical (e.g., stratigraphic) and chemical (e.g., contaminant extent)
conditions and can also be used to locate buried drums, tanks, and other
wastes. Geophysical techniques include electromagnetic induction,
seismic refraction, electrical resistivity, ground-penetrating radar,
magnetic borehole methods, and other methods. These techniques can
be particularly useful in determining appropriate sampling locations.
However, these geophysical techniques are not always applicable at a
particular site and do not provide detailed contaminant concentration
data. Therefore, sampling will generally be necessary to provide data
needed for adequately characterizing the release. Further details on
these techniques are available in Section 10 on Ground Water, and in
Appendix C (Geophysical Techniques).
Surveying and mapping-According to the 40 CFR Part 270 requirements
for RCRA permit applications, the owner or operator must provide a
topographic map and associated information regarding the site. If an
adequate topographic map does not exist, a survey may be necessary to
measure and plot land elevations. Site-specific surveying and mapping
can provide an effective means of expressing topographic-features (e.g.,
subtle elevation changes and site drainage patterns) of an area useful in
characterizing releases. Surveying and mapping are discussed in further
detail in Appendix A.
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The owner or operator should describe the following in the RFI Work Plan:
Specific techniques to be used in defining the environmental setting for
the releases of concern at the facility;
A rationale for the use of these techniques;
Specific QA/QC procedures applicable to the proposed techniques;
. Procedures for managing and presenting the data; and
Potential uses of the information obtained from this characterization.
3.4.4 Assembling Available Monitoring Data
The owner or operator should compile and assess available media-specific
monitoring data as a means of determining additional data needs. It is conceivable,
in certain instances, that available data will be sufficient to characterize a release
and provide the basis for making a determination on the need for corrective
measures. However, this conclusion would be valid only if available data are
current, comprehensive, accurate, and supported by reliable QA/QC methods.
Otherwise, the use of available data should be limited to planning additional
monitoring efforts.
3.5 Use of Models
3.5.1 General Applications
Mathematical and/or computer modeling may, provide information useful to
the owner or operator during the RFI and in the design of corrective measures. The
information may prove useful in refining conceptualizations of the environmental
setting, defining likely contaminant release pathways, and designing corrective
measures (e.g., pumping and treating contaminated ground water).
Because a model is a mathematical representation, of an often-complex
physical system, simplified assumptions must be made about the physical system, so
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that it may-fit into the more simplistic mathematical framework of the model. Such
assumptions are especially appropriate because the model assumes a detailed
knowledge of the relevant input parameters (e.g., permeability, porosity, etc.)
everywhere in the area being modeled.
Because a model uses-assumptions as to both the physical processes"involved
and the spatial and temporal variations in field data, the results produced by the
model may provide only a qualitative assessment of the nature, extent, and rate of
migration of a contaminant release. Because of the assumptions made, a large
degree of uncertainty may arise from some modeling' simulations. Such modeling
results should not be unduly relied on in selecting precise monitoring locations or in
designing corrective measures.
Use of predictive models during the RFI may be appropriate for guiding the
general development of monitoring networks. Each of the media-specific sections
identify where and how such predictive models may be used, and identify
references containing specific models. For example, models are identified in the
Surface water Section (Section 13) for use in determining the extent of a
monitoring system' which may"be necessary in a stream. Modeling results are
generally not acceptable for expressing release concentrations in an RFI. An
exception to this is the air medium (Section 12). Atmospheric dispersion models are
suggested for use (especially when downwind monitoring is not feasible) in
conjunction with emission-rate monitoring or modeling in order to predict
downwind release concentrations and to define the overall extent of a release.
Where a model is to be used, site-specific measurements should be collected
and verified. The nature of the parameters required by a model varies from model
to model and is a function of the physical processes being simulated (e.g., ground-
water flow and/or contaminant transport), as welt as the complexity of the model.
In simulating ground-water flow, for example, hydrogeologic parameters-that are
usually required include hydraulic conductivity (vertical and horizontal); hydraulic
gradient; specific yield (unconfined aquifer) or specific storage (confined aquifer);
water levels in wells and nearby surface-water bodies; and estimates-of infiltration
or recharge. In simulating contaminant transport in ground water, physical and
chemical parameters that are usually required include ground-water velocity;
dispersivity of the aquifer; adsorptive characteristics of the aquifer (retardation);
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degradation characteristics of the contaminants; and the amount of each.
contaminant entering the aquifer (source definition).
Model input parameters that can be determined directly should be measured,
with consideration given to selecting representative samples. Because the
parameters cannot be measured continuously over the entire region but only at
discrete locations, care should be taken when extrapolating over regions where
there are no data. These considerations are especially important where the
parameters vary significantly in space or time. The sensitivity of the model output
both to the measured and assumed input parameters should be determined when
evaluating modeling results. In addition, the ability of the model to be adequately
calibrated (i.e., the ability of the model to reproduce current conditions), and to
reproduce past conditions should be carefully evaluated in assessing the reliability
of model predictions. Model calibration with observed physical conditions is critical
to any successful modeling exercise,
Many models exist that may be applicable for use in the RFI. Because EPA is a
public agency and models used by or for EPA may become part of a judicial action,
EPA approval of model use should be restricted, to those models that are publicly
available (i.e., those models that are available to the public for no charge or for a
small fee). The subset of models that are publicly available is quite large and should
be sufficient for many applications. Publicly available models include those models
developed by or for government agencies (e.g., EPA, U.S. Geological Survey, U.S.
Department of Energy, U.S. Nuclear Regulatory Commission, etc.) and national
laboratories (e.g., Sandia, Oak Ridge, Lawrence Berkeley, etc.), as well as models
made publicly available by private contractors. Any publicly available model chosen
should however, be widely used, well-documented, have its theory published in
peer-reviewed., journals, or have some other characteristics reasonably ensuring its
credibility. For situations where publicly available models are not appropriate,
proprietary models (i.e., models not reasonably accessible for use or scrutiny by the
public) should, be used only where the models have been well-documented and
have undergone substantial peer review. If these minimal requirements have not
been met, the model will not be considered reliable.
The Graphical Exposure Modeling System (GEMS) may be particularly useful
for various aspects of the RFI. GEMS is an interactive computer system, developed
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by EPA's Office of pesticides and Toxic Substances which provides a simple interface
to environmental modeling, physiochemical property estimation, statistical analysis,
and graphic display capabilities, with data manipulation which supports all these
functions: Fate and transport models are provided for soil, ground water, air, and
surface water, and are supported by various data sets, including demographic;
hydrologic, pedologic, geologic, climatic, economic, amoung others. Further
information on GEMS may be obtained by calling EPA at (202) 382-3397 or (202)
382-3928 or by writing to EPA at the following address:
U.S. EPA
Office of Pesticides and Toxic Substances
Exposure Evaluation Division (TS-798)
401 M Street, S.W.
Washington, D.C. 20460
If the use of a model is proposed to guide the development of a monitoring
network, the owner or operator should describe how the model works, and explain
all assumptions used in calibrating and applying the model to the site in question.
in addition, the model and all related documentation should be made available to
the regulatory agency for review.
Case Study Numbers 20, 24, 25, and 31 in Volume IV (Case Study Examples)
illustrate the use of various models that maybe applied during the RFI.
3.5.2 Ground-Water Modeling
Ground-water modeling is often used for site characterization, remedy
selection and design, and prediction of site-specific cleanup levels and time --
requirements. As with other models, a ground-water model is a simplified
representation of reality, usually expressed with mathematics, that aids in
understanding and predicting subsurface contaminant fate and transport. As such,
models may include flow nets, ground-water flow models, simple analytical solute
transport models, method of characteristics models, or complex multi-phase finite
element models.
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Perhaps the most important role of ground-water models for assessment and
remediation programs is their application in selecting, collecting and analyzing field
data on subsurface contaminant fate and transport. Model development and site
characterization should be combined in an iterative process of fate and transport
simulation and data collection. For instance, after examining several cross-sections
and water level data sets, the investigator may develop several flow nets to better
understand the ground-water flow regime beneath a site. Following this, a series of
simulations using a simple analytical solute transport model can roughly estimate
the range of concentrations with respect to distance and time for various
contaminants. These results could then be compared with actual concentrations of
samples collected from monitoring wells. Discrepancies between observed and
predicted' concentrations may suggest that additional site characterization is
required or that the model does not adequately simulate actual field conditions.
Ground-water models may be used to some extent in predicting contaminant
migration, selecting and designing remedial systems, evaluating the performance
of technologies, and projecting cleanup levels. For instance, assuming a pump and
treat alternative is appropriate, analytical or numerical ground-water flow models
could be used to estimate the placement of recovery wells and plume control wells,
Such models could also be used in planning the timing of ground-water
withdrawals. However, these types of applications should only be used in concert
with actual data collection (e.g., collecting ground-water samples) and field
demonstrations (e.g., pilot studies). Exclusive model use for the above applications
without adequate data collection and field demonstration may lead to incorrect
and inefficient remedy selection.
The following, documents provide information on the uses of models and
point out many of their limitations and underlying assumptions:
Keely, J.F. January 1987. The Use of Models in Managing Ground Water
Protection Programs. EPA/600/8-87/003. EPA Office of Research and
Development, Washington, D.C. 20460.
U.S. EPA. January 1989. Resolution on Use of Mathematical Models bv EPA for
Regulatory Assessment and Decision-Making. Report of the Environmental
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Engineering, Committee, Science Advisory Board. EPA-SAB-EEC-89-012.
Washington, D.C. 20460.
These documents emphasize the importance of using ground-water models
that are commensurate with the extent and quality of collected field data.
Matching" the model with the type of contamination problem is equally important.
Certain instances may arise where more sophisticated models may be appropriate.
For example, a finite element model simulating multi-phase flow of a hydrocarbon
release in a well-characterized area may contribute to both defining the problem"
and selecting the remedy. The key rule to follow is to match the model with the"
type of contamination problem and the level and quality of data. In addition, every
modeling exercise should include a sensitivity analysis to determine the relative
impact of different variables on modeling results. The following presents excerpts
from the above identified EPA Science Advisory Board report on mathematical
models which are particularly relevant for regulatory assessment and decision-
making:
The use of mathematical models for envronmental decision-making has
increased significantly in recent years. The reasons for this are many,
including scientific advances in the understanding of certain
environmental processes, the wide availability of computational
resources, the increased number of scientists and engineers trained in
mathematical formulation and solution techniques, and a general
recognition of the power and potential benefits of quantitative
assessment methods. Within the U.S. Environmental Protection Agency
(EPA) environmental models which integrate release, transport, fate,
ecological effects and human exposure are being used for rule making
decisions and regulatory impact assessments.
The realistic characterization of an environmental problem requires the
collection of laboratory and field data - the more complex the problem,
the more extensive and in-depth are the required studies. In some cases
involving more complex issues, future projections of environmental
effects, larger geophysical regimes, inter-media transfers, or subtle
ecological effects, mathematical models of the phenomena provide an
essential element of the analysis and understanding. However, the
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models cannot stand alone; adequate data are required. Indeed, a major
function of mathematical models is as a tool to design field studies,
interpret the data and generalize the results.
Mathematical models should ideally be based on a fundamental
representation of the physical, chemical and biological processes
affecting environmental systems.
An improperly formulated model can lead to serious misjudgements
concerning environmental impacts and the effectiveness of proposed
regulations. In this regard, a bad model-can be worse than no model at
all.
There are a number of steps needed to confirm the accuracy and utility of
an environmental model. As a preliminary step, the elements of the basic
equations and the computational procedures employed to solve them
should be tested to ensure that the model generates results consistent
with its underlying theory. The confirmed model should then be
calibrated with field data and subsequently validated with additional
data collected under varying environmental conditions.
The stepwise procedure of checking the numerical consistency of a
model, followed by field calibration, validation and a posteriori
evaluation should be an established protocol for environmental quality
models in all media, recognizing that the particular implementation of
this may differ for surface water, air and ground water quality models.
A number of methods have been developed in recent years for
quantifying and interpreting the sensitivity and uncertainty of models.
These methods require careful application, as experience with
uncertainty analysis techniques is somewhat limited, and there is a
significant potential for misuse of the procedures and misinterpretation
of the results. Potential problems include the tendency to confuse model
uncertainty with temporal or spatial variation in environmental systems,
the tendency to rely on model uncertainty analysis as a low-cost
substitute for actual scientific research, and the tendency to ignore
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important uncertainties in model structure when evaluating
uncertainties in model parameters.
peer review is an essential element of all scientific studies, including
modeling applications. Peer review is appropriate in varying degrees and
forms at different stages of the model development and application
process. The basic scientific representation incorporated in the model
should be based on formulations which have been presented in the peer
reviewed scientific literature. Ideally, the model itself and initial test
applications should also be presented in peer-reviewed papers.
3.6 Formulating Methods and Monitoring Procedures
The RFI Work Plan should describe monitoring procedures that address the
following items on a release specific basis:
Monitoring constituents of concern and other monitoring parameters
(e.g., indicators);
Sampling locations and frequency;
Sampling methods;
Types of samples to be collected;
Analytical methods; and
Detection limits.
These items are discussed below.
3.6.1. Monitoring Constituents and Indicator Parameters
Selection and use of reliable and useful monitoring constituents and indicator
parameters is a site-specific process and depends on several factors, including the
following:
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The phase of the release investigation (e.g., verification, characteriza-
tion);
The medium or media being investigated;
The degree to which verifiable historical information exists on the unit or
release being investigated;
The degree to which the waste in the unit(s) has been characterized
through sampling and analysis;
The extent of the release;
The concentration of constituents within the contaminated media; and
The potential for physical, chemical, or biological transformations (e.g.,
degradation) of waste or release constituents.
The general strategy for the selection of specific monitoring constituents starts
with a large universe list of constituents (i.e., 40 CFR Part 261, Appendix VIII). (It
should be noted that the definition of constituent may also include components of
40 CFR Part 264, Appendix IX that are not also on Appendix VIII, but are normally
monitored for during ground-water investigations.) Based on site-specific
considerations (e.g., the contaminated media, sampling and analysis of waste from
the unit, or industry-specific information), this list may be shortened to an
appropriate set of monitoring constituents. Constituents initially deleted as a result
of this process may have to be analyzed at selected locations during and/or
following the RFI, especially if a CMS is found necessary. The discussion below
explains the use of the four lists presented in Appendix B for selecting monitoring
constituents and supplemental indicator parameters.
List 1 in Appendix B identifies indicator parameters recommended for release
verification or characterization for the five environmental media discussed in this
Guidance. This list was developed based on a review of RCRA and CERCLA
guidances, as well as on information obtained during RCRA and CERCLA site
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investigations. These indicator parameters should be used in the RFI unless the
owner or operator can show that their use will not be helpful. For example,
although total organic carbon and total organic halogen are listed as indicator
parameters for ground water, their use may not be warranted for releases
consisting primarily of inorganic (e.g., heavy-metal) contamination. In addition, as
indicated in the footnote in List 1, although TOC and TOX have historically been
used as indicator parameters for site investigations, the latest data suggests that use
of these parameters may not provide an adequate indication of contamination,
primarily due to precision and accuracy problems.
At most sites, however, the use of indicator parameters will be appropriate,
especially for ground-water monitoring. In general, any constituent not expected
to be contained in or derived from the waste or the contaminated area may not
serve as a reliable or practical indicator of a release. Studies have examined the
frequency of occurrence of analytes in ground-water at hazardous waste sites
throughout the country (Garman, Jerry, Tom Freund and Ed Lawless. 1987. Testing
for Ground-water Contamination at Hazardous Waste Sites: Journal of
Chromatographic Science, Vol. 25, pp. 328-337). These studies indicate that metals
and volatile organic compounds (VOCs) are two sets of analytes that generally
provide a reliable and practical way of detecting and monitoring a release to
ground water.
In addition, investigations by EPA's Environmental Monitoring Systems
Laboratory in Las Vegas, Nevada, and others have shown that most of the
compounds being released from hazardous waste facilities (as high as 70%) are
volatile organics. These compounds have a low molecular weight and are fairly
water soluble, which accounts for their high mobility in ground water.
Furthermore, volatiles are produced in relatively large quantities in the United
States and wastes containing them are managed in significant quantities at most
permitted hazardous waste facilities.
Metals, particularly those that are amenable to the ICP (Inductively Coupled
Plasma) scan, are the second most common set of contaminants that are released at
hazardous waste management facilities, and therefore are also expected to be
excellent indicators of releases to ground water, as alluded to earlier.
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A list of those 40 CFR 264 Appendix IX constituents commonly found in
contaminated ground water and amenable to analysis by volatile organics and ICP
(metals) methods is provided in List 2.
List 3 in Appendix B is a master list of potential hazardous constituents that
may, at one time or another, have to be monitored during an RFI. It contains the 40
CFR Part 261, Appendix VIII list of hazardous constituents in the left-hand column.
The five environmental media columns contain X's where there is a reasonable
probability, based on physical or chemical characteristics, of a particular constituent
being present in the given medium. However, constituents not containing an X for
a particular medium may still be present in that medium, despite a relatively low
probability Of their presence. Therefore, the regulatory agency may add such
constituents for monitoring when appropriate. List 3 was derived through
consultation with various EPA program offices and through examination of existing
regulations. The rationale for identifying specific Appendix VIII constituents for the
various media is explained below:
Reactivity with water. Those constituents that react with or decompose
in water were not marked with an X in the water-related columns.
Existence of viable analytical techniques for a constituent in a specific
medium. In many cases, constituents were not included for a specific
medium because valid analytical methodologies are not currently
available for that particular constituent/medium combination. In some
cases, standard reference materials are not available for the analysis.
(Note that the above two criteria describe the primary rationale used to develop the
40 CFR Part 264, Appendix IX list of ground-water monitoring constituents. Hence,
the ground-water and surface-water columns in List 3 are based on the final
Appendix IX constituent list.)
Recommendations from other EPA program offices. Offices concerned
with the release of hazardous constituents to various media were
consulted for recommendations on the analytes of primary concern.
Appendix VIII hazardous constituents regarded by EPA's Office of Air
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Quality Planning and Standards (OAQPS) as being of primary concern for
release to air are identified in the air column in List 3.
Background information. Analytes recommended for subsurface gas
releases-were chosen due to their predominance in past studies of this
problem. The primary sources used for the subsurface gas medium are:
U.S. EPA. Technical Guidance for Corrective Measures -Subsurface
Gas. Prepared by SCS Engineers for u.s. EPA, Office of Solid Waste.
Washington, D.C. 20460.
South Coast Air Quality Management District. December 1986.
Hazardous Pollutants in Class II Landfills. U.S. EPA, Region IX. San
Francisco, CA94105.
The soil column includes constituents that may be present in both
saturated and unsaturated soil. The column generally identifies
constituents that are also identified for the ground-water and surface-
water media, but contains additional constituents that are normally
analyzed during soil contamination investigations (e.g., hydrogen sulfide
and other gases), and certain other compounds that can be highly
attenuated in soil (e.g., polyaromatic hydrocarbons).
An RFI may involve the investigation of waste which is hazardous by
characteristic, as well as containing specific hazardous constituents. For example,
methane, which is not an Appendix VIII hazardous constituent, is shown as an
indicator parameter in List 1 for releases of subsurface gas. Because methane at
sufficient concentrations possesses explosive or reactive propetiies, it can be
hazardous based on the reactivity characteristic (40 CFR 261.23). Hence, subsurface
gas may be the subject of an RFI even if specific hazardous constituents are not
identified in the release.
List 4 in Appendix B is an industry-specific list. This list identifies categories of
constituents, based on the classification presented in the 3rd Edition of EPA's Test
Methods for Evaluating Solid Waste CEPA/SW-8461 that may be present if wastes
from a given industry are contained in the releasing unit. The EPA/SW-846 chemical
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classifications for these categories are reprinted as a supplement to List 4. List 4
applies to all media and may be used in conjunction with List 3 to identify industry-
specific constituents that have a reasonable probability of being present in a
particular medium. List 4 was derived from a review of the Development
Documents for Effluent Guidelines Limitations prepared for various industries
under EPA's NPDES program, information received from several EPA Regional Office
Hazardous Waste Programs, and other references, as indicated in Appendix B. It
does not cover all industries that may be subject to an RFI. The Development
Documents for Effluent Guidelines Limitations are available for the 30 industries
identified in List 4, and may be obtained from the National Technical Information
Service (NTIS).
(Note that the chemical categories upon which List 4 are based are not
mutually exclusive. If a category is identified as being appropriate for an industry,
all constituents within the category should be monitored regardless of whether the
constituent is contained in other categories.)
The use of the Appendix B lists in developing and implementing the general
investigation strategy is described below.
The phase of the release investigation is a very important consideration. For
example, the use of indicator parameters (List 1) along with specific hazardous
constituents, can be helpful in verifying the presence of a suspected release.
However, indicators alone are not adequate in showing the absence of a release,
partially because of their relatively high detection limits (i.e., generally. 1000 ug/1
versus 10 to 20 ug/1 for specific constituent analyses), and because indicator
parameters do not account for all classes of constituents that may be present.
Verification of the absence of a release should therefore always be supported by
specific hazardous constituent analyses.
For the same reasons, indicator parameters should not form the sole basis for
release characterization, especially at locations in the release where indicator
concentrations are close to detection limits. Indicator parameters may be
particularly useful in mapping large releases, but should always be used in
conjunction with specific monitoring constituents.
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Specific monitoring constituents and indicator parameters may also need to be
modified as the investigation progresses, because physical, chemical, and biological
degradation may transform constituents as the release ages or advances. When
chemicals degrade, they usually degrade into less toxic, more stable species.
However, this is not always the case. For example, one of the degradation products
of trichloroethylene is vinyl chloride. Both of these chemicals are carcinogens
Information on degradation can be found in the environmental literature.
Particular references include:
U.S. EPA. 1985. Atmospheric Reaction Products from Hazardous Air
Pollutant Degradation. NTIS PB85-185841. Washington, D.C. 20460.
U.S. EPA. 1984. Fnte of Selected Toxic Compounds Under Controlled
Redox Potential and pH Conditions in Soil and Sediment Water Systems.
NTIS PB84-140169. Washington, D.C. 20460.
This topic is discussed in more detail later in this section and in each of the
media-specific sections.
After a release is adequately characterized in terms of concentrations of
hazardous constituents (or hazardous characteristics), a comparison of these
concentrations to EPA health and environmental-based criteria will be made (see
Section 8). Although this comparison may involve a shortened list at this stage of
the RFI, all potential monitoring constituents (even those deleted earlier in the
process) may need to be analyzed at selected monitoring locations to verify their
presence or absence.
The use of ICP spectroscopy (for metals) and gas chromatography/mass
spectrometry for volatile organic compounds (List 2) can be particularly helpful in
delineating releases where little or no information is available on the source. These
methods are relatively cost-effective because they address a number of constituents
in a single analysis.
The medium or media being investigated is also an important consideration in
identifying monitoring constituents. For example, non-volatile constituents may be
poor candidates for monitoring of an air release, unless wind-blown particulate are
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of concern. List 3 in Appendix 8 has been developed to aid in identifying
constituents most likely to be measurable in each medium of concern.
Historical information (e.g., records indicating the industry from which wastes
originated) may be useful in selecting monitoring constituents. List 4 in Appendix B
may be helpful in identifying classes of constituents that may be of concern if a
particular industry can be identified.
Waste sampling and analysis (see Section?) may be performed to tailor the
initial list of monitoring constituents. Although complete waste characterization is
recommended in most cases, this may. not always be possible or desirable (e. g., for a
large unit in which many different wastes were managed over a long period or in
cases where wastes have undergone physical and/or chemical changes over a long
period). A complete historical waste characterization in such cases would not be
possible. Other cases where waste sampling and analysis would generally be
inadvisable are those where the waste is highly toxic (e.g., nerve gas) or explosive
(e.g., disposed munitions). In these cases, it may be more appropriate to sample the
environmental medium of concern at locations expected to indicate the highest
release concentrations. Such sampling activities should be performed following
appropriate health and safety procedures (see Section 6).
The extent of the release may also dictate, to some degree, the selection of
monitoring constituents. For apparently small releases (e.g., 5 square yards of
contaminated soil), it may be reasonable to base all analyses on specific monitoring
constituents. For larger releases, the use of indicator parameters along with specific
monitoring constituents may be a better approach. In this case, an appropriate
balance between indicator parameters and monitoring constituents is advisable.
In addition, the potential for physical, chemical, or biological transformations
(e.g., degradation) of constituents should also be considered in identifying monitor-
ing constituents. Biodegradation may be of particular importance for the soil and
surface-water media. For example, trichloroethylene in a waste unit or medium can
degrade over time to vinyl chloride and other products. Such products may be
present at higher concentrations than the parent trichloroethylene and may also be
more toxic. Therefore, the selection of monitoring constituents should consider the
potential for constituents to be transformed over time. Each of the media-specific
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sections contains a discussion of physical chemical and biological transformation
mechanisms.
Another approach that may be taken in selecting monitoring constituents for
a particular medium is to use physical and chemical property data, such as the
octanol/water partition coefficient or solubility, to predict which constituents may
be present in a given medium. Further guidance on the use of this approach,
including tables presenting data on relevant physical and chemical properties of
various constituents, is presented in the following reference:
U.S. EPA. October, 1986. Superfund Public Health Evaluation Manual. EPA
540/1-86/060. NTIS PB87-183125. Office of Emergency and Remedial
Response. Washington, D.C. 20460.
Case Study Numbers 1, 2, 4, 9, and 10 in Volume IV (Case Study Examples)
illustrate application of the concepts discussed above.
3.6.2 Use of EPA and Other Methods
As described in the preceding sections, and in the, media-specific sections
(Sections 9 through 13), many different types of methods may be employed in
concluding the RFI. These include, methods for sampling, QA/QC, and field
operations, as well as methods for physical, biological, and chemical analyses. These
methods were developed by various organizations, including EPA, other Federal
and State agencies, and by "standard-setting" organizations (e.g., ASTM, (American
Society for Testing and Materials)). Some of these methods are final, while others
are in draft or proposed status. As discussed previously, the RFI Work Plan should
propose methods that best suit the needs of the situation under investigation.
Guidance in the following sections, and in the media-specific sections, is given on
methods recommended in certain situations, including appropriate references. The
following discussion highlights some general guidelines to follow in the selection of
methods:
t Use of EPA Methods:
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EPA recently published the 3rd Edition of its testing manual for solid
waste (U.S. EPA. 1986. Test Methods for Evaluating Solid Waste.
EPA/SW-846, GPO No. 955-001-00000-1), generally known as SW-846.
This manual provides QA/QC methods, analytical methods, physical and
chemical property test methods, and sampling and monitoring methods.
These methods are acceptable for the RFI and contain guidance on
unique problems that may be encountered during solid and hazardous
waste investigations. Where possible, it is recommended that SW-846 (or
equivalent), methods be used over other available methods. SW-846,
however, may not provide all methods applicable in certain situations. In
such cases, other EPA methods manuals (including EPA Regional Office
methods manuals) may be used. One such document that should be
particularly useful is EPA's Compendium of Field Operations Method.
developed by the Office of Emergency and Remedial Response (OSWER
Directive No. 9355.0-14, EPA 540/P-87/OO1A, August 1987). This
document provides discussions of various methods that can be applied in
field investigations, and includes general considerations for project
planning, QA/QC, and sampling design. Specific methods presented
include:
Rapid field screening procedures (e.g., soil gas surveys using
portable field instruments);
Drilling in soils;
Test pits and excavation;
Geological reconnaissance;
Geophysics;
Ground-water monitoring;
Physical and chemical properties;
Surface hydrology;
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Meteorology;
Biology and Ecology/Bioassay and Biomonitoring; and
Surveying, Photography, and Mapping.
* Use of Other Federal or State Methods:
The Occupational Safety and Health Administration (OSHA), the Food
and Drug Administration (FDA), and several other Federal agencies have
developed methods and methods manuals for specific applications. In
addition, State and EPA Regional Offices have also developed methods
and methods manuals. These methods may also be used during release
investigations, if appropriate. The media-specific sections of this
Guidance identify where such methods may be particularly applicable.
Use of Other Methods:
Several "standard-setting" organizations are involved in the
development of test methods for. various applications. One such
organization, the ASTM, publishes test methods and other standards in
its Annual Book of ASTM Standards, which is updated yearly. Many of
ASTM's methods may be applicable for use in the RFI; however, if
comparable EPA methods exist, they are preferred because they often
contain important information necessary for regulatory purposes.
Many ASTM and EPA methods are similar and some are identical. The primary
reason for this is that many EPA methods are derived from ASTM methods.
Some of ASTM's methods are adopted by EPA in toto. EPA's Compendium of
Field Operations Methods, for example, contains many ASTM methods that
can be used during an RFI.
Although ASTM's Committee D-34 on Waste Disposal has only published
several final methods (ASTM. 1986 Annual Book of ASTM Standards. Volume
11:04), it has many other methods currently in various stages of development.
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Several methods under development that may be applicable to the RFI process
are expected to be finalized and available soon.
Other Organizations are also involved in the development and standardization
of test methods. Many industrial and environmental association methods can
also be used during an RFI. EPA's Compendium of Field Operations Methods
identifies several of these.
All methods proposed for use by the owner or operator should be clearly
described and adequately referenced.
3.6.3 Sampling Considerations
This section discusses several considerations important in designing a sampling
plan, including sample types, and pertains to sampling of the waste source and the
affected environmental media. Section 7 contains additional guidance on waste
source sampling. A general discussion of sampling equipment and procedures is
presented in EPA's SW-846. Other guidances containing general information that
can be used in designing sampling plan include the following:
U.S. EPA. August, 1987. Compendium of Field Operations Methods. Office of
Emergency and Remedial Response. OSWER Directive No. 9335.0-14. EPA
549/P-87/001A. Washington, D.C. 20460.
U.S. EPA. 1985. Practical Guide for Ground-Water Sampling. Roberts. Kerr
Environmental Research Laboratory. EPA/600/2-85/104. Ada Oklahoma.
U.S. EPA. 1986. RCRA Grounrl-wnster Monitoring Tenhninnl
Guidance Document. OSWER Directive No. 9950.1 . Office of Waste Programs
Enforcement. Washington, D.C. 20460.
U.S. EPA. July 24, 1981. RCRA Inspection Mnnnnl. Section V. Office of Solid
Waste. Washington, D.C. 20460.
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U.S. EPA. June, 1985. Guidance on Remedial Investigations Under CERCLA.
Office of Emergency and Remedial Response. NTISPB85-238616. Washington,
D.C. 20460.
U.S. EPA. May, 1984. Soil Snmplinn Quality Assurance Users Guide. CR810550-
01. NTISPB84-198621. Washington, D.C. 20460.
3.6.3.1 General Sampling Considerations
Various methods exist for obtaining acceptable samples of waste and for each
medium described in this document. Each of the media-specific sections (Sections 9
through 13) describes appropriate methods. The RFI Work Plan should propose
methods that best suit the needs of the sampling effort. The following criteria
should be considered in choosing such methods:
Representativeness-The selected methods should be capable of pro-
viding a true representation of the situation under investigation.
Compatibility with Analytical Considerations-Sample integrity must be
maintained to the maximum extent possible. Errors induced by poorly
selected sampling techniques or equipment can result in poor data
quality. Special consideration should be given to the selection of
sampling methods and equipment to prevent adverse effects during
analysis. Materials of construction, sample or species loss, and chemical
reactivity are some of the factors that should receive attention.
Practicality-The selected methods should stress the use of simple,
practical, proven procedures capable of being used in or easily adapted
to a variety of situations.
Simplicity and Ease of Operation-Because of the nature of the material
to be sampled, the physical hazards that may be encountered during
sampling, and the wearing of safety equipment, the proposed sampling
procedures should be relatively easy to follow and equipment simple to
operate. Ideally, equipment should be portable, lightweight, and
rugged.
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Safety-The risk to sampling personnel and others, intrinsic safety of
instrumentation, and safety equipment required for conducting the
sampling should be carefully evaluated.
3.6.3.2 Sample Locations and Frequency
Because conditions in the unit or in the contaminant release will change both
temporally and spatially, the design of the monitoring network should be
developed accordingly. Spatially, sufficient samples should be collected to
adequately define the extent of the contamination. Temporally, the plan should
address spreading of the release with time and variation of concentrations due to
factors such as changes in background concentrations, waste management
practices, unit operations, the composition of the waste, and climatic and
environmental factors. For example, sampling and supplemental measurements
(e.g., wind speed) should be conducted when releases are most likely to be
observed, when possible.
Selection of specific sampling locations and times will be site- and release-
dependent. Three general approaches cap be used in selecting specific sampling
locations. Selection of a particular approach depends on the level of knowledge
regarding the release. Judgmental sampling generally involves selection of
sampling locations based on existing knowledge of the release configuration (e.g.,
visual evidence or geophysical data). A systematic approach involves taking samples
from locations established by a predetermined scheme, such as a line or grid. Such
samples can help to establish the boundaries of a contaminated area. Random
sampling involves use of a "randomizing scheme," such as a random number table,
to select locations within the study area.. Random sampling can be useful when
contaminant spatial distribution is expected to be highly variable. Regardlessof the
sampling approach taken, it is recommended that a coordinate (grid) system be
established at the site to describe and record sampling locations accurately. As a
release investigation progresses, and as more information regarding a release is
gathered, the sampling approach may be varied as appropriate. Application of
judgmental, systematic, and random sampling is discussed below.
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3.6.3.3. Judgmental Sampling
Judgmental sampling is appropriate when specific information exists on the
potential configuration of a release. Many releases are likely to fall into this
category, because site layout or unit characteristics will often indicate areas of
potential contamination. Examples of judgmental-sampling include:
Taking air samples at areas generally downwind of a unit;
, Taking grab samples of surface soils from a drainage channel that
receives surface runoff from a known contaminated area; and
Obtaining soil cores downslope from a known waste burial site.
Judgmental sampling will generally bias the data obtained toward higher
contaminant concentrations. For example, samples taken only from areas of
suspected contamination would generally be biased toward higher concentrations.
In many cases, this approach will suit the needs of the RFI.
3.6.3.4 Systematic or Random Grid Sampling
Systematic or random grid sampling allows the collection of a set of unbiased
samples at the area of concern. These samples can be used for detection of
contamination for calculation of averages (e.g., for characterizing the contents of a
surface impoundment when it is expected to be fairly homogeneous), and for
modeling purposes. The size and shape of the grid should consider-site-specific
factors. However, some general recommendations can be made for effective grid
planning. The following steps are recommended in establishing a grid system:
( 1 ) Choose the study area to be included in the grid. To define the full
extent of the contaminated area, this area should be larger than the
suspected extent of contamination.
( 2) select the shape and spacing of the grid. The shape may vary (e.g.,
rectangular, triangular, or radial), depending on the needs of the in-
vestigation. The grid spacing should be based on consideration of the
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appropriate density of sampling points. For example, an initial sampling
effort in an area of widespread, homogeneous contamination may use a
200-foot grid, whereas a search for "hot spots" in a poorly defined
contaminated area might require a 50-foot or smaller spacing.
(3) Draw (or overlie) the sampling grid on a plan of the site. To minimize
sampling bias, a random number table may be used to choose sampling
cells.
(4) Transfer the grid onto the study area by marking grid line intersections
with wooden stakes. The exact location of the sample within each grid
cell may be chosen systematically (e.g., at each node) or randomly (i.e.,
anywhere within each cell).
Figure 3-1 a shows a systematic grid with samples taken at each node. Random
grid sampling produces a sampling distribution such as that shown in Figure 3-lb. A
possible limitation of systematic grid sampling is that if contaminants are
distributed in a regular pattern, the sampling points could all lie within the "clean"
areas (Figure 3-1 c). This possibility should be considered when proposing a
sampling approach.
3.6.3.5 Types of Samples
The owner or operator should propose the types of samples to be collected
with the monitoring procedures. In general, there are three basic sample types:
grab, composite, and integrated, as discussed below.
Grab sampling-A grab sample is an individual sample taken at a specific
location at a specific time. If a contaminant source or release is known to
be fairly constant in composition over a considerable period of time or
over substantial distances in all directions, then the sample may serve to
represent a longer time period or a larger volume (or both) than the
specific point and time at which it was collected.
When a contaminant source or release is known to vary with time, grab
samples collected at suitable intervals and analyzed separately can
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a) SYSTEMATIC GRID SAMPLING
b) RANDOM GRID SAMPLING
x = BURIED WASTE
c) CASE IN WHICH SYSTEMATIC GRID SAMPLING MISSES
WASTES BURIED IN A REGULAR PATTERN
FIGURE 3-1. GRID SAMPLING.
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indicate the magnitude and duration of variations. Sampling intervals
should be chosen on the basis of the frequency with which variations
may be expected. It may not always be desirable to take samples at equal
intervals (e.g., subsurface gas releases are sensitive to seasonal
influences). If sample composition is likely to show significant variation
with time and space, grab samples from appropriate locations are
recommended.
Composite samples-Composites are combinations of more than one
sample collected at various sampling locations and/or different times.
Analysis of composites generally yields average values which may not
accurately describe the distribution of release concentrations or identify
hot spots. Compositing does not reflect actual concentrations and can
reduce some concentrations to below detection limits. Composites may,
in limited instances, be used to reduce the number of individual grab
samples (e,g., when calculating an average value is appropriate). For
example, compositing waste samples from a surface impoundment may
be performed to determine an average value over several different
locations. Compositing may also be useful in determining the overall
extent of a contaminated area, but should not be used as a substitute for
characterizing individual constituent concentrations. Therefore,
compositing should be limited and should always be done in conjunction
with an adequate number of grab samples.
Integrated samples-An integrated sample is typically a continuously
collected single sample taken to describe a population in which one or
more parameters vary with either time or space. An integrated sampling
technique can account for such variations by collecting one sample over
an extended time period, such that variations can be averaged over that
period. The most common parameter over which sampling periods are
integrated is time. Time-integrated samples can provide an average of
varying concentrations over the period sampled.
Integrated sampling may be appropriate under limited circumstances.
For example, process stream flows often change with variations in the
process itself or with environmental conditions, such as wind speed. A
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flow-integrated sampling device can collect a sample over a period of
time as the sampling rate increases or decreases with the rise and fall of
the stream flow. The device automatically biases sample collection
toward those periods of high flow, with sampling rates decreasing
during low-flow periods.
Integrated samples can be particularly useful for air and surface-water
investigations where continuous changes in environmental conditions
can affect constituent concentrations. See Sections 12 and 13 (air and
surface water, respectively) for more information.
3.6.4 Analytical Methods and Use of Detection Limits
Analytical methods should be appropriate for the constituents and matrices
being sampled. As indicated previously, the EPA publication Test Methods for
Evaluating Solid Waste (EPA/SW-846), should be used as the primary reference for
analytical methods. This document contains analytical methods that can be applied
to solid, liquid, and gaseous matrices, and also presents detection limits generally
associated with these methods. It is important to understand that detection limits
can vary significantly depending on the medium (e.g., air, water, or soil) and other
matrix-specific factors (e.g., presence of multiple contaminants). In addition to SW-
846, the following reference provides detection limit information for water and soil
matrices:
U.S. EPA. March, 1987. Data Quality Objectives for Remedial Response
Activities. Volume I (Development Process) and Volume 2 (Example Scenariol.
Office of Emergency and Remedial Response and Office of Waste Programs
Enforcement. EPA 540/G-78/003a. OSWER Directive No. 9335.0-7b.
Washington, D.C. 20460.
Detection limits should be stated along with the proposed analytical methods in the
RFI Work Plan. Analytical values determined to be at or below the detection limit
should be reported numerically (e.g., < O.lmg/L).
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3.7 RFI Decision Points
As monitoring data become available, both within and at the conclusion of
discrete investigative Phases they should be reported to the regulatory agency as
directed. The regulatory agency will compare the monitoring data to applicable
health and environmental criteria to determine the need for (1) interim corrective
measures; and (2) a CMS. " In addition, the regulatory agency will evaluate the
monitoring data with respect to adequacy and completeness to determine the need
for any additional monitoring efforts. The health and environmental criteria and a
general discussion of how the regulatory agency will apply them are supplied in
Section 8. A flow diagram illustrating RFI decision points is provided in Figure 3-2.
Notwithstanding the above process, the owner or operator has a continuing
responsibility to identify and respond to emergency situations and to define priority
situations that may warrant interim corrective measures. For these situations, the
owner or operator is directed to follow the RCRA Contingency Plan requirements
under 40 CFR Part 264 Subpart D.
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FIGURE 3-2
RFI DECISION POIMTS1
(See Following Page tor footnotes)
START
COMPARE MONITORING DATA AS THiV BECOME AVAILABLE TO
HEALTH AND ENVIRONMENTAL ASSESSMENT CRITERIA'
u*
oats
IMEHGINCV
AM
lit At IH AND
(NWIRONMEMIAL
A^IUMINICUIfMA
UUALEOOHiNCEEaEO
EHUlRONMENlAt
(E b.POIENUM
ACUU Hi AL1H
POPU1ATIONS If INC
EXPOSED HOW OH li
ENPLOUON.tfCI
HAVE
NAIUHC.tXIENI
ANUHAIIOf
CONTINUE
RELEASE
CHARACTERIZATION
CORRECTIVE
MEASURESSTUDV
NECESSARY
NO FURTHER ACTION
NECESSARY
TAKE IMMEDIATE
ACTION (E G . EVACUA T4ON)
AND NOTIFY LOCAL
AUTHORITIES AND
REGULATORY AGENCY
1
EVALUATE AND CONDUCT INTERIM CORRECTIVE MEASURES
IN CONSULTATION WITH REGULATORY AGENCY
-------
FOOTNOTES FOR FIGURE 3-2
Although the health and environmental assessment, is conducted..by,, the
reaulatorv aaencv, the owner or ooerator has a continuing responsibility tc
regulatory agency, the owner or operator nas a continuing responsiPillty to
identify and respond to emergency siutuations and to define priority situations
that may warrant interim corrective measures.
2 If sufficient monitoring data indicate that a release identified as "suspected" by
the RFA has actually not occurred, no further action is necessary unless the
regulatory agency determines that the occurrence of a release is or may be
imminent.
3 For the air medium, the health and environmental assessment criteria are
applied at actual receptor locations. For all other media, these criteria are
applied at the unit or waste management area boundary and beyond.
4 A Corrective Measures Study or interim corrective measures may still be required
based on qualitative criteria. (See Section 8 for discussion).
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SECTION 4
QUALITY ASSURANCE/QUALITY CONTROL PROCEDURES
4.1 Overview
Quality assurance (QA) is a management system for ensuring that' all
information, data, and decisions resulting from the RFI are technically sound and
properly documented. Quality control (QC) is the functional mechanism through
which quality assurance achieves its goals. Quality control programs, for example,
define the frequency and methods of checks, audits, and reviews necessary to
identify problems and dictate corrective action to resolve these problems, thus
ensuring data of high quality. Thus, a QA/QC program pertains to all data
collection, evaluation, and review activities that are part of the RFI.
Data generated during the RFI will provide the basis for decisions on corrective
measures; therefore, the data should present a valid characterization of the
situation. Utilization of erroneous or poor-quality data in reporting RFI result may
lead to unnecessary repetition of sampling and analysis or, more importantly, to
faulty decisions based on poor results. The owner or operator should develop
adequate QA/QC procedures for the RFI. Implementation of these procedures will
allow the owner or operator to monitor and document the quality of the data
gathered.
The next portion of this section (4.2) describes the general design of a QA/QC
program. The following portions of this section (Sections 4.3 and 4.4) outline and
describe important QA/QC considerations that should be accurate for, in the
performance of sampling and analysis.
Section 4 is not intended to constitute a complete guide to constructing QA
project plans or QC programs. EPA has established, through the issuance of various
documents, guidance describing the development and implementation of QA/QC
programs that can be used to design effective QA/QC procedures for the RFI. The
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final portion of this section (Section 4.5) presents reference that provide additional
guidance in constructing appropriate QA/QC procedures for the RFI.
When selecting field personnel and analytical services to perform any RFI
activity, the owner or operator is encouraged to evaluate available QA/QC programs
and procedures in light of the information and references provided in this section.
Participation in internal and/or external (e.g., Federal or State) laboratory
validation/certification programs may be particularly important in selecting
laboratory services.
Case Study No. 5 in Volume IV (Case Study Examples) provides an example of
an effective QA/QC program.
4.2 QA/QC Program Design
The initial step for any sampling or analytical work should be to strictly define
the program goals. Once these goals have been defined, a program can be
designed to meet them. QA and QC measures are used to monitor the program and
to ensure that all data generated are suitable for their intended uses. The
responsibility of ensuring that the QA/QC measures are properly employed should
be assigned to a knowledgeable person (i.e., a QA/QC specialist) who is not directly
involved in the sampling or analysis.
One approach found to provide a useful structure for a QA/QC program is
preparing both program and project-specific QA/QC plans. The program plan sets
up basic policies, including QA/QC, and may include standard operating procedures
(SOPs) for specific methods. The program plan serves as an operational charter for
defining purposes, organizations, and operating principles. Thus, it is an orderly
assemblage of management policies, objectives, principles, and general procedures
describing a plan for producing data of known and acceptable quality. The
elements of a program plan and its preparation are described in the following
reference:
U.S. EPA. September 20, 1980. Guidelines and Specifications for Preparing
Quality Assurance Program Plans. Office of Monitoring Systems and Quality
Assurance. EPA/QAMS-004/80. NTISPB83-219667. Washington, D.C. 20460.
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Project-specific QA/QC plans differ from program plans in that specific details
of a particular sampling/analysis program are addressed. For example, a program
plan might state that all equipment will be calibrated according to a specific
protocol given in written SOPs, while a project plan would state that a particular
protocol will be used to calibrate the equipment for a specific set of analyses that
have been defined in the plan. The project plan draws on the program plan for its
basic structure and applies this management approach to specific determinations.
An organization or laboratory would have only one QA program plan, but would
have a QA project plan for each of its projects. The elements of a project plan and
its preparation, presented in Table 4-1, are described in detail in the following
reference:
U.S. EPA. December 29, 1980, Interim Guidelines and Specifications for
Preparing Quality Assurance project plans Office of Monitoring Systems and
Quality Assurance. EPA/QAMS-005/80. NTISPB83-170514. Washington, D.C.
20460.
4.3 Important Considerations for a QA/QC Program
The use of qualified personnel for conducting various portions of the RFI is of
paramount importance to an effective QA/QC program. This pertains not only to
qualified QA/QC specialists, but also to specialists in other fields, including
hydrogeologists, air quality specialists, soil scientists, analytical chemists and other
scientific and technical disciplines. The owner or operator should ensure that
qualified specialists, primarily individuals with the proper education, training, and
experience, including licensed or certified professionals, are directing and
performing the various RFI activities. The same general, principles apply to selection
of contractors and/or outside laboratories.
4.3.1 Selection of Field Investigation Teams
The owner or operator should consider the following factors when selecting
any field investigation team:
Level of expertise and/or training required (e.g., experience, references);
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TABLE 4-1
ESSENTIAL ELEMENTS OF A QA PROJECT PLAN
I. Title Page
2. Table of Contents
3. Project Description
4. Project Organization and Responsibility
5. QA Objectives
6. Sampling Procedures
7. Sample Custody
8 . Calibration Procedures and Frequency
9. Analytical Procedures
10. Data Reduction, Validation, and Reporting
11. Internal Quality Control Checks
12. Performance and System Audits
13. Preventive Maintenance'
14. Specific Routine Procedures-Used to Assess Data Precision, Accuracy, and
Completeness
15. Corrective Action
16. Quality Assurance Reports to Management
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Available workforce; and
Time and equipment constraints.
4.3.2 Laboratory Selection
The owner or operator should consider the following factors when selecting a
laboratory:
Capabilities (facilities, personnel, instrumentation), including:
- Participation in interlaboratory studies (e.g., EPA or other Federal
or State agency sponsored analytical programs);
Certifications (e.g., Federal or State);
References (e.g., other clients); and
Experience (RCRA and other environmentally related projects).
Service:
Turnaround time, and
Technical input (e.g., recommendations on analytical procedures).
The owner or operator is encouraged to gather pertinent laboratory-selection
information prior to extensively defining analytical requirements under the RFI. A
request may be made to a laboratory to provide a qualifications package that
should address the points listed above. Once the owner or operator has reviewed
the various laboratory qualifications, further specific discussions with the laboratory
or laboratories should take place. In addition, more than one laboratory should be
considered. For large-scale investigations, selection of one laboratory as a primary
candidate arid one or two laboratories as fall-back candidates should be considered.
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The quality of the laboratory service provided is dependent on various factors.
The owner or operator should be able to control the quality of the information
(e.g., samples) provided to the laboratory. It is extremely important that the owner
or operator communicate to the laboratory all the requirements attendant to the
RFI. This includes the identification of the number of samples and their matrices,
sampling schedule, parameters and constituents (analytes) of interest, required
analytical methodologies, detection limits, holding times, deliverables, level of
QA/QC, and required turnaround of analytical results.
4.3.3 Important Factors to Address
A major element in release characterization is to define the QA/QC measures
that will be followed to ensure the validity of data generated during the
investigation. These measures should ensure that data generated are suitable for
their intended uses. QA/QC procedures should address the following factors:
(1) Intended use(s) for the data, and the necessary level of precision and accuracy
for these intended uses (See Section 4.4.1).
(2) Procedures for representative sampling, including:
Selecting appropriate sampling locations, depths, etc.;
Providing a sufficient number of samples and sampling sites;
Obtaining all necessary ancillary data;
Determining conditions (e.g., weather) under which sampling should be
conducted;
Determining which media are to be sampled (e.g., ground water, air, soil,
sediment, etc.);
Determining which constituents are to be measured;
Selecting appropriate sample containers;
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Selecting the frequency of sampling and duration of the sampling
period;
Selecting the types of samples (e.g., composites and grabs) to be
collected;
Detailing methods of sample preservation; and
Detailing methods of sample chain-of-custody.
(3) Documentation of field sampling operations and procedures, including:
Documentation of procedures for preparation of reagents or supplies
that become an integral part of the sample (e.g., filters and adsorbing
reagents);
Documentation of procedures and forms for recording the exact locations
and specific considerations associated with sample acquisition;
Documentation of specific sample preservation methods;
Calibration of field devices;
Collection of replicate samples;
Submission of field blanks, where appropriate;
Detailing of potential interferences present at the facility;
Listing of construction materials and techniques associated with
monitoring wells, piezometers, and other monitoring equipment;
Listing of field equipment and sample containers;
Copy of sampling order; and
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Documentation of decontamination procedures.
(4) Analytical procedures, including:
Appropriate analytical methods;
Appropriate sample storage;
Appropriate sample preparation methods;
Appropriate calibration procedures; and
Data management (e.g., review reporting, and recordkeeping)
procedures.
(5) Planning for the inclusion of proper and sufficient QA/QC activities, including
the use of QC samples, throughout the study is necessary to ensure that the
quality of the sampling and analytical data will meet the objectives of the RFI.
The factors and considerations described above are important for any
environmental monitoring and measurement project. If these factors are
adequately addressed (i.e., appropriate procedures are developed, tasks are
assigned to qualified personnel, and sufficient QA/QC steps are employed), the
goals of the RFI should be met. If the QA/QC procedures are sound, problems will be
detected early, enabling the appropriate corrective actions to be taken.
(Note that the term "corrective action," in the context of a QA/QC program
pertains to actions taken as a result of problems (e.g., sample contamination)
uncovered by an effective QA/QC program. This should not be confused with the
corrective measures that may be applied as a result of the RFI. Corrective actions as
a result of QA/QC are discussed in Section 4.4.10.)
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4.4 QA/QC Objectives and procedures
The following describes the general components of QA/QC objectives and
procedures. Specific references regarding recommended procedures are presented
in Section 4.5.
4.4.1 Data Quality and Use
Throughout the RFI process, it is important that the owner or operator keep in
mind the eventual use to which data will be put; that is, comparison of data to
health and environmental criteria to determine whether some form of corrective
measure may be necessary to correct the release. Therefore, data collected during
the investigation needs to be of sufficient quality to support decisions regarding
whether interim corrective measures and/or a CMS may be necessary.
Qualitative or quantitative statements that outline the decision-making
process and specify the quality and quantity of data required to support decisions
should be made early in the planning stages of the RFI. These data quality
objectives (DQOs) are then used to design sampling and analysis plans and to
determine the appropriate level of QA/QC.
The following discussion concerning DQOs is summarized from the following
document:
U.S. EPA. March, 1987. Data Quality Objectives for Remedial Response
Activities. Volume I : Development Process. Volume 2: Example Scenario.
EPA 540/G-87/003a. OSWER Directive No. 9335.0-7B. Office of Emergency and
Remedial Response and Office of Waste Programs Enforcement. Washington,
D.C. 20460.
This document may be reviewed for more detailed information. The Example
Scenario (Volume 2) may be particularly helpful in understanding the overall DQO
process.
The first step in the process of developing DQOs involves defining the
decisions to be made based on the data and the objectives of the investigation. The
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second step is defining a set of objectives (DQOs) that can be used to design the
sampling and analysis Plan and, determining the appropriate levell of QA/QC.
Ultimately, these DQOs are also used to determine the adequacy of the data in
terms of whether their quality arid quantity are sufficient to enable confident
decision-making. This process of defining the objectives of the investigation and
designing data-gathering efforts to meet these objectives, should be initiated prior
to starting the investigation. Refinements or revisions to these objectives may also
be necessay as the investigation progresses.
The criteria most, commonly used to specify DQOs and to evaluate available
sampling, analytical, and ,QA/QC options are known collectively as the Precision,
Accuracy, Representativeness, Completeness, and Comparability (PARCC)
parametes. A brief description of these follows:
Precision - a measure of the reproducibility of analyses under a given set
of conditions.
Accuracy - a measure of the bias in a measurement system.
Representativeness - the degree to which sampling data accurately and
precisely represent selected characteristics.
Completeness- a measure of the amount of valid data obtained from a
measurement system compared to the amount that could be expected to
be obtained under "normal" conditions.
Comparability - the degree of confidence with which one data set can be
compared to another.
When using these parameters to assess data quality, only precision and
accuracy can be expressed in purely quantitative terms. The other parameters are
best expressed using a mixture of quantitative and qualitative terms. All these
parameters are interrelated in terms of overall data quality and maybe difficult to
evaluate separately due to these interrelationships. The relative significance of.
each parameter depends on the type and intended use of the data being collected.
Each parameter is addressed in further detail below.
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Precision is a measure of the scatter of a group of measurements made at the
same specified conditions around their average. Values calculated should
demonstrate the reproducibility of the measurement process. Determination of
precision in relation to the RFI deals primarily with sampling and analytical
procedures. The sample standard deviation and sample coefficient of variation are
commonly used as indices of precision. The smaller the standard deviation' and
coefficient of variation, the better the precision.
Precision is stated in units of measurement or as a percentage of the
measurement average, as a plus and minus spread around the average measured
value. There are many sources of variation or error within any measurement system.
Depending on the nature of the investigation, variation or error may be introduced
at various stages. Examples of these are sample collection, handling, shipping,
storage, preparation, and analysis, When summarizing precision determinations,
the component or components, of the measurement system that are included should
be noted. The stage at which a replicate is placed within the measurement system,
for example, generally dictates the components that affect the precision determin-
ation.
Accuracy is defined as the agreement of a measurement with an accepted
reference or true value. This is normally expressed as the difference between
measured and reference or true values or the difference as a percentage of the
reference or true value. It may also be expressed as a ratio of the measurement to
the true value. Accuracy is a measurement of system bias.
The determination of accuracy or bias within the measurement system is
generally accomplished through the analysis of the neat sample(e.g., distilled water
as opposed to pond or local water) and the analysis of the sample spiked at a
known concentration utilizing a standard reference material. As in the case of the
precision determination, the point at which the sample is spiked determines which
components of the measurement system have an effect on the accuracy of the
analysis. The three sample spiking points are sample acquisition (field matrix spike);
preparation (lab matrix spike); and analysis (analysis matrix spike). The field matrix
spike provides a best-case estimate of bias based on recovery. It includes matrix
effects associated with sample preservation, shipping, preparation, and analysis.
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The lab matrix spike provides an estimate of recovery incorporating matrix effects
associated with sample preparation and analysis only. The analysis matrix spike
provides an indication of matrix effects associated with the analysis process only. In
addition to the above sample spiking points, the analysis of a known concentration
of a standard reference material into the appropriate method solvent (e. g.,
deionized water, methanol, 2 percent nitric acid, etc.) provides an indication of the
accuracy of the analytical system calibration.
Completeness is defined as the measure of the amount of valid data obtained
from a measurement system compared to the amount that could be expected to be
obtained under "normal" conditions. The completeness goals should be identified,
to the extent possible, at the beginning of the RFI to ensure that sufficient valid
data are collected to meet the RFI objectives and to provide a measurement
whereby the progress of the RFI may be monitored during data collection.
QA/QC procedures may benefit through tabular presentations of the precision,
accuracy, and completeness goals for the work performed under the RFI.
Representativeness expresses the degree to which data accurately and
precisely represent a characteristic of a population, parameter variations at a
sampling point, a process condition, or an environmental condition. QA/QC
procedures should address all data gathering with regard to representativeness. All
RFI data compilation should reflect as precisely and as accurately as possible the
conditions that existed at the time of measurement. Examples of factors that
should be considered include:
Environmental conditions at the time of sampling;
Fit of the modeling or other estimation techniques to the event(s);
Appropriateness of site file information versus release conditions;
Appropriateness of sampling and analytical methodologies;
* Number of sampling points;
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Representativeness of selected media; and
Representativeness of selected analytical parameters.
Comparability is defined as an expression of the confidence with which one
data set can be compared to another. In termsof the RFI, comparability may be
applied to:
RFI data generated by the owner or operator over a specific time period;
Data generated by an outside laboratory over a specific time period;
RFI data generated by an outside laboratory versus data generated by
the owner or operator; and
Data generated by more than one outside laboratory.
The utilization of standard methodologies for the various data generation
categories (e.g., sampling, analysis, geological, and meteorological) should ensure
data comparability. The owner or operator should take the appropriate measures
to ensure the comparability of data compiled under the RFI.
The PARCC parameters are indicators of data quality. Ideally, the end use of
the measurement data should define the PARCC parameters necessary to satisfy
that end use. Ideally, numerical precision, accuracy, and completeness goals should
be established to aid in selecting measurement methods to be used. However, RFI
work may not fit this ideal situation. RFI sites are likely-to differ substantially from
one another, and information on overall measurements (e.g., sampling and
analysis) may be limited such that it may not be practical to initially set meaningful
PARCC goals. In such cases, the historical precision and accuracy achieved by
different sampling and analytical techniques should be reviewed to aid in selecting
the most appropriate technique, Only those techniques that have been adequately
evaluated (e.g., precision and accuracy studies), and which therefore have a
documented history of acceptable performance, should be proposed for use.
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Precision and accuracy statements and detection limit information for
analytical methods can be found in the DQO document referenced earlier in this
section, as well as the following reference:
U.S. EPA. November, 1986. Test Methods for Evaluating Solid Wastes.
EPA/SW-846. GPO No. 955-001-00000-1. Office of Solid Waste. Washington,
D.C. 20460.
Each of the PARCC parameters should be considered in evaluating sampling
and analysis options. To the extent possible, they should be defined as goals to be
achieved by the data collection program. It should be recognized, however, that
DQOs can be developed firm RFI work without strictly defined PARCC goals.
Whenever measurement data are reviewed, the PARCC parameters should be
included in the review. Precision and accuracy data may be expressed in several
ways and are best evaluated by an analytical chemist or a statistician. The data
reviewer should keep the action levels (health and environmental criteria) and the
end use of the data in mind when reviewing precision aid accuracy information. In
some cases, even data of poor precision and for accuracy may be useful. For
example, if all the results are far above an action level, the precision and accuracy
are less important. However, close to the action level, precision and accuracy are
much more important and should be carefully reviewed. If results have very good
precision but poor accuracy, correcting the reported results using the percent
recovery or percent bias data may be acceptable.
4.4.2 Sampling r o c e d u r e s
To ensure that sample collection will provide high quality and representative
data, the owner or operator is advised to carefully select appropriate sampling
procedures that will meet the objectives of the investigation. Some factors to
consider in choosing the best sampling methodologies include the following:
Physical and chemical properties of the medium to be sampled;
Relative and absolute concentrations of analytes of concern;
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Relative importance of various analytes to RFI objectives;
Method performance characteristic;
Potential interferences at the site; and
Time resolution requirements.
QA/QC procedures relevant to sampling activities should, also be formulated
and followed during any site environmental characterization. These procedures
should include a description of the techniques to be utilized in Performing tasks
such as well drilling, stratigraphic analysis, meteorological measurements, and
surface water flow measurements. More information can be found in the
references identified in Section 4.5, and in the media-specific sections (Sections 9
through 13).
4.4.3 Sample Custody
An essential part of any program that requires sampling and analysis is
ensuring sample integrity from collection to data reporting. This includes the ability
to trace the possession and handling of samples from collection through analysis
and final disposition. The documentation of the history of the sample is referred to
as chain-of-custody.
Chain-of-custody procedures should identify the components that will be
utilized for all sampling and analysis under the RFI, including a transfer in custody
and how the chain-of-custody procedures and documents will effectively record
that transfer. The following sample custody procedures should be addressed:
(1) Field sampling operations:
Documentation of procedures for preparation of reagents or supplies
that become an integral part of the sample (e.g., filters and adsorbing
reagents);
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provision of procedures and forms for recording the exact location and
specific considerations associated with sample acquisition;
Documentation of specific sample presentation methods;
Provision of pre-prepared sample labels containing all information
necessary for effective sample tracking; and
. Establishment of standardized field tracking reporting forms to establish
sample custody in the field prior to shipment.
(2) Laboratory operations:
Identification of a responsible party to act as sample custodian at the
laboratory facility authorized to sign for incoming field samples, obtain
documents of shipment, and verify the data entered onto the sample
custody records;
Provision for a laboratory sample custody log consisting of serially
numbered standard lab-tracking report sheets; and
Specification of laboratory sample custody procedures for sample
handling, storage, and dispersement for analysis.
4.4.4 Calibration Procedures
Another important consideration in any environmental measurement is the
calibration of the measurement system. An improperly and/or infrequently
calibrated system may have a serious negative impact on the precision and accuracy
of the determinations. The result will be erroneous data and the need to repeat the
measurement. The calibration procedures utilized should therefore be defined.
Points that should be addressed include:
For each measurement parameter, including all contaminant
measurement systems, reference the applicable SOP or provide a written
description of the calibration procedure(s) to be used;
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List the frequency planned for recalibration and/or the criteria utilized to
dictate the frequency of recalibration; and
List the calibration standards to be used and their source(s), including
traceability procedures.
4.4.5 Analytical Procedures
The owner or operator should select analytical procedures that will meet the
objectives of the RFI. Factors to consider in choosing appropriate analytical
methodologies include:
. . Scope and application of the procedure;
Sample matrix;
Potential interferences;
Precision and accuracy of the methodology; and
Method detection limits.
EPA-approved methodologies, such as those identified in the 3rd edition of
Test Methods for Evaluating Solid Wastes (EPA/SW-846) or equivalent, should be
utilized when available.
For each measurement parameter, including all contaminant measurement
systems, the owner or operator should reference the SOP or provide a written
description of the analytical procedure(s) to be used in support of the RFI. If any
method modifications are anticipated due to the nature of the sarnple(s) being
investigated, these modifications should be explicitly defined.
An important factor to consider in any analytical procedure is holding time.
Samples have a limited shelf life. Analysis should occur within the time specified by
the method. This is especially important for organic contaminant. For example,
4-1 7
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volatile organic compound (VOC) analysis should occur within 2 weeks of sampling.
Acceptable sample holding times for all classes of, Appendix VIII constituents are
discussed in Test Methods for Evaluating Solid Waste fEPA/SW-846\
4.4.6 Data Reduction Validation, and Reporting
This portion of the QA/QC procedures applies to all measurements performed
in support of the RFI. The owner or operator should identify the data reduction
scheme planned for collected data and include all equations and reporting units
used to calculate the concentration or value of the measured parameter.
Data validation is the process of reviewing data and accepting or rejecting it
on the basis of sound criteria. Validation methods may differ for various
measurements but the chosen validation criteria must be appropriate to each type
of data and the purpose of the measurement. Records of all data should be
maintained, even those judged to be "outlying" or spurious values, personnel
assigned the responsibility of data validation should have sufficient knowledge of
the particular measurement system to identify questionable values.
The owner or operator should identify the principal criteria that will be
applied to validate data integrity during collection and reporting. In addition, the
methods that will be utilized to identify and treat outliers should be addressed. The
validation process should include mechanisms whereby data reduction is verified. In
the case of computerized data reduction, this may include subjecting a surrogate
data set to reduction by the software to ensure that valid results are produced.
4.4.7 Internal Quality Control Checks
Quality control checks are performed to ensure that the data collected is
representative and valid data. Internal QC refers to all data compilation and
contaminant measurements. Quality control checks are the mechanisms whereby
the components of QA objectives are monitored. Examples of items to be
considered are as follows:
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(1) Field Activities:
Use of standardized checklists and field notebooks;
Verification of checklist information by an independent person;
Strict adherence to chain-of-custody procedures;
Calibration of field devices;
Collection of replicate samples; and
Submission of field blanks, where appropriate.
(2) Analytical Activities:
Method blank(s);
Laboratory control sample(s);
Calibration check sample(s);
Replicate sample;
Matrix-spiked sample(s);
"Blind" quality control sample(s);
Control charts;
Surrogate samples;
Zero and span gases; and
Reagent quality control checks.
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The owner or operator should consider those checks that will meet the QA
objectives of the RFI. In addition, the owner or operator should present, in tabular
format the frequency with which each control check will be used.
4.4.8 Performance and Systems Audits
A systems audit is a qualitative evaluation of all components of the
measurement systems to determine their proper selection and use. This audit
includes a careful review of all data-gathering activities and their attendant QC
procedures. Systems audits are normally performed before or shortly after systems
are operational. However, such audits should be performed at sufficiently regular
internals during the lifetime of the RFI or continuing operation. Systems audits
should be conducted by an individual who is technically knowledgeable about the
operation(s) under review and who is independent of any other contribution to the
RFI. The primary objective of the systems audit is to ensure that the QA/QC
procedures are being adhered to.
After systems are operational and generating data, performance audits are
conducted periodically to determine the accuracy of the total measurement
system(s) or component parts thereof. Performance audits are quantitative
evaluations of the measurement system(s). QA/QC procedures should include a
schedule for conducting performance audits for each measurement parameter
where all measurement systems are included. Examples of performance auditing
mechanisms for analytical activities would be the inclusion of "blind" samples into
the normal sample flow, an analyst performing the analysis of a sample previously
analyzed by another analyst, and the results of any appropriate interlaboratory
study samples analyzed during the term of the RFI. Performance audit checks
relative to data handling operations might be the insertion of erroneous
parameters into field records. This should trigger the validation procedures by
entering unreasonable combinations of responses.
4.4.9 Preventive Maintenance
Preventive maintenance schedules ensure the maximum amount of active time
for analytical instrumentation, field devices and instrumentation, and computer
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hardware over the course of the RFI program. The following types of preventive
maintenance should be considered:
A schedule of important preventive maintenance tasks that must be
carried out to minimize downtime of all measurement systems; and
t A list of any critical spare parts that should be on hand to minimize
downtime.
4.4.10 Corrective Action for QA/QC Problems
Corrective actions are those measures taken to rectify a measurement system
that is out of control. (Note that the term "Corrective Action," as used in this
section, is a common QA/QC term applied to problem-solving activities. It should
not be confused with the RCRA Corrective Action Program.) Corrective action may
be initiated by any person performing work in support of the RFI at any time. For
example, an analyst should be familiar with the precision and accuracy of the
analysis that is being performed. If the results of the analysis are not within the
anticipated limits, there are appropriate corrective actions that should be initiated
by the analyst. There are, however, other checks within the measurement system
that only the person assigned QA/QC responsibilities would be in a suitable position
to evaluate and take action upon if required. A "blind" sample inserted in the
normal sample flow would be an example of such a check.
The corrective action procedures to be utilized in the accomplishment of the
RFI objectives should be contained in the QA/QC procedures and should include the
following elements:
The predetermined limits for data acceptability beyond which corrective
action is required; and
For each measurement system, the identity of the individual responsible
for initiating the corrective action and also the individual responsible for
approving the corrective action, if necessary.
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In addition to routine corrective actions taken by all personnel contributing to
the RFI, performance and systems audits may result in the necessity of more formal
corrective action.
4.4.1.1 Quality Assurance Reports to Management
Another important aspect of the QA/QC program is the communication
between the QA/QC organization and the management organization. Regular
appraisal by management of the quality aspects related to the ongoing RFI data-
gathering efforts provides the mechanism whereby the established objectives may
be met.
QA/QC procedures should provide detail relating to the schedule, information
to be provided, and the mechanism for reporting to management. Reports to
management should include:
Periodic assessment of measurement data accuracy, precision, and
completeness;
Results of performance audits;
Results of system audits;
Significant QA/QC problems and recommended solutions; and
Resolutions of previously stated problems.
The individual(s) responsible for preparing the periodic reports should be
identified. These reports should contain a separate QA/QC section that summarizes
data quality information.
4.5 References
Following is a list of the major references, including EPA guidances,
recommended for use in designing effective QA/QC programs for RFIs:
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U.S. EPA. September 20, 1980. Guidelines and Specifications far Preparing Quality
Assurance program plans. Office of Monitoring Systems and Quality
Assurance. QAMS-004/8O. NTISPB83-219667. Washington, D.C. 20460.
U.S. EPA. December 29, 1980. Interim Guidelines and Specifications for Preparing
Quality Assurance Project Plans. Office of Monitoring Systems and Quality
Assurance. QAMS-005/80. NTISPB83-170514. Washington, D-C. 20460.
U.S. EPA. 1986. Test Methods for Evaluating Solid Wastes. 3rd Edition. Office of
Solid Waste. EPA/SW-846. GPO No. 955-001-00000-1. Washington, D.C.
20460.
U.S. EPA. August, 1987. Compendium of Field Operations Methods. OSWER
Directive No. 9355.0-14. EPA/540/P-87/001 A. Office of Emergency and
Remedial Response. Washington, D.C. 20460.
u.s. EPA. July, 1981. RCRA Inspection Manual. Office of Solid Waste. Washington,
D.C. 20460.
U.S. EPA. June, 1988. Guidance on Remedial Investigations Under CERCLA. Office
of Emergency and Remedial Response. NTIS PB85-238616. Washington, D.C.
20460.
u.s. EPA. May, 1984. Soil Sampling Quality Assurance Users Guide. EPA 600/4-84-
043. NTIS P884-198621. Washington, D.C. 20460.
U.S. EPA. 1985. Sediment Quality Assurance Users Guide. EPA 600/4-85-048. NTIS
PB85-233542. Washington, D.C. 20460.
U.S. EPA. March, 1987. Dntn Quality Objectives for Remedial Response Activities.
Volume 1: Development Process. Volume 2: Example Scenario. EPA 540/G-
87/003a. OSWER Directive No. 933 S.O-7B. Office of Emergency and Remedial
Response and Office of Waste Programs Enforcement. Washington, D.C.
20460.
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SECTION 5
DATA MANAGEMENT AND REPORTING
5.1 Data Management
Release characterization studies may result in significant amounts of data,
including results of chemical, physical, or biological analyses. This may involve
analyses of many constituents, in different media, at various sampling locations,
and at different times. Data management procedures should be established to
effectively process these data such that relevant data description (e. g., sample
numbers, locations, procedures, methods, and analysts) are readily accessible and
accurately maintained.
In order to ensure effective data management, the owner or operator should
develop and implement a data management plan to document and track
investigation data and results. This plan should address data and report processing
procedures, project file requirements and all project-related progress reporting
procedures and documents. The plan should also provide the format(s) to be used
to present the data, including data reduction.
Data presentation, reduction and reporting are discussed in Sections 5.2, 5.3,
and 5.4 respectively.
5.2 Data Presentation
RFI data should be arranged and presented in a clear and logical format.
Tabular, graphical, and other visual displays (e.g., contaminant isopleth maps) are
essential for organizing and evaluating such data. Tables and graphs are not only
useful for expressing results, but are also necessary for decision-making during the
investigation. For example, a display of analytical results for each sampling location
superimposed on a nap of the site is helpful in identifying data gaps and in
selecting futur sampling locations. Graphs of concentrations of individual
constituents plotted against the distance from the source can help to identify
patterns, which can be used to design further monitoring efforts.
5-1
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Various tabular and graphic methods are available for data presentation, as
illustrated in Table 5-1. Particular methods most applicable to the RFI may vary with
the type of unit, the type of data, the medium under consideration, and other
factors. The owner or operator should propose methods in the RFI Work Plan that
best illustrate the patterns in the data.
Often, certain types of data, such as stratigraphy and sampling location
coordinates, are more effectively displayed in graphic form. Such data may be
presented in tabular form but should also be transformed into graphic
presentations. For example, stratigraphy might be effectively illustrated on a two-
dimensional (or possibly three-dimensional) cross-sectional map. Three-
dimensional data presentation is particularly relevant to the RFI, as three-
dimensional characterization is generally required to adequately characterize the
nature, extent, and rate of release migration.
Sampling locations may be effectively illustrated on a topographic map, as
shown in Figure 5-1. Topographic maps and the regulatory requirements for their
preparation (40 CFR Part 270.14(b)) are also discussed in Appendix A. Table 5-2
provides some useful data presentation methods. In addition, many of the Case
Studies presented in Volume IV illustrate effective data presentation techniques.
Case Study No. 6 is of particular relevance to data presentation techniques. Specific
data presentation techniques are discussed below.
5.2.1 Tables
Tabular presentations of both raw and sorted data are useful means of data
presentation. These are discussed below.
5.2.1.1 Listed (Raw) Data
Simple lists of data alone are not adequate to illustrate trends or patterns
resulting from a contaminant release. However, such lists serve as a good starting
point for other presentation formats. These lists are also valuable for sample
validation and auditing. Therefore, such lists are highly recommended for reporting
results during the RFI. Each data record should provide the following information:
5-2
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TABLE 5-1
USES OF TABLES AND GRAPHICS IN AN RFI
Tabular Displays
1. Display site information and measurements
Water table elevations
Sampling location coordinates
Precipitation and temperature data
Lists of site fauna and flora
2. Display analytical data
List of constituents of concern and other monitoring parameters
with associated analytical measurements
Display sorted results (e.g., by medium, sampling date, soil type)
Compare study and background area data
Report input data, boundary conditions, and output values from
mathematical modeling
Graphic Displays
1. Display site features
Layout and topography (equivalent to the required RCRA permit
application map)
Sampling locations and sampling grids
Boundaries of sampling area
Stratigraphy and water table elevations (profile, transect, or fence
diagram)
Potentiometric contour map of ground water
Ground-water flow net
Population plot and/or local residential map
Features affecting inter-media transport
2. Illustrate the extent of contamination
Geographical (areal) extent of contamination
Vertical distribution of contaminant(s)
Contamination values, averages, or maxima at sampling locations
3. Demonstrate patterns and trends in the data
Change in concentration with distance from the source
Change in concentration with time
Display estimates of future contaminant transport derived from
modeling
5-3
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figure
-------
Table 5-2
Useful Data presentation Methods
Tables
Unsorted (raw) data
Sorted tables
Graphic Formats and Other Visual Displays
Bar graphs
Line graphs
Area or plan Maps
Isopleth (contour) plots
Ground-water flow nets
Cross-sectional plots, transects, or fence diagrams
Three-dimensional graphs
5-5
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Unique sample code;
Sampling location and sample type;
Sampling date;
Laboratory analysis identification number;
Property or component measured;
Result of analysis (e.g..concentration);
Detection limits; and
Reporting units.
Analytical data will generally be reduced at the laboratory before they are
reported (i.e., the owner or operator does not have to report instrument readings or
intermediate calculations, although this information should be maintained for
ready access if needed). The owner or operator should report all data to the
regulatory agency, including suspected outliers or samples contaminated due to
improper collection, preservation, or storage procedures. The rejected data should
be marked as such in the data tables, and explanations of rejected data should be
presented in footnotes.
In addition to analytical data, the owner or operator may be required to
provide sampling logs for all samples obtained during the investigation. Sampling
logs are records of procedures used in taking environmental samples, and of
conditions prevailing at the site during sampling. Information in the log should
include:
Name and address of sampler;
Purpose of sampling;
Date and time of sampling;
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Sample type (e.g., soil) and suspected contaminants;
Sampling location, description, and grid coordinates (including photos);
Sampling method, sample containers; and preservation (if any);
Sample weight or volume;
: Number of samples taken;
Sample identification number(s);
Amount purged (for ground water);
Field observations;
Field measurements made (e.g., pH, temperature};
Weather conditions; and
Name and signature of person responsible for observation.
The owner or operator should also describe any unusual conditions
encountered during sampling (e.g., difficulties with the sampling equipment, post-
sampling contamination, or loss of samples).
5.2.1.2 Sorted Summary Tables
Presentation of results grouped according to data categories is one of the
simplest formats used to display trends or patterns in data. Examples of categories
of data include medium tested, sampling date, sampling location, and constituent
or property measured. Table 5-3 shows an example of a sorted table; data are
sorted by medium (ground water), sampling date, and constituent measured.
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TABLE 5-3
SORTED DATA
(Concentration of Volatile Organic
Compounds in Monitoring Well #32
Date
1/3/82
2/12/82
4/24/82
Sample
Identification
Number
MW-32-1/3A
MW-32-2/12A
MW-32-4/24A
Concentration (ug/l
Methylene
Chloride
20
< 10
< 10
Acetone
120
220
140
Trichloroethylene
20
NA
20
Benzene
30
<.'10
20
NA- Not analyzed.
5-8
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In Table 5-4, the data are sorted by medium, location, depth, and constituent
analyzed. Inclusion of the sample identification number allows the reader to cross-
reference the data and look up any information not listed in the table.
preparation of data summary tables can be simplified by use of a computer
spreadsheet program. These programs can perform sorting operations, perform
simple calculations with the data, and display results in a number of tabular and
graphical formats.
5.2.2 Graphic Presentation of Data
The graphic methods of data presentation will often illustrate trends and
patterns better than tables. Some graphic formats useful for environmental data
include bar graphs, line graphs, areal maps, and isopleth-plots. These graphic
methods of data presentation are discussed below.
5.2.2.1 Bar Graphs and Line Graphs
Bar graphs and line graphs may be used to display changes in contaminant
concentrations with time, distance from a source, or other variables. For example,
Figure 5-2 compares two methods of displaying changes in concentrations over
distance. Bar graphs are generally preferable to line graphs in instances where
there is not enough information to assume continuity between data points.
However, line graphs generally can display more information in a single graph.
Attention to the following principles of graphing should provide clear and
effective line and bar graphs:
Do not crowd data onto a graph. Plots with more than three or four lines
or bar subdivisions become confusing. Different symbols or textures
should be used to distinguish each line or bar;
Choose the scale of the x and y axes so that data are spread out over the
full range of the graph. If one or two data points are far outside the
range of the rest of the data, a broken line or bar may be used to indicate
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TABLE 5-4
SOIL ANALYSES: SAMPLING DATE 4/26/85
Sample Identification, Location, and Depth
^^-^ "
Sample ID
Number
^^^^^
SB-1
SB-2
SB-3
SB-4
SB-5
SB-6
. ^ ^ ~^^
Location
^^^^^^
N of lagoon
N of lagoon
N of lagoon
SE corner
SE corner
SE corner
^^*
Depth
^^^^i
surface
6 inches
18 inches
surface
6 inches
18 inches
Concentration (mg/kg)
Lead
240
40
15
360
170
22
Arsenic
55
15
15
84
29
< T.O
Chromium
1,200
220
36
5,300
430
47
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METALS IN RiVER SEDIMENTS: LINE GRAPH
DISTANCE FROM SOURCE (MILES)
METALS IN RIVER SEDIMENTS: BAR GRAPH
DISTANCE FROM SOURCE (MILES)
Figure 5-2. Comparison of line and bar graphs
5-11
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a discontinuous scale. If the data range exceeds two orders of
magnitude, the owner or operator may choose to plot the logarithms of
the data;
The x and y axes of the plot should be clearly labeled with the parameter
measured and the units of measurement; and
The x axis generally represents the independent variable and the y axis
the dependent variable.
5.2.2.2 Area or Plan Views (Maps)
The distribution of hazardous constituents at a site may be represented by
superimposing contaminant concentrations over a map of the site. Distributions
may be shown by listing individual measurements, or by contour plots of the
contaminant concentrations. Individual techniques are discussed below:
Contamination shown at discrete points - in this format, no assumptions, are
made concerning contamination outside the immediate sampling area. For
example, in Figure 5-3, soil phenol concentrations are shown by the height of the
vertical bar at each sampling site. Soil samples indicated on this map were taken
from approximately the same depths. Note that one bar is discontinuous so as to
bring the lower values to a height that can be seen on the graph. Other possible
representations of the same information could use symbols of different shapes,
sizes, or colors to represent ranges of concentration. For example, a triangle might
represent 0 to 10 ppm; a circle 10 to 100 ppm, etc.
Display of average concentrations - Shadings or textures can be used to
represent average contamination concentrations within smaller areas at a site.
Shading represents estimated areas of similar concentration only and should not be
interpreted as implying concentration gradients between adjacent points.
Contaminant isopleth maps -- Lines of equal concentration are called isopleths.
Construction of a contaminant isopleth map generally requires a relatively large
number of sampling locations spaced regularly across the study area. An isopleth
map is prepared by marking the site map with the concentrations detected at each
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O)
O)
II
Q.
Jfi
a
s
3
, _c
o
I
1
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o
01
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3
01
5-13
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sampling location. Lines are drawn to connect data points of the same
concentration similar to contours of elevation as shown in Figure 5-4. Figure 5-5
demonstrates the use of an isopleth plot to show the distribution of an air release.
5.2.2.3 Isopach Maps
A technique that is useful for displaying certain types of geological data is the
isopach map. Isopachs are contour maps in which each line represents a unit of
thickness of a geologic material (e.g., the soil layer) as shown in Figure 5-6. This
format would be useful if, for example, oil is known to be contained within a highly
permeable sand layer of varying thickness, confined between low-permeability clay
layers. The isopach map displays thickness only, and does not provide information
on absolute depth or slope.
5.2.2.4 Vertical Profiles or Cross-Sections
Vertical profiles are especially useful for displaying the distribution of a
contaminant release in all media. For soil and ground water, the usual approach is
to select several soil cores (or monitoring-wells) that lie in approximately a straight
line through the center of the contaminant release. This cross-section represents a
transect of the site. A diagram of the soil (or ground water) profile should be
prepared along the length of the transect, displaying subsurface stratigraphy,
location of the waste source, and the location and depth of boreholes, as shown in
Figure 5-7. Concentrations may also be indicated on the plot as discrete
measurements or isopleths and may be drawn as in Figure 5-8. Figure 5-9 presents a
plan view of Figure 5-7, showing the offset in cross-section. If the sampling points
do not fail in a straight line, an alternate display called a fence diagram can be used.
Figure 5-10 shows a fence diagram of subsurface stratigraphy which also includes
analytical data.
To characterize the three-dimensional distribution of a subsurface
contaminant release, the owner or operator will generally need to prepare several
transects crossing the plume in different directions.
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scale, meters
Figure 5-4. Isopleth Map of Soil PCB Concentrations (ug/kg)
5-15
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130PUTH3 ARI IN M1CROGRAM3 P» CUBIC M6TER
Figure 5-5. Isopleth Map of Diphenylamine Concentrations in Ambient Air in the
vicinity of a SWMU.
5-16
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in
SUHfACC
IHPOUMPUEHI
OIHICIIOM
Of
CROUNUWATtH
Figure 5
.5. sand .sop«h Map Showing Contours (lsopleths)
100200300
Scute, Feel
-------
EOB
Figure 5-7. Cross Section A-A'-Site Subsurface Prof.le
-------
in
570
560
550
540
530 O
520
510
500
490
TOTAL HAZARDOUS ORGANIC COMPOUNDS IN GROUND WATER (u»/U
HVDROGEOLOGIC CROSS SECTION C E
Figure 5-8. Transect Showing Concentration Isopleths (ug/l)
-------
Iff- Btdrack Spring .:;:-;;.;:
Figure 5-9; Plan View of Figure 5-7 Showing Offsets in Cross Section
5-20
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Ul
t
(VJ
HOHIZOHTAt
TB, SO.L COMCENTHAHONS
figure 5-10.
Fence Diagram of Stratigraphy Showing Lead (Pb) eoncenua^on,
(ppm = mg/kg)
-------
5225 Three-Dimensional Data Plots
Computer graphic package are available from several commercial suppliers
to produce three-dimensional data plots. A common use of this technique is to
represent contaminant concentrations across the study area as a three-dimensional
surface, as shown in Figure 5-11. The information provided by this approach does
not differ greatly from that of Figure 5-4. The primary difference is that the
smoothing of the concentration dissimilarities between adjacent sampling locations
in Figure 5-11 makes patterns in the data easier to visualize. Precise concentrations,
however, cannot be displayed in this format because the apparent heights of the
contours change as the figure is rotated.
5.3 Data Reduction
Data should be reported according to accepted practices of QA and data
validation. All data should be reported. Considerations, however, include
treatment of replicate measurerment, identification of outlier values, and reporting
of results determined to be below detection limits.
5.3.1 Treatment of Replicates
Replicate measurements of a single sample should be averaged prior to
further data reduction. For example, Table 5-5 shows how to calculate an overall
mean when replicate analyses for, a single sample have been performed. The three
"B" values are averaged before the mean is calculated. This removes bias from the
overall mean. The number of analyses is indicated by "n".
5.3.2 Reporting of Outliers
Any program of environmental measurement can produce numbers that lie
outside the "expected" range of values. Because field variability of environmental
measurements can be, great, deciding whether an extreme (outlier) value is
representative of actual contaminant levels may be difficult. Outlier values may be
the result of:
A catastrophic unnatural (but real) occurrence such as a spill;
5-22
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Figure 5-11 Three-Dimensional Data Plot of Soil PCB Concentrations (ug/g)
5-23
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TABLE 5-5
CALCULATION OL MEAN VALUES EOR REPLICATES
Concentration
5-24
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inconsistent sampling or analytical chemistry methodology;
Error in the transcription of data values or decimal points; and
True but extreme concentration measurements.
The owner or operator should attempt to correct outlying values if the cause
of the problem can be documented. The data should be corrected, for example, if
outliers are caused by incorrect transcription and the correct values can be obtained
and documented from valid records. Also, if a catastrophic event or a problem in
methodology occurred that can be documented, data values should be reported
with clear reference. Documentation and validation of the cause of outliers must
accompany any attempt to correct or delete data values, because true but extreme
values must not be altered. Statistical methods for identifying outliers require that
the analytical laboratory have an ongoing program of QA, and that sufficient
replicate samples be analyzed to account for field variability.
Outlier values should not be omitted from the raw data reported to the
regulatory agency; however, these values should be identified within the summary
tables.
5.3.3 Reporting of Values Below Detection Limits
Analytical values determined to be at or below the detection limit should be
reported numerically (e.g., <_ 1 mg/l). The data presentation Procedures should
cite analytical methods used including appropriate detection limits.
5.4 Reporting
As indicated in Section 3.7, the owner or operator should respond to
emergency situations and identify to the regulatory agency priority situations that
may require interim corrective measures. Such reporting should be done
immediately. In addition, results of various activities conducted during the RFI
should be reported to the regulatory agency, as required in the compliance order or
by the permit conditions.
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Various reports may be required. These may include interim, draft, and final
reports. In addition periodic progress reports (e. g., bimonthly) may also be
required. Progress reports should generally include the following information:
A description and estimate of the percentage of the RFI completed;
Summaries of all findings;
Summaries and rationale for all changes made in the RFI Work Plan
during the reporting period;
Summaries of all contacts with representatives of the local community,
public interest groups, or government representatives during the
reporting period;
Summaries of all problems or potential problems encountered during the
reporting period;
Actions being taken to rectify problems;
Changes in personnel during the reporting period;
Projected work for the next reporting period; and
Copies of daily reports, inspection reports, laboratory/monitoring data,
etc.
Reports, including interim, progress, draft, and final reports may also be
required for specific activities that may be performed during an RFI. Examples of
specific reports or components that may be required include:
RFI Work Plan;
Description of Current Situation;
Geophysical Techniques;
5-26
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Waste and Unit Characterization;
Environmental Setting Characterization;
Selection of Monitoring Constituent/Indicator Parameters;
Results of "Phases" of the Investigation;
QA/QC results;
Interim Corrective Measures; and
Identification of Potential Receptors.
In addition, a draft and final RFI report that incorporates the results of all
previous reports will generally be required. This report should be comprehensive
and should be sufficiently detailed to allow decisions to be made by the regulatory
agency regarding the need for interim corrective measures and/or a CMS. It should
be noted that these decisions may also be made by the regulatory agency on the
basis of results of progress reports and/or other reports as described above.
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SECTION 6
HEALTH AND SAFETY
6.1 Overview
Protecting the health and safety of the investigative team, as well as of the
general public, is a major concern during hazardous waste RFIs. Hazards to which
investigators may be exposed include known and suspected chemical substances,
heat stress, physical stress; biological agents, equipment-related injuries, fire, and
explosion. Many of these hazards are encountered in any type of field study, but
exposure to chemical hazards is a major concern for the investigative team at
hazardous waste facilities.
In addition to the protection of team members, the public's health and safety
should also be considered. RFIs may attract the attention and presence of the news
media, public officials, and the general public. Not only is the safety of these
observers a concern, but their actions should not hinder the operations and safety
of the investigative team. Other public health concerns include risks to the
surrounding community from unanticipated chemical releases, and events such as
fires and explosions.
The facility owner or operator should develop and update as necessary health
and safety plans and procedures to address the needs of the RFI. The health and
safety plan should, in particular, establish requirements for protecting the health
and safety of the investigative team, facility workers, and the general public
throughout the investigation.
Health and safety plans should be reviewed and approved by qualified (via
education and work experience) safety and health professionals. While professional
cerifications such as Certified Industrial Hygienists or Certified Safety Professionals
are highly regarded, such certifications are not required under the OSHA standard
for plan review/approval, nor do they inherently guarantee proficiency in
hazardous materials operations. In addition, health and safety plans should be
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discussed thoroughly With the investigative team prior to initiating field activities.
Other appropriate parties (e.g., local emergency services) should also be involved, as
necessary.
Compliance with health and safety regulatory requirements is the ultimate
responsibility of the employer, who, for purposes of the RFI, is the facility owner or
operator. Development and implementation of health and safety procedures is
therefore the responsibility of the owner or operator. Although these procedures
may be presented as part of the RFI Work Plan and reviewed by the regulatory
agency, ultimate responsibility and liability rest with the owner or operator.
Section 6.2 presents general health and safety regulations and guidance that should
be reviewed prior to developing health and safety procedures, Section 6.3 outlines
basic elements of health and safety procedures which should be addressed, and
Section 6.4 reviews application of zones of operation or work zones.
6.2 Applicable Health and Safety Regulations and Guidance
On December 19,1986, the Occupational Safety and Health Administration
(OSHA) issued, in the Federal Register (29 CFR 1910.120), an interim final rule on
hazardous waste site operations and emergency response, which specifically
requires certain minimum standards concerning health and safety for anyone
performing activities at CERCLA sites, RCRA sites, emergency response operations,
sites designated for remediation by a state or local agency, or any other operation
where employees' operations involve dealing with hazardous waste. The following
discussion provides details on the major requirements of the interim final rule.
Development and implementation of a safety and health program:
The development and implementation of a formal, written safety and health
program has long been recognized as a foundation for successful occupational risk
minimization. In recent years, this recognition has been receiving increased
emphasis from the Occupational Safety and Health Administration (OSHA). For
example, as stated in the July 15, 1988 Federal Register (53 FR 26791):
. . . OSHA has become increasingly convinced of the relationship between
superior management of safety and health programs - which address all safety
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and health hazards, whether or not covered by OSHA standards - and low
incidence and severity of employee injuries.
As a result, OSHA has intensified its focus on management practices in its
evaluation of workplaces. One primary area of this focus has been on documented
safety and health programs. This increased emphasis is evidenced in several other
OSHA standards that have been promulgated (e.g., Respiratory Protection -29 CFR
1910.134, Occupational Noise Exposure -29 CFR 1910.95, Hazard Communication -
29 CFR 1910.1200, and Subpart C of the Construction Industry Standards -29 CFR
1926).
In addition to these individual subject area requirements, OSHA has released
for comment and information a proposed rule on General Safety and Health
Programs (previously-referenced Federal Register -53 FR 26791). In that proposal,
suggested guidelines for establishing and implementing new safety and health
programs - or evaluating/modifying existing programs - are provided. The proposed
rule advises employers to institute and maintain...a program which provides
policies, procedures and practices that are adequate to recognize and protect their
employees from occupational safety and health hazards. "
Specific elements of the program proposed by OSHA are addressed under four
subject headings. These headings include management commitment, worksite
analysis, hazard prevention and control, and safety and health training.
It is of no small consequence that management commitment is the first issue
addressed in this proposed rule. A strong commitment from top management
representatives is critical to the success of any program. Additionally, this
commitment needs to be highly visible to employees. Clear program goals and
objectives need to be specified, as well as identification and assignation of
appropriate levels of authority, responsibility and accountability. Finally, at least
annual program reviews and evaluations are necessary to identify the effectiveness
of the program, and incorporate any necessary program modifications.
The second program area recommended for inclusion is worksite analysis. The
intent of this part of the program is to identify methods and practices to be utilized
for recognizing potential hazards. Examples of methods that can be used to achieve
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these objectives include periodic, comprehensive worksite surveys; analysis of new
processes, materials and equipment; and performance of routine job or phase
hazard analyses other recommended methods include the conduct of regular site
inspections, and accident (or near-accident) investigations.
The third program area addresses hazard prevention and control. These
efforts should include identifying appropriate engineering, administrative, and/or
personnel protective equipment arid hazard controls. Additionally, emergency
preparedness and a medical program should be elements of .this portion of the
overall program.
The final topic identified in the proposed rule addresses safety and health
training. Employee education and training needs should be provided so that
employees are fully aware and capable of handling potential hazard,s in the
performance of their work. Additionally, safety arid health training of supervisors
and managers needs to be addressed and performed to ensure that they are aware
of their responsibilities in regard to health and safety.
To summarize, a written, comprehensive health and safety program, that has
visible top-management support, is an important element of a safe and healthful
work environment. However, the written program itself must be effectively
implemented, periodically evaluated - and modified as necessary, in order to
achieve its objectives.
Performance of site characterization and analysis:
In addition to the general items of worksite analysis identified above, specific
requirements for this type of analysis are presented under OSHA regulation 29 CFR
1910.120. Performance of site characterization and analysis is specifically addressed
in paragraph (c) of this regulation.
A site characterization and analysis addressing each site task and operation
planned to be performed needs to be conducted. This effort generally proceeds in
three phases. Initially (prior to any actual site entry, a data-gathering phase is
performed to colled any relevant information that may identify potential site
hazards. This activity may include such items as obtaining shipping/disposal
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manifests or other such records, including newspaper/media reports, and
interviewing Persons with potential knowledge of past Operations (e.g., Previous
employees, nearby residents). This initial phase may also consist of the conduct of
an offsite recannaissance (e. g., around the perimeter of the site), and
characterization based on all of the collected data. The second phase of this process
is the conduct of an onsite survey. Finally the third phase involves site entry, with a
continuance of monitoring efforts to provide current information for evaluating
potential site hazards.
In view of this-phased approach, it is clearly intended that site characterization
and analysis is a continuous process. It is initiated prior to any actual onsite
involvement, and continues throughout the performance of onsite activities.
Development and implementation of a site control program:
Site control elements need to be established to minimize potential for
employee contact with contamination, and the transfer of contaminants into non-
contaminated areas. These program elements need to be clearly defined in the
employer's site safety and health plan. As stated in the preamble of the rule
establishing 29 CFR 1910.120, (December 19, 1986 Federal Register), the
establishment of a site control program should be performed in the planning
stages of a project and modified based on new information and site assessments
developed during site charatierization. The preamble further states that the
"appropriate sequence for implementing these measures should be determined on
a site-specific basis. "
The primary intent of this requirement is that the site control program must be
addressed on a site-specific basis. However, employers should develop a general
program that identifies minimum performance requirements in order to establish
overall uniformity for all projects. For each specific project, the OSHA regulations
specify that the site control program include - at a minimum - the following:
A map of the site;
Designation of site work zones;
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The practice of using what-the regulation refers to as a "buddy system"
(defined as a "system of organizing employees into work groups in such
a manner that each employee of the group is designated to abserve the
activities of at least one other employee in the work group. The purpose
of the buddy system is to provide quick assistance to those other
employees in the event of an emergency.");
Establishment and maintenance of site communications;
Establishment and implementation of site standard operating
procedures or safe work practices; and
Identifying the nearest medical facility that would be contacted in the
event of a site incident resulting in a need for such services.
Compliance with employee training requirements (specified in paragraph (e) of the
standard) and the development and implementation of an employee training
proaram:
An employee training program, must be developed and implemented, meeting
(at a minimum) the training requirements specified in paragraph (e) of the
hazardous waste regulation The program must include provisions for both initial
and refresher training of employees on matters if health and safety. All involved
employees must receive effective training prior to performing any operations that
could result in their exposure to potential safety and health hazards.
The training requirements specified in this regulation are categorized into
several, subject areas. While the majority of the requirements address CERCLA
(Superfund)-related operations, RCRA-related projects and emergency response
operations, general training requirements are also specified. The intention of this
categorization is to recognize that varying degrees of risk potential exit, thereby
requiring different types of health and safety training.
Additionally, for CERCLA-type operations, the program must be further
subdivided to address health and safety training program elements for employees
and onsite management and supervisors. All individuals must receive introductory
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training (40 hours in duration) prior to their initial assignment. This is to be
supplemented by 8-hours of annual refresher training, and the conduct of site-
specific training for each assignment. Onsite managers and supervisors who will be
assigned responsibility for direct, onsite supervision, must receive an additional 8-
hours of specialized training for operations management upon job assignment.
Employees involved in normal RCRA aerations are required to receive a lesser
amount of initial training (24-hours) and 8-hours of annual refresher training.
These requirements are applicable for employees who will be involved in hazardous
waste operations involving storage, disposal and treatment. However, major
corrective actions under RCRA would need to be addressed in a manner similar to
the previously - identified CERCLA training requirements.
The final category specifying employee training requirements addresses
individuals who participate in (offsite) emergency response operations (e. g.,
HAZMAP team personnel). Any employees involved in such operations are required
to receive at least 24 hours of training annually.
The development and implementation of an employee training program must
be initiated by first identifying which of the requirements are applicable, and
identifying the employees who need to be included. The overall program also
needs to address other types of required employee health and safety training
applicable to the work site(s) and job tasks. Examples of other types of required
training may include:
Hazard Communication Training (29 CFR 1910.1200);
Hearing Conservation Training (29 CFR 1910.95);
Respiratory Protection Training (29 CFR 1910.134); and
others-based on types of equipment, processes, etc.
After all training needs have been identified and the program has been
developed and implemented, it must be periodically reviewed and evaluated to
determine its effectiveness, with appropriate modifications made where necessary.
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Finally, appropriate recrds of employee training must be maintained to satisfy
applicable recordkeeping requirements.
Development and implementation of a medical surveillance program:
A comprehensive medical surveillance program must be established for
employees engaged in hazardous waste operations, Employees who have been, or
are expected to be, exposed to hazardous-substances or health hazards must be
participants in such a program. Therefore, one of the first tasks in program
development should be to define how many (and which) employees need to be
covered.
A second critical element in the development of the program is the selection
of a physician (or physicians) who will be utilized to perform the examinations. The
selected physician must be licensed, should be knowledgeable in occupational
medicine, and familiar with the nature of the work tasks that the employees that
he/she will be examining will be performing.
The program needs to provide examinations to employees prior to their first
hazardous materials job assignment, at least once every twelve months following
the initial examination, upon job termination,or reassignment, as soon as possible
for any employee demonstrating symptoms of overexposure to hazardous
substances, and at more frequent times as determined to be necessary by the
examining physician.
The extent of the examination is at the discretion of the examining physician.
However, in order for the physician to appropriately determine the necessary
parameters, protocols, tests, etc., he/she must be made very familiar with the nature
of the patient's job duties. Therefore, the regulation requires that the physician be
provided with a copy of the standard-in its entirety, a description of the employee's
duties relative to potential exposures, a description of known or anticipated
exposure levels that have been - or may be, encountered by the employee, a
description of personal protective equipment that the employee has used or may
use, and the employee's previous medical history.
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The established medical Program should be developed to address medical
concerns specified by other regulations as well as hazardous waste operations (e.g.,
respiratory protection usage, audiometry, asbestos exposures, and other applicable
regulations). Therefore, it should have a mechanism incorporated to provide for
periodic program review and evaluation to determine effettiveness, and the need
for modification as deemed necessary. Finally, medical surveillance recordkeeping
must be performed and maintained in accordance with OSHA 29 CFR 1910.20.
Incorporation of engineering controls, administrative controls, and the
development and implementation of a personal protective equipment program:
To protect employees from potential hazards that may be encountered in
hazardous materials operations (e.g., chemical, physical, biological hazards),
employers are required to implement appropriate control efforts. In order of
preference, such approaches are to employ engineering and administrative controls
where feasible, and (as a last resort), personal protective equipment. However,
these control efforts are not mutually-exclusive. The regulation provides for the
employer to utilize appropriate combinations of these three types of controls in
protecting his/her employees. However, where items of personal protective
equipment (PPE) are used, a PPE program must be developed and implemented.
In the developmental stages of the program, the employer must define the
types of PPE that will or may be necessary for employee usage. Examples include
respiratory protection (with considerations given to the types necessary - e.g., air-
supplied vs air-purifying, half-face masks, full facemasks, etc.), hearing protection,
head protection, foot protection, dermal protection, eye/face protection, etc. Many
of these types of PPE are regulated under specific OSHA standards. Therefore, upon
identification of the types of PPE to be used, the regulations must be consulted in
developing and implementing the program to ensure overall compliance and
program adequacy.
The program must also provide for proper selection of equipment on the basis
of the known or suspected hazards to be encountered, proper maintenance,
cleaning, servicing, storage of equipment, and, proper training of employees in the
correct use and recognition of the limitations of the selected equipment. As with
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other programs, provisions for review and evaluation for effectiveness must be
incorporated, enabling necessary modifications to be made.
Development and implementation of an air monitoring program:
The establishment of an air monitoring, program is essential. The purpose of
the program is to gain accurate information on employee exposures in order to
implement the correct PPE, engineering controls, and work practices. Airborne
contaminants can present a significant threat to employee safety and health. Thus,
identification and quantification of these contaminants through air monitoring is
an-essential component of a safety and health program.
The intent, of this requirement is that the air monitoring program be
addressed on a site-specific basis. After the site characterization and analysis phase
has been completed, personnel should be cognizant of possible contaminants on
each specific site. With this information, proper air sampling and, analytical
methods can be chosen.
Reliable measurements of airborne contaminants are useful in selecting
proper personal protective equipment, determining whether engineering controls
can achieve permissible exposure limits and which controls to use. Also, this
information is used in delineating areas where protection is needed and in assessing
potential health effects of exposure. Knowledge of potential health effects will
further aid in determining the need for specific medical monitoring.
In view of this approach, air monitoring is a continuous process. It should be
initiated prior to any actual onsite involvement, and should continue throughout
the performance of onsite activities.
The developed program needs to contain elements identifying the types of
monitoring equipment available for employee use, proper selection, maintenance
and calibration procedures, employee training, and provisions for equipment
cleaning and storage.
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Development and implementation of an employee informational program:
The Occupational Safety and Health Administration is requiring under 29 CFR
1910.120, that employers, as part of their safety and health program, develop and
implement a site-specific health and safety plan (HASP) for each hazardous waste
site operation.
The site health and safety plan must be developed by the employer, utilizing
the other parts of the organizational plan and the employer's safety and health
program. The HASP must address the anticipated health and safety hazards
associated with each work operation or task, and the means to eliminate the
hazards or to effectively control them to prevent injury or illness.
The minimum requirements that a HASP must include is the following:
The names of those responsible for assuring that safe and healthful
practices and procedures are followed throughout all work operations;
Risk analysis or systems analysis for specific work tasks or operations on
the site;
Employee training assignments both offsite and on-the-job training
onsite;
A list of personal protective equipment needed for each work task and
operation onsite;
The employers medical surveillance program for the site;
The methods for identification and characterization of safety and health
hazards on the site including the air monitoring procedures that will be
performed throughout the work onsite;
Site control measures including those for establishing work zones on the
site;
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The necessary contamination procedures which are matched to the
kinds of anticipated contaminants to e cleaned from personnel and
equipment;
The general safe work practices to be adhered to by personnel onsite;
The contingency plan for emergencies and confined space entry
procedures;
Site-specific training and site inspections and procedures, to be followed
in changing or modifying the plan; and
All emergency numbers of local authorities (e.g., ambulance, police), as
well as directions to the nearest hospital and a map to the hospital.
As a separate section, an emergency response plan must also be included. This
plan is discussed in greater detail, in a latter section of this subsection of the
guidance document.
Adherence to proper procedures for handling drums and containers:
The handling of drums and containers at hazardous waste sites poses one of
the greatest dangers to hazardous waste site employees. Hazards include
detonation, fire, explosion, vapor generation, and physical injury resulting from
moving heavy containers by hand and working in the proximity of stacked drums,
heavy equipment and deteriorated drums. The employer must implement
procedures and provide proper work practices in order to minimize the risks to site
personnel.
The appropriate procedures for handling drums depend primarily upon the
drum contents. Thus, prior to handling, drums should be visually inspected to gain
as much information as possible about their contents. The inspection crew should
look for symbols, words, or other marks on the drum indicating that its contents are
hazardous, e.g., radioactive, explosive, corrosive, toxic and/or flammable. The crew
should also look for signs of deterioration (such as rust, corrosion, and leaks), and
whether the drum is under pressure.
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Conditions in the immediate vicinity of the drums may also provide
information about drum contents and their associated hazards. Monitoring should
be conducted in the area around the drums using instruments such as a radiation
survey meter, organic vapor monitors, and combustible gas indicators.
As a precautionary measure, personnel should assume that unlabeled drums
contain hazardous materials until their contents are characterized. Also, they
should bear in mind that drums are frequently mislabeled - particularly drums that
are reused.
Employers must ensure that any personnel involved with handling drums are
aware of all pertinent regulations. OSHA regulations (29 CFR Parts 1910 and 1926)
include general requirements and standards for storing, containing, and handling
chemicals and containers, and for maintaining equipment used for handling' drums
and containers. EPA regulations (40 CFR Part 265) stipulate requirements for types
of containers, maintenance of containers, and design and maintenance of storage
areas. DOT regulations (49 CFR Parts 171 through 178) also stipulate requirements
for containers and procedures for shipment of hazardous wastes.
Development and implementation of a decontamination procedure:
Decontamination procedures must be developed on a site- and/or task-specific
basis, and be implemented, prior to performing any site entrance activities, These
methods must be specifically matched to the hazardous substance(s) of concern at
the site in order to be effective. Procedures for both personnel and equipment
decontamination must be developed and implemented in order to minimize
potential for:
Employee exposure to substances of concern;
Transferring contaminants offsite or to previously non-contaminated
areas; and
Exposing the environment and/or offsite receptors to hazard potential.
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The standard requires that upon implementation Of these procedure, the site
safety and health officer must conduct monitoring for effectiveness on a continuous
basis.
Decontamination procedures must be supplemented by incorporation of and
adherence to standard operating procedures that are developed to minimize
potential for personnel and equipment to come into contact with contaminated
substances and surfaces. Additionally, the developed' decontamination procedures
must incorporate provisions for controlling, collecting, and disposing generated
wastes in a proper manner. These materials will typically include items, of personal
protective equipment, decontamination (wash and rinse) fluids, as well as materials
generaed during site activities (e.g., drill cuttings, pumped monitoring well fluids,
etc.).'
Development and implementation of an Emergency Response Plan:
prior to any onsite work, the employer must develop and implement an
emergency response plan that is site-specific, and all involved employees must be
made aware of the provisions of this plan. This is to be incorporated as a separate
section of the site safety and health plan, and it must include provisions for:
recognition of emergency situations; methods for alerting onsite personnel of
emergency situations; site evacuation procedures; provisions for emergency
medical treatment; lines of authority in emergency situations; emergency
decontamination procedures; and methods for evaluating the effectiveness of the
emergency response plan.
The regulations require that the role of individual employee's in emergency
situations be reflected in the plan. Two categories of employee activities are also
discussed. One is from the standpoint of onsite emergency response, while the
other addresses offsite response activities. In addition, the greater the roles and
responsibilities of the employee in a response situation, and the greater the risk
potential that may be presented, the more detailed and comprehensive the
emergency response plan will need to be. It is also common that both on and
offsite response efforts may be necessary, depending on the nature and extent of
the specific situation. Therefore, the emergency response plan needs to address
both onsite and offsite activities.
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The emergency response plan must include provisions for the following
elements, at a minimum:
t Pre-emergency planning;
Personnel roles, lines of authority, training, and communication;
Emergency recognition and prevention;
Safe distances and places of refuge;
Site security and control;
Evacuation routes and procedures;
Decontamination;
Emergency medical treatment and first aid;
Emergency alerting and response procedures;
Critique of response and follow-up;
Personal protective equipment and emergency equipment;
Establishment of an Incident Command System;
Procedures for incident reporting to appropriate local, state, and/or
Federal agencies;
Regular rehearsal and employee training of the elements of the plan;
and
Periodic plan review, with necessary modifications, for plan
effectiveness.
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Compliance with the requirements for both illumination, and sanitation at
temporary workplaces:
Minimum requirements for illumination and sanitation (potable and non-
potable water supplies and toilet facilities) are specified in the regulation,
incorporating the requirements of Subpart C of the Construction Industry standards
(29 CFR Part 1926).
Illumination requirements are specified by site areas or operation. Generally,
lower levels of illumination are necessary in areas where employee presence is
incidental or nonfrequent, and where activities involve low risk potential. Greater
amounts of illumination are required in general site areas, indoor site facilities, and
in personnel facilities. The highest illumination intensity requirements are specified
for areas including first aid stations, infirmaries, and offices.
Sanitation requirements address procedures for providing, identifying, and
dispensing potable water and nonpotable water. Additionally, if appropriate,
provisions must be made for toilet facilities, food handling, sleeping quarters, and
washing facilities.
Compliance with the requirements' specified under paragraph (o) of the standard
for certain operations conducted under RCRA, including developing and
implementing a hazard communication program (meeting the requirements of
OSHA 29 CFR 1910.1200):
The OSHA regulation contains less extensive requirements for normal (e.g.,
non-corrective action type) RCRA operations (vs CERCLA operations) in recognition
that, by comparison, hazards should be "better controlled and more routine and
stable" (51 FR 45661, December 9, 1986). Employers conducting operations on
RCRA facilities must develop and implement the following" programs and
procedures:
Hazard Communication Program in conformance with the requirements
of OSHA 29 CFR 1910.120;
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A medical surveillance program;
A health and safety program;
Decontamination procedures; and
An employee training program.
Following is a list of other regulations that should be considered when
developing health and safety programs and procedures:
Citation
29 CFR 1910.134
29CFR1910.95
29 CFR 1903
29 CFR 1904
29 CFR 1926
29 CFR 1960
29 CFR 1975
29 CFR 1977
Title
Respiratory Protection
Hearing Conservation
Inspections, Citations, and Proposed Penalties
Recording and Reporting of Occupational
Injuries and Illnesses
Safety and
Construction
Health Regulations for
Federal Employee Safety and Health Programs
Coverage of Employers Under the
Occupational Safety and Health Act
Regulations on Discrimination Against
Employees Exercising Rights Under the
Occupational Safety and Health Act
Other Federal and State regulations may also address the health and safety of
the investigative team and the public. Department of Transportation (DOT)
regulations (49 CFR 171-178), for example, specify containers, labeling, and
transportation restrictions for hazardous materials. These regulations cover the
transport of compressed-air cylinders, certain instruments, solvents, and samples.
RCRA regulations (40 CFR 260-265) may apply to the storage, treatment, and
disposal of investigation-derived materials, including disposable clothing, used
respirator cartridges and canisters, and spent decontamination solutions.
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Individual states may have occupational safety and health regulations more
stringent than OSHA's. These should be consulted to determine their applicability
and to ensure compliance. In addition, several guidance manuals exist that may be
helpful in establishing health and safety procedures. These are listed below:
Ford, P. J. and Turina, P. T. 1985. Characterization of Hazardous Waste
Sites-A Methods Manual: Volume l--Site Investigations. EPA-600/4-
84/075. NTIS PB 85-215960. Washington, D.C. 213460
U.S. EPA. 1984. Standard Operating Safety Guides. Office of Emergency
and Remedial Response. Washington, D.C. 20460.
U.S. EPA. 1985. Basic Field Activities Safety Training. Office of
Emergency and Remedial Response. Washington, D.C. 20460.
NIOSH/OSHA/USCG/EPA. 1985. Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities. NIOSH 85-115.
GPO No. 017-003-00419-6.
Levine, S.P. and W.F, Martin. 1985. Protecting Personnel at Hazardous
Waste Sites. Butterworth Publishers,
U.S. EPA. 1985. Guidance on Remedial Investigations Under CERCLA.
Office of Emergency and Remedial Response. NTIS PB 85-238616.
Washington, D.C. 20460.
U.S. EPA. 1986. Occupational Health and Safety Manual. EPA 1440.
U.S. EPA. Order 1440.2 - Health and Safety Requirements for Employees
Engaged in Field Activities.
U.S. EPA. Order 1440.3- Respiratory Protection.
Professional recommendations and standards have also been offered by
organizations such as the American Conference of Governmental Industrial
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Hygienists, the ASTM, the American National Standards Institute, and the National
Fire Protection Association.
6 . 3 Elements of a Health and Safety Plan
RFI health and safety plans should address the following:
Names of key personnel and alternates responsible for site safety and
health, and the appointment of a site safety officer;
A safety and health risk analysis for each site task and operation;
Employee training assignments;
Personal protective equipment (PPE) to be used by employees for each of
the site tasks and operations being conducted;
Medical surveillance requirements;
Frequency and types of air monitoring, personnel monitoring, and
environmental sampling techniques and instrumentation to be used -
also, methods of maintenance and calibration of monitoring and
sampling equipment to be used;
Site control measures;
Decontamination procedures;
Site standard operating procedures;'
Confined space entry procedures; and
A Contingency Plan addressing site emergency action procedures.
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6.4 Use of Work Zones
Although this section of the RFI Guidance is intended to be only an
introduction to the health and safety aspects of hazardous waste site investigations,
the establishment of zones of operation or work zones deserves same attention. It
should be recognized, however, that the health and safety aspects described below
may not apply to all sites.
Hazardous waste sites should be controlled to reduce the possibility of (1)
exposure to any contaminants present, and (2) transport of contaminants offsite by
personnel and equipment. One recommended method to prevent or reduce the
possibility of the transfer of contaminants offsite, and to maintain control at the
site, is to establish work zones, or areas on the site where prescribed operations
occur. It is also important to control access points (i. e., entrances or exists) for each
designated work zone. The use of a three zone system might include:
Zone 1: Exclusion Zone
Zone 2: Contamination Reduction Zone
Zone 3: Support Zone
Zone 1, the Exclusion Zone, would include all areas onsite where
contamination is known or suspected to be present. The boundaries can be
established based on results of previous investigations, visual observations, facility
records, or similar information. Appropriate levels of personal protective
equipment (PPE) in this zone are based on the types and concentrations of
contaminants known or suspected to be present, and other hazards that may be
present. In addition, only specifically authorized personnel should be allowed into
this zone. Once the boundaries of Zone 1 have been determined, they should be
physically secured and defined by barriers such as fences or barricades.
Zone 2, the Contamination Reduction Zone, would be set up to provide a
buffer to separate contaminated areas from non-contaminated areas, and may
actually surround Zone 1. Decontamination stations would generally be set up
between Zone 1 and Zone 2, or within Zone 2. These stations would serve as areas
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for decontamination of both personnel and equipment. Some level of PPE may also
be required in this zone, as some level of contamination or other hazard may be
present. Access into Zone 2 from the Support Zone (Zone 3), is also controlled; only
authorized personnel should be allowed access. Any worker entering Zone 2 should
also be wearing the appropriate PPE.
The Support Zone, Zone 3, would be located in a clean or uncontaminated
area, and would be directly outside of Zone 2. The support zone may have several
functions, including use as a command post and first aid station, and would serve to
house equipment sheds or trailers, mobile laboratory facilities, training and briefing
areas, etc.
6-21
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SECTION 7
WASTE AND UNIT CHARACTERIZATION
7.1 Objectives and Purposes of Waste and Unit Characterization
Because the waste managed or contained in a unit provides the. source for a
contaminant release, detailed knowledge of the source characteristics is valuable in
identifying monitoring constituents and indicator parameters, possible release
pathways, a conceptual model of the release, monitoring procedures, and also in
linking releases to particular units. Waste and unit characteristics will also provide
information for-determining release rates and other release characteristics (e.g.,
continuous as opposed to intermittent). Waste and unit information is-also
important for determining the nature and scope of any corrective measures which
may be applied.
Without adequate waste characterization, it is difficult to ensure, that all
constituents of concern will be monitored during the release investigation, unless
all possible constituents are monitored. The extent of adequate waste
characterization, however, will vary depending upon the nature of the facility and
types of units studied. For example,waste characterization for a unit dedicated to a
single steady-state process will be much less extensive than for a unit at an offsite
facility that manages a variety of wastes that vary over time.
As indicated above, waste characterization may also be helpful in identifying
constituents to discriminate among releases from different units. In some situations
(e.g., more than one unit in a waste management area), it may be important to
identify which unit is responsible for the release of concern. Accurate identification
of the unit from which the release is occurring may hinge on the ability-to link the
released contaminants to the waste managed in a particular unit (or, in some cases,
to "decouple" the contamination from a particular unit).
Sufficient characterization of the waste for the purpose of the RFI may not be
possible due to the diversity of wastes managed in the unit overtime or the relative
7-1
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inaccessibility of the waste in the unit. Waste characterization may be of limited
utility where:
The waste managed in the unit varies over time such that adequate
determination of the waste constituents cannot be made. An example of
this is an offsite commercial facility receiving different wastes from
different generators.
The unit of concern is no longer active and the waste cannot be sampled
through a reasonable effort. This situation may occur at closed landfills
where sampling of buried drums may not be practical due to their
inaccessibility.
In cetiain situations, waste characterization may also not be advisable. For
example, the waste in question may be extremely toxic (e.g., nerve gas), or highly
reactive or explosive (e.g., disposed munitions). In such cases, release
characterization may be based on constituents (or parameters) identified in the-
affected medium (e.g., leachate) at the point where the medium becomes (or is
suspected of becoming) contaminated. If it becomes necessary to conduct waste
characterizations in these situations, or to remove the waste in question, a high
level of health and safety protection (See Section 6) should be instituted.
Waste characterization should also be designed to provide sufficient
information to support the implementation of interim measures and/or corrective
measures. For example, if buried drums are identified during the RFI, the nature of
the waste within these drums (e.g., ignitability, corosivity, reactivity, constituent
concentrations), if accessible, should be ascertained to determine if they should be
removed from the site and how they should be subsequently managed as well as to
support the investigation of media-specific releases under the RFI.
Design and operational characteristics of the unit are factors that will affect
the rate of release and location within the unit from which the contamination is
being or has been released. Such factors as unit size, type, operational schedule,
and treatment, storage, or disposal practices should be helpful.
7-2
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Although 40 CFR Section 264.13 of the RCRA regulations (General Waste
Analysis) contains waste analysis requirements, the information required may not
always be suficient for purposes of the RFI. Waste characterization to determine
specific hazardous constituents, for instance, is not always required. In addition,
little or no data on inactive units may be available. The RFI Work Plan should be
consistent, as appropriate, with the items identified in the requirements of 40 CFR
Section 264.13. Further guidance is given below.
7.2 Waste Characterization
In cases where a waste characterization is to be performed, the following
approach is recommended:
Identify data needs through review of existiting information;
Sample the waste; and
Characterize the physical and chemical properties of the waste and waste
constituents.
If the unit has a leachate collection system, the leachate should also be
sampled and analyzed, as it may also provide useful information, particularly with
respect to the leachable portions of wastes contained in the unit.
7.2.1 Identification of Relevant Information
In general, a waste characterization should produce the following types of
information:
Identification of specific hazardous constituents and parameters which
can be used in release verification or characterization (See Section 3.6);
Physical and/or chemical characteristics of the waste useful for
identifying possible migration pathways through the environmental
media of concern; and
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Physical and/or chemical characteristics of the waste, which may be
necessary to evaluate treatment and/or management options.
Identifying specific constituents of the waste through a sampling and analysis
program may require an extensive level of effort. The owner or operator is advised
to use various informational sources, on the specific waste in question in order to
focus the analytical effort required. Such sources are described below.
7.2.1.1 EPA Waste Listing Background Document Information
The RCRA Hazardous Waste Listing Background Documents developed for
the identification and listing of hazardous wastes under 40 CFR Part 261 contain
information on waste-specific constituents and their physical and chemical
characteristics. These documents contain information on the generation,
composition, and management of listed waste streams from generic-and industry-
specific sources. In addition to identifying hazardous constituents in the wastes, the
documents may also provide data on potential decomposition products. In some
background documents, migratory, potential is discussed and exposure pathways,
identified.
Appendix B of the Listing Documents provides detailed information on the
fate and. transport of hazardous constituents. Major physical and chemical
properties of selected constituents are listed, including molecular weights, vapor
pressures and solubilities, octanol-water partition coefficients, hydrolysis rates,
biodegradation rates, volatilization rates, and air chemistry (e.g., reaction) rates.
Another section of this appendix estimates the migratory potential and
environmental persistence of selected constituents based on a conceptual model of
disposal in an unconfined landfill or lagoon.
The appropriate uses and limitations of the Listing Documents are, outlined in
Table 7-1. In addition, Case Study No. 1 in Volume IV (Case Study Examples)
illustrates the use of the Listing Documents.
A list of the available listing background documents may be obtained by
reviewing 40 CFR Parts 261.31 and 261.32. These background documents are
available in EPA's RCRA docket at the following location:
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Table 7-1
Uses and Limitations of EPA Listing Background Documents
Uses
Limitations
Identifies the hazardous Applicable only for listed hazardous
constituents
was listed.
for which a waste
In some cases, provides
information on additional
hazardous constituents that may
be present in a listed waste.
In some cases, identifies
decomposition products of
hazardous constituents.
l» Provides overview of industry;
gives perspective on range of
waste generated (both quantity
and general characteristics).
May provide waste-specific
characteristic data such as,»
density, pH, and leachability.
May provide useful information
on the migratory potential,
mobility, and environmental
persistence of certain hazardous
constituents.
May list physical and chemical
properties selected
constituents.
wastes.
Industry coverage, may be limited in
scope. For example, the Wood
Preserving, Industry Listing Document
only covers organic preservatives,
Inorganic such as inorganic arsenic,
salts, account for approximately 15
percent of the wood preserving
industry.
Data may not be comprehensive. For
example, not all potentially
hazardous constituents may be
identified. Generally, only the most
toxic constituents common to the
industry as a whole are identified.
Data may not be specific.
Constituents and waste characteristics
data often represent an industry
average which encompasses many
different types of production
processes and waste treatment
operations.
Some Listing Documents were
developed from limited data/reports
available to EPA at the time of
promulgation, resulting in varying
levels of detail for different
documents.
Listing Documents for certain
industries (e. g., the Pesticides
Industry) ma be subject to CBI
(confidential business information)
censorship. In such cases, constituent
information may be expurgated from
the document.
7-5
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EPA RCRA Docket
U.S. Environmental Protection Agency (WH-562)
Room S-212
401 M St., S.W.
Washington, D.C. 20460
7.2.1.2 Facility Information
Identification of the constituents of a waste stream may be made through
examination of records already,existing in the facility. Engineering data on process
raw materials or analytical data on the process effluents will also provide a good
starting point for waste characterization. In some cases, generally where waste
characteristics are well-defined, data on process raw materials or effluents will
provide sufficient information, for performing the RFI. More specifically, these
sources may be:
Hazardous waste characterization data used for a RCRA Permit
Application;
Waste Analysis Plan (as required by 40 CFR Part 264.13);
State or local permit applications;
Initial batch treatment results from an offsite hazardous waste disposal
facility;
Hazardous waste compatibility results for bulk shipments;
t Purchase orders and packing lists;
Analyses conducted to. provide data for shipping manifests;
Facility records of past waste analyses;
Process operational data;
t Product quality control analyses;
7-6
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Data from past releases of hazardous waste into the environment;
compatibility results for containment liner studies;
Past Federal, State, or local compliance and inspection results;
OSHA industrial hygiene monitoring results;
Facility health and safety monitoring data;
Engineering design data from construction of plant processes;
Performance specifications for process equipment;
Related emissions data such as NPDES discharge results; and
Information from past or present employees.
7.2.1.3 Information on Physical/Chemical Characteristics
Information on physical or chemical characteristics of the waste or waste
constituents that may be useful in predicting movement of the contamination
through the media of concern or in evaluating waste treatment or management
options may be found in the following references:
Callahan, et al. 1979. Water-Related Environmental. Fate of 129 Priority
Pollutants, Volumes I and II. Office of Water Planning and Standards. NTIS PB
297606. Washington, D.C. 20460.
Dawson, et_aL_ 1980. Physical/Chemical Properties of Ha7ardnus Waste
Constituents. Prepared by Southeast Environmental Research Laboratory for
U.S. EPA. EPA RCRA Docket. Washington, D.C. 20460.
U.S. EPA. 1985. Health Effects Assessment for [Specific Chemical]. [Note: 58
individual documents, available for specific chemicals or chemical groups].
7-7
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Environmental Criteria and Assessment Office. Cincinnati, Ohio 45268. [See
Section 8.4 for a list of these documents]
Jaber, et al. 1984. Data Acquisition for Environmental Transport and Fate
Screening. Office of Health and Environmental Assessment, U.S. EPA. EPA
600/6-84-009. NTIS PB 84-140102. Washington, D.C. 20460.
Lyman, et al. 1982. Handbook of Chemical Property Estimation Methods.
McGraw-Hill, New York.
Mabey, et aL 1982. Aquatic Fate Process Data for Organic Priority Pollutants.
Prepared by SRI International, EPA Contract Nos. 68-01-3867 and 68-03-2981.
Prepared for Office of Water Regulations and Standards. Washington,. D.C.
20460.
U.S. EPA. 1980. Treatabilitv Manual. Volume I. EPA 600/2-82-001 a. Office of
Research and Development. NTIS PB 80-223050. Washington, D.C. 20460.
U.S. EPA. 1984. Characterization of Constituents from Selected Waste
Streams Listed in 40 CFR Section 261. Office of Solid Waste. Washington, D.C.
20460.
U.S. EPA. 1984. Exposure Profiles for RCRA Risk-Cost Analysis Model. Office
of Solid Waste. Washington, D.C. 20460.
U.S. EPA. 1986. Ambient Water Quality Criteria. Office of Water Regulations
and Standards. Washington, D.C. 20460.
Perry and Chilton. 1973. Chemical. Engineers' Handbook. McGraw-Hill.
5th Ed. New York.
Verschueren. 1983. Handbook of Environmental Data-for Organic Chemicals.
Van Nostrand Reinhold Co. New York. 2nd ed.
Weast etal. 1979. CRC Handbook of Chernisttv and Physics. CRC Press.
7-8
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Windholtz, elaL 1983. The Merck Index Merck&Co. Rahway, NJ.
U.S. EPA. 1986. Test Methods for Evaluating Solid Wastes. 3rd Edition.
Office of Solid Waste. EPA/SW-846. GPO No. 955-001-00000-1. Washington,
D.C. 20460.
U.S. EPA. 1984. Characterization of Hazardous Waste Sites-A Methods
Manual. Volume III. Available Analytical methods. EPA 600/4-84-038. NTIS
PB84-191048. Washington, D. C. 20460.
Some commercially available computer information systems that contain
chemical properties data and/or estimation methods may also be used. An example
would be the Chemical Information System (CIS) (7215 York Road, Baltimore, MD
21212). Another example is the Graphical Exposure Modeling System (GEMS) data
base discussed in Section 3.5. The owner or operator should consult with the,
regulatory agency prior to use of such systems.
7.2.1.4 Verification of Existing Information
If existing information is current and sufficient to completely identify the
type, amount, and location of waste, then available information may be considered
adequate. If existing information is used, constituents present should be verified by
recent waste analysis or by dated analysis that is substantiated by recent facility
records showing that no changes in process, manufacturing, or other practices that
could alter waste composition have occurred. If existing information does not
provide adequate waste characterization, or if the waste characteristics have
changed, sampling may be required.
7.2.2 Waste Sampling
All sampling should be conducted in a manner that maintains sample
integrity and encompasses adequate QA/AC. The characterization of waste in any
unit must be representative. As wastes are often generated in bulk quantities from
a large variety of processes, adequate determination of the waste profile requires
that cyclical or random variations in waste composition be considered. The
characterization should account for variation in waste content by collecting samples
7-9
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that are representative of all potential waste variations: If a wide variation in waste
composition is expected, it is preferable to document the range of this variation
through the' analysis of numerous samples. If litile variation is anticipated, a lesser
amount of sampling may be appropriate. If composite sampling is proposed, it must
not mask unexpected or unanticipated compositional variations, and should always
be complemented with an appropriate number of grab (non-composited) same
Generally, compositing should not be used when evaluating variation in waste
composition. Collection of representative samples will involve different procedures
for different waste and unit types. This is discussed further in Section 7.4. Case
Studies No. 3,4, and 17 in Volume IV (Case Study Examples) provide illustrations of
waste sampling uses, considerations, and techniques.
7.2.3 Ptiysical/Chemical Waste Characterization
Compound-specific waste charatierization should consider the constituents
listed in 40 CFR Part 261, Appendix VIII, as the universe of overall constituent
Except for especially complex waste, many of the compounds on this list may be
eliminated using the guidance presented previously in this section and in
Section 3.6. As indicated in Section 3.6
The owner or operator should provide's sound justification or analytical
results of waste analyses as substantiation for the elimination of
constituents from further consideration;
The analysis of waste samples to determine their characteristics should be
performed using standard methods, such as those described in. the 3rd,
edition of EPA/SW-846 (Test Methods for Evaluating Solid Waste), or
equivalent methods; and
A detailed QA/QC Plan should clearly define the sample preparation
techniques, analytical methodology, required analytical sensitivities and
detection limits, and collection of blanks and duplicates.
In addition, for units that contain a mixture of solid, dudge, and/or liquid
waste material, each phase should be analyzed and volume proportions measured.
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.*
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7.3 Unit Characterization
Information on unit characteristics may affect release properties and
pathways. The owner or operator should obtain relevant information on the unit
for use in developing the RFI strategy. Such information may include
Unit dimensions (including depth below grade);
Unit type;
Unit purpose (e.g., biodegradation);
Structural description, including materials and methods of construction,
and any available drawings;
Amounts of waste managed;
previous uses of area occupied by unit;
Unit location;
Description of liner or cap materials;
Holding/retention time;
Key operating parameters, such as waste management schedule;
Waste treatment/application or loading rate;
Biological activity present;
Vent numbers and sizes; and
Drainage areas.
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7.4 Applicable Waste Sampling Methods
7.4.1 Sampling Approach.
References for waste sampling methods discussed in this section are listed in
Section 3.6.3. A summary of available waste sampling methods for various waste
matrices is provided in Table. 7-2.
Collection of waste samples requires methodology suited to the type of waste
and unit sampled. In addition, waste sampling requires specialized equipment and
protocols that may be designed especially for waste analysis or adapted from other
sampling methods. Several important points to consider when developing a
sampling approach are as follows:
Compatibility of sampling methods and materials with the constituents
being sampled.
Ensuring the safety of personnel. Careful attention should be given to
the level of protection and safe practices required for sampling activities.
If the sampler is wearing protective gear that limits vision and mobility,
or is fatiguing to wear, the collection procedures should be as simple as
possible.
Waste samples are generally not preserved and are considered hazardous
for shipping purposes.
7.4.2 Sampling Solids
Sampling of solid materials should utilize readily available techniques. In
general, the primary concern for the sampling of solid materials is effectively
representing a large amount of possibly heterogeneous material in small samples.
In order to address this concern, discrete samples should be collected from sufficient
locations to characterize the waste with respect to location and time. Sampling
methods vary depending on whether samples are to be collected at the surface, or
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TABLE 7-2. SAMPLING METHODS SUMMARY FOR WASTE CHARACTERIZATION
Waste Type/Unit Type
Solid Wastes
Waste Piles
Land Treatment Units
Landfills
Drum Handling
Sacks and Bags
Trucks
Conveyor Belts
Unloading/Loading/
Transfer Areas
Sludae Wastes
Waste Piles
Drum Handling
Tanks
surface Impoundments
Trucks
Conveyor Belts
Unloading/Loading/
Transfer Areas
Liquid Wastes
Drum Handling
Tanks
Surface Impoundments
Trucks
Unloading/Loading/
Transfer Areas
1
scoops
and
Shovel
X
X
X
X
X
X
X
X
X
X
X
X
X
2
Triers
X
X
X
X
X
X
3
Thiefs
X
X
X
X
4
Augers
X
X
5
Core
Samplers
X*
X
X
X
X
X
X
X
6
Glass
Tubes
X
X
X
7
Petite
Ponar
Grab
X
X
X
8
Dippers
X
X
X
X
X
X
X
X
9
Coliwasa
X
X
X
X
X
X
10
Pump
and
Tubing
X
X
X
X
X
11
Kemmerer
Bottle
X
X
X
12
Bacon
Bomb
X
X
X
X
* Core Sampler modified to serve as air-tight container for retention of volatile fraction.
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below the surface. For a unit currently in operation, variation in waste stream
composition over time should be considered in determining when samples should
be taken.
For large amounts of solid materials; sample locations may be-determined by
applying a three-dimensional grid in combination with random sampling.
techniques as discussed in Section 3. In certain circumstances, compositing samples
may be acceptable to minimize the number of sample analyses, as long as waste
composition remains fairly constant over the sampling period. When composition
waste is expected to vary (e.g., in complex wastes), grab samples should be taken.
Compositing should be employed only when the representativeness of the waste
characterization is uncompromised, and should always be accompanied by
confirmational grab samples.
Bulk solid materials are generally homogeneous. They are likely to be found
in waste piles, drums, bags, trucks or hoppers, or on conveyor belts. Bulk solid.
materials can be sampled using various methods. Surface soil or soil-like materials
found at land treatment units, in landfills, and at waste transfer (e.g., loading and
unloading) areas can also be sampled using the same basic methods. Deeper soil
sampling will require other methods as described in Section 9 on soil.
Five basic solid sampling methods are discussed below:
SCOOPS and shovels are useful for sampling dry or moist granular,
powdered, or otherwise unconsolidated solids from piles as well as from
other containers of solid material (e.g., bags, drums, hoppers, trucks, or
shallow containers). Waste material transported to the unit by conveyor
belt can be sampled using a scoop to collect samples from the belt.
Scoops are applicable to solid waste materials that are within easy reach
of sampling personnel. Scoops made of stainless steel or Teflon are
preferable due to the inertness of these materials to most waste types.
This sampling method is limited in utility to collection of samples near or
on the surface of the waste. For collection of samples at greater depth,
other methods, are necessary. Shovels are used in the same manner as
scoops when larger quantities, of sample are needed or when an
extended reach is required. Shovels are available in inert materials like
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Teflon or stainless steel. Scoops and shovels will enable collection of land
treatment unit samples from depths Up to about 16 inches. Because most
land treatment units manage organic waste streams, extreme care must
be taken to retain the volatile organic components of the sample
through rapid handling of the exposed sample during., the collection
process. Containers that, have septum caps or air-tight lids should be
used in conjunction with the scoop and shovel sampling method.
Collection of soil-samples from depths lower than the normal, depths of
tilling are described in Section 9. Contaminated surface soils at waste
transfer areas are also easily sampled using scoops and shovels.
Triers are used to withdraw a core of sample material. The trier is similar
to a scoop in that it is inserted by hand into the material to be sampled;
however the design allows for the collection of a core of material. Triers
are most useful for sampling waste piles, bags, hoppers,, or other sources
of loose solid waste material. Cores are most readily obtained with triers
when the material being sampled is moist or sticky so that the core,
which is cut by rotating the trier, stays together while the sample is
removed from the waste, material source. These samplers are useful only
when they can be inserted horizontally into the material being sampled.
Triers are readily available in lengths from 61 to 100 cm and are usually
made of stainless steel with wooden handles.
Thiefs are essentially long hollow tubes with evenly spaced openings
along their lengths. An inner tube with similar openings is oriented so
that the openings are not aligned and the entire dual-tube thief is
inserted into the solid waste material. After insertion, the inner tube is
rotated to align the openings, thus allowing the solid material to flow
into the inner tube. The inner tube is then rotated back to the closed
position, sealing the openings prior to withdrawal of the sampler. Thiefs
can be inserted horizontally, vertically, or at various angles into the
sample as long as the material will flow (by gravity) into the slots of the
sampling tubes. This method is best suited for sampling of dry free-
runnig solids. Thiefs are available in a range of sizes to allow for
collection of materials of varying particle size, but are not generally
useful for particles in excess of 0.6 cm. Thiefs, like triers, are available in a
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variety of materials, usually brass or stainless steel, and are appropriate
for sampling waste piles, drums, or hoppers.
Augers can be used to sample solid material at varying depths. The use
of augers is generally exclusive to the collection of soil samples at depth
such as at landfills. However, for large waste piles which cannot be
sampled in any other manner, it may be necessary to obtain samples from
the inside portions of the pile in order to-assess the overall characteristics
of the material in the pile. Generally, augers are used in conjunction
with a thin-wall tube sampler that is inserted into the borehole to collect
an undisturbed sample from the depth at which the auger was stopped.
The nature of the solid material and the physical size and accessibility of
the unit will determine tile applicability of augering and the most
suitable type of auger. Augers are designed for general types of soil
conditions and "disturb" samples to vaying degrees. If possible,
sampling of waste material should be conducted prior to or during waste
placement because sampling by augers and thin-wall tubes can be
difficult and time consuming. Backhoes may be required to gain access to
the interior portions of the unit (e.g., a waste pile).
Core samplers such as previously described in conjunction with augers are
frequently used for"soil sampling. Section 9 addresses soil sampling in
greater detail. Core samplers can also be used to collect cores of land
treatment unit samples and provide excellent samples for spanning the
depth of treated soil. Thin-wall tube core samplers can be used to collect
vertical cores at most desired locations. Sampling of top soil layers that
contain the applied waste material can usually be accomplished using
conventional hand coring techniques. As with the scoop and shovel
method, extra consideration should be given to preventing losses of
volatile organic components from the sample; the use of air-tight sample
containers is recommended. Another-technique is to utilize a core
sampler which can itself be used as an air-tight sampling container.
Recent designs include a coring device with Teflon-gasketed end caps
that can be used to both collect and contain land treatment samples for
soil and soil-gas analyses.
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7.4.3 Sampling Sludges
Sludges are "semi-dry" materials ranging from dewatered solids to high-
viscosity liquids. Due to their liquid content, sludge materials are not usually stored
or handled as solids; and often require containment in drums, tanks, or
impoundments, to prevent runoff of the liquid portion of the sludge. Sludges also
include sediments with high liquid content under a liquid layer. Sampling must
frequently include extended-reach equipment to gain access to the submerged
sludge layer. For those cases where sludges are piled and have a sufficiently high
solids content, methods previously discussed under "Solids" may be adequate. The
equipment used in some of the solid material sampling methods is available with
modifications to contain samples with a high liquid content.
Sediments can accumulate at the bottom of drums due to settling of
suspended solids in liquid and sludge wastes. These sediments can be readily
sampled using the previously discussed methodology. Glass-tube samplers,
particularly those of larger bore, can be pressed into bottom sediments of drums to
obtain samples. For bottom sediments or sludges that are too thick-or resistive for
glass tubes, corers with or without core catchers can be inserted into the drum for
collection of sediments.
Basic methods for sampling sludges are discussed below:
Scoops and shovels are useful for collecting sludge samples from the
surface of a sludge pile, or at shallow depths in drums, tanks, or surface
impoundments. Shovels will allow for the collection of larger volume
samples. Extra care may be required to collect "representative" samples
if the liquid fraction of the sludge tends to separate from the sample
while being collected. The liquid fraction should be considered part of
the sludge material and must be retained for adequate characterization.
Long-sleeve gloves may be required for personnel protection.
* Triers may be useful for collection of cores of material from sludge piles.
The nature of the waste will determine the utility of this method. Triers
are not generally used for sludges; however, on a trial-and-error basis,
their applicability may be-determined.
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Core samplers modified to retain sludge material can be used to collect
sludge from waste piles where samples are required-from various depths.
Core catchers, such as thin-wall tube samplers that prevent washout of
the wet sludge during recovery of the sampler from the sludge source,
are available for attachment to the tip of coring devices. Because sludges
are most often formed through deposition of solids from a liquid
mixture, the composition of the sludge may vary significantly with time
and location. The use of a core sampler equipped with a core catcher can
provide for collection of a sample profile. These types of corers are
available with extension sections that allow for collection of samples
from depths well below the surface of the waste. Corers are generally
equipped with a cutting edge on the tip that greatly facilitates
penetration of a thick bottom layer and can also be outfitted with core
catchers to assist in retaining looser sediment materials that might be
more readily lost from the bottom of a glass tube. The amount of sludge
present can be easily estimated by measuring the depth to the apparent.
bottom and Comparing it to the known interior depth.
Glass tubes or a Composite Liquid Waste Sampler (COLIWASA) can be
used to collect bottom sediments from drums or shallow tanks when they
are gradually inserted into the solid layer at the bottom. Due to the
fragility of glass and the danger of cuts, this technique is applicable only
for materials easily penetrated by the tube. High-liquid-content bottom
sediments may exhibit washout characteristics similar to liquid samples.
in many cases, the only way to determine if sample losses from the
bottom of the tube will occur is to carefully test it to see what happens.
Petite Ponar Grab Samplers are clamshell-type scoops activated by a
counter-lever system. The shell is opened and latchedin place, then
lowered to the bottom. When tension on the sample line is released, the
shell halves are unlatched. The lifting action of the cable on the lever
system closes the clamshell. These dredges, are capable of collecting
most types of sludges or sediments from silts to granular materials up to
a few centimeters in diameter. As agitation of the liquid above the
sludge occurs during sampling, it is advisable to collect sediment samples
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after all liquid sampling is complete. This method is particularly useful
for tanks and surface impoundments.
7.4.4 Sampling Liquids
Liquid wastes require distinctly different sampling methods than do solids
and sludges, with the exception of some techniques for sampling submerged
sediments, and should also account for parameters of interest (e.g., for volatile
contaminants, it is important to prevent volatilization). Common liquid waste
sources are drum handling units, tanks, and surface impoundments. A general
safety concern associated with drums and tanks is the structural integrity. Safe-
access procedures for sampling these units should be established prior to sample
acquisition.
Liquid wastes handled in drums can be sampled, before being loaded into the
drum or, if necessary after placement. For facilities that receive wastes in drums,
sampling should be conducted prior to the removal of the waste material from the
drum. For waste streams that can be sampled directly prior to drum loading, grab
sampling techniques are appropriate. As always, sufficient samples-should be
collected to account for waste variation over time. Sampling of drums can be done
using several different methods, including grab sampling with a dipper from the
open drum, routine full-depth drum sampling using a disposable glass tube or
COLIWASA, or with a sampling pump with tubing that is lowered into the drum for
sampling.
Tanks are containment structures, larger than drums that can hold more than
a million gallons. Tanks include tanker trucks, above-ground tanks, and partially or
fully underground tanks. Tanks usually have limited access due to small hatchway
openings, or ladders or walkways that often extend across open-top tanks. Due to
the greater depth of tanks versus drums, methods with extended-reach capabilities
are necessary. Waste materials in tanks generally include liquids and bottom
sludges: When retention time of liquid wastes in tanks is long, layering or
stratification including settling out of sediments is likely to occur. Great care should
be taken to minimize the disturbance of liquid layers while collecting samples. The
surface should be broken gently and samplers lowered gradually. Liquid sampling
utilizes either pump and tubing methods or discrete depth samplers, such as
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Kemmerer Bottles or Bacon Bomb samplers. Bottom sediments that cannot be
drawn up with a pump will require the use of small dredges, such as the Petite Ponar
Grab sampler.
Surface impoundments can range from several hundred to several million
gallons in capacity. Due to their large size, they are usually open to the atmosphere
rather than covered. Sampling of an impoundment may be difficult, except near its
edges or from walkways that extend over the impoundment. "Off-shore" sampling,
when necessary, should be considered a serious, potentially dangerous operation
and should be performed according to strict health and safety procedures.
Common means of sampling off-shore locations are boats, floating platforms,
cranes with suspended enclosed platforms, and mobile boom vehicles with
platforms.
Whenever possible, the waste should be characterized prior to its transfer
into the impoundment. For example, waste pipelines can be sampled from valves,
and tanker trucks discharging waste into impoundments can be sampled prior to
discharging. However, taking samples from the units is desirable, because changes
in the concentrations reported for samples taken during transfer may have large
impacts on the estimates of the amounts of hazardous waste or constituents in the
impoundment.
Liquid sampling techniques for impoundments include Dippers (particularly
in the pond sampler configuration with a telescoping handle), pump and tubing,
Kemmerer Bottles, and Bacon Bomb samplers. The dipper or pond sampler method
is the easiest to use; however, it is not capable of reaching-off-shore locations or of
collecting samples at varying depths below the surface.
Liquid sampling methods are described below:
Dippers can be used to collect samples from the surface liquid layer of
open drums, tanks, or impoundments. (Other techniques are required to
collect samples from drums where the only access is through the bung
hole in the lid). This method is appropriate only for wastes that are
homogeneous and likely to be represented by a grab sample from the
top layer. In most cases, a full-depth composite liquid sample is more
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representative. The dipper technique involves the use of an intermediate
vessel that is submerged in the waste liquid. The sample is then poured
into the designated sample container. Handles are attached to the vessel
to make sampling easier and reduce direct contact of the sampling
technician with the waste material. In one configuration, the dipper is
attached to a telescoping pole for an extended reach; this configuration
is called a pond sampler. The dipper sampling device is also useful for
sampling from piping system valves.
Glass tube samplers can collect a full-depth liquid sample from a drum
and can be used through the bung hole on the drum lid such that the lid
need not be removed. Conventionally, the glass tubes are 122 cm long
and 6 to 16 mm in inside diameter. Larger diameter tubes can be used if
the liquid to be sampled is more viscous. The major limitation of this
method is spillage (i.e.,liquid loss from the bottom of the tube is
unavoidable). Smaller diameter tubes have fewer problems with sample
loss than do large-bore tubes. This method is perhaps the most common
drum sampling technique due to its relative ease of use and the minimal
equipment decontamination required.
COLIWASA samplers are a more formalized version of the glass-tube
samplers. The COLIWASA (composite liquid waste sampler) utilizes an
inner rod attached to a stopper at the bottom of the sampling tube. The
sampler is slowly inserted into the drum with the bottom stopper open.
When the sampler reaches the bottom, the inner rod is pulled up, sealing
the sampling tube for removal of the sample. A COLIWASA can be made
of many materials; however, inert materials (e.g., Teflon or glass) are the
materials of choice.
Pump and tubing (e.g., bladder pumps) systems are readily available and
are useful for withdrawing liquid samples from up to 28-foot depth.
Peristaltic pumps are available in many sizes and flow rates to
accommodate many sampling situations. Full-depth composite samples
can be collected by gradually lowering the tubing into the material being
sampled. One limitation of this system is that the pump applies a vacuum
to the sample that can alter the chemical-equilibrium in the sample,
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resulting in the loss of volatile organic components. A modification to
this basic system can be made by placing a sample vessel in-line between
the tubing and the pump to prevent sample material from contacting the
pump parts. In this configuration, collection of numerous samples is
facilitated beta use pump tubing need not be cleaned or replaced
between sampling events.
High flow rates are not advisable because rapid overflowing of sample
bottles may occur. A lower flow rate will assist in minimizing the
disturbance of liquid layers in the tank and will cause less agitation of the
sample as it enters the sample bottle. The peristaltic pump and tubing
system can be utilized in two configurations -- one with the tubing
connected directy to the pump and a second with an intermediary
sample vessel in-line between the pump and tubing. The second
configuration also eliminates pump decontamination between samples.
When sufficient waste characterization data are available, small
submersible pumps can also be used; however, these pumps are not
generally made of chemically resistant or relatively inert materials. The
utility of these small submersibles depends on their ability to provide
samples from greater depths. Peristaltic pumps have an upper limit of
approximately 8 meters, whereas submersibles can be used for most
depths of concern.
Kemmerer Bottles are discrete-depth liquid samplers that are usually
appropriate for tank or impoundment sampling. The Kemmerer Bottle is
a spring-loaded device that is lowered into-the liquid in the open
position, allowing the liquid sample to flow through it while it is
descending. At the desired depth, a messenger is dropped down the
sample line, releasing the spring-loaded closing device to obtain the
sample. Limitations of Kemmerer Bottles include the poor availability of
devices constructed of relatively inert materials, the difficulty in
decontamination between sampling, and the inability of this sampler to
collect purely depth-discrete samples (because the sampler's surfaces are
exposed to materials in the liquid layers as the sampler passes through
them to arrive at the designated depth)
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Bacon Bomb samplers are lowered on a sample line. A second line
attached to an opening rod, which runs down the center of the bomb,
will open the sampler when pulled. The sample can be collected with a
minimal amount of agitation since the rod can open the top and bottom
of the bomb, allowing the sample to enter the bottom and air to exit
through the top. Bacon Bomb samplers are readily available from
laboratory supply houses and are frequently constructed of chrome-
plated brass. Relatively inert construction materials, such as Teflon or
stainless steel, are preferable. Careful maintenance and regular
inspection of samplers is advised. Samplers with plating materials flaking
off should be removed from use. If waste characteristics are known,
sample changes caused by the sampler can be avoided by using materials
compatible with the type of waste being sampled. An advantage of the
Bacon Bomb sampler is its ability to be lowered to the desired depth in
the closed position before collecting a sample. This technique minimizes
cross-contamination from liquid layers above.
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SECTION 8
HEALTH AND ENVIRONMENTAL ASSESSMENT
8.1 Overview
This section describes the Health and Environmental Assessment (HEA) that
will be conducted by the regulatory agency as part of the RFI. The primary element
of this assessment is a set of health and environmental criteria (chemical
concentrations) to which measured and in some cases predicted (e.g., for the air
medium) concentrations of hazardous constituents developed during the release
characterization will be compared. When these criteria ("action levels") are
exceeded or there is a reasonable likelihood of this occurring, a Corrective Measures
Study (CMS) will generally be required, although the owner or operator may
because of site specific factors, present data and information to support a
determination that no further action is necessary. This section describes the HEA
process (Section 8.2), the determination of potential exposure routes for each
environmental medium of concern (Section 8.3), and the development and use of
the health and environmental criteria (Section 8.4), leading to an evaluation of the
need for appropriate interim corrective measures and/or a CMS. The evaluation of
chemical mixtures is discussed in Section 8.5, Special considerations involved in the
evaluation of soil and sediment contamination are discussed in Section 8.6. Section
8.6 also provides a review of statistical procedures that may be used to evaluate
ground-water monitoring data. Section 8.7 discusses qualitative and other factors
which may be used by the regulatory agency in conducting the health and
environmental assessment. Interim corrective measures are discussed in Section 8.8.
References used in developing this section are listed in Section 8.9. Finally, Section
8.10 presents the health and environmental criteria and provides several
worksheets which may be used to conduct the HEA.
The health and environmental criteria used in determining the need for a CMS
are based primarily on EPA-established chronic-exposure limits. These values and
their use are described herein. Subchronic exposure limits and qualitative criteria
are also discussed. It should be emphasized that the health and environmental
criteria provided, in this section do not necessarily represent clean-up target levels
that must be achieved through the implementation of corrective measures. Rather,
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they establish presumptive levels that indicate that a closer examination is
necessary. This closer analysis would generally take place as part of a CMS.
The guidance provided in this section presents a general framework for
conducting a HEA. It is intended to provide a flexible approach for interpreting
release characterization data, as case-specific factors may enter into consideration.
For example, State-established criteria and consideration of past environmental
problems (e.g., fish-kills) may also be considered.
The regulatory agency may require both interim corrective measures and a
CMS as a result of the HEA. One difference between interim corrective measures
and definitive corrective measures may be timing. The development and
implementation of a comprehensive corrective action program can be a time-
consuming process. Between the time of the identification of a contaminant
release and the implementation and completion of definitive corrective measures,
existing conditions or further contaminant migration could endanger human health
and the environment. Under these conditions, interim corrective measures, which
may be temporary or short-term measures (e.g., providing bottled water or
removing-leaking drums) designed to prevent or minimize adverse exposure, can be
applied. Case Study No. 11 in Volume IV (Case Study Examples) provides an
illustration of the HEA process.
The HEA procedures described in this section apply to releases from all units
except: releases to ground water from "regulated units" as defined under 40 CFR
Part 264.90(a)(2). Releases to ground water from "regulated units" must be
addressed according to the Requirements of 40 CFR §264.91 through §264.100 for
purposes of detection, characterization, and appropriate response.
8.2 Health and Environmental Assessment Process
The HEA is a continuous process that begins with the initiation of the RFI. As
investigation data (from monitoring and/or modeling) become available, both
within and at the conclusion of discrete phases, they should be reported to the
regulatory agency as required, the regulatory agency will compare these data to
applicable health and environmental criteria, including evaluation against
qualitative criteria, to determine the need for (1) interim corrective measures;
and/or (2) a ,CMS. Notwithstanding this process, the owner or operator has a
8-2
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continuing responsibility to identify and respond to emergency situations and to
define priority situations that may warrant interim corrective measures. For these
situations, the owner or operator should follow the RCRA Contingency Plan
required under 40 CFR Part 264, Subpart D and Part 265, Subpart D.
The results of the media-specific investigations described in Volumes II and, III
of this Guidance will be used to identify the constituents of concern, constituent
concentrations within the release, general release characteristics (e. g., organic,
inorganic), the affected environmental media, exposed or potentially exposed
human or environmental eceptors, the rate of migration of the release, and the
extent of the release. The objective of the HEA is to integrate these results to.
determine whether interim corrective measures and/or a CMS may be necessary. In
general, this objective is achieved in a two-step process.
First, potential human and environmental exposure routes are determined.
Section 8.3 provides guidance for determining potential exposure routes for the
media of concern. For ground water, surface water, soil, and air, methods are
described for making exposure route-specific comparisons with the health and
environmental criteria. Subsurface gas migration and inter-media transport of
contamination from other media to air (e.g., ground-water contamination resulting
in seepage of volatile constituents to basements) are addressed as. air problems to
the extent that they contribute hazardous constituents to ambient air, whether
indoors or outdoors. Evaluation of the migration of methane gas in the subsurface
is also addressed in this section (Section 8.8). as part of the guidance on interim
corrective measures, due to the immediate explosion potential of methane.
Second, the measured (or in some cases, such as releases to air, predicted)
constituent concentrations in the release are compared to EPA-established,
exposure-limit criteria. At any time during the RFI when contaminant:.
concentrations in the release are found to exceed the health and environmental
criteria, a CMS will generally be required by the regulatory agency, although the
owner or operator may, because of site-specific factors, present data and
information to support a determination that no further action is necessary. In
addition, when health and environmental criteria are exceeded, the need for
appropriate interim corrective measures will also be determined. This process
8-3
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involves an evaluation of exposed or potentially ex posed human and environmental
populations. This process discussed in more detail in Section 8.8.
The determination of whether a CMS may be necessary will be made by the
regulatory agency, by comparing constituent concentrations determined at
locations within the release to the health and environmental criteria discussed in
Section 8.4. These criteria serve as "action levels" for determining whether a CMS
will be necessary. Figure 8-1 depicts a hypothetical facility with individual solid
waste management units and a contaminant release originating from one of the
units. For ground water, surface water, soil, and-subsurface gas, the comparison of
constituent concentrations with the criteria will be made for all measurements
within the release at and beyond the limit of the waste management area.
The evaluation procedure for releases to air differs from the other media in
that comparison of constituent concentrations with the health and environmental
criteria will be made at the facility property boundary. However, onsite air
comparisons may be necessary in cases where people reside at the' facility or when
worker safety regulations are deemed inadequate to protect human health and the
environment, although onsite air contamination normally would fall under the
jurisdiction of OSHA. As indicated in the Air Section (Section 12), the values
compared can be either measured values derived from monitoring or predicted
values derived from modeling.
8.3 Determination of Exposure Routes
Some of the more significant potential exposure routes for each
environmental medium are presented in Table 8-1. This table should be used to
determine the appropriate health and environmental criteria to be used in the
comparison with measured or preditied constituent release concentrations. For
example, when releases to ground water have been identified, a primary exposure
route of concern is drinking water. For each constituent identified inn the ground-
water release, the measured concentrations are compared with the appropriate
criterion values discused for drinking water in Section 8.4.
Suspected or known inter-media transfers of contamination should have been
characterized (i.e., nature, extent and rate) during the RFI process. For example, if
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FACIL TY BOUNDARY
LEGEND:
SAMPLING LOCATIONS
FIGURE 8-1. HYPOTHETICAL FACILITY WITH INDIVIDUAL SOLID WASTE
MANAGEMENT UNITS AND A CONTAMINANT RELEASE
ORIGINATING FROM ONE OF THE UNITS.
8-5
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TABLE 8-1
Some Potential Exposure Routes
Contaminated Medium
SoiP
Ground Water
Subsurface Gas2
Air
Surface Wateri
Exposure Route
Soil Ingestion (surficial soil), Dermal
Contact
Ingestion of Drinking Water
Inhalation
Inhalation
Ingestion of Drinking Water
Consumption of Contaminated Biota
(e.g., fish)
Exposure routes for deep contaminated soils and bottom sediments
underlying surface water bodies are addressed separately in Section 8.6.
2 Migration of methane gas in the subsurface presents a problem due to the
explosive properties of methane. This is treated as an"immediate hazard
and is discussed under intetim corrective measures (Section 8.8).
[Note: Other important exposure pathways can include inhalation of
volatile constituents released during domestic use of contaminated
ground water or when such ground water seeps into residential
basements. Similarly, various exposure pathways can lead to
adverse effects on environmental receptors (i.e., animals and
plants).]
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the initial contaminant release was to the soil medium and eroded soils have been
transported to surface water, both soil and surface water contamination should
have been adequately characterized during the RFI. In this example; the regulatory
agency will onsider exposure in both media. In cases where subsurface gas, soil, or
ground-water releases have, caused contaminant seepage to basements, inter-
media transfer to the air may pose an inhalation hazard. In such cases,
contamination of basement areas should have been adequately characterized
during the RFI process.
8.4 Health and Environmental Criteria
The preliminary set of health and environmental criteria are presented in
Tables 8-5 through 8-10 in Section 8.10. The constituents shown in Tables 8-5
through 8-10 are a subset of the hazardous constituents listed in Appendix VIII of 40
CFR Part 261. It should be noted that the definition of constituent may also include
components of 40 CFR Part 264, Appendix IX that are not also on Appendix VIII, but
are normally monitored for during ground-water investigations. Tables 8-5 through
8-10 identify such constituents, where criteria for these constituents are available.
The concentrations shown for each constituent are derived, from EPA-
established chronic (and in some cases acute) toxicity criteria for ingestion (soil and
drinking water) or inhalation exposure routes, and were calculated using a set of
intake assumptions for the various media, as shown in Table 8-2. As indicated in the
footnotes accompanying Tables 8-5 through 8-10, the criteria presented are subject
to change. Therefore, these numbers should be confirmed by the regulatory agency
prior to use.
8.4.1 Derivation of Health and Environmental Criteria
Maximum Contaminant Levels (MCLs) -- Table 8-5 provides the maximum
contaminant levels (MCLs) for drinking water promulgated under the Safe Drinking
Water Act. In developing these values, total environmental exposure to a particular
contaminant from various sources (e.g., air, food, water) and gastrointestinal
absorption were considered.
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TABLE 8-2
Intake Assumptions for Selected Routes of Exposure
Surficial Soils (Inqestion):
0.1 g/day for 70 kg person/70 year exposure period for
carcinogens
0.2 g/day for a 16 kg child/5-year exposure period for
systemic toxicants*
Surface and Ground Water (Ingestion):
2 liters/day for 70 kg adult/70-year exposure period
Air(lnhalation):
20 m3air/day for 70 kg adult/70-year exposure period
* Corresponds to the period of 1 to 6 years of age.
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The MCL, when available for a constituent released to ground water or surface
water, should be used as the evaluation criterion for human drinking water
consumption for that constituent. If an MCL does not yet exist for a particular
constituent, criteria in the other tables presented in Section 8.10 should be used,
where available. If air, surficial soil, or sediment (See Section 8.6) are the media of
concern, or when evaluating aquatic life exposure or human consumption of
aquatic organisms, the MCL is not used. In such cases, the criteria in the other tables
should be used, as described below. [Nate: EPA is in the process of developing a
number of new MCLs to be issued over the next several years.]
Carcinogens -- Table 8-6 presents the human health-based criteria for
carcinogens. These criteria, calculated from Risk-Specific Doses (RSDs), were
developed according to EPA Guidelines for Carcinogen Risk Assessment (U.S. EPA,
1986). The RSD is an upper bound estimate of the average daily dose of a
carcinogenic substance that corresponds to a specified excess cancer risk for lifetime
exposure. The values presented in Table 8-6 are environmental concentrations that,
under the intake assumptions shown in Table 8-2, correspond to excess lifetime
cancer risks of 10-6 for Class A and B carcinogens, or 10-5 for Class C carcinogens. ,
Table 8-6 presents the class (A, B or C) of the carcinogen (See U.S. EPA, 1986, for a
description of carcinogen classification).
The criteria presented in Table 8-6 were calculated from RSDS in the following
manner:
Ci = (R/qi*)x(W/l) (Equation 8-1)
where
Ci = the criterion concentration for the constituent of interest;
R = the specified risk level (e.g., 10"6);
q^ = the carcinogen slope factor (CSF) in (mg/kg/day)"1 developed
by the Carcinogen Assessment Group (CAG) of the EPA, Office
of Health and Environmental Assessment, or the Agency's
Carcinogen Risk Assessment Verification Endeavor (CRAVE)
Workgroup;
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theRSD;
W = the assumed weight of the exposed individual; and
I s: the intake amount for a given time period.
For example, the health-based criterion (Ci) for aldrin, a Class A carcinogen,
was calculated for water in the following manner:
C = (R/qr)x(W/l)
- 2.1 x KTrng/liter
» 2.1 x 1Cr3ug/liter
Calculation of the criteria for soil ingestion and air inhalation shown in Table
8-6 takes essentially the same form. However, the valuesfor the, assumed intake
rate (I) differ. The assumed intake rate for soil that is used in the calculations for
carcinogens is 0.1 g/day for a 70-kg person. The current conservative, linear models
that" the Agency uses in cancer risk assessments consider the expression of
carcinogenic effects to be a function of cumulative dose, and thus assume that, in
general, elevated exposures during early childhoodaione are not that significant in
determining lifetime cancer risk. Therefore, the soil intake value of 0.1 g/day is an
upper-range estimate of soil ingestion for adults. The intake rate (I) for air
inhalation is 20 m'Vday for a 70-kg person.
Many of the health-based criteria for carcinogens shown in Table 8-6 are
below current analytical detection limits (See Section 3.6 for a discussion of
detection limits). For example, the concentration for dieldrin in Table 8-6 is 2.2 x
io3ug/l for the drinking water exposure route, while the corresponding current
limit of detection for this constituent is approximately 5 x10"2ug/l. In those cases
where the HEA criterion is less than the limit of detection, the detection limit will be
used as a default value when making comparisons to investigation data, unless
acceptably determined modeling values can be applied (i.e., values from air
dispersion models).
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The criteria provided in Table 8-6 address the surficial soil (ingestion), water
(ingestion), and air (inhalation) routes of exposure. For human health assessment,
the carcinogen criteria for water should be used when ground water or surface
water is the medium of concern, unless MCLs exist or there are lower values for the
constituents of concern in Table 8-7. The carcinogen criteria for surficial soil
(ingestion) and air (inhalation) should be used if surficial soil or air, respectively, is
the medium of concern, unless a lower value appears in Table 8-7. If a particular
constituent is not identified in Table 8-6, the criteria in Table 8-7 (systemic toxicants)
should be used, if available. As alluded to above, constituents that are both known
carcinogens and systemic toxicants (e.g., chloroform) will have values in both Tables
8-6 and 8-7. In such cases, the lower of the two values should be used as the action
level. Both values are presented in the tables if needed for determining the
additive toxicity of mixtures (see Section 8.5).
Systemic Toxicants - Table 8-7 presents the human health-based criteria for
systemic toxicants. These criteria, calculated from Reference Doses (RfDs), are an
estimate of the daily exposure an individual (including sensitive individuals) can
experience without appreciable risk of health effects during a lifetime. For water
ingestion, the systemic criteria are calculated"for a 70-kg adult for achronic lifetime
exposure period (i.e., 70 years). For soil ingestion, the assumed intake rate of 0.2
g/day is based on a 5-year exposure period for a 16-kg child. These exposure.
assumptions for soil are reflective of an average scenario in which children ages 1-6
(who exhibit the greatest tendency to ingest soil) are assumed to ingest an average
amount of soil on a daily basis. The concentrations shown in Table 8-7 were
calculated using the intake assumptions presented in Table 8-2 for the selected
exposure routes, as shown in the following equation:
C< = (RfD) x (W/l) (Equation 8-2)
For example, the concentration (Ci) for surface water and ground water for
pentachlorobenzene shown in Table 8-7 was calculated in the following manner:
Ci = Criterion concentration for constituent of interest
RfD = Reference..Dose for pentachlorobenzene
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= 8 x 10"4mg/kg/day
I = ingestion rate (from Table 8-2)
= 2 liters
day
W = adult body weight (from Table 8-2)
= 70 kg
Ci = (8 x 1CT4mg/kg/day) x (70 kg/2 liters/day)
= 2.8 x 10"2mg/liter
Ci = 2.8 x 101ug/liter (which rounds off to 3 x 101ug/liter)
As with the carcinogen criteria, some of the systemic criteria presented in
Table 8-7 may be below current, analytical detection limits. (See Section 3.6 for a
discussion of detection limits.) In cases where the criterion is less than the limit of
detection, the detection limit will be used as a default value when making
comparisons to investigation data, unless acceptably determined modeling values
can be applied (i.e., values from air dispersion models).
EPA is in the process of developing inhalation criteria for 49 systemic toxicants
based on inhalation toxicity studies. Inhalation criteria for several of these systemic"
toxicants are currently available. These criteria are identified in Table 8-7. When
additional criteria are developed, they will be incorporated into the Integrated Risk
Information System (IRIS) data base (see Section 8.4.2). In addition, EPA is currently
conducting research on development of systemic toxicity criteria for dermal
exposure through contact with contaminated soil.
The systemic criteria for the water, (human ingestion) route of exposure should
be used unless MCLs or lower carcinogen criteria exist. For other routes of exposure
(e.g., soil ingestion), carcinogen criteria should be used unless lower systemic
criteria exist. As indicated previously, some toxicants are both carcinogenic and
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systemically toxic (e.g., chloroform) and, thus appear in both Tables 8-6 and 8-7. In
such cases, the lower of the two values should be used for human health
assessment.
Water Quality Criteria - A summary of the EPA Water Quality Criteria (WQC)
appears in Tables 8-8 and 8-9. These criteria exist to protect both marine and fresh-
water aquatic life and address both acute and chronic toxicity. WQC also exist for
protection of human health through water and fish consumption (incorporating
both routes of exposure), and for fish consumption only. If human consumption of
both the suflace water and contaminated aquatic organisms is a factor, the set of
criterion values based on ingestion of contaminated aquatic organisms and drinking
water should be used. The values based on consumption of fish alone Should be
used only when human consumption of the surface water is not of concern. WQC
should be used only when surface water is the medium of concern. If aquatic life
exposure and human exposure are both of concern, the more stringent criteiidn
should be used. Aquatic life criteria may be applied even if human exposure is not
of concern. [Note: In states which have adopted numerical Water Quality
Standards or where numerical standards can be calculated from non-numeric state
standards, such standards may be used in lieu of EPA WQC or other available levels
on a constituent-specific basis.]
Acute and Subchronic Criteria -- These criteria address impacts on both
children and adults, and are presented in Table 8-10. These criteria are most
commonly applied for the determination of the need for interim corrective
measures, Their use is described in Section 8.8.
8.4.2 Use of Criterion Values
As indicated previously, the criteria presented in Tables 8-5 through 8-10 are
subject to change. These tables do not present action levels for ail of the 40 CFR
Part 261, Appendix VIII constituents. In addition, action levels for components of 40
CFR Part 264, Appendix IX that are not also on Appendix VIII, but are normally
monitored for during ground-water investigations, may also-be applied. As existing
health effects data are reviewed and more information becomes available from
laboratory and epidemioiogical studies, these tables may be expanded to include
additional hazardous constituents, including those from Appendix IX.
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Current information on the health and environmental effects of various
toxicants, including information on RSDs and RfDs, and supporting toxicological
studies, may be obtained from review of the following document:
U.S. EPA. Integrated Risk Information System (IRIS) Chemical Files. Office of
Health and Environmental Assessment, Office of Research and Development.
Washington, D.C. 20460.
The Integrated Risk Information System (IRIS), is a computerized library of
current information that is up-dated on a continuous basis. It contains health risk
assessment information on chemicals which have undergone a detailed review of
toxicity data by work groups composed of EPA scientists from several Agency
program offices, and repesent EPA consensus: IRIS may be accessed by the EPA
Regions, and State and local governments through the EPA electronic mail system
(Dialcom) or through the Public Health Network of the Public Health Foundation
(contact the Network at (202) 898-5600 for details). IRIS is also available to the
general public through the EPA electronic mail system (Dialcom-(202)488-0550), In
addition, IRIS is also available on floppy diskettes in ASCII format through the
National Technical Information Service (NTIS-(703) 487-4763).
If EPA has not yet developed criteria for constituents which may be pertinent
to a particular release, there are various options which may be exercised by the
regulatory agency. A literature search may be performed to locate any health
effects data which can be used to develop an interim criterion value or at least,
information such as type of health effect (e.g., carcinogenicity) which can be used to
make judgments. The regulatory agency, for example, may obtain-and review EPA
summaries of health and environmental effects produced for a particular
constituent. These summaries include Health and Environmental Effects Profiles
(HEEPs), Health Effects Assessment (HEA) documents, and other documents
produced by EPA to summarize health and environmental effects for particular
constituents. These documents are collectively known as Health and Environmental
Effects Documents (HEEDs), and are available for many of the 40 CFR Part 261,
Appendix VIII constituents through EPA's RCRA Docket and library, located at EPA
Headquaters in Washington, D.C. A listing of all the HEEDs currently available is
8-14
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contained in the following adocument, which is also available through EPA's RCRA
Docket and library:
U.S. EPA, 1987. Backround Document. Resource Conservation and Recovery
Act, Subtitle C -- identification and Listing of Hazardous Waste, Appendix A --
Health and Environmental Effects Documents. Office of Solid Waste.
Washington, D.C. 20460.
Additionally, the HEA documents can be obtained from the National Technical
Information Service (NTIS). Table 8-3 presents a list of all chemicals for which HEAs
are currently available, and also identifies the NTIS ordering number.
If little or no useful information regarding a particular constituent can be
located, the initiation of a toxicity bioassay may be considered. The Technical
Assessment Branch, Health Assessment Section of the Office of Solid Waste, located
in Washington, D. C., may be contacted for toxicological information [(202)382-
4761)]. This office may also be contacted to determine whether a toxicity bioassay
for a particular constituent is planned or is in progress. Comparison of background
concentrations (as action levels) to constituent concentrations in the release may be
made by the regulatory agency when health and environmental effects information
are not available.
Note also that the criteria presented in Tables 8-5 through 8-10 do not address
all routes of exposure or forms of toxicity which may be of concern in particular
circumstances. For example, dermal toxicity (absorption of toxicants through the
skin) may also be of concern in particular cases. Phytoxicity (toxicity to plants) and
other forms of environmental toxicity, such as terrestrial toxicity (toxicity to animals
and birds) may also be of concern. Additional information regarding other routes
of exposure and forms of toxicity may be obtained from the following reference:
U.S. EPA. October, 1986. Suoerfund Public Health Evaluation Manual. EPA
540/1-68/060. NTIS PB87-183125. OSWER Directive No. 9285.4-1. Office of
Emergency and Remedial Response. Washington, D.C. 20460.
Worksheet 8-1 in Section 8.10 may be used to present release characterization
data and to facilitate the comparison of constituent concentrations to health and
8-15
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TABLE 8-3
CHEMICAL AND CHEMICAL GROUPS HAVING EPA HEALTH
EFFECTS ASSESSMENT (HEA) DOCUMENTS1
CHEMICAL
NTIS2PB NUMBER
e n z e n e
III
VI
and
and
Compounds
Compounds
Acetone
Arsenic and Compounds
Asbestos
Barium and Compounds
Benzene
Benzo (a) pyrene:
Cadmium and Compounds
Carbon Tetrachloride
Chlordane
C h I o r o b
Chloroform
Chromium
Chromium
Coal Tars
Copper and Compounds
Cresol
Cyanides
DDT
1,1-Dichloroethane
1,2-Dichloroethane (DCE)
1,1-Dichloroethylene
1,2-cis-Dichloroethylene.
1,2-trans-Dichloroethylene
Dichloromethane
Ethylbenzene
Glycol Ethees
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
gamma-Hexachlorocyclohexane
Iron and Compounds
Lead and Compounds (Inorganic)
(Lindane)
86 134277/AS
86 134319/AS
86 134608/AS
86 134327/AS
86 134483/AS
86 134335/AS
86 134491/AS
86 134509/AS
86 134343/AS
86 134517/AS
86134210/AS
86 134467/AS
86 134301/AS
86 134350/AS
86 134368/AS
86134616/AS
86 134228/AS
86 134376/AS
86 134384/AS
86 134137/AS
86 134624/AS
86 134269/AS
86 134525/AS
86 134392/AS
86 134194/AS
86 134632/AS
86 134285/AS
86 134640/AS
86134129/AS
86 134673/AS
86 134657/AS
86 134665/AS
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TABLE 8-3 (continued)
CHEMICAL AND CHEMICAL GROUPS HAVING EPA HEALTH
EFFECTS ASSESSMENT (HEA) DOCUMENTS1
CHEMICAL
NTIS2PB NUMBER
Manganese and Compounds
Mercury
Methy Ethyl Ketone
Naphthalene
Nickel and Compounds
Pentachlorophenol
Phenanthrene
Phenol
Polychlorinated Biphenyls (PCBs)
Polynuclear Aromatic Hydrocarbons
Pyrene
Selenium and Compounds
Sodium Cyanide
Sulfuric Acid
2,3,7,8-TCDD (Dioxin)
1, 1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Vinyl Chloride
Xylene
Zinc and Compounds
Complete Set of 58 HEAs
86 134681/AS
86 134533/AS
86 134145/AS
86 134251/AS
86 134293/AS
86 134541/AS
86 134400/AS
86 134186/AS
86 134152/AS
86 134244/AS
86 134418/AS
86 134699/AS
86 134236/AS
86 134426/AS
86 134558/AS
86 134434/AS
86 134202/AS
86 134442/AS
86 134160/A5
86134566/AS
86 134574/AS
86 134459/AS
86 134582/AS
86 134475/AS
86 134178/AS
86 134590/AS
86 134111/AS
1As of the date of publication for this guidance document.
"National Technical Information Service.
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environmental criteria. Additional worksheets are provided for evaluating hazards
posed by mixtures of constituents. Evaluation of chemical mixtures is discussed in
the following section.
8.5 Evaluation of Chemical Mixtures
There are several situations when the overall potential for adverse effects
posed by multiple constituents may be assessed. For example, if no individual
constituent exceeds its action level in a given medium, but there are many
constituents present in the medium, the overall (additive) health risk may be
assessed to determine whether a CMS may be required. In other cases, an
evaluation of the health risk posed by a mixture of constituents may be used in
assessing the need for interim measures, patiicularly where exposure is actually
occurring. The Guidelines for the Health Risk Assessment of Chemical Mixtures (U.S.
EPA, 1986) describe the recommended approach to be used in evaluating the
chronic effects of exposure to a chemical mixture. According to the guidelines, a
mixture is defined as any concentration of two or more chemicals regardless of
source or of spatial or temporal proximity. " Under these guidelines, additivity of
effects for carcinogens can be assumed. The guidelines also allow for additivity of
systemically toxic constituents which cause similar systemic effects. Carcinogens and
systemic toxicants must be evaluated separately. When evaluating mixtures of
systemic toxicants constituents should be grouped by the same mode of
toxicological action (i.e., those which induce the same toxicological endpoint, such
as liver toxicity).
The overall risk posed by a mixture of constituents is evaluated through the
use of a Hazard Index (HI) that is generated for each health endpoint. For systemic
toxicants, the hazard index (HIT) takes the form:
n E|
HIT = Z - (Equation 8-3)
where
n = total number of toxicants;
E; = exposure level of the its toxicant; and
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AL ; = maximum acceptable level for the its toxicant.
The hazard index for carcinogens (Hlc) is similar:
HI c = n Ej
2 - (Equation 8-4)
i = 1 ORj
where
n = total number of carcinogens;
E j = exposure level to the jth carcinogen; and
DR j = dose at a set level of risk for the jth carcinogen.
If any calculated hazard index exceeds unity (i.e., one), then the need for
interim corrective measures and/or a CMS may reassessed.
The use of the hazard index in the evaluation of chemical mixtures is described""
below for an example case in which three carcinogens were measured within a
contaminant release. Trichloroethylene and carbon tetrachloride levels in the
ground water were measured at 2 and 1 ug/l; respectively. A breakdown product of
carbon tetrachloride, chloroform, was also measured at a level of 3 ug/l. None of
these concentrations exceed the indtvidual criteria presented in Tables 8-5 through
8-10. (The MCL for both trichloroethylene and carbon tetrachloride is 5.0 ug/l, and
the carcinogenic criteria for chloroform is 5.7 ug/l.) However, the hazard Index (Hlc)
for these three chemicals exceeds unity. Rewriting Equation (8-4) in terms of the
measured concentration (E,) and the criterion concentrations (DRj) shown in Tables
8-5 through 8-10 gives:
Hie = 2 uq/l + 1 uq/l + 3 uq/l
5.0 ug/l 5.0 ug/l 5.7 ug/l
Hlc = 0.4 + 0.2 + 0.53
Hlc = 1.T3
Thus, in this situation, the need for interim corrective measures and/or a CMS
may be assessed.
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Contaminant additivity is possible both within a medium and across media.
When appropriate, the regulatory agency may use the hazard index approach for
multiple contaminants within a given medium to help determine the need for
interim corrective measures and/or a CMS. Similarly, contaminant additivity may be
applied across media, especially when site-specific factors indicate a likelihood of
chronic exposure to constituents from multiple media. Information on the
toxicological effects of individual systemic toxicants may be found in the HEEDs, and
the IRIS data base, referenced earlier.
Worksheet 8-2 (Section 8.10) provides a format that the regulatory agency
may use to assess the toxic effects of chemical mixtures based on the hazard index.
An example case worksheet is also presented.
8.6 Evaluating Deep Soil and Sediment Contamination and Use of Statistical
Procedures for Evaluating Ground-Water Contamination
As indicated previously, determining whether deep soil and', sediment
contamination warrants consideration of interim corrective measures and/or CMS
may involve the application of specific exposure assumptions and consideration of
other factors. Guidance regarding these topics is presented in Subsections 8.6.1 and
8.6.2. This guidance may be revised in future editions of this document as a result of
ongoing EPA studies. Subsection 8.6.3 presents a discussion on statistical
procedures that may be usedfor evaluating ground-water contamination.
8.6.1 Deep and Surficial Soil Contamination
As described in the Soil Section of this Guidance (Section 9), releases of
hazardous waste or constituents to soil can. be described as surficial or deep.
Surficial soil is generally described as the top 2 feet of soil; in site-specific conditions,
it may extend to 12 feet. Land use that involves housing developments is an
example of when the surficial soil depth may extend to 12 feet, because foundation
excavation may result in deep contaminated soils being moved to the surface.
Because of the potential for inter-media transport of contamination, the
potential routes for exposure to surficial soil contaminants are soil, air, surface
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water, and ground water. While air, surface water, and ground-water routes are all
important, the most, relevant and major route of exposure is through direct contact
with and/or ingestion of soil.
Surficial soils may be contaminated with organics, inorganic, organometals,
or a combination of these. At high concentrations, some contaminants will cause at
least irritation at the point of skin contact. For many contaminants, however,
toxicity occurs after they pass through certain barriers (e.g., the wall of the
gastrointestinal tract or the skin itself), and enter blood or lymph, and gain access to
various organs or systems of the body. Generally, because of the chemical forms in
which metals are usually 'found in soils (e.g., salts, ligand, and chelate complexes),
the concern is with their ingestion rather than with dermal contact.
Surficial soil contaminated with lead and/or cadmium presents a unique health
risk to children because of the possible ingestion of contaminated soil through their
normal exploratory behavior, coupled in some instances with pica, and because of
the cumulative nature of lead and cadmium poisoning.
Currently, there is no verified Reference Dose (RfD) or Risk Specific Dose (RSD)
for lead. The Carcinogen Assessment Group (CAG). of ORD is evaluating lead as a
potential human carcinogen via the oral route of exposure and is currently working
on estimating a Carcinogenic Slope Factor (CSF) for lead based on current toxicity
studies. The Agency is also attempting to develop a RfD for lead based on new
toxicological data on the non-carcinogenic, neuro-behavioral effects of lead
exposure. It is not likely, however, that either the RfD or the RSD will be developed
and approved soon.
Another metal of concern is cadmium. Although the Agency has not formally
approved an RfD for cadmium, a value of 0.0005 mg/kg/day will likely be approved,
as an RFD. This value would translate to an acceptable soil level of 9 mg/kg.
Toxicological information on lead and cadmium are undergoing extensive
Agency review, and decisions on relevant health-based standards are currently
being made. The Integrated Risk Information System (IRIS) chemical files should be
searched periodically for updated material concerning lead and cadmium.
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The criteria discussed in Section 8.4 that apply to soil (and shown in Tables 8-6
and 8-7 in Section 8.10) pertain to ingestion of surficial soils. Because ingestion-of
deep soils may not be a likely exposure scenario, different evaluation methods may
be used for deep soils, as described below.
In making the determination of whether interim corrective measures and/or a
CMS should be considered for deep contaminated soils, the regulatory agency may
evaluate the potential for the contamination within deep soils to contaminate
underlying ground water. If the potential exists for contaminated deep soils to
release hazardous constituents to ground water, such that the criteria levels for
ground water discussed in Section 8.4 may be exceeded, interim corrective measures
and/or a CMS will be considered. This applies not only-to situations where ground
water has not yet been impacted by deep soil contamination, but also to situations
where deep contaminated soils are acting as a continuous source of contamination
to already contaminated ground water. In addition, the regulatory agency may
apply this evaluation to surficial soils, particularly in cases where the soil ingestion
criteria (Section 8.4) are not exceeded and where the surficial soil may pose a future
or continuing threat to ground water.
In-order to determine whether contaminated soils pose a future or continuing
threat to ground water, leaching tests a-rid/or other evaluation procedures may be
performed on representative samples of contaminated soils following the guidance
presented in Section 9.4.4.3. If the concentration of constituents of concern
measured in leachate resulting from leaching tests and/or other procedures exceeds
the applicable criteria for ground water discussed in Section 8.4, interim corrective
measures and/or a CMS may be necessa-, unless the owner or operator
demonstrates (following the guidance presented in Section 9.4.4.3) that
attenuation and other mechanisms will reduce these concentrations to acceptable.
levels prior to entry into the ground' water.
Case Study No. 16 in Volume IV (Case Study Examples) illustrates the
application of leaching tests and the evaluation of other site-specific information to
determine whether contaminated soil poses a threat to ground water.
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8.6.2 Sediment Contamination
As with deep contaminated soils, direct ,human exposure to contaminated
sediments, underlying surface waters is unlikely. However, such sediments may pose
risks to both the surface water ecosystem and humans due to toxicity and/or
bioaccumulation and biomagnification through the food chain. The regulatory
agency may therefore assess the potential for contaminated sediments underlying
surface water to act as a continuing or future source of contamination to the water
column, to aquatic lifethat may be present in the surface water, and consequently
to humans who may ingest the surface water and/or the aquatic life within the
surface water.
Section 13, in addressing releases to surface water, recommends that,
whenever metal species or organic constituents having bioaccumulative potential
are known to be present in bottom sediments (or in the water column),
biomonitoring (e.g., sampling and analysis of aquatic species) be conducted. If
potentially bioaccumulative organic or inorganic contaminants (as discussed in
Section 13) are measured in the aquatic species of interest, interim corrective
measures and/or a CMS may be necessary.
If other hazardous constituents (e.g., those which are not known to be
potentially bioaccumulative) are measured in the sediment that can be
subsequently released from the sediment into the. surface-water column at
concentrations above the applicable criteria discussed in Section 8.4, interim
corrective measures and/or a CMS may also be required by the regulatory agency:
However, the owner or operator may attempt to show that constituents
within the sediment have not bioaccumulated or will not bioaccumulate. The
owner or operator may also attempt to show, through use of static or flow-through
testing (i.e., analysis of water or aquatic species following a period of contact with
the contaminated sediment) or through the use of chemical stability/volubility.
information, that sediment contaminants will not be released to the water column
in concentrations that would exceed the applicable criteria discussed in Section 8.4.
It should also be noted that EPA is working to establish numerical sediment
quality criteria that can be applied on a site-specific basis, depending primarily on
8-23
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the physical/chemical characteristics of the sediment (e.g., sediment organic carbon
content). The approach being investigated to assessing sediment contamination
examines the correspondence beween sediment contaminant concentration,
laboratory bioassay, and in situ assessments of biomass and species diversity.
Although these criteria are still in the developmentivalidation process, when issued,
they may be applied in the case of sediment contamination to determine whether
interim corrective measures and/or a CMS may be necessary. Contact the EPA
Criteria and Standards Division for additional information at (202) 475-7301.
8.6.3 Use of Statistical Procedures For Evaluating Ground-Water
Contamination
On October 11, 1988, EPA promulgated the final rule for Statistical Methods
for Evaluating Ground-Water Monitoring Data From Hazardous Waste Facilities (53
FR 39720). This rule, part of 40 CFR Part 264; Subpart F, requires ground-water
monitoring at permitted hazardous waste land disposal facilities to detect ground-
water contamination. This rule amends the requirement that the Cochran's
Approximation to the Behrens Fisher Student's t-test (CABF), be applied to ground-
water monitoring data to determine whether there is a statistically significant
exceedance of background or other allowable concentration levels of specified
chemical parameters. Concerns with the CABF procedure were brought to EPA's
attention, and after a review of comments on the procedure, EPA promulgated 5
different statistical methods that are more appropriate for the analysis of ground-
water monitoring data. These 5 methods are 1) Parametric analysis-of-variance,
2) Analysis-of-variance based on ranks, 3) Tolerance intervals, 4) Prediction intervals,
and 5) Control charts.
Analysis-of-variance models are used to analyze the effects of an independent
variable on a dependent variable. For ground-water monitoring data, a well or
group of wells is the independent variable, and the aqueous concentration of
certain, constituents or of a specified contaminant or contaminants is the dependent
variable. An analysis-of-variance can determine whether observed variations in
aqueous concentrations between different wells or groups of wells are statistically
significant. Use of analysis-of-variance models is appropriate in situations where
background concentrations for the specific constituent can be determined.
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Tolerance intervals define, with a specified probability, a range of valuesthat
contain a discrete percentage of the sample population. With ground-water
monitoring data, tolerance intervals can be constructed with concentrations from
the background well(s); these intervals are then expressed as an interval centered at
the mean background well concentration. Possible ground-water contamination is
indicated when concentrations, of the specified constituent(s) at the compliance
well(s) plot outside of the tolerance interval limits.
Prediction intervals are intervals in which the user is confident at a specified
percentage that the next observation will lie within the interval, and are based on
the number of previous observations, the number of new measurement to be made,
and the level of confidence that the user wishes to obtain. This method of statistical
analysis can be used in both detection and compliance monitoring programs. It is
useful in a detection monitoring program when constituent concentrations from
individual compliance wells are compared to one or more background wells. The
mean concentration and standard deviation are estimated from the background
well sample. In a compliance monitoring program, prediction intervals are
constructed from compliance well concentrations beginning when the facility
entered the compliance monitoring program. Each compliance well observation is
tested to determine if it lies within the prediction interval, and if it is greater than
the historical prediction limits, quality has deteriorated to such a point that further
action may be warranted.
Control charts are based on repeated random sampling done over various time
intervals from the population distribution of a given variable. Different statistical
measurements, such as the mean of replicate values at a point in time, are
computed and plotted together with upper and/or lower predetermined limits on a
chart whose x-axis represents time. When a data point plots outside these
boundaries, the process is "out of control", and when it plots within the boundaries
the process is "in control". Control charts can be used to analyze the inherent
statistical variation of ground-water monitoring data and to note aberrations.
Further investigation of out of control points is necessary before taking any direct
action. Control charts are. also used to evaluate ground-water monitoring data
when these data are adjustedand/or transformed as necessary. A control chart can
be constructed for each constituent in each well to monitor the concentration of
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that constituent over time. New samples can be compared to the historical data
from the welt to determine if the well is in or out of control.
The October 11, 1988 final rule (53 FR 39720) should be reviewed for further
information. In particular, the rule provides a glossary of some of the terminology
commonly used in the field of statistics, which may be particularly helpful. The EPA
Office of Solid Waste Land Disposal Branch may be contacted for further
information at (202) 382-4658.
8.7 Qualitative Assessment and Criteria
Qualitative criteria may also be used to assess the need for interim corrective
measures and/or a CMS. Qualitative criteria for interim corrective measures are
discussed in Section 8.8. Qalitative criteria for assessingthe need for conducting a
CMS are discussed below.
The regulatory agency may require that a CMS be performed even though
quantitative criteria (See Section 8.4) have-not been exceeded. Circumstances under
which such actions may be-appropriate include the following:
Presence of sensitive ecosystems or endangered species;
Data indicating that release concentrations may be increasing overtime;
Information inidicating that other contaminant sources may be
contributing to overall adverse exposure;
Information indicating that exposure routes other than those addressed
by quantitative criteria (e.g., dermal contact and phytotoxicity) are
Additional exposure as a result of normal use of a contaminated medium
(e.g., use of contaminated ground water or surface water for drinking'as
well as for washing, cooking, showering; watering the lawn, etc.).
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The above list of circumstances is not exhaustive. The regulatory agency may
identify other factors on a case-specific basis.
8.8 Interim Corrective Measures
If interim corrective measures are determined to be necessary, population
exposure should be prevented or minimized to the extent necessary and further
release migration should also be prevented or minimized. The process of
determining whether interim corrective measures should be taken, and the
selection and implementation of such measures is similar to removal actions that
may be taken under CERCLA (Superfund). In many cases, such action may be
relatively simple (e.g., removal of drums from the land surface with proper storage,
or disposal), while in other cases more extensive action may be necessary.
In evaluating whether interim corrective measures may be necessary the
regulatory agency will review pertinent information about the source and nature of
the release or potential threat of release. The regulatory agency will apply scientific
judgment in evaluating the potential threat to human health or the environment.
The decision to apply interim corrective measures will be made in consideration of
the immediacy and magnitude of the potential threat, the nature of appropriate
corrective action, and the implications of deferring corrective measures until the
RFI/CMS is completed. The following factors will be considered in determining the
need for interim corrective, measures:
Actual or potential exposure of nearby human populations or animals to
hazardous wastes or constituents;
Actual or potential contamination of drinking water supplies or sensitive
ecosystems;
Presence of hazardous wastes or constituents in drums, barrels, tanks, or
other bulk storage containers that may. poses threat of release;
Presence, of high concentrations of hazardous wastes or constituents in
soils largely at or near the, surface that may migrate readily to receptors,
or to which the public may be inadvertently or unknowingly exposed;
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Weather conditions that may cause hazardous wastes or constituents to
migrate or be released;
Threat of fire or explosion; and
Other situations or factors that may pose actual or imminent threats to
human health or the environment.
Exceedance of any of the criteria discussed in Section 8.4 does not necessarily
mean that interim corrective measures will be required. Although the regulatory
agency should be notified if 'health and environmental criteria are exceeded, the
overall circumstances will be considered by the regulatoy agency in determining
whether interim corrective measures should be applied. Notwithstanding this
process, the owner or operator has a continuing' responsibility to identify and
respond to emergency situations and to define priority situations that may warrant
interim corrective measures. For such situations, the owner or operator should
follow the RCRA Facility Contingency Plan as required under 40 CFR Part 264,
Subpart D and Part 265, Subpart D.
It should also be noted that the regulatory agency may apply health criteria
based on acute or subchronic effects, to the determination of the need for interim
corrective measures. For example, the EPA Office of Drinking Water has developed
drinking water health advisories for a number of compounds, which address acute
(1 day) and subchronic (10 day) exposures for both children and adults. A list of the
currently available drinking water health advisories is provided in Table 8-10.
Health advisory numbers may be periodically revised and can be found in IRIS. For
further information on health advisory numbers, call the EPA Office of Drinking
Water Hotline at (202) 382-5533 or 1-800-426-4791.
The regulatory agency will base the decision on the need to apply interim
corrective measures on a determination of the type and magnitude of the potential
hazard and an evaluation of the likelihood and effects of actual or potential human
or environmental exposures. For example, in the hypothetical case depicted in
Figure 8-1, initial measutements at the indicated sampling locations identified
constituent concentrations in excess of health and environmental criteria.
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Accordingly, the owner or operator notified the regulatory agency immediately.
The circumstances indicated that human population would be exposed to release
constituents before definitive corrective measures could be selected and
implemented. Therefore, immediate steps to address the hazard, were required of
the owner or operator. Examples of specific interim corrective measures are
provided in Table 8-4. For additional information see RCRA Corrective Action
Interim Measures (U.S. EPA, 1987).
To determine whether an actual or potential threat to human health or the
environment requires interim corrective measures, the regulatory agency will
consider such factors as receptor locations, and rate and extent of release
migration. Worksheet No. 3 in Section 8.10.2 presents a list of questions that the
regulatory agency may consider in making a determination.
The decision to apply interim corrective measures may involve estimates of the
rate of release migration and an assessment of potential human or environmental
receptors. Estimates of the rate of release migration will generally be based on
simple calculations, analytical models, or well-understood numerical models. For
example, the rate of contaminant migration in ground water is likely to be based on
time of travel (TOT) calculations or other simple methods for estimating rate.
Additional information on determining media-specific migration and the
characterization of exposed populations is provided in the Superfund Public Health
Evaluation. Manual (U.S. EPA, 1986) and the Draft Superfund Exposure Assessment
Manual .(U.S. EPA, 1987). In addition, information describing data requiremens for
exposure related measurements is expected to be published by the EPA Office of
Research and Development Exposure Assessment Group in the Federal Register in
late 1988 or aerly 1989.
As discussed above, the detemination of the type and magnitude of the
potential hazard posed by most contaminant releases will be accomplished as part
of the assessment, including the comparison of projected or actual exposure
concentrations to the health and environmental criteria, as described in Section 8.4,
However, the evaluation of subsurface releases of methane gas may pose a direct
explosion hazard as a result of a concentration build-up (e.g., in building structures).
Explosions of methane gas can occur at the Lower Explosive Limit (LEL) in the
presence of a heat source (e.g., a spark). EPA has promulgated criteria for explosive
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TABLE 8-4
EXAMPLES OF INTERIM CORRECTIVE MEASURES
SOILS
Sampling/Analysis/Disposal
Run-off/Run-on Control (Diversion or
Collection Devices)
« Temporary Cap/Cover
CONTAINERS
Overpack/Re-drum
Construct Storage Area/Move to Storage
Area
Segregation
Sampling and Analysis
Treatment, Storage and/or Disposal
Temporary Cover
GROUND WATER
Delineation/Verification of Gross
Contamination
Sampling and Analysis
Interceptor Trench/Sump/Subsurface Drain
» Pump and Treat
In-situ Treatment
Temporary Cap/Cover
TANKS
Overflow/Secondary Containment
Leak Detection/Repair/Partial or Complete
Removal
SURFACE WATER RELEASE (Point and Non-
Point)
Overflow/Underflow Darns
Filter Fences
Run-off/run-ori Control (Diversion or
Collection Devices)
Regrading/Revegetation ...
Sample and Analyze Surface Waters and
Sediments or Point SourcSDischarges
SURFACE IMPOUNDMENTS
Reduce Head
Remove Free Liquids and or Highly Mobile
Wastes .-",--
Stabilize/Repair Side Walls, Dikes or Liner(s)
Provi de Tern pora ry Cover
Run-off/Run-on Control (Diversion of
Collection Devices)
Sample and Analysis to Document the.
Concentration of Constituents Left in Place
When a Surface Impoundment Handling
Characteristic Wastes is Clean Closed
interim Ground-water Measures (See
Ground-water Section)
GAS MIGRATION CONTROL
Barriers/Collection/Treatment/Monitoring
Evacuation (Buildings) .-_
LANDFILL
Run-off/Run-on Control (Diversion or
Collection Devices)
Reduce Head on Liner and/or in Leachate
Collection System
Inspect Leachate Collection/Removal
System or French Drain
Repair Leachate Collection/Removal System
or French Drain
Temporary Cap
Waste Removal (See Soils Section)
Interim Ground-water Measures (See
Ground-water Section)
8-30
-------
TABLE 8-4 (continued)
EXAMPLES OF INTERIM CORRECTIVE MEASURES
PARTICULATE EMISSIONS
Truck Wash (Decontamination Unit)
Re-vegetation
Application of Dust Suppressant
WASTE PILE
Run-off/Run-on Control (Diversion to
Collection Devices)
Temporary Cover
Waste Removal (See Soil Section)
Interim Ground-Water Measures (See
Ground-water Section)
OTHER TYPES OF ACTIONS
Fencing to Prevent Direct Contact
t Extend Contamination Studies to Off-site
Areas if Permission is Obtained as Required
. Under Section $3.004(v)
Alternate Water Supply to Replace
Contaminated Drinking Water
Temporary Relocation of Exposed
Population
Temporary or Permanent, Injunction
t Suspend or Revoke Authorization to
Operate Under Interim Status
8-31
-------
gases under the RCRA, Subtitle D program in 40 CFR Part 257.3. These criteria state
that the concentration of explosive gases generated by the facility shall not exceed:
(1) 25 percent of the lower explosive limit (LEL) for the gases in facility structures,
and (2) the lower explosive limit for the gases at the property boundary. Where
these criteria are being approached or exceeded, interim corrective measures for
gas migration will generally be necessary.
8-9- References
U.S. EPA. 1986. Suoerfund Public Health Evaluation Manual. EPA/540-1-86-060.
NTIS PB87-183125. OSWER Directive No. 9285.4-1. Office of Emergency and
Remedial Response. Washington, D.C. 20460.
US. EPA. September 24, 1986. Guidelines for Carcinogen Risk Assessment. Federal
Register 51(185):33992-34003.
U.S. EPA. September 24, 1986. Guidelines for the Health Risk Assessment of
Chemical Mixtures. Federal Register 51 (185):34014-34025.
U.S. EPA. 1986. Test Methods for Evaluating Solid Wastes. EPA/SW-846.
GPO No. 955-001-00000.1. Office of Solid Waste. Washington, D.C. 24060,
U.S. EPA. 1986. Suoerfund Exposure Assessment Manual. Draft. Office of
Emergency and Remedial Response. Washington, D.C. 20460.
U.S. EPA. 1987. Data Quality Objectives for Remedial Response Activities: Volume 1
- Development Process, Volume 2: Example Scenario. EPA 540/G-87/003a.
OSWER Directive No. 9335.0-7B. Office of Emergency and Remedial Response
and Office of Waste Programs Enforcement. Washington, D.C. 20460.
U.S. EPA. 1987. Integrated Risk Information System (IRIS) Chemical Files. EPA/600/8-
86/032b. Office of Health and Environmental Assessment, Office of Research
and Development, Washington, D.C. 20460.
8-32
-------
U.S. EPA. 1987 Background Document, Resource Conservation and Recovery Act,
Subtitle C-ldentification and Listing of Hazardous Waste, Appendix A-Health
and Environmental Effects Documents. Office of Solid Waste. Washington,
D.C. 20460.
U.S. EPA. 1987. RCRA Corrective Action Interim Measures. Office of Solid Waste.
Washington, D.C. 20460.
8.10 Criteria Tables and Worksheets
This section presents both the health and environmental assessment criteria
tables and worksheets that the regulatory agency may use in conducting the health
and environmental assessment.
8.10.1 Criteria Tables
The following are the health and environmental assessment criteria tables
discussed in Section 8.4 and 8.8. Table 8-5 presents the Maximum Contaminant
Levels (MCLs) promulgated under the Safe Drinking Water Act. Table 8-6 presents
human health-based criteria for carcinogens (based on Risk-Specific Doses or RSDs).
Table 8-7. presents human health-based criteria for systemic toxicants (based on
Reference Doses or RfDs). Table 8-8 presents a summary of the EPA Water Quality
Criteria developed under the Clean Water Act. Table 8-8 identifies individual
constituents as well as groups of constituents (e.g., chlorinated benzenes). Table 8-
9 presents a list of all the individual constituents contained in the chemical groups
identified in Table 8-8. Table 8-10 presents drinking water health advisories
developed by EPA's Office of Drinking Water.
8-33
-------
Table 8-5
MAXIMUM CONTAMINANT LEVELS (MCLs) PROMULGATED UNDER THE
SAFE DRINKING WATER ACT*
Chemical
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chromium (hexavalent)
2,4-Dichlorophenoxy acetic acid
1 ,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichioroethyiene
Endrin
Fluoride
Lindane
Lead
Mercury
Methoxychlor
Nitrate
Selenium .
Silver
Toxaphene
1,1,1 -Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenoxy acetic acid
Vinyl chloride
CAS No.
7440-38-2
7440-39-3
71-343-2
7440-43-9
56-23-5
7440-47-3
94-75-7
106-46-7
107-06-2
75-35-4
72-20-8
58-89-9
7439-92-1
7439-97-6
72-43-5
;
7782-49-2
7440-22-4
8001-35-2
71-55-6
79-01-6
93-76-5
75-01-4
MCL (mg/l)
0.05
1.0
0.005
0.01
0.005
0.05
0.1
0.075
0.005
0.007
0.0002
4
0.004
0.05
0.002
0.1
10
0.01
0.05
0.005
0.2
0.005
0.01
0.002
These criteria are subject to change and will be confirmed by the
regulatory agency prior to use.
8-34
-------
Table 8-6. Health-Based Criteria for Carcinogens1
Constituent
Acrylamide4
Acrylbmtrile
Ald'nn
Aniline*
Arsenic4
Benz(a)anthracene4
Benzene4
Senzidme
8enzo(a)pyrene4
Beryllium4
Bis(2-chloroethyl)
ether
Bis(chloromethyl)
ether (BCME)4
Bis(2-ethylhexyl).
phthalate
Cadmium
Carbon tetrachloride
Crilordane
l-Chloro-2, 3-
epoxypropane
(Epichlorohydrm)
Chloroform
Chloromethyl
methyl ether4
(CMME)
Chromiurn
(hexavalent)
ODD
DDE
DDT
Dibenz(a.h)
anthracene4
1,2-Dibromo-3-
chlciropropane4
(DBCP)
CAS
. No. .
79-06-1
107-13-1
309-00-2
62-53-3
7440-38-2
56-55-3
71-43-2
92-87-5
50-32-8
7440-41-7
111-44-4
542-88-1
117-81-7
7440-43-9
56-23-5
57-74-9
106-89-3
67-66-3
107-30-2
7440-47-3
72-54-8
72-55-9
50-29-3
53-70-3
96-12-8
Class
(A,3,C)J
8
8
" B
C
A
3
A
A
3
8
B
A
B
B '
'B
B
8
3
A
A
B
B
8
3
B
Oral Exposure Route RSD^
CSF
(mg/kg/day)-1
3.85E+00
.5.4E-01
1.7E + 01
2.6E-02
- ,
3.T2E + 00
2.9E-02
2.3E + 02
1.15E+01
4.90 + 00
1.1E + 00
9.45E + 00
3.4E-03
1 .3E-01
1.3E*00
9.9E-03
6.1E-03
.9.4SE + 00
«
2.4E-01
3.4E-01
3.4E-01
4.90E + 01 .
2.21E+01
Soil
(mg/kg)
i1.82E-01
1.30E*00
4,16-02
2.7E + 02
-
2.24E-01
2.4E*01
30E-03
6.09E-02
1.43E-01
6.45^)1
7.41 E-02-
8.3E-.-01
** . .
5.46-cOO
5.4E-01
7.1E+01
1.16 + 02
7.41E-02
2.9E+00
2.1E+00
2.1E+00
1.43E-02
3.17i-02
Water
(ug/D
9.09E-03
6.5E-02
2.1E^03
1.3E + OV
See MCL
1.12E-02
See MCL
1.5E-04
3.04E-03
7.14E-03
3.2E-02
3.70E-03
4.2E+00
See MCL
See MCL
2.7E-02
3.5E.OO
5.7E+00
3.70E-03
See MCL .,
1.SE-01
. 1.0E-01-
1 OE-01
7.14E-04
1.58E-03
inhalation Exposure Route
RSDJ
CSF
(mg/kg/day)-1
3.85E + 00
2.4E-01
1.7E+01
2.S9E-02
1. 516+01
3.1 26 + 00
2.9E-02
2.3E+02
1.156 + 01
s:40E+oo
1.1E+00
9.45E+00
-?
7.8E+00
1.3E-01
13E + 00
4.3E-03
8.1E-02
9.45E + 00
4.1E + 01
-
. . .
3.4E-01
4.90E + 01
2.21E+01
Air
(Ug/m'J
9 09E-04
1 5E-02
2.1E-04
1.35E+00
2.32E-04
- 1.12E-03
1 2E-01
1.5E-05
3.04E-04
4.17E-04
3.2E-03
3.70E-04
4.5E-04
2 7E-02
2.7E.03,
.73E-01
4.3E-02
3.7QE-Q4
8.5E-05
1 OE-02 .
7.14E-05 .
" 1-58E-0.4
Note: These criteria are subject to change and will be confirmed by the regulatory agency
prior to use.
8-35
-------
Table 8-6. (continued)i
Constituent
1,2-Dibromoethane
Dibutylnitrosamme
1,2-DichJoroethane
1,1-DicWoroethylene
Dichloromethane
(Methylene chjonde)
1,3-Dichlorporopene
Dieldrm
Dietnylnitrosamine
Diethylstilbestroi4
(DES)
2,4-Oinitrotoluene
1,4-Dioxane
1.2-
Diphenylhydrazme
Ethylene oxide4
Heotachlor .
Heptacnlor epoxida
Hexa'chtorobenzene4
Hexachlorobuta-
diene
Hexachlorodibenzo-
p-dioxm'
Hexa'chioroethane
Hydrazine
Hydrazirre sulfate
Undane (gamma -
Hexachlorocyclo-
hexane)4-
3-Methyl
cholanthrene4
4,4-Methylene-bis-<2-
chloroanilme)4 .
Nickel4
Nickei (refinery OUST)
CAS ;
No. [,
106-93-1
924-16-3 -
107-06-2
75-35-4
75-09-2
542-75-6 ,
60-57-1 .
55-18-5-
.56-53-1 - .<.
,12.1-14-2 -
- 123-91-1
122-66-7
75-21-8 '-
76-44-8
'024-57-3
11 8-74-1
87-68-3
19408^74:3 '.
67-72-1
302-01-2
10034-93-2
58-89-9
56-49-S; r
101-14-4
1440-02-0
7440-0 Z-0
Class
(A.B.C)J
9 "
3
3
C
3'
B -
.-a-
3
A
«. B -'
3
B
3
g
I"
'" 3'
C
3
C
3
3 -
C
a
3
A
A
Oral Exposure Route
CSF
(mg/kg/day)''
--
5.40E + 00
9 1E-02
6.0E-01
7.5E-03
1 .86-01
1 6E-c01
1 SE^OZ
4.90E+02
3.08E-01
4 90E-03
8.0E-01
3.50E-01
4.5E*00
9.1 E* 00
1.72E*00
7.8E-02
6.2E*03
1 4E-02
: 3-OEt-OO
3,OE^OO
1 3E.-^00
9.45E*00
1.65E-01
-
«
Soil
(mg/kg-)
-
i 30E-01
77E*00
1 2E*01
93Er01
s.seiVbo
44E-02
4 66-03
"1. 43,6-03
2:27EiOO
1 43£*02
3.8E-01
2.006*- 00
1.6E-01
7.7E-02
4.07E-01
9.0E>01
1.16-04
5.0E-H02
2.3E-01
2.3E-01
5.4Ei-00
7.41 E-02
4.24E+00
*
»
RSD*
Water
(vg/i)
--
6.48E-03
See MCL
See MCL
4.7E*00
1 9E-01
2.2E-03
2.3E-04
7.14E-OS
1.14E-01
7.14E*00
4.4E^)2
1 OOE-01
7 8E-03
33E-03
2.03E-02
4.5E*00
5.6E-06
2.5E*01
. 1.2E-02
1 2E-02
Se« MCL
3.70E-03
2.12E-01
-
-
;nhaiation Exposure Route
RSD3
CSF
(mg/kg/day)-'
76E-01
S 4QE * 00
91 E-02
1 2E*00
1.-4E-02 ,
- ^ .
1 6E*01 '
1 3E*02
4.90E^02
-
a. 90E-03
8.0E-01
3.50E-01
4.5E*00
9. IE -00.
1.72E-02
78E-02
6.2E*03 ,
1.4E-02
.1.02E+01 -
-
1.-3E+00
9.45E+00
1 BSE.-OI
3.40E-01
3.4E-01
Air
(ug/'m3)
4.6E-03
6.48E-04
.38E-02
2.9E-02
2.5E-01
2.2E'-04
2.3E-OS
7 14E-06
1E-01
.714E-0.1
4.4E-03
i OOE-02
7 8.E.-04
3.8E-04
2.03E-01
4.5E-01
5.6E-07
2.5E*00
3.43E-04
-
2.7E-02
3.70E-0"4
-2.12E-02
4 17=-03
42E-03
Note: These criteria aresubject to change and will be confirmed by the regulatory agency
prior to use.
8-36
-------
Table 8-6. (continued)i
Constituent
Nickel subsulfide
2-Nitropropane4
N-Nitrosodi-
ethanolamine
ISi-fjitrosodimethyl -
amine (Dimethyl-
nitrosamme)
N-Nrtrosodi-N.
propylamme
N-Nitroso-N-
methyle.thylamme
N-Nitroso-N-methyl
urea4
N-Nitroso-
pyrrolidine
PCB.'s
Pentachloromtro-
benzene4
Perchloroethylene
(Tetrachloro-
ethylene)
Pronamide(Kerb)4
Rissrpins4
Styrene
1,1,2,2- .
Tetrachloroethane
Thiou.rea4
Toxaphene
1,1,2- .
Tnchloroetnane
Tnchloroethyi«n»
2,4,6-
Tncnlorophenol
CAS
No. ;
12035-72,2
79-46-9
1116-54-7,
: 62-75-9
62.1-64-7
10595-95-6
684-93-5
930-55-2
1336-36-2
32-68-8
. 127-18-4
.23950-58-5
50-55=5
100-42-5
79-34-5
62-56-6
8001-35-2
79-00-5
79-01-6
88-06-2
. Class
(A, s; qi
A
a, -
a
s
:;3
' ,"B'
a
a "
B
c
c
c
3
8
C
a
a
c
3
8
Oral Exposure Route RSD^
CSF
(mg/kg/day)-'
- -
9.45E + 00
2.8E+00
5.1£+01
7.0E-S-00
2.2E + 01
3.01E+02
2.16 + 00
7.7E + 00
2.56E-01
5.1E-02
-
LOSE* 01
3.0E-02
2.00E-01
1. 936 + 00
1.1E+00
5.7E-02
1.1E-02
2 OE-02
Soil
(mg/kg)
--
7.41 E-02
2:5E-01
1.4E-02 -
I.OE^DI
3.2E-02
2.33E-03
3.3E-01
9.1E-02
2.73E+01
1.4E+02
.-
S.S7i^32
2.3E+01
3.50E+01
3.63E-01
6.4E-01
1.2E + 02
6.4E + 01
3.5E+01
Water
.(vg'D
3.70E^03
1.3E-02
; 6.9E-04
5.0E-03
1.6E-03
1.16E-04.,
1.7E-02
4.SE-03
1.37E + 00
6.9E+00
..
3.33E-03
1.2E+00
1.75E+00
5.186-02
SecMCL
6.1E+00
See MCL
1.3E+00
inhalation Exposure Route
RSD3
CSF'
(mg/kg/day)-'
1.7E+00
945E+00
5.1E + 01 '
. =
3,01 E +02
2-IEi-OO
-
2.56E-01
2.5E-01
-
LOSE +01
2..QE-03
2.00E-01
1 93E+00
1.1E+00
5.7E-02
1 3E-02
2.0E-02
Air "
(Ug/m3)
2.1E-03
3 70E-04
6.9E-05 ,
,,- -
. -
1.16E-05
1.7E-03
-' ' ,
1,37E-01
1.4E-01
2E * 00
3.33S-OA
1 .8E + 00
1..75E-01
S.lSE-ftS
3 2E;03; ,
_6..1E:01,'
2.7E-01
1.8E-01 -
1 These criteria are subject to change and will be confirmed by the regulatory agency prior
to use. ' , ..;
2 The EPA Carcinogen Classification system is discussed in 51 FR 33992-34003 (Guidelines for
Carcinogen Risk Assessment)
3 See Table 8-2 for the appropriate intake assumptions used to derive these criteria.
I Indicates criteria undergoing EPA review.
-------
Table 8-7. Health-Based Criteria for Systemic Toxicants1
Constituent
Acetone
Acetonitnle
Acetophenone .
Aldicarb
Aldrm
fcllyl alcohot
Aluminum phosphide
Antimony
Janum
Jarium cyanide
?enzidine
Beryllium
Bis(2-ethylhexyl)
phthalate
Jromodichloromethane
Jromoform
Jromomethane
Calcium cyanide
Carbon disulfidc
Carbon tetrachlonde
Chlordane
Chlorine cyanide
Chlorobenzene
1-ChlorO-2,3,
epoxypropane
EpichTbrbhydrin)
Chloroform".
Chromium (III)
Chromium (VI)
Copper cyanide
Cresols .
Crotonaldehyd*
Cyanide
Cyanogen
2,4-0
)DT
>i-n-butylphthalate
CAS ...
NO.
67-64-1
75-05-8 i .
98-86:2 !; ,
116-06-3- ,
309rOO-2.
107-18-6
20859-73-3
7440-36-0
7440-39-3 .
542-62-1
92-87-5
7440-41-7
117-81-7
75-27-4
75-25:2
74-83-9
592-0 1:-8
75-154
56-23:5
57-74-9
.506-77-4
108-90-7
106-89-8
67-66-3
16065-83-1
7440-47-3
544-92-3
1319-77-3
123-73-9
.. ,
460-1 9-5 :
94-75-7
50-29-3 ,
84-74-2
RtD2
(mg/kg/day)
1E-01 .
6E-03
1E-01
1 E-03
3E-05
5E-03
4E-04
4E-04
5E-02
7E-02
2E-03
5E-03
2E-02
2E-02
2E-02
4E-04
. ... 4E-02
1E-01
76-04
5E-05
5E-02
3E-02
2E-03
1E-02
IE ( 00
56-03
5E-03
5E-02
... 1E-02
2E-02
4E-02
1E-02 :
. 5E-04
1E-01
Soil
(mg/kg)
ae + 03
5E+02
8"6>03
SE+01
2E +00
4E+02
3E*01
3E+01
4E+03
6E*03
2E^02
4Ei-02
2E-c03
2E + 03
2E*03
. 3E+01
3£t03
BE + 03
6E*OV
4E+00
4E+03
2E + 03
2E+02
3E+02
3E>04
4E*02
4E +02
4E+03
3Et-02
2E>03;
SE-t-03
aeVo2
. 46*01
8E+03
Water
(ug/D
4E*03
2E+02
4E+03
4E+01
1E+00
2E+02
1E+01
1E + 01
See MCL
2E*03
7E+01
2E+02
7E + 02
7E*02
7E-I-02
1E+01 .
16*03
4E + 03
See MCL
2E+00
2E+03
. 1E+03
7E + 01
4E+02
4E+04
See MCL
2E + 02
2E + 03
4E+02
7E+02
1E + 03
See MCL
2E-t-01
4E + 0
Air
(ug/m3)
--
-.
-
5E + 00
-
-
--
-
-
-
.
-
7E+01
-
- . -
- .'
-
-
-
-
: ~. .'
"
- ...
--
-
- .
.
r.
-
-
-
Note: These criteria are subject to change and will be confirmed by the regulatory agency prior
to use.
-------
Table 8-7.
Constituent
Dichlorodifluoro-
nn ethane
1,1-Dichloroethylene
Dichloromethane
.(Methylene chloride)
2,4-Oichlorophenol
1,3-Dichloropropene
Dieldrin
Oiethyl phthalate
Dimethoate
2,4-Oimtrophenol
Dinoseb
Diphenylamme
Disulfoton
Ertdosulfan
Endothal
Endrm
Ethylbenzene
Heptachlor
Heptachlor epoxide
Hexachlorobuta-
diene
nexaehloracycio-
pentadiene
Hexachloroethane
Hydrogen cyanide
Hydrogen'sulfide
Isobutyl alcohol
isophorone
Lindane(hexa-
chlorocydohexana)
Maleic hydrazide
Methacrylonitrile
Methomyl
Methyl ethyl ketone
Methyl isobutyl-
ketone
CAS
No.
7S-71-8
75-35-4
75-09-2
120-83-2
26952-23-3
60-57-1
34-66-2
60-5 1-S
51-28-5
38-85-7
127-39-4
29S-04-4
115-29-7
14S-73-3
72-20-8
100-41-4
76-44-8
1024-57-8
87-68-3
77-47-4
67-72-1
74-90-3
7783-06-4
78-83-1
78-59-1
58-89-9
108-31-6
126-98-7
16752-77-5
78-93-3
108-10-01
RfD2
(mg/kg/day)
26-01
. 9E-03
6E-02
3E-03
.3E-04
5E-05
8E-01
2E-02
2E-03
IE -03
3E-02
.4E-05
5E-05
2E-02
36-04
1E-01
SE-04
. 1E-OS
2E-03
7E-03
1 E-03
2E-02
3E-03
3E-01
2E-01
3E-04
5E-01
1E-04
3E-02
SE-02
5£-02
Soil
(mg/kg)
2E*04
7E+02
5E*03
2E*02
26+01
4E +-00
6E+04
2E+03
26 + 02
8E+01
2E+tf3
3E + 00
46+00
2E + 03
26+01
86+03
46+01
3E-01
26+02
6E + 02
86+01
2E+03
26+02
2E+04
26 + 04
2E + 01
4E+04
86+00
2E+03
4E+03
46+03
Water
.(pg/i)
7E+03
SeeMCL ....
2E + 03
1E+02 = -
1E + 01
2E+00
3E+04
-7E+02 .
7E+01
4E + 01
, 1E+03
1 E + 00
2E + 00
7E + 02
SeeMCL
4E +03
2E+01
4E-01
7E+01
2E + 02
4E + 01
7E + 02
1E + 02
1E + 04
7E +.03
See MCL
2E+04
4E + 00
1E+03
2E + 03
2E+03
Air
(yg/m3)
-
-
-
1E+01 "
-- '.
-
-- "
.- '
7E + 00
-
-
2E-01
-
1E + 00
- ' : ",.'
-
»
-
- -
. -
-
' "
1E+03
-
-
'
~
--
-
-
Note: These criteria are subject to change and
to use.
be confirmed by the regulatory agency prior
8-39
-------
Table 8-7. (continued)1
Constituent
Methyl mercury
Methyl- parathion
Nickel
Nitric oxide
Nitrobenzene
Nitrogen dioxide
Octamethylpyro-
phdsphoramide
Parathion '
Pentachlorobenrene
Pentacnloronitro-
benzene
Pentacnlorophenol
Perchloroethylene
(Tetrachlo*o-
ethylen*)
Phenol
Phenyl mercuric
acetate
PhoJphme
Potassium cyanide
Potassium silver
cyanide
Pronamide(Kerb)
Pyndine
SelentousAcid
Selenourea
Silver-
Silver cyanide
Silvex(2,4,5-TP)
Sodium cyanide
Strychnine
Styrene
1,2,4,5-
Tetrachrorob«nifn«
CAS
No.
22967-92-6
298-00-6
7440-02-0
"10102-43-9
98-95-3
10102-44-0
152-16-9
56-38-2
608-93-5;
82-68-8
87-86-5
127-18-4'
108-95-2
62-38-4
7803-51-2
1.51-50-8
506-61-6
23950-58-S
110-86-1 -
7782-49-2
630-10-4
7440-22-4
506-64-9
93-72-1
143-33-9
57-24-9
100-42-5
95-94-3
RfD2
(mg/kg/day)
: 3E-04
. 3E-04
2E-02
1E-01
5E-04
IE 1-00
-2E-03
3E-04
8E-04
3E-03
3E-Q2
1E-02
4E-02
8E-05
3E-04
5E-02
2E-01
8E-02
1E-03
3E-03
5E-03
3E-03
1E-01
8E-03
46-02
. 3E-04 .
2E-01
3 £-04
Soil
(mg/kg)
' 2E + 01
2E+01
2E*03
SE^-03
4E*01
8E*04
2E + 02
2E*01
6E+01
2E*02.
2£+03
' ,8Et02
3| -f 03 -
;6E/fOO
2E+01
46 * 03
2E + 04
5E+-03
86*01
2E>02
46 + 02
26+02
86 +03
6E + 02
3E+03
2Ef01
2E*04
2E-I-01
Water
(ug/D .
. 1E+01
1E + 01
7E+02
4E+03
2E+01
4E+04
7E+01
1E + 01-
3E+01. ..
. 1E+02
1E-c03
4E+02
1E+-03
3E+00
1E+01
2E + 03
7E + 03
3E + 03
4E+01
See MCL
2E + 02 :
See MCL
4E+03
3E + 02
1E+03
1E+01 -
7E+03
' IE +01 ' "
Air
. . (ug/m3j
-- -
1E+00 .
- ., -
"
-
-
. .
3E+00-
-
1E+02
""
-
-
-- -
-
-
- -
-
- .'
-
-
-
.. -- -
.
IE +00
Note: These criteria are subject to change and will be confirmed by the regulatory agency
prior to use. -
8-40
-------
Table 8-7. (continued)1
Constituent
2,3,4,6-
Tetrachlorophenol
Tetraethyl lead
Thallic oxide
Thallium acetate
Thallium carbonate
Thallium chloride
Thallium nitrate
Thallium selemte
Thallium.sulfate
Thiram,. .
Toluene
1.2>4-
Trichlorobenzene
1,1,1-
Trichloroethane .
'1,1.2-
Tnchloroethane
Trichloromono-
fluoromethane
2.4,5-
Tnchiorophenol
2,4,5-Tnchloro-
phenoxy acetic acid
(2.4,5-T)
1.1V2-
Trichloropropane
1,2,3-
Trichloropropane
Vanadium
peotoxide
Warfarin
Xylenc (total)
Zinc 'cyanide
Zinc phosphide
CAS
No.
58-90-2
78-00-2
1314-32-5
563-63-8
6533-73-9
7791-12-0
10102-45-1
12039-52-0
10031-59-1
137-26-8
108-88-3
120-82-1
71-55-6
79-00-5
75-69-4
95-95-4
93-76-5
598-77-6
96-18-4
1314-62-1
81-81-2
1330-20-7
557-21-1
1314-84-7
RfD2
(mg/kg/day)
3E-02
li-07
4E-04
5E-04
4E-Q4
46-04
5E-04
5E-04
3E-04
5E-03
3E-01
2E-02
9E-02
2E-01
3E-01
, 1E-01
3E-03
SE-03
1E-03
2E-02
3E-04
2E+00
5E-02
3E-04
Soil
(mg/kg)
2E + 03
8E-03 .
3E-*-01
4E-ci01
3E+01
3E+01
4E+01
4E + 01
25-t-OI
4E4-02
2E*04
2E-I-03
7E*03
2E + 04
2E*04
3E + 03
2E-I-02
4E*02
8E*01
2E+03
2E + 01
2E*05
4E*03
2E*01
Water
(yg/i)
IE +.03
4E-03
l£*01
26 + 01
16+01
1E+01
2E + 01
2E+01
. 1E + 01
2E+02
1E + 04
76+02
SeeMCL
76 + 03
1 E + 04.
4E + 03
SeeMCL
2E + 02
4E + 01
76+02
16 + 01,.
76, + 04
26+03
15 + 01
Air
(ug/m3)
1E+02
4E-04
-
-
- -
-' " '
',
-
--
-
-
-
_[ '
-
4E + 02
"
-
-
-
- . .
- - . . ,
...
--
1 These criteria are subject to change and will be confirmed by the regulatory agency prior to
use.
See Table 8-2 for the appropriate intake assumptions used to derive these criteria.
8-41
-------
Table 8-8. Water Quality Criteria Summary1
Chemical
Acenapthene "
Acrolein
Acrylonitrile
Aldrin
Alkalinity"
Ammonia211
Antimony
Arsenic
Arsenic (PENT)
Arsenic (TRI)
Asbestos "
Bacteria3-11
Barium
Benzene
Benzidine
Beryillium
BHC
Cadmium
Carbon
tetrachloride
Chlordane
Chlorindated
Benzenes
Chlorinated
Naphthalenes
Chlorine11
Chloroalkyl Ethers"
WATER
CONCENTRATIONS IN ug/L
FOR AQUATIC LIFE
Fresh
Acute
Criteria
1700'
68B
7,550B
3.0
9.000°
850°
360
5,300B
2,500s
1308
1000
3.97
35,200°
2 . 4
250°
1 ,600°
19
238,000°
Fresh
Chronic
Criteria
520°
218
2,600°
20,000
1 .600°
488
190
5.38>
1.17
0.0043
50°
11
Marine
Acute
Criteria
970'
55°
1.3
2,319s
69
5,100°
0.34°
43
50,000°
0.09
160°
7.5°
13
Marine -
Chronic
Criteria
7 1 O8
1 38
36
700°
9.3
0.004'
1 2 98
7.5
'WATER CONCENTRATIONS IN
UNITS PER LITER
FOR HUMAN EXPOSURE
Water
and
Fish
Ingestlon
320ug
0.058|jg
0.074ng9
146|jg
2.2ng8
30k f/L8
1mg
0.66ug9
0.12ng8
6.8ng9
10|jg
0.4ug9
0.46ng8
488|jg
Fish
Consumption
Only
780 |jg
0.65|jg8
0.079ng"
45,000ug
17.5ng9
4 Dug9
0.53ng8
117ng8
6.94ug9
0.48ng9
Date
Reference
1980FR
1980FR
1980FR
1980FR
1976RB
1985FR
1980FR
1980FR
1985FR
1985FR
1960FR
1966FR
1976RB
1980FR
1980FR
1980FR
1980FR
1985FR
1980FR
1980FR
1980FR
1980FR
1985FR
1980FR
Note: These criteria are subject to change and will be confirmed by the regulatory agency-prior to
use.
8-42
-------
Table 8-.8. (continued) 1
Chemical
Chloroethyl ether
(BIS-2).
Chloroform
Chlorolsopropyl
ether (BIS-2)11
Chloromethyl ether
(BIS)
Chlorophenol 2"
Chlorophenol 4
Chlorophenoxy
Herbicides (2,4,5-TP)
Chlorophenoxy
Herbicides (2,4,-D)
Chlorpyrifos "
Chloro-4 methyl-3
phenol
Chromium (HEX)
Chromium(TRI)
Color411
Copper"
Cyanide
DDT
DDT Metabolite
(DDE)
DDT Metabolite
(TOE)
Demeton"
Dibutylphthalate
Dichlorobenzenes
Dichlorobenzidine
WATER
CONCENTRATIONS IN ug/L
FOR AQUATIC LIFE
Fresh
Acute
Criteria
2 8 , 9 C
4,380s
0.083
308
1.6
1,700'
187
22
1.1
1 ,050s
0.06s
1,120°
Fresh
Chronic
Criteria
O8 1 , 2 4 0
2 , 0 0 O8
0.041
1.1
2 1 O7
1 27
5.2
0.001
0.1
7 6 3s
Marine
Acute
Criteria.
29,700°
0.011
1,100
10,300s
2.9
1
0.13
1 4s
3,a«
1,970s
Marine
Chronic
Criteria
0.0056
50
2.9
1
0.001
0.1
WATER CONCENTRATIONS IN
UNITS PER LITER
FOR HUMAN EXPOSURE
O.OSug9
0.19ug'
34.7|jg
0.00000376
ng9
1 Dug
100^ig
50|jg
170mg
200ug
0.024ug9
35mg
400|jg
0.01 ug9
. Date
Reference
1980FR
15.7ug9 1980FR
4.36mg
0.00184|jg8
3,433mg
0.024ng9
154mg
2.6mg
0.020|jg8
1980FR
1980FR
1980FR
1980FR
1980FR
1976FR
1986FR
1980FR
1985FR
1985FR
1976RB
1985FR
1 985FR
1980FR
1980FR
1980FR
1976RB
1980FR
1980FR
1980FR
Note: These criteria are subject to change and will be confirmed by the regulatory agency prior to
use.
8-43
-------
Table 8-8. (continued)1
Chemical
Sichloroethane 1,2
Jichioroetnylenes
Jichlorophenol 2,4 .
Jichloropropane
Jichloropropene
Jieldrin
Jiethylphthalate
JimethyJ phenol 2,4 -
5imethyi phtnaiate
)imtrotoluene 2,4
Jmitrotoluene
Dmitrotoluene
>mitro-o-Cresol 2,4
Jtoxm (2,3.7,8-TCDD)
Jiphenylhydrazine
>iphenylhydrazine
1,2
Di-2-ethy! hexyl
>hthalat»
Indosulfan ---'
ndrm
Ithylbenzene'1
'liioranthene
Gases, Total4-'1
)issolved
Guthion11 .
WATER
CONCENTRATIONS IN ug/L
FOR AQUATIC LIFE
Fresh
Acute
Criteria
118,000»
1 1 ,600"
2,020«
23,000»
, S,060« ,
2.5
2,120« '
330»
0.018
2708
0.22
0.18
32.000"
3,9808
;
Fresh
Chronic
Criteria
20,000«
365>
S,700»
-244»
0.0013
230"
0.000018
|n
'-'
o;ose
0.0023
0.01
Marine
Acute
Criteria
113,0008
224.0008
10,3008
7908
0.71
5908
i .
. . -
0.034
0037
4308
40s
Marine
Chronic
Criteria
. , -.,-.,-.
3,040»
.. - - 1
0019 ,
3708
-, ,'- .- )
'
t
00087
0.0023
- -1
r is*
0.01
WATER.CONCENTRATIONS IN
UNITS PiR LITER
FOR HUMAN EXPOSURE
Water
and
Fish
Ingest! on
0,94Ug9
0.033yg»
3.Q9mg
87yg
0.071 ng<»
350mg
313mg
0.1 lUg9
70yg
I3.4yg
0.000013
ngS
42ng»
ISmg.
7dug
lug
1.4mg
42ug
Fish
Consumption
Only
2.43ug9
' "i 85yg9
I4.lmg
0.076ng9 .
Log
2-99
9.i-wg»
14,3yg
76SU9
0.0000 14ng9 \
0.56ugS
50mg
7'AVi
3.28mg
54Ug
-
Date
Reference
19SOFR
1980F3
1980FS
1980FR
1980FR
...1980FR
, 1.980FR
'. .19.80F-R
1980FR
1980FR
. 1980FR
1980FR
1980FR
19841=R .
. 1 980FR
1980FR
1980FR
1980f.R
1980FR
- ' 1980FR
1980FR
1.976RB
197SR8
Note: "These criteria are subject to change and will be confirmed by the regulatory agency priorto
use
8-44
-------
Table 8-8. (continued)1
Chemical
Haloether*
Halom ethanes
Heptachlpr -
Hexachlproethane
Hexachlorobenzene
Hexachloro-
butadiene
Hexachlorocyclo-
hexane(Undane)
Hexachlorocyclo-
hexane-Alpha"
Hexacnlorocydo-
hexan.e-Beta1?
Hexachlorocyclo-
nexane-Gamma"
Hexachlorocyclo-
hexane-Techmcal"
Hexachlorocydo-
pentadme
Iran1" '
Isophorone"
Lead
Malatnion ' '
Manganese11
Mercury
Mcthoxychlor
Mi rex"
Monochloco
benzene
Naphthalene
Nickel - -
WATER
CONCENTRATIONS IN ugL
FOR AQUATIC LIFE
Fresh
Acute
Criteria
360«
11,000*
. 0,52
960«
90«
2.0
78
117.000*
327
2.4
2.300*
1,4007
Fresh
Chronic
Criteria
122*
0.0038
540»
9.38
0.03
5.2«
1.000
3.27
0-1
0.012
0.03
0.001
620«
1607
Marine
Acute
Criteria
12,0008
0.053
94^8
32«
0.16
7»
1,2,900»
140
2.1
2.350*
75
Marine
Chronic
Criteria
8,4008
0.0036
S.6
0:1 '
0.025
0.03
0.001
3.3
WATER CONCENTRATIONS IN
, UNITS PER LITER
FOR HUMAN EXPOSURE
Water
and
Fish
Ingestion
0.19Ug«
0.28ng3
i.9ug
0.72ng9
0.45Ug'
9.2ng9
16.3ng»
18.6ng»
12.3ng9
206ug
0.3mg
5.2'mg
SOU9
. . ,
I S0]ig
144ng
lOOug
488Ug
, 13.4ug.
Fish
Consumption
Only
1 15.7yg9
0"29ng9
8.74yg
0.74ng9
50ug«
31ng?
.54.7n'g9
62.5ng9
4l,4ng»
,520mg
lOOug
146ng
lOOug
Date ,
Reference
1980.FR
1.980.PR .
1980FR :
1980FR
1980FR "
1980FR -
1980FR
198.0FR
1980FR -
1980FR ;,-
1980FR- "
1980FR
1976RB -'
1980FR :
1985FR
1976R8 .
1976R3 "
1985F.R, ;;..,.
1976RB, .'..'.
1976RB
1980FR.
1980FR
1986FR-1 -'
Note: These criteria are subject to change and will be confirmed by the regulatory agency prior to
use.
8-45
-------
Table 8-8. (continued)1
Chemical
Nitrobenzene
Nitrophenols
Nitrosamines
Nitrosodibutyl-
ammeN
Nitrosodretnyl-
ammeN
Nitrosodimethyl-
armneN
Nitrosodipnenyl-
ammeiN
Nitrosopyrrolidme N
Oil and Grease*- "
Oxygen Dissolved5-"
Parathion
PCB's
Penta.c.hlormated,
Ethanes
PfntaCniOfQ-,
benzene.
Pentaehloropheno!
pH'l
Phenol .
Phosphorus
Elemental'1
Phthalate Esters
Polynuciear
Aromatic
Hydrocarbons
Selenium
Silver
WATER
CONCENTRATIONS IN ugA
FOR AQUATIC LIFE
Fresh
Acute
Criteria
27,0008
230»
5,6SO«
0.065 ,
2.0
7,240*
20'"
10,200*
940*
260
4.1' '
Fresh
Chronic
Criteria
1508
....
0.0-13 -
0.014
T;lOp8
, ,,-13'o
6.5-9
2,560* ,
. ''
3«
;
,' 35
0 12
Marine
Acute
Criteria.
6,6808
4850«
3,300,0008
10
390«
.
13"
. 5,800»
2,9448 .
3008
410
2.3
Marine
Chronic
Criteria
0.03
231*
7.9* '
6.5-8.5
0.1
3.4*. ,,.
54
WATER CONCENTRATIONS IN
UNITS PER LITER
; FOR HUMAN EXPOSURE
Water
and
Fish
Ingestion
- 198mg
0.8ng9
- 6.4ng9
0.8ng»
1.4ng»
4.900ngi
1Sng9
I
0.079ng9
74g
I.OImg
3.'Smg
2.8ng9
10U9
SOyg
. Fish
Consumption
Only
1 240ng9 '
587ng9
1,240ng»
I6,000ng'
I6,100ng9
91.90iOng9
0.079ng9
S5Ug
31.1ng9
Date
Reference
1980FR
1980FR
. 1980FR
1 980FR
198.0FR
1980FR
1980FR
1980FR
1976RB
1986FR
1986FR
1980FR
1980FR
19SOFR
1966FR
1976RB
1980FR
1976R8
1980FR
1980FR ;
1980FR
1980FR
Note: These criteria are subject to change and will be confirmed by the regulatory agency prior to
use.
8-46
-------
Table 8-8. (continued)1
Chemical
Solids Dissolved arid
Salinity
Solids Suspended
and Turbidity41
Sulfide-Hydrogen
Sulfide
Temperature611
Tetrachlorinated
Ethanes
Tetrachloro-
benzene 1.2.4.5
Tetrachloroethane
1,1,2,2
Tetrachloroethanes
Tetrachloro-
ethylene
Tetrachlorophenol
2,3,5,6
Thallium
Toluene
Toxaphene
Trichlorinated
Ethanes
Trichloroethane
1,1,1
Trichloroethane
1,1,2
Trichloroethylene
Trichlorophenol
2,4,5
Trichlorophenol
2,4,6
Vinyl Chloride
Zinc"
WATER
CONCENTRATIONS IN ug/L
FOR AQUATIC LIFE
Fresh
Acute
Criteria
9,320s
9,320«
5,28
1,400s
17.50.08
0.73
1 8,0008
45,000'
1207
Fresh
Chronic
Criteria
2
2,400B
I8 8 4 O8
4Q8
0.0002
9.4008
21,900s
970°
110'
Marine
Acute
Criteria
9,020s
10,200°
2,130s
6,300s
0.21
31,200s
2,000s
95
Marine
Chronic
Criteria
2
450s
44Q8
5,000s
0.0002
86
WATER CONCENTRATIONS IN
UNITS PER LITER
FOR HUMAN EXPOSURE
Water
and Fish
Fish Consumption
Ingestion Only
250mg
38ug
0.17ug '
0.8ug9
13|jg I
14.3mg,
0.71 ngs
18.4mg
0.6ug9
2.7U99
2.600pq
1.2^g8
2ug9
48Ug
10.7ug 9
8.85|jgs
48vg
424mg
0.73ng8
1.03g
41.8|jgs
80.7ug'
3.6ug9
525ug8
Date
Reference
1976RB
1976RB
1976RB
1976RB
1980FR
1980FR
1980FR
1980FR
1980FR
1980FR
1980FR
1980FR
1986FR
1980FR
1980FR
1980FR
1980FR
1980FR
1980FR
1980FR
1987FR
Note: These criteria are subject to change and will be confirmed by the regulatory agency prior to
use.
8-47
-------
Footnotes for Table 8-8:
1 This table is for general information purposes only; see criteria documents or
detailed summaries in Quality Criteria for Water 1986 for more information.
These criteria are subject to change and will be confirmed by the regulatory
agency prior to use.
2 Criteria are pH and temperature dependent - See Document (1)
3 For primary recreation and shellfish uses - See Document (1)
4 Narrative statement - See Document (1)
5 Warmwater and cold-water criteria matrix - See Document (1)
6 Species dependent criteria - See Document (1)
7 Hardness Dependent Criteria (100 mg/l used)
8 Insufficient data to develop criteria. Value presented is lowest observed
effect level.
9 Human health criteria for carcinogens reported for three risk levels. Value
presented in this table is the 10"6risk level.
10 pH dependent criteria - 7.8 pH used.
11 Indicates chemical or parameter not on Appendix VIII. The regulatory
agency will exercise discretion prior to requiring such chemicals or
parameters to be monitored during the RFI.
General - g = grams FR = Federal Register
mg = milligrams RB= Quality Criteria for
u g = micrograms Water, 1976
ng = nanograms
f = fibers
8-48
-------
Table 8-9. Individual. Listing of Constituents Contained Within
Chemical Groups Identified in Table 8-8
Chemical Group.
Chlorinated Benzenes
Chlorinated Ethanes
Chloroalkyl Ethers
Chlorinated Naphthalene
Chlorinated Phenols
Dichlorobenzenes
Dichlorobenzidine
Dichloroethylenes
Dichloropropane and
Dichloropropene
Dinitrotoluene
Haloethers
Halomethanes
Individual Constituents
Chlorobenzene
1 ,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
Hexachloroethane,
1,1-Dichloroethane
1 ,1 ,2-Trichloroethane
Chloroethane
Bis(chloromethyl) ether
Bis(2-chloroethyl ether
2-Chloroethyl vinyl ether (mixed)
2-Chloronaphthalene
2,4,5-Trichlorophenol
Parachlorometa cresol
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
3,3'-Dichlorobenzidine
1,1-Dichloroethylene
1 ,2-Trans-dichloroethylene
1,2-Dichloropropane
1 ,2-Dichloropropylene(1 ,3-dichloropropene)
2,4-Dinitrotoluene
2,5-Dinitrotoluene
4-Chlorophenyl phenyl ether
4-Bromophenyl phenyl ether
Bis(2-chloroisopropyl)ether
Bis(2-chloroethoxy)methane
Methylene chloride (dichloromethane)
Methyl chloride (chloromethane)
Methyl bromide (bromomethane)
Bromoform (tribromomethane)
Dichlorobromomethane
Trichlorofluoromethane
Dichlorodifluoromethane
Chlorodibromomethane
8-49
-------
Table 8-9. (Continued)
Chemical Group
Nitrophenols
Nitrosamines
Phthalate Esters
Polynuclear Aromatic Hydrocarbons
Endosulfan and Metabolites
Endrin and Metabolites
Heptachlor and Metabolites
Polychlorinated Biphenyls
individual Constituents
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
4,6-Dinitro-o-cresol
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosodi-n-propylamine
Bis (2-ethylhexyl) phthalate
Butyl benzyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(a) anthracene (1 ,2-benzanthracene)
Benzo(a) pyrene
3,4-Benzofluoranthene
Benzo(k) fluoranthene(1 1 ,12-benzofluoranthene)
Chrysene
Acenaphthylene
Anthracene
Benzo(ghi)Perylene (1 ,12-benzoperylene)
Fluorene
Phenanthrene
Dibenzo(a,h)anthracene (1 ,2,5,6-dibenzanthracene)-
Indeno (1,2,3-cd) pyrene
Pyrene
a-Endosulfan-Alpha
p-Endosulfan-Beta
Endosulfan sulfate
Endrin
Heptachlor
Heptachlor epoxide
PCB-1242(Arochlor 1242)
PCB-1254 (Arochlor 1254)
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB-1248 (Arochlor 1248)
PCB-1260 (Arochlor 1260)
PCB-1 01 6 (Arochlor 101 6)
8-50
-------
4/5/89
Table 8-10
DRINKING WATEF STANDARDS AND HEALTH ADVISORIES
** DRAFT
page 1
Chemicals
O r g a n i c s
Acenaphthylene
Acif I u o rf e n
Acrylamide
Acrylonitrile
Adipates
Alachlor
Aldicarb
Aldicarb sulfone
Aldicarb sulfoxide
Ametryn
Ammonia
Ammonium Sulfamate
Anthracene
Atrazine
Baygon
Bentazon
Benz(a)anthracene (PAH)
Benzene
Benzo(a)pyrene (PAH)
Benzo(b)fluoranthene (PAH)
Benzo(g,h,i)perylene (PAH)
Benzo(k)fluoranthene (PAH)
bis-2-Chloroisopropyl ether
Bromacil
Bromobenzene
Bromochloroacetonitrile
Bromochloromethane
Brornodichloromethane (THM)
Bromoform (THM)
Bromornethane
Butyl benzyl phthalate (BBP)
Butylate
Butylbenzene n-
Butylbenzene sec-
Butylbenzene tert-
Carbaryl
Carbofuran
Carbon Tetrachloride
Standards
Status NIPDWR MCLG MCL
Reg.* (ug/l) (ug/l) (ug/l)
P - zero TT
L
T - zero
P - zero 2
P - 10 10
P 40 40
P 10 10
L
L
P 3 3
T - zero
F - zero 5
T - zero
T - zero
T - zero
T - zero
L
L 100 - -
L 100 - -
T zero
-
P - 40 40
F zero 5
Health Advisories
Status
HA*
D
F
F
F
F
F
F
F
D
F
' F
F
F
F
D
F
D
D
D
D
D
D
F
D
D
D
F
F
F
10-kg Child 70-kg Adult
Longer-
One-day Ten-day term
ug/l ug/l ug/l
2000. 200 100
150 300 20
100 100
10 10 10
60 60 60
10 10 10
9000 9000 900
20000 20000 20000
100 100 50
40 40 40
300 300 300
200 200
5000 5000 3000
-.
2000 2000 1000
1000 1000 1000
50 50 50
4000 200 70
Longer- ug/l
term RID DWEL Lifetime at 10-4
ug/l ug/kg/day ug/l ug/l Cancer
Risk
400 13 400 - 100
70 0.2 7 - 1
10 400 - 40
40 1 .3 40
200 6.0 200
40 1.3 40 10
3000 9 300 60
80000 250 8000 2000
200 5 200 3
100 4 100 3
900 2.5 90 20
100
9000 130 5000 90
2 - -
20
200 - -
1000 50 2000 350
1000 100 4000 -700
,200 5200 40
300 0.7 -30, - 30
Cancer
Group
82
6 2
B2
D
D
D
D
D
D
c
c
D
B2
A
B2
B2
D
B2
C
C
D
D
E
B2
-------
4/5/89
Table 8-10 (continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES
** DRAFT
page 2
Chemicals
uarboxin
Chloramben
Chtoramine
Chlorate
Chlordane
Chlorine
Chloiine dioxide
Chlorite .
Chloroacelaidehyde
Chlorodibromomethane (THM)
Chloroethane
Chloroform (THM)
Chloromethana
Chloroplienol (2.4,6-)
Chlorophenol (2,4-)
Chlorophenol (2-)
Chtoropicrin
Chlorothatonil
Chlorotoluene p-
Chrysene (PAH)
Cyanazine ,
Cyanogen Chloride
Cymene p-
2.4-D
Oacthal (DCPA)
Dalapon
DCE(ds-1,2-)
DCE (lrans-1,2-)
DJazingn
Dibenz(a,h)anlhracene (PAH)
pibromoaceioniiriie
Dtoiomochtoropropane (DBCP)
Dibromomethana
Dibutyt phthalata (OBP)
Dicamba .
Pichloroacelaldahyde
Dichloroacelic acid
Dichloroacetonitrile
Standards
Status NIPDWR MCLG MCL
Reg.* (ug/l) (ug/l) (ug/l)
L -
L -
P - zero 2
L -
L -
L - " -
L -
L 100
L -
L 100 -
L -
L -
L -
L ...
I . .
L -
L ...
T - zero
L - zero
L ...
P 100 70 70
T - 200 -
P - 70 70
P - 100 100
T - zero
L -
P - zero 0.2
L -
T - zero
L - - -
L ,..-
L -
L -
Health Advisories
Status
HA'
F
F
D
D
F
D
D
D
D
D
D
D
D
0
D
F
D
D
F
D
D
F
F
F
F
F
F
D
F
D
F
D,
D
D
10 kg Child
Longer-
One-day Ten-day term
ug/l ug/l ug/l
1000 1000 1000
3000 3000 200
60 60 0.5
- .... - . . :; ;
.
200 200 200
100 100 - 20
1000 300 100
80000 60000 5000
3000 3000 300
4000 1000 1000
20000 2000 2000
20 20 5
200 50
, 300 300 300
-
70-kg Adult
Longer- ug/l
term RID DWEL Liletima at 10-4
ug/l ug/kg/day ug/l ug/l Cancer
Risk
4000 100 4000 700
500 15 500 100
0.5 0.045 2 - 3
2
10 - - 800
300
3 100 -
5 200 -
500 15 500 200
20
0.1
70 2 70 10
400 10 400 70
20000 500 20000 4000
900 26 900 200
1000 10 400 70
6000 20 600 100
20 0.09 3 0.6
100 - -
1000 30 1000 200
8 - - -
Cancer
Group
P
D
B2
82
B2
B2
D
D
B2
D
D
D
P
P
D
E
B2
B2
D
P
D
C
00
ui"
ro
-------
4/5/89
Table 8-10 (Continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES
DRAFT**
page 3
Chemicals
Dichlorpbenzene p- |
Dkhlorobenzene o-,m-
DichlofodiJIuoromethane
Dicrtloroethaoe(l.l-)
Dichbroelhana (1,2-)
DJcriJoroBthvlene (1.1-1
Dichlorornethane
Dichloropiopane (1.1-)
DJchtoropropane (1,2-)
Dkhloropropane (1,3-)
DichloroproDane 12.2-}
pichlorbpfopene (1,1-)
bicriloropropene (1.3-)
Dieldrin
Diethyl phlhalata (DEP)
Diethvthaxvl ohthalate (DEHP1
Dimelhrin
Dimelhylphihlate(DMP)
DinHroloIuena (2.4-)
Dinoseb
Dioxane p-
Piphenamid
Diqual
Disullolon
Diuron
Endolhall
Endrin
Epichlororiydrin
Elhylbenzene
Ethylerie dibromide (EDB)
Elhylene glycol
ETU
Fenamiphos
Fluometuron
Fluorene (PAH)
Fluofolrichloromelhane
Fonolos
Formaldehyde
Gasoline
Status NIPDWR MCLG MCL
Reg,* (ug/l) (ug/i) (ug/l)
F - 75 75
P - 600 600
L -
F - zero 5
F -77
T - zero
P - zero 5
L -
L -
L -
L -
L -
T - zero
T - zero
L -
L -
T - 7 -
T -20 -
T - 100 -
T 0,2 2 -
P - zero TT
P - 700 700
P - zero 0.05
T
L -
T - zero
- ' .--- ;
Health Advisories
Status
HA'
F
F
D
0
F
F
F
D
F
D
D
D
F
F
D
D
F
D
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
D
D
10-kg Child
Longer-
One-day Ten-day ternr
ug/l ug/l ug/i
10000 100QO 10000
9000 9000 9000
700 700 700
20430 1000 1000
10000 2000
" T
90
T
30 30 30
0.5 0.5 0.5
10000 10000 10000
" - .
300 300 10
4000 400 -
300 300 300
10 10 3
1000 1000 300
BOO 800 200
20 20 3
100 100 70
30000. 3000 1000
a a 4
20000 6000 6000
300 300 100
9 95
2000 2000 2000
20 20 20
70 kq Adult
Longer- ' ug/l
term RID OWEL Lifetime al 10-4
ug/l ug/kg/day ug/l 'ug/l Cancer
Risk
40000 100 4000 75 -
30000 69 3000 600
20
A * » .
2600 40
4000 9 400 7
60 2000 500
- - - - 60
100 0.3 10 - 20
2 0.05 2 - 0.2
800
- 20
40000 300 10000 2000
40 1 40 7
- - - 700
1000 30 1000 200
2.2 - -
9 0.04 1 0.3
900 2 70 10
200 20 700 100
10 3 92
70 2 70 - 400
3000 100 3000 700
0.04
20000 2000 40000 7000 -!
400 0.03 1 - 20
20 0.25 9 2
5000 13 400 90
70 2 70 10
Cancer
Group
C
D
B 2
C
B2
B2
B2
D
B2
U
D
B2
D
E
D
D
D
B2
D
B2
D
B2
D
O
0
D
-------
4/5/89
Table 8-10 (Continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES ** DRAFT
page 4
Chemicals
Giyphosaia
Heplachtor
Hepiachlor epoxide
Hexachlorobenzene
Hexachlofobutadiene
Hexachlorocyclopentadiene
Hexarie (n-)
Hexazinone
Hypochtorita
Hypochibrous acid
lndeno(1.2,3I-c,d)pyrene (PAH)
Isophordne
Isopropy benzene
Lindana
Maleic hydrazkJa
MCPA f
Methbmyl
Methoxychlor
Methyl ethyl kelone
Methyl paralhipn
Methyl tert butyl ether
Meldjachlor . .
MetribuziR
Monochjoroacetic acid
Monochlorobenzene
Naphthalene
Gxamyi (Vydate)
Ozone by-products
Paraquat
Pentachloroelhane
P.entathtorophe not
Phenanthrene (PAH)
Phenol
Picldfam .
Potychtorinaled byphenols (PCBs)
Promelon
Pronamide
Propachlor
Propazina
Standards
Status NIPDWR MCLG MCL
Reg.* (ug/l) (ug/1) (ug/l)
T - 700 -
P - zero 0.4
P - zero 0.2
T - zero
T 50
L ....._..
L -
T - zero
i- '
P 4 0.2 0.2
P 100 400 400
; L
L - - -
L -
L . . . -
P - 100 100
T 200
L -
P - 0/200 0/200
T - zero
T - 500
P - zero 0.5
-
Health Advisories
Status
HA'
F
F
' F
F
D
F
F
D
O
F
F
F
F
F
F
F
D
F
F
0
F
D
F
F
D
F
D
F
P
F
F
F
F
10^g Child
Longer-
One-day Ten-day term
ug/l ug/l ug/l
20000 2GCOO 1000
10 10 5
10 - 0.1
50 50 50
10000 4000 4000
3000 3000 3000
1000 1000 30
10000 10000 5000
100 100 100
300 300 300
6000 2000 500
: 80000 8000 3000
300 300 30
2000 2000 2000
5000 5000 300
2000 2000 2000
200 200 200
100- 100 50
1000 300 300
20000 20000 700
- - i
200 200 200
800 BOO 600
500 500 100
1000 1000 500
70-kg Adult
Longer^- ' ug/l
term RfD DWEL Liletime at 10-4
ug/l ug/kg/day ug/l ug/l Cancer
Risk
1000 .100 4000 700
5 0,5 20 - 0.8
0.1 0.013 0.4 - 0.4
200 0.8 30 - 2
2 - 50
7 200
10000 ...
9000 30 1000 200
150 - -
100 0.3 10 0.2 3
20000 500 20000 4000
400 0.5 20 4
300 25 900 200
2000 50 2000 400
9000 50 900 200
100 0.25 9 2
5000 150 5000 100
900 25 900 200
7000 20 700 100
410
900 25 3GO 2GO
200 4.5 . 200 30
1000 30 1000 0/200
600
2000 70 2000 500
4 - - - 0.5
500 15 500 100
3000 75 3000 50
500 13 500 90
2000 20 700 10
Cancer
Group
D
B2
82
B2
C
D
D
B2
C
D
E
D
D
O
D
C
D
O
E
E
B2/D
D
B2
D
C
D
C
-------
4/5/89
Table 8-10 (Continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES * * D R A F T * *
page 5
Chemicals
Pfopham
Propylbenzene n-
Fyrena (PAH)
Simazina
Styrene
2,4.5-T
2.3.7.B-TCDD (Dioxin)
Tebulhiuron
Terbacil
Tsfbutes
Tetrachloroethane (1.1.1,2-)
Teuachioroeihana (1,1,2.2-)
Tetrachlorpelhylene
Toluene
Toxaphana
2.4,5-TP
Trichloroacelatdehyde
Tfichtoroacelic acid
Trictiloroaclanhrile
Trichloiobenzene (1, 2.4-)
Trtchtorobenzene (1,3,5-)
Trichtoioethane (1,1.1-) f
Tiicriioroeihane {f.1.2-}
Tiichloroelhanol (2,2,2-)
Trichtoroeihyiene
trichlofopropana (1.1. 1-)
Trichloropropane (1,2,3-)
Trilluralin
Trimethylbenzene (1,2,4-)
Trimelhylbenzene (1.3,5-)
Vinyl chloride
Xyle.nss
Standards
Status NIPDWH MCLG MCL
Rag.' (ug/1) {ug>!) (ug/!)
T - zero
T - 4 -
P - zero/100 5/100
L -
T - zero
L
L - - T
P - zero 5
P - 2000 2000
P 5 zero 5
P 10 50 50
L -
L -
L -
T - 9 -
F - 200 200
T - 3 -
L - - -
F - zero 5
L - . -
F - zero 2
P . iQOOO 10000
Health Advisories
Status
HA'
F
0
F
F
F
F
F
F
F
D
D
F
F
F
F
D
D
D
D
D
F
D
F
b
D
F
D
D
F
F
10-kg Child
Longer-
One-day Ten-day term
ug/! ug/! ug/!
5000 5000 5000
500 500 50
20000 2000 2000
BOO 800 BOO
0.001 1E-04 tE-05
3000 3000 700
300 300 300
5 5 1
2000 2000 1000
20000 3000 3000
500 40
200 200 70
-
100000 40000 40000
30 30 30
3000 3000 10
4QQQO 4QOQQ 40000
70 kg Adult
Longer- ' ug/l
term RID DWEL Lifetime at 10-4
ug/! ug/kg/day ug/! ug/! Canes:
Risk
20000 20 800 100
200 5 200 4
7000 200 7000 0/100 1
1000 10 350 70
4E-05 1E-06 4E-05 - 2E-05
2000 70 2000 500
900 13 400 90
5 0.13 5 0.9
- 30
5000 10 500 - 70
10000 300 10000 2000
100 . - - 3
300 7.5 300 50
600
100000 90 1000 200
30
7 300 - 300
6
30 3 100 2
50 1.5
1QQOQ 2000 60000 10000
Cancer
Group
D
D
C
B2/C
0
B2
D
E
D
B2
B2
.
D
C
B2
C
A
D
-------
4/5/89
Table 8-10 (continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES
*DRAFT**
page6
Chemicals
Standards
Status NIPDWR MCLG MCL
Rag.* (ug/1) (ug/l) (ug/t)
Health Advisories
Status
HA*
1Okg Child
Longer -
One-day Ten-day term
ug/l ug/l ug/l
70-kg Adult
Longer- ' ug/l
term RIO DWEL Lifetime at 10-4
ug/l ug/kg/day ug/l ug/l Cancer
Risk
Cancer
Group
Inorganics
Aluminum
Antimony
Arsenic
Asbestos (tibets/1 > 10um)
Barium
Beryllium
Boron , ; ,
Cadmium ...
Chromium (total)
Copper
Cyanide
Fluoride
Lead (at source)
Lead (at lap)
Manganese
Mercury
Molybdenum
Nickel
Nitrate (as N)
Nitrite (as N) :
Nitrate +- Nitrite
Selenium
Silver
Sodium '
Strontium i,
Sullate
Thallium
Vanadium
Zinc
L -
T 3
T 50 zero
P - 7E+06 7E+06
P 1000 SOOO 5000
T - zero
L
P 10 ,5 5
P 50 100 100
P 1300 1300
T 200
F - 4000 4000
P - zero 5
P 50 zero TT
P 222
L -
T 100
P 10000 10000 10000
P - 1000 1000
P - 10000 10000
P 10 50 50
L 50
L
L -
T 300
T 0.4
L - - -
L -
D
D
D
F
0
D
F
F
F
F
D
F
F
F
D
D
D
D
0
D
5000 5000 5000
40 40 5
1000 1000 200
200 200 200
-
20000 200 6
1000 1000 100
1000
- 1000 ..'..-
-
v '.- -
0.4 - -
1 - - 3
5000 - - 5000
5 - -
20 0.5 20 5
600 5 200 100
800 22 800 200
60
6 0.3 10 2
20 0.6 20 4
600 20 600 100
3
- 20000 "*
0.07
20
A
D
B2
P
D
D
D
D
D
O
D
-
-
-------
4/5/89
Table 8-10 (Continued)
DRINKING WATER STANDARDS AND HEALTH ADVISORIES **DRAFT*
page?
Chemicals
Standards
Status NIPDWR MCLG MCL
Reg.* (ug/l) (ug/l) (ug/l)
Health Advisories
Status
HA*
10-kg child
Longer-
One-day Ten-day term
ug/l ug/l ug/l
70-kg Adult
Longer- ug/l
term RfD DWEL Lifetime at 10-4
ug/l ug/kg/day ug/l ug/l Cancer
Risk
Cancer
Group
Microbiology and Turbidity
Ciyptosportdium
Giardia lamblia
Legionella
Standard olata count
Tola! colilorm (current MCL bast
on density)
Turbidity
Viruses
MOU Chemicals
o Diisopropyl methylphosphona
n FogOil
^ HMX
Niirocellulose (non-toxic)
Nitroquanidine
RDX
Trinitioglycerot
Trinitrotoluene
White Phosphorus
Zinc chloride
Radfonuclidcs
Beta particle
and photon activity (formerly
man-made radionudides)
Gross alpha particle activity
Radium 226/228
Radon
Uranium
L -
P - zero TT
P - zero TT
P - NA TTi
P <1/100ml zero
P 1NTU 0.1 NTU PS
P - .zero TT
...
.
T 4mrem/Vr zero
T 15pCi/l zero
T 5pCi/l zero
T - zero
T - zero
F
-
F
F
F
F
F
F
-
.
-
6000 8000 8000
5000 5000 5000
100 100 100
5 5 - .- 5
20 20 20
.
.
. . . - .
30000 80 3000 600
20000 50 2000 400
400 3 100 2 30
5 - - 5
20 0.5 20 2 100
- 4 mrem/vi
- 29pCi/l
- 160 pCi/l
: - - 160pCi/l
-
-
D
D
C
C
A
A
A
A
A
-------
Legend for draft version of Drinking Watpr stanHarHg anH Health Advisories table.
Abbreviations column descriptions are:
NIPDWR - National Interim Primary Drinking Water Regulation. Interim enforceable
drinking water regulations first established under the Safe Drinking Water
Act that are protective of public health to the exte"nt feasible.
MCLG - Maximum Contaminant Level Goal. A non-enforceable concentration of a
drinking water contaminant that is protective of adverse human health
effects and allows an adequate margin of safety.
MCL - Maximum Contaminant Level. Maximum permissible level of a contaminant
in water which is delivered to any user of a public water system.
RfD - Reference Dose. An estimate of a daily exposure to the human population
that is likely to be without appreciable risk of deleterious effects over a
lifetime.
DWEL - Drinking Water Equivalent Level. A lifetime exposure concentration
protective of advere, non-cancer health effects, that assumes all of the
exposure to a contaminant is from a drinking water source.
(*) The codes for the Status Reg and Status HA columns areas follows:
F - final
D - draft
L - listed for regulation
P - proposed (Phase II draft proposal)
T - Tentative (Phase V)
Other codes found in the table include the-following:
NA - not applicable
PS - performance standard 0.5 NTU - 1.0-NTU
TT - treatment technique
" No more than 5% of the samples maybe positive. For systems collecting fewer
than 40 samples/month, no more than 1% may be positive.
*** guidance
t Large discrepancies between Lifetime and Longer term HA values may occur
because of the Agency's conservative policies, especially with regard to
carcinogenicity, relative source contribution, and less than lifetime exposures in
chronic toxicity testing. These factors can result in a cumulative UF (uncertainty
factor) of 10 to 1000 when calculating a Lifetime HA.
8-58
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8.10.2 Worksheets
Worksheets 8-1 and 8-2 may be used by the regulatory agency in comparing
constituent concentrations in the release to health and environmental criteria.
Example filled in worksheets are also shown. These worksheets address the
fallowing:
8-1: Comparison of individual contaminant concentrations with criteria
8-2: Use of hazard indices for exposure to chemical mixtures.
A questionnaire that may be used in determining it interim corrective
measures are necessary is provided in Worksheet 8-3. Questions are posed to help
focus the determination., These questions will be addressed to the extent possible
based on available information. The regulatory agency will not necessarily need
answers for all questions in order to make a decision as to whether interim
corrective measures are necessary. If release concentration information is available,
Worksheets 8-1 and 8-2 may also be filled out.
8-59
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WORKSHEET 8-1
COMPARISON OF INDIVIDUAL CONSTITUENT CONCENTRATIONS
WITH HEALTH AND ENVIRONMENTAL CRITERIA
Facility Name
Releasing Unit
Contaminated Media
Sample Location
Sample Number(s)
Date
Analyst
Exposure
Medium
WATER
SOIL
AIR
Constituent Released
Release
Concentration
Table No.
and Criterion
Type Used
Criterion
Value
Release
Concentrations
Exceed Criterion?
INSTRUCTIONS
1. List chemicals with human-health and environmental criteria for the appropriate exposure medium.
2. List chemical concentration for the appropriate exposure medium.
3. List type of human-health and environmental criteria used and applicable table number.
4. List appropriate criteria values.
5. Compare chemical concentration and criteria values and identify whether release concentration
exceeds criteria.
8-60
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EXAMPLE WORKSHEET 8-1
COMPARISON OF INDIVIDUAL CONSTITUENT CONCENTRATIONS
WITH HEALTH AND ENVIRONMENTAL CRITERIA
Site Name
Releasing Unit
Contaminated Media
Sample Location
Sample Number(s)
Date
Analyst
SiteX
Impoundment 2
Ground Water/Air/Soil
MW 2/X-7 (see Map)
MW2-1/X-7-1
9/4/86
.IDP
Exposure
Medium'
WATER
SOIL
AIR
Constituent Released
Trichloroethylene
Carbon tetrachloride
Chloroform
Chl;orobenzene
Pentachlorobenzene
Trichloroethylene
Release
Concentration
2yg/l
lwg/1
3ug/i
10mg/kg
7mg/kg
0.1 ug/m3
Table No.
and Criterion
Type- Used
MCL
Table 8-7
MCL
TableS-7
Carcinogen
Table 8-6
Systemic Tox.
Table 8-7
Systemic Tox.
Table 8-7
Carcinogen
Table 8-6
Criterion
Value
Swg/l
5ug/l
5.7pg/l
2000 mg/kg
60mg/kg
0.27 jig/m3
. Release
Concentrations
Exceed Criterion!
1Mb
NO
No.
No
No
-
NO
INSTRUCTIONS
1. List chemicals with human-health and environmental criteria for the appropriate exposure medium.
2. List chemical concentration for the appropriate exposure medium.
3. List type of human-health and environmental criteria used and applicable table number.
4. List appropriate criteria values.
5. Compare chemical concentration and criteria values and identify whether release concentration
exceeds criteria.
8-61
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WORKSHEET 8-2
USE OF HAZARD INDICES FOR EXPOSURE
TO CHEMICAL MIXTURES
Facility Name
Releasing Unit
Contaminated Media
Sample Location
Sample Number(s)
Date
Analyst
Exposure ... . ,-, , .
Medium Constituent Released
WATER
SOIL
Al R
Ratio of Release
Concentration to
Criterion Value
HAZARD IN DICES
Medium
Total
Value Exceeds
Unity? ' -'
INSTRUCTIONS
1. List chemicals in each environmental medium, as shown in Worksheet 8-1.
2. Compare chemical concentrations and appropriate health criteria, values, as shown in Worksheet 8-1.
Determine ratio of release concentration to the criteria values.
3. Determine a hazard index for the chemicals in each medium by summing the ratios calculated by
comparing chemical concentrations and health criteria.
4. Determine if the hazard index for the chemical mixture found in each individual exposure medium
exceeds unity.
8-62
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EXAMPLE WORKSHEET 8-2
USE OF HAZARD INDICES FOR EXPOSURE
TO CHEMICAL MIXTURES
Site Name
Releasing Unit
Contaminated Media
Sample Location
Sample Number(s)
Date
Analyst
SiteX
Impoundment 2
Ground Water/Alr/Soil
MW 2/X-7 (see Map)
MW2-1/X-7-1
9/4/86
JDP
Exposure
Medium
WATER
SOI L
AIR
Constituent Released
Trichloroethylene
Carbon tetrachloride
Chloroform
Chlorobenzene
Pentachlorobenzene
Trichloroethylene
Ratio of Release
Concentration to
Criterion Value
.0.4
0.2
0.53
0.0005
0.12
0.37
HAZARD INDICES
Medium
Total
1.13
0.125
0.37
Value
Exceeds
Unity?
Yes
No
No
INSTRUCTIONS
1. List chemicals in each environmental medium, as shown in Worksheet 8-1.
2. Compare chemical concentrations and appropriate health criteria values, as shown in Worksheet 8-1.
Determine ratio of release concentration to the criteria values.
3. Determine a hazard index for the chemicals in each medium by summing the ratios calculated by
comparing chemical concentrations and health criteria.
4. Determine if the hazard index for the chemical mixture found in each individual exposure medium
exceeds unity.
8-63
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WORKSHEET 8-3
QUESTIONS TO BE CONSIDERED IN DETERMINING IF INTERIM CORRECTIVE
MEASURES MAY BE NECESSARY
In considering the actual or potential threat to human health or the
environment posed by a contaminant release, the regulatory agency will consider
factors such as type and extent of the 'release and site demographics. The following
questions may be used in evaluating these factors. If sufficient information is
available, the worksheets presented on the previous pages may also be used in
evaluating the need for interim corrective measures. For further details, see RCRA
Corrective Action Interim Measures (U.S. EPA, 1987)
A. Release Characterization
1. What is the source(s) (e.g., nature, number of drums, -area, depth,
amount, location(s))?
2. Regarding hazardous wastes or constituents at the source(s):
a. Which hazardous wastes (listed, characteristic) and hazardous
constituents are present?
b. What are their concentrations?
c. What is the background level of each hazardous waste or
constituent?
3. What are the known pathways through which the contamination is
migrating or may migrate and the extent of contamination?
a. Through which media is the release spreading or likely to spread?
Direction? Rate?
b. How far has the release migrated? At what concentrations?
8-64
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c. How mobile is the constituent?
d. What are the estimated quantities and/or volumes released?
4. What is the projected fate and transport?
B. Potential Human Exposure and Effects
1. What is or will be the exposure pathway(s) (e.g., air, fire/explosion,
ground water, surface water, direct contact, ingestion)?
2. What are the location and demographics of populations and
environmental, resources (potentially)-, at risk from exposure (e,g.,
residential areas, schools, drinking water supplies, sole source aquifers
near vital ecology or protected natural resources)?
3. What are the potential, effects of human exposure (short- and long-term
effects)?
4. Has human exposure actually occurred? Or when may human exposure
occur?
a. What is the exposure route(s) (e.g., inhalation, ingestion, skin
contact)?
b. Are there any reports of illness, injury, or death?
c. How many people will be affected?
d. What are the characteristics of the exposed populations(s) (e.g.,
presence of sensitive populations such as infants or nursing home
residents)?
5. If response is delayed, how will the situation change (e.g., what will be
the implications to human health)? .
8-65
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c. Potential Environmental Exposure and Effects
1. What media have been and may be contaminated (e.g., ground water,
air, surface water)?
2. What are the likely short-term and long-term threats and effects on the
environment of the released waste'or constituents?
3. What natural resource and environmental effects have occurred or are
possible (terrestrial, aquatic organisms, aquifers whether-or not used for
drinking water)?
4. What are the known or projected ecological effects?
5. When is this threat/effect likely to materialize (days, weeks, months)?
6. What are the projected long term effects?
7. If response is delayed, how will the situation change?
8-66
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APPENDIX A
AERIAL PHOTOGRAPHY, MAPPING, AND SURVEYING
A-1
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APPENDIX A
AERIAL PHOTOGRAPHY, MAPPING, AND SURVEYING
Aerial photographs, maps, and surveys can assist in verifying and
characterizing contaminant releases and are particularly helpful sources of
information that can be used during the development of a monitoring plan. They
can also be used, when viewed in historical sense (e.g., over the same location, but
at different points in time), to locate old solid waste management units, stream
beds, and other facility features. Stereo viewing (using a stereoscope) can further
enhance the interpretation of photographs and maps because vertical as well as
horizontal spatial relationships can be observed. , This Appendix discusses the
potential applications of aerial photography, mapping, and surveying in the RFI
process.
Case Study Numbers 12, 13 and 14 in Volume IV (Case Study Examples)
illustrate the use of several of the techniques presented in this Appendix.
AERIAL PHOTOGRAPHY
Introduction
Aerial photography may be used to gather release verification and
characterization information during the RFI. Although detailed aerial photographic
analysis usually requires a qualified photo-interpreter, the site information that it
can readily provide may warrant its use. Aerial photography can provide valuable
information on the environmental setting as well as indications of the nature and
extent of contaminant releases. However, when using aerial photographic
techniques, important release information should be verified through field
observations.
Information Obtained From Aerial Photographs
The basic recognition elements commonly utilized in photographic
interpretation are shape, texture, pattern, size, shadow, tone and/or color. Natural
A-2
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color, false color or color infrared, and black and white film are routinely used in
aerial photographic applications. Color imagery may be more readily interpreted
than black and white film, by providing enhanced differentiation of subtle evidence
of such items as surface leachate (e.g., seeps), and surface water quality. Color,
infrared film offers an added element of information with its near infrared
sensitivity by enabling, assessment of vegetation type, damage, or stress, and
providing a wide range for detection of moisture conditions in soils.
Subsurface characteristics can be inferred by surface information in the
photographs. For example, vegetative stress may indicate leachate and gas
migration where the water table is shallow or in discharge areas. Infrared may be
able to detect vegetative stress not noticeable during a field 'inspection, Geologic
features (variation in the distribution of geologic, units, bedrock fractures, fault
zones, etc.) that can affect ground-water flow pathways can also be identified from.
aerial photographs. Fractures at shallow depths in consolidated rocks can serve as
pathways for contaminated ground water and for rapid infiltration of surface
runoff. Contamination of surface water bodies can be detected by-discoloration or
shading in aerial photography. Land surface elevation determinations and contour
maps can be compiled, and ground-water flow direction, in shallow systems can be
estimated using this information. The time of year is also an important
consideration when interpreting geologic and hydrologic features. For example,
the presence of heavy vegetation during the summer months may obscure certain
geologic and hydrologic features. As another example, drainage patterns and
seasonal high water tables are more readily observed after or during winter
snowmelt.
Other information available from aerial photographs includes: Natural
topography, drainage and erosional features, vegetative cover and damage,
indications of leachate, damaged unit containment structures, etc. Observable
patterns, colors, and relief can make it possible to distinguish differences in
geology, soils, soil moisture, vegetation, and land use. Aerial photography can also
indicate important hydrologic features. Springs and marshy areas represent.
ground-water discharge areas. In cases of- releases to ground water, aerial
photographs can indicate the existence of likely contaminant migration pathways,
(e.g., recharge areas, sink holes, karst terrains, subsurface flow patterns, fissures,
and joints). For releases to surface water, aerial photographs can indicate the
A-3
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location of potential contaminant receiving bodies (e.g., ponds and streams) and
site runoff channels. Aerial photography can also be used to obtain input
information for designing monitoring plans (e.g., 'defining boundary conditions
such as ponds, streams, springs, paved areas, large buildings, irrigation canals).
Major benefits in-using aerial photography as a supplement to other
investigative methods include:
Obtaining information on relatively large areas, including surrounding
land use and environmental features;
Indicating effects of contamination; and
Providing indirect indications of subsurface conditions.
The following limitations should be considered when using aerial
photography:
It does not provide direct information on subsurface characteristics;
There may be variations in photo quality with age, season of flight, film
type, photo scale; cloud cover, etc.; and
Information obtained from photographs should not be used alone in
evaluating surface/subsurface conditions. They should always be verified'
through field observations.
Use of Existing Aerial Photographs (Historical Analysis)
Existing aerial photographs may be available that show the site prior to the
existence of some or all hazardous waste management activities. Individual
photographs provide an opportunity to identify specific features and activities at a
single point in time. By identifying conditions at a site at several points in time (i.e.,
historical analysis), the sequence of events leading to the current conditions can be
better understood. This process may identify changes in surface drainage
conditions through time, locations of landfills, waste treatment ponds/lagoons and
A-4
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their subsequent burial and abandonment, the burial of waste drums, number of
drums, estimated depth and horizontal extent of burial pits, sources of spillage, and
discharge of liquid wastes, etc. Historical photographic analysis can be used to
make maps that reflect conditions that previously existed at a facility if enough
control points are provided (e.g., road intersections, power lines, buildings, railroad
tracks). This information may be very useful in determining appropriate monitoring
locations. Analysis problems that should be considered when using historical
photos include variations in placement of the site within a given frame of
photography and variations in scale.
Sources
Town or county offices may have aerial photographs on file. Also, most of the
United States has been photographed in recent years for various Federal agencies.
A map entitled "Status of Aerial Photography in the United States" has been
compiled that lists all areas (by county) that have been photographed by or for the
Agricultural Stabilization and Conservation Service, the Soil Conservation Service,
Forest Service, U.S. Geological Survey, Army Corps of Engineers, Air Force, and
commercial firms. These maps are available from:
Map Information Office
U.S. Department of the Interior
Geologic Survey
507 National Center
Reston, VA 22092
(703) 860-6045
The names and addresses of agencies holding negatives for photographs are
printed on the back of the map.
The U.S. EPA may also have taken aerial photos of certain facilities. The owner
or operator may inquire at specific federal and state regulatory offices for access to
any photos that may have been taken. Other sources of aerial photographs are
listed below.
Federal government-The following two U.S. Geological Survey locations can
provide indices of ail published maps and include order blanks, prices, and detailed
A-5
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ordering instructions. They, may also provide a list of addresses of local map
reference libraries, local map dealers, and Federal map distribution centers.
Eastern Distribution Branch
U.S. Geological Survey
1200 South Eads Street
Arlington, VA 22202
Western Distribution Branch
U.S. Geological Survey
Box 25286 Denver Federal Center
Denver, CO 80225
Other Federal Agencies include:
Aerial Photography Field Office
ASCS-U.S. Department of Agriculture (USDA)
P.O. Box 30010
Salt Lake City, Utah 84130"
(801) 524-5856
EROS Data Center
U.S. Geological Survey
Sioux Falls, SD 57198
(605) 594-65-11 (ext. 151)
Soil Conservation Service
P.O. Box6567
Fort Worth, TX 76117
(817) 334-5292
National Archives
841 South Pickett Street
Alexandria, VA 22304
(703) 756-6700
(Has all Agricultural
Stabilization and
Conservation Service
photos, Forest Semite
photos; etc.)
(Landsat and U-2
photos,
black and white at
1:80,000 scale.
Computer listings of
all available photos
can be accessed)
(Supplies mostly low
altitude, "1:20,000 scale,
photos)
(For historical photos)
All of the above agencies will require some information identifying the site
location to locate relevant photos. This information may be in the form of a town
engineer's map; Department of Transportation map; description of the township,
range, section; a hand-drawn map of the site in relation to another town; precise
longitude and latitude coordinates of the site area; or a copy of the portion of a U.S.
Geological Survey quadrangle that shows the site.
A-6
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For facilities near the United States-Canada border, the following agency may
provide aerial photographs:
The National Air Photo Library
Surveys and Mapping Branch
Department of Energy, Mines and Resources
615 Booth Street
Ottawa, Ontario KIA OE9
State Government-State agencies may also have aerial photographs on file.
These include:
Pollution control agencies;
Health departments;
Water resources departments;
Forestry or Agricultural departments;
Highway departments; and
Geological survey departments.
Private companies-Photographs required for the site of concern may be held
by private aerial survey companies and can often be ordered directly from these
sources. Local telephone listings and Photogrammetric Engineering, the Journal of
the American Society of Photogrammetry, can provide sources of information.
Aerial photographic survevs-lf existing photographs are not available or do
not provide enough information, the owner or operator may arrange for an aerial
photographic survey to be conducted. When deciding whether an aerial survey is
appropriate, the owner or operator should consider whether the information needs
can be filled with data obtained from an aerial survey (or from another source or
investigative technique) and the size of the site (for a small site, a ground survey
may be more economical). This survey should be concluded by professionals who
A-7
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will plan, schedule, and perform the flight, collect data with appropriate scale
and/or film requirements, analyze results, and compile maps, if necessary.
Conducting New Aerial photographic Survevs-A local telephone listing, the
Journal of the American Society of Photogrammetry, or the government agencies
listed in this section may provide names of companies or organizations that conduct
aerial photographic surveys. When requesting that an aerial photographic survey
be conducted the owner or operator should supply the site location (e.g., marked
on a topographic map). Property boundaries and waste management areas should
be outlined. If photographic interpretation is also requested, a brief site
description, type and number of solid waste management units, and types of wastes
handled would also be helpful.
MAPPING
To assist in adequately characterizing a release, various types of maps may be
useful. Maps can be used to show geology, hydrology, topography, climate, land
use, and vegetative characteristics. Maps can be generated through compilation of
existing maps, aerial photographs, or through ground surveys. This section discusses
the usefulness of mapping in verifying and characterizing the nature and extent of
a release. In general, displaying information from all types of maps can be
presented on the facility's existing topographic map as discussed below.
Topographic Maps
The owner or operator should use, to the extent possible, the topographic
map and associated information that meets the requirements of 40 CFR Part 270
14(b)(19) of EPA's Hazardous Waste. Permit Program which states:
"A topographic map showing a distance of 1000 feet around the facility at a
scale of 2.5 centimeters (1 inch) equal to not more than 61.0 meters (200 feet).
Contours must be shown on the map. The contour interval must be sufficient
to clearly show the pattern of surface water flow in the vicinity of and from
each operational unit of the facility. For example, contours with an interval of
1.5 meters (5 feet), if relief is greater than 6.1 meters (20 feet), or an internal of
0.6 meters ( 2 feet), if relief is less than 6.1 meters (20 feet). Owners and
operators of HWM facilities located in mountainous areas should use large
contour internals to adequately show topographic profiles of facilities. The
map shall clearly show the following:
A-8
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(i) Map scale and date.
(ii) 100-year floodplain area.
(iii) Surface waters including intermittent streams.
(iv) Surrounding land uses (residential, commercial, agricultural,
recreational).
(v) A wind rose (i.e., prevailing wind-speed and direction).
(vi) Orientation of the map (north arrow).
(vii) Legal boundaries of the HWM facility site.
(viii) Access control (fences, gates).
(ix) injection and withdrawal wells both onsite and offsite.
(x) Buildings; treatment; storage, or disposal operations; or other
structures (recreation areas, runoff control systems, access and
internal roads, storm, sanitary, and process sewerage systems,
loading and unloading areas, fire control facilities, etc.).
(xi) Barriers for drainage or flood control.
(xii) Location of operational units within the HWM facility site,
where hazardous waste is (or will be) treated, stored, or
disposed (include equipment cleanup areas).
Additional information that should be noted on the topographic map is
specified in the requirements of 40 CFR Part 270.14(c)(3), which states:
"On the topographic map required under paragraph (b)(19) of this section, a
delineation o the waste management area, the property boundary, the
proposed "point of compliance" as defined under §264.95, the proposed
location of ground water monitoring wells as required under §264.97, and, to
the extent possible, the information required in paragraph (c)(2) of this
section.", that being . . . "(2) Identification of the uppermost aquifer and
aquifers hydraulically interconnected beneath the facility property, including
round water flow direction and rate, and the basis for such identification
i.e., the information obtained from hydrogeologic investigations of the
facility area). "
The use of topographic maps will enable the owner or operator to identify and
display many features useful in characterizing a release, such as potential surface
water receiving bodies, runoff pathways, and engineered structures.
Sources
Topographic maps of the facility area maybe available or obtained from:
U.S.G.S. (generally with 10-foot contour internals);
Local town offices (e.g., Building Department, Board of Assessors);
A-9
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Onsite surveying to obtain site-specific elevation information; and
Use of an aerial photographic consultant to fly the site and surrounding
area and develop a map.
A site specific topographic map may be constructed by measuring and plotting
land elevations by a stadia survey. This method of surveying determines distances
and elevations by means, of a telescopic instrument having two horizontal lines
through which the marks on a graduated rod are observed. A local telephone
directory will usually list companies providing this service.
Existing topographic maps may also-be obtained from:
Eastern Distribution Branch
US. Geological Survey (East of the Mississippi River)
1200 South Eads Street
Arlington, VA 22202
Western Distribdtion Branch
U.S. Geological Survey
BOX 25286 (West of the Mississippi River)
Denver Federal Center
Denver, CO 80225
Before requesting a map, the proper quadrangle must be determined. Maps
are indexed by geographic location-longitude and latitude. The quadrangle size is
given in minutes or degrees. 7.5 minute quadrangles provide the best resolution.
Other sources of topographic information include:
Local colleges or universities that may have index map sets;
Local town officials (town engineers, planners, etc.) who know which
quadrangles cover their area;
Nearby institutions or firms that deal with land holdings are likely to
have USGS quadrangles for that area; and
Local USGS offices, map distributors and other suppliers.
A-10
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Although for the most part the above identified sources will not supply
topographic maps which satisfy the requirements of 40 CFR Part 27,0, they may still
be useful for pointing out old solid waste management units and other facility
features which may be useful in planning the RFI.
Land Use Maps
Land uses, including residential, commercial, industrial, agricultural, and
recreational, should also be shown on the site topographic map. This information is
useful for assessing the need for interim corrective measures, and in evaluating
potential exposure points and the need for a Corrective Measures Study when air is
the medium of contamination.
Sources
Information may be obtained by contacting local officials, conducting first-
hand observations, and using a USGS quadrangle. USGS maps indicate structures,
including dwellings, places of employment, schools, churches, cemeteries, barns,
warehouses, golf courses, and railroad tracks. Various types of boundary lines
delineate city limits, national and state reservations, small parks, land grants, etc.
Other land use information may be obtained by contacting local planning boards,
regional planning commissions, and State agencies. Also, the USGS has special land
use maps available for some areas. Inquiries regarding the availability of such maps
may be directed to:
Geography Program
Land Information and Analysis Office
USGS-MS 710
Reston, VA 22092
(703) 860-6045
Climatological Maps
Relevant Climatological data should be identified. For example, a wind rose
graphically displays wind speed and direction. Such information may be critical in
the characterization of an air release. Other Climatological and meteorological
information (e.g., precipitation, and temperature) are often important in
A-11
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characterizing releases to the various environmental media. Because many of these
types of meteorological and climatological information may not be effectively
displayed on the 40 CFR part 270 topographic map, they should be identified in a
separate map or other document.
Sources
National Climatic Center
Department of Commerce
Federal Building
Ashville, NC 28801
(704) 258-2850
The National Climatic Center may also refer the owner or operator to a data
collection office in the vicinity of the area of concern. In addition, local libraries and
other sources may provide local climatological data for various period storms (e.g.,
the 100-year storm), and other information.
Floodplain Maps
The 100-year floodplain area, if applicable, should also be included on the
facility's topographic map. Special flooding factors (e.g., wave action) or special
flood control features included in the design, construction, operation or
maintenance of a facility should also be noted. The topographic map submitted
should 'include the boundaries of the site property in relation to floodplain areas.
Sources
The National Flood Insurance Program (NFIP) has prepared Flood Hazard
Boundary Maps for flood-prone areas. These maps delineate the boundaries of the
100-year floodplain. Such maps are often included as part of the Flood Insurance
Study for a particular political jurisdiction along a waterway. The U.S. Federal
Emergency Management Administration (FEMA) located in Washington, D.C. ((202)
246-2500) publishes such studies. Hydraulic analyses used to determine flood level,
community description, and principal flood problems and flood protective measures
(provided in the flood insurane studies) should also be included. The USGS, U.S.
Army Corps of Engineers, U.S. Soil Conversation Service and the Office of Coastal
Zone Management maybe contacted for further floodplain information.
A-12
-------
Additional Information:
Other information that should be shown on the topographic map includes:
Access control (fences, gates, etc.);
Buildings, treatment, storage, disposal operation areas and other
structures nearby or onsite;
Buried pipeline, sewers and electrical conduits;
Barriers for drainage or flood control;
Areas of past spills;
Location of all existing, (active and inactive) solid waste management
units;
Location and nature of industrial and product process and storage units;
and
Facility design features such as run-on/runoff control systems and wind
dispersal control systems.
Sources
This information can be obtained from aerial photographs, field observations,
operating records, construction and inspection records, etc. The owner or operator
may need to locate additional site-specific information. This information may be
available on existing, maps, such as:
Geomorphology - surficial geology maps
historical aerial photographs
topographic maps
Eolian Erosion and Deposition - county soil maps
historical) aerial photographic
A-13
-------
Fluvial Erosion and Deposition -
Drainage Patterns
Geologic Features
Land Use
Hydrologic Features
interpretation topographic maps
floodplain maps
county soil maps
(historical) aerial photographic
interpretation topographic maps
topographic maps
county soil maps
hydrologic maps
aerial photographic interpretation
bedrock geology maps
county soil maps
topographic maps
zoning maps
current aerial photos
local conservation commission
maps
county soil
recent topographic maps
hydrologic maps
topographic maps
wetlands maps
well data
aerial photographic interpretation
local conservation commission
maps
Some examples of how the above information may be useful to the owner or
operator in characterizing a release are given below:
Knowledge of floodplain areas, surface water bodies, drainage patterns
and flood control systems identifies potential migration pathways for
surface and ground water contamination;
Wind speed and direction may help identify air contaminant dispersion
areas;
Injection and withdrawal wells may provide locations aid information
(e.g., influences in ground-water flow patterns) for ground-water
monitoring;
Structures on or offsite can provide ideal locations for subsurface gas
monitoring; and
A-14
-------
Potential sources of contamination in close proximity to the facility may
be revealed by investigating surrounding land use practices.
SURVEYING
Ground surveying is a direct process for obtaining topographic and other
terrain features in the field. A local telephone directory should be consulted for
companies providing surveying services.
Information that can be obtained from a ground survey includes:
Facility boundary;
Location of engineered structures (e.g., buildings, pipelines);
Natural formations at the site (e.g., bedrock outcrops); '
Topographic features;
Drainage patterns and pending areas;
Elevation benchmarks ("permanent" elevation reference points that can
be used in the future);
Location of ground-water monitoring wells (e.g., surface location and
elevation); and
Profiles of surface water bodies (e.g., depths of lakes/ponds) that are not
possible by aerial means.
The above information, obtained during a survey of the facility, may be useful
in characterizing a contaminant release through:
Identification of engineered structures that may inhibit or promote
contaminant migration (e.g., accumulation areas for subsurface gas);
A-15
-------
Identification of natural features at the site (e.g., barriers or pathways)
affecting contaminant migration;
Topographic influences (e.g., drainage patterns and pending areas);
Location of ground water or subsurface gas monitoring wells;
Ground-water depth (knowledge of location and elevation of wells,
enables measurement of ground-water depth); and
Depths of surface water bodies that may be useful in predicting surface
water contamination and in determining ground-water breakout.
A-16
-------
REFERENCES
Ritchie. 1977. Mapping for Field Scientists. A. S. Barnes & Co., NY.
Todd, David. 1980. Ground Water Hydrology seconded. Wiley& Sons, NY
U.S. EPA. 1982. Environmental Science and Technology, "Airborne Remote
Sensing", Vol. 16, No. 6. 1982
U.S. EPA. 1983. Permit Applicants' Guidance Manual for the General Facility
Standards of 40 CFR 264. EPA SW-968. NTIS PB 87-151064. Washington, D.C.
20460.
A-17
-------
APPENDIX B
MONITORING CONSTITUENTS AND INDICATOR PARAMETERS
LIST1: Indicator Parameters Generally Applicable to Specific Media
List 2: 40 CFR 264 Appendix IX Constituents Commonly Found in Contaminated
Ground Water and Amenable to Analysis by EPA Method 6010-
Inductively Coupled Plasma (ICP) Spectroscopy (Metals) and by Method
8240. (Volatile Organics)
LISTS: Monitoring Constituents Potentially Applicable to Specific Media
LIST 4: Industry Specific Monitoring Constituents
B-1
-------
LIST 1
INDICATOR PARAMETERS
GENERALLY APPLICABLE TO SPECIFIC MEDIA
SOIL
INDICATOR PARAMETERS
Aluminum
Boron
Calcium
Carbonate/bicarbonate
Chloride
Cobalt
Copper
Fluoride
Iron
Magnesium
Manganese
Nitrate (as N)
Phosphorus
Potassium
Silica
Sodium
Soil Eh
Soil pH (Hydrogen Ion)
Strontium
Sulfate
Total Kjeldahl Nitrogen (TKN)
Total Organic Carbon (TOC)*
Total Organic Halogen (TOX)*
Total Phenols
Vanadium
Zinc
Although TOC and TOX have historically been used as indicator parameters for
site investigations, the latest data suggests that the use of these parameters
ma not provide an adequate indication of contamination. Both methods
suffer precision and accuracy problems. The normal procedure for TOC can
strip samples of the volatile fraction, and the presence of chlorine/chloride has
been shown to interfere with the TOX determination. In addition, the
sensitivity of these methods (generally in the parts per million level) are often
too high for constituents of concern.
B-2
-------
LIST 1 (Continued)
GROUND WATER (See also 40 CFR 264, Appendix IX)
INDICATOR PARAMETER
Aluminum pH (Hydrogen Ion)
Boron Potassium
Calcium Silica
Carbonate/bicarbonate Sodium
Chloride Strontium
Cobalt Sulfate
Copper Specific Conductance
Fluoride Total Organic Carbon (TOC)*
Iron Total Organic Halogen (TOX)*
Magnesium Total Phenols
Manganese Vanadium
Nitrate (as N) Zinc
Although TOC and TOX have historically been used as indicator parameters for
site investigations, the latest data suggests that the use of these parameters
ma not provide an adequate indication of contamination. Both methods
suffer precision and accuracy problems. The normal procedure for TOC can
strip samples of the volatile fraction, and the presence of chlorine/chloride has
been shown to interfere with the TOX determination. In addition, the
sensitivity of these methods (generally in the parts per million level) are often
too high for constituents of concern.
B-3
-------
LIST 1 (Continued)
SUBSURFACE GAS
INDICATOR PARAMETERS
Methane
Carbon dioxide
Total Hydrocarbons (THC)
Calorimetric Indicators (e.g., Draeger Tubes)
Explosivity
AIR
INDICATOR PARAMETERS
Total Hydrocarbons (THC)
Calorimetric Indicators (e.g., Draeger tubes)
B-4
-------
LIST 1 (Continued)
SURFACE WATER
INDICATOR PARAMETERS
Alkalinity (mg/l as CaCOs)
Biochemical Oxygen Demand (BOD)
Calcium
Chemical Oxygen Demand (COD)
Chloride
Dissolved Oxygen (DO)
Dissolved solids
Magnesium
Nitrates
Nitrites
PH
Salinity
Sodium
Specific Conductance
S u I f a t e
Suspended solids
Temperature
Total solids,
Total Organic Carbon (TOC)
Total Organic Halogen (TOX)*
Total Phenols
Turbidity
Although TOC and TOX have historically been used as indicator parameters for
site investigations, the latest data suggests that the use of these parameters
ma not provide an adequate Indication of contamination. Both methods
suffer precision and accuracy problems. The, normal procedure for. TOC can
strip samples of the volatile fraction, and the presence of chlorine/chloride has
been, shown to interfere with the TOX determination In addition, the
sensitivity of these methods (generally in the parts per million level) are often
too high for constituents of concern.
B-5
-------
LIST 2
40 CFR 264 APPENDIX IX CONSTITUENTS COMMONLY FOUND IN CONTAMINATED
GROUND WATER AND AMENABLE TO ANALYSIS BY EPA METHOD 6010-
INDUCTIVELY COUPLED PLASMA (ICP) SPECTROSCOPY (METALS) AND BY METHOD
8240 (VOLATILE ORGANICS)
Common Name
Acetone
Acrolein
Acrylonitrile
Allyl chloride
Antimony
Arsenic
Barium
Benzene
Beryllium
Bromodichloromethane
Bromoform, Tribromomethane
Cadmium
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane, Ethyl chloride
Chloroform
Chloroprene
Chromium
Cobalt
Copper
D ibromoch I orom ethane,
Chlorodibromomethane
1 ,2-Dibromo-3-chloropropane, DBCP
1,2-Dibromoethane, Ethylene
dibromide
Chemical
Abstracts
67-64-1
107-02-8
107-13-1
107-05-1
(total)
(total)
(total)
71-43-2
(total)
75-27-4
75-25-2
(total)
75-15-0
56-23-5
108-90-7
75-00-3.,
67-66-3
126-99-8
(total)
(total)
(total)
124-48-1
96-12-8
106-93-4
Method1
8240
X
xa
xa
xb
x c
xb
xb
X
xb
xb
xb
xb
xb
x b
X "
Method
6010
x
X
X
X
X
X
X
X
B-6
-------
LIST 2 (Continued)
Common Name
trans-1,4-Dichloro-2-butene
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane, Ethylene
dichloride
1,1-Dichloroethylene, Vinyl idene
chloride
trans-1,2-Dichloroethylene
1,2-Dichloropropane
cis-1 ,3-Dichloropropene
trans-1 ,3-Dichloropropene
Ethyl benzene
Ethyl methacrylate
2-Hexanone
Lead
Methacrylonitrile
Methyl bromide, Bromomethane
Methyl chloride, Chloromethane
Methylene bromide,
Dibromomethane
Methylene chloride,
Dichloromethane
Methyl ethyl ketone; MEK
Methyl Iodide, lodomethane
Methyl methacrylate
4-Methyl-2-pentanone, Methyl
isobutyl ketone
Nickel
Pentachloroethane
Chemical
Abstracts
Number
110-57-6
75-71 -8
75-34-3
107-06-2
75-3.5-4
156-60-5
78-87-5
10061 -01-5
10061 -02-6
100.41-4
96-63-2
591-78-6
(total)
126-98-7
74-83-9
74-87-3
74-95-3
76-09-2
78-93-3
74-88-4
80-62-6
108-10-1.
(total)
76-01-7
Method 1
8240
X
X
xb
xb
xb
xb
xb
xb
xb
xc
xd
X .
xd
xb
xb
xb
xb
x°
xb
xd
xd
X "
Method
X
0-7
-------
LIST 2 (Continued)
Common Name
2-Picoline
Propionitrile, Ethyl cyanide
Pyridine
Selenium
Silver
Styrene
1,1,1 ,2-Tetrachloroethane
1 ,1 ,2,2-Tetrachloroethane
Tetrachloroethylene,
Perchloroethylene,
Tetrachloroethene
Thallium
Toluene
1,1,1-Trichloroethane, Methyl
chloroform
1 , 1 ,2-Trichloroethane
Trichloroethylene, Trichloroethene
Trichlorofluoromethane
1 ,2,3-Trichloropropane
Vanadium
Vinyl Acetate
Vinyl Chloride
Xylene (total)
Zinc
Chemical
Abstracts
Number
109-06-8
10.7-12-0
110-86-1
(total)
(total)
100-42-5
630-20-6
79-34-5
127-18-4
(total)
108-88-3
71-55-6
79-00-5
79-01-6
96-18-4
96-18-4
(total)
108-05-4
75-1-4
1330-20-7
(total).
Method1
8240
X
x d
xe
X °
xb
xb
xb
X °
X
xb
xb
xb
xb
X
xb
xc
Method
6010
X
X
X
X
X
NOTE: Method 6010 is not recommended for Mercury and Tin.
1 Caution, these are representative methods and may not always be the most
suitable for a given application.
a Method 8030 is also suggested.
b Method 8010 is also suggested.
C Method 8020 is also suggested.
d Method 8015 is also suggested.
e Method 8070 is also suggested.
B-8
-------
LIST 3
MONITORING CONSTITUENTS POTENTIALLY APPLICABLE TO SPECIFIC MEDIA
Common Name
Acetonitrile
Acetophenone
2- Acety 1 aminofluorene
Acetyl chloride
1-Acetyl-2-thiourea
Acrolein
Acrylamide
Acrylonitrile
Aflatoxins
Aldicarb
Aldrin
Allyl alcohol
Allyl chloride
Aluminum phosphide
4-Aminobipheny I
5-(Aminornethyl)-3-isoxazolol
4-Aminopyridine
Amitrole
Ammonium vanadate
Aniline
Antimony, and compounds,
N.O.S.'
Aramite
Arsenic and compounds, N.O.S.1
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
A u r a m i n e
Azaserine
Barium and compounds, N.O.S.1
Barium cyanide
Benz(c)acridine.
Chemical
Abstracts
No.
75-05-8
98-86-2
53-96-3
75-36-5
591-08-2
107-02-8
79-06-1
107-13-1
1402-68-2
116-06-3
.309-00-2
107-18-6
107-05-1
2.0859-73-8
92-67-1
2763-96-4
504-24-5
61-82-5
7803-55-6
62-53-3
7440-36-0
140-57-8
7440-38-2
7778-39-4
1303-28-2
1327-53-3
492-80-8
115-02-6
7440-39-3
542-62-1
225-51-4
Ground
Water
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water
X
X
X
X
x
X
X
X
X
X
X
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
A i r
X
X
X
X
X
X
X
X
B-9
-------
LIST 3 (continued)
Common Name
Benz(a)anthracene
Benzal chloride
Benzene
Benzenearsonic acid
Benzidine
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(a)pyrene
p-Benzoquinone
Benzotrichloride
Benzyl chloride
Beryllium and compounds,
N.O.S.'
Bis(2-chloromethoxy)ethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(chloromethyl)ether
Bis(2-ethylhexyl)phthalate
Bromoacetone
Bromoform
4-Bromophenyl phenyl ether
Brucine
Butyl benzyl phthalate
Cacodylic acid
Cadmium and compounds,
N.O.S.1
Calcium chromate
Calcium cyanide
Carbon disulfide
Carbon oxyfluoride
Carbon tetrachloride
Chloral
Chemical'
Abstracts
No.
56-55-3
98-87-3
71-43-2
98-05-5
92-87-5
205-99-2
205-82-3
50-32-8
106-51-4
98-07-7
100-44-7
7440-41-7
111-91-1
.111 -44-4'
39638-32-9
542-88-1
117-81-7
589-31-2
75-25-2
101-55-3
357-57-3
85-68-7
75-60-5
7440-43-9
13765-19-0
592-01-8
75-15-0
353-50-4
56-23-5
75-87-6
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
'*
X
X
X
X
x
X
X
x
X
x
Soils
x
X
X
Subsurface
Gas4
x. ;
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
x
Air
X
x
x
X
X
X
x
x
x
B-10
-------
LIST 3 (continued)
Common Name
Chlorambucil
Chlordane, alpha and gamma
isomers
Chlorinated benzenes, N.O.S.1
Chlorinated ethanes, N.O.S.1
Chlorinated fluorocarbons,
N.O.S.1
Chlorinated naphthalene,
N.O.S.1
Chlorinated phenol, N.O.S.1
Chlornaphazine
Chloroacetaldehyde
Chloroalkyl ethers, N.O.S.i
p-Chloroaniline
Chlorobenzene
Chlorobenzilate
p-Chloro-m-cresol
1-Chloro-2,3-epoxypropane
2-Chloroethyl vinyl ether
Chloroform
Chloromethyl methyl ether
beta-Chloronaphthalene
o-Chlorophenol
Mo-Chlorophenyl) thiourea
Chloroprene
3-Chloropropionitrile
Chromium and compounds,
N.O.S.1
Chrysene .
Citrus red No7 2
Coal tars
Copper cyanide
Creosote
Cresols(Cresylicacid)
Crotonaldehyde
Chemical
Abstracts
No.
305-03-3
57-74-9
494-03-1
107-20-0
106-47-8
108-90-7
510-15-6
59-50-7
106-89-8
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
5344-82-1
126-99-8
542-76-7
7440-47-3
218-01-9
6358-53-8
8005-45-2
544-92-3
8001-58-9
1319-77-3
4170-30-3
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
x
x
X
x
: .,
" x ..
x
x
x
x
X
X
Soi|3
X
X
X
X
X.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
x
x
x
x
. ,
Air
x
X
x
. x , ',
x
X
X
1 " <
X
X
x
x
x
X
X
X
-------
LIST 3 (continued)
Common Name
Cyanides (soluble salts and
complexes) N.O.S.1
Cyanogen
Cyanogen bromide
Cyanogen chloride
Cycasin
2-Cyclohexyl-4,6-dinitrophenol
Cyclophosphamide
2,4-D, salts and esters
Daunomycin
ODD
DDE
DDT
Diallate
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenz(a,h)anthracene
7H-Dibenzo(c,g)carbazole
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,i)pyrene
1 ,2-Dibromo-3-chloropropane
Dibutylphthalate
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
Dichlorobenzene, N.O.S.1
3,3'-Dichlorobenzidine
1,4-Dichloro-2-butene
Dichlorodifluoromethane
1 ,2-Dichloroethylene
Chemical
Abstracts
No.
460-19-5
506-68-3
506-77-4
14901-08-7
131-89-5
50-18-0
94-75-7
20830-81-3
72-54-8
72-55-9
50-29-3
2303-16-4
226-36-8
224-42-0
53-70-3
194-59-2
192-65-4
189-64-0
189-55-9
96-12-8
84-74-2
95-50- 1
541-73-1
106-46-7
25821-22-6
91-94-1
764-41-0
75-71-8
156-60-5
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Soil3
x <
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas*
X
X
Air
X
X
X
X
X
X
X
X
X
B-12
-------
LIST 3 (continued)
Common Name
Dichlorethylene, N.O.S.1
1 , 1 -Dichloroethylene
2,4-Dichlorophenol
2,6-Dichlorophenol
Dichlorophenylarsine
Dichloropropane, N.O.S.1
Dichloropropanol, N.O.S.1
Dichloropropene, N.O.S.1
1,3-Dichloropropene
D i e I d ri n
1,2,3,4-Diepoxybutane
Diethylarsine
1 ,4-Diethy leneoxide
N-,N'-Diethylhydrazine
0,0-Diethyl S-
methyldithiophosphate
Diethyl-p-nitro phenyl
phosphate
Diethylphthalate
0,0-Diethyl 0-pyrazinyl
phosphorothioate
Diethylstilbesterol
Di hy drosafrole
3,4-Dihydroxy-alpha-
(methylamino)methyl benzyl
alcohol
Diisopropylfluorophosphate
(DFP)
Dimethoate
3,3'-Dimethoxybenzidine
p-Dimethoxyminoazobenzene
7,12-
Dimethylbenz(a)anthracene
3,3'-Dimethylbenzidine
Dimethylcarbamoyl chloride
1,1-Dimethylhydrazine
1,2-Dimethylhydrazine
Chemical
Abstracts
N o .
25323-30-2
75-35-4
120-83-2
87-65-0
696-28-6
26638-19-7
26545-73-3
26952-23-8
542-75-6
60-57-1
1464-53-5
692-42-2
123-91-1
1615-80-1
3288-58-2
311-45-5
84-66-2
297-97-2
56-53-1
94-58-6
329-65-7
55-91-4
60-51-5
119-90-4
60-11-7
57-97-6
1 19-93-7
79-44-7
57-14-7
540-73-8
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
X
"X
X
X
X
X
X
Soils3
X
X
X
X
X
X
X
X
X
X
X
X
X"
X
X
X
X
Subsurface
Gas4
Ai r
X
X
X
X
X
X
X
B-13
-------
LIST 3 (continued)
Common Name
alpha, alpha-
Dimethylphenethylamine
2,4-Dimethylphenol
Dimethylphthalate
Dimethyl sulfate
Dinitrobenzene, N.O.S.1
4,6-Dinitro-o-cresol and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di noseb
Di-n-octylphthalate
Diphenylamine
1,2-Diphenylhydrazine
Di-n-propylnitrosamine
Disulfoton
Dithioburet
Endosulfan
Endothal
Endrin
Ethyl carbamate (urethane)
Ethyl cyanide
Ethylenebisdithiocarbamic acid,
salts, and esters
Ethylene dibromide
Ethylene dichloride
Ethylene glycol monoethyl
ether
Ethyleneimine
Ethylene oxide
Ethylenethiourea
Ethylidene dichloride
Ethyl methacrylate
Chemical
Abstracts
No.
122-09-8
Ground
Water*
X
105-67-9 x
131-11-3
77-78-1
25154-54-5
534-52-1
51-28-5
121-14-2
606-20-2
88-85-7
117-84-0
122-39-4
122-66-7
621-64-7
298-04-4
541-53-7
115-29-7
145-73-3
72-20-8
51-79-6
107-12-0
X
X
X
X
X
X
X
X
X
X
X
X
X
111-54-6
106-93-4
107-06-2,
110-80-5
151-56-4
75-21-8
96-45-7
75-34-3
97-63-2
X
Surface
Water2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
'
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
X
- -
x
Air
x
X
X
,-.
x
X
X
x
X
B-14
-------
LIST 3 (continued)
Common Name
Ethylmethane sulfonate
Famphur
Fluoranthene
Flourine
Fluoroacetamide
Fluoracetic acid, sodium salt
Formaldehyde
Glycidylaldehyde
Halomethane, N.O.S.1
Heptachlor
Heptachlor epoxide
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene -
Hexachlorodibenzo-p-dioxins
Hexachlorodibenzofurans
Hexachloroethane
Hexachlorophene
Hexachloropropene
Hexaethyltetraphosphate
Hydrazine
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
lndeno(1,2,3cd)pyrene
Iron dextran
Isobutyl alcohol
Isodrin
Isosafrole
Kepone
Lasiocarpine
Lead and compounds, N.O.S.1
Lead acetate
Chemical
Abstracts
No.
62-50-0
52-05-7
206-44-0
7782-41-4
640-19-7
62-74-8
50-00-0
765-34-4
76-44-8
1024-57-8
118-74-1
87-68-3:
77-47-4
67-72-1
70-30-4
1888-71-7
757-58-4
302-01-2
74-90-8
7664-39-3
7783-06-4
193-39-5
9004-66-4.
78-83-1,
465-73-6
120-58-1
143-50-0
303-34-4
7439-92-1
301-04-2
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
"X
X
X
X
X
X
X
X
X
X
X
Soils3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas*
X
X
Air
X
X
X
X
X
X
X
X
B-15
-------
LIST 3 (continued)
Common Name
Lead phosphate
Lead subacetate
L i n d a n e
Maleic anhydride
Maleic hydrazide
Malonitrile
Mel phalan
Mercury fulminate
Mercury and compounds N.O.S.1
Methacrylonitrile
Methapyrilene
Methomyl
Methoxychlor
Methyl bromide
Methyl chloride
Methychlorocarbonate
Methyl chloroform
3-Methylcholanthrene
4,4',Methylenebis(2-
chloroaniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK)
Methyl ethyl ketone peroxide
Methyl hydrazine
Methyl iodide
Methyl isocyanate
2-Methyllactonitrile
Methyl methacrylate
Methyl methanesulfonate
Methyl parathion
Chemical
Abstracts
N o .
7446-27-7
1335-32-6
58-89-9
108-31-6
123-33-1
109-77-3
148-82-3
628-864
7439-97-6
126-98-7
91-80-5
16752-77-5
72-43-5
74-83-9
74-87-3
79-22-1
71-55-6
56-49-5
101-14-4
74-95-3
75-09-2
78-93-3
1338-23-4
74-88-4
624-83-9
75-86-5
80-62-6
298-00-0
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
X
X
Air
X
X
X
X
X
X
X
X
X
X
X
X
B-16
-------
LIST 3 (continued)
Common Name
Methylthiouracil
Mitornycin C
MNNG
Mustard gas
Naphthalene
1 ,4-Naptithoquinone
alpha-Naphthylamine
Beta-Naphthylamine
alpha-Napththylthiourea
Nickel and compounds, N.O.S.1
Nickel carbonyl
Nickel cyanide
Nicotine and salts
Nitric oxide
p-Nitroaniline
Nitrobenzene
Nitrogen dioxide
Nitrogen mustard and .
hydrochloride salt
Nitrogen mustard N-oxide and
Hydrochloride salt
Nitroglycerin
p-Nitrophenol
2-Nitropropane
4-Nitroquinoline-1 -oxide
Nitrosamine, N.O.S.1
N-Nitrosodi-n- butyl a mine
N-Nitrosodiethanolamine
N-Nitrosodiethylamine
N-Nitrosodi methyl ami ne
N-Niroso-N-ethyl urea
N-Nitrosomethylethylamine
N-Nitroso-N-methylurea
Chemical
Abstracts
No.
56-04-2
50-07-7
70-25-7
505-60-2
91-20-3
130-15-4
134-32-7
91-59-8
86-88-4
7440-02-0
13463-39-3
557-19-7
54-11-5
10102-43-9
100-01-6
98-95-3
10102-44-0
51-75-2
126-85-2
55-63-0
100-02-7
79-46-9
56-57-5
35576-91-1
924-16-3
1116-54-7
55-18-5
62-75-9
759-73-9
10595-95-6
684-93-5
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
Soil3
X
X
X
X
X
X
)
X
X
X
X
X "
X
X
X
X
X
X
Subsurface
Gas4
A i r
1
. X
X
X
X
X
X
B-17
-------
LIST 3 (continued)
Common Name
N-Nitroso-N-methylurethane
N-Nitrosomethlvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
Nitrosopyrolidine
N-Nitrososarcosine
5-Nitro-o-toluidine
Octamethylpryophosphoramide
Osmium tetroxide
Paraldehyde
Parathion
Pentachlorobenzene
Pentachlorbdibenzo p dioxins
Pentachlorodibenzofurans
Pentachloroethane
Pentachloronitrobenzene
(PCNB)
Pentachlorophenol
Phenacetin
Phenol
Phenylenediamine
Phenylmercury acetate
Phenylthiourea
Phosgene
Phosphine
Phorate
Phthalic acid esters, N.O.S.1
Phthalic anhydride
2-Picoline
Polychlorinated biphenyls
N.O.S.1
Potassium cyanide
Potassium silver cyanide
Pronamide
Chemical
Abstracts
No.
61 5-53-2
4549-40-0
59-89-2
16543-55-8
100-75-4
930-55-2
13256-22-9
99-55-8
152-16-9
20816-12-0'
123-63-7
56-38-2
608-93-5
76-01-7
82-68-8
87-86-5
62-44-2
108-95-2
25265-76-3
62-38-4
103-85-5
75-44-5
7803-51-2
298-02-2
85-44-9
109-06-8
151-50-8
506-61-6
23950-58-5
Ground
Water*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
Air
X
X
X
X '.
X
X
X
X
X
X .
X
B-18
-------
LIST 3 (continued)
Common Name
1 ,3-Propane sultone
n-Propylarnine
Propargyl alcohol
Propylene dichloride
1 ,2-Propyleriini'me
Propylthiouracil
Pyridine
Reserpine
Resorcinol
Saccharin and salts
5a frole
Selenium dioxide
Selenium and compounds,
N.O.S.
Selenium sulfide
Selenourea
Silver and compounds, N.O.S.1
Silver cyanide
Silvex (2,4,5-TP)
Sodium cyanide
Streptozotbcin
Strontium sulfide
Strychnine and salts
TCDD
1 ,2,4,5-Tetrachlorob«nzene
retrachlorodibenzo-p-dioxins
Tetrachlorodibenzofurans
Tetrachloroethane, N. O.S.i
1,1,1 ,2-Tetrachloroethane "'
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethy lerie
Chemical
Abstracts
No.
"1 126-71-4
107-10-8
107-19-7
78-87-5
75-55-8
51-52-5
110-86-1.
50-55"5
108-463
81. -07-2
94-59-7
7783-00-8
7782-49-2
7446-34-6
630-10-4
" 7440-22-4
506-64-9
93-72-1
143-33-9
18883-66-4
1314-96-1
57-24-9"
1746-01-6
95-94-3
' 25322 -20-7
630-20-6
'79-34-5
127-18-4
Ground
Water*
X
x
X
X
X
X
X
X
X
X
X
X
" X
Surface
Water2
X
X .
' . X
X
, x
X
x
X
X
X
" X .
X
X.
Soil3
x
X
X
.x
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface.
Gas4
j
,.. .
. i.
X
X
x
II
Ai r
)>
>
i
X
'
" x "
" x .
X
- -
. , . ~ .
5.. "
.5
'' X'
B-19
-------
LIST 3 (continued)
Common Name
2,3,4,6-Tetrachlorophenol
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethy 1 pyrophosphate
Tetranitromethane
Thallium and compounds,
N.O.S.i
Thallk oxide
Thallium (1) acetate
Thallium (1) carbonate
Thallium (1) chloride
Thallium (1) nitrate
Thai !i urn selenite
Thallium (1)sulfate
Thioacetamide
Thiofanox
Thiomethanol
Thiophenol
Thiosemicarbazide
Thiourea
Thiram
Toluene
Toluenediamine
2,4-Toluenediamine
2, 6- Toluenediamine
3,4-Toluenediaminc
Toluene diisocyanate
p-Toluidine
o-Toluidine hydrochloride
Toxaphene
1 ,2,4-Trichlorobenzene
1 , 1 ,2-Trichloroethane
Chemical
Abstracts
No.
58-90-2
3689-24-5
78-00-2
107-49-3
509-14-8
7440-28-0
1314-32-5
563-68-8
6533-73-9
7791-T2-0
10102-45-1
12039-52-0
10031-59-1
62-55-5
39196-18-4
74-93-1
108-98-5
79-19-6
62-56-6
137-26-8
108-88-3
25376-45-8
95-80-7
823-40-5
496-72-0
584-84-9
106-49-0
636-21-5
8001-35-2
120-82-1
79-00-5
Ground
Water*
X
X
X
X
X
X
X
Surface
Water2
X
X
; x
I-
; :
i
X
X
x
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Ga$4
...
-
. .,
.
X
. . ... .
...
X
Air
X
X
X
X
X
X
X
X
-------
LIST 3 (continued)
Common Name
Trichloroethylene
Trichloromethanethiol
Trichloromonofluoromethane
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-T
Trichloropropane, N.O.S.1
1 ,2,3-Trichloropropane
0,0,0-Triethylphosphorothioate
sym-Trinitrobenzene
Tris(1-aziridinyl)phosphine
sulfide
Tris(2,3-
dibromopropyl)phosphate
Trypan blue
Uracil mustard
Vanadium pentoxide
Vinyl chloride
Warfarin
Zinc cyanide
Zinc phosphide
Chemical
Abstracts
, No.
79-01-6
75-70-7
75-69-4
95-95-4
88-05-2
93-76-5
96-18-4
126-68-1
99-35-4
52-24-4
126-72-7
72-57-1
66-75-1
1314-62-1
75-01-4
81-81-2
557-21-1
1314-84-7
Ground
Water*
X
X
X
X
X
X
X
X
X
III
X
Surface
Water2
X
X
X
X
X
' X
X
X
"x
X
Soil3
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Gas4
X
X
Air
X
X
X
X
X
* See also 40 CFR 264, Appendix IX.
1 The abbreviation N.O.S. (not otherwise specified) signifies those members of the general class not
specifically listed by name.
2 Applies to the water column only. Additional constituents may be of concern if sediment and/or biota are
to be sampled and subjected to analysis (See Section 13).
s Includes both saturated and unsaturated soils, Some of these are gases at ambient temperature and
pressure which may be present in wet or saturated soils. Degradation as a result of chemical, biological or
physical processes, may result in decreasing concentrations of constituents overtime, and is dependent on
moisture content as well as other factors.
4 Compounds indicated are those which maybe present within a carrier gas (e.g., methane).
B-21
-------
LIST 4
INDUSTRY SPECIFIC MONITORING CONSTITUENTS
REFERENCES FOR INDUSTRY SPECIFIC MONITORING CONSTITUENTS
1. 40 CFR 122, National Pollutant Discharge Elimination System
2. U.S. EPA, Development Document for Effluent Limitation Guidelines and
Standards for the ... Point Source Category.
(Total of 30 Industries)
3. U.S. EPA, 1980, Treatability Manual. Volume I. Treatability Data
4. U.S. EPA Regional Offices for Industry Specific Data.
B-22
-------
LIST 4*
SW-846 Chemical Classifications - See Supplemental Tables
Industrial Category
Auto and Other Laundries ,
Coal Mining
Coal Coating
Copper Forming
Electroplating
Electrical and Electronic
Components
Explosives Manufacturing
Foundries
Gum and Wood Chemicals
Inorganic Chemicals
Manufacturing
Iron and Steel Manufacturing
Leather Tanning and Finishing
Metal Finishing
Nonferrous Metals
Manufacturing
Ore Mining
Organic Chemicals
Manufacturing
Paint and Ink Formulation
Pesticides and Herbicides
2-1
«
«
«
«
»
»
»
»
«
«
«
«
9
9
9
*
«
2-2
'
._ _
2-3
-'
::-.
2-4
,
2-5
-
'
2-6
;
*
'
". -
2-7
-
2-8
" '"
2-9
2-10
'
. ~
i
.
- -
2-11
2-12
.. .
'
-
2-13
-
-
2-14
'
2-15
.
-
-------
LIST 4 (Continued)*
SW-846 Chemical Classifications - See Supplemental Tables
: Industrial Category
Peiroieurn Refining
Pharmaceutical Preparations
Photographic Equipment and
Supplies
Plastics Molding and Forming
Porcelain Enameling
Pulp and Paper Mills
Rubber Processing
Soap and Detergent
Manufacturing
Steam Electric Power Plants
Textile nriiiis
Timber Products
Wood Preserving
2-1
«
*
e
~ 9
«
»
«
2-2
*
»
«
'
. w '
»
2-3
*
e
'
e
2-4
s
«
e
' "
e
»
*
e
2-5
- «
2-6
»
»
«
-
»
w
e
»
2-7
2-8
e
«
0
w
w
' w
2-9
2-10
V
e
£
.
*
*
e
2-11
2-12
V
»
«
*
V
*
2-13
»
' m
i *
»
2-14
V
»
«
:
*
*
2^15
9
»
9
'
*
*
*
V
A "" indicates that one or more constituents within a category are likely candidates for monitoring.
This list does not contain all industries that may be subject to an RFI.
- The constituents within tie categories indicated may not be mutually exclusive. If a chemical category is checked for a particular industry, the
owner or operator maybe responsible for all constituents within the-category, regardless of whether the constituent is contained in other
categories.
-------
SUPPLEMENT TO LIST 4
REPRINTED TABLES FROM TEST METHODS FOR EVALUATING SOLID WASTES:
3RD ED. U.S. EPA SW-846. GPO No. 955-001-0000-1. 1986.
B-25
-------
Table 2-1: Phenols and Organic Acids
Benzole acid
Benzyl alcohol
2-sec-Butyl-4,6-dinitrophenol(DNBP)
4-Chloro-3-methylphenol
2-Chlorophenol
Cresol (methyl phenols)
2-Cyclohexyl-4,6-dinitrophenol
2,4-Dichlorophenol
2,6-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2-Methyl,4,6-dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
Tetrachlorophenols
Trichlorophenols
B-26
-------
Table 2-2: Phthalate Esters
Benzyl butyl phthalate
Bis(2-ethylhexyl)phthalate
Diethyl phthalate
Di-n-butyl phthalate
Dimethyl phthalate
Di-n-octyl phthalate
B-27
-------
Table 2-3: Nitroaromatics and Cyclic Ketones
Dinitrobenzene
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Isophorone
Naphthoquinone
Nitrobenzene
B-28
-------
Table 2-4: Polyaromatic Hydrocarbons
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Chrysene
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenz(a,h)anthracene(Dibenzo(a,h)anthracene)
7H-Dibenzo(c,g)carbazole
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,i)pyrene
Fluoranthene
Fluorene
lndeno(1,2,3-cd)pyrene
3-Methylcholanthrene
Naphthalene
Phenanthrene
Pyrene
B-29
-------
Table 2-5: Chlorinated Hydrocarbons
Benzotrichloride
Benzyl chloride
2-Chloronaphthalene
Dichlorobenzenes
Dichloromethylbenzenes( Dichlorotoluenes)
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclohexane
Hexachlorocyclopentadiene
Hexachloroethane
Pentachlorohexane
Tetrachlorobenzenes
Trichlorobenzenes
8-30
-------
Table 2-6: Base/Neutral
Acenaphthene
Acenaphthylene
Acetophenone
Aldrin
Aniline
Anthracene
4-Aminobiphenyl
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
Benzidine
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzo(a)pyrene
a-BHC
J3-BHC
5-BHC
Y-BHC
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenl phenyl ether
Butyl benzyl phthalate
Chlordane
4-Chloroaniline
l-Chloronaphthalene
2-Chloronaphthalene
4-Chlorophenyl phenyl ether
Chrysene
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dibenz(a,j)acridine
Dibenz(a,h)anthracene
Dibenzofuran
Di-n-butyl phthalate
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichlorobenzene
3,3'-Dichlorobenzidine
Dieldrin
Diethyl phthalate
p-Dimethylaminoazobenzene
7,12-Dimethylbenz(a) anthracene
a-,a-Dimethylphethylamine
Dimethyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Diphenlamine
1,2-Diphenylhydrazine
Di-n-octylphthalate
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin aldehyde
Endrin ketone
Ethyl methanesulfonate
Fluoranthene
Fluorene
2-Fluorobiphenyl
Heptachlor
Heptachlorepoxide
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
lndeno(l,2,3-cd)pyrene
Isophorone
Methoxychlor
3-Methylcholanthrene
Methyl methanesulfonate
2-Methylnaphthalene
Naphthalene
1-Naphthylamine
2-Naphthylamine
2-Nitroaniline
3-Nitroaniline
4-Nitroaniline
Nitrobenzene
N-Nitroso-di-n-butylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosodi prop lam ine
N-Nitrosopiperidine
Pentachlorobenzene
Pentachloronitrobenzene
Phenacetin
Phenanthrene
2-Picoline
Pronamide
Pyrene
1,2,4,5-Tetrachlorobenzene
1,2,4-Trichlorobenzene
Toxaphene
B-31
-------
Table 2-7: Organophosphorous Pesticides
Azinphos methyl
Bolstar (Sulprofos)
Chlorpyrifos
Coumaphos
Demeton
Diazinon
Dichlorvos
Dimethoate
Disulfoton
EPN
Ethoprop
Fensulfothion
Fenthion
Malathion
Merphos
Mevinphos
Monochrotophos
Naled
Parathion
Parathion methyl
Phorate
R o n n e I
Stirophos (Tetrachlorvinphos)
Sulfotepp
TEPP
Tokuthion (Prothiofos)
Trichloronate
B-32
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Table 2-8: Organochlorine Pesticides and PCB'S
Aldrin
a-BHC
p-BHC
5-BHC
Y-BHCl (Lindane)
Chlordane
4 , 4 ' - D D D
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlorepoxide
Kepone
Methoxychlor
Toxaphene
PCB-1016(Aroclor-1016)
PCB-1221(Aroclor-1221)
PCB-1232(Aroclor-1232)
PCB-1242(Aroclor-1242)
PCB-1248(Aroclor-1248)
PCB-1254(Aroclor-1254)
PCB-1260(Aroclor-1260)
B-33
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Table 2-9: Chlorinated Herbicides
2,4-D
2,4-DB
2,4,5-T
2,4,5-TP (Silvex)
D a I a p o n
Dicamba
D i chIo ro p ro p
Dinoseb
M C P A
MCPP
B-34
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Table 2-10: Halogenated Volatiles
Benzyl chloride
Bis(2-chloroethoxy)methane
Bis(2-chloroisopropyl)ether
Bromobenzene
Bromodichloromethane
Bromoform |
Bromomethane
Carbon tetrachloride
Chloracetaldehyde
Chloral
Chlorobenzene
Chloroethane
Chloroform
1-Chlorohexane
2-Chloroethyl vinyl ether
Chloromethane
Chloromethyl methyl ether
Chlorotoluene
Dibromochloromethane
Dibromomethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1 -Dichloroethylene(Vinylidene chloride)
trans-1,2-Dichloroethylene
Dichloromethane
1,2-Dichloropropane
1,3-Dichloropropylene
1,1,2,2-Tetrachloroethane
1,1,1,2-Tetrachloroethane
Tetrachloroethylene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Trichloropropane
Vinyl chloride
B-35
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Table 2-11: Non-halogenated Volatiles
Acrylamide
Diethyl ether
Ethanol
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone (MIBK)
Paraldehyde (trimer of acetaldehyde)
B-36
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Table 2-12: Aromatic Volatiles
Benzene
Chlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Ethyl benzene
Toluene
Xylenes (Dimethyl benzenes)
B-37
-------
Table 2-13: Acetonitrile, Acrolein, Acrylonitrile
Acetonitrile
Acrolein (Propenal)
Acrylonitrile
B-38
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Acetone
Acrolein
Acrylonitrile
Benzene
Bromochloromethane
Bromodichloromethane
4-Bromofluorobenzene
Bromoform
Bromomethane
2-Butanone (Methyl ethyl
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
Dibromomethane
1,4-Dichloro-2-butane
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichlrorethene
trans-1,2-Dichloroethene
Table 2-14: Volatiles
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
1,4-Difluorobenzene
Ethanol
Ethylbenzene
Ethyl methacrylate
2-Hexanone
lodomethane
Methylene chloride
ketone) 4-Methly-2-pentanone
Styrene
1,1,2,2-Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Trichlorofluoromethane
1,2,3-Trichloropropane
Vinyl acetate
Vinyl chloride
Xylene
B-39
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Table 2-15: (Partial): Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
B-40
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RFI GUIDANCE FEEDBACK QUESTIONNAIRE
Commenter
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1. Does the format of the guidance lend itself to easily finding specific topics of
concern when needed? (Please provide any suggestions you may have to
improve the format).
2. Does the guidance provide adequate information on how to develop an RFI
Work Plan? (Provide suggestions if applicable).
3. Are the technical methods in the guidance up-to-date? Are there other technical
methods that should be added?
4. Does the guidance provide sufficient examples to perform investigatory tasks?
5. Other comments or suggestions?
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