United States
Environmental Protection
Office of
Solid Waste
Washington DC 20460
October 1986
SolkJ
&EPA
RCRA
Facility Assessment
Guidance
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RCWA
Permits and S t * t R Programs n1v1s1o n
Office of So! id Waste
U.S. Environmental Protection Agency
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Ihp document was prpp.i rnd by the joint efforts of the following
o
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TABLE OF CONTENTS
Page
CHAPTER ONE - INTRODUCTION
I. OBJECTIVES AND SCOPE OF THE RCRA CORRECTIVE
ACTION PROGRAM 1-1
II. PURPOSE OF THE RFA 1-2
III. SCOPE OF THE RFA 1-3
IV. TECHNICAL APPROACH 1-5
V. ORGANIZATION OF THIS DOCUMENT 1-9
CHAPTER TWO - CONDUCTING A PRELIMINARY REVIEW
INTRODUCTION 2-1
A. Purpose 2-1
B. Scope 2-1
C. Product 2-2
II. GATHERING PR INFORMATION 2-2
A. Written Information and Documents 2-3
B. Meeting with Relevant Individuals 2-5
C. Collecting Additional Information 2-6
III. EVALUATING PR INFORMATION 2-6
A. Investigating Facility Waste Generation
Processes 2-6
B. Identifying SWMUs and Other Potential
Releases of Concern 2-7
C. Evaluating the Facility's Release Potential 2-8
IV. COMPLETING THE PRELIMINARY REVIEW 2-11
A. Identifying Significant Data Gaps 2-12
B. Focusing the Visual Site Inspection and
Samp ling Visit 2-12
C. Documenting the Preliminary Review 2-13
CHAPTER THREE - CONDUCTING A VISUAL SITE INSPECTION
INTRODUCTION 3-1
A. Purpose 3-1
B. Scope 3-1
C. Product 3-1
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Page
II. PLANNING THE VISUAL SITE INSPECTION 3-2
III. CONDUCTING THE FIELD ACTIVITES DURING THE VSI 3-2
A. Obtaining Visual Evidence of Unit
Characteristics 3-4
B. Obtaining Visual Evidence of Waste
Characteristics 3-4
C. Obtaining Visual Evidence of pollutant
Migration Pathways 3-4
D. Obtaining Visual Evidence of Release 3-5
E. Obtaining Visual Evidence of Exposure
Potential 3-5
IV. IV. DETERMINING THE NEED FOR FURTHER ACTION
DURING THE RFA 3-5
A. Determining the Need for a Sampling Visit 3-6
B. Determining the Need for Interim Measures 3-7
C. determining the Need for a Remedial
Investigation 3-7
CHAPTER FOUR - CONDUCTING THE SAMPLING VISIT
I. INTRODUCTION 4-1
A. Purpose 4-1
B. Scope 4-1
C. Product 4-2
II. DEVELOPING A SAMPLING VISIT PLAN 4-2
A. Determining the Need for Sampling at Facilities 4-2
B. Developing a Sampling Plan 4-4
Ml. PREPARING FOR THE SAMPLING VISIT 4-8
A. Gaining Facility Access 4-9
B. Community Relations 4-10
C. Preparing a Safety Plan 4-1o
D. EPA Oversight of Owner/Operator Sampling
Act i v i t i es 4-11
IV. CONDUCTING THE SAMPLING VISIT 4-11
A. Preliminary Site Activities 4-11
B. Samp I ing Procedures 4-12
C. Photography 4-12
D. Logbook 4-13
E. Sample Shipment/Sample Analysis 4-14
F. Decontamination/Demobilization 4-14
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Page
V. FINAL RFA RECOMMENDATIONS FOR FURTHER ACTION 4~14
A. Making RFA Release Determinations 4-14
B. Making Recommendations for Each SWMU or
Group of SWMUs 4-15
VI. FINAL RFA PRODUCT 4-18
CHAPTER FIVE - GROUND WATER
I. INTRODUCTION 5-1
A. Purpose 5-1
B. Scope 5-1
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL SITE
INSPECTION OF GROUND-WATER RELEASE POTENTIAL 5-2
A. Unit Characteristics 5-2
B. Waste Characteristics 5-7
C. Pol Iutant Migration Pathways 5-9
D. Evidence of Release 5-9
E. Exposure Potential 5-1o
F. Determining the Need for Additional
Sampling Information 5-11
III. COLLECTING ADDITIONAL SAMPLING INFORMATION
IN THE SV 5-14
A. Sampling of Existing Ground-Water
Mon itori ng We I Is 5-14
B. Soi I Sampl ing 5-17
C. Soil Gas Monitoring 5-17
D. Electromagnetic Conductivity Mapping 5-19
E. Sampling of Domestic Wells 5-20
F. Installation Of New Monitoring Wells 5-20
IV. MAKING GROUND-WATER RELEASE DETERMINATIONS 5-21
CHAPTER SIX - SURFACE WATER
I. INTRODUCTION 6-1
A. Purpose 6-1
B. Scope 6-1
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Page
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL SITE
INSPECTION OF RELEASES TO SURFACE WATER 6-2
A. Unit Characteristics 6-2
B. Waste Characteristics 6-5
C. Pollutant Migration Pathways 6-6
D. Evidence of Release 6-8
E. Exposure Potential 6-9
F. Determining the Need for Additional Sampling 6-10
III. COLLECTING ADDITIONAL SAMPLING INFORMATION IN THE SV 6-12
A. Surface Water Sampling 6-13
B. Sludge and Sediment Sampling 6-14
C. Soi I Sampl ing 6-14
D. Run-Off Sampling 6-14
IV. MAKING SURFACE WATER RELEASE DETERMINATIONS 6-15
CHAPTER SEVEN - AIR
I. INTRODUCTION 7-1
A. Purpose 7-1
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL
SITE INSPECTION OF AIR RELEASE POTENTIAL 7-2
A. Unit Characteristics 7-2
B. Waste Characteristics 7-6
C. Pollutant Migration Pathway 7-13
D. Evidence of Release 7-13
E. Exposure Potential 7-14
F. Determining the Need for Additional
Sampling Information 7-15
OBTAINING ADDITIONAL SAMPLING INFORMATION 7-16
MAKING RELEASE DETERMINATIONS 7-18
CHAPTER EIGHT - SUBSURFACE GAS
I. INTRODUCTION 8-1
A. Purpose 8-1
R. Scope 8-1
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL SITE
INSPECTION OF SUBSURFACE GAS RELEASE POTENTIAL 8-2
A. Unit Characteristics 8-2
B. Waste Characteristics 8-5
C. Pollutant Migration Pathways 8-9
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Page
D. Evidence of Release 8-10
E. Exposure Potential 8-10
F. Determining the Need for Additional
Sampling in the SV 8-11
III. COLLECTING ADDITIONAL INFORMATION IN THE SV 8-12
IV. MAKING SUBSURFACE GAS RELEASE DETERMINATIONS 8-14
CHAPTER NINE - SOILS
I. INTRODUCTION 9-I
A. Purpose 9-1
B. Scope 9-1
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL
SITE INSPECTION OF RELEASES TO SOILS 9-2
A. Unit Characteristics 9-2
B. Waste Characteristics 9-5
C. Pollutant Migration Pathways 9-6
D. Evidence of a Release 9-7
E. Exposure Potential 9-7
F. Determining the Need for Additional Sampling 9-8
III. COLLECTING ADDITIONAL SAMPLING INFORMATION
IN THE SV 9-10
A. General Information on Selecting Sampling
Locat i ons 9-10
B. Sampling Methodology and Evaluation of Results 9-11
IV. MAKING A RELEASE DETERMINATION 9-12
APPENDIX A - SAMPLE RFA REPORT OUTLINE
APPENDIX B - RFA INFORMATION SOURCES
APPENDIX C - SAMPLE LETTER OF REQUEST FOR OWNER/OPERATOR
INFORMATION
APPENDIX D - GAINING FACILITY ACCESS WHEN DENIED
APPENDIX E - PHYSICAL AND CHEMICAL PARAMETERS FOR
CONSTITUENTS OF CONCERN
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LIST OF EXHIBITS
jor Factor": t
r* ! Ranking nf :«,,M I" -5* *>n t 1 ^ 1 for rirotint! WAter
Releases A r> .< M p • h ^ n i s m «; of Release 5-4
" - 'J M o n i t o r i n q w n n i n « 4 t: i i) n 5 - 1 £
^ ^ r, hpckllst f •? r- ri r t\>«N(t y fl tp r R ft 1 ea s es 5-2?
•"'•'. Ranking of :>nU P.ii^ntial for Surface Water
R^lsase and MP r:h a n ' sms of Release • 6-4
" - ? Checklist for stirf^rp Wat pr Release 6-17
"-1 Unit Potential for Air Releases and
Hethan1$m$ofRe1ease 7-4
~ -'* Parameters anrt Measures for Use In Evaluating
Potential Air Re1p*5t>s n? Hazardous Waste
Constituents 7 _ j
- - 1 Hazardous Constituents of Concern as Vapor •
Rel eases 7-8
7 --4 Hazardous Constituents of Concern as
•Part leu late Releases 7- 10
7-5 Checklist for Air Release's 7-20
3-1 Unit Potential for .Stihsurf ace Gas Releases
and Mechanisms of 'Release 8-4
3-2 Subsurface Ras Generation /Migration ie a
Landfill " 8_6
R-3 Suhsurface fia? Generation /Migration from
Units Closed at -Landfills ' 8-7
fl-4 Cherklfst for iiihsiirfacp fias Releases fl-15
9-1 Ranking •; f Unit Potential for Soil Release
ai'dMerhanitfflcnfRplpase q«3
I': h o r t 1 i s t fMrRplnflSPstoSoH'; 9-14
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CHAPTER ONF
c now
' OBJECTIVES AND SCOPF OF THE RCRA CORRECT I VF ACTION PROGRAM
Ihe primary objective nf the RCRA corrective action program
< -". * f • r. lean up releases M h,-»?<, t i v y-, , These new authorities are:
15 §3004 (u ) - Correct] vfc Actl on for J^jHi^iiuj nj Rejea^fes
Requires that any permit issued after November 3, 1984,
require corrective a < ; 1 1 o n for all releases from solid
waste management units at the facility. The provision
also requires that owner/operators demonstrate financial
assurance for any re quired corrective action, and allows
schedules of compliance to be used in permits where the
corrective action cannot be completed prior to. permit
issuance.
|3Q08(h ) - jnter 1 m 5 1 B t us C Q££fe c 1 1 ye A c t i on Orders
Provides authority to issue enforcement orders to com.pel
corrective .action or other response measures at Interim
.status facilities, and to take civil action against
facilities for appropriate re lief.
§3004 (y ) - Cor rective Action Beyond the Facility Boundary
Directs EPA to issue regulations requiring corr-ective
action beyond the facility boundary where necessary tn
protect human healtSi and the environment, unless the
owner/operator can demonstrate that he Is unable to
obtain the necessary permission, despite his best efforts
Until such regulations are promulgated, corrective action
orders can be issued to require the necessary corrective
a r t i o n „•
These authorities change the focus of the RCRA corrective
action program from detecting dnd correcting future releases from
regulated units to cleaning up problems resulting from past waste
management practices at RCRA facilities. Prior to passage of the
H S W A ^ EPA's authority to require corrective action for releases
of ha/ardo'.js constituents under RCRA was limited to ground water
releases from units that were covered by RCRA perm-Its. Part ?64,
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Subpart F provided the vehicle for requiring corrective action at
these "regulated units*. The post-HSWA program extends RCRA
authority to releases to all media and all units at RCRA facili-
ties and encourages the use of other authorities, as needed or
appropriate, to help achieve corrective action objective* at
those facilities.
The RCRA corrective action program consists of three phases:
1. The RCRA Facility Assessment (ftFA) to identify releases
or potential releases requiring further investigation,
?. The RCRA Facility Investigation (Rrl) to fully charac-
terize the extent of releases.
3. Corrective Measures (CM) to determine the need for and
extent of remedial measures. This step Includes the
selection and implementation of appropriate remedies
for all problems identified.
This guidance document describes the first phase of this
process and outlines procedures and criteria EPA and State
personnel should follow in conducting RFAs'at RCRA facilities.
1 I. PURPOSE OF THE RFA
The RCRA facility Assessment is a three-st.age process for:
o Identifying and gathering information on releases at
RCRA facilities;
o Evaluating solid waste management units (SWMUs) and other
areas of concern for releases to all media and regulated
units for releases to media other than ground water;
o Making preliminary determinations regarding releases of
concern and the need for further actions and Interim
measures at the facility; and
o Screening from further investigation those SWMUs which
do not pose a threat to human health or the environment.
During the RFA, EPA or State investigators will gather information
on SWMUs and other areas of concern at RCRA facilities. They will
evaluate this information to determine whether there are releases
that warrant further investigation or other action at these
facilities. Upon completion of the RFA, Agency personnel should
have sufficient information to determine the need to proceed to
the second phase (RFI) of the process.
All three steps of the RFA require the collection and analy-
sis of data to support initial release determinations:
1-2
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o The preliminary review (PR) focuses primarily on eval-
uating existing Information, such as Inspection reports,
permit applications, historical monitoring data, and
Interviews with State personnel who are familiar with
the facility.
o The visual site Inspection (VSI) entails the on-site
collection of visual information to obtain additional
evidence of r i ease ,
n The sampling visit (SV) fills data gaps that remain upon
completion of the PR and VSI by obtaining sampling and
field data .
Ill, SCOPE OF THE RFA
Fh i >,*. section addresses:
o Releases covered in the RFA;
o Relation of the RFA to the CERCLA PA/SI;
o The extent and role of sampling In the RFA; and
o Roles and responsibilities.
Rj^ eases Coyered In the RFA
The RFA should Identify all areas.of potential release at
RCRA facilities and Include the Investigation of releases to all
media: air, surface water, ground water, and soils. However,
ground water releases from regulated units are not addressed 1n
the RFA, EPA and/or State Investigators should use the full com-
plement of RCRA authorities to secure appropriate action. These
include §3004(u). §3008(h), §3004(v), §3013 and §7003, If these
authorities are not sufficient to compel the desired action,
Agency Investigators may wish to use other authorities, such as
CERCLA §106 or TSCA §7 authorities and should consult with EPA or
State offices responsible for administering these programs.
The HSWA §3Q04(u) provision focuses on Investigating releases
from SWMUs at RCRA facilities. Solid waste management units are
def1ned as:
o Any discernible waste management unit at a RCRA facility
from which hazardous constituents might migrate, Irre-
spective of whether the unit was Intended for the manage-
ment of solid and/or hazardous waste.
The SWMU definition includes:
o Containers, tanks, surface impoundments, waste piles,
land treatment units, landfills, Incinerators, and
1-3
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underground injection wells, Includl ng those unl ts def
as "regulated units" under:
o Recycling units, wastewater treatment units and other
units which EPA has generally exempted from standards
applicable to hazardous waste management units.
o Areas contaminated by "routine, systematic, and deliber-
ate discharges" from process areas.
The definition does not Include accidental spills from production
areas and units 1n which Bastes have not been managed (e.g.,
product storage areas).
The RFA will not routinely address releases that are per-
mitted cr required to be permitted under other environmental
programs, or contamination resulting from permitted discharges.
W'nere such discharges are of concern, RCRA personnel should refer
the case to the original permitting authority. If that authority
does not take appropriate action, EPA can exercise Its authority
under §3004(u), §3004 ( v } , :§3008 (h ) or §3013. Where the RFA
identifies contami na ti on requiring further Investigation, RCRA
staff should work on a case-by-case basis with the Regions and
other EPA permit programs to develop a solution to the contami-
rt a t 4 on probl em .
The RFA does address rele"«*es from SWMUs to media other
than the one covered by the unit's discharge permit. For example,
EPA can use §3004{u) or §3008(h) to control the release of volatile
organic compounds from NPDES-pertnl tted wastewater treatment units
where there 1s cause for concern.
Relation of the RFA to the CERCLA PA/SI
The CERCLA PA/SI and the RFA differ in two important respects.
First, the CERCLA PA/SI focuses on the potential for offslte
exposures from releases, while the RFA focuses on Identifying
specific releases at RCRA facilities and considers the potential
for offslte exposures primarily in determining whether to require
Interim corrective
Second, the CERCLA HA/SI was developed primarily as a method
for scoring facilities to determine whether they should be on the
CERCLA National Priority List (NPL). The RFA does not formally
rank or prioritize facilities. The RCRA program may use the
facility management planning (FMP) process to estab?}sfc State and
Regional priorities at and among RCH* factl^t^es. TVie FWPs
provfde A framewrt far determining specific permitting
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Extent and Rote of Sampling
. 'A purposely designed the RFA to be limited in scope.
This guidance establishes a framework to assist £PA Investigators
in making preliminary release determinations that are largely
based on eMlstlng information and best professional judgment. The
framework emphasizes the need to focus data collection and analysis
efforts (1»e., sampling data} on those data that are required to
support specific permit or enforcement order conditions. In
general, the stronger the case t^at the Investigator must make
to compel an owner/operstor to conduct an RPI or to convince the
public that a SWMU does not pose i threat, the greater the amount
of Information he/she will need to collect 1n the SV.
The Agency recognizes that sampling netds will differ on a
case-by- ase basis. The extent of sampling will dipend on the _
amount and quality of Information gathered 1n the PR and VSI, the
investigator's professional Judgment regarding the amount of In-
formation necessary to support an initial release determination»
and the degree of owner/operator cooperation.
Rre j>jpj) n §jjaJJr1 J|,: foj^ Jjpj d y c t.|||JLJh er:.JJF A
As the program 1s currently set up, EPA md/or the Statts
are responsible for conducting RFAs. Became of the subjective
nature of thcs* Investigations, the Agency btl1tv*s that it 1s
appropriate for a regulatory agency to conduct the RFAs. These
initial release determinations will provide the basis for requiring
a number of potential follow-on activities ranging in scope from
no further action ,to a full corrective action program. EPA and
the States may use contractors to assist them In conducting these
Investigations, but the regulatory agency retains overall respon-
sibility for the RF* decisions.
In some Instances, 1t miiy be appropriate for the facility
owner/operator to perform certain sampling activities. EPA
and/or the State should make such determinations on a case-by-case
basis and should carefully review and approve plans developed by
owner/operators and oversee field activities conducted by the
owner/operator,
IV, TECHNICAL APPROACH
All three steps of the RFA r*nu1re the Investigator to ex-
amine extensive data on the facility and specific units at the
facility. These data can generally be divided into five categories
0 Unit characteristics;
o Waste characteristics;
o Pollutant migration pathways;
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o Evidence of release; and
o Exposure potential .
Exhibit 1-1 provides a matrix of these categories and the specific
factors that Investigators need to consider 1n each category.
The Investigator will need to apply his/her best professional
judgment 1n examining these factors, how they Interact, and their
effects on the likelihood of a release and Its significance.
Exhibit 1-2 outlines the types of Information In each cate-
gory that Investigators are likely to obtain during each of the
three steps 1n the RFA. In general, during the PR, the Investi-
gator will examine documents and other written materials to
obtain information on the facility's location, potential environ-
mental receptors, characteristics of the waste handled at the
facility as a whole.and managed 1n SWMUs , the design and operating
features of the SWMUs themselves, and evidence of past releases.
This Information will assist the Investigator In determining
which media and migration pathways are of concern and why. The
investigator will supplement this Information with additional
evidence gathered during the VSI and samples taken during the SV.
Specific factors 1n each category that must be considered
will vary depending on which medium 1s of concern. For example,
land-based units are more likely to have ground-water releases
than aboveground units; surface Impoundments are more Hkily to
have air releases than 1 an
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EXHIBIT 1-1
WUOR FACTORS TO CONSIDER IN CONDUCTING RFfts
Unit
Characteristics
• type of unit
design features
operating prac-
tices (past and
present)
period of
operation
age of unit
location of
unit
general physical
conditions
method used to
close the unit
Waste
Characteristics
type of waste
place in the
j unit
migration and
dispersal char- {
acteri sties of
the waste
toxfcalRgical
characteristics
physical and
chemical
characteristics
Migration
Pathways
facility's geo-
logic setting
facility's hy-
drogeo logic
setting
atmospheric
conditions
topographic
characteristics
Evidence of
Release
prior inspec-
tion reports
1
citizen
complaints
raonitoring data
visual evidence
e,g., discolored
soil, seepage,
discolored
surface water or
runoff.
other physical
evidence, e.g.,
fish kills,
worker illness,
odors
saopling data
Exposure
Potential
proximity to
affected pop-
ulation
proximity to j
sensitive
enri rorwents
likelihood of
migration to
potential
receptors
„ !
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o Identified all potential releases of concern;
o Identified all SWMUs;
o Determined which areas need further Investigation and
and collected sufficient Information to focus these
Investigations;
o Determined which areas require Interim measures;
o Screened out releases that do not require any further
Investigation; and
o Referred permitted releases to other authorities,
as appropriate.
Upon completion of the RFA, the Investigator prepares a
report summarizing his/her findings. The report should Integrate
the findings from all three steps 1n the RFA and Include a de-
scription of the facility and Its waste management practices,
release Information for all SWMUs or groups of SWMUs and other
areas of concern, Campling plan and results, and final release
determinations and recommendations. This report should clearly
indicate those areas of the facility that require further Inves-
tigation In a RFt and should contain Information to foeus these
investigations. A sample outline of an RFA report Is presented
1n Appendlx A ,
Conducting an RFA cart present an opportunity to gather
Information on a facility which may be useful for purposes other
than making RFA determinations. Regions or States may choose,
for example, to collect certain data on facility characteristics
and other site-specific environmental data as a means of estab-
lishing programmatic priorities for corrective action. Appendix
F provides a listing of some example data elements which could be
used for such purposes.
V. ORGANIZATION OF THIS DOCUMENT
This document contains nine chapters. The second chapter
describes the PR process, the third chapter describes the VSI,
and the fourth chapter explains the SV. In addition, there are
five technical chapters that apply the technical approach out-
lined 1n chapters two, three and four to the various media of
concern.1 ground water, surface water, air, subsurface gas and
soil .
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CHAPTER TWO
CONUUCTINQ A PRELIMINARY REVIEW
I. INTRODUCTION
A. Purpose
This chapter describes how to conduct a preliminary review
(PR), thi first itep in the RCRA Facility Assessment (RFA) pro-
cess for Identifying releases or potential releases it RCRA
facilities under the RCRA corrective action requirements. The
PR serves two primary purposes;
(1) To gather and ev.iyate existing Information on facili
ties 1rt order to identify and characterize potential
§nd
(2) To focus the activities to be conducted In the second
and third steps of the RFA, the visual site Inspection
(VS1) and the sampling visit (SV).
B. Scope
i mm miiiiinf niuu ..n.
During the PR, IPA personnel will e aluate existing docu*
merits and, speak with relevant Individuals («*g.t RCRA Inspectors,
state and Federal permitting staff, ate/) In order to Identify
areas at i facility which may be releasing haiarduus waitei or
hazardous constituents posing a potential threat *io human health
and the environment. The PR will consider Information an the
entire facility, and will not be limited tc collecting and eval-
uating Information covering the RC! A»regu1ittd afiis at the
facility, In particular, the Investigator will Idinilfy and
gather Information oft SHwUs and other areas when wastes have
been managed at the facility.
While the scope of the PR win focus on Identifying and
evaluating releases resulting from waste management activities,
the Investigator should consider documents he/she flrtdi which
provide Information on releases at the facility which may be
beyond the scope of the RCRA corrective action authorities,
These could Include releases subject to Investigation and remedi-
ation under CERCLA or TSCA authorities,
The scope of the PR includes Investigating release potential
to all environmental media at the facility (with thi exception
of ground-water releases from regulated un1ts)i
o Ground water;
o Surface water;
p hi r ;
o Soils*, and
o Subsurface ( gas ) .
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At eotttplix facilities with many SKMUs, 1t may he more
practical to evaluate groups of similarly located or designed
S^MUs rather thin characterizing each unit separately, Addi-
tionally, Investigators should not focus solely on releases
from SHMUSi but should examine the full facility for evidence
of spills and/or other releases resulting from waste management
act1v1t1ts which may not fit the definition of a SWHU release
(see definition of a SWMU on page 1-4),
This chapter describes how to conduct a. PR at RCRA facili-
ties by:
(I) Collecting PR Information;
(2) Evaluating PR Information; and
(3) Completing the PR,
C. Product
At the end of the PR, the Investigator will summarize the
findings of the PR. Ho/she should document the Information
sources evaluated, describe t.he potential releases of concern
identified at the facility (especially all SWHUs), and mike
recommendations that will focus subsequent activities In the
VSI and the SV. The results of the PR will serve as the founda-
tion of the RFA report, which w111 be revised at tha end of the
VSI and finalized following the SV» A lample outline for an RFA
report Is Included as Appendix A,
II. RATHERINI PR INFORMATION
The first step 1n the PR Involves collecting Information on
a facility that will provide evidence of Its potential for release
The success of the PR will depend to a great extent dn the Inves-
tigator's ability to collect relevant 1 nfarmat10ri» A PR may pro-
vide misleading results when significant sources of Iftfbrmitlon
are not considered fe*g,» enforcement document',! describing known
releases, relevant sampling or monitoring date, etc,)* EPA
should plan each PR to ensure that all relevant sources of Infor-
mation pertaining to a facility are examined. Gathering riita in
the PR will usually Involvet
(t) Collecting documents and other written reports;
(2) Meeting with relevant Individuals; »rd
(3) Collecting additional Information from the
o^ner/operator,
The PR focuses on evaluating Information In the fivi basic
categories presented 1n the RFA Information matrix (Exhibit 1*1).
2-2
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The matrix Illustrates the types of Information In each category
(unit chifactafistles, waste characteristics, pollutant migra-
tion pathwaySj evidence of release* and exposure potential) which
should be evaluated during the PR, It should be noted* however,
that 1t fs difficult to obtain complete data for any of the five
categories during the PR, and that the VSI and SV will provide
additional Opportunities to collect information during the RFA.
A. Writ ten Info rm a tIon and D o c u me n13
This section briefly summarizes those data sources which
have been found to be most useful 1n conducting PRs to date. A
detailed discussion of all potentially relevant data sources is
Included as Appendix B to this document.
Four basic RCRA file sources and several additional RCRA
documents typically contain the most useful information during
the PR :
(1) RCRA permit applications;
(2) Facility SWMU response (RSI #3);
(3) RCRA inspection reports;
(4) RCRA exposure information reports; and
(5) Additional RCRA sources.
Brief discussions on each ui these sources follow.
1 * Permit Appi1 cations
Part A and 0 permit applications or closure plans are avail-
able for all facilities in the permit pipeline arid addressed
under the corrective action program,£/ Although owner/bperatcrs
develop these applications to support permitting or closure of
regulated units, they will usually contain information on other
areas of the facility relevant to the RFA.
Part A permit applications provide information on the wastes
being treated, stored, and/or disposed 1n the regulated units at
a facility. These forms can be useful 1n identifying the wastes
of concern at the facility, although 1t should be noted that the
wastes disposed in old SWMUs may have different characteristics
than those currently disposed In regulated units, due to changes
In facility production processes or changes of ownership. The
Part A will often provide a scale drawing showing the location of
all past treatment, storage, and disposal areas (§270.13(h)),
which cart be useful 1n Identifying SWMUs and other areas of
concern.
V The proposed Codification Rule of March 28, 1986 1ncorpor<
ates ^SI #3 Information (described above) Into permit application
requl rements.
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A land disposal Part B permit application provides extensive
hydrogeol ogle Information related to the surfldat aquifer at a
facility, Including a description of the facility's ground-water
monitoring system. This Information 1s useful for Identifying
ground-water pollutant migration pathways and prior releases from
SWMUs at land disposal facilities. However, this information 1s
not likely to be available for storage and treatment facilities.
2 • SHMU Response (RSI .,3 Submission)
The ReauthoH zat 1 on Statutory Interpretation (RSI #3) Issued
hy EPA Headquarters required the EPA Regional Offices to request
owner/operators of RCRA facil1tier to submit data on each SWMU at
their facilities. The data owner/operators submitted In response
to this request 1s usually helpful for Identifying SWMU* at a
facility. However, many submissions have been found deficient,
and RCRA \ nvest1gatbrs should not assume that these submissions
accurately identify all of a facility's SWMUs. Other sources,
such as compliance inspection reports and the VSI should be used
to verify and augment the information contained in the SWMU
response.
3, Comp11 ance Inspectign Reporfts/I n fQrmat1 an
TVom Ehtorernehf ITrtie rs " "
RCRA Inspection reports will often provide extensive Infor-
mation on facility waste generation and handling practices, old
and new waste management units, and prior releases at the facility.
They mat also describe migration pathways and exposure points.
4. Exposure Information Report
Only facilities seeking permits for landfills and surface
impoundments are required to submit exposure Information* These
submissions provide Information on all five categories Ifi the RFA
information matrix (Exhibit 1-1). These reports can be Useful 1n
identifying pollutant migration pathways from the facility to
potential exposure points, and may also discuss the likelihood of
human exposure to hazardous constituents.
5. Additional R C R A 5 ou r c e s
o Biennial Report (§265.75) -- The biennial report, prepared
by the owner/operator and submitted to the Regional
Administrator, provides a description and the quantities
of each hazardous waste received during the previous year,
and the method of treatment, storage, or disposal for
each waste.
o Operating Log (§265.73) -- The facility operating log
provides a map displaying the location and quantities of
wastes disposed throughout the facility. It also provides
reports of all incidents that required Implementation of
the Facility Contingency Plan.
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o RCRA Masts Manifest (§265.7)) '-- The manifest will provide
details on all wastes received at the facility after
November 18, 1380. Facilities are only required however,
to retain manifest for three years.
o Notice to Local Authority (§265.14) -- The owner/operator,
within 90 days after closure of a disposal unit, must
submit to the local land authority and the Region records
of the locations and quantities of wastes within a closed
tfnlt. The owner/operator must also provide descriptions
of the types, locations, and quantities of wastes In
units closed before promulgation of the Part 265 regula-
tions ,
fi* Other Squrcej
Many other sources can provide useful Information for evalu-
ating the likelihood of releases at a facility. After the RCRA
sources outlined above, these are Hkely to contain the most
valuable Information:
o NFDES and CAA permits and permit applications;
o CERCLA PA/SI Repo-ts;
o Installation Restoration Program (1RP) Reports;
o MRS Documentation;
o CERCLA JU/FS Studies;
o CERCLA 103(c) Notifications;
o Aerial Photographs;
o Other Federal /State Agencies; and
o TSCA/OSHA/NPDE5 Inspections.
A number of other sources may also provide some useful Informa-
tion, although they will be needed less often:
o GEMS (Sraphlcal Exposure Modeling System)?
o State/Local Mall Permit Offices;
o Municipal /County/City Public Health Agencies;
o Local Hell Drillers;
o State /County Road Comml ssl ons -,
o Utilities;
o Local Airports/Weather Bureaus;
o Naturalists/Environmental Organizations;
o Facility Employees;
o Colleges/Universities; and
o Interviews with Local Residents.
It will not be necessary to look at each of these sources 1n at1
situations, but they can be examined as appropriate to help fill
Information gaps. All the data sources listed above are described
more fully In Appendix H.
!lS™Hll^
It will be useful to meet with personnel from Sta> \ agencies
and other EPA program offices (e.g., NPOES permitting program) In
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the Initial stages of the PR. Other EPA permitting programs may
have considerable historical knowledge of a facility, Including
Information on 5WMU releases, Instances of non-qompl I ance » facility
waste generation practices, and Inspection reports. Early contact
with these groups can help ensure that all relevant Information
1
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The 'allowing example Illustrates the bentflts of Investiga-
ting a facility's waste generation processes. A secondary lead
smelting facility elostd several surface Impoundments that were
orglnally part of an NPDES wastewater treatment process. The
Impoundments were clean closed by excavating to a depth determined
by the eofltentratlon of lead 1n the soil. The facility stated
that lead was the only constituent of concern 1n these units.
Curing the PR, EPA Investigated the facility's production
processes and found that several other metals such as cadmHrn,
nickel, antimony, and barium might be mixed with the lead
wastes. Based qn this Information, EPA took soil samples for
f*ach of these other constituents of concern.
«. Idfnt1f|1nq SHMUs and Other Potential Releases of Concern
Once the Investigator has gained an understanding of the
facility's overall waste generation and management activities*
he/she should locate all areas with potential releases of concern
on a map of tht facility. The map should Include all SUMUs Iden-
tified In tht RSI 13 SWMU response, SWMUs described In other
documents, and other potential releases of concern, e.g., spills
of hazardous waste or constituents from waste management activi-
ties. In addition, the Investigator should locate on the facility
m*p other potential releases of concern which may be beyond the
scope of the RCRA authorities.
The facility map will be an extremely useful document
throughout the RFA, especially when conducting the VSI and the
sv, in addition to locating SWMUs, It will often be possible
to Idtntlfy relevant migration pathways and potential exposure
points (e.g., rivers and nearby housing) on this nap. Additional
releases of concern can be added to the map when Identified at
later stages 1n the RFA* particularly the VSI,
As discussed 1n the Introduction, the definition of a SWMU
Includes recycling units, wastewater treatment units (such as
those regulated under NPDES), and other units which EPA has"
generally exempted from P.CRA permitting standards. Each of
these units Identified at a facility should be located on the
facility map as a SWMU. Regulated land disposal units are also
treated as SWMUs, since they will be Investigated for releases
to media other than ground water 1n the RFA,
Several Information sources will be especially useful,whet
Identifying SWMUs and other releases of concern 1n addition to
thi* RSI 13 submission. Historical aerial photographs, such as
those available from EMSL or EPIC, way reveal the presence of
past waste management areas which have become overgrown or
otherwise hidden. In some cases, closed landfills and surface
Impoundments cannot be distinguished from ordinary open fields
and historical aerial photographs can help Identify these units.
Appendix 8 provides a more detailed discussion on obtaining and
evaluating aerial photographs.
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C. Eva 1 u a 11 ng the Fac 111 ty' s R e 1 ease p..oternit_iaj_
Once the Investigator has Identified potential releases of
concern at the facility, he/she should determine the likelihood
of release at each location by evaluating information gathered
in the Initial steps of the PR. It will seldom be possible to
determine from one document that a SWMU has released hazardous
wastes or constituents. In most cases, the Investigator will
have to deduce the likelihood that a release of concern has
occurred by evaluating Information from numerous sources covering
the five categories of Information presented In Exhibit 1-1: unit
characteristics, waste characteristics, pollutant migration path-
ways, evidence of release, and exposure potential.
The evaluation requires the Investigator to seek evloence
that a unit has released or Is likely to have released. The
Investigator should make deductions based on various amounts of
information on the wastes contained within a unit, the design/
operating characteristics of the unit, and the presence of con-
taminants In any of the pollutant migration pathways associated
wi th the unlt.
In some cases, the Investigator may have actual evidence
that a unit released to a particular medium. In other situations,
it may be necessary to draw connections between a constituent
identified In a unit, the likelihood that this constituent could
have been released from the unit, and sampling data showing the
presence of the constituent 1n a migration pathway. While this
deduction may not prove unequivocally that the constituent Identi-
fied 1n the environment originated 1n the suspected unit, such
deductions will usually be sufficient to Identify a release of
concern 1n the RFA.
The Investigator's ability to make deductions on the likeli-
hood of release will depend on the extent of Information he/she
collects pertaining to the first four Items 1n the RFA Informa-
tion matrix: unit characteristics, waste character!sties * pollu-
tant migration pathways, and evidence of release. Information on
exposure potential 1s not needed to determine the likelihood of
release, but 1s Important 1n determining the need for Interim
corrective measures due to Immediate exposure risks. The kinds
of information to be considered 1n each of these five categories
are described below.
1. Unit Characteristics
The design and operating characteristics of a SWMU will
determine to a great extent Its potential for release. Many
treatment, storage, and disposal units are designed to prevent
releases to the environment. The Investigator should evaluate
the physical characteristics of each SWMU or group of SWMUs to
determine how they affect the potential for releases.
The media-specific chapters In this guidance provide detailed
discussions of how the design and operating characteristics of
2-8
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various types of SWMUs affect their potential for releasing to
each medium. For example, surface Impoundments with w@l 1 -desl gned ,
Intact berms for controlling overtopping do not exhibit a high
potential for surface water releases. EPA assumes, however, that
unllned surface Impoundments have a high potential for releasing
constituents to ground water. Surface impoundments which contain
volatile organic compounds also exhibit a high potential for air
releases. Tht Investigator should examine the characteristics of
each SWMU bastd upon the discussions presented 1n Chapters Five
through Nine 1n order to consider the likelihood of release to
each of the environmental media; ground water, surface water,
air, soils, ard subsurface (gas). Investigators will often find
situations where unit design characteristics suggest that a SWMU
poses little or no threat to the environment from releases (e.g.,
fntAct above-ground storage tanks).
?. Waste C h a r a e 1 1 r 1 s tjcs
In evaluating a SWMU's release potential'. the investigator
should Identify the wastes originally or currently contained In
the unit in order to link constituents observed 1n the environ-
ment wtth those present 1n the contaminant source. The Investi-
gator can usually deduce that a release his occurred when he/she
determines that a SWMU contained a constituent that has been
observed 1n a pollutant migration pathway associated with that
uni t .
The Information gathered while Investigating the waste
generation processes at a facility will provide the basis for
this part of the PR. In many cases, a facility will , ndicate how
it managed many of Its waste streams* e.g., off-s1tt shipment,
disposal 1n a specific surface impoundment, or storage 1n a waste
pile. When a particular waste stream can be traced to a particular
unit, the investigator can generally assume all of the constituents
present 1n that waste stream are also present 1n the unit.
The Information gathered on facility waste generation
processes may often be useful in identifying constituents other
than listed constituents of concern to RCRA. For example, rapidly
decomposable refuse may produce methane when placed 1n landfills
under certain conditions.
The investigator should Identify all of the hazardous con-
stituents which itia> be present 1n each SWMU or other areas of
concern. Some constituents will have a greater potential for
release from one kind of SWMU than another. For example, the *1r
chapter discusses the likelihood that volatile organic constituents
will be released from wastewater treatment units. The fnfdia-
spedflc chapters discuss the ways 1n which constituent properties
can affect the likelihood of releases to various media.
3. Pollutant Migration P^a
The Investigator should evaluate existing Information con-
cerning the likely pollutant migration pathways associated with
2-9
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itch SHHU Of release of concern. in cases Involving environmental
data, tht Investigator will have to demonstrate that 1t Is reason-
able to deduct that a constituent observed In the environment
originated it a specific SWMU or location, based upon knowledge
of the pollutant migration pathway.
While some pollutant migration pathways are largely facility-
wide (e.g., ground water), the Investigator should evaluate the
Importance of all pollutant migration pathways (I.e., ground
water, surface water, air, soils, and subsurface gas) t..at could
be associated with each SWMU and then evaluate Information on
their characteristics, SWMUs which contain the same wastes and
are adjacent to each other may be grouped together during tht RFA,
It will often be possible to eliminate certain pathways from con-
sideration for various SWMUs at this point 1n tht PR.
Different types of SWHUs will exhibit different potentials
for releasing constituents to specific ml gratlon :,pathways. The
Investigator should determine which SWMUs are likely to Impact
which pollutant migration pathways at the facility, and gather
specific Information that will aid 1n determining the charac-
teristics of these pathways. This part of tht analysis also
provides a critical role In Identifying potential exposure points
along various migration pathways, which Is Important 1n evaluating
exposure potential for Interim measures at the facility.
The media-specific chapters provide Information to aid the
Investigator 1n evaluating the physical characteristics of each
migration pathway of Interest. The 1 nvestl.gitor should consider:
o Potential routes of pollutant transport;
o Physical factors within the pathway that could affect
the migration of constituents (e.g., organic content of
soil for 'releases to soil and ground water, or prevailing
V,
wind patterns for air releases); and
o Other factors which could affect tr"i fate of constituents
present 1n a migration pathway.
4.
The Investigator should examine available sources of Informa-
tion to Identify any evidence that constituents have been released
at a facility. The Investigator may have access to direct and
Indirect evidence of release, both of which may help 1n making
determinations of release at a facility.
Direct evidence of release Includes official reports of
prior release Incidents (which may be found, 1n RCRA enforcement
or permitting documents, other Federal, Statt, or local government
documents, facility records, RSI 13 responses, etc.), visual
evidence clearly showing a release Incident, or sampling dita
that clearly Identifies a releasing SWMU (e.g., surface water
samples for a specific constituent 1n a clear run-off pathway),
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Indirect evidence of release Includes sampling data taken along
relevant migration pathways which, whin linked together *1th waste
composition data, can support a deduction concerning the
likelihood of release from a specific unit at the facility.
The VSI , which 1s described 1n Chapter Three, 1s generally
an excellent source of both direct and Indirect evidence on
releases. Stained soils 1n a we! 1 -defined drainage pathway below
a unit can provide direct evidence of release; stressed vegeta-
tion may prcvide Indirect evidence of release.
The mtdi a-speci f ic chapters describe the types of evidence
that are Important for releases to each of thi environmental
media. For example, visual sightings of seepage along a stream
bank provide evidence of both a ground-witer release and a sur-
face water release* The Investigator should refer to the section
on evidence of release in each of the media-specific chapters,
In all cases, the Investigator should use best professional Judg-
mtnt 1n assessing the strength of any Information source 1n
providing evidence of release.
5. E x p QLS u re
The Investigator should evaluate available Information on
the location, numbert and characteristics of receptors that could
be affectad by continuing releases at the facility. These recep-
tors Include human populations, animal populations (particularly
any endangered or protected spades), and sensitive environments.
This Information will be most useful 1n helping the Investigator
determine tht need for Interim corrective measures at the facility
to alleviate especially high risks of exposure. The Investigator
should refer to the RCA_.§3006(_h).Corrgct1 e Action Ofjders Interim
":l"IIIII to"~1 mp YemanT
^
measures.
Tht media-specific chapters provide Information on what
receptors are likely to be affected by releases to each of the
medi a.
EV. COMPLETING THE PRELIMIHARY REVIEW
The Investigator's ability to determine that t release may
pose a threat to human health or the environment will increase
with the quantity and quality of Information gathered 1n the
RFA. By the end of the PR, the Investigator will usually have
identified many of the potential releases of concern at the
facility, tnd will hive made a preliminary evaluation concerning
the likelihood that a release of concern has occurred at each
SWMU, group of SWMUs, or other potential areas of concern.
The next phase of the RFA, the VSI, provides additional
evidence to help the Investigator determine which units or
areas of concern require: additional Investigation in a sampling
visit, interim measures, further Investigation 1n an RFI, or no
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further action. Tht Investigator will usually consider the
following factors before proceeding with the VSI; 1) Identi-
fying significant data gaps, 2) focusing the next two steps of
the RFA, and 1) beginning the RFA report.
A. Identifying Significant Data Saps
Depending upon the quaMty of Information gathered during
the PR, thi Investigator m?.y have a strong Idea concerning the
likelihood of releases from SWMUi or other areas of concern
Identified In thi PR, In many cases, however, the Investigator
will be missing Important Information on a potential release or
unit of concern (e.g., Information on the wastes handled
w1thin the unit),
In such cases, 1t may be necessary to make a formal request
for additional Information from thi owner/operator. As stated
earlier, Investigators may need to cite the RCRA §300? Informa-
tion authority when making this request. Thi letter should be
extremely specific 1n order to ensure that the owner/operator*
clearly understands what Information has baen requested (see
Appenrilx C ) ,
B. Focusing the VIsual Site Inspection AM^lilJ"? V1Mt
One of the primary purposes of the PR 1s to provide thi
Investigator with an understanding of the waste management
activities at the facility, enabling him/her to focus subsequent
orservatlons 1n the VSI and the SV to the greatest axteflt
possible. Because all facilities will undergo a PR and a VSI,
emphasis will be placed on tht quality of the Information
gathered in these two stages. If the conclusions drawn, from a
PR and VSI are not based upon sufficient information, 1t 1s
J1kely that .owner/operators or the public will challenge/permit;
conditions or enforcement orders developed to compel further
actions at the facility.
The Investigator should.evaluate tht Information gathered 1n
the PR on each SWMU or potential release of concern, and deter-
mine whether; 1} 1t 1s likely that the unit has released, 2) 1t
1s unlikely that the unit has released, 3) there 1s Insuffi-
cient evidence at this stage to assess the likelihood of release,
or 4) a release could threaten human health or the environment.
The VSI will provide more useful Information 1f the Investigator
conducts It wlili these preliminary determinations 1n mind*
While 1t 1s ':oo early to draw conclusions at the end of the PR,
1t will oftefl be possible to screen out units from further con-
sideration at the end of the VSI. During the PR, the Investigator
may Identify units that are not likely to hive releases of concern.
These units should be Inspected carefully 1n the VSI before deter-
mining thft they net*4 no further Investigation or action.
The Investigator can also make preliminary recommendations
concerning the need for collecting additional sampling data 1n
an SV. It will often be possible to Identify units or locations
where sampling data can help 1n making determinations of release.
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Recommendations on sampling location! made 1n the PR should be
checked for ipproprlatiness during thi VSI, In general, the VSI
and SV should provide tht additional Information needed to fill
data gaps 1dtnt1f1id during the PR,
C, Document 1 nj ..the P re 11 m1nary Re view
The Investigator should document the fl.iMngs of tht PR by
beginning thi RFA report, which *111 summarize the complete RFA
process. The Investigator w11l Incorporate the results of each
step of the RFA Into this report, resulting 1n a complete docu-
ment providing recommendations concerning: 1) thi need for in RFI
at the facility, 2) the need for Interim measures at the facility,
or 3} the need for no further action at thi unit/facility at
this time.
At thi end of the PR, the report should document Information
sources. Identify SWHUs and other areas of potential release on a
facility map, and contain preliminary evaluations of the likelihood
of release at each locations. This Information will bt used
throughout both the VSI and the SV.
A sample outline of an RFA report 1s Included as Appendix A.
Z-13
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CHAPTER THREE
CONDUCTING A VISUAL SITC INSPECTION
I. INTRODUCTION
A,
The visual site Inspection (VSI) 1s the second step of the
three-sttp RFA process for Identifying releases at RCRA facilities
1n the corrective action program, The VS1 W111 focus on Identify-
ing SMHUs and collecting visual evidence of release at facilities
to assist IPA In recommend* ng further stips In thi corrective
action process. The major purposes of the VSI Include:
(1) Visually Inspecting the entire facility for evidence
thst releases o^ hazardous wastes or conitHuertts have
occurred and Identifying additional areas of concern;
(2) Ensuring that all SWHUs and areas of concern have been
Identified;
(3) Filling data gips Identified 1n thi PR} ind
(4) Focusing ricommfendatlons concerning thi netd for a
sampling visit, Interim measures* an RF1, or no further
action it a facility.
By the end of the VSI, the Investigator w111 be ablf to
determine at which" locations 1t w11l be necessary to collect
additional environmental samples 1n a sampling vfslt CSV). In
some cases, 1t will be possible to screen a unit from further
investigation or to rteommend further Investigation 1n an KFl
without conducting additional sampling, thus complitlnij the RFA,
The VSI w111 Include the entire RCRA facility and can extend
beyond the property boundary 1n certain casis, The VSI should
focus on Inspecting the discernible SWHUs at the facility. How-
ever, the 1nve*t1gitor way Inspect areas outside the facility
boundary to determine If a release has migrated offslte. The VSI
will generally be limited to collecting visual evidence of poten-
tial releases (I.e., photographic documentation), although 1t may
be appropriate 1n some cases to conduct air monitoring for safety
purposes 1 n the VSI .
Visual evidence gathered during the VSI will support the
Initial Information gathered during the PR on the likelihood of
release §t specific locations 1n the facility, This Information
should be evaluated along with the original Information collected
-------
during the PR and Inttgrattd Into the draft RFA rtport, Initial
deterwlnations on the likelihood of release at the facility
should bt Pt¥liBd accordingly. Typical VSts will result In
substantial dofeumarttati on of facility characteristics, which
should ha Integrated Into the RFA report.
II. PLANNINQ THE VISUAL SITE INSPECTION
The VSI 1s a relatively simple procedure and should not
require a griit dta! of tlmp to plan and execute. In general, the
site Inspection activities can be completed In one day, although
there wiy b« some extremely large facilities which will require
more time.
The PR provides most of the Information needed to prepare
for conducting thi Vsi, During th§ PR, the Investigator will
identify potential areas of release on «' facility map, and make
preliminary evaluations of the likelihood of rtliise at each loca-
tion. The investigator should rely upon this map when conducting
the VSI, documenting any unusual observations on the map and In a
logbook.
The VSI w11l usually be the Investigator's first vHU to
the facility during the corrective action prostsi. Therefore,
the investigator should develop a sltt safety plan prior to
conducting the VSI which outlines thi nted for ptrsoflil lafety
devices {e.g., respirators, protective 'clothing, «tc») while
conducting the f1i1d activities. THi. exact eorttittt of iich
safety plan will vary by site, depending on the eompltxlty of the
site and on the Investigator's planned activities* 1PA personnel
should participate in an Agency-sponsored safety course prior to
conducting a VSI, Sifety preparation 1i discussid further 1n
Chapter Four (see "Preparing for the Sartpllng Visit") and Appen-
dix E *
The VSI will probably be the owner/operator's first experience
with the new RCRA corrective action program as well, Thi investi-
gator should contact the owner/operator to scheduli a dite for
the VSI. At this time, he/she should also request a melting with
representatives from the facility prior to cortdudtlrtg the field
activities. This meeting will provide the Invfstlgltor with an
opportunity to explain the various iteps of the corrective action
process to the owner/operator, and to answer any of thf owner/
operator's questions about the RFA or the corrective action
program. During this meeting* the Investigator should discuss
with the owner/operator the proposed safety plan and Incorporate
his/her recommendations in the safety plan prior to conductlna
the VSI. . y
III, CONDUCTING FIELD ACTIVITIES DURING THE VSI
Once the investigator has made the arrangements for conducting
the VSI and has completed the PR, he/she should conduct the field
3-Z
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activities. The owner/operator will usually accompany the Inves-
tigator around the facility*
During the VSI, the Investigator should:
o make visual observations of SWMUs and other areas of
concern at the facility;
o Identify on a facility map all areas of concern;
o document all observations 1n a field logbook}
o take photographs of all SWMUs, potential releases, and
other locations of Interest; and
o monitor for vapor emissions where appropriate to protect
the investigator's safety,
One of the primary purposes of the RFA W111 be to allow the
Investigator to Identify potential releases of concern not Identi-
fied during the PR. The VSI also provides the Investigator with
an opportunity to Inspect the entire facility for potential
releases of concern and to gain Insight Into facility management
practices.
The investigator will focus in the VSI on Identifying and
characterizing SWMUs, as defined In the Irttroductlofu The §3004(u)
corrective action permitting authority requires that corrective
action be addressed at all SWMUs. In some cases» however, he/she
will Identify spills or other releases from waste management
activities which may require corrective action. These should
also be Inspected fully 1n the VSI.
Finally, there may be situations where releases of concern
from manufacturing processes or product storage areas may be
observed during the VSI* The Investigator should doGUffiiftt and
photograph the presence of these releases. It may be necessary
1n some cases to use CERCLA or TSCA Investigative or ertfdfeement
authorities to address these releases.
Field activities should be photographed carefuly to document
all visual observations. This will be especially Important at
facilities where the VSI represents the last step In the RFA.
For additional discussion of photographic documentation proce-
dures, refer to Chapter 4, Section III.C.
The Investigator should obtain Information on each poten-
tial release based upon the five categories of Information shown
in the RFA Information Matrix (Exhibit 1-1): unit characteristics,
waste characteristics, pollutant migration pathways, evidence of
release, and exposure potential. The following sections briefly
describe some of the types of Information that may be found 1n
each of these categories.
3-3
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A. ObtilrtingHlual lvilen
-------
The Investigator should locate all potential migration path-
ways of coneirfl art tHt facility «»p. These will be Important
areas for stapling should it be necessary f.o conduct a SV at
these units* In addition, the 1nvest1gator should correlate
photograph! of these pathways and thilr documentation on the map
whenever possible,
D. Obt.ilftlrtg Visual Evidence of Release
The investigator should inspect the entire facility for
visual evidence of release. While it will not always be possible
to determine conclusively that a release has occurred based on
visual evidtnee, such evidence can provide a strong Indication
that one has Occurred. Visual evidence of release, coupled with
Information indicating that a unit contained haiardous consti-
tuents, W111 often be sufficient to compel further investigation
In an RFI.
The 1 nvestigator should look for obvious signs of release*
such as: discolored soils, dead vegetation or ahiiWals, die* The
media-specific chapters describe in ditail flit types of visual
evidence that may be apparent at various types df waste management
ti n i t s «
E. Obtaining Viaual Evidence of EjUMSure PatMtlat
Thi VSt wit! provide only limited 1nfijriation on ixposure
potential at the fatuity. Thi VSI shoulii inilute sii iiives.tlga-
tlon of the area acoiind the facility to dilfPiiwe if thiPe are
potential off-site releases and documenting evident! Of sucH
releases. In most cases, the PR will hawe .identified iheffier
there are nearby residences, streams, and lakes* At a minimum,
the VSI should note any locations not Identified in ihi PS where
the public could be exposed to releases*
IV. OETERMININQ THE NEED FOR FURTHER ACTION DUftlNQ THE RFA
The results of the VSt should be incorporatstl irtto the draft
RFA report begun upon completing the PR. The rtsUlts of the PR
and the VSI together will provide sufficient eVlde'fiGM for each
potential release of concern to determine either^,I) the need for
a sampling visit (SV) 1n the RFA» 2) the need for 1rit|f1m measures,
3) ,ne need for further investigation in an RFlt or 4) the nefed
for no further action. It is crucial that the investigator document
the results of the VSI In a concise and thorough manner in the
RFA report. Thiese data, together with Information obtained during
the PR, must be sufficient to support decisions regarding tile
necessity of additional action at the facility, and are likely
to be closely scrutinized or possibly challenged. As stated
previously, the RFA report w111 be the primary legal document
supporting the Agency's initial corrective action activities at
the facility. Incomplete, contradictory, or obscure information
1n the RFA report may jeopardize the Agency's position.
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Tht following sections discuss aaeh of the possible recommen-
dations that can be made after completing the PR and the VSI,
A, Determining the Need for a SjMlJ nj_jMsjjt .
By the arid of the VSI, the Investigator win have reflected
1 nf orntation on eacH potential release of concern and will have
made a prel 1m1 nary evaluation concerning the likelihood of re1«ase
at each location. He/she will also Nave Identified important
data gaps that Interfer with the ability to make an enforceable
determination of release potential. In many cases, the Investi-
gator will recommend the collection of new en vl rdnmental samples
from the facility during the'RFA to support his/her recommenda-
tions for further action during the HCRA corrective action process,
The need for sampling at specific units will depend upon
several Important factors, Including; the complexity of the unit
and environment!! setting, the quantity and quality of Information
gathered during the PR ind VSI, the preliminary rteowmindatlons
for further action at the facility, and the eoopirati ventss of
the owner/operator. The inves tl g«ta»- must consider these factors
and rety upon hls/htr professional judgment In determlni ng when
and where "it will be useful to co'lect samples 1n the S,V.
The preliminary recommendations for further aietion at a
facility can pliy an Important role In determining the need for
and extent of sampling in the SV. If the investigator believes
that a SWMU may have a release he/she may want to cdllect samples
In the SV to support the decision to require further 1 finest 1 datl on.
Sampling conducted during a SV can be an Important sujjpleittent to
Information gathered during the PR and'VSI, and proVlrft the docu-
mentation necessary for developing enforceable permit conditions.
On the other hand. If the Investigator believes It is unlikely
that a SWMU has released o"r that other areas actually present
problems, he/she nay make § preliminary recommendation that the
unit wilt not need Investigation in an RFi, it will Often be
useful to support this recommendation with appropriate environ-
mental samples at the unit which will demonstrate that there Is no
evidence that a release of concern Is present* this will provide
valuable evidence to support the investigator's recommendation
should ft be' contested In a public hearing. It is lively to be
Just as Important to sample at units which will not require an
RFI §s at those .,'here one will be required.
There will be situations where the Investigator mafcts i pre-
liminary recommendation that a unit should be Investigated in an
RFI without actual sampling data demonstrating a release. In some
cases, 1t may be possible to make this fico^mendat Ion without
taking additional samples In a SV. More typically, however, the
Investigator will take samples at these units in order to demon-
strate that a release his occurred. More enforceable permit
conditions or enforcement orders can be developed when supported
by sampling evidence.
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Taking environmental samples will be especially Important
when the Investigator believes the owner/operator will be unlikely
to cooperate 1rt conducting an RFI at the facility. When the
owner/operttor1s cooperatlveness Is questionable, the Investigator
shoyld usually take samoles to support recommendations for further
stsps In the corrective action process, In case these recommenda-
tfons are contested in an administrative hearing. Even the most
cooperative atrtir/operatur, however, can challenge permit condi-
tions whleli are not supported by strong evidence,
B * DetermI n 1 nj.::imthf_; Need f-or ^lnterlim_Measuares!
The Investigator can recommend ImplementatJon of Interim
measures at any time during the RFA, although ht/she may not
have sufficient Information prior to thf VS1 tu 'make this recom-
mendation. Interim measures should be conducted at the facility
whpnever there may be a significant risk of Immediate exposure
resulting from, releases at the facility. Interim measures typically
include such actions as repacking damaged drums, requiring safety
precautions for workers at the facility, or fencing off areas of
concern near the facility.
Details on planning and Implementing Interim measures can be
found in the RC|A §3 008 \ h) C g r r e e 1| v e A c 11 to _ .flrdf gl.. J jM.Eln _.fteja -
u r e s Bu 1 danee^l&raf II~. i neTnv e s I t-'gaf6 r § N'0U 1A i «itl:s"y H tiH 1 s "~"
¥o"cumen"t wfiert atttFiTnl ng the need for sych Imwedlite actions a*
a facility* Interim measures are applicable to a fifclliti rhither
ft Is conducting corrective action yr.der §3QO$(h), §3004(u)» or
$3004(vJ.
c • D e term In Ing the N e e d for a H e m.e d 1 a 1 1 n v e s 11 ftit .1 ati • '
Releases and likely releases that are Identified durlnp thi
RFA as requiring further Investigation will be fully character- '
lied -during the remedial Investigation phase of fchei rtCRA correc-
tive action process. The RFI will be conducted by the owner/
operator and may be an extremely resource Intensive activity.
For this reason, 1t will be necessary to ensure that reeofflinertda-
tions for RFIs at facilities are supported fay sufficient evidence
collected during the PR, the VSI, and the SV. In most Situations,
the Investigator will choose to collect samples at questionable
units 1n order to support recommendations at the @!nd cjf the RFA.
There will be cases, however^ whera the Investigator will
recommend an RFI far particular units without collecting additional
samples In an SV. This will usually take piece at facilities
where 1t was possible to evaluate a targe amount of high quality
evidence of release during the PR and VSI. In these cases, the
existing evidence of release must be sufficient to stand alone,
without, supplemental sampling, In justifying an RFI. EPA should
collect additional sampling data whenever necessary, to develop
strong enforceable permit conditions.
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CHAPTER FOUR
CONDUCTING THE SAMPLING VISIT
I. INTRODUCTION
A, P
The sampling v->1t (SV) is the third step of the three-step
RFA proces! designer? to Identify releases at RCRA facilities,
The SV focuses on collecting additional sampling Information to
fin data gaps that remain upon completion of the PR and VSI to
enable the Investigator to make release determinations 1n the RFA
By the end of the SV, the Investigator will have completed
the first ph^se of the RCRA corrective action process, and should
have Identified all releases or potential releases requiring
further 1 nvesti gati on at a facility.
B .
The scope of the SV 1s limited.. It 1s EPA's objective to
focus the collection and analysis of new sampling data fn making
preliminary release determinations* and rely upon existing Infor-
mation sources Identified in the PR and technical Judgments as
much as possible. By Identifying specific areas where new Infor-
mation 1s needed during the PR and VSI, 1t should be possible to
conduct focused, limited SVs that wtl! enable the Investigator
to Identify releases. EPA will risfer major new data gathering
efforts' to th* RCRA Facility Investigation (RFI) phase of the cor-
rective action process.
As discussed previously, the RFA should examine each SMHU or
group of SWHUs at a facility. It will seldom be necessary to
Investigate each SWMU 1n a SV, as the PR and VSI will ofttn pro-
vide sufficient information to make release determinations.
The extent of the SV at a facility will vary on a case-by-
case basis, and will depend upon the amount and qua'lty of Infor-
mation gathered 1n the PR and VSI. The Investigator's professional
judgment regarding the amount of Information necessary to make an
Initial release determination will influence the -extent of the
SV. Thtse determinations should consider a number of factors
Including the degree of owner/operator cooperation and the
regulatory action planned for requiring further action. While
Investigators are encouraged to minimize the amount of sampling
conducted during the SV, certain situations may require extensive
sampH ng.
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As discussed 1n Chapter One, Regions may rely under special
circumstances upon facility owner/operators to develop a sampling
plan and to conduct sampling and analysis activities during the
SV. In these cases, the Regions should review and approve the
owner/operator activities to ensure the quality of the new data.
This chapter describes these oversight responsibilities.
This chapter provides guidance to the Investigator on the
following aspects of an SV;
(1) Developing a sampling plan;
(2) Preparing for the sampling visit;
(3) Conducting the sampling visit; and
(4) Making final RFA recommendations for further action.
C„ Product
The results of the SV should be Incorporated Into the draft
RFA report begun after the PR and VSI activities. Because the
objectives of the SV are to fill data gaps Identified previously
and to assist the Investigator 1n making final recommendations at
the facility, 1t should be a straightforward matter to Integrate
the SV findings Into the RFA report.
It. DEVELOPING A SAMPLING PLAN
One of the major purposes of the PR and VSI 1s to make a
preliminary assessment of the need for further Investigation at
locations of concern throughout the facility and to focus the SV.
This section describes the major factors in developing a sampling
plan:
(1) How to determine the need for collecting sampling
Information during an SV; and
(2) How to develop a sampling plan for the facility where
appropriate.
A. Determining theNeed for Samp!1ng at Faci11t1es
The need for additional sampling of potential releases of
concern will vary on a case-by-case basis, and the Investigator
should rely upon best professional judgment in determining when
it will be appropriate. The investigator may choose to sample 1n
these situations:
o to collect additional Information to suppport a determlna
*ion that a unit or facility does not need an RFI;
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o to collect additional Information when the Investigator
1s unsure whether a release has occurred; and
o to collect additional Information to confirm a determina-
tion of release and to compel an owner/operator to begin
an RFI (or some other further action).
In some cases, the Information gathered 1.n the PR and VSI
may provfdt sufficient evidence to Indicate the need for an RFI at
a facility, or conversely, that no further action Is necessary at
a facility. For example, 1f previous ground-water monitoring
results clearly Indicate that an old, closed landfill has released
hazardous conitltuents to a surflclal aquifer, the Investigator
will have sufficient evidence to compel the owner/operator to
conduct an RFI at the unit, and 1t will not be necessary to conduct
additional sampling. Facility records reviewed during the PR may
indicate that an old, closed surface Impoundment never contained
hazardous constituents, and ground-water monitoring data Indicate
that the SWMU has not released. In this case, also, 1t would not
he necessary to take samples to support a determination that no
further- action 1s necessary at this time*
In many cases, the Information gathered In the PR and VSI
*»111 not be sufficient to enable the Investigator to determine
conclusively that a SWMU has or has not released. For example, a
facility may have clean closed a surface Impoundment several
years ago that once contained sludges analyzed to be marginally
EP toxic for a heavy metal. It may not be clear whither or not
the Impoundment released constituents to the ground water 1n the
past, or whether any contaminated soil remains which could leach
contaminants to the ground water. It may be necessary to sample
the soils around the closed unit or to sample the ground water
(from existing wells) downgradlent from the unit fn order to
Identify a release.
Sampling may also be necessary at SWMUs where records do not
Indicate what wastes were disposed In them. Old landfills and
surface Impoundments without Information on prior wastes may
require sampling; however, due to the danger Involved when coring
or drilling Into oTd waste, this 1s best left for an RFI,
In cases such as the previous one, the Investigator may
determine, based upon best professional judgment, that a release
1s likely to have occurred it a unit. At facilities with coopera-
tive own«.-/operators, 1t may be possible to move directly to an
RFI without collecting new sampling Information, even though the
evidence does not conclusively Indicate that a release has oc-
curred. However, at some facilities, 1t may be necessary to
conduct sampling 1n the SV 1n order to confirm or deny the preS"
tnce of a release before moving further 1n the corrective action
process.
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B. 0eve 1 op 1 n f a S amgj 1n_§ .P. 1 an
The sampling plan will be the primary document directing the
collection of additional Information In the SV. When the Inves-
tigator determines that sampling 1s necessary at a facility. It
will be Important to clearly specify the data that are required
and the reasons for obtaining 1t. Investigators should remain
focused on the objectives of collecting additional Information at
each unit, because the choice and extent of sampling locations,
methods, and parameters will be critical to their ability to make
meaningful release determinations.
The sampling plan should be developed to collect evidence
the Investigator needs to make a release determination at a SWMU,
group of SWMUs, or other locations of concern. This may Involve
collecting direct evidence (e.g., air samples from above or
around a surfact Impoundment) or Indirect evidence (e,g, ground-
water sampling at a well downgradl ertt from the SWMU) of a release.
In most cases, the investigator will collect samples from the
waste source and/or from an environmental medium, and based upon
knowledge of the pollutant migration pathway, deduce the likelihood
that the constituent originated 1n the SWMU.
The sampling plan may be developed by EPA, a contractor, the
owner/operator, or a combination of these, depending upon the
situation. In all cases, EPA should review and approve the
sampling plan carefully before Initiating sampling activities.
Even 1n cases where EPA develops the sampling plan, It 1s Impor-
tant to review the plan 1n order to ensure that 1t meets Its
intended objectives. Due to the cost and time Involved 1n an SV,
1t may be necessary to revise sampling plans several times through
an Iterative process before finally Beginning work.
The remainder of this section describes how to:
(1) determine the extent and locations of sampling at the
fadl 1ty ;
(2) determine sampling methods and parameters;
(3) format the sampling plan; and
(4) review sampling plans.
1. Pet e r ml n1 figt h e E x t e n t an d L o c at 1 o n s
£TJ>a m pTTng '''at the F:acTT1ty ' """""
Once the Investigator has determined the need to collect
additional Information at various SWMUs or other areas of concern,
he/she will need to determine how much sampling will be necessary.
As stated previously. Headquarters encourages the Regions and
States to Hm1t the amount of sampling Information collected
during the SV to that necessary to support a release determination.
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Because of tht time and personnel required to conduct sampling,
tht Information collected should be as concise and focused as
possible.
The extent of sampling required 1n the SV will vary on a
ease-by-cai« basis, and will depend upon the Investigator's best
professional Judgment concerning thi need for new information.
Several factors will play a role In determining the extent of
sampling at the facility:
o The extent of Information gathered during the PR and VSI;
o The cooperatlveness of the owner/operator; and
o The complexity of the unit and the potential environmental
media of concern.
The following guideline should be followed when determining
how much sampling 1s required; The stronger the cast that nttds
to be made to compel an owner/operator to conduct an RFI, or to
convince the public that a SWMU dots not post a threat, the more
Information that should be collected 1n the SV.
In general, the Investigator should saek evidence that a
constituent Identified 1n a SWMU has migrated to ont of tht
environmental media. In such cases, one positive sample confirm-
ing the presence of th« constituent of concern 1n a well-diflnid
migration pathway may be sufficient to compel the owner/optrator
to conduct an RFI. However, 1t may be necessary to tafce samples
at several different points around a unit to ensure that all of
the potential migration pathways have been sampled.
Detailed Information on pollutant migration pathways 1n each
of the environmental media 1s presented In Chapters Five through
Nine. The Investigator should Identify the potential migration
pathways of concern for each SWMU during the PR and VSI. The
location and number of samples necessary to Identify a release
will vary by unit type and by the migration pathway being Inves-
tigated. For example, one groundwater monitoring wt11 may be
Insufficient to Identify a release from a closed landfill dug to
the complexities of the ground-water pathway. However. 1t may
only be necessary to take one hNU reading from above or around
a wastewater treatment ynlt 1n order to Identify an air release.
Each of the media-specific chapters contains specific details on
determining the extent and location of sampling.
When the Investigator his reason to believe that an owner/
operator 1s likely to contest EPA's determination that a SMMU
should be Investigated 1n an RFI, the Investigator should be sure
to gather sufficient sampling Information to support his/her
judgment on the likelihood of release. Should It be necessary to
compel the owner/operator to conduct an RFI through an enforcement
order and administrative hearing, the outcome will depend greatly
on the quality and conclus1veness of the data. Similarly the
4-5
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Agency will r§qu1ri strong data when defending Its actions in a
public hearing.
2. Chops1ng Sampl1n| Methods and Perimeters
The Investigator should choose appropriate sampling methods
and parameters during the SV 1n order to obtain meaningful sam-
pling results. The sampling plan should specify what methods and
parameters will be used at each sampling location at the facility,
It should also specify the number of samples to be taken at each
sampling point (sampling SOPs and QA/QC guidelines are discussed
later In this chapter). The media-specific chapters describe
many of the sampling methods which will be most valuable during
the SV and the criteria for choosing them.
In general* 1t will be possible to chooss sampling techniques
and parameters which provide Information on the unit ranging from
general Indications of a release to precise, quantitative evidence
of a release. In some cases, It may be appropriate to take
screening level measurements (e.g., a VOC measurement with an hNU
photolonlzer), while 1n other cases H may be necessary to sample
for specific organic or Inorganic compounds. As stated previously,
sampling for specific compounds will generally provide the most
useful results during the SV. This will aid 1n developing a
more defensible Remedial Investigation Plan,
Sampling for Indicator parameters such as total organic
halogens (TQX), conductivity, or pH may be useful when the
Investigator has little or no Idea what wastes may have been
released to a medium. However, these parameters can give only
limited Information a/id will not provide sufficient evidence of
release 1n most cases. Whenever possible, 1t will be advantageous
to Identify the constituents of concern at each SMWU and sample
for those specific parameters,
The Investigator should choose those sampling methods that
will provide the most usable results. In some cases, then may
only be one method appropriate for sampling a specific medium
(e.g., the presence of methane 1s normally monitored w,1th a
combustible gas meter). However, there w111 be casas when
several methods may provide evidence of release.
For example, when Investigating ground-water releases from
old landfills where existing monitoring wells ar« present, the
Investigator should sample the ground water 1n order to Identify
releases. However, existing monitoring wells may not always be
located sufficiently close to SWMUs to provide meaningful data on
releases. In these cases, 1t may be necessary to take a number
of soil samples around the unit and/or 1n the unsaturated zone
beneath the landfill 1n order to Identify evidence of releases.
Alternatively, there may be Instances where electromagnetic
conductivity (EM) testing or soil gas testing will provide useful
screening level Information on prior releases at such units.
Finally, there may be unusual situations where the Investigator
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Mill nied to drill new ground-water monitoring wells 1n order to
obtain Information on ground-water contamination. The Investigator
should be familiar with each of the potentially appropriate
sampling techniques and choose the best ones for each situation.
The media-specific chapters provide details on how to choose
appropriate sampling techniques.
3. Forffiil fqj Samp11 ng Plan
The sampling plan should be dear and understandable and
present logical actions for meeting the sampling objectives
at each SHMU, group of SWMUs, or other locations of concern. The
Investigator should organize the sampling plan to Identify the
actions to be taken at the facility. Depending upon the facility
characteristics, 1t may be appropriate to organize 1t by location
or by sampling technique, ?or example, there could be sections
for each SWMU that describe all of the sampling activities asso-
ciated with 1t; alternatively, there would be a section on soil
sampling that Identifies all of the locations and methodologies
for sampling the soil throughout the facility.
The sampling plan should Include Information on each of the
following factors:
o Field ope fat 1 on
The sampling plan should discuss the sequence for conducting
the field activities.
o Sampling 1 o c: § 11 onis ../. r a t Ion ale
As precisely as possible, the sampling plan should Iden-
tify the location of each sample. A site map should be
prepared to guide the Investigator to the appropriate
locations. Specific sampling methods, the number of
samples, the parameters being sampled, and a description
of the objectives for each sampling activity Should be
included in the sampling plan.
o A n a 1yt1c a 1 requ1r ement s
The sampling plan should discuss the technique and level
of detection that will be used to analyze each sample.
o Sample_handl ijj^
Sample preservation and other handling practices should
be described.
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ii||f4Aim/|.p 11M c o n t PP. I
TN« plan should Identify the number and typt of quality
assurance samples, specifically the number of blanks,
dupHeitiS, Of spikes that will be taken. The specific
QA/QC guidelines to be followed 1n this program are to
be stipulated by each Region,
o Ei«.1J1i1tat jtacontaffil nation
The sampling plan should Identify the reagents and any
special procedures associated with equipment decontamina-
tion*
o Chtifii of custody
All samples collected (including blanks and spikes) must
be maintained under cha1n-of-custody procedures. Chaln-
of-eustody minimizes the potential for damaging OP losing
samples before they are analyzed. Chalrt-of-eustody tracks
the possession of a sample front the time of collection,
through all transfers of custody, to when 1t Is received
1n thi laboratory, where Internal laboratory chalrt-Of*
custody procedures take over* Investigators should gen-
erally follow regional protocols for eha1n-of"Custody
procedures.
4, RevltwJfit I SlfflBlIng Plan
The Investigator should review the sampling plan carefully
to ensure that It meets EPA's objectives at each unit being
sampled. The Investigator should be sure tint appropriate sampling
methods and locations are selected, and that the extent of sam-
pling 1s appropriate for the determinations that are made at each
sampling location. This will be especially Important when the
owner/operator or an EPA contractor develops the Sampling plan;
however, even when the EPA Investigator develops thi sampling
plan, H will be useful to review the plan In order to ensure Its
completeness.
The sampling plan also describes the leva! of effort required
to conduct the proposed sampling strategy. This Information
1s usually presented 1n terms of person/hours for each sampling
technique or SWMU Investigated, and may also Include an estimate
of the elapsed time and the total costs.
III. PREPARING FOR THE SAMPLING VISIT
The Investigator should plan a number af activities prior to
Initiating the SV activities at e site, Once the sampling plan
has been completed, reviewed, and finalized, the Investigator can
make plans to begin the on-s1te activities. These plans will
1 ndude:
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(1) i*1fflHfl facility
(2) Handling somMufHty relations (1f approprlate);
|3) PfiptMng a safity plans and
(4) Spielfylng EPA oversight of owner/operator sampling
activities.
A. 0a.1_n 1 nft IMJ111y Access
Prior to conducting the field work, the Investigator should
contact tht owner/ open tor to schedule a time for thi SV team
to inter thi site and perform tht ntetssary field activities,
Although EPA staff nay already be coordinating activities for the
RFA with tht owner/operator, the appropriate regional person
should contact thi owner/operator to verify datii and describe the
nature of the field activities — sample collett 16ft, photographic
documentation,, facility inspection* and/or Instrument Monitoring.
If the owner/operator Is responsible for collecting and
analyzing the safltplis, then the IPA official should contact the
owner/operator to schedule a date to d¥iriti thi f1i1d atitlvltles.
The agency should send the sampling plan and pfflitflyfis for
performing the sample collection to thi dWfiif/opifater suffl*
clently ahead §f tlfflt for htm to obfciln tht ippfipfliti tupport^
If EPA is collecting and analyllng the sawpliii IPA Sftiuld offer
the owner/operator a split of a11 samplis eo11«6tidi If iht
owner/optrator wlshiS to havi Splits, IPA shiuld Initruct Him to
provide analytical sample bottles for the splits*
After completing these arrangements, tPA should Sirtd a
letter to the owner/optrator confirming th§ dates and field
activities, If accssi 1s denied. Appendix 0 pfovldts guldinct
on hot* to obtain access to a facility.
In some cases 1t may be necessary to access adjacent Of
nearby properties in order to conduct a visual 1nspfct1«n or
collect samples. SPA should provide verbal as wilt as Written
notification of the dates and nature of the work to owftsrt of
these properties,
Although the RCRA Investigator 1s authorlied to Inspect a
facility and collect samples and photographs, the owner/operator
can require the Investigator to conduct the Inspection and sample
collection activities to protect his legitimate rights. The
admlss1b111ty of data 1n court way later be challenged 1f data
are collected 1n violation of the owner/operator's constitu-
tional rights. The owner/operator can observe Inspection actlvl*
ties, unless he Interferes with the safe, or technically sound,
conduct at tha sampling wlslt.
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Tha cmnif/o|frator has the right to request confidential
treatment of Confidential Business information (CBl), Ordinarily,
environmental monitoring data are not confidential. If data
deemed confidential by the owner/operator are needed to properly
evaluate the facility, then the Investigator should Include a
precise description of the confidential data 1n the field log
book. The ifivelti gator should Instruct the owner/operator to
follow up with a letter Identifying the confidential data and
explaining the reason why the data are business confidential,
EPA regulations governing treatment and handling of confidential
data are delineated 1n 40 CFR Part 2, Subpart B. Sections 2,201
through 2.309i
6. C ommu n 11 j,, nej at 1 o n s
If 1t 1S necessary to conduct field activities 1n or near
residential or non-Industrial business areas, then the agency
should contact the appropriate local officials ahead Of time*
It is difficult to remain unobtrusive while conducting site
Inspections, particularly 1f field workers are wearing protective
clothing. Moreover, the presence of "official" people eOl1ict1ng
samples can cwse alarrta In some caseS|.1t tflll be difficult fcO
prevent thl? but prior, well-handled community contact can minimize
the alarm.
The Office cif Solid Waste 1s preparing guidance on community
relations that will be available later this year* This document
will provide specific guldanee on when and how to Implement a
community relations prdgram at RCRA facilities*
C. Prepftflftfl a Safejyt Plan
Agency personnel should prepare a safety plan for each sam-
pling visit In accordance with appropriate EPA guidance* the
safety plan 1s usually prepared last and 1s tailored to the
specific SV activities. For some SVs, the safety plan will be
very simple and require few protective measures. Other, more
problematic sites, may require use of higher levels of protection,
For example, If the SV Involves sampling lagoons, then the safety
requirements will be more Involved than for one Involving simple
visual reconnaissance. In developing the safety plan* the owner/
operator should be asked about potential hazards 1n advance of
field work, and should consult the Facility Contingency Plan.
Appendix E contains Chapter 9 from EPA's S t a nd a f ft Qg t rating
Safety Suldes. 19B2 (SOSG) that explains how to develop a proper
site safety plan. The SOSSs were prepared 1n accordance with EPA
and other Federal health and safety guidelines, regulations and
orders. This appendix discusses the steps Involved 1n developing
a safety plan and elaborates on the contents of each section of
the plan.
A brief outline of the contents of the safety plan 1s provided
below.
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o Describe Known Hazards and Risks
o Us! Key Personnel and Alternates
a Identify Li*8ls of Protection to be Worn
o Identify Work Areas
o Identify Access Control Procedures
o DeseMiSi (Jeegntamlnation Procedures
o Deseflbs Site Monitoring Program
o Identify Special Training (Ulred
o Describe Heather-Related Precautions
EPA personnel should participate In an Agency-sponsored
safety course before visiting a site,
0. EPA Oversi git of Owner/Ope rat or Sampling Activities
The sampling visit plan should Include provisions for EPA
oversight when the owner/operator conducts the sampling activities.
The level of IPA Involvement will depend upon the extent of
sampling, the complexity of the s1t0^ and the edoperstlveness of
the owner/operator. In some cases, EPA may believe that the
owner/operator can be counted on to provide reliable results* In
such situations* EPA oversight of the sampling activities Way be
limited to presence at the facility during one ddy of the sampling
only. In other cases, 1t may be necessary to provide iPA presence
at the facility it-all times during the sampling activities* The
investigator should take splits of all samples edlliited. by the
owner/operator.
!V. CONDUCTING THE SAMPLING VISIT
The Investigator may begin the site activities once he/she
has completed all of the preliminary activities* the sampling
visit Involves gaining access to the site, performing tfie sampling
activities, taking photographs of all activities* keeping the SV
portion of the logbook, preparing samples for shipment and analysis,
and, finally, decontamination/demobilization.
A. Preliminary Site Activities
The investigator should meet with the owner/dperator prior
to entering the facility to conduct sampling* The 1f*vest1 gjator
will already have conducted a VSI; therefore, the otfrtirVbperator
should have some understanding of the corrective action process
from the Initial meeting with the investigator(s)„ However, the
investigator should be prepared to answer questions concerning
his/her plans for sampling, In cases where the owner/operator
will conduct the sampling, the investigator can ffitke the arrange-
ments to accompany him/her at this time. In addition, the Inves-
tigator should offer to provide the owner/operator with duplicate
samples,
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B,
The investigator should fallow the sampling plan once He/she
has gained access to the facility. Tha sampling plan should
describe a1 1 tf tHe Sampling locations, methods, and procedures
to bi fulloiidf If, for any reason, It is necessary to diverge
from the sirtpllrig plan, changes should be documented carefully.
ss of who performs the sample collection, continuous
monitoring for vipor emissions 1s needed to detect §1r releases
from sampling i Set 1 vltles . If tht owner/operator 1s collecting
the sampltSi EPA/State Investigators should document precisely the
sequence of sirtpllng activities, the procedures and Instruments
used, and desirlbe the samples (Including location* depth§
appearance, etc*}*
\
The IPA Regional offices have developed SON for most SV
sampling tasks under the CERCLA PA/SI prpfram, trt addition, IPA's
Office of Waste Programs Envorcement {OWPf) h« diVfloped the
RCP5A B round i§Sftf ,::Mmn||or1n| Teeh,tileA| EJlttM^
{Mot (fliO')" ti |f6¥Tle';'gu1dlInce ort "ii'il l^ftifil 1|f16H III sllpllnf
procedyrtsi EPS/SW-i4e also provides sirtplirfg Iftd irtil^sli proce-
dures for media rflevant to the SV. Nr tlie ias'i part j t-hise
SDPs are §pp|1eaiie to RCftA field tr^.ivltjii*. If fHf ION, are
not applicable Of SpprOprlate fur the pirtleultF flild iell^Hy,
then a new SOP should tie developed. Where modifications to
existing SOPs are rnidfe, they s'hould be nofeid in the Hild
c. P
Investigators should use regular ISfrtrn canleril for
photographs* They should not use filters, as tH|| tishd if dis-
color the picture ind ftay unfairly bias the rssilll | lt|g
leachafce seeps or lagdins look different from fell 1lfi* THe
Investigitor should Iderttlfy and record In the fliliUttifc tMe
estact type of cinferi (including 1*d» numbir), flltff |i*ti» PUJ1
ASA 200), and the lens used. Photographs tafesrt «HH
lenses (e.g., wide-angle) are not admissible In court.
Photographs should be taken to doeumertt thi feSfltfitidfts of
the facility and procedures used In Inspection leiivlfles*
Particular emphasis should be placed on matters Idewtlflid 1n
the work plan. Types of pictures that should bi tSfcefi Include:
o Representative overall plcture(s) of f»c111||j
o Posted signs Identifying ownership of facility?
o Evidence of releases — leachate seeps, pools,, discolored
water, or strained soils;
o Individual un1 ts~-l agoons , drums, landfills, etc.;
o Visual evidence of poor facility mal ntenince j
o Adjacent land use; and
o Area that unauthorized persons can easily access.
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0.
The logbook fs ; irftips th"t most Important document produced
during the §V« It series as a basis for Integrating the SV
results into tH« RF^ report, rtost Importantly, supporting the
work done and rlsults obtained In any future legal proceedings
under RCRA* of
A unique logbook should be developed for each sltt and each
v'sft to the site. Logbooks should be bound and each page sequen-
tially numbered. Entries Into the logbook should be chronological
-- a tlrtt flotation ;shoul d Introduce §ich entry. The logbooks
should be maintained with indelible ink,
The f ol 1 of 1 fig 'types of entries should be rtade in the logbook:
o All personnel on site during each phase of the on sits
work;
o All Instruments used during the field work with unique
Idehtlf lestlun numbers;
o Description of film used;
o Description of th« weather and chftnges 1ri tNi weatHir;
o WiteM|l observations related to UiwS JtUfitlflftd Iri
work piiflj
o Results of fltld fneasurements--d1stifiees * IHstrumerit
readings, well mfasureintnts » loeat
o Factual descriptions of structures • and feat tjf-fs--wel 1 s
and well construction, units* contilnmertt, ilfUeturis,
buildings, hoads, topographic and giomorpMc ffaitffllf,
.locations;
o Signs of cont«fn1nat1on--o1ly discharges , discolored sd
fices, dead or stressed vegetation;
o Sketches of facility layout, structured futures flrtd
points, of contamination;
o Map of facility showing point and direction of photo-
graphs;
o Location and time of each sample! and
o Any other relevant items.
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,E. Stfflpli SJtiiiiii/AAnimlfi Ana ly s is
Upon eoififnstlon of the onsite work EPA or the owner/operator
should deliver- all samples to the laboratory for analysis, SOPs
covering saniptf shipping are available In each of the regional
offices oh 1H EPA safety training manuals, T> time involved in
analyzing samples can vary from 40 days to thru« to four months.
F . DaearttAiin,Ation/D^emo^j jjjj/tlain
DeeoiitaffH nation of persons and equipment occurs not only at
the completion of all field work but each time persons exit the
site, including rest breaks.
In many eases, decontamination may be very simple, e»g«»
removing disposeble coveralls and Cashing field boots. Decon-
tamination after sampling activities will usual ly 1 ncl ude decon-
tamination of field persons, and sampling and field equipment.
All clothing and support material;
hould be containerized either for tr,si
isposal or for on-site disposal.
,.,. .,..., __rr_. - ._Js that wilt not be reused
should'be containerized either for transport and eventual off-site
d' " ' "
V. FINAL RFA RECOMMENDATIONS FOR FURTHER ACfldfl
The final task in the RFA process is to raal|e re<;fmm£H<|ai1ons
concerning the need for further actions at iHe facility* These
recommendations include: (1) taking no further Icilohj (2) con-
ducting an RFI to idefitify the rate and extertt tif riieissfs from
SWMUs, groups of SMMi/Sj or other releases of c^rte«Fnj If) fjllrtrtirtg
and implementing irrterim measures at the facility; fr (4) referring
the further investi gfation and control off permitted SWMu releases
or othsr unusual releases to other erivi ronmentsl p^giri
The investigator will have completed the RFA only iffer
dations have been made which cover all potential re?iiase*S (if
concern investigated in the
In order to make these reciommendat ions , the irttf^stf gator
may make determinations concerning the likelihood of release
for some SWMUs after completing the PR and VSl . IrtJJther eases,
it will not be oossible to. make determinations urtti? s^ipling
results from th;! SV have been evaluated. Me diseass i.tjgiow how to
make final release determinations at the end of the RFA arfd how
to make recommendations for further action.
A. H a k ing RFA Release Determinations
1 . EyaAuat _Safi_n^
The first step in making an RFA release determination wi
require the investigator to use best professional judgment in
evaluating the sampling results from the SV. This evaluation
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should be straightforward as long as the sampling plan was devel-
oped correctly, e.g., sampling points were selected to provide
enougn additional evidence to support this determination.
After the laboratory completes Its analysis, the Investigator
can evaluate the validity of the analytical results from the
*ampl1ni, activities. When EPA conducts the sampling, preliminary
review of analytical data Involves ensuring that all deliverable*
required by the CLP ar* Included fn the data package, checking
that all forms are completed within the requirements of the
contract^ ar»d Identifying tr*e key quality assurance Items In the
data package. The EPA Regional Environmental Services Divisions
(ESOs) will perform s qualitative analysis of the data after this
preliminary data review* and determine 1f the data results are
valid. When the sampling Is conducted by the owner/operator,
the investigator should rely upon best professional judgment In
evaluating the validity of the lab results,
2. Integrating Data Collected During the PR. VSI,and 5V
Once the Investigator has evaluated the validity of the
sampling results, he/she should Incorporate this additional data
with the Information collected previously on each release location.
Hy this point \fi the process, the Investigator should have all
additional Information that was requested of the owner/operator
to facilitate determining the likelihood of a release.
3. petarginlng the_JLj[kel1 hood .of Rjejjase
The Investigator should rely upon his/her best professional
judgment At the end of the RFA process to determine the likeli-
hood of release to all environmental media for all SWMUs and
other areas of concern. The VSI chapter described how the Investi-
gator should make Initial determinations of release it each SMMU,
group of $WMUs» or other potential areas of concern. The Inves-
tigator will use the same basic judgment at the end of the SV;
the primary difference will be that there should be additional
Information to support a determination after conducting the SV.
The Investigator should determine the likelihood that a SWMU
has released by evaluating evidence collected 1n the 8FA. In
sorae cases, the investigator w'll have dlract evidence of a
release, which s*1l 1 provide the strongest support for a determi-
nation* In most cases, the Investigator will be required to make
deductions from Indirect evidence about the likelihood of release.
A*, stated previously, the strength of these deductions will
depend upon the quality of the waste Information, the extent to
which the pollu ant migration pathways have been characterized,
and the quality of the environmental sampling results and visual
observations.
The level of evidence needed to support a determination will
vary on a case-by-case basis, depending upon the cooperatlveness
of the owner/operator, the EPA objectives at the facility, and
the complexity of the facility, In general, it will be sufficient
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to Identify one constituent that 1s present 1n both a SMMU and 1n
the migration pathway to support a release determination.
The Investigator does not need to demonstrate with statistical
confidence that the SWMU has released during the RFA.
8. Making Recommendations forEachSWMU or Group of SHMUs
The final step 1n the RFft will entail making recommendations
cc erning the need for further Investigations under the corrective
action authority, based upon the release determinations described
above. This section describes each of the four possible recommen-
dations below: no further Investigation, Investigate further 1n
an Rrl, plan and Implement Interim corrective measures, and refer
the control of a permitted release to another environmental
program office.
1. No Further Invesit 1ga11on
Investigators may conclude that a SWMU, a grouping of SHHUs,
or an entire facility does not require further Investigation
based on the Information available from the PR and a visual In-
spection. In some cases 1t will be advisable to collect some
sampling and analytical data to confirm that a unit or area has
not created a release that poses a threat to human health and the
environment. For many SHMUs, the determination that no further
Investigation 1s necessary will be relatively simple and straight-
forward.
Some units will have design and operating characteristics
which will effectively prevent releases to the environment. For
example, a wastewater treatment unit nay have a cover to prevent
the release of VOCs to the air; such a unit would not require
further Investigation for air releases.
SWMUs which never contained constituents of concern w11l
not require further Investigation.
It 1s also appropriate to eliminate certain units from
further study on the basis that they clearly have not released
hazardous wastes or constituents into the environment. Examples
of such units Include elevated tanks and, 1n some cases, surface
level storage tanks. In the case of aboveground tanks, unit
design and operation, plus the Inspector's direct knowledge of
the facility, can provide sound evidence that the unit has not
caused a significant release. It will rarely be possible to make
such determinations for landfills and surface impoundments. More
explicit information as to making a "r,o further action" determina-
tion is presented In the media-specific chapters.
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2. InvestigateReleases Further 1n
a RCgi Seltdlal Investlgat1on"
T'/ie Investigator should recommend that a SWMU or other
release be Investigated further In an RF-I when he/she Identifies
a SWHU with a likelihood (or documented evidence) of a release
which may pose a potential threat to human health and the environ-
ment. He/she should describe each SMWU and the relevant environ-
mental media which should be Investigated 1n the RFI. It will be
Important 1n focusing the RFI to determine which media are of
concern for each SHMU or potential release.
There are situations where the facility as a whole poses a
problem and where 1t 1s difficult to distinguish between Individ-
ual SWHUs as sources of contamination. In these cases, it may be
more efficient to refer the entire facility to the RFI and require
the owner/operator to Investigate the facility as a whole.
3 , Adjopt In t e r 1m He a sure s
The RFA should result 1n a recommendation to adopt Interim
measures at the facility when the Investigator believes Immediate
action should be taken to protect human health or the environment
from releases. The Investigator should evaluate the severity of
the release and the proximity of potential receptors when assessing
the need for Interim corrective measures.
Temporary corrective measures may be appropriate 1n situa-
tions where there Is a release of hazardous wastes or constituents
Into the environment that Is currently affecting or will affect
target populations or sensitive environments and the release may
be temporarily or permanently arrested by some type of Interim
solution.
The R C R A §3008(h) Correct I ye A ct1 on Orders In t e r1m Hea5 u re s
Guidance TTr'a'ftl pro v 1 "desTUet a 11s on a p p r op rl ate a ct 1 bhs To t a k e
1n situations where Immediate action fs needed. Examples of
Interim measures Include: fencing a facility 1n order to prevent
direct contact with wastes; or stabilizing weak dikes to prevent
further surface water releases from Impoundments. It 1s Important
that these units should be Investigated further 1n an RFI 1n order
to determine the adequacy of the Interim measure and/or to design
a permanent solution.
4. Refer PC r Ml_t_ted Release to Other Pjro.gr am C^f|ees
Permitted releases which may either directly or Indirectly
be posing a threat to human health or the environment should be
referred to the State or Federal program office that Issued the
permit. EPA has not developed guidelines on such referrals, thus
they should be conducted as necessary on a case-by-case basis.
When the other program office cannot or will not Investigate or
control the release, the Investigator may recommend that the
units be Investigated in an RFI and/or that Interim measures be
1nltlated.
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When the RFA Identifies contamination resulting from permit-
ted discharges or discharges requiring permits that require
further Investigation 1n an RFI, EPA will work on a case-by-case
basis with the Regions and other EPA permit programs to develop a
solution to the contamination resulting from the discharges. For
example, when frequent violations of NPDES permits 1n the past
have resulted 1n an accumulation of hazardous materials In stream
sediments, the RCRA Investigator should work with the NPDES auth-
ority to develop a solution to the contamination.
VI. FINAL RFA PRODUCT
The final RFA report will document the activities undertaken
In the PR, VSI, and SV. Many documents win be generated during
the SV, Including a sampling plan, safety plan, sampling results,
an evaluation of the sampling results, and release determinations
and recommendations for each unit. All of this Information
should be compiled Into the RFA report for future reference
during further phases of the corrective action program. Appen-
dix A provides a sample outline for the RFA report.
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CHAPTER FIVE
GROUND WATER
I. INTRODUCTION
A. Purpose
This chapter provides technical Information to support the
investigation of releases to ground water, with the exception of
releases from regulated units, during the RFA. While Chapters Two
through Four provide general guidance on conducting an RFA, this
chapter focuses OP specific factors unique to the ground-water
medium that should be considered by the Investigator.
B. SCOJNS
The scope of the RFA, discussed 1n Chapter One, extends to
all operating, closed, or closing RCRA faculties, The Investi-
gator should evaluate the likelihood that a facility may have
releases to the ground water, with the exception of "regulated
units" (land disposal units that received wastes after July 26,
1962). Releases to ground water from regulated units should be
addressed 1n permits according to the requirements of Subpart F
of Part 264 (or corresponding State regulations), rather than
through §3QQ4(u). The Investigation of ground-water contamina-
tion from regulated units will not be part of the RFA.
It 1s not the purpose of the RFA to install Sul^part f mon-
toMng wells 1n order to detect conclusively the presence of a
release. It will usually be sufficient to demonstrate that there
1s a likelihood of release from a specific unit to the ground
water 1n order to require further investigations. The Investi-
gator should rely upon best professional judgment when estab-
lishing evidence of release to ground water.
This chapter 1s organized to reflect -the separate phases of
the RFA process. The first section describes the technical
factors that should be considered during the PR and VSI. The
second section describes the technical approach to obtaining
additional sampling Information 1n the SV for ground wattr, and
sh&jild be consulted along with Chapter Three on conducting a
sampling visit. The final section discusses factors to consider
when making release determinations for ground water at the end of
the RFA. This section also presents options for further investi-
gation of ground-water releases to be evaluated at the end of the
RFA.
-------
It. CONDUCTING A PRELIMINARY REVIEW AND VISUAL SITE
INSPECTION §F &R0UN0-WATER RELEASE POTENTIAL
Th1i ttctlGft presents technical Information related specif-
ically to the ground-water pathway to be considered when conduct-
Ing the prtllsflrtary review and visual sltt Inspection, Accordingly,
this station 1s organized to reflect the primary goals of the PR
and VS! described In Chapters Two &,id Three:
o Identifying and describing potential threats to ground
water at 8CRA facilities; and
o Malting a preliminary assessment of thi nted for further
1nvest1gallons at these facilities.
This section reflects the Importance of the five categories
of Information to consider 1n conducting RFAs presented In Exhibit
1-1. It presents technical Information specific to thi ground-
water pathway covering the five areas and technical Information
to help the Investigator determine when additional sampling will
he necessary 1n an SV to Identify ground-water rtltases. The
section discusses each area separately:
(1) Unit characteristics;
(2) Waste characteristics;
(3) Pollutant migration pathways;
(4) Evidence of release;
(5) Exposure potential,' and
(6) Determining the need for additional sampling Information.
This Information will be relevant to the evaluation of
written documents 1n the PR and Information gathered 1n a VS1.
Consult Chapters Two and Three for general guidance on how to
conduct PRs and VSls.
A. Un11 C ha r a c t a r1st 1cs
The design and operating characteristics of a unit w111
determine to a great extent Its potential for releas1n§ hazardous
constituents to ground water. Many treatment, storage, and
disposal units are designed to prevent releases to tht environ-
ment. The Investigator should evaluate the unit characteristics
of each SMWU or group of SMMUs at a facility to determine Its
potential for releasing hazardous constituents to ground water.
The general potential for ground water contamination from
any unit depends, to a great extent, upon Its nature and function.
This concept Is reflected 1ft RCRA hazardous waste regulations.
For example, ground water monitoring 1s not a requirement for
5-2
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container storage units, while monitoring 1s required for land-
based units. Therefore, 1n evaluating the likelihood of ground-
water releases from a unit, the Investigator should assess each
unit based upon:
o ftn understanding of the overall potential of the unit
to cause ground water releases;
o An understanding of the primary mechanisms by which
releases may occur from the unit; and
o An assessment of unit-specific factors which, singularly
or 1n combination, Indicate the relative likelihood of
ground water releases from the unit.
The Investigator should first consider the relative potential
of the unit to release. Exhibit 5-1 presents a generalized rank*
1ng, 1n rough descending order, of different types of units and
their overall potential for causing ground-water contamination.
It lists the most common mechanisms by which ground-water releases
can occur from each unit type.
Exhibit 5-1 provides only a very theoretical sense of the
relative potential for units to cause ground water releases.
Unit-specific factors should be evaluated 1n determining whether
further ground water Investigations are needed for a particular
unit.
The following un1t*spec1f1c factors should be evaluated 1n
assessing a SWMU for ground water releases:
(1) Unit design; ,
(2) Operational history; and
(3) Physical Integrity of the unit.
/
In making a unit assessment, the Investigator should consider
ways 1n which the above factors may combine to suggest whether or
not releases have occurred. For example, examination of an above-
ground tank may reveal evidence of soil contamination adjacent to
the unit. However, the operational history of the unit reveals
that the tank has been 1n operation for only six months, the tank
1s 1n good condition, and records Indicate that the contamination
occurred as a s1ng!e> relatively small overflow event. Considera-
tion of all of these factors Indicates that, despite the evidence
of so11 contamination, likelihood of a release to ground water 1s
very remote, and furtiier remedial Investigations for ground water
may not be necessary. The factors listed above are discussed 1n
more detail below.
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EXHIBIT 5-1
RAMKtMS OF UNIT POTENTIAL FOR GROUND HATER
RfLIASES AND MECHANISMS OF RELEASE
Unit
Rtletsi Mechanism
Class IV Injection
Well
Lanrffll 1
Land Treatment Unit
Underground Tank
Waste Pile
Class I Injection
Well
Spillage of other releases from waste
handling operations at the well head
Escape of wastes from well casing
Wastes are Injected directly Into the
subsurface
Surface Impoundment o
Migration of wastes/constituents through
liners {If present) and soils
Damage to liners
Overflow events and other spillage outside
the Impoundment
Seepage through dikes to surface artd/or
subsurface
Migration of liachate through Unsrs
(1f present) and softs
Precipitation rynoff to surrounding
surface and subsurface
Spills and other releases outside the
containment area from loading/unloading
operations
Migration of constituents through the
unsaturated zone
Precipitation runoff to surrounding
surface and subsurface
Tank shell failure
Leaks from piping and ancillary equipment
Spillage from coupling/uncoupling
operations
Overflow
Leachate migration through Uner
(if present) and soils
Precipitation runoff to surface/subsurface
Spillage or other releases from waste
handling operations at the well head
Escape of wastes from well casings
Migration of wastes from the Injection zone
through confining geologic strata to upper
aqulfers
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EXHIBIT 5-1 (Continued)
RANK1N6 0^ UNIT POTENTIAL FOR SROUNO WATER
RELEASES AND HICHANISMS OF RELEASE
MftIt Tjgjrt. Release HeehiMsm
In-ground Tank* o Overflow
o Tank wall failure
o Leaks from ancillary eaulpfftent
o Spillage from coupling/uncoupling operations
Container Storage o Spills from contalrttrs/contalrter failure
Unit subsequent migration through liner of base
(1f any) and soils
o Predpttitfon runoff from storage areas
Above Bround Tank o Overflow
o Shell fa1 lure/eorrcfsfon
o Leaks fram anclllafy equipment
o Coupling/uncoupling operations
Incinerator o Spillage or other reltiSes from waste
handlfnf er pfipnrat1tn tctltitles
o Spills due to mechanical failure
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1. Unit flill4n
Evaluation of the unit's design should focus on the following
areas:
o The unit's capacity and dimensions;
o Materials, design, and construction of a unit;
o Any engineered features designed to prevent
releases to ground water; and
o The adequacy of such features.
The capacity and dimensions of a unit affect the potential
for a release 1n several ways depending upon the unit type. A
large volume, shallow surface Impoundment 1s more likely to have
a release than a smaller capacity unit. The shallow depth with
the large volume Indicates that there 1s a large surfaca area on
the bottom of the Impoundment. Most releases occur through the
bottom by exflltratlon through a clay liner or through leaks In a
synthetic liner. The larger the bottom surface, ths greater the
livelihood that bottom leaks or exflltratlon Will oeeiir.
Some units have engineered features that will reduce the
potential for a release to ground water, Landfills with double
liners and a leachate collection system will be much less likely
to have a release to ground water than do either land-based units
without liners or with single clay liners. Some features In-
stalled to prevent ground water releases have different abilities
to do so effectively. For example, single clay liners do not
prevent releases, but they delay the movement of leachate through
the less permeable clay layers.
2- Operational History
During the PR, the Investigator should evaluate the unit's
operational history for Information that Indicates a release to
ground water may have occurred. Operational factors that may
Influence the likelihood of ground water releases Include:
o $ierV1[ce> 1Mlfe gif_ thie u_n 1^. Units that have been managing
wastes for long peTrToffs of time usually have a greater
likelihood of releases than units that have been opera-
ting for short periods of time. For example, an under-
ground tank that has been 1n service for six months will
have a much smaller likelihood of leakage due to corrosion
than will a twenty-year eld underground tank.
0 Ope r at 1 0 g a 1 s.t at u s . In some cases, the operational
'status of a storage unit (e.g. closed, Inactive, decom-
missioned) may have an effect on the relative likelihood
of a ground water release.
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0 |it|iiiAC Jiff MtM^-i-ft * Proper wilntenanee, regular inspec-
for ensuring waste compatibility
with tht tfiMt my Indicate that a unit 1s unlikely to havt
ri1*Ii«d (this Is particularly true for storage units
tttth it tiftks tnd container storage areas). Evidence of
good (jrperitlonal practices may be available from owner/
optritor records, and/or visual observation or historical
Insjseetloft reports. Conversely, poor operating practices
(«*!*» underground tanks that are fttvtr leak tested or
d Internally, storage of open containers of
may Indicate relativity greater potential for
water releases,
3. Phy_ MM ,L , lit li flr 1 1 y of Unit
During the Vsr, the investigator should examine the physical
condition of the unit for Indications of releases that way contami-
nate ground w«ter. Deterioration of above-ground tanks should
reveal obvious signs of rust, corrosion and spills. Records of
recent leak inspections may also be available for both above and
below ground tanks, and these should be reviewed as part of the
PR,
It is likely to be difficult to evaluate the physical Integ-
rity of many larfeMBised units, Mowevir, dlket ir'itfnd surftee
impoundments tay show signs such as cruwbllrigj sltiiflrtg, dnd
1nf lltratlttff around the toe, suggesting that iht 1fit^§7i1ty of the
impoundment Is quest lemable. In general, the Irtvtfsflgator cart
assume that Ktost WrtHned landfills and surfiee 1iipoahd«ints hive
leaked to ground water,
B. Has t e C h a r MS t e r 1 s t Us
The fnvestlfttor should attempt to Identify the wastes
handled at a facility and originally contained within a Sttfftt or
group of SWMUs during the PR. In the PR, the IriVesf IfitBf will
try to connect 1nf&r«»t1on on waste types, hydrttf if legit charac-
teristics, and ground-water contamination to deiif-wlrte whtthfer
or not a SWMU, or group of SMMUs, or other areas tf fe^neern at
RCRA facilities have released constituents to the grtfcind water,
This section describes technical factors to consider whtn identl*
fying waste characteristics relevant to ground-water releases.
It also discusses physical /chemical properties thit will affect
tne release potential of wastes and their subsequent transport in
ground water*
The tendency for different haiardous constituents to migrate
from a given unit or area, through the unsatiirated zone, and Into
the ground water, will depend upon: the amount of wtste present,
Us physical state (I.e., liquid or solid), and the physical and
chewical properties of the constituents and the geologic materials
Many of the constituents In Appendix VII! are essentially Insol-
uble In water (at neutral pH) and/or bind tightly to soil par-
ticles, reducing their tendency to migrate in ground water. The
5-7
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Investigator Should consider the potential mobility of the wastes
In a unftj 1ri combination with previously described unit-specific
factors, when assessing the likelihood of release.
The Mobility of organic constituents can be expressed quan-
titatively by the sorptlon equilibrium coefficient (Kjj). The
value of K^ depends upon the organic content of the soil and the
constituent-specific soil adsorption coefficient (Koc). In most
cases, 1t dill be more useful to estimate the relative mobility
of a constituent by considering only the Inherent mobility of the
constituent as expressed by Koc; the Investigator will seldom have
access to Information on the organic content of soils at a facility
Few Koc values have been estimated for specific constituents;
however, the octane!-water partition coefficient, (Kow), can be
used as an Indicator of KQC. Appendix E presents KQ^ and log
(Kow) values for many constituents of concern for ground-water
releases. Because these are log values, chemicals with Kow values
of more than two can be considered relatively Immobile; a value of
less than one Indicates that the constituent Is relatively mobile.
There are several limitations on using this measure of mobil-
ity. As stated above, actual constituent ffiob1l1ty depends upon
the organic content of the soil, Which will not be known 1n most
cases. In addition, other geologic factors fe^g*, fitilts, frac-
tures, solution cavities) may provide opert eHafiriels for the
migration of contaminants which could make the application of the
concept of waste mobility Inappropriate In these §1t«a*1orts» The
presence of other wastes In a unit may also substantially alter
the mobility of a constituent*
Hazardous metals and Inorganic compounds may also be" rela-
tively mobile 1n ground water (e.g., arsenic and cyanides are
extemely mobile constituents). Their mobility will depend upon
the pH of the wastes and the ground water, the ox^datldfi-redtietlon
potential of the ground water, *nd the Hgsnds present ftif complex
formation (e.g., the presence of carbonate Ions In the ground
water will support the formation of relatively Immobile metal
complexes), and the geologic factors discussed above. The geo-
chemistry of the materials underlying the facility will affect
constituent mobility by governing the presence off these Hgands
(e.g., carbonate Ions will generally predominate 1n limestone
aquifers).
n. Pollutant Migration Pathways
The Investigator should evaluate any available Information
pertaining to the hydrogeolog1c characteristics of a facility
1n order to determine the pollutant migration pathways associated
with ground-water releases during the PR. This Information, such
as the direction and magnitude of ground-water flow, soil charac-
teristics, depth to ground water, aquifer media, and climate,
may play a major role In Identifying ground-water releases at a
facility. The Investigator should rely on best professional
5-8
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Judjmtftt and Stirtdird geologic and hydregeologie principles,
consulting lift irtforfltaff on sources discussed In Chapter Two or?
the sutrtuffiei eMiraeterlstles of the site.
In easts wfitri the Investigator finds little direct evidence
that a piftltulif unit had a release to ground water (e.g.,
documented evJffrtet of a substantial tank leak), he/she may have
to deduct the likelihood of release from a facility by linking In-
formation on wastiS, units comprising the facility characteristics
of the pollutant migration pathway, and evidence of ground-water
contamination located In this migration pathway. This demonstra-
tion will depend primarily upon an adequate characterisation of the
direction and rate of ground-water flow at the facility*
The Investigator may choose to recommend more detailed or
immediate Investigations at the end of the RFA for facilities
with particularly vulnerable ground water {eig*, shallow sattd and
gravel aquift*«sj, More definitive guidance on evaluating thi
vulnerability of ground water Is contained in the criteria for
determining ground water vulnerability which OSM released In July
1986, [Interim {*'«!,_ July 31. 1986 "Criteria fer Identifying
Areas of Vulnerable Hydrogeolofy . "1 this guldifei #*y fc* Helpful
ir» situations where a more complete understandlrtf $f grfturtd wltar
vulnerability irfoUld assist 1n waking tfte rteees/ilry dit e r iff 1 rial ions
in the RFA for a facility.
The ground water regime of the facility should fce evaluated,
for other potential migration paths, for eAaiplf, §r*ourtd i^aier
often recharges surface water bodies. Locating |(fttt»fjd-wiitf r
discharge points may toe Important when identifying |Ne pofeefftial
for surface water releases resulting fro* corrtailrtiitd f round water
Evaluation 8f the ground-water pollutant rn
may also Include evaluating any existing ground*wattr fohitorlng
systems at the facility which may be capable of. deiectlrtg releases.
If ft appears that an existing monitoring system way provide
information on continuing releases it the facility, 1t may be
ntcessiry to evaluate Its technical adequacy. Procedures for
examin-fng the technical adequacy of existing m0nv1*0Mrig wells are
described in Section III of this chapter,
When the investigator determines that an e*1st1n§ ground-
water monitoring system and tn£ sampling and analysis program are
adequate to detect releases t,6 ground water, and analytical data
(e.g., within the past year) indicate that there is no release,
it may not be necessary to Investigate the unit or facility
further.
D . Evidence of Release
The investigator should examine any available sources of
1 ^formation to identify evidence that constituents have been
released to the ground water at a facility, The Investigator
should evaluate both direct and indirect evidence of release
5-9
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during the PR fftd VSI. Qeneral considerations on how to look for
evidence of release are discussed 1n Chapters Two and Three.
Direct evidence of release to ground water may Include
official reports of prior release Incidents, such as a major tank
car sp1H to the ground or documentation that a surface impoundment
hss released to ground water (e*g«» some states used to permit
releases to ground water through their NPDES permitting process).
Indirect evidence of a release from the facility or a specific
unit at the facility win usually entail Information on general
ground-water contamination. When the Investigator identifies
indirect evidence of a SWMU release of this type, It may op
necessary to determine which SNMUs are likely to have released
the relevant constituents by evaluating the pollutant migration
pathways (hydrogeoiogic characteristics* and the waste character-
istics at the facility, as discussed previously,
VSIs may detect releases to other media, particularly soils,
that may indicate a high probability that eorttaminants have
migrated to the ground water. Evidence of soil eontanH nation,
either through visual or sampling data, can provide an indication
tnat a release to ground water has occurred.
At some facilities, ground-water sampling data n*ay be
available from wells at the facility; off-site wells* or from a
spring near the facility. Other facilities maty Hav0 no greund-
water monitoring Information relevant to the cryerstl facility.
At these facilities, the investigator should consider available
data -on soil contamination or results of Soil gas rntmltdrlricj.
Electromagnetic conductivity surveys may provide evldertce of
release for ionic species.
At facilities with ground-water monitoring data, these data
may indicate that hazardous constituents could have migrated from
the facility. However, the investigator will still rt£ed to eval-
uate the facility's units, waste, and migration pathway charac-
teristics, in order to support the possibility that the consti-
tuents originated from SWMUs at the facility.
E. Ex p. os a r eP o t e n 11 a 1
The investigator should evaluate available information on
the location, number, and characteristics of potential receptors
that could be affected by ground-water releases at the facility.
These receptors include human populations, animal populations
(particularly any endangered or protected species), and sensitive
en vi ronment s *
Exposure potential Information will be used primarily in
helping the investigator determine the need for interim corrective
measures at the facility in order.to address instances of ground-
water contaminatfon posing especially high risks of exposure.
Types of exposure information of concern include:
5-10
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o Tht proximity of the unit/facility to downgradient
drinking water and Irrigation wells;
o The potential for use of the aquifer as a drinking water
source; and
o The potential effect of aqylfer discharges to nearby
surface water.
the Needf ofyAddl 1.1 on a 1 Sajl 1 no Inf ormat 1 on
The Investigator may not be able to determine whether a
yroynd-watef release from a unit/facility has occurred or Is
likely to have occurred based upon existing data and the factors
described previously. In these situations, he/she should consider
whether conducting a sampling visit to obtain additional evidence
and fill data gaps will be needed 1n making a determination. In
this sect 1 on „ me presenit:
I) General information on factors to consider In determining
th« need for additional sampling Information;
2) Factors to consider In selecting sampling parameters', and
3] An example to Illustrate this discussion.
1 , Sen £jrajtv In f o r «a 1 1 on on Oe t e r wjj^ijrH} ....... _ t h e Meed .:irf Of S a mp 1 1 ,n 3
4f some facilities existing monitoring wells may be present
which coyld detect contaaf nat Ion from SMMUs at the facility.
Existing analytical data from such wells way, however, be Inadequate
or unreliable. In such situations, new analytical data may be
yseful In waking release determinations. The following 11st
presents situations where additional sampling data could be
helpful In determining If a release has occurred;
o Available data are outdated, generally when data ire
over one year old;
o The analytical methods use4 were Inappropriate,
parti :Mlarly if methods with very high detection levels
that may obscure significant releases weft used;
o QA/OC was of unknown levels or non-existent;
o Qft/QC information available (e.g. contaminated field/
trip blanks) suggests that available data m-ay be Invalid;-
o The parameters monitored do not correspond to the waste
constituents suspected from the release, due to factors
such as quantity and mobility. For example, SC/MS
priority pollutant scans are available to detect a
relfrsse o* those chemicals, however, the waste contains
metallic cyanides and there is no data on either metals
or cyanide in the available sampling data;
5-il
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o The available data are not of a rigorous QA/QC level or
may be questioned for other reasons, and It 1s anticipated
that the facility will challenge any permit condition or
enforcement order requiring an RFI; and
o The available data are based on samples taken from
wells which were not adequately oriented to detect a
release from a specific unit and better wells have
since been Installed or located but not sampled. It Is
not routine to require that wells be Installed during
an RFA.
2. Se1 e; c11 on of SampH ng Pararceter s
Knowledge of the wastes that may be potentially released
from a unit is the starting point when Identifying sampling
parameters. However, many facilities have Incomplete or no data
on the wastes deposited over time. When little Is known of the
wastes managed in the unit, gas chromotography/mass spectrometry
(GC/MS) scans of various constituent groups (e.g., volatlles) are
often a good starting point. Investigators should select the
parameters to be analyzed for based on the facility-specific
information available and on the Investigator's professional
j udgment,
When a waste source is hazardous due to EP Toxlclty, the
metals of concern are: arsenic, barium, cadmium, chromium, lead,
mercury, selenium, and silver.
The volatile SC/MS scan Identifies chemicals that are charac-
teristic of solvents and lighter petroleum products (e.g., gasoline)
Many of these compounds are readily found in the environment from
releases from various waste sources. Because they are very vola-
tile, older wastes may no longer contain these constituents since
they may have been released by evaporation Into the air. The
indicator parameter, TOX, identifies the presence of halogenated
organics. If TOX levels have been Identified, a volatile scan
should be helpful in identifying the specific compound released.
Acid extractable compounds may be present In heavier petro-
leam feedstocks, and certain industrial processes (e.g., penta-
chlofophenol from wood preserving). Some compounds (e.g., phenol,
pentachlorophenol, 2-chlorophenol) are commonly found from many
waste sources including organic waste treatment sludges. Phenol
and the mono halogenated phenols biodegrade readily In most soil
and surface water environments.
Base/neutral compounds can often be found In wastes from
industries such as organic chemicals, plastics, and synthetic
fibers manufacturers. The pesticide scan 1oent1f1es pesticides
that are found specifically in pesticide was*.es and products from
the agrichemical industry.
5-12
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3, Example
An 1t1ystratlon ef a situation 1n which sampling would be
called for 1s as follows; An unlfned surface Impoundment, con-
structed twenty years ago from naturally occurring site material,
1s located at a facility close to homes withdrawing water from
domestic wells. The onslte soils are high 1n clay content,
although they ilso contain abundant cobbles which would Interfere
with adequate compaction.
The Investigator determines that the Impoundment has not
received any wastes 1n the last five years; however, the pre-
viously deposited waste material has never been removed. The
wastes are Identified as unspecified wa&te oils from unknown
sources and wastts containing lead and cadmium. While monitoring
wells have been Installed, the worft.teHng data collected from
them only measure Indicator parameters (t.g.» pH, condyetlvlty,
TOX and TOC), Only one parameter (TOC) showed an Increase over
background. In addition, State sampling data from off-site
domestic wells detected significantly elevated levels of lead and
copper. However, the sampling protocol collected samples directly
from the resident's tap, making It possible thit the contamination
originated 1n the domestic plumbing system.
Because of the unit's design, construction method, and age,
the Investigator may strongly suspect that a release has occurred.
While monitoring data exist, Indicator parameters are not ade-
quate to Identify potential releases of heavy metals. The one
elevated parameter, TCC, suggests that orginlcs may have been
released from the oily wastes* However, elevated TOC values do
not conclusively Indicate contamination from man-wade sources,
ind may result from natural sources.
In this scenario, the Investigator should probably call for
additional ground-water sampling from existing wells to ffnd
constituent-specific evidence of release not provided by the
Indicator parameters. He/she would probably sample both on-s1te
and off-site wells for lead, cadmtum, add extractabl es, and the
base/neutral priority pollutants.
The add extractables and base/neutral priority pollutant
scans would be appropriate since they can Identify many of the
constituents commonly fouid in petroleum oil based wastes
{especially since the composition of the wastes was largely
unknown). While ft might be possible to Identify other constit-
uents at the site (e.g., VQCs), the Investigator would probably
limit the sampling parameters to those most likely to be present.
Because of the high cost and delay associated with analyzing
sampling results, the Investigator should attempt to limit the
selection of sampling parameters to those most likely to result
1n an Identification-of a release from.
5-13
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III. COLLECTIKG ADDITIONAL SAHPLIHG INFORMATION IN TH* SV
This section presents technical Information related specific-
ally to th* ground-water pathway to be considered when collecting
additional sampling Information In the SV. The Information
presented here should be used to help the Investigator meet one
of the primary goals of the SV:
o To collect additional sampling Information to fill data
gaps Identified In the PR and VSI leading towards a
release determination.
For each sampling method discussed, this section describes:
1) the general kinds of situations 1n which 1t will be appropriate
co employ a specific technique, 2) technical Information on how
to conduct the sampling, and 3) specific details to be considered
when evaluating the sampling results. He do not provide the
actual SOPs on the sampling techniques here, although we do
reference the relevant manuals.
The choice of appropriate sampling methods will have a large
impact on the cost and usefulness of the SV. The Investigator
should be confident when developing and reviewing the sampling
plan that the procedures chosen will meet the needs of the RFA,
while not resulting 1n the collection of unnecessary data. We
discuss the following five sampling methods whtch way be of use
when Investigating ground-Mater releases 1n the RFA;
(1) Sampling of existing ground-water monitoring wells;
|2) Soil sampling;
(3) Soil gas monitoring;
(4) Electromagnetic conductivity mapping;
(5) Sampling of domestic wells; and
(6) Installation and sampling of new ground-water
monitoring wells.
A. Samp11 ng of Exist 1 ng firound-Water Mon 11or 1 njt Welljs
The Investigator should sample existing groun*-water moni-
toring wells when they may provide useful data on contamination
resulting from facility-wide releases. As discussed 1n the
previous section, the Investigator may decide to sample wells
when the most recent data are outdated, when the laboratory
analysis procedures are unknown or questionable, or when the
sampling parameters were Inadequate. The Investigator may alsu
choose to sample existing wells to provide EPA with data of Its
own when the only available data was collected by the owner/
operator.
5-14
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The procedures for sampling monitoring wells have been de-
scribed extensively 1n many available documents. The Investigator
should rely upon his/her best professional Judgment when collecting
samples at existing wells. Well configurations at SHMUs should
be adequate to detect releases from these units. Before collecting
additional Information, the Investigator should ascertain the
adequacy of an existing monitoring system. He/she should evaluate
the locations of wells 1n relation to the specific SHMUs or other
areas of concern. In many cases, a facility's monitoring wells
will have been Installed to detect contamination resulting from
regulated units, and will not pick up releases from other units
or areas of concern. Exhibit 5-2 depicts three examples of moni-
toring well systems, one that would be adequate for detecting
SWMU releases and two that would be Inadequate.
After assessing the adequacy of well locations, the Investi-
gator should evaluate data on well construction and design 1n
order to determine Its adequacy. While data from properly con-
structed wells may be of higher quality, 1t will not be necessary
to ensure that existing wells meet the stringent requirements
discussed 1n the RCRA ground -,.att>r Monitoring Enforcement 6u Ida nee;
8CRA '''
. :
" Tfie~~1 nvestl 'galfor "Vffouftf use beW pFoTessonal
Ji7?gmenT 1n evaluating sampling data based upon the quality of
the ex1 st1 ng wel Is .
Sampling of ground-water monitoring wells In the RFA should
be conducted by trained personnel. EPA has developed numerous
guidance manuals on appropriate sampling procedures. These
manuals may be consulted for specific field procedures:
Q Ground Water Technical Enforcement Guidance Document
Pr_aft» IS u gust 1985 "~ ' ~
o RCRA Draft Permit Writer's Manual: Ground-Hater
FrotecTion. October 1983 — — — — <—
o Manual for Sround-Mater Qua! 1ty Sampl ing Procedures .
TUT" "~~" "" " """"
--.-.-- 6r ou nd -jja t er ...... |nspfcjt Ions
fc t' r ' '
The Investigator should refer to Chapter Four for specific
recommendations on QA/QC* chal n-of -custody , safety, and
decontamination procedures to be followed 1n the field. In
general, the OA/OC and sampling procedures followed by the
Investigator should be appropriate to the Intended use of the
data. For example, 1f the Investigator anticipates that the
owner /opef ator may contest EPA's sampling results 1n court, 1t
would be advisable to use more stringent procedures.
5-15
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EXHIBIT 5-2
LOCATION
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Ho
for SUHtf If all unit* *re
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O - «« rfc R rmiiul Honltorlntj U«> U
Driving* n»t t«» dole.
-------
The Investigator should use best professional judgment in
evaluating sampling results collected 1n the SV, based upon
sound geologic and hydrogeol ogle principles. General guidance
on evalutlng tasnpUng results 1s presented 1n Chapter Four.
a. Soil Sampling
The Investigator may choose to sample soils at the facility
1n order to gain a;i understanding of the likelihood of a releise
to ground water. Many constituents, when released to soils, w1l 1
further migrate into the surfldal aquifer. The potential for
migration to the ground water will depend upon the properties of
the relevant constituents and the site geology (this Is discussed
in greater detail 1n Section II of this chapter). Soil Sampling
will be especially useful In situations where a facility lacks
ground-water monitoring data or the ground water 1s deep.
Sampling locations should be chosen to provide the most useful
Information. For example, the Investigator may want to determine
whether constituents have migrated from a closed surface Impoundment
Stratified sampling around the unit, and where possible, underneatn
the unit, may be helpful 1n detecting constituent concentration
gradients Indicative fif migration, In other cases, the Investigator
may simply wish to confirm that a release Incident occurred, such
as a spill, by sampling the locution where the suspected Incident
took place* Technical details on how to sample soils Is provided
in Chapter Eight of this guidance.
C . Sol 1 Gas .Mpn ItoMng
Soil gas monitoring can be used to detect the presence of
volatile organic compounds (VOC's) in ground water and wilt be
especially useful 1n cases where existing ground-water monitoring
systems are Inadequate to detect these contaminants. Thfs tech-
nique, developed and used extensively by.EPA's Environmental
Response Team (ERT), detects the presence of VOC's 1n the unsat-
urated zone and provides a good Indication of subsurface soil
and/or groundwater contamination. In addition, this method can
provide same-day results during a field Investigation and will
cost substantially less per sample than well drilling and SC/MS
analysis.
Soil gas monitoring should be performed by trained personnel
The following document describes 1n detail standard procedures
for conducting soil gas monitoring at waste sites:
Lappala, I and S. Thompson, "Detection of Ground-Water Con-
tamination by Shallow Soil Gas Sampling In the Vadose Zone
Theory and Applications." P r pc ee d ings of the H f t h N a 1 1 o n a 1
C on far e nee g n H a n a ge ffl|n t T J? I. ' Jl Ac Q n t r of 1 e d 'nf^a^rl|cKiT__M j s t e
TTTes, Washington. D.C., 19S4.
5-17
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The following description of soil gas monitoring procedures
ts Intended to assist the permit writer In recognizing those
situations where Its use would be appropriate, and to enable
him/her to oversee Its Implementation by a contractor or the
owner/operator.
When ground water or soils have been contaminated by VOC's,
gaseous components of these compounds will be present 1n the
Interstitial pore spaces of the soil matrix, and are known as
soil gas. By sampling the gas 1n this Interstitial space and
analyzing ft for VOC's with a portable gas chromatograph In the
field or In the laboratory with a 6C/MS, the presence of soil
and/or ground-water contaminants can be Indicated.
First, the Investigator must make a vertical hole In the
soil through which the gas samples can be drawn. A hole can be
made to a depth of five feet with a solid spring steel single
piston slam bar {1.75m x 16.7 mm diameter). Threaded four foot
sections can be added to the slam bar when holes deeper than five
feet are deslred.
After the hole has been made, the slam bar should be removed
carefully to prevent the walls of the hole from collapsing. The
Investigator should then Insert a stainless steel sampling tube
into the hole. In order to prevent soil from clogging the sam-
pling tube, a Teflon tube, slightly longer than the sampling
tube, should be Inserted Into the sampling tube. The Teflon tube
should be just wide enough to hold a small nail in Its end, so
that the nail head 1s wide enough to cover the end of the stain-
less steel sampling tube.
The sampling tube should be Inserted Into the hole* nail end
first; when the sampling tube has been Inserted to the desired
depth, the Teflon tube can be removed, causing the nail to drop
to the bottom of the hole. The sampling tube should then be
removed 6 to 12 Inches to ensure that soil gases will enter
freely. Finally, top dirt should be packed around the tube to
minimize 1n1ltrat1on of ambient air from the surface.
Soil gas will be pulled from the sample hole using a S1Han
pump. ERt recommends evacuating five to seven gas volumes prior
to sampling the hole. For a 1/4" hole about 10? deep and a
pumping rate of three liters/minute, this evacuation should take
about 15 seconds.
The gas 1n the well can he collected and sampled using three
different methods. Tfe simplest Involves attaching a portable
photo1on1zat1on detector (e.g., Hntf) to the stainless steel tube,
using a short piece of Teflor, tubing. The HnU provides Indica-
tions of the total organic vapor concentration within the hole
calibrated to a benzene standard. This method does not provide
the Investigator with Information on Individual compounds present
In the soil, but may provide a sufficient Indication of contami-
nation to suggest the likehood of a release.
5-18
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The HftU thould be calibrated properly prior- to use. A back-
ground reading of 1 to 2 ppm {Ȥ benzene) may result from soil
moisture. Once the HnU reading his stabilized, usually §fttr 4S
to 60 seconds^ the reading should be recorded,
Tedlar bags cin also be used to collect soil gis for field
analysis with a portable photo1onizit1on gas ehromatograph (e.g.,
Photovae) or Ifbontory analysis with a cryogenic trapping capil-
lary column gis ebromatograpb/mass spectrometer. The Tedlar bag
should be filled with about 200-700 ml of vapor from the borehole,
and inalyied within no more than 48 hours. This technique has
the advantage th*t Individual compounds miy be detected, provid-
ing more detailed sampling data during the SV, One disadvantage
Involves uncertainties concerning the Interaction of the Tedlar
bag ind the gas being collected. However, the quality of the
data will be higher than that obtained using an HnU,
The most accurate technique for sampling »nd «tii.!ysis will
Involve the use cf sorbent tubes (e,g.» Tenix, Chromosorb, etc,)
to collect gas samples for laboratory analytis by SC/MS. Seeause
contaminants collected on sorbent tubes maintain their Integrity
for a longer period (14 days) than those collected with Tedlar
bags, 1t may be advantageous under some circumstances to use them
to collect soil gas samples. The chief disadvantage of this tech-
nique Involves the necessity of analyzing the samples in a labora-
tory, adding time and expense to the monitoring procedure,
Soil gas monitoring can be effective in detecting VOC's in
soil gss which have a vapor pressure greatar than xylene (5 mm
Hg). Vapor pressures of a number of constituents of concern are
listed In Appendix E for further reference. This monitoring
technique does not provide a direct Indication of the concentra-
tion of contaminants 1n ground water or soil. The r»fatioftship
between soil and ground-water concentrations ind soil gas concen-
trations will depend greatly upon the organic content of th* soil
and the octanol-water partition coefficient of the Constituent of
concern. The technique will provide the investigator with evidence
of subsurface contamination, which will usually be sufficient to
Indicate the need for an RF! at the locations of concern.
0. Electromtflnet1c Conductjy1ty Mljping
geophysical techniques hiva gained acceptability in the last
five years for the Identification of waste releates to both ground
water and soils, as well as for the sensing of buried wastes,
This section briefly discusses one of these techniques, electro-
magnetic conductivity mapping (EM)P which may be useful during
the RFA.
•*
EM surveys can provide an Indication of ground-wat«jr contam-
ination at sites with relatively simple, well-defined hydro-
geologies (e.g., shallow, relatively uniform sand and gravel
aquifers). This technique measures changes 1n the conductivity
of the subsurface materials at a site, which may depend upon the
5-19
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composition of the tubsurfiee so1l$» and/or the presence of
dissolved contaminants In the ground water.
EM surveys provide 1so*conduct1vlty contours it a site,
Indicating tht movement of contaminants from i source. While
this technique dots not provide Information on either the types
of constituents present, or their concentrations, It can provide
Indirect evidence of a release. However, It will primarily
Indicate only the presence of ionic constltutents fn ground water.
Conducting IM surveys requires qualified personnel and
expensive equipment, although It will be a relatively Inexpensive
method when using experienced contractors In the SV, This section
does not provide technical Information on how to perform an IM
survey.
The Investigator should be cautious when evaluating the re-
sults of an IM survey, due to the potential for Interference from
unusual geologic conditions at the site. Different geologic
materials hive different conductivities (e.g., moist clays have a
higher conductivity than do dry sands). At facilities with
complex hydrogetlof1c characteristics, the results of EM surveys
could provide a false Indication of contamination where non-homo-
geneities in the subsurface media reveal differences In conduc-
tivity. The difficulties associated with analyzing these data
represent the major drawback to using this technique,
E. Sampl 1 ng of Pojtejt 1 e EelIs
In certain unusual cases, the Investigator may choose to
sample domestic wells 1n order to identify releases from the
facility. This will be especially Important whtn the Investigator
believes that a contaminant plume originating at the facility
could pose an Imminent threat to human health or the environment
near the facility. Sampling data taken from domestic wells could
provide sufficient evidence to suggest the need for tmuftditte
interim corrective measures at a facility (e.g., such as cotfnttr-
pumplng, or provision of an alternate drinking water supply).
Sampling residential water supplies could alarm affected
residents. Because of this potential for community reaction*
domestic wells should only be sampled when the Invastlgator has
strong evidence to suggest the presence of a threat,
When sampling domestic wills, 1t Is Important to run the
water to remove any standing water within the distribution system.
It is also important to take the samples prior to any 1n line
treatment systems (e.g., water softeners).
F. InstallationOf New Monitoring Hells
In unusual situations, EPA may find that new monitoring
wells should be Installed during the RFA in order to obtain
useful ground-water data. While this should not be necessary at
5-20
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most, facilities, ft may be appropriate where ground-water data
are wholly Inadequate, where other sampling ttchrdques do not
provide sufficient Information on the site, or 1f tnt owner/operator
Is recalcitrant and the Investigator suspects that a release has
occurred.
In most cases such is that presented above, the Investigator
should rely upon Information collected during the RFA to demon-
strate that a release may have occurred, and recommend that the
facility conduct an RFI. However, this may not be possible when
dealing with recalcitrant owner/operators. As a last resort,
the Investigator can recommend that new wells be Installed,
Procedures for Installing new wells should be based upon
accepted hydrogeologle principles and best professional judgment.
New wells should conform to standards described In the TESD or
Sybpart F. their locations should be chosen based on knowledge
of site hydrogeology and best professional judgment.
IV. MAKING SftOUND-HATeft RELEASE DETERMINATIONS
Th§ final tssk 1ft the RFA process Is to wake determinations
of release potential throughout the facility and to mafce recommen-
dations for further action to address these potential releases.
In making release determinations, Investigators should evaluate
the relevant Information on unit characteristics» waste charac-
teristics, site hydrogeology, and any evidence available from
sampling and analytical data* Potential for exposure of receptors
to contaminated ground water may also be a consideration In making
conclusions for further action. If on the basts of th§ Information
and evidence available to the Investigator, and his/her best pro-
fessional judgment. It can be reasonably determined that there
is, or Is likely to be, a release of wastes or hazardous constituents
to ground water which merits further Investlgatlemysfirsricterliatlon,
or an Immediate Interim remedy, the owner/operator should be
required 1n the RF! to conduct these necessary actions. It should
often be possible, from the Information gathered 1n the RFA, to
be abls to specify 1n some detail the nature of the Investigations
to be conducted; I.e., the area to be given further subsurface
investigation, the constituents to be monitored ftfr, the general
area to be monitored for, and other elements of the ground water
characteHlatIon program*
It should be understood that 1t 1s not necessary to prove 1n
an RFA that ground-water contamination has occurred from SMHUs at
a facility. Confirming the presence of a release will often be
the Initial phase of a follow-on RF1 Investigation.
Exhibit 5-3 is a checklist that should help the investigator
evaluate specific factors to Identify ground water releases and
determine the relative effect on human health and the environment.
In identifying releases, the Investigator should consider the
types of Information presented in Exhibit l-l, which art high-
lighted in this checklist,
5-21
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Exhibit S-3
for Ground Hater Releases
I dent 1 f y I ng Releases
l« Potent! & 1 f fl r ft r o u n d tf a t a r Re 1 e a s e s
o Unit type ind design
Does the unit type (e.g., land-based) indicate th
potential for release?
Does the unit have engineered structures (e.g.,
lifters, leschate collection systems, proper
construction materials) designed to prevent
releases to ground water?
o Unit operation
Does the unit's age (e.§,, old unit) or
operating status (e.g., inactive, active)
Indicate the potential for release?
Does the unit have poor operating procedures
that increase the potential for release? >
Does the «rt1t have compliance problems that
indicate the potential for a release to
ground water?
o Physical condition
Does the unit's physical condition indicate the
potential for release {e.g., lack of structural
integrity, deteriorating liners, etc.)?
o Locational characteristics
Is the facility located on permeable soil
so the release could migrate through the
unsaturated soil lone?
Is tr.a '*ciMty located in an arid area with less
1nr
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Exhibit S-3 (continued)
Checklist for Ground Mater Releases
o Miste eharaet ~r1 sties
Does tht waste exhibit high or moderate character-
istics of mobility (e.g., tendency not to sorb to
soil particles or organic matte:* 1r> the unsaturated
zone)?
Does the waste exhibit Nigh or moderate levels of
toxlclty?
Does the waste exhibit hazardous characteristics
(e.g., lower high pH)?
E-yJjidenee....of ,,S round Wat_e:rii ReJ ...... e_asjss
o Existing ground-water monitoring systems
Is there an existing system?
Is the system adequate?
Are there recent analytical data that
Indicate a release?
o Other evidence of ground water releases
Is there evidence of contamination around
the unit (e.g,f discolored soils, lack of or
stressed vegetation) that indicates the
potential for a release to ground wattr?
Does local well water or soring water sampling
data Indicate a release from at facility?
Determining
..
1. Exposure Potential
o Conditions that Indicate potential exposure
Are there drinking water well(s) located near
the facility?
Does the dfrectfon of ground water flow
indicate the potential for hazardous consti-
tuents to migrate to drinking water wells?
Does the ground water discharge to a surface
water body with recreational use or that supports
fish or arty endangered species?
S-Z3
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CHAPTER SIX
SURFACE MATER
I. INTRODUCTION
A. P.Mf.i.Qse
This chapter provides technical Information to support the
investigation of SWMU and other releases to surface water during
the RFA. While Chapters Two, Three, and Four provide general
guidance on conducting RFAs, this chapter focuses on specific
factors unique to the surface water media that should be con-
sidered by the investigator.
This chapter has been organized to reflect the separate
phases of the RFA process
o Conducting a preliminary review of existing information
related to releases to surface water;
o Inspecting the facility to obtain evidence of release;
o Collecting additional sampling Information in the SV; and
o Making final release datermlnations .
The first section describes the technical factors that should
be considered during the PR and VSI. The second section describes
the technical approach to obtaining additional Stripling information
In the SV for surface water, and should be consulted along with
Chapter Four on conducting a SV, The, final sect 1 art discusses
factors to consider when making release determinations to surface
water at the end of the RFA, This section also discusses the
options for further investigation to be evaluated at thfe end of
the RFA for surface water releases.
B.
The investigator should evaluate all RCRA facilities for
releases to surface water that pose an actual or potential threat
to nuraan helath and the environment. These releases may include
surface water discharges permitted or required to be permitted
under the NPOES program. In these cases, the investigator should
attempt to make an initial characterization of the potential
problem. However, he/she should usually refer the further inves-
tigation and control of these discharges to the NPOES permitting
authority, rather than addressing them through RCRA authorities
[§3008(h), §3004(u), or §3004(v)J. EPA is developing more specific
guidance on how to make these referrals.
-------
In most easts surface water Investigations will relate to
run-off froat sp®cif1e SMMUs . However, there may be situations
where general facility ryn-cff may be impacting human health and
th« environment, The 30Q8(h) corrective action authority allows
the investigator to address these situations,
II, CONDUCTING A PRELIMINARY REVIEW AND ¥ISUAl SITE
INSPECTION OF RELEASES TO SURFACE WATER
This section presents technical information related specifi-
cally to the surface water pathway to be considered when eonduct-
4 fig the PR and' VSI» Accordingly, this section has been organized
to reflect the pri«a~y goals of these steps as described in
Chapters Two and Three:
o Identifying aid describing potential threats to surface
water it RCP.A facilities; and
c Baking a preliminary assessment of the need for a SV or
other actions at these facilities.
This section reflects the importance of the RFA information
matrix (Exhibit 1.1} for evaluating the likelihood of releases to
surface water in the PR. ft describes each of the five types of
information described in this matrix as It applies to the surface
water pathway. In addition, this section provides technical
information to help the investigator determine when additional
sampling #111 be necessary in a SV to identify surface water'
releases. The factors discussed are as follows;
(!) Unit characteristics;
(2) Vaste characteristics;
(3) Pollutant migration pathways;
{4} Evidence of release;
(5) Exposure potential; and
(6) Determining tne need for additional sampling information.
This information will be relevant to the evaluation of
written documents in' the PR and information gathered1 during the
VSI. Consult Chapters Two and Three for general guidance on
conducting PAs and VSfs,
A . Urn t haraegri stj_cs
Tiie design and operating characteristics of a SMHU will
determine to a great extent its potential for releasing hazardous
constituents to surface water. Wan/ treatment, storage, and
d.sposal units are designed to prevent releases to the environment
6-2
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The Investigator should evaluate the unit characteristics of each
SMWU or group of SWMUs at a facility to determine their potential
for releasing hazardous constituents to surface water.
As with the other media, the likelihood that a SWMU has con-
taminated surface water or a surface water drainage pathway 1s
largely dependent on the nature and function of the unit. For
example, open units that contain liquids (e*g., surface Impound-
ments} have a greater potential for release than closed landfill
cells that have been properly capped.
Exhibit 6-1 loosely ranks commonly observed SWMUs In a de-
scending order on the basis of their potential for having releases
that may cause surface water contamination. It 1s Intended to
provide a general sense of the relative potentials for units to
cause these types of releases,. The investigator will also ft.sed-
to evaluate unit-specific factors In determining the
for release from & particular unit,
The raajor unit-specific factors the in^e^tf-gato
evaluate are discussed below. ' • '• " -
1. Unit design , ' •<'
\
The investigator should determin^ whether the--tin it has
engineered features (e.g., run-off control systems) that are
designed to prevent releases from the ynit. If such features
are in place, the investigator should evaluate whether they are
adequate (in terms of capacity, engineering, etc.) to prevent
releases, A landfill, for example, mai\^gve berms to control
run-off, but the berms may not be adequate tq contain run-off
daring periods of peak rainfall. In a d «J\t 1 tfh, a surface impound-
ment or open tank with insufficient freeboard v&y not be able to
prevent overtopping that could occur because &f wave action
during storm events.
2. Operational history
\
Ouring the PR and VSI, the fnvesti gator. shsuldj examine the
unit's operating history to obtain information that Indicates
releases have taken place. There are several' operational factors
that influence the likelihood of release.
o Op_erji_t_ 1_n_g__ l_1j^g___. o f._ Jth _e_ ^ u n l^t. Units tha\t. have been operat-
Tng~forr~T6n~g" "p"e7l^ods""of J"tTs»e are generally wore Hkely to
have releases than new units.
o 0p_j^ra_11_n_g^_s_t_at_u_s_o_f__the__u_n_l_t_. In some \:ases!( the operat-
ing" status of a unft TeTgT7~cl osed-5 inactive, etc.) may
have an effect an the relative likelihood of release.
6-3
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EXHIBIT 6-1
RAHKIRG OF UNIT POTENTIAL FOR SURFACE WATER RELEASE
AMD ME:HA«IS«S OF RELEASE
Unit Type
Surface Impoundment
Landfill
Waste Pile
Land Treatment Unit
Container Storage
Area
Above-ground Tank
In-ground Tank
Incinerator
Mass I and IV
Injection Well
Release Mechanism*
o Releases from overtopping
o Seepage
o Migration of run-off outside the unit's
run-off collection and containment system
o migration of spills and other releases
outside the containment area from
loading and unloading operations
o Seepage through dikes to surrounding
areas (e.g., soils, pavement, etc.)
o Migration of run-off outside the unit's
run-off collection and containment system
o Migration of spills an<} other releases
outside the containment area from
loading and unloading operations
o Migration of run-off outside the
containment area
o Migration of run-off outside the
containment area
o Releases from overflow
o Leaks ". rough tank shell
o Spills from coupling/uncoupling
operations
o Releases from overflow
o Spills from coupling/uncoupling
operations
o Spills or other releases front waste
handling/preparation activities
o Spills due to mechanical failure
o Spills from waste handling opera-
tions at the wel1 head
The two remaining solid waste management units; waste transfer*
stations, and waste recycling operations generally have mechanises
of release similar to tanks. All units may release to ground
water when the surface water at the facility is hydrogeologicaS!y
connected to ft,
6-4
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0 p • r a t . "I |M| P f o c e d u r t s . Maintenance and inspection records
snouT "d ...... tnUf cat e 'Whet he r a unit Is likely to hive released.
Units that are Inspected regularly and properly maintained
are less likely to have releases than units that have
been poorly maintained.
Phy.f.1 cal condition of Ejie
During the VSI, the Investigator should examine the units
for evidence of releases or characteristics that could cause
releases. For example, when Inspecting a surface Impoundment,
the Investigator should determine whether the earthen dikes are
structurally sound to prevent releases. Cracks, slumping or
seeps around the tot In these dikes way cause releases to the
surface water draf-rage pathway.
8 . MaA%Ji..._C.hl^r,_'act6r1 st 1 cs
The Investigator should attempt to Identify the wastes
originally contained within a SWMU or group of SWHUs during the
PR, In the PR, the Investigator will try to connect Information
on waste types , the surface water drainage pathway, and evidence
of surface water, sediment, or soil contamination to demonstrate
the likelihood that specific SWMUs, groups of SMMUs, or other
areas have released constituents to the surface water, This
section describes technical factors to consider when Identifying
waste characteristics relevant to surface water releases. It
also discusses physical /chemical properties that will affect the
release potential of wastes and their subsequent transport In the
surface water drainage pathway.
Information on constituents and their properties can aid the
Investigator 1n identifying migration pathways of eonctirn and
sampling locations in environmental media. For example, knowing
that the waste primarily contains heavy metals, which have a ten-
dency to precipitate and settle* the Investigator can look for
evidence of a release In the sediments around the point of dis-
charge Into a river and plan on taking samples of tht bottom
sediment,
Constituents, depending on their properties, will tend to
migrate 1n different forms and at different raits In the pathway.
Some constituents, which are highly soluble, will dissolve 1n
water and be transported within the water column. Insoluble
constituents can be transported Into surface wtt.ar by suspension
from turbulent run-on/run-off. Other generally insoTtrble waste
constituents are lighter than water and will be transported on
the surface, forming oily sheens. Hazardous mttals and inor-
ganics (e*g., arsenic and cyanides) may be relatively mobile 1n
water, depending upon the pH of the wastts and the surface water,
the oxidation-reduction potential of the surface water (this
will be most important 1n the lower layers of deeper lakes), and
the llgancfs present for complex formation. Hard surface watar,
6-5
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due to tht g>r©-f«»ee of higher concentrations of carbonate Ions,
will support tl*« formation of retatlvfcly Immobile metal complexes.
These metal complexes form precipitates, which will settle out
with $ed1«»§nt»-
The tendency of organic constituents to adsorb to soils can
&e expressed quantitatively by the sorptlon equl Mbrlunt coeffi-
cient fX
-------
deductions on the likelihood of release by Unking Information
on waste characteristics, the pollutant migration pathway, and
Indirect evidence of release (e.g., environmental sampling data
showing contamination of surface water, soils 1n drainage pathways,
or stream sediments). It will be easier to demonstrate that a
contaminant originated at a particular SWMU when the Investigator
can show that, based on the characteristics of the surface water
drainage pathway, a release from the particular SWMU would be
likely to result 1n the observed contamination.
In chtraeterlzfng surface water release pathways, the Invest-
igator should Identify any drainage pathway(s) leading from
the unit of concern to surface water. Topographic maps provide
information on the slope of the Intervening terrain between the
units of concern and downgradlent surface water, which 1s helpful
in determining the route run-off follows to surface water. These
maps may also help 1n locating surface water bodies.
Upon entering surface water, the transport of the constituents
in the surface water pathway 1s highly dependent on the type of
surface water body. The three major classifications of surface
water are: rivers and streams, Impoundments (e.g., lakes, bays,
etc.) and estuaries (Including wetlands).
Contaminants entering rivers and streams will tend to be
transported downstream. However, as discussed earlier, heavy
metals are likely to settle out with sediment. Also, VOCs entering
a turbulent stream may volatilize Into the air.
Constituents entering Impoundments or estuarlne systems will
tend to pollute areas near their discharge points because these
water bodies are relatively slow moving and are not likely to
transport the constituents significant distances.
The Investigator also should look for any effect that permit-
ted discharges (e.g., NPOES, dredge or fill) may have on environ-
mental pathways. For example, a NPOES discharge may be releasing
ftCRA constituents not covered by the permit, causing downstream
contamination. In addition, the Investigator should consider the
possibility that waste 1n NPDES units or In other permitted
discharges may be releasing to ground water or air.
Finally, the Investigator should consider possible Intermedia
transfers to surface water. He/she should consider the potential
for releases from soil and/or ground water (ground water discharge)
to affect the surface water pathway.
In sum, the Investigator should use his/her knowledge of the
constituents 1n the waste, the drainage patterns leading from the
ur,1t tc surface water, and the effect of different surface water
bodies on the transport of various constituents, to Identify areas
to look for evidence of release. He/she should also use this
knowledge to specify appropriate sampling points.
6-7
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0, Cvldtftgf of Rfltase
The 1r»ve§t1gator should examine any available sources of
Information td Identify evidence that constituents have been
released to the surface water at a facility. The Investigator
should evaluate both direct and Indirect evidence of release
collected during the PR. General considerations on how to look
for evidence of release are discussed 1n Chapters Two and Three.
Direct evidence of release to surface water may Include
official repofti of prior release Incidents, such as a major tank
car spill to the ground or documentation that a surface Impound-
ment has released to surface water. Indirect evidence will
usually entail tnformatlon from surface water quality monitoring
data, Including visual observations of aquatic stress (e.g., fish
kills) from water contamination, When the Investigator Identifies
indirect evidence of this type, It may be necessary to determine
its source at the facility by evaluating the pollutant migration
pathways and the waste characteristics at the facility.
The Investigator should examine available sources of Infor-
mation and use recent visual observations obtained during a
site inspection to Identify any evidence that hazardous constit-
uents have released from SMMUs at the facility to surface water.
NPOES.files are particularly useful 1n Identifying historical
releases to surface water or determining the likelihood of current
releases, NPDES personnel that are familiar with the facility can
often obtain Information on past releases. Other key sources
of information Include: RCRA Inspection reports, CERCLA reports
(e.g., PA/SI), and,discussions with the State agency responsible
for fisheries and wildlife management,
Due to the Intermittent nature of many surface water releases,
the VSI 1s particularly Important. The investigator should
examine the site and nearby surface water for physical evidence
of release and focus on trying to obtain evidence of releases 1n
areas between the un1» and the closest surface water body. The
Investigator should look for visible evidence of uncontrolled
run-off. If releases have occurred or are occurring at a unit,
there 1s likely to be evidence around the unit that Indicates a
ralease 1s taking place. In addition, 1f the facility 1s located
adjacent to surface water, the Investigator should examine the
surface water for evidence of releases. During the VSI, the
Investigator should look for:
o Observable contaminated run-off or leachate seeps;
o DrainsP« patterns that Indicate possible run-off from
units at the facility;
o Evidence of wash-outs o* floods,, such as highly eroded
son, damaged trees, etc.;
-------
o Discolored son, standing water, or dtad vegetation
along drainage patterns leading from the unit;
o Discolored surfaci water, sediment or dead aquatic
vegetation;
o Evidence of fish kills;
o Uflpermitted point source discharges;
o Units (Including old fill material that 1s now considered
hazardous waste) discharging 1n surface water; and
o
Permitted discharges that are of concern, e.g., downstream
contarwl nation resulting from permitted discharges;
release of RCRA constituents to surface water; PfPOfS
units/discharges causing contamination problems In other
media (e.g., air, ground water).
E. jjywsjirfrp.. tenti V
The Investigator should evaluate available information on
the location, number, and characteristics of potential receptors
that could be affected by surface water releases at the. facility.
These receptors Include human populations, animal populations
(particularly any endangered or protected species), and sensitive
envl ronments .
Potential receptor information will be used primarily in
helping the Investigator determine the need for Interim corrective
measures at the facility in order to address instances of surface
water contamination posing especially high risks of exposure.
The Investigator should evaluate the likelihood for receptors
to be exposed to hazardous constituents through releases to
surface water 1n order to assess the severity of release. If
receptors ire currently being exposed to a release .or Wave a high
potential for being exposed, thin the Investigator should consider
recommending Immediate corrective measures (e.g., run-off control
measures) to limit or eliminate exposure to the release*
The types of information that ire useful in evaluating the
potential far hu««n and environmental receptors to be exposed to
surface wate*" releases are discussed below.
Human receptors can be exposed to the reltase via their
use of surface water. The Investigator should determine the use(s)
of the surface water body of concern (e.g., no use, commercial or
industrial. Irrigation, fisheries, commercial food preparation.
recreation, or drinking). A release Is more likely to signifi-
cantly Impact human health 1f the surface water 1s being used as
a source of contact recreation (e.g., swimming) rather than being
6-9
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usid for* Industrial df * eomwMrctal purposes. Information on the
location &? any drifting or Irrigation water intakes fs usually
listed in ptf&lic records, which way be obtained from the local
health depftftuMrfft*
2, E n vl roj^fff ft.t.a.l,,, rectpt ors
Constituents In a release to surface water may contact sen-
sitive habitats (e.g., a highly productive biological community,
or a hab1t»t of rire or endangered plants or animals). The
Investigator should locate any sensitive habitats in the surface
water pathway. This information can federally be obtained by
talking with State F
-------
ft P triMate rs
Knowledge 0f tfr* wistts that may be potentially released
from a unit Is tWt starting point when Identifying sampling
par ameters « Wwtvtr, many SWMUs have Incomplete of no data on the
wastes deposited dver time. When little- 1s known of the wastes
managed in thrt tfntt, gas ehromotography/mass speetrometry (5C/MS)
scans such as aefd extractables or base/neutral extract ablts be-
come a good starting point when selecting parameters for analysis
1ft surface water ar»d sediments.
When a wastt source ts hazardous due to EP Toxlcity, tht
metals of concern are arsenic, barium, cadmium, chromium, lead,
mercury, selenium, and silver. Tht following metals precipitate
readily under many naturally occurring conditions and can be
found 1n sediment analysis: cadmium, lead, nickel, and zinc,
The volatile SC/MS scan identifies chemicals that art eharar-
teristic of solvents and lighter petroleum products (e.g., gaso-
line), Many of these compounds are readily found in the environ-
ment from releises from various waste sources. Because they are
very volatile, and surface water bodies (particularly rivers and
streams) have the capacity to release the'se constituents via
evaporation into the air, evidence of these ehemfeals may be very
difficult to obtain. It Is not recommended to sriilyit surface
water bodies for these constituents unless a release is current
or on-going, Leach*tt samples and run-off, 1f tvitlfble, are
more ammenable to retaining evidence of volatile scfrtstfttrertt
releases .
Add extrictable compounds may be present in heavier petro-
leum feedstocks, and certain Industrial processes (**•$*•* penta-
chl oropherfol from woffd preserving). Some of those eo-flfpoands
(e,g., phsnol , pentaehl orophenol t 2-chlorophenol ) »re prtsent in
common waste i?ourc*s, including POTW discharges. PHewol »r»d tht
mono-hal ojenateu phenols blodtgrade readily In most s(rfl awd
surface wat^r environments.
Base/neutral compounds can often be found 1n wastes from
Industries such as plastics and synthetic fibers mamrfictuftrs .
The pesticide scan Identifies pesticides that are found specif-
ically in pesticide wastes and products from the agrf chentlsal
1 ndustry,
When collecting surface water and sediment samples. It may
be valuable to sample an up-stream site for the sam« chemical
parameters that will be analysed in the area of the suspected
release. There will often be a high potential for other waste
sources (e.g., ?OTWs, Industrial NPOES di scharges) .to contaminate
surface waters with the same constituents under Investigation in
the RFA.
6-11
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3.
An 11 lattPitf on of a situation in which sampling would be
called far Is t't follows: A waste pile of thickened and filtered
wastewatef treitiHent sludges from an electroplating operation has
been stockpiled on a cement pad for almost ten years. Visual
inspection of the waste pile shows that thtpe are no on-s1tt
controls to present run-on and run-off. In fact, channels are
observed leteHrnj downgradiant from the pile, reaching a medium
sfzed stream abotft 200 yards away.
The waste pile contains both copper and nickel from the
electroplating process. The sludge was formed by the treatment
of wastewaters containing copper cyanide and nickel cyanide by
the addition of lime to form Insoluble precipitates. Analysis
of current sludge samples shows significant levels of cyanide.
There Is no data on the cyanide levels in the ttn year old
waste pil§, There 1s no water quality data from the stream
on the parameters of interest (e.g., copper, nickel, or cyanide).
Fish kills were reported on the stream eight or more years ago.
There have been no recently documented fish (tills,
In this scenario, the investigator should probably call
for sampling to find constituent-specific evidence of a release
to surface water. Cyanide, being mobile in water* Is anticipated
to be leached otit of the waste pile, and dispersed down stream
during storm events. Any evidence of a Release mtfst be preserved
in the soil and sediment. Therefore, the samfllhg7 program centers
around copper and nickel analysis fi* the soils and sediments*
Soil sampling Is recommended for the low spots In the dfttnage
where run-off may have formed puddles.
The investigator should take, sediment samples of the stream
bottom, and analyze them for copper, nickel, and cyanide*
Because cyanide 1s soluble and degradable In small ejufhtltles 1n
the sediments and soils, it may not be found in the sr«dfnife fits' or
remain in the water, Because of the high cost and deliy asso-
ciated with analyilng sampling r-esults, the investigator may
attempt to limit the selection of sampling parameters to those
most likely to result 1n an identification of a release.
III. CGLLECTi'NG ADDITIONAL SAMPLING INFORMATION IN THE SV
This section presents technical information related specifi-
cally to the 'surface water pathway to be considered when collect-
ing additional sampling information in the SV. Accordingly, the
information presented here should be used to help the Investigator
meet one of the primary goals of the SV:
o To collect additional sampling information to fill data
gaps identified in the PR and SVI.
6-12
-------
Per etch taNffplfftf method discussed, this section describes:
1) the ftntrtl fclii^t <*f situations In which it will be appropriate
to employ § speifffe leehnf^uf, 2) technical information on how
to conduct tfct tifftpt1«f» and 3) specific details to be considered
when evaluating fWi sampling results. This section does not pro-
vide tht acini! S0Ps on sampling techniques, but references
relevant
The choice of appropriate sampling methods will have a large
Impact on the cost and usefulness of the SV. The Investigator
should be confident when developing and reviewing the sampling
plan that the pre-cedures chosen will meet the needs of the ft?At
while not resulting in the collection of unnecessary data. This
section d1se«fss«s the following four sampling methods which may
be of use:
(1) Surface water sampling;
(2) Sediment sampling;
(3) Soil samp 11 ft 9; and
(4) Run-off sampling,
A. S u r face Mat IT Sajftpl 1 n fl
It Is Important to select sampling locations ftfr surface
waters prior to actual sample collection since iQCttfan will
often affect the choice of sampling equipment. St'ltetlon of
sampling location depends on surface water body typt (*,g*, pond
or stream), flow rate, depth, and width. In prtetlci, saffty and
physical access limitations will often affect sample locatierts.
Surface water samples can be collected direetly $y
ing the sample bottle. However, it Is preferable to »te t
collection container (e«,g.t beaker), properly cleaned fnd of
appropriate material, to a¥0id contaminating the otiitfde of the
bottle used to transport the sample back to the laboratory,
It is often necessary to collect samples away froit the
shore. If a plume 1s visible, samples should be taken wfthfn the
plume. A telescoping aluminum pole with an adjustable b'tfatfc-er
damp attached to the end 1s the easiest device to use to reach
sampling locations several feet off-shore. The collection vessel
or the sample bottle is held by the clamp. Samples can be trans-
ferred to appropriate bottles for shipment back to the laboratory
Surface water samples should be preserved and cooled to 4®C prior
to shipment to the laboratory. The laboratory may provide the
preservatives within the bottles. These cannot be used for
direct sampling.
6-13
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8. S^tttffjt ajjMt SfecHfflent Sgntftl t ng
Sediment or sludge can usually be sampled by using a
stainless Sttf| scoop or trier, Where sediment has a shallow
liquid layer above ft, It may be scooped by a pond sampler or
preferably with i thin-tube sampler, This device 1s preferred
because ft causes less sample disturbance and will also collect
an aliquot of the overlying liquid, thus preventing drying or
excessive stwple oxidation before analysis.
If the sltfdge layer is shallow, less than 30 centimeters,
corer penetration may damage the container Hner or bottom. In
this cast, i £onar or EcMman portable dredge can be used since
these samplers can generally only penetrate a few centimeters,
Of the two samplers, Ponar grab samplers can be applied to a
wider range of sediments and sludges. They penetrate deeper and
seal better than the spring-activated Eekmtn dredges, especially
In granular substrates.
When sampling, the investigator should consider a nuinber of
additional factors. For instance, because streams, lakes, and
impoundments generally demonstrate significant variation In
sediment composition resulting from distance front inflows, dis-
charges, or othtr disturbances, the Investigator should document
exact sampling locations by means of trlangul ation with stable
references on the banks of the stream or lake. In addition, the
investigator wty have to modify or not use some devices described
above If rocks, debris and organic material 1ri the sediment
complicate sampling.
EPA's publication, Characterization of
Waste SI tL||-A- Methods Harjajil: Volume II. fva I f ifrl t "Stiffly >.1 .ftft
Ifetfads , f icIncT ...... fitffon , pa g'es ..... t-f ....... f oT- if 7" d^eSe rf be .......... these
saSpTf ng t §c!lrtTqiuecsT I n great e r detail.
C. Son Sampling
If run-off or leachate samples cannot be obtained directly
(e.g., lack of precipitation), soil samples can be tilen within
gullies or other run-off channels to identify corrtamlnatien,
Results showing contaminated soil 1n a run-off pathway will Indi-
cate the potential for a surface water release. Constituents
found i rv drainage pathways may confirm the presence of contaminated
run-off. The identification of a release to soils tnd the appro-
priate sampling protocol is coveted 1n Chapter Seven, Soils.
0. .Ru.n_^oT;f ..... Samp.) i nj
Sampling of run-off and leachate seepage involves several
technical difficulties and will be less common in the RFA, The
major criteria used tu determine Now and where to sample Include:
obtaining a r-epresentat i ve sample, safety of the personnel con-
ducting the sampling, and the timing of sample collection with
the high precipitation necessary to create run-off or infiltration
6-14
-------
and seepage, Licit of precipitation during the sampling program Is
the major obstacle to obtaining run-off samples.
Out to tht differences In run-off patterns between facilities,
no one sampling method is considered reliable for obtaining a
representative sample it every location. The Investigator will
need to use professional judgment when designing site-spe«ci f 1 c
sampling plans. When sampling sheet run-.off or small leachate
streams, a *e1r may be used to enable the liquid to spring free
of the surface to provide a sufficient volume for the parameter
analysis.. These, samples should be collected as grabs and all
parameters should be taken within a short period of time (I.e.,
less than 15 minutes ) ,
The best method for manually collecting samples 1s to use
the actual sample container that will be used to transport the
sample to the laboratory. 'This .veil V prevent the contamination of
samples by the use of a collection device. The collection
container should be properly cleaned.
Samples for oil and grease analysis sfrouTd be collected dir-
ectly from the run-off,, The Investigator should avoid, using
collection vessels wWn transferring oil and grease samples since
oil residue will adhere to the vessel and may fret be transferred
with the sample to. the container.
Care should be taken to avoid collecting leaves and debris- in
the vessel, the sample can then be transferred to the appropriate
container. Some laboratories will add the preservatives directly
to the sample containers a«d other laboratories will htvt the
sampling team preserve the samples. The investigator should
use appropriate methods to preserve run-off samples* Leachate
samples, which are fenerally considered to be hAzffpddtts samples
rather than environmental samples, should not bt preserved. SM
84 6, Test Met herds, for ..g.vaTuat..1n.o Solid JJasts - fi||jlAatl Ctoiical
': ..........
of Water and Bastes 1s a good
"" "
p re s' e r vTtTdff t e c FTnTq - « e i for run""ofT "Tamp 1 e. s .
In evaluatlng results. It is very Important to determine If
representative samples were obtained and appropriate- sampling
methods were used to collect parameters. QA/QC protocol for
sampHftg is described in Chapter Four.
IV, MAKING SURFACE WATER RELEASE DETERMINATIONS
This section summarizes information that the Investigator
should consider rfhert making release .determinations in the surface
water pathway, • , •
6-15
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and seepage. Lack of precipitation during the sampling program 1s
the major obstacle to obtaining run-off samples.
Due to the differences 1n run-off patterns between facilities,
no one sampling method 1s considered reliable for obtaining a
representative sample at every location, The Investigator will
need to use professional judgment when designing s1 te-spe^l f 1 c
sampling plans. When sampling sheet run-off or small leachate
streams, a weir may be used to enable the liquid to spring free
of the surface to provide a sufficient volume for the parameter
analysis. These samples should be collected as grabs and all
parameters should be taken within a short period of time (I.e.,
less than IS minutes).
The best method for manually collecting samples 1s to use
the actual sample container that will be used to transport the
sample to the laboratory. This will prevent the contamination of
samples by the use of a collection device. The collection
container should be properly cleaned.
Samples for oil and grease analysis should be collected dir-
ectly from the run-off. The Investigator should avoid using
collection vessels when transferring oil and grease samples since
oil residue will adhere to the vessel and may not be transferred
with the sample to the container.
Care should be taken to avoid collecting leaves and debris 1n
the vessel. The sample can then be transferred to the appropriate
container. Some laboratories will add the preservatives directly
to the sample containers and other laboratories wilt have the
sampling team preserve the samples. The InvestigatoY should
use appropriate methods to preserve run-off samples. Leachate
samples, which are generally considered to be hazardous samples
rather than environmental samples,, should not be preserved. SW
846, Test Met hcid s f Q r Eva 1 u a 1 1mng 5 o 1 1 d Haste - P hy s 1 c a 1 Chemi c a 1
Methods' IT "tHe" 'FeT £'"r°^^'p^^^'^^r"j^"g'arj'ou''s' sampiesT^etWffs' ..... for
cjLl Ana .ly_s , 1 s of Water ,_an_d Wastes 1s a good reference for
pr ese r*Vat Ton t echniques f o r run -of f samp 1 es .
In evaluating results, It 1s very. 1 mportant to determine if
representative samples were obtained and appropriate sampling
methods were used to collect parameters. QA/QC protocol for
sampling is described 1n Chapter Four.
IV. MAKING SURFACE WATER RELEASE DETERMINATIONS
This section summarizes Information that the Investigator
should consider when making release determinations 1n the surface
water pathway.
6-15
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Chapter Four presents the general procedure to be followed
when making release determinations 1n tht RFA, This Involves:
o Evaluating sampling results from the S¥;
o Integrating facility Information gathered 1n the PR,
VSI, and the SV;
o Determining the likelihood of release at the facility; and
o Miking recommendations concerning the need for further
1nvestlgatlons.
The Investigator should rely upon Information available ind
his/her best proVasslonal judgment when making release determina-
tions In the surface water pathway. As stited 1n Chapter Four,
it will often be necessary to make deductions on the likely
origins of surface water contamination 1n the RFA when there 1s
evidence of such contamination. In order to do this, the Inves-
tigator should be able to demonstrate that: 1) the constituents
identified 1n the surface water or sediments were present 1n the
specific unit or group of units; and 2) the pollutant migration
pathways at the site support a determination thit a constituent
leaking from a specific unit or group of units would be likely to
migrate to the surface water of concern. The Investigator should
rely upon best professional judgment In making this determlnation.
Further Investigations to establish the presence of, and
character of» surface water (and/or sediment) contamination
problems, and the sources of such contamination, should be required
of the owner/operator when Information or evidence Indicates that
there 1s or is likely to be releases from the facility to tht
surface water body which poses an actual or potential threat to
human health or the environment.
Exhibit 6-2 is a checklist that should help the Investigator
evaluate specific factors to Identify surface water releases
and determine the relative effect on human health and the en-
vironment. In identifying releases, the Investigator should
consider the types of information presented 1n Exhibit l-l
which are highlighted in this checklist.
6-16
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EXHIBIT 6-2
Ctiicklist for Surface Water Releases
o Unit Design and Physical Condition
Are engineered features (e.g., run-off control systems)
designed to prevent releases from the unit)?
Does tie .operational history of the unit Indicate that a
release his taken place (e.g., old, closed or Inactive unit,
not Inspected regularly. Improperly maintained)? ,
Does the physical condition of the unit Indicate tttat re-
leases may have occurred ( e.g., cracks or stress fractures
1n tanks or erosion of earthen dikes of surface Impound-
ments)?
o Release Migration Potential
Does the slope of the facility and Intervening terrain
Indicate potential fgr release? <
- Could surface run-off from the unit reach tht nearest
downgradltnt surface water body?
/
Is the Intervening terrain character! zed 'by soils ind
vegetation that allow overland migration ( t.g., clayey
soils, and sparse vegetation)?
Does data on one-year 24-hour rainfall Indicate the poten-
tial for area storms to cause surface water or surface
drainage contamination as a result of run-off?
6-17
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EXHIBIT 6-2 (cont.)
Checklist for Surface Water Releases
o Waste Characteristics
Is the volume of discharge high relative to the size and
flow rate-of the surface water body?
Do constituents In the discharge tend to sorb to sediments
(e.g., metals)?
Do constituents 1n the discharge tend to be transported
downstream? ,
\
Do waste constituents exhibit moderate or high characteristics
of persistence (e.g., PCBs, dloxlns, etc.)?
- Do waste constituents exhibit moderate or high characteristics
of toxlclty (e.g., metals* chlorinated pesticides, etc,)?
o Evidence of Release
Is there direct e.vidence (e.g., sampling data; observed
contaminated run-off)?
I
Is there Indirect evidence (e.g., discolored soil, dead
vegetation)?
6-18
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CHAPTER SEVEN
AIR
I. INTRODUCTION
*
A. P u r P ojte
This chapter provides technical Information to support the
Investigation of air releases during the RFA. While Chapters Two
Three, and Four provide general guidance on conducting an RFA,
this chapter focuses on sped fie. factors unique to the air medium
that should be considered by the Invastlgator.
In Investigating the potential for air releases during the
RFA, the Investigator should focus his/her attention on operating
units. Operating waste management units have the greatest poten-
tial for air releases because they actively expose wastes to the
air on a continuous basis. In invest Jgttl rig air releases, EPA
personnel should take safety precautions In order to reduce their
exposure to on-s1te emissions. Safety precautions are discussed
1n Chapter Four.
Wastewater treatment units, such as those In treatment
trains regulated by NPDES, can cause significant volatile air -
emissions. The Investigator should address potential §1r releases
from these units In the RFA.
*
This chapter 1s organized to reflect the separate phases of
the RFA process;
o Conducting a preliminary review of existing Information;
o Conducting a visual site Inspection;
o Collecting additional sampling Information In a SV; and
o Making release determinations. .
The first section describes the technical factors that should
be considered during the PR and VSI, The second section describes
the technical approach to obtaining additional sampling Information
1n the SV for air, and should be consulted along with Chapter
Four on conducting a SV. The final section discusses factors to
consider when making air release determinations at the end of the
RFA. This section also presents options for further Investigation
of air releases to be evaluated at the end of the RFA.
-------
U. CONDUCTING A PRELIMINARY REVIEW AND VISUAL
SITE 1HSPECTION OF AIR RELEASE POTENTIAL
This section presents technical Information related specifi-
cally to the air pathway to be considered when conducting the PR
and VSI, Accordingly, this section has been organized to reflect
the primary go/ls rf these phases zf the RFA described 1n Chapters
Two and Three:
o Identifying and describing potential threats to air at
RCRA facilities; and
o Making a preliminary assessment of the need for a SV or
other actions at these facilities.
*
This section presents technical Information specific to the
air pathway covering the five types of Information described 1n
Exhibit 1-1, and technical Information to help the Investigator
determine when additional sampling will be necessary 1n a SV to
Identify air releases. We will discuss these six types of Infor-
mation separately:
(1) Unit characteristics;
(2) Waste characteristics;
/
(3) Pollutant migration pathways;
(4) Evidence of release;
(5) Exposure potentlal; and
(6) Determining the need for additional sampling Information.
This Information 1s relevant to the evaluation of written documents
1n the PR and Information gathered 1n the VSI.
A, Unit Cha ra ct e r1s11 c s
The design and operating characteristics of a SWMU will
determine to a great extent their potential for releasing hazardous
constituents to air. While the Investigator should evaluate all
SWMUs for air releases. Including NPDES units, the Investigation
should focus on operating units. As previously mentioned, opera-
ting units have the greatest potential for air releases because
they actively expose wastes to the air on a continuous basis.
Wastes 1n closed, Inactive units will have a lower potential to
cause air releases. There may be some exposure to the air 1f a
cover has eroded or broken do*n, but air releases resulting from
these situations are likely to be negligible (I.e., undetectable).
When assessing the potential for releases, the key factors
to examine Include:
7-2
-------
0 Unl t Slif • The slit of a unit determines the mass of
pWeritlliY contaminants available for release. Volatil-
ization ratts are likely to be larger from open units
(e.g., surface Impoundments and open tanks) with large
surface areas.
o P y f p a s e ^o f t h e unit [t r ta t men t . s to rage , or d 11 s p o s a 1 ) .
i n gsmeraT » un It sin wh ich~™Ict 1 ve t reatment 1 s occu r r 1 ng
have tht greatest potential for air releases. In many
cases, treatment is designed to promote volatilization of
constituents. In other cases, this 1s not the main
purpose of the treatment method 1n use. However, the
resultant mixing and movement of wastes leads to high
volatilization rates.
o Qes 1 grt of L the unit. Units 1n which wastes ara In direct
c ; o n t a c t w f f n the atmosphere have a higher potential for
releases than closed or covered units.
o Cujrr en t ....... Qfieravtl o n a. 1 s tat us . The nature of air releases
1 " s""™s ¥c h ..... tnW~t h e m i j o r ft y o f the mass available for
release will be released shortly after tht waste 1s
placed 1n the unit. Thus, as mentioned, operating units
are of greater concern than closed units. This 1s par-
ticularly true for unit types and wastes for which vola-
tilization 1s Important, Units with potential pirtlculate
releases may continue to release contaminants well after
closure, especially 1f the unit has been poorly maintained,
o Unl It stfjcl f 1e factors* There art specific design and oper-
at 1 o n aT f a c tors a s s o c 1 a t e d with each unit type which are
useful In evaluating the potential for release* These
factors are summarized 1n Exhibit 7-1.
In addition to considering the Individual unit sizes, tht Investi-
gator should be aware of the total area used for solid waste
management at a facility. Alflough Individual units may have
undetectable releases, the total release from a facility can be
significant. Exhibit 7-1 lists specific considerations for par-
ticularly Important unit types.
In assessing a unit's potential for air release, the Inves-
tigator should be aware of the Importance of Interactions between
the various unit characteristics listed above and the character-
istics of the wastes placed 1n the unit. It 1s Important to
examine how these two factors combine to result In an air release.
For example, a facility may have several large operating surface
Impoundments, suggesting a potential for large air releases.
However, 1f the facility 1s a steel manufacturer treating only
spent pickle liquor 1n these ponds, 1t H unllkel.y any air
release will occur because the hazardous constituents 1n the
waste are non-volatile, soluble metals.
7-3
-------
EXHIBIT 7-1
UNIT POTENTIAL FOR AIR RELEASES
AND MECHANISMS OF RELEASE
Unit Type
Characteristics and Mechanisms of Release
Operating Surfact
Impoundments
Wastes directly exposed to atmosphere
promotes vapor phase emissions
Large surface areas and shallow depths
promote Increased volatilization
Mechanical treatment methods (such as
aeration) Increase volatilization
Open Roofed Tanks
o Wastes directly exposed to atmosphere
(promotes vapor phase emissions)
o Mechanical treatment or frequent mixing
will Increase volatilization
Landfi11s
Volatilization of vapor phase constituents
through the sub-surfict and dafly/perwanent
cover
Poor or no dally cover Increases volatili-
zation
Open trench fill operations allow direct
exposure of waste to atmosphere
Volatile gases transported by convection
of biogenlc gases released via routine
landfill venting (particularly Important
In sanitary/hazardous mixed fills)
Partlculate releases generated by machinery
during filling operations
Partlculate releases due to wind erosion of
cover and/or exposed wastes
Land Treatment Units
Wastes normally 1n direct contact with
atmosphere
Application techniques which maximize waste
contact with atmosphere, such as surface
spreading or spray 1rr1gatlonpromote
Increased volatilization
Partlculate releases due to wind erosion
7-4
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EXHIBIT 7-1 (Continued)
UNIT POTENTIAL FOR AIR RELEASES
AND MECHANISMS OF RELEASE
Unit type
Wasf. Piles
Characteristics and Mechanisms of Release
Partlculate emissions from uncovered
waste piles
Location of waste pile 1n open area with
no erosion protection promotes pirtlculate
generatlon
Waste handling activities on and around
pile Increase emissions
Volatile emissions are likely to be rare,
but cm occur based on waste composition
Drum Storage Areas
Vaporization from drums frequently left
open to atmosphere or from poorly sealed
drums
Vapor emissions from areas containing
leaking drums
Covered Tanks
o Volatile releases from pressure venting,
poorly sealed access ports, or Improperly
operated and maintained valves and seals.
Inclnerators
o Stack emissions of parMculates
o Stack emissions of volatile constituents
High temperatures may cause volatilization
of low vapor pressure organlcs and metals
o Volatile releases via malfunctioning valves
during Incinerator charging
Non-RCRA Wastewater
Treatment Ponds and
Tanks
Low concentration wastes may volatilize
due to large surface area and active waste
treatment. Releases can be significant
due to generally large treatment
capad t1 es
Other Design and
Operating Practices
Inadequate spill collection systems promote
Intermittent air releases
Lack of vapor collection systems for use
during container/tank cleaning operations
Absence of dust suppression or partlculate
control measures
7-5
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EXHIBIT 7-2
PARAMETERS AND MEASURES FOR USE IN EVALUATING
POTENTIAL AIR RELEASES OF HAZARDOUS WASTE CONSTITUENTS
Eml ss1 cm .and
A, Vapor Phast Emissions
-- Dilute Aqueous Solution^/
Units or Concern1/
Surface Imp.,
Tanks. Containers
-- Cone. Aqueous Solut1on£/ Tanks, Containers,
Surface Imp,
— Immiscible Llqufd
— Solid
Centalners. Tanks
Landfills. Waste
Piles, Land Trt.
B. Partlculatt Emissions
« Solid
Landfills, Waste
P11es» Land Trt,
Useful Parameters
and Measures
Solubility,
Vapor Pressure,
Partial Pressure,^/
Henry's Law "~
Solubility,
Vapor Pressure,
Partial Pressure,
Raoults Law
Vapor Pressure,
Partial Pressure
Vapor Pressure,
Partial Pressure,
Octanol/Water
Partition Coeff.
Particle Size
Distribution,
Site Activities,
Management Methods
JJ7 Incinerators are not specifically listed on this 'table be-
cause of the unique Issues concerning air emissions from these
units. Incinerators can burn all the forms of waste "listed In this
table. Tht potential for release from these units 1s primarily a
function of Incinerator operating conditions and emission controls,
rather than waste characteristics.
£/ Although the octanol/water partition coefficient of a con-
stituent 1s usually not an Important characteristic 1n these waste
streams, there are conditions where It fan be critical. Spedf'c-
ally, 1n waste containing high concentrations of organic partlcu-
lates, constituents with high octanol/water partition coefficients
will, adsorb to the partlculates. They will become part of the sludge
or sediment matrix, rathtr than volatilising from the unit,
jj/ Applicable to mixtures of volatile components.
7-7
-------
EXHIBIT 7-3
HAZARDOUS CONSTITUENTS OF CONCERN AS VAPOR RELEASES
Hazardous Constituent
Acet aldehyde
Acrolein
Acrylonitrile
Allylchlorlde
Benzene
Benzyl chloride
Carbon Tetrachloride
Chi proberuene
Chloroform
Chloroprene
Creosols
Cumene (isopropylbenzene)
I,4~diehlor0benzene
1,2-dfchloroethane
Qichloromethane
01ox1n
Ep1chloroNydr1n
Ethyl benzene
Ethylene oxide
Formaldehyde
Hexachlorobutadiene
Hexachlorocyclopentadlene
Hydrogen cyanide
RCRA Waste Codes
K001.U001
K012
K011.K01Z,K013,U009
F024.F025
F024.F025,K001,K014fK019,K083,K085,K103IK105
K015,K085,P028
F001,F024,F025,KOl6,K016,K020,K021tK073iU2111
F001,F002,F024,F025,K015 »K016 »K085 »K105
Fp02,F024fF025,K009,K010.K016.K01d.K020fK073<.
K021,K029,U044
F024.F025
F004,U052
U055
F002»F024tF025,K016,K085,Kl05,U072
K018,K019,K020,K029,K030tK096tF024,F028,U077
F001JF002,F0241F025tK009,K010fK021tUd80;
F020(F021tF022'.F023lF028
K017»K019,K020,U041
F003
U1T5
K009,K010tK033,K040»U122
F024.F02S,K040PK016,K018.K030,U128
F024,F025tK032,K033,K034,U130
F007,F009tF010fK013fK060
7-8
-------
EXHIBIT 7-3 (cont.)
HAZARDOUS CONSTITUENTS OF CONCERN AS VAPOR RELEASES
Hazardous Constituent RCRA Waste Codes
Hydrogen flourlde
Hydrogen sulflde
Mal®1c anhydride K023,K093,U147
Hethyl acetate
N-D1methyln1trosam1ne U100
Naphthalene F024tF025,K001,K035,KQ60»KQ87,U165
Nitrobenzene F004,K025,K083,K103,U169
N1trosomorphol1ne
K001,K022»K087,U188
P095
^nthallc anhydride K016,K023,K024,K093,K094,U190
PolychloHnated bipheriyls K085
Aroclor 1242
Aroelor 1248
Aroelor 1254
1?50
F024,F025,K016,K019,K020,K021,K030,K095,K096»U209
Tttrachtoroethylene F001.F002,F024,F025,K016,K018,K109,K020,K021,U210
F005,F024,F025,K015,K036,K037,U220
Ul.Utrlchloroethane F001fF002,F024,F025.K019,K020,K028,K029»K073,K095,
K096,U226
F001,F002,F024,F025,K016,K018,K019»K020,U228
Vlnyichloride KO)9,K020,K023,K029,KO?8,F024.F025,U043
F003,F02!t,K019,K020,F024»K029,U078
7-9
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EXHIBIT 7-4
HAZARDOUS CONSTITUENTS OF CONCERN AS PARTICIPATE RELEAStS
Hazardous Constituent
Arsenic
RCRA Waste Codes
0QOQfD004,K060>KQ21tK084,P01Q,
P011.P012
Asbtstos
U013
Beryl 1lum
DOOO,0006,P015
Cadmlum
DOOO,0006,F006tFOOT,F008.F009,
F061.F062, F064tFO§8iF06?»F068lF06i
Chromium
0000»0007,F006tF007,F008sF009,F002»
F064.F069.F086,
Lead
0000,0008,F006tF009,K003,K044,K04Sf
KOi2,K061,K062,K064tK089 K086.PHO
Mercury
DOQ8.KOn.K106
Nickel
F006fF007,F008,F009
7-10
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higher the concentration of a particular constituent present
1n a wn1t» thi grtattr 1s Hs potential for air release. However,
the Intrinsic potential for a constituent to volatilize depends
on chemical and physical properties that vary greatly between
different constituents. Accordingly, a highly concentrated
solution of ont constituent may result In a lower release potential
than a dilute concentration of another constituent.
Constituent-specific physical and chemical parameters «re
very Important Indicators of the potential for a vapor-phase
release* The parameters most Important when assessing the v^a-
tlllzatfon of a constituent Include the following;
0 Wa t e^^olub 1 1 1 1^ . The solubility 1n water Indicates the
maxl mu¥ eoncentratl on at which a constituent can dissolve
1n water at a given temperature. This value can help
the Investigator estimate the distribution of a constituent
between the dissolved aqueous phase 1n the unit and the
undlssolved solid or Immiscible liquid phase. Considered
1n combination with the constituent's vapor pressure, 1t
can provide a relative assessment of the potential magni-
tude of volatilization of a constituent from an aqueous
environment.
0 Vapor prejjjire, Vapor pressure measures the pressure of
v a p o r i n^equTT 1 b r 1 u m with a pre liquid. It 1s best used
1n a relative senst; constituents with high vapor pres-
sures are more likely to have releases than those with
low vapor pressures, depending on other factors such as
ilattve solubility and concentrations (1»e. at high
concentrations releases can occur even though a
constituent's vapor pressure 1s relatively low).
o Octanyl/wattr parti tl on coefficient . The octanol /water
pa r 1 11 to n ....... "coW f 1 cf¥n f i n oTc alt e s t he tendency of an organic
constituent to sorb to organic constituents 1n the soil
or waste matrices of a unit. Vapors with high octanol/
wattr partition coefficients will adsorb readily to, organic
carbon, rather than volatilizing to the atmosphere, This
1s particularly Important 1n landfills and land treatment
units, whert high organic carbon contents In soils or
cover material can significantly reduce the release
potential vapor phase constituents.
o Partial pr e s sure . For constituents In a mixture, partlcu-
1 arty in a soTfd matrix, the partial pressure of a consti-
tuent will be more significant than the purt vipor pressure
In general, the greater the partial pressurt, thi greater
the potential for release. Partial pressures will be
difficult to obtain. However, when waste characterization
data is available partial pressures can be estimated
using methods commonly found 1n engineering and environ-
mental science handbooks.
7-11
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o Ha n ry' s law con St. a n t. Henry's lav constant 1s the ratio
"of ine vapor pressure of a constituent and Its aqueous
solubility (at equilibrium). It can be used to asstss
the relative ease with which the compound may be removed
from the aqueous phase via vaporization. It 1s accurate
only when used concerning low concentration wastes 1n
aqueous solution. Thus 1t will be most useful when the
Liilt being assessed 1s a surface Impoundment or tank con-
taining dilute wastewaters „ Generally, when the value of
Henry's Law constant 1s less than 1QE-7 atm-m^ the consti-
tuent will not volatilize from water. As the value In-
creases the potential for significant vaporization Increas-
es, and when 1t 1s greater than iOE-3 rapid vo1at111z«t1rn
will occur.
0 Raoultis Law- Raoult's Law can be used to predict re-
Teasts from concentrated aqueous solutions {I.e. solutions
over 101 solute). This will be most useful when the unit
of concern entails container storage, tank storage, or
ti jatment of concentrated waste streams.
For solid wastes, Imlsclble liquids, and wastes disposed of
in landfills, land treatment, or waste piles, thtfe are no simple
measures that can bt used to assess the potential for volatiliza-
tion of a constituent. The Investigator will need to consider the
appropriate chemical, physical, and unit parameters, and then use
his/her best Judgment In determining the potential for release.
2. Part 1 cu 1 ate Em1 s.s 1 ons
Exhibit 7-4 lists hazardous constituents thit art of special
concern for partl'-.ulate air releases. Partlculate emissions from
solid waste management units can contain organic material, heavy
metals, or both. The heavy metals shown 1n Exhibit 7-4 are pre-
dominantly associated with paniculate releases, although both
arsenic and mercury may be present as vapor phase releases due to
thtlr relatively high vapor pressures. Similarly, the organic
compounds shown in Exhibit 7-3 may also be found adsorbed or bound
to soil and/or other partlculate matter releases.
In general, there will be fewer facilities with ^articulate
emissions. However, at some facilities partlculate emissions may
be very significant (e.g., discharges from a lead smelter) and
threaten the safety of on-s1te workers and EPA personnel during a
sltt visit.
The likelihood of partlculate releases at hazardous waste
management facilities 1s generally associated with landfills,
land treatment units and/or waste piles. The potential for
partlculite releases 1s governed by different parameters than
those that afftct vapor-phase releases.
For partlculate releases, the size distribution of the
particles 1n the release plays an Important role 1n both
dispersion and actual exposure. Large particles will settle out
7-12
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of the §1r more ripldly thin swill particles, thus they will not
travel a$ ftr off-site or be diluted as much by dispersion. Very
small particles {1,t.» those that are less than 5 microns 1n
diameter), are considered to be resplrable and thus present a
greater health hatard than larger particles. The Investigator
should examine the source of the participate emissions to obtain
Information on particle size.
The primary mechanism for generating partlculate releases at
hazardous waste facilities is wind erosion. In general, the
unit's location will affect the potential for the wind to erode
wjistes 1n the unit* The unit's location and orientation with
respect to the prevailing winds and large structures on-s1te will
determine the unit's vulnerability to wind erosion and the poten-
tial for partlculate releases. Agency personnel should determine
the location of SWHUs of concern with respect to prev«%111ng winds
and the use of wind screens (both natural and mart-made) and dally
covers to determine the unit's vulnerability to wind erosion.
C. Pollutant Migration Pathway
The investigator should Identify the migration route(s) for
potential air releases tn-order to 1dent,1fy:
o The locations along the route where target populations
may be exposed to the release; and
o Locations to sample for evidence of release (e.g., south
or north edge of the unit), where no evidence of release
exists* but the Investigator believes, based on unit and
waste characteristics, that releases may occur.
In Identifying air pollutant migration pathways, the investi-
gator should determine the direction of the prevailing winds
around the facility, and characterize the geography (e.g., narrow
valleys and urban areas containing large buildings, or artificial
canyons) along the wind pathway. Using this information, he/she
should be able to Identify upwind and downwind sampling locations
and target populations that may be exposed to air releases along
their migration route.
The Investigator may be able to obtain some of this Information
from local weather data bases as part of the PR, Most of this
Information, however, will probably be collected during the VSI.
0. E v1 d ei fjic e o f R e 1 e a s e
The Investigator should examine any available sources,of
information to Identify evidence that constituents have been
released to the air at a facility 1n a proportion that poses an
actual or potential threat to human health and the environment.
General considerations on how to look for evidence of release are
discussed 1n Chapters Two and Three.
7-13
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Direct evidence of air releases will Include the following;
o A1r St«pl1ng/won1tor1ng dati associated with a particular
unit (i.g*9 samples taken from above a NPOES unit; moni-
toring data required under a Clean A1r Act permit);
o Visual evidence of partlculate releases from a unit;
Indirect evidence of release Includes the following;
o Evidence of contamlnation around the facility that may have
rtfylted from an air release (e.g., accumulated partlculate
emissions from a smoke stack or landfill/waste pile);
o On-s1tt air monitoring data gathered under the OSHA program;
o Records of citizen complaints associated with the facility
concerning odors, headaches, nausea, or observed partlculate
releases.
^
During the yin sal site Inspection, the Investigator should
identify any evidence that hazardous constituents have released
or art continuing to release from SMMUs at the facility to the
afr. During the visual site Inspection he/she should confirm the
presence of units of concern and look for evidence of partlculate
emissions from units. Although the Investigator may occasionally
smell vapor-phase releases, 1n most cases, these releases will be
difficult to Identify without samples. Procedures for collecting
additional sampling Information are discussed 1n Section HI.
E. Exposure Potential
The Investigator should evaluate available Information on
the location, number, and characteristics of potential receptors
that could be affected by air releases at the facility* Human
receptors ire of primary concern for air releases. Potential
receptor Information will be used primarily in helping the Inves-
tigator determine the need for Interim corrective measures at the
facility 1n order to address Instances of air contamination
posing especially high risks of exposure.
Population density and distance from the source are the pri-
mary factors 1n determining the significance of a potential
exposure. Distance should be measured from the un1t(s) containing
the waste rather than from the facility boundary, although total
facility emissions from all SWMUs should also be kept 1n mind.
Most Importantly, the Investigator should consider the density of
the population residing near the site, as well as transients such
as workers 1n factories, offices, restaurants, motels, or students.
The most significant exposure potential will occur 1n situa-
tions when there 1s a high population density very close to the
site. However, because concentrations can be quite high, even
low density populations 1n such close proximity to the site art
7-14
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of concern. Dispersion can significantly reduce concentrations
as distance from a site Increases. Thus, the significance of
high population density at larger distances from the site 1s
reduced.
The Investigator needs to consider the relationship between
distance, concentration, and population density 1n evaluating the
significance of an exposure potential. An additional factor to
consider Is the population located along the line of the most
predominant wind direction at a site. Because the RFA 1s pri-
marily concerned with continuous releases, populations located
along this line downwind of the site are more likely to receive
significant exposures than populations located along other vectors.
If the investigator determines that units at a facility are
releasing large volumes of unsaturated hydrocarbons* he/she may
need to consider population density over a much larger area*
These constituents contribute to the formation of photochemical
smog and ozone, which, in combination with other regional pollu-
tant releases, can cause significant exposures over a wide
geographic area.
F. Determining the Need for Additional Sampling Information
If the Investigator determines, based on his Inspection of
the unit, that there is a significant potential for the unit to
be releasing substantial quantities of volatile constituents and
fn consideration of the proximity of receptors, he/she may choose
to sample to determine conclusively whether an air release 1s
occurring which merits further Investigation^ We discuss 1n this
section:
(1) General Information on factors to consider in determining
the need for additional sampling information; and
•v,.^
(2) Factors to consider in selecting sampling parameters.
1. General Information on Determining the Need for Sampling
The Investigator should use his/her best professional judgment
1n determining when a unit may be releasing hazardous constituents
to the air. In some situations, a unit may exhibit a strong poten-
tial for air releases, based upon unit and waste characteristics,
but the Investigator wants to confirm this with additional data.
This may be necessary 1n situations where the owner/operator has
not cooperated with EPA, and he/she may contest an EPA request to
conduct further investigations by denying the presence of air
releases.
7-15
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2, Salec11 an of S a mp11ng Parameters
In selecting sampling parameters, the Investigator should
consider those constituents he/she believes to be of concern at
the facility. These constituents are discussed 1n detail earlier
1n this chapter. In general, the Investigator will be able to
confirm a release when one constituent has been shown to release,
and therefore, the number of parameters considered should be as
limited as possible.
In many cases, the Investigator will be able to confirm or
deny the presence of an air release by sampling for VOCs with an
indicator device. However, these devices can miss episodic re-
leases. These devices (e.g., OVA and HNU) measure the concentra-
tion of volatile organlcs 1n the air, and thus provide a screening
level technique for Identifying releases. These sampling methods
are discussed further 1n Section III.
III. OBTAINING ADDITIONAL SAMPLING INFORMATION
This section presents technical Information related specifically
to air releases to be considered when collecting additional
sampling Information 1n the SV. The Information presented here
should be used to help the Investigator meet one of the primary
•goals of the SV;
o To collect additional sampling Information to fill data
gaps Identified 1n the PR and VSI, leading towards final
release determinations.
For each sampling method discussed, this section describes:
1) the general kinds of situations 1n which 1t will be appropriate
to employ a specific technique* 2) technical Information on how
to conduct the sampling, and 3) specific details to be considered
when evaluating the sampling results. This section does not
provide the actual SOPs on sampling techniques here, although it
does reference the relevant manuals where possible.
The choice of appropriate sampling methods will have a large
Impact on the cost and usefulness of the SV. The Investigator
should be confident when developing and reviewing the sampling
plan that the procedures chosen will meet the needs of the RFA»
while not resulting In the collection of unnecessary data.
We describe several sampling techniques that will be appro-
priate for Identifying air releases during the RFA;
(!) Indicator techniques (OVA and HNU);
(2) Draeger tubes; and
(3) Monitoring stations wltTn Tenax tubes.
7-16
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1. Indicator 1frfetin1.gu.ti COVA and HNU)
j
The most common air sampling technique will Involve the use
of portable air monitoring Instruments which measure total organic
constituents present 1n the air at the sampling point. The two
most commonly used devices are the organic vapor analyzer (OVA),
and the HNU photolonizatlon detector. The OVA detects the pres-
ence of organic compounds 1n air with a flame 1onizat1on detector,
while the HNU detects organic compounds with a photolonizatlon
detector. While these units provide somewhat different results,
this discussion will be limited to the HNU; most of the discussion
will be applicable to use of the OVA,
The HNU provides the Investigator with a quick and simple
method for determining the presence of organic compounds 1n the
air, and for providing a general indication of their magnitude,
When evaluating the likelihood of releases at wasttwater treatment
tanks, the Investigator should hold the HNU as close as possible
to the unit and wait for the meter to equilibrate. The Instrument
provides a reading of organic vapor concentration 1n terms of
parts per mil 11on.
The Investigator should be aware that both of these Instruments
are calibrated to measure accurately only out volatile constituent;
the HNU is calibrated for benzene, while the OVA 1s calibrated
for methane. Thus, when encountering other organic constituents,
the meter may Indicate either higher or lower c§ne«ntrat1ons of
that constituent than are actually present. The 1hvift1|ator
should consider that these Instruments provide general Indications
on the presence of volatile organic*, not quantitative evidence.
However, an HNU Indication of organic vapors at a site may be
sufficient to compel further Investigations at that unit,
2. Draeger Tubes
When the Investigator seeks more detailed Information on the
presence of'Organic constituents 1n the air, Draeger tubes can be
useful for measuring specific constituents. This sampling tech-
nique shares the advantage of the HNU and OVA 1n that Draeger
tubes are a portable, field technique, which does not require
laboratory analysis*
Draeger tubes contain a sorbent material encased 1n a small
glass tube, through which an air sample 1s pulled with a hand-
held pump. The sorbent material has been chemically-treated
to turn a color when the specific constituent of concern 1s
present in the air. The length of the stained material Indicates
the concentration of the constituent 1n the a1r» the tube contains
a calibrated scale for reading concentration 1n parts per million
directly off of the tube.
7-17
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Draeger tubes have several advantages over the Indicator
techniques discussed above. Because they are constituent-specific,
they provide a better Indication of the toxlclty posed by an air
release. They also will provide a more accurate measurement of
the constituents of concern, since there 1s no problem based upon
the calibration to one constituent. However, Draeger tubes are
not available for all volatile constituents of concern. They are
also slightly wore difficult to use, 1n that the Investigator
should carry around Draeger tubes for each of the potential
constituents or vapor classes of concern at tht site. Still,
they should be considered extremely portable.
3. Monitorin|Statlons with Tenax Tubes
In some situations, tht Investigator may find It necessary
to Instill a stationary monitoring station for waking more quan-
titative determinations of air releases at a site. This air
monitoring will involve the use of Tenax tubes to collect organic
constituents* and subsequent laboratory analysis of thes*
constituents with a 8C/HS, This sampling technique will seldom
be ntctssary during the RFA, primarily due to its technical
difficulty, and because the simpler techniques described here
will generally provide sufficiently useful results.
The Investigator should consult with qualified professionals
familiar with the use of air monitoring devices, when h«/sbf
believes that more quantitative evidence of a release will be
necessary in the RFA,
IV. MAKINS RELEASE DETERMINATIONS
The final task in the RFA process is to make determinations
of release potential throughout the facility and to make recommen-
dations for further action to address these potential releases.
This section summarizes information that the Investigator should
consider when making release determinations In the air pathway.
Chapter Four presents the general procedure to be followed
when making release determinations during the RFA. This involves;
o Evaluating sampling results from the SV;
o Integrating facility Information gathered 1n the PR and
the VSl;
o Determining the likelihood of release at the facility; and
o Making recommendations concerning the need for further
1nvestlgatlons.
7-18
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The Investigator should rely upon his/her best professional
Judgment when making release determinations 1n the air pathway.
In order to make a release determination, the Investigator will
probably have to demonstrate that a unit of concern contains
constituents that have i potential for vapor-phase or participate
release. In most cases, this Information on constituent release
potential along with some Indirect evidence of release (e.g.,
odors, observed partlculate releases, facility-wide sampling
data) will prov* sufficient to make an adequate release determin-
ation. However, in certain cases, It will be necessary to obtain
existing or new direct evidence of release that links constituents
identified through sampling with constituents In the unit.
Exhibit 7-5 1s a checklist that should help the investigator
evaluate specific factors to identify air releases. In identifying
releases, the investigator should consider types of Information
presented In Exhibit 1-1, which are highlighted In the checklist.
7-19
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EXHIBIT 7-S
CHECKLIST FOR AIR RELEASES
o Unit Characteristics
Is tht unit operating and does 1t expo.s wastes to the
atmosphere?
Does the surface area of tht unit create create a potential
for air release?
o Does the unit contain waste that exhibits a potential for
vapor phase release?
Does the unit contain hazardous constituents of concern as
vapor releases?
o Does the unit contain waste and exhibit site conditions that
suggest a potential for partlculate release?
Does the unit contain hazardous constituents of concern as
partlculate releases?
Do constituents of concern as partlculate releases (e.g.,
smaller, Inhalable partlculates) have potential for release
via wind erosion, rttntralnmtnt by moving vehicles, or
operational activities?
o Evidence of A1r Release
Is there direct evidence of release from the unit (t.g.,
air sampling data; observed partlculate releases)?
Is there Indirect evidence of release from the unit (e.g.,
evidence of contamination around the facility that may have
resulted from an air release; OSHA monitoring data; citizen
compliant* regarding health problems, odors, or observed
partlculate releases)?
7-20
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CHAPTER EIGHT
SUBSURFACE GAS
I. INTRODUCTION
A. Purpose
This chapter provides technical Information to support the
investigation of releases of subsurface ges during the RFA,
While Chapters Two, Three, and Four provide general guidance on
conducting RFAs, this chapter focuses on specific factors unique
to subsurface gas releases that should be conslderd by the 1nves
tigator.
B.
In the RFJt Investigators should determine whether releases
of subsurface gas have occurred at a facility. In general, EPA's
primary concern Is to determine whether there are gas releases
that could reach explosive levels 1n on-slte or off*s1te buildings.
Therefore, the primary constituent of concern 1n the subsurface
gas investigation 1s methane, due to Its explosive properties and
frequency of detection In subsurface gis.
As with other media, the Investigations that m*y be required
1n an RFI to determine the nature and extent of subsurface pas
releases will be very resource Intensive for both the owner/operator
and for the Agency. Therefore, the Investigator should also
identify 1n the RFA those units/facilities that do not require
further Investigation for subsurface gas releases,
This chapter has been organized to reflect the separate
phases of the RFA process:
o Making a preliminary assessment of subsurface gas
releases 1n the PR;
o Obtaining evidence 1n a VSI;
o Collecting additional sampling information 1n a SV; and
o Making release determinations.
The first section describes the technical factors that should
be considered during the PR and VSI. The second section describes
the technical approach to obtaining additional sampling Information
in the SV for subsurface gts releases, and should bt consulted
along with Chapter Four on general guidance to be followed In
conducting a SV. The final section discusses factors to consider
when making release determinations of subsurface gas releases.
This section also presents options for further investigation of
subsurface gas releases to be evaluated at the end of the RFA.
-------
II. CONDUCTING A PRELIMINARY REVIEW AND VISUAL SITE
INSPECTION OF SUBSURFACE GAS RELEASE POTENTIAL
This section presents technical information related specif-
ically to subsurface gas releases to be considered when conduct-
Ing the PR and VSI. Accordingly, this section has been organized
to reflect the primary goals of these steps In the RFA:
o Identifying and describing potential threats from
subsurface gas at RCRA facilities; and
o Making a preliminary assessment of the need for and
extent of sampling required.
This section presents technical information specific to this
pathway covering the five types of information described in
Exhibit 1-1, ,-nd technical information to help the investigator
determine when additional sampling will be necessary 1n a SV .0
identify subsurface gas releases. The section discusses these
six types of information separately:
(1) Unit characteristics;
(2) Waste characteristics;
(3) Pollutant migration pathways;
(4) Evidence of release;
(5) Potential receptors; and
{6) Determining the need for additional sampling
Information.
This information will be relevant to the evaluation of
written documents In the PR and Information gathered In a VSI,
A. Unit Characteristics
The design and operating characteristics of a unit will
determine to a great extent Its potential for releasing methane.
The investigator should evaluate the unit characteristics of each
SWMU or group of SWMUs at a facility to determine their potential
for contributing to the generation and release of methane in
subsurface gases.
The general potential for subsurface gas releases from a
SWMU depends, to a great extent, upon the nature and function of
the unit. The investigator should assess each unit based upon:
o An understanding of the overall potential of the unit
to cause subsurface gas releases;
8-2
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An understanding of the primary mechanisms by which
rt1i$$ii may occur from the unit; and
An tsstisme-nt of unlt~spedf1c factors which, singularly
Of 1ft combination with tach other, Indicate the relative
liktHhood of subsurface gas releases from the unit*
Investigator should first consider the relative potential
of tht yfjlt to release* Exhibit 8-1 presents a generalized rank-
Ing, 1ft royjh descending order, of the different types of SWMUs and
thtlr ovtrtM pot»ntlal for causing subsurface gas releases, and
a listing $f tht most common mechanisms by which these releases
can oeeyf trow tach unit type.
It should be understood that Exhibit 8-1 provides only a
tri«o**ttleal sense-of the relative potential of these units to cause
release** Uftit»sp*c1f1c factors should be evaluated In determining
whtthtr furthtr Investigations are needed for a particular unit.
Only two typts of solid waste management units are of
canctrn in tht subsurface gas Investigation dut to their poten-
tial for generating mtthine or othtr subsurface gases of concern.
fhist units Include active and closed landfills and units that
nave betn closed as landfills. Each 1s described more fully
btlow;
Q ii-ft|f:1]1s* landfills are the most Hktly SWMUs to
fwtFaft**subsurface gasei rtsultlfig 1n i release. The
underground dtposltlon of decomposible refuse with or
without hazardous constituents provides a large source
of gas an4 a driving force that can carry other gtses
vtr>t1«fl to tht atmosphere and/or migrating horizontally
as a subsurface gas. Closing landfills with Impermeable
caps without venting systems retards the release of these
landfill gases as surface emissions. In these Instances,
a large percentage of those gases migrate laterally
through soils along confining barriers such as ground
water tablet, clay layers, synthetic liners, and compacted
covers. This migration coulid cause significant accumula-
tions of potentially explosive gas 1n facility structures
or in buildings off-site.
o Unl t s c.1.0 sad a i 1 a n d f 11 |s . Inactive SWMUs that have been
clostd as fandTllls may generate subsurface gases. These
sites Include closed surface impoundments or waste pl'.es
containing decomposable or volatile wastes with 1n-place
Impermeable covers. Similar to landfills* gases generated
1n sites closed as landfills may migrate literally, pos-
sibly causing significant accumulations. However, closed
surface impoundments and waste piles generally contain
small quantities of decomposable and volatile wastes and
are at shallow depths. Thus, significant gas migration
and subsequent subsurface gas releases are less likely
for these units than for landfills.
8*3
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EXHIBIT 8-1
UNIT POTENTIAL FOR SUBSURFACE GAS
RELEASES AND MECHANISMS OF RELEASE
Unit Type
Closed Landfills
o Lateral migration of methane beneath
landfill cap to on-site OP off-site
structures.
o Migration of methane through conduits
to on-s1te or off-site structures.
Active Landfills
o Lateral migration of methane beneath
landfill cap to on-site or off-site
structures
Closed Water Piles
o Lateral migration of methane beneath
landfill cap to on-s1te or off-site
structures.
Closed Surface
Impoundments
o Lateral migration of methane beneath
landfill cap to on-sitt or off-site
structures.
8-4
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Other SNMUs are unlikely to have subsurface gas releases
because gases generated 1n the units are more likely to vent to
the atmosphere than to concentrate 1n the unsaturated soil.
Barriers (e«g«t paving, compaction» or installation of covers for
closure), can permit some lateral migration to occur from these
units, Sentrally, however, this lateral migration w111 be Halted
to the extent of the barrier. Shallow SWMUs will also have a
lower potential for releasing methane, since availability of
oxygen will interfere with the anaerobic conditions supporting
methane generation.
Although depth 1s ono of several considerations for deter-
mining th« potential for releases, the type of SuMU establishes
potential migration pathways and the waste characteristics create
the driving force for subsurface gas movement. Exhibits 8-2 and
8-3 Illustrate some potential pathways from a few types of SWMUs.
The Investigator should consider the characteristics presented
here when evaluating the likelihood of a SWMU to release methane.
•3. Mais t eiu Characte r 1sties
The Investigator should attempt to Identify the wastes
originally contained within a SWMU or group of SWMUs during the
PR, 1n order to determine their potential for generating methane.
The investigation for methane is different than Investigations
for releases to the other media discussed in this guidance, 1n
that the constituent of concern 1n this chapter is generated 1n
the unit, rather than merely a waste present from a treatment,
storage, or disposal activity. Therefore, the investigator
should determine whether wastes conducive to the generation of
methane are present in SWMUs at the facility*
Anaerobic decomposition of organic wastes generates large
volumes of methane gas under the proper conditions* When methane
is generated in SWMUs, tht potential exists for it to accumulate
under pressure and to migrate from the unit, thereby posing a
significant risk of explosion. The methane may also be mixed
with other volatile hazardous constituents present in the unit,
and may Increase the potential hazard associated with the accumu-
lated gas.
Conventional solid waste refuse and biological sludges
are the primary waste type of concern for generating methane gas,
The volume of gas produced In the unit depends upon both the
quantity and types of refuse present. Units may either contain
primarily refuse or a mixture of refuse and hazardous wastes.
Units where refuse has been codlsposed with hazardous wastes may
pose the most serious threat, because of the potential for other
volatile hazardous wastes to be mixed with the methane*
Higher volumes of methane will be generated at units con-
taining larger quantities of refuse. The volume of gas generated
also depends upon the age of the unit and how long the waste has
been in the unit. Methane generation will Increase slowly after
waste emplacement to a maximum neneratlon rate which will slowly
decline as the waste decomposes! The active lifetime for methane
8-5
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generation from units closed as landfills depends primarily upon
the amount of precipitation Infiltrating Into the waste. Land-
fills 1n the arid Southwest will generally produce methane for
20-30 years, while landfills 1n the humid Southeast may only
generate methane for 4-5 years after waste emplacement. Landfills
with higher moisture content provide a more suitable environment
for bacterial degradation.
The temperature of waste at the time of emplacement can also
affect the methane generation rate. Wastes placed 1n landfills
1n the winter at temperatures below 10° C may not generate methane
for up to 5 years, even In climates with warm summers, due to the
Insulating properties of the waste* The waste can remain at tem-
peratures low enough to effectively Inhibit bacterial decomposition
for several years. The types of refuse disposed 1n the unit can
also affect the rate of methane generation. Descriptions of the
two types of refuse that can generate methane and a brief discus-
sion of other wastes that may mix with methane follow:
o Rapid Decomposable Refuse. Rapid decomposable wastes
will produce methane at high rates under the proper
conditions. These wastes Include organic sludges from
wastewater treatment facilities, food wates, garden
wastes, and other vegetable matter (e.g., grass clippings,
tree trimmings, etc.). The high concentration of readily
degradable organic compounds 1n these wastes provides in
ideal energy source for the anaerobic organisms that
produce methane.
o Slow Decomposable Refuse. Slow decomposable* will not
produ c e the1 mmed1 ate high volumes of methane possible
with the rapid decomposable*. However, they will produce
methane at lower rates In the unit over a longer period
of time, and thus also pose a substantial threat. Slow
decomposable^ Include paper, cardboard, wood, leather,
some textiles, and several other assorted organic ma-
terials. Slow decomposables are commonly a large percen-
tage of municipal refuse, and should be present In large
quantities 1f the SWMUs contain municipal refuse.
o Other Wastes of Concern. Volatile organic wastes disposed
in the unit of concern for subsurface gas releases way
volatilize into the pockets of methane gas produced by
refuse decomposition and Increase the haiard associated
with the gas. This situation could occur where liquids
such as solvents have been disposed of In landfills or
waste piles 1n high concentrations. These compounds are
not likely to migrate from the unit unless methane 1s
present to act as a carrier. However, certain volatile
compounds would be likely to form mixtures with methane
where wastes are codlsposed. The volatile wastes and
waste constituents of concern for subsurface gases are
the same as those that have the potential for air
releases. These are listed 1n Exhibit 7-2.
8-8
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C, Pollutant Migration Pathways
The investigator should evaluate any available information
pertaining to tht hydrogeologlc characteristics of a facility
1n order to determine the pollutant migration pathways associated
with subsurface gas releases during the PR. As stated previously,
methane can accumulate under pressure within certain types of
units, and then migrate from that unit through the subsurface due
to the force of this pressure.
Certain natural conditions and engineered structures can act
as barriers that Impede the migration or conduits that promote
the migration of subsurface gas. For example, venting systems
can prevent subsurface gas migration, while underground utility
lines can promote migration. We describe below several factors
that can affect the migration of subsurface gas;
(1) Natural barriers and conduits; and
(2) Engineered barriers and conduits*
1. N a t u r a 1B a r r 1 e r i aji d Conduits
Gas migration can be Impeded by various geologic barriers.
A soil's effective porosity and permeability are perhaps the most
Important natural barriers to gas migration. Porosity 1s a
function of soil type, moisture content, and weathering* Permea-
bility 1s determined by soil type. Tight, uniform solid such as
clays, at least to the depth of the unit, are good barriers.
Sandy soil will likely encourage venting of gas to the atmosphere,
thus preventing horizontal migration. Climatic conditions such
as precipitation or freezing can also affect gas migration* Both
factors tend to reduce the porosity of surface soils preventing
upward
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Z. Engineered Barriers and Conduits
Some facilities m«y have engineered structures which either
Intentionally or unintentionally Impede the migration of subsurface
gas. Engineered barriers Include;
o Synthetic liners that effectively contain wastes;
o Slurry walls that border landfill units; and
o Gas control or venting systems.
The Investigator should review documents on the design and opera-
tion of thtse systems and Inspect the systems to confirm that
they are functioning properly. Subsurface gas control systems
are almost exclusively associated with disposal sites for
municipal-type waste rather than for hazardous waste. These
systems are probably only present at hazardous waste facilities
where municipal waste 1s codlsposed with hazardous waste or where
a sanitary landfill 1s operating at the same sltt.
Gas migration from SWMUs may be facilitated by man-made
structures located within the facility or near the property
boundary. Examples of engineered structures which may act as
conduits Include:
o Underground power transmission lines;
o Sewer and drainage pipes; and
o Underground telephone cables.
Bases migrating from a SWMU may enter the gravel-backfilled
trenches surrounding these structures and travel great distances
to buildings or other engineered structures, resulting 1n a
potential hazard. It may be useful to Inspect the facility blue-
prints and check with utilities to the extent that these tasks
were not completed during the PR or VSI 1n order to ensure that
no structures are present that could Increase the likelihood of
gas migration to on- and off-site receptors.
D, Evidence of Release
The Investigator should examine any available sources of
Information to Identify evidence that subsurface gas has migrated
from a facility. Most evidence of subsurface gas releases will
usually be limited to official reports of explosions at or near
the facility. In some cases, there may be sampling Information
taken from vents placed near the units Indicating the presence of
methane 1n a unit. Under most circumstances, the Investigator
should assume that units containing methane will pose a threat
for migration and potential explosion.
E. E xposure P o t e n 11 aj
The Investigator should evaluate available Information on
the location, number, and characteristics, of buildings that
could be affected by subsurface gas releases at the facility* As
stated at the beginning of this chapter, the RFA will focus
8-10
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primarily on the potential for methane to migrate to on-slte and
off-site buildings. Typically, methane can migrate up to 1000
feet from Its source, although 1t could travel further under Ideal
conditions.
Potential receptor Information will be used primarily to
help the Investigator determine the netd for Immediate corrective
measures at the facility 1n order to alleviate potentially high
risks of explosion attributable to methane migration. In general,
Immediate actions may be necessary when the Investigator encounters
buildings with exploslmeter readings above 2§£ of the LEL (lower
explosive limit). The Investigator should Identify those structures
that may be located close enough to a source of methane to warrant
further Investigation, and 1n some cases, sampling.
F. Determining the Need for Additional Sampling 1n the SV
If the Investigator determines, based on his Inspection of
the unit, that there 1s a significant potential for the unit to
generate methane, and that the site geologic and bydrogeolog(c
conditions may promote migration,'he/she may choose to sample to
determine conclusively whether methane has been released. We
discuss 1n this section:
(1) General Information on factors to consider 1n determining
the need for additional sampling Information;
(2) Factors to consider 1n selecting sampling parameters; and
(3) An example to Illustrate this discussion*
1. General Information en Determining theNetd for Strnpiloj
The following 11st presents several situations In which the
Investigator may find it useful to obtain additional sampling
Information during a SV:
o To Identify explosive levels of methane 1n structures; to
Identify the need for emergency action;
o To confirm adequate operation of a landfill gas venting
system;
o To Identify the presence of refuse 1n units with unknown
waste composition; and
o To confirm the presence of toxic constituents mixed with
subsurface gas.
The Investigator should use best professional judgment 1n
determining when a SWMU may be a source of subsurface gases.
When he/she believes that a unit contained decomposable wastes,
and believes that the site conditions could facilitate methane
8-11
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migration, 1t may be appropriate to sample for methane at appro-
priate locations* These are described in detail 1n Section
ill of this chapter.
2, Selection of Sampling Parameters
As stated previously, methane will be the primary constituent
of concern for Investigations of subsurface gas releases. There-
fore, the Investigator will usually sample for methane when
Identifying releases.
However, under certain unusual situations (e.g., units where
large quantities of refuse were codlsposed with hazardous wastes),
1t may bt necessary to Identify the presence of other potentially
hazardous constituents in subsurface gas* In these cases, the
potential constituents of concern will the same as those Identi-
fied as potential constituents of concern for air releases* The
Investigator should refer to Chapter Seven §f this document for
guidance on Identifying and sampling these constituents of concern.
3. Example
An Illustration of a situation 1n which sampling would be
called for follows: An eltctroplatlng facility previously dis-
posed some of Its electroplating sludges along with refuse gen-
erated at the facility 1n a medium-sized landfill (2 acres). The
company closed the landfill five years before the RCRA Investi-
gator began conducting the RFA. They closed the landfill by
installing a clay cap with a vegetative cover.
The Investigator found records of the past use of the land-
fill during the PR, and recognized a potential methane generation
problem. After requesting a facility diagram from the owner/oper-
ator, the Investigator discovered a telephone line running from
off the facility boundary, underneath and adjacent to tht landfill,
towards one of the facility structures. The Investigator recog-
nized the underground telephone line to be a potential conduit
for any methane migrating from the closed landfill.
Because the telephone line entered a facility structure, the
Investigator would decide to take explosltneter readings within
the structure of concern. However, because the absence of methane
In the facility structure does not necessarily prove the absence
of methane, the Investigator also decides to take several soil
gas measurements around the perimeter of the landfill, 1n order
to Identify the presence of methane at the unit boundary.
III. COLLECTING ADDITIONAL INFORMATION IN THE SV
This section presents technical Information related specific-
ally to subsurface gas releases to be considered when collecting
additional sampling Information 1n the SV. The Information
presented here should be used to help the Investigator meet one
of the primary goals of the SV;
8-12
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o To collect additional sampling Information to fill data
gaps Identified 1n the PA, leading towards final release
determinations.
For each sampling method discussed, this section describes:
1} the general kinds of situations 1n which 1t will be appropriate
to employ a specific technique, 2) technical Information on how
to conduct the sampling, and 3) specific details to be considered
when evaluating the sampling results. This section does not
provide the actual SOPs on the sampling techniques here. However,
1t references the relevant manuals.
The choice of appropriate sampling methods will have a large
Impact on the cost and usefulness of the SV. The Investigator
should be confident when developing and reviewing the sampling
plan that the procedures chosen will meet the needs of the RFA,
while not resulting 1n the collection of unnecessary data.
One example of a sampling technique that will be appropriate
for Identifying subsurface gas releases during the RFA 1s the
combustible gas meter (explosimeter) measurement. Considerations
on how to use this device and on evaluating Its results follow
below.
I. Combust1b1e fias Met er
Methane field monitoring can be performed with combustible gas
meters 1n buildings, sewers, or 1n the soil. A combustible gas
meter will provide a reliable determination of combustible gas
concentrations. It will not Indicate whether or not the combust-
ible gas detected 1s actually methane: gas, although. If the waste
in the unit could generate methane, It 1s likely that the meter
1s detecting methane. Any significant gas reading {whether 1t 1s
methane or not) Is of concern.
Combustible gas meters usually Indicate the percentage of
the lower explosive limit (LEL) of the atmosphere being monitored.
The LEL Indicates the lowest concentration of methane In air
which could result 1n combustion, or 1n sever® cases, an explosion.
EPA guidelines under CERCLA consider 25% of the LEL to be an
action threshold; the Investigator should evacuate Immediately
when readings higher than 257. of the LEL are obtained.
Reported experience Indicates 0 to 100 percent of tht lower
explosive limit detection to be accurate with hotwire catalytic
combustion principal Instruments. However, many users prefer
Instruments with the capability of determining both the 0 to 100
percent LEL and the percent methane present when the concentra-
tion exceeds 100 percent LEL (I.e., 5 percent methane). Dual
scale Instruments are available for this application. Typically,
the 0 to 100 percent gas scale uses a thermal conductivity sensor.
The carbon dioxide 1n landfill-generated gas 1s reported to
Interfere with the thermal conductivity sensor, so the Investigator
should not assume that readings above 100 percent LEL are accurate.
8-13
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Some of the single scale 0 to 100 percent LEL Instruments can
also be fitted with air dilution tubes or valves to allow readings
of the percent gas when the concentration 1s above the lilt
Irstructlons on the use and calibration of these Instruments
should be obtained from the manufacturer.
Monitoring 1n a facility structure (e.g., buildings, sewers,
existing monitoring wells, gas vents) should normally be done
after the building has been closed overnight or for a weekend.
and when the soil surface has been wet or frozen for seven!
days. Monitoring or sampling should be done 1n confined areas
where gas may accumulate, such as basements, crawl spaces, near
floor cracks, attics, around subsurface utility connections, and
in untrapped drain lines.
Soil gas monitoring can be performed to Identify the potential
for methane releases at a unit. The Investigator will normally
drill shallow wells of a minimal diameter (2") and Insert the
monitoring device 1n the hole. There will be some time delay
due to the slow movement of gas through the soils and Into the
wel 1 .
IV. MAKINS SUBSURFACE GAS RELEASE DETERMINATIONS
The final task In the RFA 1s to make release determinations
and recommendations concerning the need for further Investigation
(e.g., an RFI). While subsurface gas problems may not occur at
a large number of facilities, where they are encountered, they
may pose extremely hlfh risks to the Investigator tnd facility
employees.
Exhibit 8-4 1s a checklist that should help the Investigator
evaluate specific factors to Identify subsurface gas releases, or
to Identify sites that have a high potential for gas release and
gas migration to on-slte or off-site buildings* In Identifying
releases, the Investigator should consider the series of factors
described 1n the chapter and highlighted 1n the checklist to
determine the potential for release. Tht primary factors Include:
whether or not the unit contains waste that generates methane, and
the po'jntlal for migration through the subsurface.
8-14
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Exhibit 8-4
Checklist for Subsurface Gas Releases
1. Potential for Subsurface Gas Releases
o Does the unit contain «raste that generates methane or
generates volatile constituents that may be carried by
methane (e»g.» decomposable refuse/volatile organic wastes)?
o Is the unit an active or closed landfill or a unit closed
as a landfill (e.g., surface Impoundments and waste piles}?
2, Migration of Subsurface Gas to On-s1te or Off-site Buildings
o Are on-s1te or off-site buildings cloie to the unit?
o Do natural or engineered barriers prevent gas migration
from the unit to on-s1t:< or off-site buildings (t.§«, low
soil permeability and porosity hydrogeologle barrtars/lIners,
slurry walls, gas control systems)?
o Do natural site characteristics or man-made structures
|e.g.» underground power transmission lines, sewer pipes/
sand and gravel lenses) facilitate gas migration from the
unit to buildings?
3, Evidence of Release
o Does sampling data Indicate a release of concern?
8-15
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CHAPTER NINE
SOILS
I. INTRODUCTION
This chapter provides technical Information to support the
Investigation of releases to soils during the RFA. While
Chapters Two, Three, and Four provide general guidance on conduc-
ting RFAs, this chapter focuses on specific factors unique to the
soil medium that should be considered by tht Investigator.
This chapter has been organized to reflect the separate
phases of the RFA process:
o Conducting a preliminary review of Information on soil
releases;
o Conducting a visual inspection of tht facility;
o Collecting additional sampling Information in the SV; and
o Making release determinations.
The first section describes the technical factors that
should be considered during the PR and VSI. The second section
describes the technical approach to obtaining additional stapling
information In the SV for soils, and should be consulted along
with Chapter Four on conducting a SV. The final section discusses
factors to consider when making final release determinations to
soils at the end of tht RFA.
It should bi understood that,J^,1s not the objective of an
RFA to identify all areas of contaminated sjil at a facility, and
to require further Investigaitan for all contaminated soil areas.
Investigators should focus on Identifying soil contamination
which, through direct contact uf humans or other potential
receptprs, or by leaching or otherwise migrating to otht»* media
such as ground water or surface water, poses a threat to human
health and the environment. Not all soil contamination poses
such rfsks; Investigators should only focus on areas of soil
contamination which clearly have the potential for causing serious
environmental problems,
B. SiCjope
During the RFA, the Investigator should evaluate the likeli-
hood that the facility has releases to soils which pose a threat
to human health and the environment. While in most cases this
will relate to contamination from specific units, there may be
situations where other sources of soil contamination may be
Impacting human health and the environment.
-------
II. CONOUCTINS A PRELIMINARY REVIEW AND VISUAL
SITE INSPECTION OF RELEASES TO SOILS
This section presents technical Information related specifi-
cally to the soil medium to be considered when conducting the PR
and VSI. Accordingly, this section has been organized to reflect
the primary goals of these processes described In Chapters Two
and Three;
o Identifying and describing potential releases to soils at
RCRA facilities; and
o Making a preliminary assessment of the need for and ex-
tent of sampling required.
This section presents technical details on each of the five
types of Information described In Exhibit 1-1:
(1) Unit characteristics;
(2) Waste characteristics;
(3) Pollutant migration pathways;
\
(4) Evidence of release; and
(5) Exposure potential.
In 80d1t1on» technical Information 1s provided to help the Inves-
tigator determine when additional sampling will be necessary 1n a
SV to Identify soil releases. Each area 1s discussed separately.
A. Unit Ch aracter1st 1 cs
A unit's design and operating characteristics of a SMWU will
determine to a great extent Its potential for releasing hazardous
constituents to soils. Many treatment, storage, and disposal
units are designed to prevent releases to the envlronment. The
Investigator should evaluate the characteristics of each SWWU or
group of SWMUs at a facility to determine their potential for
releasing hazardous constltyents to soils.
As with other media, tht likelihood that a SWMU hjs contam-
inated soils 1s largely dependent on the nature and function of
the unit. Therefore, each SWMU or grouping of similar units
should be evaluated for Its potential to release constituents
that may contaminate surrounding soils. The unit evaluation
should be based upon:
o An understanding of the Inherent design characteristics
and features that might cause the unit to have a release
to surrounding soils;
9-2
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EXHIBIT 9-1
RANKING OF UNIT POTENTIAL FOR SOIL RELEASE
AND MECHANISMS OF RELEASE
Unit Type
Surface Impoundment
Landfill
Waste Pile
Land Treatment Unit
Container Storage
Area
Abo¥e-ground Tank
In-ground Tank
Incinerator
Class I and IV
Injection Well
Release Mechanism
o Releases from overtopping
o Seepage
o Migration of run-off outside the unit's
run-off collection and containment system
o Migration of spills and other releases
outside the containment area from
loading and unloading operations
o Seepage through dikes to surrounding
soils
o Migration of run-off outsldt the unit's
run-off collection and containment system
o Migration of spills and other releases
outside the containment area from
loading and unloading operations
o Migration of run-off outside the
containment area
o Migration of run-off outside the
containment area
o Releases from overflow
o Leaks through tank shell
o Spills from coupling/uncoupling
operations
o Releases from overflow
o Spills from coupling/uncoupling
operations
o Spills or other releases from waste
handling/preparation activities
o Spills due to mechanical failure
o Spills from waste handling opera-
tions at the well head
* The two remaining solid waste management units; waste transfer
stations, and wasta recycling operations generally have mechanisms
of release similar to tanks.
9-3
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o An understanding of the primary mechanisms by which the
releases way occur from the unit and the potential for
this release.
When assessing the likelihood of releases to soils from a
unit, the Investigator should Initially consider the relative
potential of the unit for a release. For example, an above-ground
tank located directly on soil has a greater potential for a
release than does the same tank raised two feet above a cement
pad with adequate curbing. Exhibit 9-1 presents a generalized
ranking of the different types of SWMUs and their potential for
having releases that contaminate surrounding soils. Exhibit 9-1
also lists the mechanism for release associated with each unit
type.
The major unit-specific factors the Investigator should
evaluate are discussed below.
1. Unlt deslgn
The design factors of the unit, Including Its capacity and
dimensions, can Indicate the potential for a soil release. For
example, an undersized above-ground tank will be more susceptible
to overtopping than an adequately sized unit.
Features designed to reduce or eliminate release should also
be considered. Some features are better able to eliminate releases
than others. A triple-lined landfill with a leachatt collection
system will be less prone to subsurface releases than a single
clay-lined surface Impoundment.
2. Operational history
The Investigator should evaluate the unit's operational
history for Information which Indicates that a release may have
occurred. Operational factors that may Influence the potential
for a release Include;
o The length of service life of the un1t» Older units will
have a greater potential for a release, particularly due
to failure of liners or control equipment than newer units*
o Operational status (Active, Inactive, closed)
o Operational procedures such as proper maintenance, regular
Inspections and records, A well maintained unit has less
likelihood of leaks, spills or equipment failure.
3, Physical Condition of Unit
During the VSI, Investigator should examine the units for
evidence of releases ^r characteristics that could cause releases.
For example, when examining a surface Impoundment, he/she should
determine whether the earthen dikes are structurally sound and
capable of preventing releases. Cracks, slumping, or seeps
9-4
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around the toe In the dike may show evidence that the unit's
condition may cause releases to the surrounding soils.
B. Waste Character1s t1cs
The Investigator should attempt to Identify the wastes
originally contained within a SWMU or group of SHMUS during the
PR. In the RFA, the Investigator should try to connect Informa-
tion on waste types, unit characteristics! and evidence of soil
contamination to demonstrate the likelihood that specific SWMUs
or groups of SWMUs have released constituents to the soils* This
section describes technical factors to consider when Identifying
waste characteristics relevant to soil releases* It also discusses
physical/chemical properties that affect the release potential
of wastes and their subsequent transport 1n soils.
Information on wastes Is usually available In Part A permit
applications. Inspection reports, and facility operating records
reviewed during the PR. The investigator should compile specific
Information on waste characteristics 1n order to assess not enly
the potential for a release to soils, but also to Identify the
chemical form that the hazardous constituent might take In the
soil environment, and to determine 1f a contaminant found 1n a
soil release can be expected to migrate to other media.
Constituents tend to migrate 1n different forms and it dif-
ferent rates 1n the soil medium, depending upon their properties.
Some Appendix VIII constituents are Insoluble 1n water and bind
tightly to soil particles, thus minimizing their migration poten-
tial* Therefore, 1t Is Important to evaluate a waste's mobility
1n order to determine Its potential for dispersion 1n soils and
Its tendency for transfer to other media* Releases of organlcs
may behave very differently than metals 1n the soil environment.
Hazardous metals and Inorganics (e.g., arsenic and cyanide)
may be relatively mobile* Other Inorganics and metals (e.g.,
lead) are less mobile depending upon the pH of the wastes, and
the llgands available *n soil for complex formation.
The mobility of organic constituents can be expressed
quantitatively by the sorptlon equilibrium constant (Kd), The
value of KH depends upon the organic content of the soil and the
constituent-specific soil adsorption coefficient (Koc)»
The Investigator will seldom have access to Information en
organic content of soils at a facility; Instead 1t will be more
useful to estimate the relative mobility of a constituent as
expressed by Koc. Koc values have been calculated for only a
small stt of hazardous constituents; however, the octanol-water
coefficient as expressed by (Kow), can be used as an Indicator of
Kd. Appendix E presents Koc and log(Kow) values for most consti-
tuents of concern. Because these values are log values, chemicals
with Kow values of more than two can be considered relatively
immobile. Values less than one are considered to be mobile.
9-5
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The volatility and blodegradabll1ty of constituents can also
be Important 1n Identifying whether contaminated soil can act as
a transfer medium. For example* highly volatile components of a
past release may no longer be present for detection 1n i sampling
program. Readily biodegradable components also may not be present,
although certain degradation products may Indicate that a release
has occurred.
C. PoVIutant Migration Pathways
The Investigator should evaluate during the PR available
information pertaining to potential soil migration pathways at a
facility. Contaminated soils can transfer chemicals to ground
water by leaching, to surface water by contaminating run-off, and
to air by the suspension of contaminated particulars* This
Information will play a major role 1n Identifying the potential
for Intermedia transfer of releases during the PR,
The Identification of migration pathways associated with
soil releases will be most Important when the soil 1s being
evaluated as a transfer medium. Basic to any evaluation of
pathways for soils 1s the assessment of site geology, soil type,
and climate. This evaluation relies on standard Information
usually available during the PR for each site, The primary
climatic effect that should be determined 1s tht annual rainfall.
Sites located 1n regions with high annual or seasonal precipitation '<
will have a greater potential for releases to spread through the
soil or to tht other aqueous media. Conversely, very arid regions
may be susceptible to wind-borne distribution of contaminated
soil particulates . •
t
The Investigator should evaluate the site's topography and j
look for low lying areas where spills may collect. He/she should {
also estimate the proximity of the unit 1n question to surface
water, particularly locations within flood plains. j
The underlying geology of a site should be determined 1n j
order to evaluate the potential of soils to transfer contaminants !
to that medium. Soil characteristics that are to be evaluated I
are dependent upon underlying geology. !
The determination of site-specific soil characteristics will ?
be useful when determining the Impact of a potential soil release.
Soils are characterized by particle size, ranging from large sand
particles, to silt, to the small clay colloids. Loams are soils
where these particles are found 1n various percentages. Releases
will be distributed through sandy soils more readily than through
clays. Clays usually have an associated attraction for certain
chemicals since they are weakly Ionized.
The organic content of soils will also affect their ability
to bind or blodegrade certain chemical releases. This Informa-
tion Is available for most sites from USGS or State Soil Conserv-
ation Service soil maps. Interpretive data are usually available
9-6
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along with the map. General Information Mill often be Included
on the depth of a soil layer,
0, Evidence of a Release
During tht PR, the Investigator should examine available
sources of Information to Identify evidence that constituents*
have been released to soils at a facility. The Investigator
should evaluate both direct and Indirect evidence of release
during the PR, Chapter Two outlines general considerations on
looking for evidence of releases.
The VSI Is particularly useful for Identifying releases to
soils. Stressed vegetation can Indicate the likelihood of a soil
release. Direct evidence of soil releases Includes:
o Evidence of olllness or slick on soils; and
o Discoloration from background soil color.
Direct evidence of a release may also Include official
reports of prior release Incidents, such as a major tank leak
onto the ground. Indirect evidence of a release to soils may be
provided by ground-water monitoring data that show contamination.
When the Investigator Identifies Indirect evidence of this type,
it may be possible to determine the source of the release by
evaluating the pollutant/soil migration pathways and the waste
characteristics at the facility. Soil sampling data may exist at
some facilities, although this will not be likely, since there
are no requirements for soil monitoring.
There are likely to be Instances of soil contamination that
cannot be linked directly to units at a facility. Areas that
were used to handle wastes 1n the past but are now unused may
have contaminated soil.
E, E xPOsure Potential
The Investigator should evaluate available Information on
the location, number, and characteristics of potential receptors
that could be affected by releases to soils at the facility.
These receptors Include human populations, animal populations
(particularly any endangered or protected species), and sensitive
envlronments*
While 1t 1s not within the scope of the RFA to estimate the
risk associated with a release to soils, 1t Is Important to Iden-
tify any potential for direct exposure to the release. Informa-
tion on the potential for direct exposure Include:
o The security of the facility. Is access to the site
prevented by adequate fencing or barriers?
9-7
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o Tht projtlmtty of the unit/facility to children, specifi-
cally to schools and play grounds.
If the migration of chemicals from soil releases to other
media has been Identified* the sections 1n this Guidance on
releases to those media should be refered to In order to determine
exposure potential to constituents released and transfered to
other media.
The Investigator should evaluate the severity of the release
to soils along with the potential for direct exposure* If recep-
tors are currently b®1ng exposed to highly contaminated soils or
have a high potential for being exposed, the Investigator- should
consider recommending Immediate corrective measures to limit
access and direct exposure.
F. Determining the Need for Additional Samp!1ng
The Investigator may not be able to determine whether a
release to soils from the unit has occurred, slnct existing data
may be unavailable or Insufficient* In cases where historical
Information and visual observations are not adequate to determine
1f a release from a unit to soil has occurred of 1s likely to
have occurred, he/she should consider whether additional sampling
and analysis would help make a determination. In this section,
we present: i
(1) General Information on factors to consider 1n deter- ;
mining the need for additional sampling Information;
(2) Factors to consider 1n selecting sampling parameters;
(3) An example to Illustrate this discussion. j
1. Gene ra 1 Inf orjnait 1 on p_n_ Determl n 1 ng the Need for Samp1Ing . i
Soil sampling during the SV will generally be confined to I
surface soils or to shallow coring using hand equipment* Because
of the relative ease 1n obtaining soil samples, 1rt some cases, !
soil sampling may be used to obtain Information on releases to I
ground water where existing wells may not be adequate and new I
well placement 1s beyond the scope of the RFA, j
The following are situations where soil sampling data could
be useful ;
o Visual examination reveals an area at a facility where
unspecified wastes were applied 1n liquid form for several
years. Facility 1s situated on sandy soils with rapidly
moving ground water, with nearby drinking water wells
located apparently downgradlent. Sampling data would
reveal presence of and types of constituents 1n the soil,
which If positive could trigger additional ground water
Investigations.
9-8
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o Ground-water data downgradient from an above-ground tank
Indicates contamination from Its wastes. No record of
a spill exists and the unit appears structurally sound,
however, the observed contamination should have migrated
to the ground-water through the soils.
o Drainage patterns show that runoff from a landfill tends
to collect 1n a low lying area. Constituents expected to
be released sorb to soils and contamination of the run*
off can be verified.
2. Sel ect.1 Qip^of Sampjjfnj Parramete_rs
Knowledge of the wastes that may be potentially released from
a unit Is the starting point when Identifying sampling parameters.
However, many SWMUs have Incomplete or no data on the wastes
deposited over time. When little 1s known of the wastes managed
in the unit, 8C/MS scans for volatHes, add extractablts or
base/neutrals become a good starting point when selecting param-
eters for analysis 1n soils.
Metals are also of concern under RCRA. If a waste source 1s
hazardous dut to EP Toxldty, the metals of concern are a smaller
subset: arsenic, barium, cadmium, lead, mercury, selenium, and
silver. The following metals precipitate readily under many
naturally occurring conditions and may be detected 1n soil anal-
ysis: cadmium, lead, nickel and zinc.
The volatile 6C/MS scan Identifies chemicals that are charac-
teristic of solvents and lighter petroleum products. Because
they are volatile, they can evaporate from soil releases Into the
air. Evidence of these chemicals may be difficult to obtain 1n
older releases.
The acid extractables (I.e., phenols) may be present 1n
heavier petroleum feed stocks and certain Industrial processes
(e.g. pentachlorophenol from wood preserving). Phenol and the
mono-halogenated phenols blodegrade 1n a soil environment.
Pentachlorophenol 1s very persistent.
Base/neutral compounds can often be found 1n wastes from
Industries such as the plastics and synthetic fibers manufacturers
The pesticide scan Identifies pesticides that are found 1n pesti-
cide wastes and products from the agrlchemlcal Industry.
All monitoring data should be coordinated with the unit
specific Information available on the potential for constituents
to be released to soils and the Investigator's professional
judgment.
9-9
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III. CQLLICTINfi ADDITIONAL SAMPLINi INFORMATION IN THE SV
This section presents technical Information related specifi-
cally to the soils medium to be considered when collecting addi-
tional sampling Information 1n the SV, Accordingly, the Informa-
tion presented here should be used to help the Investigator meet
one of the primary goals of the SV:
o To collect additional sampling Information to fill data
gaps Identified In the PR and VSI.
For eacfc sampling method discussed, this section describes;
1) general situations where 1t Is appropriate to employ a specific
technique* 2) technical Information on how to conduct the sampling,
and 3) specific details to be considered when evaluating the
sampling results* This section does not provide the actual SOPs
on the sampling techniques. However, 1t references relevant
manuals.
large
The choice of appropriate sampling methods will have a lai
Impact on the cost and usefulness of the SV, The Investigator
should be confident when developing and reviewing the sampling
chosen will meet the objectives of the
1n the collection of unnecessary data.
at surface, shallow depths, and special
are warranted.
plan that the procedures
RFA, while not resulting
We discuss soil sampling
cases where deep samples
A. General Information on Selecting Sampling locations
The Investigator should use best professional Judgment 1n
determining appropriate locations for soil sampling. During the
visual site Inspection, pertinent topographic features should be
located. These features Include drainage patterns, fill areas,
eroslonal and deposltlonals areas. Any surface run off, seeps,
springs and the proximity to surface water and wet areas should
also be noted. Releases from a unit will seek the lowest area.
Such low spots may be deposltlonal areas for any released chemicals
and would be the best location to start any subsequent sampling.
Topographic maps are helpful. Strategically locating the sampling
areas should minimize the number of samples necessary a i the
effort for their collection.
After Identifying the areas designated for soil sampling,
the exact location of the sample area and the specific sample
location should be recorded on a site map. Soil sampling will be
generally completed by using surface samples and hand equipment.
Surface soil sampling should be conducted 1n deposltlonal areas
since these areas tend to have higher concentrations of released
constituents. This Is valuable for the screening function of the
RFA, but these levels are not Indicative of the overall area
conditions. The extent of a release will be determined under the
RFI.
9-10
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The d«pth of the sample (e.g., surface, one foot below
surface) should be recorded 1n a field log book. When Identify-
ing metal constituents from a release, 1t may be Important to
consider soil type since many have natural background levels of
certain heavy metals.
B. Sampling Methodology and Evaluation of Results
Soil sampling will usually be done using hand equipment such
as stainless steel spoons, scoops, shovels* hand auger and small
diameter push tubes* This equipment 1s available for sampling at
shallow depths; however, when soil Is difficult to penetrate,
even shallow sampling may require power equipment such as augers.
Shelby sampling tubes or thin wall push tubes can be used by both
hand and power equipment. Stainless steel components are recom-
mended for these tubes. Soil samples are extruded from the tubes
for logging and for selective sampling, T*e tubes can also be
capped and sent directly to the laboratory fur analysis.
Surface sampling of soils can be done with a stainless steel
spoon or scoop. Grass, leaves and other debris should be scraped
off the surface prior to sampling* Shallow samples can be col-
lected by digging a hole with a shovel or post hole digger, then
removing all loose soil from the hole and sampling with a stain-
less steel spoon at the desired depth. For densely packed soils
or deeper soil samples, a soil auger may be used. The sample is
extruded and 100 to 200 grams of the sample 1s transftrtd to a
250 ml container. A label 1s attached with required Information
and the de,>th of the sample, and Its location Is recorded in the
field logbook.
Soil samples are collected in wide-mouth glass jars equipped
with Teflon-lined screw caps. These samples require no preserva-
tion or refrigeration. Tape the lid securely and mark with
collector's Initials. Carefully pack the samples with the appro-
priate cha1n-of-custody forms. Chapters six and seven of the
"Revised Draft Protocol for Ground-Water Inspections at Hazardous
Waste Treatment, Storage and Disposal Facilities11 October 1985,
are a good reference for these soil sampling techniques. Charac-
terization of Hazardous Waste Sites « A_ Methods Manual. Volume
II'. Ava'fTa"bTe Sampling~Methpds is al so"~a good reference for more
Ie"tal1 on soil sampling technlques.
If H is necessary to sample soils at depths greater than 18
Inches, sampling with power equipment can be done* It may be
Important to sample at lower depths when the release 1s very
mobile and not of recent occurrence. The Investigator may suspect
that the release has moved several feet below the surface and
that surface sampling may no longer show evidence of the release.
Split barrels or piston-type samplers will be most useful 1n
these situations. These methods are based on ASTM 01586-67(1974),
"Method for Penetration Test and Split Barrel Sampling of Soils*,
and ASTM 01587-74, Thin Walled Tube Sampling of Soils.
9-11
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The sampling of soils at depths greater thin 4 feet can be
accomplished by the use of ttst pits and trenches. The size of
the pits and trenches will vary, but should be large enough to
permit the entry of personnel, under strict safety requirements.
The excavation of tht pits Is performed most commonly by a back-
hoe. Because of the equipment Invoked, sampling from a pit will
seldom be appropriate 1n the RFA, a iough this method may bit
applied 1n certain circumstances when It 1s valuable to make £
visual 1n situ Inspection. This technique may be applied 1n
situations where the Investigator suspects that the release may
be 1n pockets distributed both horizontally and vertically through-
out the soils, and may not be detected readily by sample borings.
Once the pit or trench has been opened. It should be stabil-
ized by sloping the walls or by the use of shoring material.
Sampling then occurs at designated spots by using scoops, shovels
or hand augers. All pertinent Information on pit location and
sample location within the pit should be recorded 1n the field
logbook. Photographs are a valuable aid when Identifying the
exact location of a sample within a pit or other subsurface
visual evidence of contamination*
The exact depth and construction of a test pit should be
designed by a field geologist or soils scientist. Sufficient
space on site should be maintained for placement of removed
material. After sampling, backfill material should be returned
to the pit under the direction of the field geologist or soils
sclentlst.
IV. MAKING A RELEASE OfTERMINATION
The final task 1n the RFA 1s to make determinations of release
potential throughout the facility and to make recommendations for
further action to address potential releases. This section
summarizes Information that the Investigator sh Mid consider when
making release determinations for the soils meoi..
Chapter Four presents the general procedure to be followed
when making release determinations at the end fo the RFA. This
involves:
o Evaluating sampling results from the SV;
o Integrating facility Information gathered 1n the PR,
VSI, and SV to determine the likelihood of release at the
facility; and
o Making final recommendations concerning the need for
further Investigations.
The Investigator should rely upon his/her best professional
Judgment and available Information when making determinations as
to whether or not contaminated soils pose a potential or actual
9-12
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threat to human health and the environment. Further Investigations
should be required 1f It 1s determined that exposure of receptors
1s occurring or 1s likely to occur through direct contact with
contaminated soils, or 1f there 1s a likelihood that contaminated
soils are causing contamination of ground water or other huimn
health or environmental problems.
Exhibit 9»2 1s a checklist that should help the Investigator
evaluate specific factors to Identify releases to soils and to
determine the effect on human health and the environment. When
Identifying releases, the Investigator should consider the series
of characteristics described 1n the chapter and highlighted 1n
the cheek list that determine the potential for releases to soil
from units of concern. These characteristics Include; the unit
type (e.g., above ground tank), the unit's containment systems
(e.g., liners), and the unit's design capacity. Also, factors
such as the unit's age, condition, the quality of Its operating
procedures, and whether or not the unit has a record of compliance
problems may Indicate the potential for a release*
9-13
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EXHIBIT 9-2
CHECKLIST FOR RELEASES TO SOILS
Identifying Releases
Potential for Soil Releases from theUnlt
o Unit type and design
- Does th* unit type (e.g., landbased) Indicate the potential
for release?
- Does tht unit have engineered structures {e.g., liners,
proper construction material) designed to prevent releases?
o Unit operation
- Does the unit's age (e.g., old unit) or operating status
(e.g., Inactive) Indicate the potential for release?
- Does the unit have poor operating procedures that Increase
the potential for a release?
o Physical condition
• Does the unit's physical condition Indicate the potential
for release (e.g., lack of structural Integrity)?
o Site characteristics that affect the ability for soil to act
as a transfer media
- Is the soli particle slie large (e.g.* sand) such that the
migration of releases through the soil can readily occur?
- Is the soil high 1n organic material that may either bind or
blodegrade certain chemical releases?
- Is the soil layer shallow (e.g., less than six feet)?
- Is high annual rainfall characteristic of this climate?
Is the unit located near a body of water (e.g.. In flood
plain)?
Is runon and runoff from the unit controlled?
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APPENDIX A
SAMPLE RFA REPORT OUTLINE
-------
APPENDIX A
SAMPLE RfA REPORT OUTLINE
I. Conducttog the Preliminary Review
A. Facility Haste Generation and Manufacturing Process Description
B. General Background on Environmental Setting
C. Location* and Characteristics of SWMUs and Other Potential
Areas of Concern
1« Facility Map Identifying SWMUs and Potential Araaa of Concern
2. SWMU Information (for each SWMU or location of concern)
a. Unit Characteristics
b. Waste Characteristics
c. Pollutant Migration Pathways
d* Evidence of Release
e« Exposure Potential
D. Identifying Data Gaps and the Need Cor Additional Owner/Operator
Information
II. Conducting the Visual Site Inspection
A. Description of VSI Activities and Observations
B. Update SVMU Information Baaed Upon VSI Results
C. Conclusions and Recommendations for Further Action at Each
SWMU/Location
1. Ho Further Action
2m Conducting a Sampling Visit
3. Conducting a RCRA Facility Investigation
4* Implementing Inter!* Measures
x
III. Conducting the Sampling Visit
A. General Description of Sampling Objective*
B* Sampling Plan for SV
C. Results of Sampling Visit
D. Conclusions and Final RFA Recommendations for Further Action at
Each SWMU/Location
APPEHBICES
A. Visual Site Inspection Logbook
B. Photographic Documentation of VSI
C Sampling Visit Logbook
D. Photographic Documentation of SV
I. Sampling Visit Safety Plan
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APPENDIX B
INFORMATION SOURCES
-------
RFA INFORMATION SOURCES
This appendix provides details on th« many source* of information whcih may be
useful during the RFA, particularly the preliminary review. Most of these sources
will be readily available to Regional/State staff. This section provides a brief
description of the contents of each source and information on how to obtain them*
I• RCflA Sources ». B-1
1. Permit Applications B-l
2. RSI 13 Submission (SWMU Response).** 8-1
3. Compliance Inspection Reports/Information from
Enforcement Orders B-2
4. Exposure Information Report..**..»..»...»...« *» B-2
5, Other RCRA Sources *.* .*...*...*..... B-2
II. CERCLA Sources ...*. B-2
1. CERCLA PA/SI Reports 8-2
2. HRS Documentation B-3
3. CERCLA RI/FS Studie 8-4
4. CERCLA 103(C) Notifications B-4
III. Other Federal Environmental Program Sources .... B-4
1. NFDES Permits and Permit Applications. * B-4
2. Clean Air Act Permits and Permit Applications ..,...«». B-4
3. TSCA/OSHA Inspections ... B-5
4. Department of Defense Installation Restoration
Program (IRP) Reports B-5
IV. Other Miscellaneous Sources ......<,..*.... B-5
1 * Aerial Photography*». .*.»*......* B-5
2. State/Local Well Permits. B-6
3. U.S, Geological Survey and State Rydrogeologic Maps B-6
4. U.S. Soil Conservation Service Soil Haps....*..*..*..,*.. B-7
5, GEMS (Graphical Exposure Modeling System) B-7
6. Municipal /County /City Public Health Agencies B-7
7. State/County Road Commissions B-7
8. Utilities. „ B-8
9. Local Airports/Weather Bureaus..*.,**..*. B-8
10. Naturalists/Environmental Organizations....... *...»».. B-8
11. Employees B-8
12. Col leges/Universities <»... B-8
13. Interviews With Local Residents « B-8
14. Standard Reference Texts.. B-9
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UFA INKIRKATION SOURCES
I. RCRA Sources
I* Partait Applications
?-.rt A notifications and Part B applications for permits contain a sizable
amount of information on the facility design and physical characteriseica of the
surround Ing ar««. This Information will sometimes apply to both unregulated
releases fron ragulat«d units and releases froo unregulated ("old") units, and
should prove invaluable at many facilities in assessing the potential for old
units to contaminate ground eater. If the facility it seeking only an above-
ground storage facility permit, however, the permit application data may not
provide nueh Information useful in evaluating an "old" landfill.
Part B application* may not characterize the lower aquifers if they are not
connected to the uppermost aquifer* If the application data are Inadequate to
properly assess the Impacts to ground water, the information may need to be
developed through other source* discussed later*
In addition to relevant data on the facility as a whole, the permit applica-
tion also providea Information that can be used to evaluate the potential for
unregulated releases from regulated units, specifically surface water and air
releases. Moat of the pertinent data/relate to the design and maintenance of the
unit will be contained in the application* Part B permit applications for land
dispoeal facilities will alto provide Information on whether actual releases
have occurred*
It la important to evaluate well placement when reviewing ground water
monitoring data for regulated units. In some cases the location of existing
monitoring wells may make it difficult to determine if contamination reaulta
from the regulated unit, an unregulated unit, or both. Review of the analytical
data must be coupled with data on well location and ground water flow to posi-
tively identify the source of the observed release*
The Regional offices and/or the State offices will have copies of the
permit application* for the facilities within their Jursidlction.
2. RSI 13 Submission (SWMU Response)
The data submitted in response to the Reauthorication Statutory Interpreta-
tion (RSI 13), dated February 5, 1985 froa Jack W. McGraw, should provide infor-
mation on the type and location of SwMUa, and information on the quantities and
types of wastes disposed in the SWMU*. These submissions, however, may be incom-
plete or Inaccurate, and should not be relied upon solely to Identify and charac-
terize SWMUa. In many cases, the owner/operator was unclear which units to
consider SUHUs, and the historical information on wastes diapoaed in them may not
have been readily available to the owner/operator*
The SWWU response will be Available to Regional RCRA personnel.
1-1
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3» C«mpii«occ Inspection Reports/Information from Enforcement Orders
Compliance Inspection Reports are available for most RCRA facilities. :
Tha»« reports contain useful information on alta management practices, monitor-
ing data, and unit conditions and should help in identifying problem units and
release* for possible sampling. Comprehensive monitoring evaluations (CME's),
which evaluate fround water monitoring systems at the facility, may provide an j
indication of whether prior releaae* have occurred at the facility, frequent , {
violations of operating standards nay indicate prior releases. Sons RCRA in- j
•peetlon reports will contain detailed information on the management practices
at the facility, auggeating the wastes most likely to be found on site.
Bnforcaaent actions at facilities way result in enforeesMtnt orders* Re-
port i of these actions say provide useful information on releases at a site.
In oany cases, the Investigator taay be able to obtain information on unregulated
units from results of investigations required in enfortament actions*
These reporta will usually be leapt on file in Regional and State offices
with Jurisdiction over the facility.
4. B«pos!]?e Information Report
The 1984 Hazardous and Solid Waat« Amendments require owner/operators to
submit an exposure information report (EIR) to describe the likelihood of expo-
sure resulting from watte disposal activities* Only facilities seeking operat-
ing permits for landfills and surface impoundments are required to "submit ins.
Elfts will be available at Regional /State offices for facilities within their
Jurisdiction*
5, Other RCRA Sources
Several additional RCRA aources may provide useful information during the
RFA. These sources will all be on file at the Region/State office for facili-
ties within their Jurisdiction.
o Biennial report
o Operating log
o RCRA waste manifest
o Notice to local authority
o ACL requests
II. CERCLA, Sources
1. CZRCLA PA/SI Reports
Almost IS percent of the iaclllties seeking RCRA Part B permits have re-
ceived CERCLA inspections. Ttwt site Inspection reports for these facilities
can provide a considerable amount of information on facility and unit design
and management, waste characterisation, and pollutant dispersal pathways,
particularly for SWMUs and Inactive units. They may also have limited Informa-
tion about target populations. The exact amount of information provided in
each report will depend on the amount of information available at the time the
report was completed.
B-2
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Th* ttRCLA SI rtport 1» Ukaly to provide »«i» information for the follow
inn «t«forl««J
o Facility deaign/aaaagenent praeticaa
— Uating of SWOT operations, facility layout!
<— Diacuecioa of condition* of Want if lad SWtUej and
— Detiign epaclficatlona for SWMUe (when available).
o Waste eh»?«eterii£iea
— Typa and quantity of waste received to the extent known
o Pollutant iltperaal pathways
— Analytical data on "observed ralaaaaa" from tho facility;
— Geology, topography, hydrogeology, climate of tha area (if unit could
ba releasing to ground watar)}
— Cliouitic data (a.«. practpitation, wind data); and
~» Facility topography at it ralataa to aurfaca drainaga pattarna.
o Rtcapto? charactari»tlc.»
— Sisa and characterlitica of naarby populationa and aanaitiva anviron-
Mnts potaa£lally aipoaad through air, aisrfaca watar, and ground
watar routaa.
In addition to raviawlng tha final SI raport, tha paraon conducting tha RCRA
preliminary aaaaaawunt ahould alao **Mminm tha CERCLA alt« fila* fhaat fllaa
contain supplemantary infotnatlon uaad to avaluata tha tit* undar CBRCLA. Thase
fiia* include »uch it*na aa:
o Fiald log book for tha SI
Q frip raporta for the SI
o Record a of comunleation
o MiacaUanaooa hiatorieal data/ raport a
Except for tha firat iten, tha axact contanta of tha fila will vary d«pand-
Ing upon the typa of inforaation available and tha data collaction procaduraa
used at tha tiaa of tha CERCLA SI,
Tha CERCLA FA/SI reports will ba on fila in eh* Supcrfund diviaion of
Raglonal/Stata offices with Jurisdiction over tha facility*
2, HitS; Docuaantation
Sow* aub««t of tha altaa that have undergone CiRCLA PA/SIa have bean acored
ualng tha Haiafd Ranking Syataa * Inforaation on target populations and
aeniitlve environments ahould ba available for each of tha routes scored. Tha
•oat frequently scored routaa are aurfaca watar and ground watar* This document
way identify potential location* of concern for tha RFA, though it My not
ba coatpreh*naive.
Tha Regional CERCLA progran office* have copiaa of all CERCLA RR§ reports
and file*.
1-3
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11/ftStudies.
Again, some subset of th« sites that have been given an HRS *eor« will have
been subject to a remedial investigation/feasibility study (RI/FS). If eo, thaaa
raporta will eharaetarize In great detail: alt, aurfaca water, ground water and
aoil contamination, aa wall aa population* actually or potentially affected by
thaaa ralaaaaa.
Tha Regional CERCLA program offlet* hava coplaa of all CERCLA RX/FS raporta
and fllaa*
4. CBRCLAJtO^e) Notifications
Some altaa nay hava Information available on waataa dlapoaed of at the
facility from a CERCLA 103(c) notification, which providaa information on all
reportabla quantities. In the early stages of the CERCLA program, owners or
operators of waate management facilities and transporters ware required to
notify EPA of places where CERCLA hazardous substances had bean disposed. EPA
reviewed approximately 9000 notifications representing approximately 2000
sites, after accenting for redundant reporting. If the facility filed a CERCLA
103(c) notification, and no other aource of information is available, this
source aay provide a record of past disposal operations, such aa Information on
types, locations and volumes of waate disposed*
The reviewer should contact the Regional CERCLA coordinator to see if a
CERCLA 103(c) notification exlats for the facility*
III, Other Federal Environmental Program Sources
1. NPDES Permits and Permit Applications
The National Pollutant Discharge Elimination Program (NPDES) regulates the
discharge of all pollutants into the waters of the United States. Many RCRA
facilities also have NPDES peraits for their wastewater diachargea, and will
have submitted permit applications and usually received permits. These permit
applications aay provide a large amount of detail on the types of waste generated
at the facility, and aome historical data on how these wastes were dlapoaed in
the past*
The Investigator should contact the Raglonal or State NPDES office In order
to obtain copies of pertinent pen .its and/or permit applications*
2. Clean Air Act Permits and Permit Applications
Some RCRA facilltiea will have air emissions requiring stationary aource
controls under the Clean Air Act. These permits and permit application* may
provide uaeful Information on waste generation at the facility* The baghouse
emission control dusts from some facilities (e.g., secondary lead smelting
facilities) are listed hazardous westes and must be disposed in accordance with
RCRA. The Clean Air Act permits and permit applications should be consulted at
the appropriate facilities.
The investigator should contact the Regional/State air permitting office
for Information on permitting at these facilities.
B-4
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S. T8CA/08HA laapectiona
The fwtte Substsness Control Act (TSCA) regulates tit* disposal of PCB« and
fCB equipment. In some cases the responsibility for conducting TSCA inspections
i» merged with the HSRA inspection program* In other eases, these inspection*
are eooduetttd by « different wnit within If A. TSCA Inspection films may have
useful data OB how swell and where disposal and storage of FOB* has taken place
at a particular facility.
The Occupational Safety and Health Administration (OSHA) inspection reports
•ay identify the types of Materials handled by a facility and may also establish
whether the owner or operator has a history of violations* Violation histories
can indicate a facility's propensity for releases that Bight be subject to cor-
rective action*
For information on TSCA activities at a facility, the investigator should
contact the Regional toxic substances office* For information on OSHA inspec-
tions, the investigator should contact!
Occupational Safety ftnd Health Administration, Federal Agency Program*
202-523-602?
4. 3epartmeat of DefenaeInstallation ReetorattonProgram {IRP) Report•
The Department of Defense has been conducting « corrective action program
at its facilities, entitled the Installation Restoration Program (Iftf), for
approximately ten years. This program was developed to characterise and remed-
iate contamination st SOD facilities, and is similar to the Superfund program.
The UP program is organised into four phases* Phaee I, which is similar to
the UFA; Phase II, which is similar to a CERCU Remedial Investigationi Phase
III, which is similar to a CKRCLA Feasibility Study; and Ftiase IV, which is the
dealgn/ccmatruct phase of the program.
All OOD facilities should have a completed Phase I report, which will be
very useful during the BFA at these facilities. Many of the facilities 11
also have a completed Phase IX report, which will also be of great use during
the RFA. Each branch of the armed forces has a separate office coordinating
their IRf work. The investigator should contact the following offices in order
to obtain copies of ZRP reportss
o U.S. Air Force: Occupational and Environmental Health Laboratory (01HL)
o U.S. Army: U.S. Army Toxic and Hazardous Materials Agency (OSATHMA)
o U.S. Navyt Naval Facilities Engineering Command (HavFEC) .
IV. Other Miscellaneous Source*
1. AerialPhotography
Aerial photography, especially historical aerial photography, can be a
valuable tool in a prelimary assessment* Historical aerial photography can
provide the following types of information;
o The location of past disposal units;
o The location of releases;
1-5
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o Evidence of existing or past; vegetation stress;
o Potential routes for contamination migration;
o Location and nuabers of target populations; and
o Land uses in eh* sr«a.
A nuabar of 1CR& cites that wars evaluated under CERCLA have had both
historical and recent aerial survey analysis, fhs WJIA reviewer should contact
his/her regional coordinator for aerial photography. These coordinator! have
accetc through ORD/EMSL/LV to an index of sites that have had a«rial photo-
graphic analyse*.
If an historical analysis and currant overflight do not axis*, tha>y can b*
requested through the regional coordinator* BMSL has a computerized system
which accesaas the major sources of extensive aarial photography including
libraries, archives, and tha U.S. Geologic Survey. BMSL can use this to ordar
copies of the photographs, analyze tha photographs for relevant features and
prepare a bound copy of th« analysis. In most cases* historical aarial photo-
graphy will suffice for the purposes of tha RCRA RFA*
The usefulness of current aarial photographs is oore Halted. They nay ba
able to identify vestiges of old disposal practices, currant vegetation damage,
and surface drainage patterns. Infrared photographs nay be useful in identify-
ing areas of strained vegetation, they can also accurately locate target
populations* However, much of this information nay ba readily aacartalnable
from a visual inspection of the facility* Accordingly, requests for overflights
should be requested only when there are no other sources of the data*
2. State/local well permits
Most states require wall drillers to obtain well installation permits.
This source, if available, can provide tha •oat reliable information on tha
nusjbar of households using wall watar in a particular area. These offices can
often identify tha aquifer froa which individual wells draw and tha construction
of individual walls, including diameter. This information can also help in
identifying tha closest downgradlent wells that have tha appropriate wall
construction characteristics for sampling.
This information is usually kept on file In stata environmental program
offices, or aay be found at county public works departments,
3» O.S• Geologic Survey andState HydrogeologicMaps
Tha U.S. Geologic Survey (USGS) and stata geologic surveys aay have detailed
aaps characterizing the hydrogeology at locations of RCRA facilitiet. Many of
these aaps will supplement the ground-water characterisation found in Part B
applications, and for storage and treatment facilities, aay provide the most
available source of hydrogeologic information.
the USGS also has a sarlas of geological atlases providing data on geology
and soils. These maps can covar areas as small as one quadrangle (a 7»5 minute
map), which is approximately 6 by 8 alias. These aaps can also provide data on
soils and rock types underlying facilities which may ba helpful if data provided
by the applicant are incomplete or unavailable. This aay ba especially useful
for evaluating larger facilities*
B-6
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U8CS hydrologlecl map* provide Information on ground wattr yield, soil
tranamlaalvlty and location of US08 well* (for monitoring water level*). This
typs of aap may assist the reviewer la understanding etui relationship between
land based units *nd tenth Co ground water, location of ground water recharge
area*, prevailing regional flow, and ground water dl*continuities (if the owner
or ojsrstof IMS not already provid*d this typs of information). Th*ss maps are
aleo available for arsas aa small at 7-1/2'«
These MBS can be obtained by contacting th« local USGS office, or in th*
cate of state napa, th« local «£at* turvay offica*
4. P.S Soil Conaarva11on Servica So11 Map<
UeS. D«parto«nt of Agricultura Soil Con«arvation Sarvics (SCS) offices owp
aoil typ«a and paraatbiliti** at a resolution extending down to 2 acre* in toa«§
eatt»* Th»*« v«ps typically characterise aoll typ« to a depth of aix feet, and
the backup information uaad to develop these «ap* nay evaluate aolla Co greater
depth*. This backup information la alao available through the local SCS.
5. GEMS (Graphical Expoeure Modeling Syateo)
EPA has acc«aav through each of ch* regional offices, to a cotaputerixed
systea with th« capability to identify the number of individuals within a
specific radius of a facility* This syatan la readily available and can provide
reliable information on populations potentially at risk froa air releases.
When coupled with data on ground use patterns, It can also quantify target
population* drinking ground water.
6. Municipal/County/City Publle Health Agencies
Munlcipal/county/city public health ag«neiee or departauints can provide a
wealth of information on the type* of units located at a particular facility
and the vaataa routinely received at the site. Fir* marahalls can provide
information on the nature of any fires or explo*ion« that have occurred at the
facility. Information on incidents and ait* management prncticas can assist in
determining If any r«lea*«a have occurred or are likely to lecur a* a result of
poor facility management. These agencies maintain their record* and files for
a number of year* and often provide th* only other aourc* of Information on
"old" units.
Even if theae file* contain little information, employees who have worked
with the local agency or fire department for a number of years, oftan know a
lot about the site or whar* to obtain additional information.
7» State/County Road Coramisitions
Core samples of coil* and rock* underlying a proposed road are often
analyzed during the engineering and planning stage* of road construction.
Records of these analyses are usually retained and available through most
State/County road coaaisaions. This information can provide useful data, where
none or little are otherwise available, to evaluate the potential for contami-
nant* to migrate through soils and ground water, and possibly to determine
where to sample. This source will not be ua*d routinely during th* RFA.
1-7
-------
i.
Dtilitiee may fee able co provide e*trem«ly reliable *nd up-to-date popula-
tion data, ffcaj? can Identify th« number of households using public water aup-
pllee, both ground mot and surface water* They can also identify the location
of public water wells end Intake*, fills information la necessary not only to
determine th« affected population but may alao help identify possible locations
for sampling. It will not usually b« necessary to use this source during the If A.
9* Local Airports/Weather Bureaus
2 These organisations maintain accurate historical records of the local ell*
•ate. This information is essential In evaluating the potential and direction
that contaminants eould migrate through the air and the rate that contaminants
could migrate through the ground water and surface water routes. Contaminants
can be expected to Migrate faster through the ground water in areas with higher
precipitation* Wind dlraction(s) i* essential in identifying downwind targets
for air release*. Temperature is essential to evaluate the propensity for
materials to volatilise* The amount of rainfall, especially during peak periods,
can alao indicate the likelihood that contaminants will migrate overland to
surface water*
10. Na turalis t«/Environmental _0rganilatlona
Local environmental groups can provide information on the presence and
location of wildlife and endangered species. They oftan have access to indi-
viduals or information which can Identify the nesting grounds for animals.
They can alao identify any other sensitive environments,
11* Employees
Employees at the facility, both currant and former, may be able to provide
information on facility design and management a* wall aa information on the
types of waste* received at the facility. It may b» difficult to obtain owner
or operator permission to Interview current employees, for former employee*,
it may be difficult to Identify a knowledgable and reliable individual. Whan
interviewing former and current employees, the Investigator should be aura to
understand the employee'* motivation for providing the information and should
find out why former employees no longer work at (he facility.
12. Colleges/Pnlveraitlet
The biology departmenta of local colleges and universities may have informa-
tion on the location of sensitive environments* In some eases, graduate student
reports and publications have carefully mapped the location of nesting grounds
and migratory pathways. Such studies can be valuable in identifying the impact
of release* on target environmenta. The geology or agriculture departments of
local colleges and universities may have information characterizing the local
geology and hydrogeology. This can Include maps of the area and studies evalu-
ating the permeabilities of soil*..
13. Interviews with Local Residents
Aa a last resort, local residents can be a source of information on a
facility. Sometimes, long-term residents know a considerable amount about the
B-8
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klad of operation* cofldueted at a facility end the type and amount of waste
received at a facility. In gen*ral, thi« source of Information should be
•voided to prevent any undue or premature alarm.
14. StandaH tof er«nc« T««tB
Chemical Fate and Tram port Information
I. U.S. EPA, Water-Related Environmental Fata of 129 Priority Pollutanta,
EPA-440M-79-029a&b, 1979.
2. U.S. BPA, Aquatic Fate Process Data for Organic Priority Pollutant*.
EPA-440/4-81-014, December 1982.
3. W«««t» II.C*i wd., CRC Handbook of Ch«aii»try and Phyaieg. 6l»t «d.,
CRG Pr««a, 1981.
4. ICF, Inc.. T>raft. Suparfund Public Haalth Evaiuation Manualf Praparad
for U.S. EPA, Office of Eanergeacy and RaaadialReaponna, Deeevbar 18,
1985.
Ground-W»t«r Hydrology and Monitoring Well Construction
1. Freeze, R. Allan, and John Cherry, Croundwater. Pr«ntie*-Hall, 1979.
2. U.S. EPA, Office of Waste Programs Enforcement, RCRA Cround-Watar
Monitorinft Technical Enforcattant Guidance DocutMnt. Draft. Augijat. 1985,
3. Johnson Division, Croundvater and Wells. 2nd 4d*, 1986*
Hazardous Waste Site Characterization, Sampling, and Analyiis
1. U.S. EPA, Environmental Monitoring Systems Laboratory, Character!gation
of Hazardous Waste Sit«««A Method* Manual. Volume I-Sitalnvestigatione,
Volume IIt Available Saapllng tet.hodit and Voluaa III. Available Laboratory
Analytical ttethods,EPA76007»~e4yQ75t April 1985.
2. U.S. EPA, Office of Emergency and Remedial Response, Guidance on
Remedial Investigations Under CERCLA. May 198S.
3. U.S. EPA, Test Methode for evaluating Solid Waste. Physical/Chemical
Methods, EPA SW-846, July 1982.
4. Standard Methods for the Examination of Water and Wastewater, 16th
Ed., American Public Health Association, 1985.
Personal Safety
1. American Conference of Governmental Industrial Hyglenists, Threshold
Limit Values and Biological Exposure Indices for 1985-86. 1985,
B-9
-------
2. National Institute of Occupational Safety and Health/Occupational
Safatf and Health Administration. NIOSH/03HA Pocket Guide to Chaaieal
Eaattda, Q.S* Government Printing Offiea*
3. U.S. EPAf Offiea of Soergency and Remedial Resoonse, Standard Oparat ing
Safety Guid««. ldl«ont HJ» l§84.
Toxlcologtcal Properties of Chemicals
l» Sax, Irving, «d., Dangeroua Propartig* of Industrial Material! , 6th «d.,
Van Nloatrand Relnhold, 1934.
2. National Institute of Occupational Stfety and Health, Raglgtry of Toxic
Effects of Chaaical ......... Substances, U.S. Government Pri nt ing Of f lea , ( annual ) *
3. Clayton, G.D. and F.B» Clayton t Patty 'B Indua trial Hygiene and Toxicology,
3rd ed.,Vol«. l-3t Wiley Intarsctence,
4. ICF, Inc., Draft, Super fund Public Health Evaluation Manual. Prepared for
U.S. EPA, Office of Emergency and R«oedlal Response, December 18, 1985.
3-10
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APPENDIX C
SAMPLE LETTER OF REQUEST FOR
OWNER/OPERATOR INFORMATION
-------
Dear Sirs:
As we have discussed In our re-zenc telephone conversations , the
Plant has been selected by EPA as a subject for testing EFA's draft guidance,
RCRA ^FacJjLi^j|»«eg9aient Guidance. The preliminary assessment (FA) la the
first phase in the process of determining whether solid waste management units
(SWMU's) are releasing hazardous constituents Co the environment and require
corrective action.
After reviewing EPA files on the -_______ Plant, a list of questions
regarding additional information, has been developed. It is anticipated that
the requested information exists In your files. An attempt was made to keep
the requested information to a ninitauni in order to avoid lapacting your effort
in preparing the Part 8 application.
The following information is requested:
1. Provide elevations of all SWMU units and/or Identify chs 100-year floodplain
for the entjjre facility property.
2. Provide any available information (dates, quantities, mate rials, locations)
on past spills in the production area.
3. Spill tanks are shown on Figure B-l of ^_mia_m__ subatittal, but are not
mentioned in the text. Explain the purpose of the tanks and provide chemical
information on the material stored in the tanks. If this unit does not fit
the definition of a solid waste mar,af?am
-------
7. For the Waste Recycling Operations (Unit 4), provide the following:
1) A «*p »hewing the location o* each recycling unit And associated
atorage tank and piping. The nap should be on a scale of one-inch
equal to not more than 200 feet.
ii) An explanation of disposal and/or treatment of residues for each
recycling unit.
8* Provide the axact locations of the land farm areas and delineate boundaries
where possible. Clarify how many land farm areas have been used in the past.
9. Provide Amy available Information on Che chemical composition of the sludge
that has been applied to the land farms in the past.
10. For the Storage tanks (Unit 8), provide the following:
1) A aay showing the location of each tank and associated piping. The
nap should be on a scale of one-Inch equal to not wore than 200 feet.
A map combining the Waste Recycling Operations (Unit 4), as requested
above, with the storage tanks is acceptable*
ii) For each tank, indicate if any secondary containment exists. A 'yea"
or "no** response will suffice.
Hi) Describe the leak test performed, frequency and date of last test for
each tank.
iv) For each tank identified as having been found to leak, provide any
available information describing the approximate period of leakage
and estimated volume of leaked wastes.
v) For the tanks identified which nay have been used in the past for
solid waste storage, indicate which tanks are underground, elevated
or at surface level.
II. Clarify how many landfills exist or have existed at the facility* Delineate
boundaries of each landfill (where possible). If any other landfills are
identified, describe what materials were disposed of In these landfills.
12. Provide any available Information (dates, quantities, materials, locations)
on past spills at the facility that were reported to the National Response
Center (or the ^^^ Depart»ant of Health) as required under CERCLA.
C~2
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APPENDIX B
GUIDANCE OH 08TAIMISG ACCESS TO
A RCRA FACILITY I? ACCESS FOE
A SITE IIWESTIGATtQN IS DENIED
[SOURCE MATERIAL FROM: U.S.E.P.A. HAZARDOUS WASTE GROUND
HATEI TASK FORCE, "EEVISSD DEAFT PROTOCOL FOR 6ROU8D-WAT1R
IHS?KH!iOMS AT HAZARDOUS WASTE TREATMENT, STORAGE AND
DISPOSAL FACILITIES". JUME 1985]
-------
GUIDANCE 00 OBTAINING ACCESS TO A 1OU FACILITY
TO* A SITE INVESTIGATION IF ACCESS IS DENIED
If an investigator 1* d«ni«d access fco a facility co conduce * site Investigation,
th« following procedural itepa oust be followed.
•
Upon Denial of Access
1. Upon denial of access, thoroughly document the event, noting tlae,
date, and facility personnel encountered. *
2. A* It for reason of denial of access Co facility.
3, If ch« problem ta beyond the investigator 'a authority, augment that ch«
owner/operator contact an attorney to obtain legal advice regarding
his/her responsibility for providing facility access under Section 3007
of
&« IE entry I* still denied, exit fron the premises and document
any observations aade pertaining to the denial, particularly any
suspicion* of violations being covered up.
5. Report all aspects of denial of entry to the U.S. EPA Office of
Regional Counsel for appropriate action, which may include help
in obtaining a search warrant. **
Sear c h_^tfs rrant^ Jaff^-* e jEiona_
Conducting A *ita Investigates under a search warrant trill differ froa a noraal
inspection. The following procedures should be complied with In thtse
situations:
Development of a Search Warrant
1. An EPA Office of Regional Counsel attorney will assist Che investigator
in the preparation of the documents necessary Co obtain a search warrant
and will arrange for a meeting with him/her and a U.S. Attorney* The
investigator should bring a copy of the appropriate draft warrant and
affidavits to the meeting.
2. The U.S. EPA Office of Regional Counsel attorney will infora Ch,s
appropriate Headquarters Enforceeent attorney of any denials of
entry and send a copy of all papers filed to EPA Headquarters.
3. The attorney will then secure the warrant and forward it ta the
U.S. Marshall who will issue it to the owner/operator.
* Uoder no circuantances discuss potential penalties or do anything
which saay be construed as threatening*
** It should be stressed chat it is the policy of U.S. EPA to obtain a warrant
only whets all other efforts to gain lawful entry have been exhausted.
0-1
-------
08* of * H«rt«BC to Gain Entry
I. the iovestigator should a«v«r attempt Co eaeke any forceful estcy of Che
facility,
2. If eh«r* if * high probability chat entry will b« refused evta with a *
warrant of vh*ra there are threat* of violence, Eh* investigator should
b« aceoapaniad b* * U.S. Marshall,
3. tf *atry la refused to an investigator holding a warrant but not
•ecoBpaniad by a U.S. Harshall, th« lnv«*tig*cor ahould laavt the
facility and infora the U.S. EPA Offlca of Regional Counsai.
Use of a Warrant co Conduct the tnveatlgation
1. The lovasclgacion oust be conducted strictly in accordance with tha
warrant. II ch« warrant restricts tha investigation to c*rtain ar*aa
of ch« premises or to certain records, choaa reitrtction* «u*t be
followed.
2* If sapling is author Izad, all standard procedure* •use b* cartful iy
fallowed including presentation of r«c«ipts Cor all Jaapl«s taken. The
facility should also b* informed of its eight Co retain a portion of
the aaaplt? obtained by the investigator (split samples).
3. tf record* o? property are authorized to be taken, tha inv«i:igator must
provide receipts Co the owaer/oparator and wintain »n Inventory o£ all
removed fron th« premises.
4. to accordance with eh* varrant, th« inveatlgitor should take photograph*
of all araas wh*r« violacionn arc suspected. Photographs should alto
b« taken at each saapling location as a quality control procedure*
For further guidance regarding denial of facility access coosulc the national
Enforcement Investigation Cancer. (303) 236-5100
0-2
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APPENDIX E
PHYSICAL AND CHEMICAL
PARAMETERS FOR CONSTITUENTS
OF CONCERN
[THE ATTACHED HAS PREPARED BY ICF, INC., FOR THE
OFFICE OF EMERGENCY AMD REMEDIAL RESPONSE, EPA,
AMD FOUND IN "DRAFT SUPERFUND HEALTH ASSESSMENT
MANUAL", MAY 1985]
-------
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APPENDIX F
EXAMPLE DATA ELEMENTS FOR FACILITY PRIORITIZATION
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APPENDIX F
EXAHPLE DATA ELEMENTS FOR FACILITY PRIORITIZATION
1, What 1s the net recharge of tht facility area?
2. What Is the distance from the unit to the aquifer below the
unit"? If actual depth Is unknown, circle closest approxlma-
tlon of depth from ranges given below:
Feet: 0-5 5-10 10-30 30-50 50-75 75-100 100+
3, What 1s the slope of the surface topography within the
facility boundary? Circle closest approximation of slope
from ranges given below:
% Slope: 0-2 2-6 6-12 12-18 18+
4, How deep 1s the soil layer beneath the facility?
(Use soil references cited 1n RFI guidance.)
5. Is there a surface water body downgradlent that 1s within
two miles of the unit?
If yes, what 1s the distance hetwen the surface water body
and the unit?
6. For land disposal facilities (that should have Information
on hydraulic conductivity* hydraulic gradient, and effective
porosity Included 1n their Part B permit applications),
calculate the time of travel (TOT) to the *ac1!1ty boundary
and the nearest drinking water well downgradl ent . Refer to:
C r 1 1 er1a for Identl f Areas of Vu 1 ner&le
_
ffli F 1 na^JJune iS; the t' 1 me of" Tri v el c a uaton
was developed by the U.S. EPA Office of Solid Haste as &
tool to be used 1n assessl ng the vulntrabfl 1 ty of^ground
water 1n different hydrogaol og1 c settings.
The following steps should be completed when calculating TOT
a) What is the calculated or average velocity (V) of ground'
water flow below the facility? (Refer to criteria dtyd
above. )
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b) What 1s the distance to:
1} facility boundary?
2) nearest downgradient drinking water well(s)?
What 1s the TOT for:
1) time tu facility boundary?
2) time to nearest downgradient drinking water well(s)?
(Rtfer to Criteria cited above.)
7. F_gp_ facilities other than land disposal facilities, facilities
located on karst terrain or fractured bedrock:
If a rapid ground water velocity Is suspected, collect data
on hydraulic gradient, hydraulic conductivity, and effective
porosity in order to calculate TOT from the unit to 1)
facility boundary and 2} nearest drinking water well.
8, WhaJ^ is/are the waste constituent (s) of concern? If unknown,
provide available information on the following aspects of
the waste to allow reasonable Inferences to be drawn on what
constituents are present.
a) Suspected classes of compounds (e.g., organic solvents,
inorganics , etc.);
b) Waste streams {e.g., pickle liquor);
c) Manufacturing proeess(es) s*hich produced waste.
9. Are there any active production wells near the unit or
7a~c"l lity? If yes:
a) What is the distance between the unit and the production
wel1(s)?
b) What 1s the production capacity of the well(s)?
c) How old is the unlt(s)?
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join MI
DOCUMCHTATON
PAGE
MO.
Oclobcr. 1986
KCRA Facility Assessment Guidance
Me
ll. c«-«r»ctfC) x
rci
fOl
IX.
Office of Solid Uaste/F.PA
401 M ;it n-et , S.W.
Washington, D.C. 20460
II.
14.
it. *«»»rwci aim* »oo MT«» FJU-j j (t [ c s wliifti m.inagf ha z a r don s w;isU's ;irc ri-r,uiroo lo obtain '[
pi-rmlts undL-r the Ri'sourco Const-rvnt ion nnd Rocovi-ry Act (RCKA) of 1976. This guid.1ni.-i-
document informs RCRA pormit writors nnd c>nf orn-mont officials of prot fdurt-s tc bo used in
conducting RCRA Facility Assessments. The RCRA Facility Assessment is the first stiip 0!
the- corrective action process authorised hy Sections 300i(u), BOO^U'), and 300^ (lO of RIKA
as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1934.
The RCRA corrective action program was established to investigate and
require clean up of releases of hazardous wastes or constituents to the environment .it
facilities subject to RCRA permits. Releases to ground water, surface water, air, soil,
and subsurface strata may be addressed. Contamin.it ion from RCRA facilities which has
migrated beyond the facility boundary may also be addressed. When facilities not being
reviewed immediatel' ror issuance of a permit are found to have releases of concern, the
releases may be addressed thronf,'-! the enforcement authority of Section 3008(h).
17. Document An*ly*l* •.
T.rmt
e- CO*ATI
IL
It.
CUM rr*ii
CiM« n>'« **r*'i
.y.. f v- ••/
tl. Ho 91
ir
172 l*-»7]
NTIJ-JJ)
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